ML121020375

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Redacted, Request for Additional Information, Nrr/De/Emcb Review of Steam Dryer, Round 7, Amendment Request for Extended Power Uprate to Increase the Maximum Reactor Core Power Operating Limit from 3898 to 4408 Mwt
ML121020375
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 04/18/2012
From: Wang A
Plant Licensing Branch IV
To:
Entergy Operations
Wang, A B, NRR/DORL/LPLIV, 415-1445
Shared Package
ML121020368 List:
References
TAC ME4679
Download: ML121020375 (11)


Text

OFFICIAL USE ONLY

  • PROPRIETARY INFORMATION t--\\

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 18, 2012 Vice President. Operations Entergy Operations. Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson. MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION FOR THE STEAM DRYER EVALUATION RE: EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST (TAC NO. ME4679)

Dear Sir or Madam:

By application dated September 8, 2010 (Reference 1). as supplemented by letters dated November 18, 2010 (Reference 2), November 23,2010 (Reference 3). February 23.2011 (four letters, References 4, 5. 6. and 7), March 9, 2011 (two letters, References 8) and 9, March 22, 2011 (Reference 10), March 30, 2011 (Reference 11), March 31.2011 (Reference 12). April 14, 2011 (Reference 13), April 21, 2011 (Reference 14), May 3,2011 (Reference 15), May 5,2011 (Reference 16), May 11, 2011 (Reference 17), June 8, 2011 (Reference 18), June 15, 2011 (Reference 19), June 21,2011 (Reference 20) June 23,2011 (Reference 21). July 6,2011 (Reference 22), July 28. 2011 (Reference 23), August 25, 2011 (Reference 24), August 29, 2011 (Reference 25), August 30, 2011 (Reference 26), September 2. 2011 (Reference 27).

September 9, 2011 (Reference 28), September 12, 2011 (Reference 29). September 15, 2011 (Reference 30), September 26,2011 (Reference 31). October 10, 2011 (two letters, References 32 and 33). October 24. 2011 (Reference 34), November 14, 2011 (Reference 35),

November 25,2011 (Reference 36), November 28,2011 (Reference 37). December 19, 2011 (Reference 38). February 6,2012 (Reference 39), February 15,2012 (Reference 40).

February 20,2012 (Reference 41), March 13,2012 (Reference 42), March 21, 2012 (Reference 43), and April 5, 2012 (Reference 44), Entergy Operations, Inc. (Entergy, the licensee), submitted a license amendment request for Grand Gulf Nuclear Station, Unit 1 (GGNS). Portions of the letters dated September 8 and November 23. 2010, and February 23, April 21, May 11, July 6. July 28, September 2. October 10. November 14, November 25. and November 28, 2011, and February 6, February 15, February 20. March 13, March 21, and April 5, 2012, contain sensitive unclassified non-safeguards information (proprietary) and,.

accordingly, have been withheld from public disclosure. The proposed amendment requests an increase in the maximum steady-state power level at GGNS from 3898 megawatts thermal (MWt) to 4408 MWt. This represents an approximate 13 percent Increase above the current licensed thermal power or an approximate 15 percent increase above the original licensed thermal power.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following additional information is needed for the NRC staff to complete our review of this amendment.

NOTICE: Enclosure 1 to this letter contains Proprietary Information. Upon separation from, this letter is DECONTROLLED.

OFFICIAL USE ONLY* PROPRIETARY INFORMATION 4'

OFFIOl;ltl USE ONl'l

  • PROPRIETARY INFORMATION

-2 This enclosed request for additional information (RAI) pertaining to the steam dryer evaluation was discussed with Mr. Jerry Burford of your staff on March 2B. 2012. and it was agreed that a response to the RAls would be provided by April 5, 2012. The NRC staff's proprietary version of the RAI is provided in Enclosure 1 and a nonproprietary version is provided in Enclosure 2. A list of references is provided in Enclosure 3.

If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1445 or via e-mail at Alan.Wang@nrc.gov.

Sincerely,

~~

/'

Alan B. Wang. pr:Q::ger Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

1. Request for Additional Information (proprietary)
2. Request for Additional Information (non-proprietary)
3. List of References cc w/Encl 2 and 3: Distribution via Listserv OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION

~

ENCLOSURE 2 (NON-PROPRIETARY)

REQUEST FOR ADDITIONALINFORMA TION STEAM DRYER EVALUATION GRAND GULF NUCLEAR STATION, UNIT NO.1 EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST ENTERGY OPERATIONS, INC, DOCKET NO. 50-416 OFFICIAb USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY

  • PROPRIETARY INFORMATION REQUEST FOR ADDITIONAL INFORMATION STEAM DRYER EVALUATION GRAND GULF NUCLEAR STATION. UNIT NO.1 EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST ENTERGY OPERATIONS, INC.

DOCKET NO. 50-416 By letter dated September 8, 2010, as supplemented (see Enclosure 3), Entergy Operations, Inc. (Entergy), submitted a license amendment request (LAR) for the Grand Gulf Nuclear Station, Unit No.1 (GGNS). The proposed amendment requests an increase in the maximum steady-state power level at GGNS from 3898 megawatts thermal (MWt) to 4408 MWt. This represents an approximate 13 percent increase above the current licensed thermal power or an approximate 15 percent increase above the original licensed thermal power.

The U.S. Nuclear Regulatory Commission (NRC) staff conducted an additional audit of General Electric Hitachi (GEH) during March 21-23. 2012. In addition. the NRC staff has reviewed recent responses to requests for additional information (RAls) (References 41,42, and 43).

Based on these reviews and previous docketed correspondence. the NRC staff has identified areas for which additional information is required. A response to these RAls is needed before the NRC staff can complete its review of the steam dryer (SD).

RAI-01

During the audit conducted by the NRC staff on March 21-23,2012, GEH displayed an EXCEL table that contained stresses for GGNS replacement steam dryer (RSD) in various dryer components. For dryer

, three different stress values were observed, namely

. The NRC staff noted that stress. The NRC staff requests justification for how the stress of is reduced to in the dryer

RAI-02

In addition during the audit. the NRC staff requested GEH to provide Corrective Action Reports (CARs) written in 2012. The NRC staff reviewed CAR# 57911, which pertains to a submodel that contained two unconnected nodes. The NRC staff noted that the justification for the unconnected nodes was based on a study using static analysis with reconnecting the nodes and applying static accelerations. The NRC staff requests a justification based on applying the applicable dynamic flow induced vibration (FIV) loading. and the appropriate cut boundary conditions to the submodel mentioned in CAR# 57911.

OFFlelAlliSE ONLY* PROPRIETARY INFORMATION ~

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-2 RAI*03 The licensee summarized the maximum stress intensities for the overlay and multi-point constraint (MPC) approaches in Table 1 of response to the previous RAJ 04 (Attachment 1 to GNRO-2012/00009 in Reference 40). The MPC approach resulted in higher stress with a difference for the following dryer components:

The licensee justified by performing a submodel analysis for the cover plate showing that the submodel results are lower than the overlay and MPC approaches. However, that location is not the higher stress location in terms of magnitude (dryer base plate) or the higher percentage difference location

. The licensee is requested to provide additional justification for the other significant locations noted above for the applicability of the submodel analysis conclusion, or validate the conclusion based on additional submodels.

RAI-04

During the audit. the NRC staff noted that some overlay elements were used on some in Susquehanna Steam Electric Station (SSES) steam dryer structural finite element model (FEM) in regions Based on its review of Table 1 on page 4 of DRF 0000-0087-2787, "SSES Dryer FEM with Super Element Vane Bundle Representations and Other Modifications", dated September 20, 2008, prepared by Mike Hager, GEH. the NRC staff noted the following, and requests additional information:

Element Nos. 99 and 199 are specified as ANSYS SHELL63 elements, and are described as "dummy or fictitious elements". In a subsequent table. the element thicknesses are listed as 0.10 inches. There is no information about stiffness or mass associated with these elements. It appears that these "dummy elements* are somehow related to the application of surface pressures on the fluid-exposed surfaces of solid elements. The NRC staff requests the licensee to (i) provide the purpose for using these elements; (Ii) provide the thickness and the stiffness properties - Modulus of Elasticity and Poisson's ratio (E, nul and mass density; and (3) address any impact of these elements on the structural response of the steam dryer.

Since the SSES steam dryer is a prototype for GGNS. and the FEMs are similar. the licensee is requested to provide the purpose for utilizing any fictitious overlay elements in regions

, and their impact on the GGNS RSD stresses.

OFFIelMo ~SE ONLY

  • PROPRIETARY INFORMATION ~

OFFICIAL USE ONLY PROPRIETARY INFORMATION ~

ENClOSURE3-REFERENCES

1.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission,

<<license Amendment Request, Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,' dated September 8,2010 (GNRO-2010/00056) (ADAMS Accession No. ML102660409).

2.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental License Amendment Request, Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated November 18, 2010 (GNRO-2010/00071) (ADAMS Accession No. ML103260003).

3.

Krupa, M. A., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental License Amendment Request, Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated November 23, 2010 (GNRO-201 0/00073) (ADAMS Accession No. ML103330146).

4.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,' dated February 23,2011 (GNRO-2011/00007) (ADAMS Accession No. ML110540534).

5.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated February 23, 2011 (GNRO-2011/00012) (ADAMS Accession No. ML110540540).

6.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated February 23, 2011 (GNRO-2011/00011) (ADAMS Accession No. ML110540545).

7.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station. Unit 1," dated February 23, 2011 (GNRO-2011/00013) (ADAMS Accession No. Ml110550318).

8.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated March 9, 2011 (GNRO-2011/00017) (ADAMS Accession No. ML110680507).

9.

Krupa, M. A. Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated March 9, 2011 (GNRO-2011/00016) (ADAMS Accession No. ML110730025).

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  • PRePRIETAR'I' INFORMATION

OFFICIAL USE ONLY* PROPRIETARY INFORMATION

10.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated March 22. 2011 (GNRO*2011100019) (ADAMS Accession No. ML110820262).

11.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,tI dated March 30, 2011 (GNRO-2011/00018) (ADAMS Accession No. ML110900275).

12.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate. Grand Gulf Nuclear Station, Unit 1," dated March 31, 2011 (GNRO-2011/00021) (ADAMS Accession No. ML110900586).

13.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1." dated April 14, 2011 (GNRO-2011/00024) (ADAMS Accession No. ML111050134).

14.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated April 21. 2011 (GNR0-2011/00025) (ADAMS Accession No. ML111120329).

15.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated May 3,2011 (GNRO-2011/00034) (ADAMS Accession No. ML111240288).

16.

Krupa, M. A., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated May 5, 2011 (GNRO-2011/00035) (ADAMS Accession No. ML111250552).

17.

Krupa. M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate. Grand Gulf Nuclear Station, Unit 1." dated May 11, 2011 (GNRO-2011/00037) (ADAMS Accession No. ML111320263).

18.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory CommiSSion, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated June 8, 2011 (GNR0-2011/00043) (ADAMS Accession No. ML111590836).

19.

Krupa, M. A, Entergy Operations, Inc" letter to U.S. Nuclear Regulatory CommiSSion, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated June 15,2011 (GNRO-2011/00046) (ADAMS Accession No. ML111670059).

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20.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate. Grand Gulf Nuclear Station, Unit 1," dated June 21, 2011 (GNRO-2011/00050) (ADAMS Accession No. ML111730235).

21.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated June 23, 2011 (GNRO-2011/00052) (ADAMS Accession No. ML111750244).

22.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated July 6, 2011 (GNRO-2011/00053) (ADAMS Accession No. ML111660136).

23.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated July 26,2011 (GNRO-2011/00055) (ADAMS Accession No. ML112101465).

24.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated August 25, 2011 (GNRO-2011/00070) (ADAMS Accession No. ML112370770).

25.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated August 29, 2011 (GNR0-2011/00073) (ADAMS Accession No. ML112410566).

26.

Krupa, M. A, Entergy Operations, Inc.. letter to U.S. Nuclear Regulatory Commission, "Supplemental Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated August 30,2011 (GNRO-2011/00074) (ADAMS Accession No. ML112420169).

27.

Krupa, M. A, Entergy Operations. Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental Information Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,"

dated September 2,2011 (GNRO-2011/00075) (ADAMS Accession No. ML112490050).

26.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "SuppJementallnformation Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,"

dated September 9,2011 (GNRO-2011/00033) (ADAMS Accession No. ML112521264).

29.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated September 12, 2011 (GNRO-2011/00079) (ADAMS Accession No. ML112550495).

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30.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,* dated September 15, 2011 (GNRO-2011/00080)

(ADAMS Accession No. ML112580223).

31.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,* dated September 26, 2011 (GNRO-2011/00082)

(ADAMS Accession No. ML112690143).

32.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, KRequest for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,n dated October 10, 2011 (GNRO-2011/00087) (ADAMS Accession No. ML112840155).

33.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional1nformation Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated October 10, 2011 (GNRO-2011/00088) (ADAMS Accession No. ML112840171).

34.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Supplemental Information Pertaining to Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated October 24,2011 (GNRO-2011/00092) (ADAMS Accession No. ML112980113).

35.

Krupa, M. A., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated November 14,2011 (GNRO-2011/00101) (ADAMS Accession No. ML113190403).

36.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated November 25,2011 (GNRO-2011/00105) (ADAMS Accession No. ML113290137).

37.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission.

"Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated November 28,2011 (GNRO-2011/00107) (ADAMS Accession No. ML113320403).

38.

Krupa, M. A., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated December 19, 2011 (GNRO-2011/00111) (ADAMS Accession No. ML113530656).

39.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated February 6,2012 (GNRO-2012/00006) (ADAMS Accession No. ML12039A071).

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40.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,* dated February 15, 2012 (GNRO-2012/00009)

(ADAMS Accession No. ML120470138).

41.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated February 20, 2012 (GNRO-2012/00011)

(ADAMS Accession No. ML120540043).

42.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated March 13, 2012 (GNRO-2012/00016)

(ADAMS Accession No. ML120740083).

43.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1,* dated March 21, 2012 (GNRO-2012/00018)

(ADAMS Accession No. ML120820025).

44.

Krupa, M. A, Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Extended Power Uprate, Grand Gulf Nuclear Station, Unit 1," dated AprilS, 2012 (GNRO-2012/00023) (ADAMS Accession No. ML12097A055).

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-2 This enclosed request for additional information (RAI) pertaining to the steam dryer evaluation was discussed with Mr. Jerry Burford of your staff on March 28, 2012, and it was agreed that a response to the RAls would be provided by April 5, 2012. The NRC staff's proprietary version of the RAI is provided in Enclosure 1 and a nonproprietary version is provided in Enclosure 2. A list of references is provided in Enclosure 3.

If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1445 orvia e-mail atAlan.Wang@nrc.gov.

Sincerely, IRN Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

1. Request for Additional Information (proprietary)
2. Request for Additional Information (non-proprietary)
3. List of References cc w/Encl 2 and 3: Distribution via Listserv DISTRIBUTION:

NON-PUBLIC LPLIV r/f RidsAcrsAcnw_MailCTR Resource RidsNrrDeEmcb Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMGrandGulf Resource RidsRgn4MailCenter Resource CBasavaraju, NRR/DE/EMCB ADAMS Accession Nos.:

Pkg ML121020368; Proprietary RAI ML121020371 Non-Proprietary RAI ML121023 5 7

"'RAI memo d ted a

OFFICE NRRlDORULPL4IPM AWang NRRJDORULPL4/LA JBurkhardt NRRJDE/EMCBlBC MMurphy*

NRRJDORULPL4IBC MMarkley NRRlDORLlLPL4IPM AWang (NKalyanam for)

NAME DATE 4/16/12 4/13/12 3130112 4/18112 4/18112 OFFICIAL AGENCY RECORD OFFIOIAL USE ONLY

  • PROPRIETARY INFORMATION