GNRO-2012/00119, Response to Request for Additional Information Regarding Relief Requests ISI-014, 015 and 016

Response to Request for Additional Information Regarding Relief Requests ISI-014, 015 and 016

ML12279A040
Person / Time
Site:	Grand Gulf
Issue date:	10/04/2012
From:	Perino C Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GNRO-2012/00119
Download: ML12279A040 (8)

Text

• Entergy

~~-. Entergy Operations, Inc.

P.O. Box 756 Port Gibson, Mississippi 39150 Tel: 601-437-2800 Christina Perino Licensing Manager GNRO-2012/00119 October 4, 2012 U.S. Nuclear Regulatory Commission (NRC)

Attn: Document Control Desk Washington, D.C. 20555-0001

Subject:

Grand Gulf Nuclear Station Response to Request for Additional Information Regarding Relief Requests ISI-014, 015 and 016 Grand Gulf Nuclear Station (GGNS), Unit NO.1 Docket No. 50-416 License No. NPF-29

References:

1. Grand Gulf Nuclear Station Request for Relief GG-ISI-014, GG-ISI-015 and GG-ISI-016, dated November 15, 2011 (GNRO-2011/00084) (ML113200448)

2. NRC Electronic Transmission of Questions, Request for Additional Information Regarding Relief Requests GG-ISI-014, GG-ISI-015 and GG-ISI-016, dated August 23,2012 (GNRI-2012/00188; TAC Nos. ME7592, 7593 and 7594)

Dear Sir or Madam:

Grand Gulf Nuclear Station (GGNS) requested approval of Relief Requests GG-ISI-014, GG-ISI-015 and GG-ISI-016 asking for relief from certain ASME Section XI examination requirements for the second 10-year inservice inspection (lSI) interval, in which the code of record is the 1992 edition, 1993 addenda. A Request for Additional Information (RAI) was received on August 23,2012 from the NRC with a response date of October 5,2012. Attached is GGNS's response.

This letter contains no new commitments.

If you have questions or require additional information concerning this report, please contact Mr. Ernest Rufus at (601) 437-6582.

sincere~J~

CLP~as

Attachment:

Response to Request for Additional Information (RAI) cc: (see next page)

GNRO-2012/00119 Page 2 of 2 cc:

NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U.S. Nuclear Regulatory Commission ATTN: Mr. Elmo E. Collins, Jr.

Region Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission ATTN: Mr. Alan Wang, NRR/DORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001

Attachment to GNRO-2012/00119 Response to Request for Additional Information (RAI) to GNRO-2012/00119 Page 1 of 5 GG*ISI*014

1. Do VT2 examinations currently represent the state of the art relative to examination sensitivity and dose minimization or would alternate technologies such as remote video provide better examinations?

Response

Visual inspection (VT) 2 examinations currently are performed in accordance with the ASME Section XI Code in respect to examination sensitivity per IWA-5000.

ALARA principles are implemented in accordance with Grand Gulf Nuclear Station (GGNS) Radiation Protection practices. GGNS has not attempted to use cameras or alternate technologies to perform the alternative VT-2 examinations.

2. Please estimate the difference in dose incurred during the second 10 year inspection interval between performing the examinations required by code and the VT2 exam which was actually performed.

Response

During refueling outage 18 (RF18) (third 10 year inspection interval), a qualified inspector received 17 millirem (mRem) while performing the code examination.

Although the code examination was not performed in the second 10 year inspection interval, it is expected that this dose is an acceptable estimate for the second 10 year inspection interval. During the second 10 year inspection interval, qualified inspectors received approximately 90 mRem performing the VT-2 examinations over seven outages.

3. In the licensee's submittal dated November 15, 2011, it was noted in the cover letter that the relief was submitted beyond the one year time frame specified under Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(5)(iv) and that the omission had been address in the Entergy's Correction Action Process.

a. Provide an action number, if one exists and date of the action.

Response

The failure to file the subject Requests for Relief within the one year timeframe specified under 10CFR50.55a(g)(5)(iv) was documented in the Grand Gulf Nuclear Station (GGNS) Corrective Action Process under Condition Report CR-GGN-2011-03865 which was initiated on June 6, 2011.

b. What was the reason for the lateness in submitting the requests to the NRC?

Response

The need to generate the subject Requests for Relief was inadvertently overlooked during the interval-end review process. The subject Requests should have been included with Relief Requests GG-ISI-005 through GG-ISI-012 which were developed for limited examination coverage obtained for various components. Relief Requests GG-ISI-005 through GG-ISI-012 were filed on May 29,2009.

to GNRO-2012/00119 Page 2 of 5 GG-ISI-015

1. Provide materials specifications for the welds and associated components (e.g.,

pumps and valves) for which relief is requested. Discuss which piping systems these welds belong to.

Response

The Materials for the three (3) pumps containing the subject welds were supplied per ASME Code,Section II. The pumps were constructed to the requirements of the ASME Code,Section III, Class 2. Welding operations were controlled, performed and documented to the requirements of ASME Code,Section IX.

The following table indicates the specific systems the subject pumps serve along with the associated weld and pump part material specifications:

Component 10 PUMP SYSTEM MATERIAL 01 E12C002B-SB-1 1E12C002B Residual Heat Removal System Tack/root - E7018 Final - F72-EM12K Suction Shell - SA 516 Gr 70 Suction Flange - SA 105 01 E12C002B-SB-2 1E12C002B Residual Heat Removal System Tack/root - E7018 Final - F72-EM12K Suction Shell - SA 516 Gr 70 01 E21 C001-SB-1 1E21C001 Low Pressure Core Spray System Tack/root - E7018 Final - F72-EM12K Suction Shell - SA 516 Gr 70 Suction Flange - SA 105 01 E21C001-SB-2 1E21C001 Low Pressure Core Spray System Tack/root- E7018 Final- F72-EM12K Suction Shell - SA 516 Gr70 01 E22C001-SB-1 1E22C001 High Pressure Core Spray System Tack/root - E7018 Final - F72-EM12K Suction Shell - SA 516 Gr 70 Suction FlanQe - SA 105 01 E22C001-SB-2 1E22C001 High Pressure Core Spray System Tack/root - E7018 Final - F72-EM12K Suction Shell - SA 516 Gr 70 01 E22C001-SB-3 1E22C001 High Pressure Core Spray System Tack/root- E7018 Final- F72-EM12K Suction Shell - SA 516 Gr70 to GNRO-2012/00119 Page 3 of 5

2. Clarify whether these welds were inspected during fabrication. Provide the date of fabrication and pre-service (PSI) inspection, and inspection methods. Discuss any fabrication flaws detected and repaired.

Response

Component ID Fabrication Date PSI Date Exam Method Exam Results Q1 E12COO2B-SB-1 1977 1981 Radiography No Hydrostatic relevant indications Q1 E12COO2B-SB-2 1977 1981 Radiography No Magnetic Particle relevant Hydrostatic indications Q1 E21 COO1-SB-1 1977 1981 Radiography No relevant Hydrostatic indications Q1 E21 COO1-SB-2 1977 1981 Radiography No Hydrostatic relevant indications Q1 E22COO1-SB-1 1977 1981 Radiography No Hydrostatic relevant indications Q1 E22COO1-SB-2 1977 1981 Radiography No Hydrostatic relevant indications Q1 E22COO1-SB-3 1977 1981 Radiography No Hydrostatic relevant indications

3. Clarify whether these welds have ever been inspected in service in accordance with the requirements of the ASME Code,Section XI, since commercial operation. If yes, discuss the inspection results. If no, provide technical justification for the assurance of the integrity of these welds until the next scheduled inspection.

Response

With the exception of Weld Q1E12C002B-SB-2, these welds have not been inspected in service in accordance with the requirements of the ASME Code Section XI. The integrity of subject welds is monitored continuously from the Control Room with the Leakage Detection System. Portions of Weld Q1E12C002B-SB-2 have been inspected with no indications.

4. NRC Information Notice (IN) 2011-04, "Contaminants and Stagnant Conditions Affecting Stress Corrosion Cracking in Stainless Steel Piping in Pressurized water Reactors," discusses potential stress corrosion cracking (SCC) in stainless steel piping.

to GNRO-2012/00119 Page 4 of 5

a. Provide operating pressure and temperature that these welds are exposed to.

Response

The subject welds are located in the part of the pump that experiences suction pressure. With the reactor in operation and respective systems in normal testing mode of operation, the operating pressures and temperatures for the subject pumps at the suction piping connections are shown in the following table:

PUMP PRESSURE TEMPERATURE 1E12C002B 18 psia 120 of 1E21C001 20 psia 120 of 1E22C001 20.5 psia 120 of

b. Discuss the potential for SCC in these welds.

Response

The subject welds consist of carbon steel pump base materials with carbon steel weld filler material and are therefore not considered to be susceptible to Stress Corrosion Cracking as discussed in NRC Information Notice 2011-04.

5. In the licensee's submittal dated November 15, 2011, it was noted in the cover letter that the relief was submitted beyond the one year time frame specified under 10 CFR 50.55a(g)(5)(iv) and that the omission had been address in the Entergy's Correction Action Process.

a. Provide an action number, if one exists and date of the action.

Response

The failure to file the subject Requests for Relief within the one year timeframe specified under 10CFR50.55a(g)(5)(iv) was documented in the Grand Gulf Nuclear Station (GGNS) Corrective Action Process under Condition Report CR-GGN-2011-03865 which was initiated on June 6, 2011.

b. What was the reason for the lateness in submitting the requests to the NRC?

Response

The need to generate the subject Requests for Relief was inadvertently overlooked during the interval-end review process. The subject Requests should have been included with Relief Requests GG-ISI-005 through GG-ISI-012 which were developed for limited examination coverage obtained for various components. Relief Requests GG-ISI-005 through GG-ISI-012 were filed on May 29,2009.

Attachment 1 to GNRO-2012/00119 Page 5 of 5 GG-ISI-016

1. Provide materials specifications for pump support.

Response

The Pump support material specification is ASME Section II SA-105.

2. Clarify whether these components were inspected during fabrication. Provide the date of fabrication and pre-service (PSI) inspection, and inspection methods.

Discuss any fabrication flaws detected and repaired.

Response

Component 10 Fabrication Date PSI Date Exam Method Exam Results No relevant 01 E12COO2B-S2 1977 1981 VT-3 indications

3. Clarify whether these components have ever been inspected in service in accordance with the requirements of the ASME Code,Section XI, since commercial operation. If yes, discuss the inspection results. If no, provide technical justification for the assurance of the integrity of these components until the next scheduled inspection.

Response

Portions of Support Q1E12C002B-S2 have been inspected in service in accordance with the requirements of the ASME Code Section XI with no relevant indications. The portions of the support that are inaccessible are encased in concrete and do not provide a leakage boundary to the atmosphere. Any indications within the inaccessible portion would propagate to the accessible area, where inspections are performed.

4. In the licensee's submittal dated November 15, 2011, it was noted in the cover letter that the relief was submitted beyond the one year time frame specified under 10 CFR 50.55a(g)(5)(iv) and that the omission had been address in the Entergy's Correction Action Process.

c. Provide an action number, if one exists and date of the action.

Response

The failure to file the subject Requests for Relief within the one year timeframe specified under 10CFR50.55a(g)(5)(iv) was documented in the GGNS Corrective Action Process under Condition Report CR-GGN-2011-03865 which was initiated on June 6, 2011.

d. What was the reason for the lateness in submitting the requests to the NRC?

Response

The need to generate the subject Requests for Relief was inadvertently overlooked during the interval-end review process. The subject Requests should have been included with Relief Requests GG-ISI-005 through GG-ISI-012 which were developed for limited examination coverage obtained for various components. Relief Requests GG-ISI-005 through GG-ISI-012 were filed on May 29,2009.