ML13133A229
| ML13133A229 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/11/2013 |
| From: | John Lubinski Division of License Renewal |
| To: | Mike Perito Entergy Operations |
| James Gavula 630-829-9755 | |
| References | |
| EA-13-058 IR-13-201 | |
| Download: ML13133A229 (10) | |
See also: IR 05000416/2013201
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001
June 11,2013
Mr. Michael Perito
Vice President, Site
Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION - NRC INSPECTION
REPORT 05000416/2013201
Dear Mr. Perito:
This letter refers to the evaluations by the U.S. Nuclear Regulatory Commission (NRC) Office of
Nuclear Reactor Regulation (NRR) of responses dated May 25,2012, provided by Entergy
Operations, Inc. (EOI), to requests for additional information (RAls) associated with the license
renewal application for the Grand Gulf Nuclear Station. The responses pertained to requests by
the NRC regarding the site's implementation of aging management activities for components
included in two aging management programs. The enclosed Factual Summary provides
additional details of NRC's evaluations of EOl's responses. Members of my staff including
Shahram Ghasemian, discussed details of the NRC's evaluation with members of your staff,
including Christina Perino, Director of Nuclear Safety Assurance for Grand Gulf Nuclear Station,
in a telephone conversation on April 10, 2013.
The NRC evaluation identified one apparent violation of NRC requirements that is being
considered for escalated enforcement action in accordance with the NRC Enforcement Policy.
The current Enforcement Policy is located on the NRC's web site at www.nrc.gov/about
nrc/reg u latory/enforcementlenforce-pol. htm I.
The NRC evaluation determined that EOI apparently failed to provide complete and accurate
information to the NRC in responses dated May 25, 2012, to RAls B.1.22-1, B.1.22-2, and
B.1.41-3. The three RAls addressed several issues with the aging management activities for
the Flow-Accelerated Corrosion program and the Service Water Integrity program. The license
renewal application stated that both of these programs were consistent with the corresponding
programs described in NUREG-1801, "Generic Aging Lessons Learned (GALL) Report."
However, during its reviews of operating experience associated with these programs, the staff
found indications that aspects of these programs were inconsistent with corresponding
programs in the GALL Report. Enforcement is not being considered for the statements in the
initial license renewal application, but for the apparent incomplete or inaccurate information in
the responses to RAls intended to evaluate potential inconsistencies with the programs in the
GALL Report. The RAI responses were material because the NRC needed the requested
information to verify that certain components would be adequately managed for erosion
mechanisms so that the intended functions will be maintained consistent with the current
M. Perito
- 2
licensing basis, as required by 10 CFR 54.21 (a)(3). Therefore, EOI appears to be in violation of
10 CFR 54.13. Before the NRC makes its enforcement decision, we request EOI's participation
in a predecisional enforcement conference. The conference will be open to public observation
in accordance with the NRC Enforcement Policy. Please contact Mr. Steven Bloom, Chief,
Aging Management of Plant Systems Branch, at 301-415-2431, within 10 days of the date of
this letter to notify the NRC of your willingness to participate in a predecisional enforcement
conference. In general, the NRC attempts to hold a conference within 30 days of the date of
this letter.
This conference is being held to obtain information to assist the NRC in making an enforcement
decision. The conference will afford EOI the opportunity to provide its perspective on the
apparent violation and any other information that EOI believes the NRC should take into
consideration before making an enforcement decision. The topics discussed during the
conference may include: information to determine whether a violation occurred, information to
determine the significance of a violation, information related to the identification of a violation,
and information related to any corrective actions taken or planned to be taken. In presenting
EOI's corrective actions, you should be aware that the promptness and comprehensiveness of
the actions will be considered in assessing any civil penalty for the apparent violations.
This letter is being administratively tracked as NRC Inspection Report 05000416/2013201.
Please be advised that the characterization of the apparent violation described herein may
change as a result of further NRC review. You will be advised by separate correspondence of
the results of our deliberations in this matter. In accordance with 10 CFR 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response concerning
participation in a predecisional enforcement conference will be made available electronically for
public inspection in the NRC Public Document Room or from the NRC's Agencywide
Documents Access and Management System (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction.
If you have any questions, please contact Steven D. Bloom,
Docket No. 50-416
Enclosure:
Factual Summary
M. Perito
-2
licensing basis, as required by 10 CFR 54.21 (a)(3). Therefore, EOI appears to be in violation of
10 CFR 54.13. Before the NRC makes its enforcement decision, we request EOl's participation
in a predecisional enforcement conference. The conference will be open to public observation
in accordance with the NRC Enforcement Policy. Please contact Mr. Steven Bloom, Chief,
Aging Management of Plant Systems Branch, at 301-415-2431, within 10 days of the date of
this letter to notify the NRC of your willingness to participate in a predecisional enforcement
conference. In general, the NRC attempts to hold a conference within 30 days of the date of
this letter.
This conference is being held to obtain information to assist the NRC in making an enforcement
decision. The conference will afford EOI the opportunity to provide its perspective on the
apparent violation and any other information that EOI believes the NRC should take into
consideration before making an enforcement decision. The topiCS discussed during the
conference may include: information to determine whether a violation occurred, information to
determine the significance of a violation, information related to the identification of a violation,
and information related to any corrective actions taken or planned to be taken. In presenting
EOl's corrective actions, you should be aware that the promptness and comprehensiveness of
the actions will be considered in assessing any civil penalty for the apparent violations.
This letter is being administratively tracked as NRC Inspection Report 05000416/2013201.
Please be advised that the characterization of the apparent violation described herein may
change as a result of further NRC review. You will be advised by separate correspondence of
the results of our deliberations in this matter. In accordance with 10 CFR 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response concerning
participation in a predecisional enforcement conference will be made available electronically for
public inspection in the NRC Public Document Room or from the NRC's Agencywide
Documents Access and Management System (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction.
If you have any questions, please contact Steven D. Bloom, at 301-415-2431.
Sincerely,
IRA!
John W. Lubinski, Director
Division of License Renewal
Office of Nuclear Reactor Regulation
Docket No. 50-416
Enclosure:
Factual Summary
DISTRIBUTION: See next page
ADAMS Accession No: ML13133A229
4 BC
BC:
OFFICE
LA:RPB2:DLR
NRR/DLR
NRR/DLR/RAPB BC: R-IVlDRS/EB2: BC: R-IVIDRP/RPB-C:
NAME
I Kin
J Gavula b
G Miller b mail
D Proulx b mail
DATE
5/21/13
5/22/13
5/23/13
5/28/13
NRR/DORLlLPL
NRR/DLR
S
MSimon
J Lubinski
N Hilton
5/29/13
6/11/13
6/7113
OFFICIAL RECORD COpy
Letter to M. Perito from J. Lubinski dated June 11, 2013
SUBJECT:
GRAND GULF NUCLEAR STATION-NUCLEAR REGULATORY COMMISSION
INSPECTION REPORT 05000416/2013201
DISTRIBUTION:
ELeeds
JUhle
DOorman
HNieh
AHowe
DWiliis
MHalter
RCarpenter
...ILubinski
DPelton
SBloom
JGavula
LLund
DORLPM
RBrowder
GMiller
DProulx
BHager
RKumana
RSmith
BRice
FACTUAL SUMMARY OF RESPONSES TO REQUESTS
FOR ADDITIONAL INFORMATION
Background Information:
By letter dated October 28, 2011, Entergy Operations, Inc. (EOI), applied for a renewed license
and submitted a license renewal application (LRA) for the Grand Gulf Nuclear Station (GGNS)
pursuant to 10 CFR 54.17(a). In the application, EOI described its aging management
programs, including the Service Water Integrity Program and the Flow-Accelerated Corrosion
(FAC) Program. The application states that both programs are consistent with corresponding
programs described in NUREG-1801, "Generic Aging Lessons Learned (GALL) Report."
During the week of January 23, 2012, members of the NRC staff conducted an onsite audit of
the program basis documents for the aging management programs at the GGNS facility.
Generically speaking, the purpose of the staff's review is to verify that an applicant has
demonstrated that the effects of aging will be adequately managed during the period of
extended operation, as required by 10 CFR 54.21 (a)(3). Based on its onsite audit and ongoing
review of the GGNS LRA, the NRC staff identified areas where it needed additional information
to complete its review of the Service Water Integrity program and the FAC program. The staff
subsequently issued several requests for additional information (RAls) to EOI.
RAI B.1.41-3, Service Water Integrity Aging Management Program
LRA Section B.1.41 describes the Service Water Integrity program as an existing program that
manages loss of material as described in the EOI response to NRC Generic Letter (GL) 89-13,
"Service Water System Problems Affecting Safety-Related Components." The staff noted that
the EOI response to NRC GL 89-13 states that the standby service water system does not meet
the criteria for being included in erosion/corrosion monitoring. During reviews of condition
reports (CRs) related to aging degradation, the staff identified CR GGN-201 0-01344 which
discussed minor erosion/corrosion of a component in the standby service water system and
proposed that the associated section of the system should be included in an "appropriate piping
program (i.e., [GGNS-] MS-46, [(,Program Plan for Monitoring Internal Erosion/Corrosion in
Moderate Energy Piping Components')], Moderate Energy Piping)."
The program basis documents neither included a copy of nor referred to GGNS-MS-46. At the
staff's request, EOI provided a copy of GGNS-MS-46. Based on the information in the above
CR, the staff issued RAI B.1.41-3 to EOI by letter dated April 26, 2012, asking 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 the GGNS-MS-46, Moderate Energy Piping
program. In its response dated May 25, 2012, EOI stated:
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. As stated in LRA Section B.1.41, the Service Water Integrity Program is consistent with the program described in
NUREG-1801 XI.M20, Open Cycle Cooling Water System, without exception. This
program addresses the aging effects of loss of material and fouling for the standby
service water system, as described in the GGNS response to NRC GL 89-13.
The guidance of NRC GL 89-13 has been implemented for more than 20 years and has
been effective in managing aging effects due to biofouling, corrosion, erosion, protective
ENCLOSURE
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coating failures, and silting in structures and components serviced by open-cycle cooling
water systems.
In parallel with the above issue, the staff noted that GGNS-MS-46 defines "erosion/corrosion"
almost identically to how EI'J-DC-315, "Flow-Accelerated Corrosion Program," defines
"flow-accelerated corrosion." In that regard EN-DC-315 states that "flow-accelerated corrosion"
was previously known as "erosion/corrosion." By letter dated April 25, 2012, the staff issued
RAI B.1.22-3 asking about the Clging effects being managed by GGNS-MS-46 and how it related
to or integrated with the Flow-Accelerated Corrosion Program. In its response dated
May 25,2012, EOI stated:
The inspections described in GGNS-MS-46 are not credited as an aging management
program for license renewal. These inspections 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 programs 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.
Based on the apparent conflicting information provided in the above responses to RAI B.1.41-3
and RAI B.1.22-3, the staff questioned the accuracy of the information in RAI B.1.41-3.
Consequently, the staff issued follow-up RAI B.1.41-3a asking whether the inspections specified
in GGNS-MS-46 are or are not credited in the Service Water Integrity Program, and to provide
information regarding all components being monitored for erosion/corrosion to demonstrate that
these monitoring activities are credited by an aging management program. In its response
dated October 2, 2012, EOI stated:
a. As stated in the response to RAI B.1.41-3, site procedure GGNS-MS-46 is not an aging
management program. As stated in LRA Section B.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 B.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 GGI'JS 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.
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In addition, since the GGNS response to GL 89-13 states that the standby service water system
does not meet the criteria for inclusion in erosion/corrosion monitoring, and the GGNS LRA only
describes the Service Water Integrity Program as managing components as described in its
GL 89-13 response, the description of the Service Water Integrity Program in the LRA is
incomplete because it does not address the ongoing erosion/corrosion inspections performed
through GGNS-MS-46. Further, the LRA does not contain any aging management review items
that address loss of material due to erosion for any systems where the ongoing
erosion/corrosion inspections performed through GGNS-MS-46 are being credited.
Based on the information provided in the follow-up RAI, the staff determined that EOI provided
inaccurate information in its response to RAI B.1.41-3, by stating that GGNS-MS-46 is not
necessary or credited to manage the effects of aging for components in the Service Water
Integrity Program.
RAI B.1.22-1. Flow-Accelerated Corrosion Program (Scope)
LRA Section B.1.22 describes the FAC Program as an existing program that follows the
guidelines published by EPRI in NSAC-202L and is consistent with the corresponding program
in the GALL Report. The staff notes that the corresponding program in the GALL Report also
follows NSAC-202L, and that NSAC-202L only considers wall thinning caused by flow
accelerated corrosion and does not consider other wall thinning mechanisms such as cavitation
or erosive wear.
As part of the onsite audit documents, EOI provided Calculation MC-Q1111.0811. "Evaluation of
RF16 Flow-Accelerated Corrosion Wall Thickness Data," to show how wall thickness data
obtained through inspections during refueling outage 16 were evaluated for components
inspected by the program. The "System(s)" block on the calculation cover page gives system
designations that included the low pressure core spray (LPCS) and high pressure core spray
(HPCS) systems, indicating that the FAC Program managed wall thinning in these systems.
However, the System Susceptibility Evaluation for the FAC Program states that these two
systems are not susceptible to FAC. In addition. the LRA tables containing aging management
review items for these systems did not include any items that were being managed by the FAC
Program. In order to resolve this disparity, by letter dated April 25. 2012, the staff issued
RAI B.1.22-1 asking EOI to revise all the appropriate sections and tables in the LRA to reflect
that the FAC Program manages aging effects in the low pressure core spray and high pressure
core spray systems. The staff also requested that EOI verify that no other systems were
similarly missed.
In it response dated May 25, 2012, EOI stated:
a. LRA Section 3.2.2.1.2, "Low Pressure Core Spray," and Section 3.2.2.1.3, "High
Pressure Core Spray," correctly do not identify wall thinning due to flow accelerated
corrosion (FAC) as an aging mechanism. These systems are not susceptible to this
aging mechanism since they experience single-phase flow above 200 degrees
Fahrenheit for less than 2 percent of the time. The referenced calculation
MC-Q111 08011 listed the time in service for these systems confirming the conclusion
that the FAC program is not required to manage wall thinning in the low pressure core
spray and high pressure core sprays systems. As a result, wall thinning due to flow
accelerated corrosion is not an aging effect requiring management for these systems,
and no LRA revision is required.
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b. Each plant system was evaluated for susceptibility to wall thinning due to flow
accelerated corrosion. Criteria such as material, superheated steam flow, single phase
flow at low temperature and limited operating time were considered. The conclusion of
the evaluation for each system within the scope of license renewal was used to
determine the application of this aging mechanism. No other systems have aging effects
being managed by the Flow-Accelerated Corrosion Program that were not identified in
the LRA.
However, based on detailed information obtained during its onsite audit indicating that specific
components in the LPCS and HPCS systems were being monitored through the FAC Program,
the staff questioned the accuracy of the information in RAI B.1.22-1. Consequently, the staff
issued follow-up RAI B.1.22-1 a asking EOI to determine whether the inspections conducted by
the FAC Program were for wall thinning due to FAC or for some other wall-thinning mechanism.
In its response dated October 2, 2012, EOI stated:
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.
The staff noted that the response added aging management review items in the LPCS, HPCS,
control rod drive (CRD), fuel pool cooling and cleanup, CRD hydraulic, floor equipment and
drain, condensate cleanup, main turbine and auxiliaries, and turbine bypass systems to account
for the use of the FAC Program for managing other wall-thinning mechanisms. Based on the
information provided in the follow-up RAI, the staff determined that EOI provided inaccurate
information in its response to RAI B.1.22-1, by stating that wall thinning due to FAC is not an
aging effect requiring management for the LPCS and HPCS systems, and that there are no
other systems being managed by the FAC Program that were not identified in the LRA. Since
the GGNS FAC Program manages wall thinning due to mechanisms other than FAC, the
program is inconsistent with the program described in the GALL Report. The description of the
program in the LRA Section B.1.22 is incorrect, and the LRA does not contain the aging
management review items to reflect the aging management activities being performed at
GGNS.
RAI B.1.22-2, Flow-Accelerated Corrosion Program (Implementation)
LRA Section 8.1.22 describes the FAC Program as an existing program that follows the
guidelines published by EPRI in NSAC-202L and is consistent with the corresponding program
in the GALL Report. NSAC-202L discusses the need to take various actions whenever
inspections detect "significant wear." These actions include examining addition components
downstream or upstream of the initial component, additional components in the same train and
corresponding components in other trains. GGNS Procedure EN-DC-315, "Flow-Accelerated
Corrosion Program," Section 5.11, "Components Failing to Meet Initial Screening Criteria,"
states that a condition report shall be generated when "significant wall thinning," as defined in
the procedure, is detected. However, during the audit, a search of CRs generated during recent
outages only identified CRs where wall thinning was reported to be below the minimum
acceptable wall thickness, and none appeared to report "significant wall thinning," which is a
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precursor condition when the wall thickness is above the minimum acceptable value. By letter
dated April 25, 2012, the staff issued RAI B.1.22-2 requesting EOI to confirm that significant wall
thinning, as defined in EN-OC-315, had not been detected, and that CRs were not required to
be generated in recent outages.
In its response dated May 25,2012, the applicant 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-OC-315 were required to be generated.
However, during its audit, the staff had obtained data from recent inspections and, after
performing independent calculations, identified several instances, specifically item 314a,
item 353, and item 795, where the measured wall thickness was less than 60 percent of nominal
pipe wall thickness, which meets the criteria for "significant wall thinning" in EN-DC-315. Based
on this, the staff questioned the accuracy of the information provided in response to
RAI B.1.22-2. In order to resolve this issue, by letter dated September 5, 2012, the staff issued
RAI B.1.22-2a, requesting EOI to re-verify that that significant wall thinning, as defined in
EN-DC-315, had not been detected and that CRs were not required to be generated in recent
outages.
In its response dated October 2, 2012, the EOI stated:
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.
Based on the information provided in response to the follow-up RAI, the staff determined that
EOI provided inaccurate information in its response to RAI 8, 1.22-2, by stating that no
significant wall thinning had been detected and that no additional condition reports on significant
wall thinning as defined in EN-OC-315 were required to be generated. Based on the information
in the follow-up response, significant wall thinning had been detected contrary to GGNS'
assertion.
Based upon NRR's evaluation of the information, EOI appears to have provided incomplete and
inaccurate information to the NRC in responses to RAls 8, 1.41-3, B.1.22-1 and B.1.22-2.
These actions appear to have placed EOI in violation of 10 CFR 54.13, which requires that
information provided to the Commission by an applicant for a renewed license must be
complete and accurate in all material respects.
Telephone Briefing
On April 10, 2013, NRC staff members discussed the above details with staff members of the
GGNS and other EOI personnel, during a telephone briefing. In addition, during a telephone
briefing on April 15, 2013, GGNS and EOI staff provided to NRC staff members the licensee's
perspective on the apparent violations. During that briefing, C. Robinson, licensing manager at
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GGNS, stated that the site wanted to participate in a predecisional enforcement conference for
this matter.
KEY POINTS OF CONTACT
EOI Personnel
C. Perino, Director Nuclear Safety Assurance, GGNS
C. Robinson, Licensing Manager, GGNS
L. Patterson, Engineering Programs Manager, GGNS
L. Henderson, Flow-Accelerated Corrosion Engineer, GGNS
T. Ivy, Arkansas License Renewal Office, License Renewal Manager for GGNS
A. Taylor, Arkansas License Renewal Office, Engineering Supervisor for License Renewal
A. Cox, Arkansas License Renewal Office, License Renewal Project Manager for GGNS
A. Smith, White Plains Office, Technical Specialist (FAC)
NRC Personnel
S. Bloom, Acting Chief, Aging Management of Plant Systems Branch (RAPB)
J. Gavula, Mechanical Engineer
G. Pick, Senior Reactor Inspector, RIV
R. Smith, Senior Resident Inspector, GGNS
B. Rice, Resident Inspector, GGNS