ML12125A373

Requests for Additional Information for the Review of the Grant Gulf Nuclear Station License Renewal Application (TAC No. ME7493)Grand Gulf LRA RAI Set 17

ML12125A373
Person / Time
Site:	Grand Gulf
Issue date:	05/24/2012
From:	Ferrer N License Renewal Projects Branch 1
To:	Mike Perito Entergy Operations
Ferrer N
References
TAC ME7493
Download: ML12125A373 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 May 24,2012 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 17 RAI 3.1.1.62-1 Background. LRA Table 3.1.1, item 3.1.1-62, addresses high-strength, low-alloy steel, or stainless steel closure bolting; stainless steel control rod drive head penetration flange bolting exposed to air with reactor coolant leakage being managed for cracking due to stress corrosion cracking. The LRA states that this item is not applicable because SRP-LR item 3.1.1-62 is only applicable to pressurized water reactors (PWRs).

LRA Tables 3.1.2-3 and 3.1.2-4 include carbon and low alloy steel bolting exposed to air with reactor coolant leakage which is being managed for loss of material and loss of preload.

Issue. Although the SRP-LR states that item 3.1.1-62 is only applicable to PWRs, the cracking due to stress corrosion cracking (SCC) aging effect applies to all high-strength bolting. The LRA includes carbon and low alloy steel bolting exposed to air with reactor coolant leakage in LRA Tables 3.1.2-3 and 3.1.2-4 of the reactor coolant system. The staff noted that the applicant is managing these items for loss of material and loss of preload, but not cracking due to SCC.

Request. State the basis for why cracking due to SCC is not applicable to in-scope carbon and low alloy steel closure bolting exposed to air with reactor coolant leakage (external) in the reactor coolant system, or provide an aging management program (AMP) to manage this aging effect.

RAI 3.2.1.63-1 Background. The GALL Report recommends in several items (such as VII.H2.AP-55 and VII.E5.AP-273) that stainless steel components exposed to condensation or raw water be managed for loss of material. LRA Table 3.2.2-6 states that the stainless steel moisture separator exposed internally and externally to indoor air has no aging effects and no AMP is proposed. There are no other environments listed for the moisture separator.

Issue. It is unclear why the moisture separator has no aging effects since moisture separators are usually exposed to air containing significant amounts of water, and parts may be exposed to water where the moisture accumulates.

Request. Explain why the stainless steel moisture separator is not susceptible to any aging effects and does not require aging management.

RAI 3.3.1.72-1 Background. SRP-LR Table 3.3-1, item 72, addresses gray cast iron and copper alloy with greater than 15-percent zinc or a-percent aluminum piping, piping components, and piping elements exposed to treated water, raw water, closed-cycle cooling water, or soil and recommends GALL Report AMP XI.M33, "Selective Leaching," to manage loss of material due to selective leaching.

ENCLOSURE

- 2 LRA Table 3.3.2-12 contains aging management review (AMR) results for copper alloy with greater than 15-percent zinc or 8-percent aluminum strainers exposed internally and externally to raw water and treated water. The AMR items are being managed for loss of material due to selective leaching on the internal surfaces using the Selective Leaching Program. However, the AMR items are not being managed for loss of material due to selective leaching on the external surfaces.

Issue. It is not clear why external surfaces of the strainers are not being managed for loss of material due to selective leaching.

Request. Explain why the external surfaces of the strainers do not need to be managed for loss of material due to selective leaching.

RAI3.3.1.72-2 Background. LRA Table 3.3.2-14 contains AMR results for copper alloy with greater than 15-percent zinc or 8-percent aluminum and gray cast iron valve bodies and gray cast iron pump casing externally exposed to condensation that will be managed for loss of material using the Selective Leaching program. Additionally, LRA Table 3.3.2-19-6 contains an AMR item for gray cast iron valve body internally exposed to condensation that will be managed for loss of material using the Selective Leaching program. All items refer to SRP-LR Table 3.3.1, item 72, which addresses gray cast iron and copper alloy with greater than 15-percent zinc or 8-percent aluminum piping, piping components, and piping elements exposed to treated water, raw water, closed-cycle cooling water, or soil, and recommends GALL Report AMP XI.M33, "Selective Leaching," to manage loss of material due to selective leaching.

Issue. LRA Tables 3.3.2-11,3.3.2-16,3.3.2-19-16,3.3.2-19-19, 3.3.2-19-21, 3.3.2-19-26, 3.3.2 19-27, and 3.3.2-19-28 contain AMR results for copper alloy with greater than 15-percent zinc or 8-percent aluminum and/or gray cast iron valve bodies and piping internally or externally exposed to condensation; however, loss of material due to selective leaching is not identified as an aging effect.

LRA Table 3.0.1, "Service Environments for Mechanical Aging Management Reviews," defines condensation as "air and condensation on surfaces of indoor systems with temperatures below dew point; condensation is considered untreated water due to potential for surface contamination. "

There is insufficient information for the staff to determine why selective leaching is an aging mechanism of concern for some copper alloy with greater than 15-percent zinc or 8-percent aluminum and gray cast components exposed to condensation, but not for other similar components with the same material and environment.

Request. Explain why the copper alloy with greater than 15-percent zinc or 8-percent aluminum and gray cast components exposed to condensation in the LRA tables identified in the issue statement do not need to be managed for loss of material due to selective leaching.

-3 RAI 3.3.1.92-1 Background. The SRP-LR, item 3.3.1-92, states that aluminum piping, piping components, and piping elements exposed to condensation (internal) is subject to loss of material due to general and crevice corrosion. The item recommends the use of GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," to manage the loss of material due to general and crevice corrosion aging effect.

LRA Table 3.3.1, item 3.3.1-92, states that aluminum piping, piping components, and piping elements exposed to condensation (internal) is subject to loss of material due to general and crevice corrosion, and will be managed by the Internal Surfaces in Miscellaneous Piping and Ducting Components Program. However, there are no LRA Table 2 AMR items which reference LRA Table 3.3.1, item 3.3.1-92.

Issue. If aluminum piping, piping components, and piping elements exposed to condensation (internal) are subject to loss of material due to general and crevice corrosion as stated in LRA Table 3.3.1, item 3.3.1-92, then it should be reflected through a Table 2 item in the LRA. The lack of LRA Table 2 AMR items indicates that LRA Table 3.3.1, item 3.3.1-92, is not applicable at GGNS, contradicting the information provided in LRA Table 3.3.1, or that LRA Table 2 AMR items have been omitted from the LRA.

Request. Provide an amendment to the LRA to identify appropriate LRA Table 2 AMR items which reference item LRA Table 3.3.1, item 3.3.1-92, or update item 3.3.1-92 to state that it is not applicable along with technical justification.

RAI3.3.2.10-1 Background. The "detection of aging effects" program element of GALL Report AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," states that visual external inspections of metallic surfaces are performed at a frequency not to exceed one refueling cycle.

LRA Table 3.3.2-10 includes line items stating that carbon steel and stainless steel piping exposed to waste water (external) are subject to a loss of material that will be managed by the Periodic Surveillance and Preventive Maintenance Program. The "detection of aging effects" program element of LRA Section B.1.35 states that visual inspections occur at least once every five years.

Issue. The inspection interval for external metallic surfaces exposed to waste water in LRA Table 3.3.2-10 is longer than that recommended by GALL Report AMP XI.M36; therefore, the loss of material aging effect may not be adequately managed.

Request. Review the components with external surfaces exposed to a waste water environment that are being managed by the Periodic Surveillance and Preventive Maintenance Program and provide a technical justification for the program's inspection interval and its adequacy to appropriately manage the aging effects.

- 4 RAI 3.3.2.16-1 Background. The SRP-LR, item 3.3.1-83, states that cracking due to stress corrosion cracking could occur in stainless steel diesel engine exhaust piping, piping components, and piping elements exposed to diesel exhaust. In addition, the item recommends the use of GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," to manage cracking due to stress corrosion cracking of stainless steel diesel engine exhaust piping, piping components and piping elements.

LRA Table 3.3.2-16, for the high-pressure core spray (HPCS) diesel generator system includes three separate AMR items for stainless steel expansion joints, stainless steel flexible connections, and stainless steel turbochargers exposed to diesel exhaust (internal) that are being managed for loss of material. For the corresponding material and environment, the GALL Report recommends managing for both loss of material and cracking due to stress corrosion.

Issue. The stainless steel expansion joint, flexible connection, and turbochargers exposed to diesel exhaust in LRA Table 3.3.2-16 are not being managed for stress corrosion cracking as recommended by the SRP-LR, item 3.3.1-83.

Request. Provide the bases for not managing the stainless steel expansion joint, flexible connection, and turbochargers exposed to diesel exhaust in Table 3.3.2-16 for stress corrosion cracking or provide an appropriate AMP that will manage this aging effect for this material and environment combination.

RAI3.3.2.19-1 Background. LRA Table 3.3.2-19-19 contains an AMR result for gray cast iron ejector internally exposed to raw water that will be managed for loss of material using the Service Water Integrity program. The AMR item refers to SRP-LR Table 3.3.1, Item 38, which addresses copper alloy and steel heat exchanger components exposed to raw water and recommends GALL Report AMP XI.M20, "Open-Cycle Cooling Water System" to manage loss of material due to general, pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling.

Issue. Table IX.C of the GALL Report, Revision 2, defines steel as including gray cast iron, but cautions that gray cast iron is susceptible to selective leaching. However, in Table 3.3.2-19-19, loss of material due to selective leaching is not listed as an aging effect requiring management for the gray cast iron ejector.

Request. Justify why the gray cast iron ejector exposed to raw water does not need to be managed for loss of material due to selective leaching.

RAI 3.3.2.19-2 Background. GALL Report AMP XI.M29, "Aboveground Metallic Tanks," states that for storage tanks supported on earthen or concrete foundations, corrosion may occur at inaccessible locations, such as the tank bottom. The AMP also states in the "detection of aging effects" program element that potential corrosion of tank bottoms is determined by taking

-5 ultrasonic testing (UT) for thickness measurements of the tank bottoms whenever the tank is drained and at least once within 5 years of entering the period of extended operation.

LRA Tables 3.3.2-19-20 and 3.3.2-19-24 state that carbon steel tanks exposed to waste water (internal) and treated water (internal) are managed for loss of material by the Internal Surfaces in Miscellaneous Piping and Ducting Components Program. However, the Internal Surfaces in Miscellaneous Piping and Ducting Components Program does not state that an UT for thickness of tank bottoms is included in the program for tanks that are supported by earthen or concrete foundations.

LRA Table 3.3.2-12 states that carbon steel tanks exposed to condensation (internal) and raw water (internal) are managed for loss of material by the Fire Water System Program. The Fire Water System Program description does not state that an UT for thickness of tank bottoms is included in the program for tanks that are supported by earthen or concrete foundations.

Issue. It is not clear if the tanks are on earthen or concrete foundations. If the tanks are on earthen or concrete foundations, it is not clear that tanks will be adequately tested to ensure that significant degradation is not occurring and that the component intended function is maintained during the period of extended operation.

Request. Indentify each tank and state how each is mounted or supported. In addition, for any tank that is supported on earthen or concrete foundations, indentify the aging management program and inspection technique that will be used to manage the appropriate aging effect.

RAI 3.5.1.78-1 Background. SRP-LR Table 3.5-1, item 78, recommends that steel fuel pool liners be managed for cracking due to stress corrosion cracking and loss of material due to pitting and crevice corrosion with GALL Report AMP XI.M2, "Water Chemistry," and monitoring of the spent fuel pool water level and leakage from the leak chase channels.

LRA Table 3.5.1, item 3.5.1-78, states that steel fuel pool liners will be managed for loss of material due to pitting and crevice corrosion with the Water Chemistry Control - BWR program and monitoring of the spent fuel pool water level and leakage from the leak test channels.

Item 3.5.1-78 also states that cracking due to stress corrosion cracking is not an aging effect requiring management because there are no in-scope stainless steel components exposed to treated water> 60°C (140°F). UFSAR Section 9.1.3.2 states that the spent fuel pool water temperature is normally maintained below 140°F.

Issue. The staff has identified the following issues for AMR items associated with LRA item 3.5.1-78:

a. LRA Table 3.5.2-3 states that the spent fuel pool liner and gate will be managed for cracking with the Water Chemistry Control - BWR program and monitoring of the spent fuel pool water level, referencing item 3.5.1-78. However, LRA item 3.5.1-78 states that loss of material is the applicable aging effect.

- 6

b. LRA Table 3.5.2-3 also states that spent fuel pool storage racks will be managed for loss of material with the Water Chemistry Control - BWR program and monitoring of the spent fuel pool water level, referencing item 3.5.1-78. The staff does not consider the monitoring of the pool water level to be an appropriate aging management activity to verify the effectiveness of water chemistry controls for the storage racks.

c. The AMR items in LRA Table 3.5.2-3 that are associated with LRA item 3.5.1-78 cite plant-specific note 504, which states that the One-Time Inspection Program will verify the effectiveness of the water chemistry controls. The use of the One-Time Inspection is not included in the discussion for LRA Table 3.5.1, item 3.5.1-78.

d. For the AMR items in LRA Table 3.5.2-3 that are associated with LRA item 3.5.1-78, monitoring of the leak chase channels is not cited as an aging management activity, although this activity is recommended in SRP-LR Table 3.5-1, item 78, and is included in the discussion for LRA Table 3.5.1, item 3.5.1-78.

Request.

a. Resolve the discrepancy between the AMR item for the spent fuel pool liner and gate or LRA Table 3.5.1, item 3.5.1-78, regarding whether cracking will be age managed. Also, revise the AMR item for the spent fuel pool liner and gate to include loss of material as an aging effect requiring management, or provide the technical justification for why loss of material does not need to be age managed.

b. Revise the AMR item for the spent fuel storage racks to remove monitoring of the pool water level as an aging management activity, or provide the technical justification for why such monitoring is appropriate to verify the effectiveness of water chemistry controls to mitigate loss of material for the storage racks.

c. Resolve the discrepancy between the AMR items in LRA Table 3.5.2-3 and the discussion for LRA Table 3.5.1, item 3.5.1-78, regarding whether the One-Time Inspection Program will be used to verify the effectiveness of water chemistry controls for all associated AMR items.

d. Revise the AMR items associated with LRA Table 3.5.1, item 3.5.1-78, to include monitoring of the leak chase channels as an aging management activity, as appropriate.

RAI 3.5.2.4-1 Background. The SPR-LR states that stainless steel components exposed to outdoor air can be susceptible to cracking and loss of material depending on the outdoor environmental conditions.

SRP-LR Sections 3.4.2.2.2 and 3.4.2.2.3 state that cracking and loss of material is applicable for plants with outdoor environments high in chlorides, such as those near a saltwater coastline, near a highway treated with salt, with chlorides in the soil, or that have a cooling tower treated with chlorine.

In LRA Table 3.5.2-4, the applicant stated that for stainless steel base plates, component and piping supports, anchor bolts, ASME Class 1, 2, 3 and MC support bolting, and structural bolting exposed to air-outdoor, there are no aging effects and no AMP is proposed. The AMR items

-7 cite generic note I. The AMR items also cite a plant-specific note which states that sulfur dioxide vapors or other similar substances do not chemically pollute the ambient outdoor environment at GGNS and the external environment does not contain saltwater or high chloride content; therefore aging management is not required for aluminum and stainless steel components exposed to the external environment. However, LRA Sections 3.4.2.2.2 and 3.4.2.2.3 state that the applicant has a cooling tower treated with hypochlorite and that cracking and loss of material of stainless steel components directly exposed to outdoor air are identified as aging effects requiring management and are managed by the External Surfaces Monitoring Program.

Issue. It is unclear to the staff why these stainless steel components exposed to outdoor air are not being managed for cracking and loss of material given that the applicant's outdoor air environment contains cooling tower vapor which contains chlorides.

Request. Explain why cracking and loss of material are not applicable aging effects for stainless steel base plates, component and piping supports, anchor bolts, ASME Class 1, 2, 3 and MC support bolting, and structural bolting exposed to outdoor air. If these stainless steel components are not susceptible to cracking and loss of material, resolve the inconsistency with LRA Sections 3.4.2.2.2 and 3.4.2.2.3.

..'ML12125A373 OFFICE LA:RPB1 :DLR PM:RPB1:DLR BC:RPB1 :DLR PM: RPB1:DLR NAME YEdmonds NFerrer DMorey NFerrer DATE 5/15/12 51 21/12 5124/12 5/24/12