GNRO-2012/00114, Response to Requests for Additional Information (RAI) Set 34 Dated September 5, 2012

Response to Requests for Additional Information (RAI) Set 34 Dated September 5, 2012

ML12277A079
Person / Time
Site:	Grand Gulf
Issue date:	10/02/2012
From:	Mike Perito Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
A001
References
GNRO-2012/00114
Download: ML12277A079 (44)

Text

• .-~=.Entergy GNRO-2012/00114 October 2,2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson. MS 39150 Michael Perito Vice President. Operations Grand Gulf Nuclear Station Tel. (601) 437-6409

Dear Sir or Madam:

Response to Requests for Additional Information (RAI) Set 34 dated September 5, 2012 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 1.

NRC Letter, "Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application Set 34," dated September 5, 2012 (GNRI-2012/00203)

(ML12234A671) 2.

Grand Gulf Nuclear Station, Unit 1 Letter (GNRO-2012/00076),

"Response to Requests for Additional Information (RAI) Set 21 dated June 20, 2012" Entergy Operations, Inc is providing, in Attachment 1, the response to the referenced Requests for Additional Information (RAI) from RAI Set 34. Attachment 2 includes corrections to license renewal application (LRA) tables identified during the NRC regional inspection in August, and one change to a previous RAI response included in reference 2. Attachment 3 includes an updated listing of regulatory commitments for license renewal that includes revised commitment 14 required in response to RAls in this letter.

This letter contains no new commitments. If you have any questions or require additional information, please contact Christina L. Perino at 601-437-6299.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of October, 2012.

Attachments: (see next page)

GNRO-2012/00114 Page 2 of 2 Attachments:

1. Response to Requests for Additional Information (RAI)

2. Corrections to LRA Tables

3. List of Regulatory Commitments cc: with Attachments Mr. John P. Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555 cc: without Attachments Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 U.S. Nuclear Regulatory Commission ATTN: Mr. Nathaniel Ferrer NRRlDLR Mail Stop OWFNI 11 F1 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 to GNRO-2012100114 Response to Requests for Additional Information (RAI) to GNRO-2012/00114 Page 1 of 16 The format for the Request for Additional Information (RAI) responses below is as follows. The RAI is listed in its entirety as received from the Nuclear Regulatory Commission (NRC) with background, issue and request subparts. This is followed by the Grand Gulf Nuclear Station (GGNS) RAI response to the individual question.

RAI8.1.22-1a Background. Based on information from Grand Gulf Nuclear Station (GGNS) calculation MC-01111-08011, the staff issued request for additional information (RAI) B.1.22-1 questioning whether the Flow-Accelerated Corrosion (FAC) Program manages wall thinning for components in the low pressure core spray (LPCS) and high pressure core spray (HPCS) systems. The applicant's response, dated May 25, 2012, states that these systems are not susceptible to FAC because they experience two phase flow less than two percent of the time and that the referenced calculation confirmed the conclusion that the FAC Program is not required to manage wall thinning in the LPCS and HPGS systems. The response also stated that no other systems have aging effects being managed by the FAG Program that were not identified in the license renewal application (LRA).

Information obtained during the staff's aging management program audit appears to indicate that several items in the LPGS (Le., #333, #403, #661, #662) and HPGS (Le., #253, #285, #301,

1. 307, #402, #605) systems were being monitored through inspections performed by the FAG Program. In addition, the staff identified an excess of 40 items in the residual heat removal (RHR) system that appeared to be monitored through inspections performed by the FAG Program. However these components appear to be in portions of the RHR system that the GSI Technology evaluation No. 0700.104-10, "GGNS FAG System Susceptibility Evaluation," had excluded from susceptibility for FAG for an unspecified reason.

Issue. It is not clear to the staff whether the System Susceptibility Evaluation improperly excluded systems or portions of systems that were susceptible to FAG, or the inspections being performed by the FAG Program are monitoring components that are susceptible to an aging mechanism other than FAG, or components that were previously monitored by the FAG Program have been determined to be acceptable until the end of the period of extended operation and no longer need to be monitored.

Request. Review the components contained in the FAC Program's reinspection list for future outages (specifically, items 333, 403, 661,662,253,285,301,307,402, and 605) and determine whether the inspections conducted on these components were for wall thinning due to FAG or for some other wall thinning mechanism.

If these components are no longer being inspected through the FAG Program, either identify the program that now monitors wall thinning for these components or provide details showing that these components had previously been determined to be acceptable through the end of the period of extended operation.

If these or any other components are being inspected through the FAG Program and were previously excluded through the System Susceptibility Evaluation, explain why the System Susceptibility Evaluation inappropriately excluded these components and revise the LRA to justify the use of the FAG Program to monitor aging mechanisms other than FAG.

to GNRO-2012/00114 Page 2 of 16 RAI 8.1.22-1a RESPONSE LPCS FAC locations 333, 403, and 661 and HPCS FAC locations 253, 285, 301, 307, 402, 605 are included in the FAC Program for monitoring and evaluation in future outages. FAC location 662 was replaced in 2004 with FAC-resistant material (stainless steel) and is no longer monitored for FAC.

The above referenced LPCS and HPCS components were added to the FAC program based on GGNS operating experience with the discovery of a pinhole leak in the RHR system minimum flow line in 2001. Prior to 2001, GGNS was monitoring one location on the RHR "A" loop and three locations on the RHR "B" loop. These locations were selected based on piping geometry, EPRI suggestion, and industry experience. The FAC program owner believed that the RHR "A" minimum flow line had low susceptibility due to low usage. However, Operations had been using the line at an abnormally high frequency. Following discovery of the RHR system leak, nine additional locations were monitored on the RHR "A" loop and four additional locations were monitored on the RHR "B" loop. Based on this event, GGNS systems were reviewed to identify low usage minimum flow lines and evaluate for degradation due to FAC. Subsequently, LPCS and HPCS components in high-flow lines were added for monitoring and evaluation in the FAC program as a result of FAC degradation.

GGNS also includes components in the FAC Program that were found not susceptible in the system susceptibility evaluation. Susceptibility exclusion criteria include low temperature, infrequent operation, dissolved oxygen content> 1000 ppb, and low flow. Reasons to include components in the FAC Program that may meet susceptibility exclusion criteria include plant-specific and industry operating experience, EPRI suggestions, susceptibility of heavily throttled piping regions, and cavitation concerns.

NUREG-1801 XI.M17 element 1 indicates that the program is described by the EPRI guidelines in NSAC 202L, which primarily addresses loss of material due to flow-accelerated corrosion.

The GGNS FAC Program also addresses loss of material due to erosion mechanisms other than FAC that are identified through plant-specific and industry operating experience. The monitoring of components for other than the FAC mechanism is considered an exception to NUREG-1801,Section XI.M17. This exception is justified because the program elements are applicable and effective for managing loss of material whether due to FAC or other erosion mechanisms. While a predictive model is not applicable to loss of material due to non-FAC mechanisms, the program provisions for identifying inspection locations based on operating experience are applicable and appropriate for loss of material due to non-FAC mechanisms.

LRA Appendix A and B are revised as follows with deletions shown with strikethrough and additions shown with underline.

A.1.22 Flow-Accelerated Corrosion Program The Flow-Accelerated Corrosion (FAC) Program manages loss of material due to wall thinning for piping and components by conducting appropriate analysis and baseline inspections, determining the extent of thinning, performing follow-up inspections, and taking corrective actions as necessary. The FAC program also manages the effects of aging due to other wall-thinning mechanisms that may be identified through industry or plant-specific operating experience. The program follows guidelines published by EPRI in NSAC-202L.

to GNRO-2012/00114 Page 3 of 16 8.1.22 FLOW-ACCELERATED CORROSION Program Description The Flow-Accelerated Corrosion (FAG) Program is an existing program that manages loss of material due to wall thinning for piping and components by conducting appropriate analysis and baseline inspections, determining the extent of thinning, performing follow-up inspections, and taking corrective actions as necessary. The FAC program also manages the effects of aging due to other wall-thinning mechanisms that may be identified through industry or plant-specific operating experience. The program follows guidelines published by EPRI in NSAC-202L.

NUREG-1801 Consistency The FAC Program, with enhancement, is consistent with the program described in NUREG-1801,Section XI.M17, Flow-Accelerated Corrosion, with one exception.

Exceptions to NUREG-1801 NeAeThe Flow-Accelerated Corrosion Program is consistent with the program described in NUREG-1801,Section XI.M17, Flow-Accelerated Corrosion, with the following exception.

Elements Affected Exceptions

1. Scope of Program NUREG-1801 XI.M17 element 1 indicates that the Ioroaram is described bv the EPRI auidelines in NSAG 1202L which orimarilv addresses loss of material due o flow-accelerated corrosion. The GGNS FAG Proaram also addresses loss of material due to erosion mechanisms other than FAG that are identified hrouah olant-soecific and industrY oneratinn exoerience. The monitorina of comnonents for other han the FAG mechanism is considered an exceotion o NUREG-1801 Section XI.M17.

1 1.

Exception Note This exception is justified because the program elements are applicable and effective for managing loss of material whether due to FAG or other erosion mechanisms. While a predictive model is not applicable to loss of material due to non-FAG mechanisms, the program provisions for identifying inspection locations based on operating experience are applicable and appropriate for loss of material due to non-FAG mechanisms The following LRA tables are revised to include line items that credit the Flow-Accelerated Corrosion Program for managing loss of material for carbon steel in treated water.

LRA Tables 3.2.2-2 and 3.2.2-8-2 LRA Tables 3.2.2-3 and 3.2.2-8-3 LRA Tables 3.3.2-1 and 3.3.2-19-1 LRA Tables 3.3.2-6 and 3.3.2-19-8 LRA Table 3.3.2-19-20 LRA Table 3.4.2-2-4 LRA Table 3.4.2-2-6 LRA Table 3.4.2-2-11 to GNRO-2012/00114 Page 4 of 16 Table 3.2.2-2: Low Pressure Core Spray System EiI2lilll Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-A boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.2.2-3: High Pressure Core Spray System EiI2lilll Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-A boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.2.2-8-2: Low Pressure Core Spray System, Nonsafety-Related Components Affecting Safety-Related Systems EiI2lilll Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-A boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.2.2-8-3: High Pressure Core Spray System, Nonsafety-Related Components Affecting Safety-Related Systems EiI2lilll Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-A boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.3.2-1: Control Rod Drive System EiI2lilll Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-

.Q boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.3.2-6: Fuel Pool Cooling and Cleanup System EiI2lilll Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-

.Q boundary steel water (int) material Accelerated 09 11 Corrosion to GNRO-2012/00114 Page 5 of 16 Table 3.3.2-19-1: CRD Hydraulic System [10 CFR 54.4(a)(2)]

Ei1li!J.g Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-Q boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.3.2-19-8: Fuel Pool Cooling and Cleanup System [10 CFR 54.4(a)(2)]

Piping Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-Q boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.3.2-19-20: Floor and Equipment Drain System [10 CFR 54.4(a)(2)]

Piping Pressure Carbon Treated Loss of Flow-V.D2.E-3.2.1-Q boundary steel water (int) material Accelerated 09 11 Corrosion Table 3.4.2-2-4: Condensate Cleanup System, Nonsafety-Related Components Affecting Safety-Related Systems Ei1li!J.g Pressure Carbon Treated Loss of Flow-VIILE.S-3.4.1-5 Q

boundary steel water (int) material Accelerated 16 Corrosion Table 3.4.2-2-6: Main Turbine and Auxiliaries, Nonsafety-Related Components Affecting Safety-Related Systems Piping Pressure Carbon Treated Loss of Flow-VIILE.S-3.4.1-5 Q

boundary steel water (int) material Accelerated 16 Corrosion Table 3.4.2-2-11: Turbine Bypass System, Nonsafety-Related Components Affecting Safety-Related Systems Piping Pressure Carbon Treated Loss of Flow-VIILE.S-3.4.1-5 Q

boundary steel water (int) material Accelerated 1.2 Corrosion to GNRO-2012/00114 Page 6 of 16 In addition to the above changes, LRA Sections 3.2.2.1.2, 3.2.2.1.3, 3.3.2.1.1, and 3.3.2.1.6 are revised to add the Flow-Accelerated Corrosion Program to the list of aging management programs.

RAI 8.1.22-2a Background. GGNS Procedure EN-DC-315, "Flow-Accelerated Corrosion Program,"

Section 5.1.1, "Components Failing to Meet Initial Screening Criteria," states that a condition report shall be generated when "significant wall thinning," is detected in a system or when wall thinning is below Taccpt [acceptable wall thickness]. "Significant wall thinning" is defined in Section 3.0.39 as the largest of a) a thickness less than 60 percent of nominal pipe wall thickness (T nom), b) a thickness less than Y2 (0.875 Tnom + Taccpd, or c) Taccpt +0.020 inches.

The staff issued RAI B.1.22-2 requesting GGNS to confirm that significant wall thinning, as defined in EN-DC-315, had not been detected in recent outages and condition reports were not required to be generated. The response to RAI B.1.22-2, dated May 25, 2012, stated:

A review of program documentation and data from the Fall 2008 and Spring 2010 refueling outages determined that no significant wall thinning has been detected other than the wall thinning documented in the condition reports referenced in the background of this request for information, which had resulted in wall thickness below the minimum acceptable wall thickness.

Thus no additional condition reports on significant wall thinning as defined in EN-DC-315 were required to be generated.

Information obtained during the staff's aging management program audit appears to indicate several instances where the measured wall thickness (T meas) was less than 60 percent of (T nom), which meets the criteria for "significant wall thinning" in EN-DC-315. Specifically, in calculation MC-Q111-08011, "Evaluation of RF16 Flow Accelerated Corrosion Wall Thickness Data," for the refueling outage in fall 2008:

Item 314A, 4-inch pipe to downstream tee: T nom =0.237, T meas =0.122 [51%]

Item 353, 3x6 expander: T nom =0.280, T meas =0.163, [58%]

Item 795, 2-inch elbow and pipe: T nom =0.218, T meas =0.095 [44%]

Issue. Inspections apparently identified significant wall thinning, but GGNS did not issue condition reports as required by the controlling procedure. Since the current program is not being implemented in accordance with the controlling procedure, the staff cannot reasonably conclude that the program will be implemented in accordance with the controlling procedure during the period of extended operation.

Reguest. Re-review the program documentation and data from recent outages to confirm that no significant wall thinning, as defined in EN-DC-315, "Flow-Accelerated Corrosion Program had been identified and condition reports were not required to be generated. Specifically discuss items 314, 353, and 795 to explain why these are not examples of "significant wall thinning."

to GNRO-2012/00114 Page 7 of 16 If significant wall thinning was identified, but condition reports were not generated, then provide information to demonstrate that there is reasonable assurance the program will be implemented in accordance with the controlling procedures during the period of extended operation.

RAI 8.1.22-2a RESPONSE Further review of program documentation and data from recent outages has been performed.

An incorrect interpretation of procedural requirements to generate condition reports with respect to wall thinning related to items 314,353, and 795 was identified. This incorrect interpretation has been documented in the corrective action program.

The following material replacements have been made:

FAC Item 314 was replaced with FAC-resistant material during the 2010 refueling outage.

FAC Item 353 was replaced with FAC-resistant material during the 2012 refueling outage.

FAC Item 795 was replaced with FAC-resistant material during the 2010 refueling outage.

The fact that material replacements were completed per the requirements of EN-DC-315, "Flow-Accelerated Corrosion Program" indicates that the program remains effective for managing the effects of aging. The identification of the incorrect procedure interpretation in the corrective action program will ensure that needed corrective actions will be taken to provide reasonable assurance the program will be implemented in accordance with the controlling procedures during the period of extended operation.

RAI8.1.24-1a

Background:

In its response to RAI B.1.24-1, and the updated list of commitments, the applicant stated that it will enhance the Inservice Inspection-IWF Program to identify the component supports that contain high-strength bolting in sizes greater than 1 inch nominal diameter, and that the extent of examination will be as specified in ASME Code Section XI, Subsection IWF (Table IWF-2500-1).

Issue: It is not clear whether the applicant plans to assess the plant for all component supports applicable to the Inservice Inspection-IWF Program that contain high strength structural bolting and then establish a sample based upon the criteria specified in ASME Code Section XI, Table IWF-2500-1, or if the applicant plans to identify the high strength bolts among the component supports already identified as part of the IWF examination sample.

Request: Clarify whether the applicant will identify all of the high strength bolts that are eligible to be part of the IWF inspection population and establish a new sample for high strength bolts based on the ASME Table IWF-2500-1 or it if it is going to identify high strength bolts from the already-established set of IWF supports. If the latter, explain how that approach will ensure that the ASME Code criteria for sample size will be met.

RAI 8.1.24-1a RESPONSE Grand Gulf Nuclear Station (GGNS) will augment the Inservice Inspection (ISI)-IWF program, as stated in the LRA Appendices A.1.24 and B.1.24 enhancements, to include volumetric examination of high-strength bolting comparable to that specified in ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 in addition to the VT-3 examination per Table IWF-2500-1. GGNS will enhance the ISI-IWF program to identify all the component supports to GNRO-2012/00114 Page 8 of 16 that contain high strength bolting (actual yield strength greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter. The extent of examination for support types that contain high-strength bolting will be as specified in ASME Code Section XI, Table IWF-2500-1. GGNS will examine high-strength structural bolting on the frequency specified in ASME Code Section XI, Table IWF-2500-1.

LRA Appendix A.1.24 Inservice Inspection - IWF program is revised as shown below. Note that changes include revisions to correct three minor editorial errors in the enhancement to detection of aging effects as shown below. Additions are shown with underline. Deletions are shown with strikethrough.

A.1.24 Inservice Inspection - IWF Program The Inservice Inspection -IWF Program manages aging effects for ASME Class 1,2,3 piping and component supports. The scope of inspection for component supports is based on sampling of piping supports and 100 percent of component supports other than piping as specified in Table IWF-2500-1.

The Inservice Inspection - IWF Program will be enhanced as follows.

Address inspections of accessible sliding surfaces.

Clarify that parameters monitored or inspected will include corrosion; deformation; misalignment of supports; missing, detached, or loosened support items; improper clearances of guides and stops; and improper hot or cold settings of spring supports and constant load supports. Accessible areas of sliding surfaces will be monitored for debris, dirt, or indications of excessive loss of material due to wear that could prevent or restrict sliding as intended in the design basis of the support. Structural bolts will be monitored for corrosion and loss of integrity of bolted connections due to self-loosening and material conditions that can affect structural integrity. High-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa in sizes greater than 1 inch nominal diameter) susceptible to stress corrosion cracking (SCC) will be monitored for SCC.

Clarify that detection of aging effects will include:

a.

Monitoring structural bolting (ASTM A-325, ASTM F1852, and ASTM A490 bolts) and anchor bolts will bo monitorod for loss of material, loose or missing nuts, loss of preload and cracking of concrete around the anchor bolts.

b.

Volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 should bo porformed for high strength structural bolting to detect cracking in addition to the VT-3 examination. This volumetric examination may be waived with adequate plant-specific justification.

c.

Identification of all component supports that contain high strength bolting (actual measured yield greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter. The extent of examination for support types that contain high-strength bolting will be as specified in ASME Code Section XI, Table IWF-2500-1. GGNS will examine high-strength structural bolting on the frequency specified in ASME Code Section XI, Table IWF-2500-1.

LRA Appendix B.1.24 Inservice Inspection - IWF is revised as shown below. Note that changes include revisions to correct three minor editorial errors in the enhancement to detection of aging to GNRO-2012/00114 Page 9 of 16 effects as shown below. Additions are shown with underline. Deletions are shown with strikethrough.

Elements Affected Enhancements 4.

Detection of Aging Effects The ISI-IWF Program will be enhanced to clarify that detection of aging effects will include the following:

a)

Monitoring structural bolting (ASTM A-325, ASTM F1852, and ASTM A490 bolts) and anchor bolts will se FAenit9Fee for loss of material, loose or missing nuts, loss of pre-load, and cracking of concrete around the anchor bolts.

b)

Volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 shml!e se peFfOFFAee for high strength structural bolting to detect cracking in addition to the VT-3 examination. This volumetric examination may be waived with adequate plant-specific justification c)

Identification of all component supports that contain high strength bolting (actual measured yield greater than or equal to 150 ksi) in sizes greater than 1 inch nominal diameter. The extent of examination for support types that contain high-strength bolting will be as specified in ASME Code Section XI, Table IWF-2500-1. GGNS will examine high-strength structural bolting on the frequency specified in ASME Code Section XI, Table IWF-2500-1.

RAI 8.1.24-28

Background:

In RAI B.1.24-2, the staff requested that the applicant provide information regarding degraded components in the standby service water basins and any corrective actions that were taken in accordance with the ASME code. The staff reviewed the response and noted that the applicant expanded the scope and frequency of inspections in accordance with the ASME Section XI, Subsection IWF requirements; however, the staff noted that the expanded scope and frequency of inspections was limited to the standby service water system.

Issue: The staff is concerned that there may be similar aging of IWF components in systems other than the standby service water system with the same material and environment combination.

Request: Provide information on whether there are IWF supports in other areas of the plant that may be subject to similar age-related degradation. If so, provide information as to whether the applicant performed additional examinations extending to other systems in the plant, if any, or provide justification for not determining the potential extent of the degraded condition to other areas.

to GNRO-2012/00114 Page 10 of 16 RAI 8.1.24-2a RESPONSE Grand Gulf Nuclear Station (GGNS) has not identified ASME Section XI-IWF supports in other areas of the plant that are subject to similar age-related degradation as the supports identified in the standby service water (SSW) basin. There are in-scope supports in other areas of the plant that are exposed to a fluid environment, similar to that of the SSW basin, such as suppression pool and spent fuel pool components. However, the materials for those supports are not carbon steel.

RAI 8.1.24-3a

Background:

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 staff noted in the applicant's program operating experience, the applicant discovered degraded conditions that were significant enough that the applicant chose to repair or re-work the component to as-new condition. However, the degradation was not enough to exceed the IWF-3000 acceptance criteria for expansion in scope or additional inspections.

Issue: The staff's concern, as stated in RAI B.1.24-3, is that if IWF supports and components are re-worked to as-new condition, they are no longer representative of the age-related degradation to the remaining components in the population of the IWF scope but that are not in the inspection sample.

Reguest: Explain how the applicant plans to ensure that the IWF inspection sample components represent the age-related degradation of the rest of the population. If applicable, state whether the program will include an evaluation for the need to substitute components that are re-worked with another that may be more representative of the general population, or to include additional components in the inspection sample.

RAI 8.1.24-3a RESPONSE To the extent practical, the same supports selected for examination during the first inspection interval shall be examined during each successive inspection interval. When examinations reveal degraded conditions that exceed the Acceptance Standards defined in ASME Code,Section XI, IWF-3400, applicable additional examination requirements of IWF-2430 and Inservice Examination requirements of IWF-3120 (Inservice Examinations) are applied.

When component support conditions are found to include minor age-related degradation that does not meet the threshold of "unacceptable for continued service" as defined in IWF-3400, an evaluation will be performed in accordance with the corrective action program. If this evaluation determines that the component, without repair, will continue to perform its intended function until the next scheduled inspection, the component support will not be repaired but will be monitored for increased degradation. The evaluation will also consider which inspections/repairs may be required for similar/adjacent components not included in the lSI program sample population and assure additional inspections are performed during the next scheduled inspection. As an alternative, GGNS may choose to repair the degraded component and replace it in subsequent inspection samples with a randomly selected component that is more representative of the general population. LRA Sections A.1.24 and B.1.24 are revised to add the following enhancement. Additions are shown with underlines.

to GNRO-2012/00114 Page 11 of 16 A.1.24 Inservice Inspection - IWF Program The Inservice Inspection - IWF Program will be enhanced as follows.

When a component support is found with minor age-related degradation. but still is evaluated as "acceptable for continued service" as defined in IWF-3400. the program owner may choose to repair the degraded component and substitute a randomly selected component that is more representative of the general population for it in subsequent inspections.

8.1.24 INSERVICE INSPECTION - IWF Elements Affected Enhancements

7. Corrective Actions Enhance the Inservice Inspection - IWF Program corrective actions to include the following guidance:

When a component support is found with minor age-related degradation. but still is "acceptable for continued service" as defined in IWF-3400. the program owner may choose to repair the degraded component and substitute a randomly selected component that is more representative of the general population for it in subseguent inspections.

RAI 8.1.24-5a

Background:

In its response to RAls B.1.24-1 and B.1.24-5, the applicant references the Generic Aging Lesson's Learned (GALL) Report statement that ASTM A-325, F-1852, and ASTM A-490 bolts used in civil structural applications have not shown to be prone to stress corrosion cracking (SCC). In its response to RAI B.1.24-5, the applicant also states that "cracking due to SCC is an applicable aging effect on high-strength bolting greater than one inch and having a yield strength greater than 150 ksi exposed to sustained high tensile stress in a corrosive environmenf' and that "high-strength bolting is not exposed to a corrosive environment at Grand Gulf Nuclear Station."

Issue: The statement in the GALL Report that ASTM A-325, F-1852, and ASTM A-490 bolts have not been shown to be prone to SCC does not apply to high strength structural bolting for ASME Class 1, 2 and 3 piping and component supports. The GALL Report also does not define or specify criteria for a "corrosive environmenf' that must be met for age-management of high strength structural bolting, rather it defines the applicable environment as air-indoor, uncontrolled, to manage high strength structural bolting for cracking due to SCC. The GALL Report recommends that the ASME Section XI, Subsection IWF Program is augmented to include consideration of the guidance applicable in EPRI NP-5769, EPRI TR-1 04213, and the additional recommendations of NUREG-1339 for selection of bolting material installation torque or tension and the use of lubricants and sealants to prevent or mitigate degradation and failure to GNRO-2012/00114 Page 12 of 16 of structural bolting. In addition, the GALL Report recommends that for high strength structural bolting, the preventive actions for storage, lubricants, and SCC potential discussed in Section 2 of Research Council for Structural Connections (RCSC) publication "Specification for Structural Joints using ASTM A325 or A490 Bolts" need to be used. The applicant's response to RAI B.1.24-1 does not indicate whether the applicant's procedures implement the recommended guidance or consider the preventive actions for storage, lubricants, and SCC potential discussed in Section 2 of the RCSC publication "Specification for Structural Joints using ASTM A325 or A490 Bolts".

Request: Specify whether the Inservice Inspection-IWF Program will be enhanced in accordance with the GALL Report such that:

a.

The guidance applicable in EPRI NP-5769, EPRI TR-1 04213, and NUREG-1339 for selection of bolting material and the use of lubricants and sealants will be used to prevent or mitigate degradation and failure of safety-related bolting b.

The preventive actions addressed in Section 2 of RCSC publication "Specification for Structural Joints using ASTM A325 or A490 Bolts" will be followed for structural bolting consisting of ASTM A325, ASTM F1852, and/or ASTM A490 bolts If this guidance will not be used, provide technical justification for not following the guidelines recommended in the GALL Report.

RAI 8.1.24-5a RESPONSE a.

Consistent with NUREG-1801, Grand Gulf Nuclear Station (GGNS) ASME Section XI, Inservice Inspection-IWF (ISI-IWF) Program is a condition monitoring program and does not include guidance for the selection of bolting material, installation torque or tension, and use of lubricants and sealants. The GGNS IWF program is augmented by plant procedures that ensure proper selection of bolting material, proper installation torque or tension, and the use of appropriate lubricants and sealants. However, where applicable, procedures will be enhanced to incorporate recommendations delineated in NUREG-1339, and Electric Power Research Institute (EPRI) NP-5769 and TR-104213 for high-strength structural bolting. These recommendations emphasize proper selection of bolting material, lubricants, and installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting.

LRA Appendix A.1.24 Inservice Inspection - IWF program is revised as shown below. Additions are shown with underline.

A.1.24 Inservice Inspection - IWF Program The Inservice Inspection -IWF Program will be enhanced as follows.

Clarify that preventive action will include:

Incorporate into plant procedures recommendations delineated in NUREG-1339, and Electric Power Research Institute (EPRIl NP-5769 and TR-1 04213 for high-strength structural bolting. These recommendations should address proper selection of bolting material. proper installation torgue or tension, and the use of appropriate lubricants and sealants.

to GNRO-2012/00114 Page 13 of 16 LRA Appendix B.1.24 Inservice Inspection - IWF program is revised as shown below. Additions are shown with underline.

8.1.24 INSERVICE INSPECTION - IWF Elements Affected Enhancements 2.

Preventive Actions The ISI-IWF Program will be augmented by incorporating into plant procedures recommendations delineated in NUREG-1339.

and Electric Power Research Institute (EPRI) NP-5769 and TR-1 04213 for high-strength structural bolting. These recommendations address proper selection of bolting material, proper installation torgue or tension. and the use of appropriate lubricants and sealants.

b.

GGNS procedures include the recommended guidance provided for preventive actions for storage and lubricants identified in Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts" for ASTM A325, ASTM F1852 and/or A490 bolting.

RAI8.1.41-1a Background. The operating experience discussion for the Service Water Integrity Program states that degraded areas of coatings were identified on the submerged piping in the standby service water (SSW) basins. Based on the degree of degradation noted after 12 months, the staff issued RAI B.1.41-1 questioning the adequacy of the 36-month inspection frequency specified in the coatings procedure 07-S-07-211, "Service Levell Coatings Conditions Assessment."

The response to RAI B.1.41-1, states that procedure 07-S-07-211 applies to the underwater coatings in the SSW basin, including the coatings on concrete structures, and that the 36-month inspection frequency is appropriate for these concrete structures. The response also stated:

"In addition to the SSW basin inspections specified in Procedure 07-S-07-211, GGNS performs SSW basin pipe coating inspections annually."

The Service Water Integrity Program descriptions in LRA Section B.1.41 and the updated final safety analysis report (UFSAR) supplement in LRA Section A.1.41 state that the Service Water Integrity Program manages loss of material and fouling as described in the GGNS response to GL 89-13. However, the GGNS generic letter (GL) response, dated January 29,1990, states that for protective coatings, "accessible external piping surface coatings are maintained by routine plant painting efforts." The GGNS response to GL 89-13 did not address submerged piping in the SSW basins, and GGNS Commitment Change Evaluations (CCEs) 2004-0002, 2006-0002,2006-0004, and 2007-0001, for GL 89-13 commitments did not discuss protective coatings.

Issue. Based on the response to the RAI, it is not clear whether the SSW basin pipe coating inspections are controlled through procedure 07-S-07-211, through some other procedure, or to GNRO-2012/00114 Page 14 of 16 through a combination of procedures. Since the SSW basin pipe coatings are currently inspected annually due to past piping degradation, it is not clear where the inspection frequency is specified and how the inspection frequency is controlled.

In addition, since the GGNS response to GL 89-13 stated that external surfaces are maintained by routine plant painting efforts, but the current inspection and maintenance of submerged piping do not appear to be routine painting activities, the LRA's program description and UFSAR supplement for the Service Water Integrity program do not reflect current GGNS aging management activities for the Service Water Integrity program.

Request.

a.

Clarify which GGNS procedure controls the coating inspections for submerged piping in the SSW basin, the frequency of these inspections, and how inspection frequencies are adjusted based on plant-specific operating experience.

b.

Update the program description in LRA Sections A.1.41 and B.1.41 for the Service Water Integrity program to reflect current aging management activities or provide justification that the program described in GGNS response to GL 89-13, as modified through the commitment change process, adequately describes current GGNS aging management activities.

RAI 8.1.41-1a RESPONSE a.

Inspections of coatings for submerged piping in the SSW basin are performed in accordance with GGNS procedure 07-S-07-211. Based on the results of past inspections, the inspection frequency is at least once per 12 months in the GGNS maintenance management system. This frequency was based on a study performed by the GGNS equipment reliability team. The frequency of inspections is then adjusted based on the inspection results documented in reports produced by the inspection teams, using GGNS site guidance for system monitoring and preventive maintenance activities. The frequency would be increased in response to indications of accelerated degradation to ensure that unacceptable degradation does not occur prior to the next scheduled inspection.

b.

The program description in LRA Sections A.1.41 and B.1.41 is revised as shown.

Additions are marked with underline.

A.1.41 Service Water Integrity Program The Service Water Integrity Program manages loss of material and fouling in open-cycle cooling water systems as described in the GGNS response to NRC GL 89-13. In addition, the program includes inspections of coatings for submerged piping in the standby service water (SSW) basin. The frequency of these inspections is based on the inspection results.

8.1.41 SERVICE WATER INTEGRITY Program Description The Service Water Integrity Program is an existing program that manages loss of material and fouling in open-cycle cooling water systems as described in the GGNS response to NRC GL 89-to GNRO-2012/00114 Page 15 of 16

13. In addition. the program includes inspections of coatings for submerged piping in the standby service water (SSW) basin. The freguency of these inspections is based on the inspection results.

RAI8.1.41-3a Background. Based on information in GGNS condition report CR-GGN-2010-01344, the staff issued RAI B.1.41-3 requesting information regarding whether components that are being managed for loss of material by the Service Water Integrity program are also being managed for loss of material by GGNS MS-46, "Program Plan for Monitoring Internal Erosion/Corrosion in Moderated Energy Piping Components (Safety Related)." In addition, based on the similarity in definitions between flow-accelerated corrosion," and "erosion/corrosion," the staff issued RAI B.1.22-3 requesting information regarding the aging effects being managed by GGNS MS-46.

The response to RAI B.1.41-3, dated May 25, 2012, states:

"The GGNS MS-46 procedure for moderate energy piping is not an aging management program that is necessary or credited to manage the effects of aging for components that are included in the Service Water Integrity program." [emphasis added]

By contrast, the response to RAI B.1.22-3, dated May 25, 2012, states:

These inspections [described in GGNS MS-46] are not credited as part of the aging management program described in LRA B.1.22, Flow-Accelerated Corrosion Program.

However, inspections specified in GGNS MS-46 are credited as part of the aging management program for managing loss of material described in LRA B.1.21 Fire Water System Program and LRA B.1.41 Service Water Integrity. Furthermore, the inspections described in GGNS MS-46 may be used, where applicable, as opportunistic or periodic inspections defined in other aging management programs at GGNS." [emphasis added]

GALL Report AMP XI.M20, Open-Cycle Cooling Water System, states that this program manages aging effects caused by mechanisms including erosion. Although the GGNS response to GL 89-13, Action III, Item 7, stated that the SSW system did not meet the selection criteria of the erosion/corrosion monitoring program, the GGNS review for GL 89-13 appears to have used the criteria for NRC Bulletin 87-01, which is for FAC (as clarified in NSAC-202L, "Recommendations for an Effective Flow-Accelerated Corrosion Program"). Erosion as described in GL 89-13 relates to solid particle erosion, but as discussed in DRAFT Interim Staff Guidance 2012-001, 'Wall Thinning Due to Erosion Mechanisms," erosion can be caused by other mechanisms, such as cavitation, flashing and droplet impingement.

Issue. Statements that were provided in response to RAI B.1.41-3 and RAI B.1.22-3 appear to be in conflict with each other. In addition, since the condition report and the response to RAI B.1.22-3 discuss MS-46, wall thickness inspections of pipe components are being performed at GGNS for erosion/corrosion. However, it is not clear whether these are one-time inspections that confirm the components are acceptable until the end of the period of extended operation, or whether these are ongoing monitoring activities that verify the acceptability of components for a time period less than the period of extended operation. In that regard, any one-time inspections performed early in plant life may have only considered a 40-year operating license.

to GNRO-2012/00114 Page 16 of 16 Request.

a.

Reconcile the apparent disparity between the responses to RAI 8.1.41-3 and RAI 8.1.22-2 regarding whether the inspections specified in GGNS MS-46, "Program Plan for Monitoring Internal Erosion/Corrosion in Moderated Energy Piping Components (Safety Related)," are or are not credited in the Service Water Integrity Program. In addition, if inspections performed through MS-46 are credited by any aging management program, include appropriate changes to the related sections of the LRA.

b.

Provide information regarding all components that are being monitored for erosion/

corrosion through GGNS MS-46 to demonstrate that these components are not within the scope of license renewal; or if components are within the scope of license renewal, that the monitoring activities are limited to one-time inspections which have verified the components are acceptable until the end of the period of extended operation or are credited by an aging management program in the LRA.

RAI 8.1.41-3a RESPONSE a.

As stated in the response to RAI 8.1.41-3, site procedure GGNS-MS-46 is not an aging management program. As stated in LRA Section 8.1.41, the program that manages loss of material and fouling in open-cycle cooling water systems is the Service Water Integrity Program. However, as stated in the response to RAI 8.1.22-3, the inspections performed per site procedure GGNS-MS-46 may be used, as applicable, as opportunistic or periodic inspections for aging management programs described in the GGNS LRA. Site procedures that direct specific program inspections are not specified in the LRA and therefore no LRA changes are required.

b.

The Service Water Integrity Program is used to manage the effects of aging on components subject to aging management review. This includes performing inspections, such as standby service water (SSW) heat exchanger inspections, diver inspections of the SSW basins, and inspections performed per GGNS site procedures including GGNS-MS-46. GGNS-MS-46 provides instructions for implementing the inspection of components subject to aging management review in only the plant service water, standby service water, circulating water, fire protection, component cooling water, and turbine building cooling water systems. These inspections are ongoing monitoring activities that are credited by aging management programs described in the GGNS LRA, such as the Fire Water System Program, the Water Chemistry Control - Closed Treated Water Systems Program, and the Service Water Integrity Program. These activities ensure the identification and evaluation of aging effects such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

to GNRO-2012100114 Corrections to LRA Tables to GNRO-2012/00114 Page 1 of 3 During the NRC regional inspection in August 2012 a question was raised on the need to include the Reactor Core Isolation Cooling system gland seal system shown on LRA drawing M-1083B in scope for license renewal. A review of this issue was performed and identified changes were required to the LRA. The following discussion is provided including changes to the LRA.

The pneumatic gland seal system is part of the reactor core isolation cooling system and is in scope of license renewal. The portion of the pneumatic gland seal system that is subject to aging management review is evaluated in LRA table 3.2.2-4, Reactor Core Isolation Cooling system. During the August 2012 NRC Region IV inspection associated with the review of the GGNS license renewal application (LRA), it was noted that line items for stainless steel tUbing and carbon steel valve body [with internal environment of condensation] were missing from LRA Table 3.2.2-4. These line items reflecting the compressed air lines for the pneumatic gland seal subsystem of the reactor core isolation cooling system are added to LRA Table 3.2.2-4. This also requires a change to the discussion for line item 3.2.1-46 in LRA Table 3.2.1. These changes to the LRA tables are shown below. Additions are shown with underline and deletions are shown with strikethrough.

Table 3.2.2-4:

Reactor Core Isolation Cooling System Aging Effect Aging NUREG-Component Intended Requiring Management 1801 Table 1 Type Function Material Environment Management Program Item Item Notes Tubing Pressure Stainless Condensation Loss of Internal Surfaces in V.D2.EP-3.2.1-48 A

boundary steel (int) material Miscellaneous 61 Piping and Ducting Components Valve body Pressure Carbon Condensation Loss of Internal Surfaces in V.D2.E-27 3.2.1-46 A

boundary steel (int) material Miscellaneous Piping and Ducting Components to GNRO-2012/00114 Page 2 of 3 Table 3.2.1: Engineered Safety Features 3.2.1-46 Steel piping and Loss of material Chapter XI.M38, No This item was not l;lSeg. There are components due to general, "Inspection of Internal no steel eSF system components (internal surfaces) pitting, and crevice Surfaces in exposeg to internal congensation in exposed to corrosion Miscellaneous Piping the scope of license renewal.

condensation and Ducting Consistent with NUREG-1801. The (internal)

Components" Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages loss of material for steel components exposed to internal condensation.

to GNRO-2012/00114 Page 3 of 3 In the response to RAI 3.3.2.19-3 provided in Reference 2 of this letter, the line item for Teflon flexible connection was removed from Table 3.3.2-19-8.

This change also required removing Teflon as a material from section 3.3.2.1.19 which was not included in the response.

The change to section 3.3.2.1.19 is included below with deletions shown with strikethrough.

3.3.2.1.19 Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

The following lists encompass materials, environments, aging effects requiring management, and aging management programs for the series 3.3.2-19-xx tables.

Materials Nonsafety-related components affecting safety-related systems are constructed of the following materials.

aluminum carbon steel copper alloy copper alloy> 15% zinc or > 8% aluminum elastomer glass gray cast iron stainless steel teflon to GNRO-2012100114 List of Regulatory Commitments to GNRO-2012/00114 Page 1 of 20 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Additions are shown with underline and deletions with strikethrough.

IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 1

Implement the 115 kilovolt (KV) Inaccessible Prior to GNRO-B.1.1 Transmission Cable Program for Grand Gulf November 1, 2011/00093 Nuclear Station (GGNS) as described in License 2024 Renewal Application (LRA) Section B.1.1 2

Implement the Aboveground Metallic Tanks Prior to GNRO-B.1.2 Program for GGNS as described in LRA Section November 1, 2011/00093 B.1.2 2024 3

Enhance the Bolting Integrity Program for GGNS to Prior to GNRO-B.1.3 clarify the prohibition on use of lubricants containing November 1, 2011/00093 MoS2 for bolting, and to specify that proper gasket 2024 compression will be visually verified following assembly.

Enhance the Bolting Integrity Program to include consideration of the guidance applicable for pressure boundary bolting in Regulatory Guide (NUREG) 1339, Electric Power Research Institute (EPRI) NP-5769, and EPRI TR-104213.

Enhance the Bolting Integrity Program to include volumetric examination per American Society of Mechanical Engineers (ASME) Code Section IX, Table IWB-2500-1, Examination Category B-G-1, for high-strength closure bolting regardless of code classification.

to GNRO-2012/00114 Page 2 of 20 IMPLEMENTATION RELATED COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 4

Enhance the Boraflex Monitoring Program for Prior to GNRO-B.1.4) RAI GGNS to perform periodic surveillances of the November 1, 2011/00093 B.1.4-1 boraflex neutron absorbing material in the spent fuel 2024 GNRO-pool and upper containment pool at least once 2012-00077 every 5 years using Boron-10 Areal Density Gage for Evaluating Racks (BADGER) testing.

RACKLIFE analysis will continue to be performed each cycle. This analysis will include a comparison of the RACKLIFE predicted silica to the plant measured silica. This comparison will determine if adjustments to the RACKLIFE loss coefficient are merited. The analysis will include projections to the next planned RACKLIFE analysis date to ensure current Region I storage locations will not need to be reclassified as Region II storage locations in the analysis interval.

5 Implement the Buried Piping and Tanks Inspection Prior to GNRO-B.1.5/ RAI Program for GGNS as described in LRA Section November 1, 2011/00093 B.1.5-4a B.1.5. Soil testing will be performed at two locations 2024 GNRO-near the stainless steel condensate storage system 2012100089 piping that is subject to aging management review.

Measured parameters will include soil resistivity, bacteria, pH, moisture, chlorides and redox potential. If the soil is determined to be corrosive then the number of inspections will be increased from one to two prior to and during the period of extended operation.

to GNRO-2012/00114 Page 3 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 6

Enhance the Boiling Water Reactor (BWR) Vessel Prior to GNRO-B.1.11 Internals Program for GGNS as follows.

November 1, 2011/00093 2024 (a)

Evaluate the susceptibility to neutron or thermal embrittlement for reactor vessel internal components composed of CASS, X-750 alloy, precipitation-hardened (PH) martensitic stainless steel(e.g., 15-5 and 17-4 PH steel), and martensitic stainless steel (e.g., 403, 410 and 431 steel).

(b)

Inspect portions of the susceptible components determined to be limiting from the standpoint of thermal aging susceptibility, neutron fluence, and cracking susceptibility (Le., applied stress, operating temperature, and environmental conditions). The inspections will use an inspection technique capable of detecting the critical flaw size with adequate margin. The critical flaw size will be determined based on the service loading condition and service-degraded material properties. The initial inspection will be performed either prior to or within 5 years after entering the period of extended operation. If cracking is detected after the initial inspection, the frequency of re-inspection will be justified based on fracture toughness properties appropriate for the condition of the component. The sample size will be 100% of the accessible component popUlation, excluding components that may be in compression during normal operations.

to GNRO-2012/00114 Page 4 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 7

Enhance the Compressed Air Monitoring Program Prior to GNRO-B.1.12/RAI for GGNS to apply a consideration of the guidance November 1, 2011/00093 B.1.12-1 of ASME OM-S/G-1998, Part 17; ANSI/ISA-S7.0.01-2024 1996; EPRI NP-7079; and EPRI TR-108147 to the limits specified for air system contaminants.

Enhance the Compressed Air Monitoring Program to include periodic and opportunistic inspections of accessible internal surfaces of piping, compressors, dryers, aftercoolers, and filters to apply consideration of the guidance of ASME OM-S/G-1998, Part 17 for inspection frequency and inspection methods of these components in the following compressed air systems.

Automatic Depressurization System (ADS) air Division 1 Diesel Generator Starting Air (D1DGSA)

Division 2 Diesel Generator Starting Air (D2DGSA)

Division 3 Diesel Generator Starting Air (D3DGSA), also known as the HPCS Diesel Generator Instrument Air (IA) to GNRO-2012/00114 Page 5 of 20 IMPLEMENTATION RELATED COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 8

Enhance the Diesel Fuel Monitoring Program to Prior to GNRO-8.1.16 include a ten-year periodic cleaning and internal November 1, 2011/00093 inspection of the fire water pump diesel fuel oil 2024 tanks, the diesel fuel oil day tanks for Divisions I, II, III, and the diesel fuel oil drip tanks for Divisions I, II.

These cleanings and internal inspections will be performed at least once during the 10-year period prior to the period of extended operation and at succeeding 10-year intervals. If visual inspection is not possible, a volumetric inspection will be performed.

Enhance the Diesel Fuel Monitoring Program to include a volumetric examination of affected areas of the diesel fuel tanks if evidence of degradation is observed during visual inspection. The scope of this enhancement includes the diesel fuel oil day tanks (Divisions I, II, III), the diesel fuel oil storage tanks (Divisions I, II, III), the diesel fuel oil drip tanks (Divisions I, II), and the diesel fire pump fuel oil storage tanks, and is applicable to the inspections performed during the 10-year period prior to the period of extended operation and at succeeding 10-year intervals.

9 Enhance the External Surfaces Monitoring Program Prior to GNRO-8.1.18 to include instructions for monitoring of the aging November 1, 2011/00093 effects for flexible polymeric components through 2024 manual or physical manipulation of the material, including a sample size for manipulation of at least 10 percent of available surface area.

Enhance the External Surfaces Monitoring Program as follows.

1.

Underground components within the scope of this program will be clearly identified in program documents.

2.

Instructions will be provided for inspecting all underground components within the scope of this program during each 1O-year period, beginning 10 years prior to entering the period of extended operation.

to GNRO-2012/00114 Page 6 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 10 Enhance the Fatigue Monitoring Program to monitor Two years prior GNRO-8.1.19/ RAI and track all critical thermal and pressure transients to November 1, 2011/00093 8.1.19-1, for all components that have been identified to have 2024 RAI4.3-11 a fatigue Time Limited Aging Analysis (TLAA).

Enhance the Fatigue Monitoring Program to perform a review of the GGNS high energy line break analyses and the corresponding tracking of associated cumulative usage factors to ensure the GGNS program adequately manages fatigue usage for these locations.

Fatigue usage calculations that consider the effects of the reactor water environment will be developed for a set of sample reactor coolant system components. This sample set will include the locations identified in NUREG/CR-6260 and additional plant-specific component locations in the reactor coolant pressure boundary if they are found to be more limiting than those considered in NUREG/CR-6260. Fen factors will be determined using the formulae sets listed in Section 4.3.3. If necessary following this analysis, revised cycle limits will be incorporated into the Fatigue Monitoring Program documentation.

Enhance the Fatigue Monitoring Program to provide GNRO-updates of the fatigue usage calculations on an as-2012/00063 needed basis if an allowable cycle limit is approached, or in a case where a transient definition has been changed, unanticipated new thermal events are discovered, or the geometry of components have been modified. The program revision will include providing for the consideration of the recirculation pump fatigue analysis exemption validity if cycles that were input into the exemption evaluation exceed their limits.

to GNRO-2012/00114 Page 7 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 11 Enhance the Fire Protection Program to require Prior to GNRO-8.1.20/

visual inspections of the Halon/C02 fire November 1, 2011/00093 RAI8.1.20-suppression system at least once every fuel cycle to 2024 2

examine for signs of corrosion.

Enhance the Fire Protection Program to require visual inspections of fire damper framing at least once every fuel cycle to check for signs of degradation.

Enhance the Fire Protection Program to require visual inspection of concrete curbs, manways, hatches, manhole covers, hatch covers, and roof slabs at least once every fuel cycle to confirm that aging effects are not occurring.

Enhance the Fire Protection Program to require an GNRO-external visual inspection of the C02 tank at least 2012/00042 once every fuel cycle to examine for signs of corrosion.

to GNRO-2012/00114 Page 8 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 12 Enhance the Fire Water Program to include Prior to GNRO-8.1.21/RAI inspection of hose reels for degradation.

November 1, 2011/00093 8.1.21-5, Acceptance criteria will be enhanced to verify no

~024 8.1.21-3a unacceptable degradation.

Enhance the Fire Water Program to include one of the following options.

(1 )

Wall thickness evaluations of fire protection piping using non-intrusive techniques (e.g.,

volumetric testing) to identify evidence of loss of material will be performed prior to the period of extended operation and at periodic intervals thereafter. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

OR (2)

A visual inspection of the internal surface of GNRO-fire protection piping will be performed upon 2012/00089 each entry to the system for routine or' corrective maintenance. These inspections will be capable of evaluating (a) wall thickness to ensure against catastrophic failure and (b) the inner diameter of the piping as it applies to the design flow of the fire protection system. Maintenance history shall be used to demonstrate that such inspections have been performed on a representative number of locations prior to the period of extended operation. A representative number is 20% of the population (defined as locations having the same material, environment, and aging effect combination) with a maximum of 25 locations. Additional inspections will performed as needed to obtain this representative sample prior to the period of extended operation. The periodicity of inspections during the period of extended operation will be determined through an engineering evaluation of the operating experience gained from the results of previous inspections of fire water piping.

to GNRO-2012/00114 Page 9 of 20 IMPLEMENTATION RELATED COMMITMENT SOURCE LRASECTION SCHEDULE I AUDIT ITEM 12 Enhance the Fire Water Program to include a visual (cont.)

inspection of a representative number of locations on the interior surface of below grade fire protection piping in at least one location at a frequency of at least once every 10 years during the period of extended operation. A representative number is 20% of the population (defined as locations having the same material, environment, and aging effect combination) with a maximum of 25 locations.

Acceptance criteria will be revised to verify no unacceptable degradation.

Enhance the Fire Water Program to test or replace GNRO-sprinkler heads. If testing is chosen a representative 2012-00064 sample of sprinkler heads will be tested before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the period of extended operation. Acceptance criteria will be no unacceptable degradation. NFPA-25 defines a representative sample of sprinklers to consist of a minimum of not less than 4 sprinklers or 1 percent of the number of sprinklers per individual sprinkler sample, whichever is greater. If replacement of the sprinkler heads is chosen, all sprinklers that have been in service for 50 years will be replaced.

Enhance the Fire Water Program to include visual inspection of spray and sprinkler system internals for evidence of degradation. Acceptance criteria will be enhanced to verify no unacceotable dearadation.

13 Enhance the Flow-Accelerated Corrosion Program Prior to GNRO-8.1.22 to revise program documentation to specify that November 1, 2011/00093 downstream components are monitored closely to 2024 mitigate any increased wear when susceptible upstream components are replaced with resistant materials, such as hiah Cr material.

14 Enhance the Inservice Inspection - IWF Program to Prior to GNRO-8.1.24/ RAI address inspections of accessible sliding surfaces.

November 1, 2011/00093 8.1.24-1, 2024 3.5.1.94-1, to GNRO-2012/00114 Page 10 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 14 Enhance the Inservice Inspection - IWF Program to; GNRO-B.1.24-1a.

(cont.)

clarify that parameters monitored or inspected will 2012/00105 B.1.24-3a.

include corrosion; deformation; misalignment of B.1.24-5a supports; missing, detached, or loosened support items; improper clearances of guides and stops; and improper hot or cold settings of spring supports and constant load supports. Accessible areas of sliding surfaces will be monitored for debris, dirt, or indications of excessive loss of material due to wear that could prevent or restrict sliding as intended in the design basis of the support. Structural bolts will be monitored for corrosion and loss of integrity of bolted connections due to self-loosening and material conditions that can affect structural integrity.High-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa in sizes greater than 1 inch nominal diameter) susceptible to stress corrosion cracking (SCC) will be monitored for SCC. When a GNRO-component support is found with minor age-related 2012100114 degradation, but still is evaluated as "acceptable for continued service" as defined in IWF-3400. the program owner may choose to repair the degraded component and substitute a randomly selected component that is more representative of the general population for it in sUbseguent inspections.

Enhance the Inservice Inspection - IWF Program to clarify that detection of aging effects will include:

a) Monitoring structural bolting (American Society for Testing Materials (ASTM) A-325, ASTM F1852, and ASTM A490 bolts) and anchor bolts will be monitored for loss of material, loose or missing nuts, loss of pre-load and cracking of concrete around the anchor bolts.

b)

Volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 should be perlormed for high strength structural bolting to detect cracking in addition to the VT-3 examination. This volumetric examination may be waived with adequate plant-specific justification.

to GNRO-2012/00114 Page 11 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 14 c)

Identification of s!.Lcomponent supports that GNRO-(cont.)

contain high strength bolting (actual measured 2012/00055 yield greater than or equal to 150 ksi) in sizes GNRO-greater than 1 inch nominal diameter. The 2012/00114 extent of examination for support types that contain high-strength bolting will be as specified in ASME Code Section XI, Table IWF-2500-1.

GGNS will examine high-strength structural bolting on the frequency specified in ASME Code Section XI, Table IWF-2500-1.

Enhance the Inservice Inspection - IWF Program GNRO-acceptance criteria to include the following as 2011/00093 unacceptable conditions.

a)

Loss of material due to corrosion or wear, which reduces the load bearing capacity of the component support; b)

Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support; and c)

Cracked or sheared bolts, including high strength bolts, and anchors.

Enhance the Inservice Inspection - IWF Program GNRO-preventive action to include the following.

2012/00114 Incorporate into plant procedures recommendations delineated in NUREG-1339.

and Electric Power Research Institute (EPR!) NP-5769 and TR-1 04213 for high-strength structural bolting. These recommendations should address proper selection of bolting material, proper installation torgue or tension, and the use of aODrooriate lubricants and sealants.

to GNRO-2012100114 Page 12 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 15 Enhance the Inspection of Overhead Heavy Load Prior to GNRO-8.1.25 and Light Load Handling Systems Program to November 1, 2011/00093 include monitoring of rails in the rail system for the 2024 aging effect wear, and structural connections/bolting for loose or missing bolts, nuts, pins or rivets. Additionally, the program will be clarified to include visual inspection of structural components and structural bolts for loss of material due to various mechanisms and structural bolting for loss of preload due to self-loosening.

Enhance the Inspection of Overhead Heavy Load and Light Load Handling Systems Program acceptance criteria to state that any significant loss of material for structural components and structural bolts, and significant wear of rails in the rail system, is evaluated according to ASME 830.2 or other applicable industry standard in the ASME 830 series.

16 Implement the Internal Surfaces in Miscellaneous Prior to GNRO-8.1.26 Piping and Ducting Components Program as November 1, 2011/00093 described in LRA Section 8.1.26.

2024 17 Enhance the Masonry Wall Program to clarify that Prior to GNRO-8.1.271 RAI parameters monitored or inspected will include November 1, 2011/00093 8.1.27-1 monitoring gaps between the supports and masonry 2024 walls that could potentially affect wall qualification.

Enhance the Masonry Wall Program to clarify that detection of aging effects require masonry walls to be inspected every 5 years.

18 Implement the Non-EO Cable Connections Program Prior to GNRO-8.1.28 as described in LRA Section 8.1.28 November 1, 2011/00093 2024 to GNRO-2012/00114 Page 13 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 19 Enhance the Non environmentally Qualified (Non-Prior to GNRO-8.1.29 EQ) Inaccessible Power Cables (400V to 35kV)

November 1, 2011/00093 Program to include low-voltage (400V to 2kV) power 2024 cables.

Enhance the Non-EQ Inaccessible Power Cables (400V to 35kV) Program to include condition-based inspections of manholes not automatically dewatered by a sump pump being performed following periods of heavy rain or potentially high water table conditions, as indicated by river level.

Enhance the Non-EQ Inaccessible Power Cables (400V to 35kV) Program to clarify that the inspections will include direct observation that cables are not wetted or submerged, that cables/splices and cable support structures are intact, and that dewatering/drainage systems (i.e.,

sump pumps) and associated alarms if applicable operate properly.

20 Implement the Non-EQ Instrumentation Circuits Prior to GNRO-8.1.30 Test Review Program as described in LRA Section November 1, 2011/00093 8.1.30.

2024 21 Implement the Non-EQ Insulated Cables and Prior to GNRO-8.1.31 Connections Program as described in LRA Section November 1, 2011/00093 8.1.31.

2024 22 Enhance the Oil Analysis Program to provide a Prior to GNRO-8.1.32 formalized analysis technique for particulate November 1, 2011/00093 counting.

2024 Enhance the Oil Analysis Program to include piping and components within the main generator system (N41) with an internal environment of lube oil.

23 Implement the One-Time Inspection Program as Within the 10 GNRO-8.1.33 described in LRA Section 8.1.33.

years prior to 2011/00093 November 1, 2024 24 Implement the One-Time Inspection - Small 80re Within the 6 GNRO-8.1.34 Piping Program as described in LRA Section years prior to 2011/00093 8.1.34.

November 1, 2024 25 Enhance the Periodic Surveillance and Preventive Prior to GNRO-8.1.35 Maintenance Program to include all activities November 1, 2011/00093 described in the table provided in LRA Section 2024 8.1.35 proaram description.

to GNRO-2012/00114 Page 14 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 26 Enhance the Protective Coating Program to include Prior to GNRO-B.1.36 parameters monitored or inspected by the program November 1, 2011/00093 per the guidance provided in ASTM D5163-08.

2024 Enhance the Protective Coating Monitoring and Maintenance Program to provide for inspection of coatings near sumps or screens associated with the Emergency Core Cooling System.

Enhance the Protective Coating Program to include acceptance criteria per ASTM D 5163-08.

27 Ensure that the additional requirements of the Prior to GNRO-B.1.381 RAI ISP(E) specified in BWRVIP-86, Revision 1, November 1, 2011/00093 B.1.38-1, including the conditions of the final NRC safety 2024 B.1.38-4 evaluation for BWRVIP-116 incorporated in GNRO-BWRVIP-86, Revision 1 will be addressed before 2012/00081 the period of extended operation.

Ensure that new fluence projections through the GNRO-period of extended operation and the latest vessel 2012/00081 beltline ART Tables are provided to the BWRVIP prior to the period of extended operation.

28 Enhance the Regulatory Guide (RG) 1.127, Prior to GNRO-B.1.39 Inspection of Water-Control Structures Associated November 1, 2011/00093 With Nuclear Power Plant Program to clarify that 2024 detection of aging effects will monitor accessible structures on a frequency not to exceed 5 years consistent with the frequency for implementing the requirements of RG 1.127.

Enhance the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plant Program to perform periodic sampling, testing, and analysis of ground water chemistry for pH, chlorides, and sulfates on a frequency of at least every 5 years.

Enhance the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plant Program acceptance criteria to include quantitative acceptance criteria for evaluation and acceptance based on the auidance orovided in ACI 349.3R.

29 Implement the Selective Leaching Program as Prior to GNRO-B.1.40 described in LRA Section B.1.40.

November 1, 2011/00093 2024 30 Enhance the Structures Monitoring Program to Prior to GNRO-B.1.421 RAI clarify that the scope includes the following:

November 1, 2011100093 B.1.42-3, to GNRO-2012/00114 Page 15 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 2024 B.1.42-5, a) In-scope structures and structural components.

GNRO-2.1-4, Containment Building (GGN 2) 2012/00074 3.5.1.33-2, Control House - Switchyard B.1.13-4a, Culvert No. 1 and drainage channel B.1.42-1 a Manholes and Ductbanks Radioactive Waste Building Pipe Tunnel Auxiliary BUilding (GGN2)

Turbine Building (GGN2) b) In-scope structural components GNRO-Anchor bolts 2012-00095 Anchorage 1embedments Base plates Basin debris screen and grating Battery racks Beams, columns, floor slabs and interior walls Cable tray and cable tray supports Component and piping supports Conduit and conduit supports Containment sump liner and penetrations Containment sump structures Control room ceiling support system 30 Cooling tower drift eliminators (cont)

Cooling tower fill CST/RWST retaining basin (wall)

Diesel fuel tank access tunnel slab Drainage channel Drywell electrical penetration sleeves Drywell equipment hatch Drywell floor slab (concrete)

Drywell head Drywell head access manway Drywell liner plate Drywell mechanical penetration sleeves Drywell personnel access lock Drywell wall (concrete)

Ductbanks Electrical and instrument panels and enclosures Equipment pads/foundations Exterior walls Fan stack grating Fire proofing Flood curbs Flood retention materials (spare parts) to GNRO-2012/00114 Page 16 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM Flood, pressure and specialty doors Floor slab Foundations HVAC duct supports Instrument line supports Instrument racks, frames and tubing trays Interior walls Main steam pipe tunnel Manholes Manways, hatches, manhole covers, and hatch covers Metal siding Missile shields Monorails Penetration sealant (flood, radiation)

Penetration sleeves (mechanical/ electrical not penetrating primary containment boundary)

Pipe whip restraints Pressure relief panels Reactor pedestal Reactor shield wall (steel portion)

Roof decking Roof hatches 30 Roof membrane (cont)

Roof slabs RPV pedestal sump liner and penetrations Seals and gaskets (doors, manways and hatches)

Seismic isolation joint Stairway, handrail, platform, grating, decking, and ladders Structural bolting Structural steel, beams columns, and plates Sumps and Sump liners Support members: welds; bolted connections; support anchorages to bUilding structure Support pedestals Transmission towers (see Note 1)

Upper containment pool floor and walls Vents and louvers Weir wall liner plate Note 1: The inspections of these structures may be performed by the transmission personnel. However, the results of the inspections will be provided to the GGNS Structures Monitoring Program owner for review.

to GNRO-2012/00114 Page 17 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM c)

Clarify the term "significant degradation" to include that could lead to loss of structural integrity".

d) Include guidance to perform periodic sampling, testing, and analysis of ground water chemistry for pH, chlorides, and sulfates on a frequency of at least every 5 years.

Enhance the Structures Monitoring Program to clarify that parameters monitored or inspected include:

a) inspection for missing nuts for structural connections.

b) monitoring sliding/bearing surfaces such as Lubrite plates for loss of material due to wear or corrosion, debris, or dirt. The program will be enhanced to include monitoring elastomeric vibration isolators and structural sealants for cracking, loss of material, and hardening.

c)

Include periodically inspecting the leak chase GNRO-system associated with the upper containment 2012/00054 30 pool and spent fuel pool to ensure the tell-tales (cont.)

are free of significant blockage.

The inspection will also inspect concrete surfaces for degradation where leakage has been observed, in accordance with this Program.

Enhance the Structures Monitoring Program to GNRO-clarify that detection of aging effects will:

2011/00093 a) include augmented inspections of vibration isolators by feel or touch to detect hardening if the vibration isolation function is suspect.

b)

Require inspections every 5 years for structures GNRO-and structural components within the scope of 2012/00098 license renewal.

c) Require direct visual examinations when access GNRO-is sufficient for the eye to be within 24-inches of 2012/00054 the surface to be examined and at an angle of not less than 30° to the surface. Mirrors may be used to improve the angle of vision and accessibility in constricted areas.

d)

Soecify that remote visual examination may be to GNRO-2012/00114 Page 18 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM substituted for direct examination. For all GNRO-remote visual examinations, optical aids such as 2012/00054 telescopes, borescopes, fiber optics, cameras, or other suitable instruments may be used provided such systems have a resolution capability at least equivalent to that attainable by direct visual examination.

e)

Include instructions to augment the visual examinations of roof membranes, and seals and GNRO-gaskets (doors, manways, and hatches) with 2012/00076 physical manipulation of at least 10 percent of available surface area.

Enhance the Structures Monitoring Program acceptance criteria by prescribing acceptance GNRO-criteria based on information provided in industry 2011/00093 codes, standards, and guidelines including NEI 96-03, ACI 201.1 R-92, ANSI/ASCE 11-99 and ACI 349.3R-96. Industry and plant-specific operating experience will also be considered in the development of the acceptance criteria.

31 Enhance the Water Chemistry Control - Closed Prior to GNRO-8.1.441 RAI Treated Water Program to provide a corrosion November 1, 2011100093 8.1.44-1, inhibitor for the engine jacket water on the engine-2024 8.1.44-2 driven fire water pump diesel in accordance with industry guidelines and vendor recommendations.

Enhance the Water Chemistry Control - Closed Treated Water Program to provide periodic flushing of the engine jacket water and cleaning of heat exchanger tubes for the engine-driven fire water pump diesel in accordance with industry guidelines and vendor recommendations.

Enhance the Water Chemistry Control-Closed Treated Water Program to provide testing of the engine jacket water for the engine-driven fire water pump diesels at least annually.

Enhance the Water Chemistry Control - Closed GNRO-Treated Water Program to revise the water 2012/00049 chemistry procedure for closed treated water systems to align the water chemistry control parameter limits with those of EPRI 1007820.

to GNRO-2012/00114 Page 19 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 31 Enhance the Water Chemistry Control-Closed (cont.)

Treated Water Program to conduct inspections whenever a boundary is opened for the following systems.

Drywell chilled water (DCW - system P72)

Plant chilled water (PCW - system P71)

Diesel generator cooling water subsystem for Division I and II standby diesel generators Diesel engine jacket water for engine-driven fire water pump Diesel generator cooling water subsystem for Division III (HPCS) diesel generator Turbine building cooling water (TBCW-system P43)

Component cooling water (CCW - system P42)

These inspections will be conducted in accordance with applicable ASME Code requirements, industry standards, and other plant-specific inspection and personnel qualification procedures that are capable of detecting corrosion or cracking.

to GNRO-2012/00114 Page 20 of 20 IMPLEMENTATION RELATED COMMITMENT SCHEDULE SOURCE LRASECTION I AUDIT ITEM 31 Enhance the Water Chemistry Control-Closed (cont.)

Treated Water Program to inspect a representative sample of piping and components at a frequency of once every ten years for the following systems.

Drywell chilled water (DCW - P72)

Plant chilled water (PCW - P71)

Diesel generator cooling water subsystem for Division I and II standby diesel generators Diesel engine jacket water for engine-driven fire water pump Diesel generator cooling water subsystem for Division III (HPCS) diesel generator Turbine building cooling water (TBCW -

P43)

Component cooling water (CCW - P42)

Components inspected will be those with the highest likelihood of corrosion or cracking. A representative sample is 20% of the population (defined as components having the same material, environment, and aging effect combination) with a maximum of 25 components. The inspection methods will be in accordance with applicable ASME Code requirements, industry standards, or other plant specific inspection and personnel qualification procedures that ensure the capability of detecting corrosion or cracking.

32 Enhance the BWR CRD Return Line Nozzle Prior to GNRO-B.1.6/ RAI Program to include inspection of the CRD return line November 1, 2012/00029 B.1.6-1 nozzle inconel end cap to carbon steel safe end 2024 dissimilar metal weld once prior to the period of extended operation and every 10 vears thereafter.

33 Enhance the BWR Penetrations Program to include Prior to GNRO-B.1.8/ RAI that site procedures which implement the guidelines November 1, 2012/00029 B.1.8-1 of BWRVIP-47-A will be clarified to indicate that the 2024 guidelines of BWRVIP-47-A apply without exceptions.