ML12076A014

Request for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC No. ME7493) Grand Gulf LRA Draft RAI Set 5

ML12076A014
Person / Time
Site:	Grand Gulf
Issue date:	04/16/2012
From:	Ferrer N License Renewal Projects Branch 1
To:	Mike Perito Entergy Operations
Ferrer N
References
TAC ME7493
Download: ML12076A014 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 16,2012 Mr. Michael Perito Vice President, Site Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO. ME7493)

Dear Mr. Perito:

By letter dated October 28, 2011, Entergy Operations, Inc. submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license for Grand Gulf Nuclear Station, Unit 1 (GGNS) for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Jeff Seiter, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1045 or e-mail nathaniel.ferrer@nrc.gov.

Sincerely, Nathaniel Ferrer, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50- 416

Enclosure:

Requests for Additional Information cc w/encl: Listserv

GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION SET 5 RAI8.1.2-1 Background. During the staff's walkdown of the stainless steel condensate storage tank, extensive rust stains (i.e., encompassing 360 degrees around the tank) were noted. These rust stains appear to originate from the tank roof to shell weld. The applicant could not state the cause of the rust stains on this stainless steel tank.

Issue. The impact of corrosion on managing aging of the tank is not certain without understanding the cause of the observed rust stains.

Request.

a. State the cause of the rust stains on the side of the condensate storage tank.

b. State the basis for why the cause of the rust stains does not indicate the presence of an aging effect that would require a different methodology for managing aging of the tank, or propose an alternative to the inspection program contained in the Aboveground Metallic Tanks Program.

RAI8.1.2-2 Background. Based on the staff's review of plant-specific operating experience related to the fire water storage tanks, there are a considerable number of condition reports identifying rust stains, coating damage and holidays on the bottom of the tanks. These adverse conditions were identified during inspections conducted in 2002, 2006, 2007, 2008, and 2009. In addition, during its walkdown, the staff noted several locations on both tanks where the top edge of the sealant between the tank and tank foundation had separated from the tank surface. These gaps could allow water to enter between the tank bottom and foundation.

Issue. Given the extensive number of adverse conditions identified and the span of years in which they were discovered, and the seal degradation noted during the walkdown, it is not clear to the staff that one volumetric inspection of the tank bottom within five years of the period of extended operation and then whenever the tank is drained is sufficient to manage the aging of the fire water storage tanks. The staff noted that the applicant has not stated in its License Renewal Application (LRA) or Updated Final Safety Analysis Report (UFSAR) supplement, for the Aboveground Metallic Tanks Program, how often the tanks will be drained and inspected.

Request. State the basis for why one volumetric inspection of the tank bottom within five years of the period of extended operation and then whenever the tank is drained is sufficient to manage the aging of the fire water storage tanks. If the basis includes the frequency of periodic draining and inspection of the tank, ensure this frequency is reflected in the Aboveground Metallic Tanks Program and UFSAR supplement. Alternatively, propose another means to manage the aging of the bottom surface of the fire water storage tanks.

ENCLOSURE

-2 RAI8.1.2-3 Background. The applicant's staff Identified that the condensate storage tank base seal was leaking in December 2010. The work order to correct this adverse condition is currently not scheduled to be completed until May 2013.

Issue. Given the span of time during which the tank is susceptible to corrosion due to this leaking seal, it is not clear to the staff that one volumetric inspection of the tank bottom within five years of the period of extended operation and then whenever the tank is drained is sufficient to manage the aging of the condensate storage tank.

Request. State the basis for why one volumetric inspection of the tank bottom within five years of the period of extended operation and then whenever the tank is drained is sufficient to manage the aging of the condensate storage tank. If the basis includes the frequency of periodic drain and inspections of the tank, ensure this frequency is reflected in the Aboveground Metallic Tanks Program and UFSAR supplement. Alternatively, propose another means to age manage the bottom surface of the condensate storage tank.

RAI8.1.5-1 Background. The "scope of program" program element of the Buried Piping and Tanks Inspection Program states it will manage aging for buried and underground piping; however, the External Surfaces Monitoring Program states an enhancement to its "detection of aging effects" program element to include underground components within the scope of the program. In addition, during the audit, the staff reviewed a partial list of components which appear to be under the scope of the External Surfaces Monitoring program instead of the Buried Piping and Tanks Inspection Program such as, the RHR pump suction barrels, HPCS pump suction barrels, fuel oil transfer pump discharge stop check valve. The GALL Report recommends that underground components be managed by GALL Report AMP XI.M41 , "Buried and Underground Piping and Tanks" program which includes recommendations such as protective coatings, inspection locations based on risk, expansion of scope specificity for adverse conditions, etc.

that are not included in the External Surfaces Monitoring program.

Issue. It is not clear to the staff that underground piping components will be age managed according to the recommendations of GALL Report AMP XI.M41 or XI.M36.

Request.

a. Provide a list of all underground (i.e., below grade but contained within a tunnel or vault such that they are in contact with air and are located where access for inspection is restricted) components within the scope of license renewal.

b. State which aging management program will be utilized to manage the aging of these underground components within the scope of license renewal.

c. If a program other than Buried Piping and Tanks Inspection Program will be used to manage the aging of any of the underground components, state which recommendations contained in GALL Report AMP XI.M41 will not be met and provide justification for not meeting those recommendations.

- 3 RAI B.1.5-2 Background. The "preventive actions" program element of the Buried Piping and Tanks Inspection Program states that the preventive actions of the program will be consistent with GALL Report AMP XI.M41; however, CR-GGN-2006-00727 stated that the Division II diesel fuel oil storage tank coatings had anomalies. GALL Report AMP XI.M41 , "Buried and Underground Piping and Tanks," recommends that coatings are in accordance with Section 3.4 of NACE RP0285-2002.

Issue. It is not clear to the staff if these anomalies result in the coatings not meeting the recommendations of GALL Report AMP XI.M41 , and therefore should be stated as an exception and justified by the applicant.

Request. State whether the coating anomalies described in CR-GGN-2006-00727 were corrected. If not, state whether these anomalies are such that the coatings will not meet the requirements of NACE RP0285-2002, Section 3.4. If the coatings do not meet NACE RP0285 2002, Section 3.4, state the basis for why there is a reasonable assurance that the tanks will meet their current licensing basis function(s) throughout the period of extended operation.

RAI B.1.5-3 Background. The "preventive actions" program element of the Buried Piping and Tanks Inspection Program states that the preventive actions of the program will be consistent with GALL Report AMP XI.M41; however, during its audit the staff identified six condition reports spanning 2006 through 2011, citing significant gaps in cathodic protection system performance.

GALL Report AMP XI.M41 recommends that a cathodic protection be installed, monitored, annually tested, and potential differences and current measurements be trended to identify changes in the effectiveness of the system.

Issue. The plant-specific operating experience is not consistent with GALL Report AMP XI.M41 recommendations because it demonstrates a long period of significant degraded performance of the cathodic protection system. This issue also impacts the consistency of the "monitoring and trending" program element.

Request. Revise LRA Section A 1.5, Buried Piping and Tanks Inspection Program to include a summary description related to cathodic protection being provided for in-scope buried piping and tanks that includes the standards that will be used for monitoring, and the frequency of monitoring and trending, or justify why this information should not be included in the UFSAR supplement.

RAI B.1.5-4 Background. The "preventive actions" program element of the Buried Piping and Tanks Inspection Program states that the preventive actions of the program will be consistent with GALL Report AMP XI.M41. GALL Report AMP XI.M41 recommends that protective coatings be provided (stainless steel piping is not required to be coated if soil conditions will not degrade the external surfaces of the piping) and backfill be consistent with SP0169-2007 and RP0285-2002.

-4 Issue. During its audit the staff could not verify that (a) steel in-scope systems were coated, (b) initial backfill specifications were consistent with recommendations in GALL Report AMP XLM41, and (c) in-scope stainless steel components were coated, or if they had not been coated, were sufficient soil samples obtained that demonstrated that the soil environment would not result in aging of the external surfaces of the piping.

Request.

a. State whether buried in-scope steel piping components and tanks are coated and what coating material was utilized.

b. Describe the specifications for initial backfill in the vicinity of buried in-scope piping components and tanks

c. State if buried in-scope stainless steel components were coated; or if they had not been coated, that sufficient soil samples were obtained to demonstrate that the soil environment would not result in aging of the external surfaces of the piping. If they are coated, state the coating material that was utilized. If the stainless steel components are not coated and soil sampling results are not available or acceptable, state the basis for why there is a reasonable assurance that the piping will meet its current licensing basis function(s) throughout the period of extended operation.

RAI8.1.5-5 Background. The "detection of aging effects" program element of the Buried Piping and Tanks Inspection Program, states the detection of aging effects of the program will be consistent with the GALL Report; however, procedure EN-DC-343, "Underground Piping and Tanks Inspection and Monitoring Program," Section 5.[1], states that, "[i]n general, inspections should be performed at the segments that have the highest risk ranking as determined above." The GALL Report AMP XI.M41 recommends that buried and underground piping inspection locations are selected based on risk.

Issue. It is not clear that the "in general" and "should be" modifiers in EI\I-DC-343 are consistent with GALL Report AMP XI.M41 because they could lead to lower risk inspection locations being selected based on criteria that was not presented to the staff.

Request. State how the selection of inspection locations for the Buried Piping and Tanks Inspection Program will be consistent with GALL Report AMP XI.M41.

RAI8.1.5-6 Background. The "acceptance criteria" program element of the Buried Piping and Tanks Inspection Program, states the acceptance criteria of the program will be consistent with the GALL Report. During the audit, the staff reviewed report 0900596-2, "Grand Gulf Nuclear Power Station Native and Interrupted APEC Survey," Revision 1, dated 04/14/2010. This report demonstrated that 93 percent of the in-scope buried piping was receiving adequate cathodic protection; however, the only acceptance criterion was a 100 mV of cathodic polarization of the piping and soil potential. GALL Report AMP XI.M41 recommends that the criteria for pipe-to-soil potential be consistent with NACE SP0169-2007 for which paragraph 6.2.2.3.3

-5 states that use of excessive polarization potential can result in coating disbondment. In addition, NACE SP0169-2007 paragraph 6.2.2.3.4 states, "Polarized potentials that result in excessive generation of hydrogen should be avoided on all metals, particularly higher strength steel, certain grades of stainless steel, titanium, aluminum alloys, and prestressed concrete pipe."

Issue. The staff could not verify if the cathodic protection criterion used by the applicant would not lead to pipe-to-soil potentials more negative than -1200 mV vs. CU/CUS04 reference electrode. In addition, given that in-scope piping is within a mixed metal environment, the staff lacks sufficient information to conclude that the singular 100 mV of cathodic polarization criterion is sufficient to establish that adequate cathodic protection has been applied.

Request.

a. In regard to acceptance criteria for pipe-to-soil potentials, state the maximum negative potential that will be accepted for steel and stainless steel buried in-scope components.

If as-left pipe-to-soil potentials are more negative than -1200mV vs. CuI CUS04 reference electrode, state why there is a reasonable assurance that the piping will meet its current license basis function(s} throughout the period of extended operation.

b. State the basis for the conclusion that the singular 100 mV of cathodic polarization criterion is sufficient to ensure that the most active buried in-scope piping material has achieved a 100 mV polarization.

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION, LICENSE RENEWAL APPLICATION DISTRIBUTION:

HARD COPY:

DLR RF E*MAIL:

PUBLIC [or NON-PUBLIC, if applicable]

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Mr. Michael Perito Vice President, Site Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO. ME7493)

Dear Mr. Perito:

By letter dated October 28, 2011, Entergy Operations, Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license for Grand Gulf Nuclear Station, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff).

The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Jeff Seiter, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1045 or e-mail nathaniel. ferrer@nrc.gov.

Sincerely, IRA!

Nathaniel Ferrer, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50- 416

Enclosure:

Requests for Additional Information cc w/encl: Listserv DISTRIBUTION: See following pages ADAMS Accession No ..'ML12076a014 OFFICE LA:RPB1 :DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds NFerrer wledits DMorey NFerrer DATE 03/23/12 04/11/12 04/13/12 116/12 OFFICIAL RECORD COpy