ML12115A090

Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application

ML12115A090
Person / Time
Site:	Grand Gulf
Issue date:	05/09/2012
From:	Ferrer N License Renewal Projects Branch 1
To:	Mike Perito Entergy Operations
Ferrer N 301-415-1045
References
TAC ME7493
Download: ML12115A090 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 9,2012 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 ofFederal Regulations Part 54, to renew the operating license for Grand Gulf Nuclear Station, Unit 1, 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 bye-mail at 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 12 RAI8.1.13-1 Background. The license renewal application (LRA) states that the Containment Inservice Inspection -IWE Program is consistent with GALL Report AMP XI.S1, "ASME Section XI, Subsection IWE." The Generic Aging Lessons Learned (GALL) Report aging management program (AMP) XI.S1 "acceptance criteria" program element states, "[f]or the containment steel shell or liner, material loss locally exceeding 10% of the nominal containment wall thickness or material loss that is projected to locally exceed 10% of the nominal containment wall thickness before the next examination are documented. Such areas are corrected by repair or replacement in accordance with IWE-3122 or accepted by engineering evaluation."

IWE-3122 states, "[w]hen flaws or areas of degradation are accepted by engineering evaluation, the area containing the flaw or degradation shall be reexamined in accordance with IWE 2420(b)." IWE-2420(b) states, "[w]hen examination results require evaluation of flaws or areas of degradation in accordance with 'IWE-3000, and the component is acceptable for continued service, the areas containing such flaws or areas of degradation shall be reexamined during the next inspection period listed in the schedule of the inspection program of IWE-2411 or IWE-2412, in accordance with Table IWE-2500-1, Examination Category E-C."

Issue. During the audit, the staff reviewed the results of the April 2007 IWE inspection of the containment suppression pool liner plate in base slab segments B1-B4 and S1-S4, and wall segments 93-1 through 93-8. The inspection data identified significant number (more than 100) locations where liner plate pits depths varied between 1/64 to 3/64 inches or 6 to 19% of the 1/4 inch thick liner plate. The applicant documented these pits as punch marks made during original construction and found them acceptable. The applicant plans to re-examine these pits in 2017. The applicant's use of a time interval of 10 years for augmented inspections and the criteria used for accepting degradation in the liner plate, in excess of 10 percent, does not appear to be in accordance with the ASME Section XI, IWE-2420(b).

Request.

a. Describe the basis for accepting pits greater than 10 percent of the liner plate nominal wall thickness, including description of any engineering evaluation performed in accordance IWE requirements.

b. Describe the basis for not identifying these pits for augmented inspection during the next inspection period as required by IWE-2420(b).

RAI8.1.13-2 Background. The LRA states that the Containment Inservice Inspection -IWE Program is consistent with GALL Report AMP XI.S1. GALL Report AMP XI.S1 states:

10 CFR 50.55a imposes the inservice inspection (lSI) requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, Subsection IWE, for steel containments (Class MC)

ENCLOSURE

- 2 and steel liners for concrete containments (Class CC). The full scope of IWE includes steel containment shells and their integral attachments, steel liners for concrete containments and their integral attachments, containment hatches and airlocks and moisture barriers, and pressure-retaining bolting. This evaluation covers the 2004 edition, as approved in 10 CFR 50.55a. ASME Code,Section XI, Subsection IWE, and the additional requirements specified in 10 CFR 50.55a{b){2) constitute an existing mandated program applicable to managing aging of steel containments, steel liners of concrete containments, and other containment components for license renewal.

10 CFR 50.55a{b){2){ix){8) states, U[w]hen performing remotely the visual examinations required by Subsection IWE, the maximum direct examination distance specified in Table IWA-2210-1 may be extended and the minimum illumination requirements specified in Table IWA-2210-1 may be decreased provided that the conditions or indications for which visual examination is performed can be detected at the chosen distance and illumination."

Issue. Section 3.2 of the Grand Gulf Nuclear Station (GGNS) License Renewal Project, Aging Management Program Evaluation Report Civil/Structural for Containment Inservice Inspection (CII) -IWE, states, U[t]he requirements of IWA-2210 are not applicable to Subsection IWE visual examinations per IWE-21 00."

Reguest. Please describe the basis for not using the requirements of IWA Table 2210-1.

10 CFR 50.55{a) requires the use of Table IWA Table 2210-1 as amended by 10 CFR 50.55a (b)(2){ix)(8). In addition, please provide the details of any departure, including license exemption, granted by the NRC to deviate from IWA-2210 requirements.

RAI 8.1.13-3 Background. The LRA states that the Containment Inservice Inspection -IWE Program is consistent with the GALL Report AMP XI.S1. The GALL Report AMP XI.S1 "preventive actions" program element states:

The program is also augmented to require that the selection of bolting material installation torque or tension and the use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, EPRI TR-104213, and the additional recommendations of NUREG-1339 to prevent or mitigate degradation and failure of structural bolting. If the structural bolting consists of ASTM A325, ASTM F1852, and/or ASTM A490 bolts, the preventive actions for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of RCSC (Research Council for Structural Connections) publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts," need to be considered.

Issue. Section 3.2 of the GGNS License Renewal Project, Aging Management Program Evaluation Report Civil/Structural for Containment Inservice Inspection (CII) -IWE, states:

Structural bolting is torqued in accordance with the site maintenance procedures that provide technical guidance for calculating the torque value requirements for a specified bolting material and for environment or temperature that the bolting

-3 material would be subjected to during plant operating conditions. The lubricants that are recommended in the maintenance procedure include the use of molybdenum disulfide, which is considered an outlier as described in the element above. Since the use of this lubricant is permitted by plant procedure, it is assumed that all high strength structural bolting material, i.e. ASTM A325 and A490, have used this lubricant in the torquing process during construction and maintenance activities for the life of the plant so far. GGNS procedures will be enhanced to prohibit use of this lubricant. This enhancement will be addressed in the Bolting Integrity Program.

In the statement above, the applicant has not addressed how and when the high strength bolts that were previously torqued using molybdenum disulfide lubricant will be inspected for degradation.

Request. Describe the plan, including sample size and frequency, for inspecting high strength bolts that were previously torqued using molybdenum disulfide lubricant. The plan should also describe the schedule for inspection in order to establish a trend for aging management of these high strength bolts during the period of extended operations.

RAI B.1.13-4 Background. The LRA states that the Containment Inservice Inspection -IWE Program is consistent with GALL Report AMP XLS1. The GALL Report AMP XLS1 "parameters monitored or inspected" program element recommends that pressure retaining surfaces of the containment be inspected for evidence of corrosion, cracking, and wear.

Issue. During the audit, the staff reviewed the document Program Section No. CEP-CISI-102, "Program Section for ASME Section XI, Division 1, GGNS Containment Inservice Inspection Program." Appendix A of this document lists CISI drawings for IWE Inspections. The drywell and weir wall liner plates between elevations 93' and 117' that are located in the suppression pool and the steel drywell head are not listed in this Appendix A.

Request. Provide justification for not inspecting the drywell and weir wall liner plates between elevations 93' and 117' that are located in the suppression pool, and the steel drywell head. If there are plans to inspect these components in the future, describe the frequency and procedures that will be used for these inspections to establish a trend for aging management.

RAI B.1.13-5 Background. The LRA, states that the Containment Inservice Inspection -IWE Program is consistent with GALL Report AMP XLS1. GALL Report AMP XI.S1 recommends that the Containment Inservice Inspection -IWE Program to be implemented in accordance with the ASME 2004 edition, as approved in 10 CFR 50.55a. 10 CFR 50.55a(g)(4) requires that inservice inspection of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code referenced in the 10 CFR 50.55a(b), 12 months before the start of the 120 months inspection interval.

-4 Issue. It is not clear to the staff that the Containment Inservice Inspection - IWE Program is consistent with GALL Report AMP XI.S1 because Section 3.2 of the GGNS License Renewal Project, Aging Management Program Evaluation Report Civil/Structural for the Containment Inservice Inspection (CII) -IWE states that IWE examination satisfies the requirements of the Code Edition 1998 edition with 1999 and 2000 addenda, 2001 edition with 2003 addenda, and the 2004 edition.

Request. Please identify the ASME Code edition that is being used during the current inspection interval, and if this Code edition is consistent with GALL Report recommendations and 10 CFR 50.55a(g)(4) requirements. Alternatively, provide the basis for using an ASME Code edition other than prescribed in 10 CFR 50.55a(g)(4).

RAI8.1.24-1 Background. The LRA states that the Inservice Inspection -IWF Program, with enhancements, is consistent with GALL Report AMP XI.S3, "ASME Section XI, Subsection IWF." The GALL Report AMP XI.S3 "detection of aging effects" program element states that for high strength bolting (actual measured yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter, volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 should be performed to detect cracking in addition to the VT-3 examination. The GGNS Aging Management Program Evaluation Report for ASME Section XI, Subsection IWF is enhanced to include provisions to perform volumetric examinations comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 for identified high strength structural bolts.

During its onsite audit, the staff asked how the applicant will implement the provisions for volumetric examinations, including identification of bolts to be inspected and frequency of examination. The applicant responded that it will perform volumetric examinations of any high strength bolts identified on the component supports that are in the scope of the IWF sample for each inspection interval.

Issue. The applicant's Inservice Inspection -IWF Program states that selection of component supports for examination is based on ASME classification, which includes 25% of Class 1 piping supports, 15% of Class 2 supports, and 10% of class 3 supports. The staff is concerned that performing volumetric examinations only on bolts that are already within the IWF sample of component supports does not ensure that an adequate number of bolts will be examined in order to effectively manage aging of high strength bolting. The intent of the GALL recommendation is to identify and perform volumetric examination on a representative sample of the entire population of high strength structural bolting to provide assurance that age-related degradation of high strength bolts will be managed.

Request. Describe how the volumetric inspections for the Inservice Inspection -IWF Program will effectively manage cracking for the entire population of high strength bolts for the period of extended operation. Include discussion of bolt selection methods, sample size, and frequency of examinations.

- 5 RAI B.1.24-2 Background. The LRA states that the Inservice Inspection - IWF Program, with enhancements, is consistent with GALL Report AMPXLS3. The GALL Report AMP XI.S3 "monitoring and trending" program element states that examinations that reveal indications which exceed the acceptance standards and require corrective measures are extended to include additional examinations in accordance with ASME Section XI, Subsection IWF-2430. The applicant's Inservice Inspection -IWF Program basis documentation states that the acceptance criteria are in accordance with ASME Section XI, Subsection IWF-3410(a).

Issue. During its onsite audit, the staff reviewed documentation regarding degradation of a bolt that was found while performing a VT-3 examination of a pipe restraint in the standby service water system in July 2011. The degradation of the bolt was determined to exceed the acceptance criteria of the Inservice Inspection -IWF Program and the condition was entered into the corrective action program for replacement of the bolt. During its review, the applicant did not provide documentation which indicated additional examinations would be performed or that such examinations had been performed, in accordance with the GALL Report recommendations and the requirements of ASME Section XI, Subsection IWF-2430.

Request. For the identified condition, provide documentation that demonstrates that the Inservice Inspection -IWF Program is consistent with GALL Report AMP XLS3, regarding increase in sample size when deficiencies are identified during examination of supports. If additional inspections were not performed, provide the basis for the statement in LRA Section B.1.24 that the IWF program is consistent with ASME code and Section XI.S3 of the GALL Report.

RAI B.1.24-3 Background. The LRA states that the Inservice Inspection -IWF program, with enhancements, is consistent with GALL Report AMP XLS3. The GALL Report AMP XI.S3 "monitoring and trending" program element states that examinations of component supports that reveal indications which exceed the acceptance standards and require corrective measures are extended to include additional examinations in accordance with ASME Section XI, Subsection IWF-2430.

During review of plant-specific operating experience, the staff noted cases in which conditions were found during IWF examinations that appeared to be degraded, an engineering evaluation determined that the as-found component was acceptable-as-is, but the component was still re worked to as-new condition. Since the applicant determined that the as-found condition did not affect the support's capability to perform its design function, the applicant did not apply ASME Section XI, Subsections IWF-2420 and IWF-2430 for successive or additional examinations.

Issue. The ASME Code,Section XI, Subsection IWF Program requires the inspection of the same sample of the total population of component supports each inspection interval. The staffs concern with respect to aging management is that if ASME Code,Section XI, Subsection IWF supports that are part of the inspection sample are reworked to as-new condition, they are no longer typical of the other supports in the population. Subsequent ASME Code,Section XI,

-6 Subsection IWF inspections of the same sample would not represent the age-related degradation of the rest of the population.

Request. Describe how the ASME Section XI, Subsection IWF Program will be effective in managing aging of similar/adjacent components that are not included in the sample population.

Include in your description a justification that the program will be effective in situations when corrective actions are not required per the ASME Code,Section XI, Subsection IWF, acceptance criteria, but a support within the inspection sample is repaired to as-new condition without an expansion of the sample population size.

RAI 8.1.24-4 Background. The LRA states that the Inservice Inspection -IWF Program, with enhancements, is consistent with GALL Report AMP XI.S3. The GALL Report AMP XI.S3 "operating experience" program element recommends that applicants review site-specific operating experience to ensure the IWF sampling inspections will be effective in managing aging effects for in-scope component supports and bolting. Staff review of condition reports and conversations with the applicant have indicated that there may be age-related degradation of underwater bolting of component supports in the Standby Service Water (SSW) basins. During the staff's onsite review, the applicant stated that the degraded bolting was not found during IWF inspections and thus is not subject to IWF requirements for expansion of scope per ASME Section XI, Subsection IWF-2430. In all cases, the conditions were entered into the corrective action process and scheduled for repair or determined acceptable for continued service.

Issue. The staff is concerned that although the degraded bolts were not found during IWF inspections, it is possible that bolts that are within the scope of the IWF program may have been identified as degraded during these inspections. In addition, it is not clear to the staff if there has been any effort to inspect bolts in the SSW basin that are in the IWF inspection sample population and may be subject to the same condition.

Reguest.

a. For all of the degraded bolts that have been found during underwater inspections of the SSW basin, provide information regarding an evaluation to determine if any of the identified bolts are part of the IWF sample.

b. If there are no IWF bolts in the SSW basin, provide justification for not including bolts subject to this environment in the scope of the IWF program.

c. If IWF bolts are located in the SSW basin, provide information to assess if the scope of the IWF AMP should be expanded to component supports in the SSW basins and any plans to conduct additional examinations of component supports.

d. Clarify if the latest lSI IWF inspection conducted in July 2011 included any bolts in the SSW basins and the results of the inspection of those bolts.

- 7 RAJ 8.1.24-5 Background. The LRA states that the Inservice Inspection -IWF Program, with enhancements, is consistent with GALL Report AMP XLS3. GALL Report, AMP XI.S1, "ASME Section, Subsection IWF," Element 2, "preventive actions" states:

The program is also augmented to require that the selection of bolting material installation torque or tension and the use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, EPRI TR-104213, and the additional recommendations of NUREG-1339 to prevent or mitigate degradation and failure of structural bolting. If the structural bolting consists of ASTM A325, ASTM F1852, and/or ASTM A490 bolts, the preventive actions for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of RCSC (Research Council for Structural Connections) publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts," need to be considered.

The LRA Section B.1.24 states:

"Structural bolting is torqued in accordance with the site maintenance procedures that provide technical guidance for calculating the torque value requirements for a specified bolting material and for environment or temperature that the bolting material would be subjected to during plant operating conditions. The lubricants that are recommended in the maintenance procedure include the use of molybdenum disulfide, which is considered an outlier as described in the element above. Since the use of this lubricant is permitted by plant procedure, it is assumed that all high strength structural bolting material, i.e. ASTM A325 and A490, have used this lubricant in the torquing process during construction and maintenance activities for the life of the plant so far. GGNS procedures will be enhanced to prohibit use of this lubricant. This enhancement will be addressed in the Bolting Integrity Program."

Issue. The applicant's Inservice Inspection -IWF Program does not address how and when the high strength bolts that were previously torqued using molybdenum disulfide lubricant will be inspected for degradation.

Request. Describe the plan, including sample size and frequency, for inspecting high strength bolts that were previously torqued using molybdenum disulfide lubricant. The description should also describe the schedule for inspection which enables the establishment of a trend for aging management of these high strength bolts during the period of extended operation.

SUBJECT:

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

HARDCOPY:

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, Unit 1, 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 ore-mail nathaniel.ferrer@nrc.gov.

Sincerely, IRAJ 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 'ML12115a090 OFFICE LARPB1 :DLR PM:RPB1:DLR BC:RPB1 :DLR PM: RPB1:DLR NAME IKing N Ferrer D Morey N Ferrer DATE 41 30 112 05/02/12 05/02/12 05/09/12 OFFICIAL RECORD COpy