ML15286A108
| ML15286A108 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/28/2015 |
| From: | Rebecca Richardson License Renewal Projects Branch 1 |
| To: | Kevin Mulligan Entergy Operations |
| Richardson R, NRR/DLR,415-2867 | |
| References | |
| DLR-15-0473, TAC ME7493 | |
| Download: ML15286A108 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 28, 2015 Mr. Kevin J. Mulligan Vice President, Site Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO. ME7493) - SET 53.
Dear Mr. Mulligan:
By letter dated October 28, 2011, Entergy Operations, Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license No. NPF-29 for Grand Gulf Nuclear Station, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.
These requests for additional information were discussed with David Lach and Richard Scarbrough, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2867 or e-mail Rebecca.Richardson@nrc.gov.
Sincerely,
/RA/
Rebecca Richardson, Project Manager Reactor Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
Requests for Additional Information cc: Listserv
ML15286A108 Document Name:ADRO\\DLR\\RRichardson\\GGNS LRA-safety RAIs set 53-10.8.15.docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box C = Copy without attach/encl, E = Copy with attach/encl, N = No copy OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:DLR PM: RPB1:DLR NAME YEdmonds RRichardson YDiaz-Sanabria RRichardson DATE 10/ 27 /15 10/ 27 /15 10/ 28 /15 10/ 28 /15
ENCLOSURE GRAND GULF NUCLEAR STATION, UNIT 1 LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION, SET 53 RAI 4.2.2-1
Background:
For the current licensing basis, updates of the P-T limits for Grand Gulf Nuclear Station, Unit 1 (GGNS) and the pressure-temperature limits report (PTLR) containing the P-T limits are performed in accordance with requirements in Technical Specification (TS) Section 5.6.6. The TS requirements specify that the methodology in Technical Report No. NEDC-33178P-A must be used to perform P-T limit updates. This TS section also establishes implementation criteria for times when updates of the P-T limits and PTLR must be performed and provided to the NRC.
Issue:
In UFSAR Supplement Section A.2.1.2, the applicant stated that updates of the P-T limits will be performed as required by 10 CFR Part 50, Appendix G. As stated above, the bases for updating the P-T limit curves and the plants PTLR are mandated by the requirements in TS Section 5.6.6. However, the UFSAR Supplement summary description in the license renewal application (LRA) Section A.2.1.2 does not reflect the existence of these TS requirements or establish how this TS section will be used to perform updates of the P-T limits using the licensing bases stated in the TS requirements.
Request:
Provide your basis why LRA Section A.2.1.2 does not specify that the updates of the P-T limits and PTLR for GGNS will be performed in accordance with the requirements in TS Section 5.6.6.
Alternatively, provide an amendment of LRA Section A.2.1.2 that specifies that updates of the P-T limits will be done in accordance with TS 5.6.6.
RAI 4.2.3-2
Background:
By letter dated July 29, 2015 (ADAMS Accession No. ML15212A747), the applicant updated the upper shelf energy (USE) analysis for GGNS, which has been identified as a TLAA for the LRA.
The updated USE analysis (i.e., LRA Table 4.2-2 and Note 10 of this table) identifies that the applicant performed an equivalent margins analysis (EMA) for a specific plate component (made from Heat No. C2779-1) in the third shell ring of the reactor pressure vessel (RPV).
The applicant identifies that the EMA was needed because the applicant could not sufficiently demonstrate that the USE value of the component would remain above or equal to 50 ft-lb (68 J) at the end of the period of extended operation.
Issue:
The letter of July 29, 2015, did not include the EMA as an enclosure or reference the plant records containing the EMA and the NRC safety evaluation issued in approval of the EMA Therefore, the staff cannot tell whether the referenced EMA was previously approved by the staff. Additionally, the submittal did not provide the USE value for the plate made from Heat No.
C2779-1 at 54 effective full power years (EFPY) in the revision of LRA Table 4.2-2.
Request:
(1) Clarify whether the EMA for the referenced RPV shell plate (as referenced in Note 10 of LRA Table 4.2-2) was submitted and approved by the NRC. If so, identify the date of the staffs safety evaluation (and if available, the ADAMS Accession No. or NRC microfiche Accession No.
associated with the safety evaluation) that approved the EMA for incorporation into the licensing basis. Identify the lower bound end-of-life USE value that was approved in the EMA for BWR RPV plate materials. (2) Identify the USE value for the shell plate made from Heat No. C2779-1 at 54 EFPY.
RAI 3.0.3-1-FWS-9
Background:
By letter dated August 19, 2015, the first enhancement shown on Attachment 2, page 11 of 21, for the Fire Water System Program was revised to state that the charcoal deluge system fire water distribution piping would be visually inspected to ensure that no flow blockage is occurring in lieu of inspecting nozzles.
Issue:
No basis was provided for inspecting the fire water distribution piping in lieu of nozzles.
Request:
State the basis for why the fire water distribution piping for the charcoal deluge system will be inspected instead of nozzles.
RAI 3.0.3-1-FWS-10
Background:
By letter dated August 19, 2015, the third enhancement shown on Attachment 2, page 13 of 21, for the Fire Water System Program was revised to address acceptance criteria when blisters are detected during coating inspections.
Issue:
This same enhancement was revised by letter dated May 20, 2015. See Attachment 2, page 8 of 10. However, the changes in the May 20, 2015, letter were not incorporated into the change shown in the August 19, 2015, letter.
Request:
Revise the enhancement to accurately reflect the complete and correct version of the proposed changes to the Fire Water System Program.
RAI 3.0.3-1-FWS-11
Background:
By letter dated August 19, 2015, a new enhancement was proposed for the Fire Water System Program. As shown on Attachment 2, page 10 of 21, this enhancement states the actions that will be taken prior to returning a fire water tank to service when an inspection has detected degraded coatings. The enhancement states that a qualified coating inspector will determine the acceptability of blisters.
Issue:
On November 14, 2014, the staff issued AMP XI.M42 Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, as part of LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks. The acceptance criteria program element of AMP XI.M42, recommends that a coating specialist, not a coating inspector, evaluate the acceptability of blisters. A coating inspector might be qualified to lesser requirements than those for a coatings specialist.
Request:
Revise the LRA to state that a coating specialist will evaluate the acceptability of blisters, or state the basis for using a qualified coating inspector in lieu of a coatings specialist to determine the acceptability of blisters.
RAI 3.0.3-3
Background:
By letter, dated August 19, 2015, the applicant proposed changes to three programs to address Requests for Additional Information associated with managing loss of coating integrity. The letter states that, [t]he enhancements to the Service Water Integrity (SWI) and Preventive Scheduling and Maintenance [Periodic Surveillance and Preventive Maintenance] Program (PSPM) are provided in Attachment 3 to this letter.
Issue:
The changes to LRA Section A.1.35, UFSAR Supplement for the Periodic Surveillance and Preventive Maintenance Program were provided in the August 19, 2015, letter. The changes to the Periodic Surveillance and Preventive Maintenance Program were not included in of the letter. The staff requires this information to complete its review.
Request:
Provide the changes that update the Periodic Surveillance and Preventive Maintenance Program.
Letter to K. Mulligan from R. Richardson dated October 28, 2015
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO. ME7493) - SET 53.
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