GNRO-2013/00083, Reply to Notice of Violation; EA-13-058
| ML13291A126 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/17/2013 |
| From: | Kevin Mulligan Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-058, GNRO-2013/00083 IR-13-201 | |
| Download: ML13291A126 (4) | |
Text
October 1 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Reply to Notice of Violation; EA-13-058
REFERENCES:
1.
Grand Gulf Nuclear Station - Inspection Report No.,05000416/2013201 and Notice of Violation, dated September 18,2013 (ADAMS Accession No. ML13133A229) 2.
Letter: Follow-up actions from teleconference held related to Pre-Decisional Enforcement Conference between NRC and Grand Gulf, dated August 8,2013 (ADAMS Accession No. ML13221A272)
Dear Sir or Madam:
In accordance with 10CFR2.201, Grand Gulf Nuclear Station hereby provides its required response to Reference (1).
The principal reason why a violation of 10CFR54.13 occurred was a lack of sufficient engagement and oversight by station personnel in the development and approval of responses to Requests for Additional Information (RAls). Two additional contributing causes were identified upon completion of a root cause analysis of the violation. The root cause analysis, and associated corrective actions, was discussed with NRC staff members during a teleconference held on August 1, 2013, and a summary document was submitted to the NRC as Attachment 5 of Reference (2) on August 8, 2013.
The necessary corrective steps to address the root and contributing causes have been completed: Grand Gulf has taken measures to ensure that station personnel provide input to, and review, all remaining correspondence relating to the License Renewal Application, and Grand Gulf has revised the governing procedures for developing NRC correspondence and management of the Flow Accelerated Corrosion program. The results achieved thus far are favorable, in that several RAls have not been required to explicate issues involving NRC review.
As with any root cause analysis, Entergy procedures require an effectiveness review to be performed at specified time intervals after the associated corrective actions have been implemented. No other future corrective steps are planned at this time.
Page 2 2
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Attachment:
Editorial corrections to Attachment 3 of letter dated August 8,2013 cc:
U.S. Nuclear Regulatory Commission ATIN: Mr. Marc Dapas (w/2)
Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission ATIN: Mr. Alan Wang, NRRlDORL (w/2)
Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
Attachment to GNRO-2013/00083 Editorial corrections to attachment 3 of letter dated August 8, 2013
[ADAMS Accession No. ML13221A272]
Further aetalls FAC loc,atl(~n #662 E21 1
to ASME SA-312, I'nrn'U:lfl't'::lrt at l¥I.~to,.t~1 on
-MI"'\\M-*!'1 was in RF13 per ER-GG-2003-Per NSAC-202L-R3 (Recommendations an Effective Flow-Accelerated Corrosion Program),
section 4.2.2 (Exclusion Systems Evaluation), some systems or portions of systems can be excluded from further evaluation due to their relatively low level of susceptibility. Lines made of stainless-steel piping or low-alloy steel piping with nominal chromium content equal to or greater than 1 X % (high content of FAC-resistant alloy) can be excluded from inspection program.
The flow characteristic of 4"-HCB-71 LPCS Minimum Flow and Test Return line is single-phase since the design, maximum, and normal temperatures of the piping are 200,185, and 95 degrees, respectively. Per MS02, Rev. 51, the design, maximum, and normal pressures of the piping are 250,230, and 200 psig, respectively. Since this line is not subject to other damage mechanisms such as cavitation and liquid impingement erosion, future inspections were excluded from the Grand Gulf inspection program in accordance with NSAC-202L guidelines.
Welding an 11'-89/16" of stainless steeI4"-HCB-71 piping between two sections of carbon steel piping sections will not introduce a galvanic corrosion problem at the bimetallic weld joints. This is due to the relatively small quantity of 4"-HCB-71 stainless steel material upstream of very large body of 14"-HBB-9 carbon steel piping. It should be noted that the carbon steel butt welded branch fitting connected at 14"-HBB-9 is much thicker than the upstream 4" stainless steel piping. Also, the Low Pressure Core Spray Minimum Flow and Test Return piping is not subject to continuous flow at all times during normal plant operation.