ML12152A345
| ML12152A345 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/22/2012 |
| From: | Ferrer N License Renewal Projects Branch 1 |
| To: | Mike Perito Entergy Operations |
| Ferrer N, 415-1045 | |
| References | |
| TAC ME7493 | |
| Download: ML12152A345 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 22,2012 Mr. Michael Perito Vice President, Site Entergy Operations, Inc.
PO 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 ttle 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 nathani~Lferrer@nrc.gcv.
Sincerely, Nathaniel Ferrer, Project Manager Projects Branch 1 Division of License Renewal Office of Nuc!ear Reactor Regulation Docket No 50-416 Enclosure.
Requests for Additional Information cc w/enc!: Listserv
GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION SET 22 RAI8.1.4-1
Background:
GALL Report AMP XI.M22, "Boraflex Monitoring," states:
For Boraflex panels in spent fuel storage racks, gamma irradiation and long-term exposure to the wet fuel pool environment causes shrinkage resulting in gap formation, gradual degradation of the polymer matrix, and the release of silica to the spent fuel storage pool water. This results in the loss of boron carbide in the neutron absorber sheets. A monitoring program for the Boraflex panels in the spent fuel storage racks is implemented to assure that no unexpected degradation of the Boraflex material compromises the criticality analysis in support of the design of spent fuel storage racks. This aging management program (AMP) relies on periodic inspection, testing, monitoring, and analysis of the criticality design to assure that the required 5% subcriticality margin is maintained. Therefore, this AMP includes: (a) completing sampling and analysis for silica levels in the spent fuel pool water on a regular basis, such as monthly, quarterly, or annually (depending on Boraflex panel condition), and trending the results by using the EPRI RACKLIFE predictive code or its equivalent; and (b) performing neutron attenuation testing or blackness testing to determine gap formation in Boraflex panels or measuring boron areal density by techniques such as the BADGER device.
The license renewal application (LRA) states that "the Boraflex Monitoring Program, with enhancements, is consistent with the program described in NUREG-1801, Section X1.22, Boraflex Monitoring." In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP with enhancements, the following requests for information are needed.
Request
- a. Clarify whether the "scope of the program" includes the Boraflex in the upper containment pool.
- b. The Boraflex Monitoring Program implementing procedures describe the use of a coupon monitoring technique. Clarify whether GGNS still uses the coupon monitoring technique, and whether this coupon monitoring technique will be performed in the period of extended operation. Also, if the coupon monitoring technique will be relied upon in the period of extended operation, state how many coupons are left and at what frequency will they be monitored.
2
- c. The Boraflex Monitoring Program basis documentation references, which describe the "detection of aging effects" and "monitoring and trending" program elements, state that monitoring will be done by the use of RACKLIFE on a frequency of 1 year. The enhancement states that "RACKLIFE analysis will continue to be performed each cycle."
The staff notes that each cycle is about 1.5-2 years.
- 1. Clarify if the RACKLI will be performed every year or every cycle.
- 2. Due to GGNS operating experience with Boraflex degradation, provide justification for the frequency of the RACKLIFE predictions.
RAI B.1.16-1
Background
The Updated Final Safety Analysis Report (UFSAR) Supplement description contained in the Standard Review Plan for License Renewal (SRP-LR) provides an acceptable program description for the GALL Report AMP XI.M30, "Fuel Oil Chemistry," which includes the specific ASTM Standards used for monitoring and control of fuel oil contamination to maintain fuel oil quality. LRA Section A.1.16, "Diesel Fuel Monitoring Program" states, "[t]he Diesel Fuel Monitoring Program manages loss of material and fouling in piping and components exposed to an environment of diesel fuel oil by verifying the quality of fuel oil and controlling fuel oil contamination as well as periodic draining, cleaning, and inspection of tanks. Applicable industry standards and guidance documents are used to delineate the program." The program description found in LRA AMP B.1.16 does not include the industry standards (e.g., ASTM) used in the program.
The LRA does not specify the industry standards used for this program. Specifying the applicable industry standards used in the program ensures that there is adequate description of the program to provide assurance that it will be properly executed during the period of extended operation. The UFSAR supplement and program description for the Diesel Fuel Monitoring Program do not include the specific industry standards used for the program.
Request.
Justify the absence of the above mentioned industry standards in the UFSAR supplement and the program description in LRA Appendix B for the Diesel Fuel Monitoring Program.
Alternatively, provide a revision to your UFSAR supplement and AMP program description to include the specific industry standards used for the program.
RAI B.1.16-2 Background.
The GALL Report recommends draining and cleaning of diesel fuel oil tank internal surfaces at least once every 10 years during the period of extended operation. Periodic draining and cleaning of diesel fuel oil tanks is performed so that internal surfaces can be visually and
- 3 volumetrically inspected allowing for detection of corrosion and other degradation inside the tanks. LRA AMP B.1.16, "Diesel Fuel Monitoring Program," states that the program will be enhanced to include a 10-year periodic cleaning and internal visual inspection of the fire water fuel oil tanks, the diesel fuel oil day tanks, and the diesel fuel oil drip tanks in scope of the program.
Issue The LRA AMP does not include the procedures for performing cleaning and inspection of the above mentioned tanks. That is, the staff is not clear on the cleaning and inspection approach for these tanks.
Request Provide a summary of the process for performing cleanings and internal visual inspections of the fire water fuel oil tanks, the diesel fuel oil day tanks, and the diesel fuel oil drip tanks in scope of the program.
Letter to M. Perito from N. Ferrer dated, June 22, 2012
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO. ME7493)
DISTRIBUTION:
HARDCOPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource NFerrer DDrucker DWrona DMorey AWang RSmith, RIV BRice, RIV GPick, RIV DMclntyre, OPA
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 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' ML12152A345 iOFFICE LA:RPB1 :DLR PM:RPB1 :DLR BC:RPB1:DLR NAME
~Edmonds NFerrer DMorey DATE 6/19/12 61 18/12 6/20/12 PM: RPB1 :DLR NFerrer 6/22/12 OFFICIAL RECORD COpy