ML12060A112

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Environmental Site Audit Regarding Grand Gulf Nuclear Station, Unit 1
ML12060A112
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 03/22/2012
From: David Drucker
License Renewal Projects Branch 2
To: Mike Perito
Entergy Operations
Drucker D, 415-6223
References
TAC ME7385, TAC ME7386
Download: ML12060A112 (15)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 22, 2012 Mr. Michael Perito Vice President, Site Grand Gulf Nuclear Station Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT REGARDING GRAND GULF NUCLEAR STATION, UNIT 1 (TAC NOS. ME7385 AND ME7386)

Dear Mr. Perito:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the Entergy Operations, Inc.,

license renewal application for Grand Gulf Nuclear Station, Unit 1 (GGNS). The environmental site audit will be conducted at GGNS during the week of March 26, 2012, by NRC and its contractors. The environmental audit activities will be conducted in accordance with the environmental audit plan (Enclosure 1).

To develop the Supplemental Environmental Impact Statement, the NRC staff requests the information described in the environmental audit needs list (Enclosure 2) be made available, to the extent possible, during the environmental site audit. A draft schedule of tours and meetings for the audit is also provided (Enclosure 3). The NRC staff informally transmitted this information to your staff (Rick Buckley), bye-mail on February 23, 2012.

If you have any questions, please contact me by telephone at 301-415-6223 or by e-mail at David.Drucker@nrc.gov.

Sincerely, David Drucker, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

As stated cc w/encls: Listserv

LICENSE RENEWAL ENVIRONMENTAL AUDIT PLAN GRAND GULF NUCLEAR STATION

1. Background

By letter dated October 28, 2011, Entergy Operations, Inc. (Entergy or applicant), submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Grand Gulf Nuclear Station, Unit 1 (GGNS), operating license NPF-29. The staff is reviewing the information contained in the environmental report (ER) of the license renewal application (LRA) per Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54).

During the staff's review, an environmental audit is conducted at the GGNS site. This audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of the licensing or regulatory decision.

Specifically, the NRC staff will identify pertinent environmental data, review the facility and area, and obtain clarifications regarding information provided in the ER.

Per NRC guidance, the NRC staff prepares a regulatory audit plan that provides a clear overview of audit activities and scope, team assignments, and schedule.

2. Environmental Audit Bases License renewal requirements are specified in 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." Licensees are required by 10 CFR 54.23 to submit an ER that complies with the requirements in 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions," as part of the LRA.

Review guidance for the staff is provided in NUREG-1555, "Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License RenewaL" NRC staff is required to prepare a site-specific supplement to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants." During the scoping process required in 10 CFR Part 51, NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.

3. Environmental Audit Scope The scope of this environmental audit for the GGNS license renewal review is to identify those issues which are significant and those issues which can be eliminated from further study and to identify the environmental resources that must be adequately described and evaluated in the site-specific supplemental Environmental Impact Statement. Audit team members will focus on reviewing the documents and requested information listed in the GGNS Environmental Audit Needs List (Enclosure 2) and discussing the information with the applicant's subject matter experts.
4. Information and Other Material Necessary for the Environmental Audit As described in the Site Audit Needs List (Enclosure 2).

ENCLOSURE 1

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5. Tentative Team Assignments Area of Review Assigned Auditor The environmental audit team members and their specific discipline assignments are shown in Table 1. Those members of the team who are contractors from Argonne National Laboratory will have ANL after their name. Those members of the team who are contractors from The Center for Nuclear Waste Regulatory Analyses will have CNWRA after their name. Those members of the team who are contractors from Pacific Northwest National Laboratory will have PNNL after their name.

Table 1 Environmental Audit Team Members and Resource Assignments Environmental Project Manager Aquatic Michelle Moser, NRC Terrestrial Briana Balsam, NRC I~~-----~----------~---------------+~ ---------__

Bill Ford, NRC Hydrology John Quinn, ANL Elaine Keegan*, NRC Air/Meteorology Young-Soo Chang, ANL

~*-*~----------------~------************-------I Jeffrey Rikhoff*, NRC Socioeconomic Dave Anderson*, PNNL Jeffrey Rikhoff*, NRC Land Use Dave Anderson*, PNNL r---------------------------------------+-------

l Emily Larson, NRC Cultural Resources Konnie Wescott, ANL W~ste r..1a-"agel11~ent____- ____ -- Elaine Keegan', NRC

_~Ite~n~~~::_s_____.. _____ ~______________ Michelle Moser, NRC

. Jerry Dozier, NRC I SAMA Roland Benke, CNWRA

________________________~ Bob Schmidt, CNW_R_A _______ - - - - - 1

  • Will not atterld environmental site audit~ut may pa~icipate via conference call.
6. Logistics The environmental audit will be conducted at GGNS from March 27 - 29, 2012. An entrance meeting will be held with plant management at the beginning of the audit. An exit meeting will be held at the end of this audit.

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7. Special Requests The staff requests the applicant make available the information identified on the Environmental Audit Needs List (Enclosure 2). Plant staff who are subject matter experts in the disciplines listed on the Environmental Site Audit Needs List should be available for interviews and to provide tours which have been identified on the Environmental Audit Schedule (Enclosure 3).
8. Deliverables An audit summary report is scheduled to be issued by NRC staff within 90 days from the end of the environmental audit.

GRAND GULF NUCLEAR STATION, UNIT 1 LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT NEEDS LIST The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Appendix E, the Environmental Report (ER), of the Grand Gulf Nuclear Station, Unit 1 (GGNS), license renewal application (LRA).

Please be prepared to discuss the following issues and make the following available during the environmental site audit.

Air Quality/Meteorology

1. Provide a description of the general climate and local meteorology around the Grand Gulf Nuclear Station (GGNS) (e.g., annual and seasonal wind speeds and prevailing wind direction); and most recent five-year onsite meteorological data (years with more than 90%

data recovery rate) along with data documentation (e.g., data format, units) or wind roses along with stability class distributions.

2. Provide historic severe weather events and facility interruption/shutdown/damages to the site or nearby areas, including tornadoes, hurricanes, and other extreme weather (e.g., hail, thunderstorms).
3. Provide a knowledgeable individual to discuss the following aspects of meteorological data acquisition and management:
  • Type of instruments and instrument heights along with schematic diagrams of primary and backup meteorological monitoring system(s) from meteorological tower(s} to computer display
  • Meteorological data transmission system operating procedures
  • Procedures for calibration and maintenance of on-site meteorological instruments
  • Procedures for collection, evaluation, validation, and management of meteorological data, including quality control procedures
  • Procedures for reconciling any data anomalies and for dealing with periods when no data are collected
4. Provide copies of relevant sections and correspondence with the Mississippi Department of Environmental Quality or Claiborne County relating to:
  • Air emissions inventory for criteria and hazardous air pollutants for the most recent five years
5. Provide a knowledgeable individual to discuss the following aspects of facility operation:
  • Details of stationary and mobile sources of criteria and hazardous air pollutants operating on GGNS, including, as appropriate, horsepower ratings, fuel consumption, pollution control equipment and its control efficiency, operating records, etc.
  • Details on the preventative maintenance schedules for emergency generators and other internal combustion engine sources on GGNS (e.g., emergency fire water pumps)

ENCLOSURE 2

2

  • Results of any air pollution control equipment tests/performance evaluations conducted for stationary sources of criteria pollutants
  • Details on the type of ozone depleting substances (ODSs) used on GGNS and the procedures in place for maintenance and repair of HVAC equipment, including HVAC systems that may be contaminated with airborne radioactive species
  • General specifications for the natural-draft cooling tower and auxiliary cooling tower such as dimensions, operating hours per year, air and water flow rates, drift loss rate, total dissolved solids concentration, heat rejection rate, drift droplet diameter, etc.
  • Information on the chemicals used in the cooling water system and any reported property/crop damage
6. Are there expected upgrade/replacemenUretirement activities for facility equipment/operation listed in Item 5 that could increase or decrease air emissions over the license renewal period?
7. Provide the most recent five-year site-wide emission inventory data (annual) for greenhouse gases (GHGs):
  • Include emissions from all stationary combustion sources, mobile sources (including commuters, visitors, support, and delivery vehicles), and other sources
  • If no GHG emission data are available, provide data to estimate GHG emissions, e.g.,

y Combustion sources along with capacity, activity level (e.g., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per year), fuel type, fuel consumption rates y Mobile sources along with number of vehicles, average daily trips, vehicle type, travel distance per trip y Other sources (e.g., landfill, water reclamation facility, leakage of refrigerant), if any Meetings requested with the applicant staff in charge of the following:

  • meteorological towers and meteorological data
  • air permits and emission inventories
  • equipment operation and maintenance Tours Requested:
  • General site tour - site land cover/buildings/structures, site boundaries, and nearby sensitive receptors (e.g., residences, schools)
  • Primary air emission sources (e.g., boilers, emergency generators, paint booths, cooling towers, storage tanks, water reclamation facility) and control equipment
  • Onsite meteorological towers (primary and backup)

Alternatives

1. Describe the data sources used to estimate the land requirement for the wind energy/compressed air energy system (CAES) alternative. Clarify whether the land requirement estimates include land for new transmission lines. Describe the potential or

-3 probable locations of wind farms and CAES facilities that would comprise this alternative, Provide a description of the CAES components, including the mechanism by which they would generate power, whether they would rely on engineered or geologic storage and the engineering feasibility and environmental impacts that would be associated with such technology configurations.

2. Describe the data sources used to support the conclusion that purchased power is not a reasonable alternative.

3, Describe the data sources used to support the conclusion that the utility-sponsored demand-side management is not a reasonable alternative, 4, Describe any current utility-sponsored energy conservation programs,

5. Describe the data sources used to determine the availability and reliability of biomass fuel supplies and conservation for the combination alternative.

Aquatic Ecology 1, Describe surveys of onsite aquatic resources that Entergy has completed since 1973, other than the reconnaissance level surveys in 2005 and mussel surveys in 2008, 2, Describe any studies examining the impacts of the discharges to the Mississippi River (e.g.,

extent of thermal plume).

3. Describe the potentiallocation(s) of the crystal darter (Crystal/aria asprel/a) , sicklefin chub (Macrhybopsis meekl), chestnut lamprey (lchthyomyzon castaneus), black buffalo (Ictiobus nigef) , paddlefish (Polyodon spathula), and blue sucker (Cycleptus elongates) on the GGNS site.
4. Describe the potentiallocation(s) of rabbitsfoot mussel (Epitheca spinosa) within the vicinity (6-mi) of GGNS.

Cultural Resources

1. A map detailing the level of ground disturbance at the plant, including documentation on how this level of disturbance was determined. Has this understanding of the level of disturbance been coordinated with the Mississippi State Historic Preservation Officer (MS SHPO)? [In other words is the MS SHPO in agreement that these portions of the plant have been disturbed sufficiently as to preclude the possibility of any significant archaeological resources existing in these areas, including the potential for burials? This may be available in documentation supporting the recent GGNS Unit 3 COLA].

2, A series of aerial photographs of the entire plant site and associated transmission line(s)

(during pre-construction, construction, and post-construction periods) looking at levels of disturbance that occurred during construction or since operation, whether any historic structures or possible sites are present on the property, and identifying any recent projects that will require a review of additional documentation,

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3. U.S. Geological Survey (USGS) 7.S minute topographic quadrangle maps of the plant and associated transmission lines with plant boundaries and transmission lines highlighted.

(These hard copy maps will be taken to and discussed with the MS SHPO, the maps requested are not the Generic Environmental Impact Statement maps with underlying topographic data - actual USGS-named quad sheets are needed.).

4. Vegetation/land-use maps of the plant and associated transmission line(s).

S. Maps of ownership and land use of the applicant's property and associated transmission lines. Copies of historic plat maps would be useful, if available.

6. Applicant's Environmental Compliance Manual and any other environmental review procedures for land-disturbing activities (e.g., trenching, clearing, digging). The environmental report (ER) mentions the Entergy 2008 nuclear fleet procedure EN-ENV-121 for managing cultural resources. Also, is there anything specific to the cultural resources present at GGNS?
7. Applicant's transmission line management plan, including: timing of activities; danger tree removal and other clearing; inspections and repair activities conducted by ground vehicles; standard operating procedures or guidelines for the applicant and any contractors; erosion control procedures; technician training programs; and any regulations that restrict maintenance activities (e.g., looking for activities that could affect depth of disturbance, if any disturbance is necessary along the corridor). (The main interest here is in management procedures for the site and associated transmission line(s), specifically special procedures to avoid impacts to historic and archaeological resources.) ER references a Transmission Management Manual, AM-ERS-FAC-001, which may have what is needed regarding transmission.
8. Information on management around less-developed areas of the plant site, especially near known historic and archaeological resources or near unsurveyed areas, if applicable.
9. Documentation of construction projects that have occurred on the property since the construction of GGNS to determine how historic and archaeological resources were considered. Any documentation demonstrating compliance with existing environmental procedures would be useful. What materials are used by the applicant's staff to determine whether the SHPO should be consulted? Copies of surveyor mitigation reports performed in conjunction with the plant or transmission line(s), or for other/subsequent plant activities (e.g., the Grand Gulf to Port Gibson Railroad, Grand Gulf Mound).
10. References presented in ER, especially survey reports and citations specified in Enercon 2010 (Phase 1A Literature Review and Archaeological Sensitivity Assessment of the GGNS). Maps of site and survey locations at GGNS will be needed during the site visit these maps will not be docketed, as they are considered sensitive information.
11. Verify if geomorphological work was conducted for the archaeological surveys to determine the depth of deposits and how deep archaeological remains may be present

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12. Consultation letters and other documentation indicating correspondence to and from the SHPO and Federally-recognized Native American Tribes that have aboriginal ties to the project area and surrounding lands. This would include relevant correspondence in addition to what is provided in the ER to and from the MS SHPO, NPS, and Tribes (e.g., Choctaw Nation response). Has any contact been made with local historical societies or other local organizations with an interest in historic preservation?
13. Information regarding the land transfer by GGNS to the Grand Gulf Military Monument Park.
14. Additional information about the potential sharecropper sites on the property (Sites 22CB824 and 22CB827).
15. Detailed information about the potentially eligible archaeological site within the GGNS site property boundary, Site 22CB528.
16. Information about the Callendar House, even though the structure is no longer standing.
17. Information on whether the GGNS is visible from any of the NRHP-listed (and eligible) historic properties presented in the ER Meetings requested:
1. Meeting with applicant staff and member of the grounds maintenance team to go over environmental compliance procedures to determine how they manage resources, avoid impacting historic and archaeological resources, and deal with inadvertent discovery of historic and archaeological materials and human remains. Is any cultural resource training required for staff? Based on references in the ER, this will likely include discussion of fleet procedures EN-EV-115 and EN-EV-121 and any other manuals or procedures specific to environmental compliance at GGNS.
2. Meeting with applicant staff and transmission line maintenance contractor to discuss right-of way maintenance and monitoring and any procedures in place regarding protection of historic properties along transmission line corridors. Based on references in the ER, this would include at a minimum AM-ERS-FAC-001 on the Entergy Transmission Vegetation Management Program.

Tours requested:

1. General site tour
2. Transmission line tour (including any archaeological sites recorded along the lines).
3. Archaeological site tour and tour of any adjacent areas of historical or cultural interest (Grand Gulf Military Monument), preferably led by an archaeologist. The ER indicated

- 6 18 sites have been documented on the GGNS property, but the historic/prehistoric distribution of the sites is unclear. It is also unclear which sites are still present.

Hydrology

1. Specific information for groundwater radial wells, including locations, designs, depths, and yields (and well logs, if available). Include information on wells that are currently inactive or installed but not yet operational. Also include any studies assessing groundwater drawdown (and related impacts) as a result of the facility's use of Ranney wells.
2. Permits for all on-site wells, including those that are currently inactive, new wells, domestic wells, and monitoring wells; and all related monitoring reports for the past five years. Please also include information on the Groundwater Protection Initiative and related site characterization and monitoring reports dating back to its inception at the GGNS (in 2007) to the present. Also, provide a description of what other measures (permits, best management practices, or monitoring protocols) are in place to protect groundwater quality.
3. Permits for all surface water intakes and discharges, including surface impoundments, and related (i.e., required) monitoring reports submitted to the state for the past five years. This should include a complete version of the current National Pollutant Discharge Elimination System (NPDES) permit (MS0029521) and any accompanying maps showing outfalls, monitoring locations, or other relevant site features. Also include any applications for NPDES permit renewal, if one has been submitted.
4. Any permits related to stormwater (if separate from NPDES permit) and storm management plan. If no plan exists, provide a listing of best management practices used by the facility to control stormwater.
5. From the past five years, any release notifications or violation information (e.g., Notice of Violations) associated with surface water discharges, septic or sewage systems, and groundwater or soil contamination (including spills, leaks, and other releases).
6. From the past five years, documentation related to any remedial (cleanup) activities at the GGNS.
7. Any environmental site assessments or hydrological studies (aquifer tests etc.) conducted onsite since the facility was built.
8. Status of the EPU scheduled for 2012.
9. Any studies conducted to evaluate thermal discharge to the Mississippi River and thermal monitoring reports.
10. All references cited in the ER pertaining to hydrology or the facility's water-related systems (cooling, fire protection, plant service, waste etc.).

-7 Meetings Requested:

Meeting with applicant staff who are familiar with the facility's cooling water system, as well as stormwater management system, fire protection system, plant service water system, standby service water system, evaporation ponds (if any), underground infrastructure (piping and tanks),

waste systems (radwaste and nonradwaste; liquids and solids; wet and dry), sanitary waste treatment facility, and the requirements and reporting for various monitoring programs (e.g.,

tritium monitoring).

Groundwater Protection Initiative Discuss what is being learned from the "Site Groundwater Protection Initiative" that is part of the Nuclear Energy Institute (NEI) "Industry Ground Water Protection Initiative" Specifically:

1. The vertical hydrologic interconnectivity between the Loess, Upland Complex, and Catahoula Aquifers beneath the site.
2. The horizontal direction and if available, the rate of flow of groundwater flow in the Loess, Upland Complex, and Catahoula Aquifers beneath the site.
3. The vertical direction and if available, the rate of flow of groundwater in the Loess, Upland Complex, and Catahoula Aquifers beneath the site.
4. The water quality of the Loess, Upland Complex, and Catahoula Aquifers beneath the site.
5. The location of any radiological or non-radiological contaminants detected in groundwater underlying the site.
6. Confirm the aquifers that are supplying water the North Drinking Water Well, the South Drinking Water Well, and the North Construction Well.

Dewatering Wells The onsite dewatering wells are completed into what aquifers? What is their purpose (dry basements, prevent swampy conditions, etc? Why are they not being pumped?

Basements What aquifers are plant basements excavated into? Do the basements contain sump pumps to collect inflowing groundwater and if they do, have they been in use in the recent past?

CS&I Water Association #1 If known, what aquifers (Pascagoula, Hattiesburg, or Catahoula aquifers) in the Miocene Aquifer does the CS&I Water Association #1 obtain its water from?

-8 Industrial Chemicals That Might Contaminant Groundwater What types of liquid industrial chemicals (such as sulfuric acid, chlorine, etc.) are stored on site in significant quantities (inside tanks) that if their containers broke could flow into the groundwater?

Surface Water Use On page 4-20 of the ER it states that there are no known current offsite uses of groundwater from the Mississippi River Alluvium aquifer between the Big Black River to the north and the Bayou Pierre River to the south. Does this include both sides of the Mississippi River? Does it include wells in the State of Louisiana as well as the State of Mississippi? If alluvial aquifer wells exist, what is the use of the water (industrial, agriculture, domestic use)?

Within a reasonable distance from the plant (Le., that could be impacted) are there any Mississippi River surface water users in either the State of Louisiana or the State of Mississippi?

If so, what is the water being use for (industrial, agriculture, domestic use)?

Surface Water Discharges With the exception of storm-water runoff, does all water (sewage, air conditioning, etc.) water discharged by the site flow to the Mississippi River via the 54-inch pipe? If not where and how is it discharged?

Socioeconomics The following information is needed to assist the NRC in its socioeconomic impact review:

1. How long has GGNS been making current tax payments (Le., $20,000,000)? How long is this expected to continue?
2. Do you anticipate any changes in assessed property value or any payment adjustments that could result in notable increases or decreases in tax or other payments?
3. In addition to property tax payment information presented in Section 2.7 of the ER, please describe any other major annual support payments, one-time payments, and other forms of non-tax compensation (if any) provided to local organizations, communities, and jurisdictions (e.g., county, municipality, townships, villages, incorporated places, and school districts) on behalf of GGNS.

Environmental Justice Have any unique minority and/or low-income communities been identified in the vicinity of GGNS? If so, have representatives of these communities been approached by GGNS to determine if they could be affected by continued plant operations?

Terrestrial Ecology

1. Provide a copy of the Federal Migratory Bird Depredation Permit described on ER p. 2-64.

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2. Page ER 2-64 states that Entergy seeks to minimize the legal taking of migratory birds through various non-lethal control measures. Does Entergy maintain a program or written procedure for migratory bird management? If so, please provide a copy of this document for review.
3. Provide a copy of the black bear habitat assessment described on ER Page 2-68.

Transmission Lines

1. Would Entergy Mississippi, Inc. (EMI) continue to use the 500-kV line that spans from the GGNS Unit 1 Turbine Building to the switchyard in the absence of GGNS operating?
2. Do you have any documentation of the partnership with the National Wild Turkey Federation to maintain transmission line ROWs within Homochitto National Forest mentioned on ER Page 3-31?

Interviews Request:

1. Terrestrial Interview: Interview with knowledgeable staff person on terrestrial habitat and any outstanding questions from review of the site audit needs material.
2. T-line Interview: Interview with knowledgeable staff person that can describe transmission line maintenance and vegetation maintenance along ROWs.

Tours Request:

Terrestrial Tour: Tour representative habitat types on site that are mentioned in the ER (bottomland emergent wetlands, bottomland scrub-shrub, hardwood forests, and upland fields) and any other unique areas that may be of interest to the terrestrial review.

SAM A Provide the comprehensive list of 249 candidate SAMAs considered for implementation at GGNS provided in onsite documentation [Reference E,2-21]

See Attachment for specific questions to be addressed at the audit. Note that additional questions may be developed and provided several days before the audit.

Documents requested to be available for review:

Peer review report, summary of disposition of peer review Findings & Observations (F&Os), and documentation associated with expert panel reviews cited on page E,1-71 GGNS EPU submittal and RAI responses ORIGEN calculation documents MACCS2 calculation documents E.1-2 CALC-OC-N1 000-1 0002, "GGNS Level 3 Probabilistic Safety Analysis (PSA) Model"

- 10 Rev. O.

1-3 Grand Gulf Nuclear Station Development of Evacuation Time Estimates, KLD Associates, Inc., September 2007.

1-4 PRA-GG-01-003, Grand Gulf Power Station Detailed Level 2 Analysis, Revision 0, August 2010.

1-5 GGNS PRA-GG-01-001, "GGNS Level-1 Model Revision 3 PSA Summary Report,"

Rev. 2.

E.1-9 GGNS94-0053 IPEEE, "Internal Plant Examination of External Events Seismic Margins," Revision O.

1-15 GGNS95-00041, "Internal Plant Examination of External Events Fire," October 1996.

1-17 GGNS Calculation No. XC-N1111-01007, "GGNS Level 1 PSA," Revision 2, October 17, 2002.

1-18 GGNS Calculation No. PRA-GG-09-001, "Identification of Risk Implications due to Extended Power Uprate at Grand Gulf," May 2010.

E.2-21 CALC-OC-N1 000-1 0003, "Cost-Benefit Analysis of Severe Accident Mitigation Alternatives," Revision O.

SAMA Interview: Interview with knowledgeable staff person on SAMA and any outstanding questions from review of the site audit needs material. If different person than above, interview with knowledgeable staff on Level 1, 2 and 3 PRA development as well as SAMA identification and evaluation.

Tours: No specific tour needed for SAM A.

SAMA Audit Questions

1. Changes to the plant and PRA
  • E.1.1 states there have been no major plant changes since August 2006 that would have a significant impact on the results of the SAMA Analysis. Define "significant" and how this determination was made.
  • E.1.4 PSA Model Revisions and Peer Review Summary - provides a summary of the GGNS PSA Models CDF and LERF from 1992 - 2010. Section E.1.4.2 states that the update included plant changes through refueling outage 11, but does not specifically list these changes. What were the major changes (documented in GGNS calculation XC-N1111-01007 [E.1-17] and calculation PRA-GG-01-001 [E.1-5])?
  • E.1.4.3 states the last plant data update was through August 2006. Provide assurance that more current data would not adversely impact the SAMA analysis.

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2. PRA Level 1 results
  • In Section E.1.1 it is stated that the EPU model contains the major initiators leading to core damage with baseline CDFs listed in Table E.1-1. What is meant by "major?" Are any initiators left out of this table?
  • Table E.1-1 uses the term "Initiating Event Groups." Describe the meaning of "groups."

Are the initiating events modeled in the PRA grouped together for this table?

  • Table E.1-1 gives SBO CDF of 7.5E-07. Table E.1-7 gives 1E-6. Explain the difference.

Discuss other potential ISLOCA pathways.

  • Table E.1-1 gives only two internal flooding initiators both with very small contributions.

Also note that the Peer Review guidance utilized in the GGNS peer review did not include requirements for internal flooding. Describe the internal flooding analysis and the basis for assuring its technical adequacy.

  • P E.1-23 states that the ratio of the 95th percentile to the mean is about 2.38. Since the CDF and RC frequencies used are point estimates rather than means, what is the ratio of the 95th percentile to the point estimated CDF?
  • P. 1-70 states that the EPU increases the CDF to 2.91 E-06. This is different from that given elsewhere. Presumably this CDF is from the sum of Plant Damage Status (PDS)

(or core damage sequences) frequencies which could be higher due to the inctusion of non-minimal cut sets. What are the correct CDF values used and quoted throughout the SAMA submittal?

  • Identify the truncation limit used for the various PRA revisions and confirm that the value used in the SAMA analysis meets the appropriate ASME PRA standard supporting requirement.
3. Peer review results and PRA quality E.1.4.5 PSA Model Peer Review - provides summary of the scope of the BWROG peer review of the 1997 model and other reviews.
  • Section E.1.4.5 states that all of the 'B' priority comments have been addressed except for one documentation item related to the internal flood modeling. What was the documentation item? What is meant by addressed? Were any F&Os addressed by internal reviews that conctuded that changes to the model were not needed or the F&O was incorrect? If so discuss these F&Os.
  • Paragraph 2 mentions that the expert panel review of model quantification results resulted in modifications to the model and to the credit given for human actions. What were these modifications?

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  • Paragraph 3 mentions that an expert panel review of the preliminary cutsets for the EPU Level 2 PRA model development was performed. How was the model corrected and what were the lessons learned?
  • Discuss the process and procedures for assuring the technical quality of the PRA updates since the Peer review.
4. Level 2 model PRAIPSA
  • E.1.2 PSA Model- Level 2 Analysis - provides a summary of the Level 2 PSA model.

According to this section, the Level 2 model includes a deterministic analysis of the physical processes for a spectrum of severe accident progressions and a probabilistic analysis component in which the likelihood of the various outcomes are assessed. Level 2 analysis examines the dominant accident sequences and the resulting PDS as defined in the Level 1 analysis. Level 2 also consists of Containment Event Trees (CETs) with functional nodes that represent phenomenological events and containment protection system status.

  • Provide a history of the Level 2 PSA and any modeling changes that may have occurred to impact release category frequencies. Identify steps taken to insure its technical adequacy.
  • E.2.2.6 Process Used to Group the Source Terms - provides a summary of how a value for each release-to-environment mass fractions was obtained from the representative MAAP calculation per CET sequence. Table E.1-8 summarizes the results of the CET quantification and identifies total annual release frequency per Level 2 release category.
  • Provide further information on the assignment of release categories to each CET endpoint, the determination of the representative sequence for determining the release fractions and the weighting of release fractions discussed on page E.1-54. Discuss how this weighting impacts the evaluation of the benefit of a SAMA.
  • Identify and describe the representative sequences for each release category.
  • Section E.1.2 defines release category (RC) based on the magnitude of Csi release with High (H) being> 10%, M being between 1% and 10 %, etc. The release fractions given in Table E.1-9 are not necessarily consistent with these definitions. Also RC HIE frequency is given as the LERF yet the Cs release fraction is less than 10%. Discuss.
  • Figure 1-1 indicates that negligible releases (NCE or NCF - would appear to imply no containment failure) make up 44% of the total. Identify the CET end states that make up this release category. Note that NUREG-1150 would indicate this to be 23% (sum of no vessel breach and no containment failure from figure 6.4.)
  • Was the potential impact of the EPU on release timings and magnitudes on CET end point release category assignments considered?
5. Fire Risk Analysis E,1.3.2 says that Table E.1-1 0 presents the results of the current GGNS IPEEE fire analysis.

By "current" is it meant that the IPEEE analysis has been revised? If so discuss.

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6. Level 3 Consequence Analysis
  • E.1.5.2.1 Projected Total Population by Spatial Element - stated, "Louisiana and Mississippi state tourism data was used to calculate a transient to permanent population ratio to increase each county's projected population to account for visitors." Clarify how transient population was used in the SAMA analysis.
  • Table E.1-11 Estimated Population Distribution within a 50-Mile Radius - provides a breakdown of population distribution according to sectors. Describe how these figures were obtained, as there is no stated population growth rate for sectors.
  • Are any changes in future fuel management practices or fuel design planned or being considered that would impact the core fission product inventory given in Section E.1.5.2.8?
  • Confirm if the SECPOP2000 code was used in the SAMA analysis. If used, specify the version of the code.
  • Meteorological data from 2009 were selected for the analysis because they resulted in the highest release quantities. Describe the source of precipitation data, modeling of precipitation events, and precipitation influence on calculated doses.
  • Quantify the amount of missing meteorological data, which were estimated using data substitution.
  • Discuss elements in the core inventory (Table 1-12) that are not included the Level 3 analysis (Table E.1-9). How are the nuclides in the core inventory (Table E.1-12) and not in Table E.1-9 incorporated into the MACCS2 analysis?
7. SAMA list from NEI-05 E.2.1 SAMA List Compilation_- provides a summary of how the list of SAMA candidates was developed. NEI 05-01, Severe Accident Mitigation Alternatives Analysis, was one of the industry documents reviewed. Clarify whether any SAMAs were developed considering this list.
8. External Events Multiplier - Seismic Risk Section 4.21.5.4 states that seismic risk is negligible in the estimation of external events multiplier. An August 2010 report, "Generic Issue 199 (GI-199), Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants" shows a decrease in GGNS seismic CDF using 2008 United States Geological Survey (USGS) seismic hazards curve when compared against 1994 Lawrence Livermore National Lab Hazard Curves but an increase from that based on the EPRI hazard curves. Based on a simplified approach to estimate the core damage frequency from a seismic margins analysis and using the latest published USGS seismic hazards information, GGNS seismic CDF is about or slightly less than 1E-5/year. Discuss the impact of this on the SAMA analysis.
9. Cost benefit analysis and Site specific cost estimates
  • E.2.3 Final Screening and Cost Benefit Evaluation of SAMA Candidates (Phase II) states that these cost-estimates primarily came from existing estimates of similar modifications considered in previously performed SAMAs of other Nuclear Plants. There is also a list of the estimated cost range per change type found on Page E.2-3. In

- 14 Table E.2-2 some were indicated to be site-specific cost estimates. Describe the basis for the site-specific estimates and what is included and what is not included. The auditor may ask for detailed cost breakdown for a sample of SAMAs. Note also that the discussion of the basis for the cost estimates following the listing of cost ranges, unless specifically verified for the plants cited, may not be true for the cited plants. The content of SAMA cost estimate is highly variable from plant to plant.

  • E.2.3 also states that the benefit was determined by requantifying the PDS frequency.

Discuss how this was then used to determine the release category frequencies needed for the consequence analysis.

  • Provide the release category frequencies for each Phase II SAlVIA.
  • Additional questions are expected concerning the identification and evaluation of specific SAMAs as well as alternative lower cost SAMAs.

GGNS Environmental Site Audit Schedule Tuesday, 3127 10:15 am Site Entrance Meeting 11 :15 am Work area orientation Noon Lunch 1:00 pm General Site Tour SAMA references orientation 2:30 pm Aquatic, Terrestrial, Surface Water tour Air/Meteorology tour Cultural Resource tour 3:45pm Groundwater tour Air/Meteorology discussion Transmission line discussion Wednesday, 3128 9: 15 am Aquatic discussion Terrestrial discussion Cultural Resources discussion SAMA discussion 11:00 am Auditor research Noon Lunch 1:00 pm Hydrology discussion Socioeconomics/Environmental Justice discussion 1:30 pm Alternatives discussion Thursday, 3129 9: 15 am Grand Gulf Military Park tour SAMA discussion Noon Lunch 4:00 pm NRC Site Audit debrief ENCLOSURE 3

March 22, 2012 Mr. Michael Perito Vice President, Site Grand Gulf Nuclear Station Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT REGARDING GRAND GULF NUCLEAR STATION, UNIT 1 (TAC NOS. ME7385 AND ME7386)

Dear Mr. Perito:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the Entergy Operations, Inc.,

license renewal application for Grand Gulf Nuclear Station, Unit 1 (GGNS). The environmental site audit will be conducted at GGNS during the week of March 26, 2012, by NRC and its contractors. The environmental audit activities will be conducted in accordance with the environmental audit plan (Enclosure 1).

To develop the Supplemental Environmental Impact Statement, the NRC staff requests the information described in the environmental audit needs list (Enclosure 2) be made available, to the extent possible, during the environmental site audit. A draft schedule of tours and meetings for the audit is also provided (Enclosure 3). The NRC staff informally transmitted this information to your staff (Rick Buckley), bye-mail on February 23, 2012.

If you have any questions, please contact me by telephone at 301-415-6223 or by e-mail at David.Drucker@nrc.gov.

Sincerely, IRA!

David Drucker, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

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See next page ADAMS Accession No.: ML12060A.1,:,c1=2_ _

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i OFFICE I

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. BC:RERB:DLR BC:AADB:DRA I

NAME IKing DDrucker Almboden TTate DATE 3/16/2012 3/19/2012 3/20/2012 3/21/2012

, OFFICE  ; BC:RPB2:DLR NAME DWrona DDrucker DATE 3/21/2012 3/22/2012 OFFICIAL AGENCY RECORD

Letter to M. Perito from D. Drucker dated March 22, 2012

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING GRAND GULF NUCLEAR STATION, UNIT 1 (TAC NOS. ME7385 AND ME7386)

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