View source for GNRO-2015/00079, Responses to Request for Additional Information (RAI) Set 53, Dated October 28, 2015

{{Adams
| number = ML15327A181
| issue date = 11/23/2015
| title = Responses to Request for Additional Information (RAI) Set 53, Dated October 28, 2015
| author name = Mulligan K
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000416
| license number = NPF-029
| contact person = 
| case reference number = GNRO-2015/00079
| document type = Letter type:GNRO, Response to Request for Additional Information (RAI)
| page count = 28
| project = 
| stage = Response to RAI
}}

=Text=
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~Entergy                                                                        Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2015/00079 November 23,2015 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Responses to Request for Additional Information (RAI) Set 53, dated October 28, 2015 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

==REFERENCES:==
: 1. Entergy Letter GNRO-2014/00076, "Response to Request for Additional Information (RAI) Set 51" dated November 6,2014
: 2. U.S. NRC Letter, "Request for Additional Information for the Review of Grand Gulf Nuclear Station, License Renewal Application, Set 52" dated April 6, 2015 (GNRI-2015/00020)
: 3. Entergy Letter GNRO-2015/00034, "Response to Request for Additional Information (RAI) Set 52" dated May 20, 2015
: 4. U.S. NRC Letter, "Summary of Telephone Conference Call Held On June 18, 2015, Between The U.S. NRC And Entergy Concerning Request For Additional Information Responses, Pertaining To The Grand Gulf Nuclear Station License Renewal Application (TAC NO. ME7493)
: 5. Entergy Letter GNRO-2015/00048, "Response to License Renewal Amendment Request for Additional Information (RAI) Set 47, Question 4.2.1-2c (5) (b)", dated July 29,2015
: 6. Entergy Letter GNRO-2015/00055, "Responses to Request for Additional Information (RAI) Set 52, RAls 3.0.3-1-FWS-2a and 3.0.3-2b", dated August 19, 2015
: 7. U.S. NRC Letter, "Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC NO.
ME7493) - SET 53", dated October 28,2015 (GNRI-2015/00125)

==Dear Sir or Madam:==

Entergy Operations, Inc. is providing, in the Attachment, responses to the referenced Request for Additional Information, Set 53, dated October 28, 2015.
This letter contains changes to the License Renewal Application and changes to existing commitments as documented in the Attachment.

GNRO-2015/00079 Page 2 of2 If you have any questions or require additional information, please contact James Nadeau at 601-437 -2103.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23 rd day of November, 2015.
Sincerely,
~)lio"'----
KJM/ras

==Attachment:==
Response to Requests for Additional Information (RAI), Set 53 cc: with Attachment U.S. Nuclear Regulatory Commission ATTN: Ms. Rebecca Richardson, NRR/DLR Project Manager Office of License Renewal Mail Stop 0-11 F1 Washington, DC 20555 cc: without Attachment U.S. Nuclear Regulatory Commission ATTN: Mr. Mark Dapas 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 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2015/00079 Response to Requests for Additional Information (RAI), Set 53

Attachment to GNRO-2015/00079 Page 1 of 25 The format for the Requests for Additional Information (RAI) responses below is as follows: The RAI is provided 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 questions.
RAI 3.0.3 1 FWS-9

===Background===
By letter dated August 19,2015, the first enhancement shown on Attachment 2, page 11 of21, 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.
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.
RAt 3.0.3 1 FWS-9 Response The basis for revising the wording in the subject enhancement to "inspecting the charcoal filter deluge fire water distribution piping" instead of "inspecting the charcoal filter deluge nozzles" is the wording in the vendor manuals for in-scope charcoal filtration units. It was determined that the phrase "fire water distribution piping" within the charcoal filter units was more appropriate than "nozzles" based on vendor manual wording. Regardless of the configuration, a visual observation of the fire water distribution piping within the charcoal filter units is performed whenever the charcoal is replaced, and air testing every refueling cycle ensures there is no flow blockage.

Attachment to GNRO-2015/00079 Page 2 of 25 RAt 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.
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.
RAt 3.0.3 1 FWS-10 Response The 3rd enhancement in Attachment 2 of the August 19, 2015 (reference 6) letter (Page 13 of
: 21) has been replaced with the enhancement in Attachment 2 of the May 20, 2015 (reference
: 3) letter (page 8 of 10). The LRA revisions are provided below with additions underlined and deletions marked through. The revisions are shown as changes from the version included in the August 19, 2015 letter.
LRA Appendix A.1.21
* Revise the Fire Water System Program procedures to-add-include the following acceptance criteria for loss of coating integrity: (1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to a few intact small blisters that are completely surrounded by sound coating bonded to the surface. Coatings that do not meet the acceptance citeria 'Nill be repaired or replaced.
: 1. Indications of peeling and delamination are not acceptable.
: 2. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g .. reference ASTM 0714-02. "Standard Test Method for Evaluating Degree of Blistering of Paints'').

Attachment to GNRO-2015/00079 Page 3 of 25
: 3. Indications such as cracking. flaking. and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: 4. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: 5. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: 6. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.
LRA Appendix A.4 Commitment #12 Revise the Fire Water System Program procedures to aeainclude the following acceptance criteria for loss of coating integrity(1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to a few intact small blisters that are completely surrounded by sound coating bonded to the surface. Coatings that do not meet the acceptance citeria will be repaired or replaced.
: a. Indications of peeling and delamination are not acceptable.
: b. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g .. reference ASTM 0714-02. "Standard Test Method for Evaluating Degree of Blistering of Paints").
: c. Indications such as cracking. flaking. and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: d. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: e. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: f. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coatingllining and substrate.

Attachment to GNRO-2015/00079 Page 4 of 25 LRA Appendix 8.1.21
: 6. Acceptance Criteria Revise the Fire Water System Program procedures to addinclude the following acceptance criteria for loss of coating integrity(1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to a te'"fJ intact small blisters that are completely surrounded by sound coating bonded to the surface. Coatings that do not meet the acceptance citeria 'I/ill be repaired or replaced.
: a. Indications of peeling and delamination are not acceptable.
: b. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coatingllining bonded to the substrate.
Blister size and frequency should not be increasing between inspections (e.g.,
reference ASTM 0714-02, "Standard Test Method for Evaluating Degree of Blistering of Paints").
: c. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: d. Minor cracking and spalling of cementitious coatingsllinings is acceptable provided there is no evidence

Attachment to GNRO-2015/00079 Page 5 of 25 that the coatingllining is debonding from the base material.
: e. As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
: f. Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.

Attachment to GNRO-2015/00079 Page 6 of 25 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.
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 ofLR 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 1 FWS-11 Response The LRA is revised to state that a coating specialist will evaluate the acceptability of blisters.
The LRA revisions are provided below with additions underlined and deletions marked through.
The revisions are shown as changes from the version included in the August 19, 2015 letter.
LRA Appendix A.1.21
* Revise the Fire Water System Program procedures to ensure a fire water tank is not returned to service after identifying interior coating blistering, delamination or peeling unless there are only a few small intact blisters surrounded by coating bonded to the substrate as determined by a qualified coating specialistinspector, or the following actions are performed.
: 1. Any blistering in excess of a few small intact blisters, or blistering not completely surrounded by coating bonded to the substrate is removed,
: 2. Any delaminated or peeled coating is removed,
: 3. The exposed underlying coating is verified to be securely bonded to the substrate as determined by an adhesion test endorsed by RG 1.54 at a minimum of three locations,
: 4. The outermost coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via an adhesion test endorsed by Reg.

Attachment to GNRO-2015/00079 Page 7 of 25 Guide 1.54 at a minimum of three locations adjacent to the defective area,
: 5. Ultrasonic testing is performed where there is evidence of pitting or corrosion to ensure
      .the tank meets minimum wall thickness requirements,
: 6. An evaluation is performed to ensure downstream flow blockage is not a concern, and
: 7. A follow-up inspection is scheduled to be performed within two years and every two years after that until the coating is repaired, replaced, or removed.
LRA Appendix A.4 Commitment #12
* Revise the Fire Water System Program procedures to ensure a fire water tank is not returned to service after identifying interior coating blistering, delamination or peeling unless there are only a few small intact blisters surrounded by coating bonded to the substrate as determined by a qualified coating specialistinspectoF, or the following actions are performed.
: 8. Any blistering in excess of a few small intact blisters, or blistering not completely surrounded by coating bonded to the substrate is removed,
: 9. Any delaminated or peeled coating is removed,
: 10. The exposed underlying coating is verified to be securely bonded to the substrate as determined by an adhesion test endorsed by RG 1.54 at a minimum of three locations,
: 11. The outermost coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via an adhesion test endorsed by Reg.
Guide 1.54 at a minimum of three locations adjacent to the defective area,
: 12. Ultrasonic testing is performed where there is evidence of pitting or corrosion to ensure the tank meets minimum wall thickness requirements,
: 13. An evaluation is performed to ensure downstream flow blockage is not a concern, and
: 14. A follow-up inspection is scheduled to be performed within two years and every two years after that until the coating is repaired, replaced, or removed.
LRA Appendix 8.1.21
: 4. Detection of Aging Effects            Revise the Fire Water System Program procedures to ensure a fire water tank is not returned to service after identifying interior coating blistering, delamination or peeling unless there are only a few small intact blisters surrounded by coating bonded to the substrate as determined by a qualified coating specialistinspectoF, or the following actions are performed.
: 1. Any blistering in excess of a few small intact blisters, or blistering not completely

Attachment to GNRO-2015/00079 Page 8 of 25 surrounded by coating bonded to the substrate is removed,
: 2. Any delaminated or peeled coating is removed,
: 3. The exposed underlying coating is verified to be securely bonded to the substrate as determined by an adhesion test endorsed by RG 1.54 at a minimum of three locations,
: 4. The outermost coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via an adhesion test endorsed by Reg. Guide 1.54 at a minimum of three locations adjacent to the defective area,
: 5. Ultrasonic testing is performed where there is evidence of pitting or corrosion to ensure the tank meets minimum wall thickness requirements,
: 6. An evaluation is performed to ensure downstream flow blockage is not a concern, and
: 7. A follow-up inspection is scheduled to be performed within two years and every two years after that until the coating is repaired, replaced, or removed.

Attachment to GNRO-2015/00079 Page 9 of 25 RAI3.0.3-3

===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."
The changes to LRA Section A.l.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 Attachment 3 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.
RAI 3.0.3-3 Response LRA Section 8.1.35 is revised to update the description of the Periodic Surveillance and Preventive Maintenance Program. The changes conform to the changes to LRA Section A.1.35 provided in the August 19, 2015 letter (reference 6). The revisions are shown as changes from the version included in the May 13, 2014 and November 16, 2014 letters with additions underlined and deletions marked through.
In addition to the above, acceptance criteria are added to LRA Section A.1.35 (see page 21 of this attachment) with additions underlined and deletions marked through.
8.1.35 Periodic Surveillance and Preventive Maintenance Program Program Description There is no corresponding NUREG-1801 program.
The Periodic Surveillance and Preventive Maintenance Program is an existing program that manages aging effects not managed by other aging management programs, including loss of material due to erosion, loss of coating integrity, cracking, loss of material due to recurring' internal corrosion, and change in material properties.

Attachment to GNRO-2015/00079 Page 10 of 25 Inspections occur at least once every five years during the period of extended operation. with the exception of inspections of MIC and coating inspections for which frequency is based on inspection results. Visual or other NDE inspections of components in the low pressure core spray, residual heat removal. pressure relief, reactor core isolation cooling, high pressure core spray. and floor and equipment drains systems and the containment building gaskets/seals are performed every five years. Visual or other NDE inspections of a representative sample of internal surfaces of components in the control rod drive. circulating water. and floor and equipment drains systems are performed every five years.
UT or RT wall thickness measurements of selected components of the circulating water, standby service water, plant service water and fire protection systems are performed periodically as necessary to assure minimum pipe wall thickness is maintained. The most susceptible locations will be selected for inspection based on pipe configuration, flow conditions, and operating history. A minimum of five MIC degradation inspections in the collective set of systems will be performed per cycle until MIC no longer meets the criteria for recurring internal corrosion. The scope of MIC examinations will be expanded if substantial MIC is detected during inspections. Scope expansion includes consideration of other locations for additonal sampling such as similar components in the same or redundant trains. Substantial MIC is considered an increased rate of detection of new MIC sites. increased rates of wall thinning at known sites, or unexpected piping wall loss that results in wall thickness near or below code minimum wall thickness.
During the 10-year period prior to the period of extended operation, visual inspections will be performed of coated internal surfaces. Subsequent coating inspections will be performed based on inspection results as follows.
: i.      If no peeling, delamination. blisters, or rusting are observed, and any cracking and flaking has been found acceptable, subsequent inspections will be performed at least once every 6 years. If the coating is inspected on one train and no indications are found.
and if the redundant train has the same coating and turbulent flow is not present. then the redundant train need not be inspected during that inspection interval.
ii. If the inspection results do not meet 0) and a coating specialist has determined that no remediation is required, then subsequent inspections will be conducted on an every other refueling outage interval.
iii. If the inspection results do not meet 0) and a coating specialist determines remediation is required, then the coated components can only be returned to service if the following actions are performed (1) any blistering in excess of a few small intact blisters. or blisters not completely surrounded by coating bonded to the substrate is removed. (2) any delaminated or peeled coating is removed, (3) the exposed underlying coating is verified to be securely bonded to the substrate at a minimum of three locations as determine by adhesion testing endorsed by Regulatory Guide (RG) 1.54 adjacent to the defective area. (4) the outer most coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via adhesion testing endorsed by RG 1.54. (5) ultrasonic testing is performed to ensure the component meets the

Attachment to GNRO-2015/00079 Page 11 of 25 minimum wall thickness requirements. (6) an evaluation is performed within two years and every two years until the coating is repaired, replaced or removed.
During the 10-year period prior to the period of extended operation, visual inspections will be performed of internally coated surfaces for components in this program. A qualified coating specialist will determine which of the following methods should be used to determine the condition of the coating and the condition of the component under the degraded coating when conditions such as cracking, peeling, blisters, delamination, rust or flaking are identified during the visual examination.
: 1. Lightly tapping and scraping the coating to determine the coating integrity.
: 2. Wet-sponge testing or dry film testing to identify holidays in the coating.
: 3. Adhesion testing in accordance with ASTM 03359, ASTM 04541, or equivalent testing endorsed by RG 1.54 at a minimum of three locations adjacent to the defective area ..
: 4. Ultrasonic testing to determine if the component's wall thickness meets the minimum thickness criteria.
Coating inspections will cover all accessible internal coated surfaces of applicable tanks and heat exchangers. For areas not readily accessible for direct inspection, such as small pipe lines, heat exchangers and other equipment consideration will be given to the use of remote or robotic inspection tools. For internal coatings of piping. inspections will cover 50 percent of accessible coated piping within the system or a minimum of 73 locations of 360 degrees of one linear foot for each combination of type of coating, material the coating is protecting, and environment.
Inspection locations of coated piping will be based on coating degradation susceptibility, operating experience, vendor recommendation and safety significance.
Individuals performing coating inspections are certified to ANSI N45.2.6. "Qualifications of Inspection, Examination. and Testing Personnel for Nuclear Power Plants," and shall be required to review at least two previous inspection report is available. A nuclear coatings subject matter experts qualified in accordance with ASTM 07108-05. "Standard Guide for Establishing Qualifications for a Nuclear Coatings Specialist." evaluate inspection findings and prepare post-inspection reports. Coating inspection reports will include lists of locations identified with coating degradation including, where possible, photographs indexed to inspection location, and a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where coating repair can be postponed to a subsequent inspection or repair opportunity.
Loss of coating integrity acceptance criteria:
: 7. Indications of peeling and delamination are not acceptable.
: 8. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with

Attachment to GNRO-2015/00079 Page 12 of 25 use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coatingllining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g.. reference ASTM D714-02. llStandard Test Method for Evaluating Degree of Blistering of Paints").
: 9. Indications such as cracking. flaking. and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: 10. Minor cracking and spalling of cementitious coatingsllinings is acceptable provided there is no evidence that the coatingllining is debonding from the base material.
: 11. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: 12. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coatingllining and substrate.
In the event the base metal is exposed and the visual inspection identifies corrosion, this inspection finding will be entered into the Corrective Action Program. An evaluation will confirm the component remains acceptable for continued service. As necessary. a volumetric examination will be performed to ensure there is sufficient wall thickness so that the component remains capable of performing its intended function. If repair or replacement of the coating is postponed. the evaluation will consider the minimum wall thickness requirements and the rate of corrosion and confirm the component remains acceptable for continued service until the next inspection or repair opportunity. which will be within two years.
Credit for program activities has been taken in the aging management review of the following systems and structures.
Containment                Visually inspect and manually flex the rubber gasket/seal for Building                   upper containment pool gates to verify the absence of cracks and significant change in material properties.
Low pressure core          Use visual or other NDE techniques to inspect external spray system               surface of LPCS piping passing through the waterline region (LPCS)                     of suppression pool to manage loss of material.
Residual heat              Use visual or other NDE techniques to inspect external removal (RHR)              surface of RHR piping passing through the waterline region system                     of suppression pool to manage loss of material.
Pressure relief            Use visual or other NDE techniques to inspect external system                     surface of pressure relief system piping passing through the waterline region of the suppression pool to manage loss of material.

Attachment to GNRO-2015/00079 Page 13 of 25 Reactor core        Use visual or other NDE techniques to inspect external isolation cooling   surfaces of RCIC system piping passing through the (RCIC) system       waterline region of the suppression pool to manage loss of material.
Non-safety-related  Visually inspect the internal surfaces of a representative systems affecting   sample of piping in the control rod drive (CRD) system to safety-related      manage loss of material.
systems             Visually inspect the internal surfaces of a representative sample of piping and valve bodies in the circulating water system (N71) to manage loss of material.
Visually inspect the internal surfaces of a representative sample of piping and valve bodies in the floor and equipment drain system (P45) to manage loss of material.
Use visual or other NDE techniques to inspect the internal surfaces of the piping adjacent to the high pressure, intermediate pressure, and low pressure condenser shells in the circulating water system (N71) to manage loss of material due to erosion.
Use visual or other NDE techniques to inspect the internal surfaces of the moisture separator-reheater in the moisture separator-reheater vents and drains system (N35) to manage loss of material due to erosion.
High pressure core  Use visual or other NDE techniques to inspect HPCS piping spray (HPCS)        passing through the waterline region of the suppression pool system              to manage loss of material.
Floor and equipment Use visual or other NDE techniques to inspect piping below drain system        the waterline in the in-scope sumps to manage loss of material.
Visually inspect the internal surfaces of a representative sample of piping, drain housings, and valve bodies in the floor and equipment drain system (P45) to manage loss of material.

Attachment to GNRO-2015/00079 Page 14 of 25 Circulating water    Perform wall thickness measurements using UT or RT at system               selected locations to identify loss of material due to Standby service      microbiologically influenced corrosion (MIC) in piping water system         components of these systems that are included in the scope Plant service water  of license renewal.
system               Select for inspection the most susceptible locations based Fire protection      on pipe configuration, flow conditions and operating history.
system               Periodically review the selected locations to validate their relevance and usefulness, and modify accordingly. Compare wall thickness measurements to determine rates of corrosion degradation. Compare wall thickness measurements to code minimum wall thickness plus margin for corrosion during the refueling cycle(T marg) to determine acceptability of the component for continued use. Perform subsequent wall thickness measurements as needed for each selected location based on the rate of corrosion and expected time to reach (T marg). Perform a minimum of five MIC degradation inspections in the collective set of systems per refueling cycle until MIC no longer meets the criteria for recurring internal corrosion. The scope of MIC examinations will be expanded if substantial MIC is detected during inspections. Scope expansion includes consideration of other locations for additional sampling such as similar components in the same or redundant trains. Substantial MIC is considered an increased rate of detection of new MIC sites, increased rates of wall thinning at known sites, or unexpected piping wall loss that results in wall thickness near or below code minimum wall thickness.
Prior to the period of extended operation, select a method (or methods) from available technologies for inspecting internal surfaces of buried piping that provides suitable indication of piping wall thickness for a representative set of buried piping locations to supplement the set of selected inspection locations.
Internally Coated Components Fire protection      Visually inspect internal coated surfaces of piping and tanks system               to manage loss of coating integrity.
Reactor water        Visually inspect internal coated tank surfaces to manage cleanup system       loss of coating integrity.
CRD maintenance      Visually inspect internal coated tank surfaces to manage facility, flush tank loss of coating integrity.
filter and leak test Condensate and       Visually inspect internal coated tank surfaces to manage feedwater system     loss of coating integrity.
Condensate cleanup   Visually inspect internal coated tank surfaces to manage system               loss of coating integrity.
Component cooling    Visually inspect internal coated tank surfaces to manage water system         loss of coating integrity.

Attachment to GNRO-2015/00079 Page 15 of 25 Turbine building          Visually inspect internal coated tank surfaces to manage cooling water             loss of coating integrity.
Domestic water            Visually inspect internal coated tank surfaces to manage system                    loss of coating integrity.
Plant chilled water       Visually inspect internal coated tank surfaces to manage system                    loss of coating integrity.
Drywell chilled water     Visually inspect internal coated tank surfaces to manage system                    loss of coating integrity.
Standby diesel            Visually inspect internal coated tank surfaces to manage generator system          loss of coating integrity.
HPCS diesel               Visually inspect internal coated tank surfaces to manage generator system          loss of coating integrity.
Combustible gas           Visually inspect internal coated heat exchanger surfaces to control system            manage loss of coatina integrity.
Drywell chilled water     Visually inspect internal coated heat exchanger surfaces to system                     manage loss of coating integrity.
Control room HVAC         Visually inspect internal coated heat exchanger surfaces to system                    manage loss of coating integrity.
Evaluation
: 1. Scope of Program The Periodic Surveillance and Preventive Maintenance Program, with regard to license renewal, include the specific structures and components identified in the aging management reviews as listed in the table above.
: 2. Preventive Actions Similar to other condition monitoring programs described in NUREG-1801, the Periodic Surveillance and Preventive Maintenance Program does not include preventive actions.
: 3. Parameters Monitored/Inspected The GGNS Periodic Surveillance and Preventive Maintenance Program a) monitors cracking and change in material properties for elastomeric components, and b) monitors the surface condition of internal and external surfaces of components to manage loss of material c) monitors the wall thickness of piping components to manage loss of material due to recurring internal corrosion d) monitors the condition of internal coated surfaces of components to manage loss of coating integrity

Attachment to GNRO-2015/00079 Page 16 of 25
: 4. Detection of Aging Effects Preventive maintenance activities and periodic surveillances provide for periodic component inspections to detect aging effects and loss of coating integrity. Inspection intervals are established such that they provide timely detection of degradation prior to loss of intended functions. Inspection intervals, sample sizes, and data collection methods are dependent on component material and environment and take into consideration industry and plant-specific operating experience and manufacturers' recommendations.
Established techniques such as visual inspections are used. Each inspection occurs at least once every five years with the exception of inspections for MIC and coating inspections, for which frequency is based on inspection results. The selection of components to be inspected will focus on locations which are most susceptible to aging, where practical. Established inspection methods to detect aging effects include: (1) visual inspections and manual flexing of elastomer components and (2) visual inspections or other NDE techniques for metallic components. Inspections are performed by personnel qualified to perform the inspections.
For each activity that refers to a representative sample, 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.                                .
During the 10-year period prior to the period of extended operation, visual inspections will be performed of coated internal surfaces. Subsequent coating inspections will be performed based on inspection results as follows.
: i.      If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking has been found acceptable, subsequent inspections will be performed at least once every 6 years. If the coating is inspected on one train and no indications are found, and if the redundant train has the same coating, and turbulent flow is not present, then the redundant train need not be inspected during that inspection interval.
ii.      If the inspection results do not meet (i),;tetand a coating specialist has determined that no remediation is required, then subsequent inspections will be conducted on an every other refueling outage interval.
iii. If the inspection results do not meet (i) and a coating specialist determines remediation is required. then the coated components can only be returned to service if the following actions are performed (1) any blistering in excess of a few small intact blisters. or blisters not completely surrounded by coating bonded to the substrate is removed. (2) any delaminated or peeled coating is removed. (3) the exposed underlying coating is verified to be securely bonded to the substrate at a minimum of three locations as determine by adhesion testing endorsed by Regulatory Guide (RG) 1.54 adjacent to the defective area. (4) the outer most coating is feathered and the remaining outermost coating is determined to be

Attachment to GNRO-2015/00079 Page 17 of 25 securely bonded to the coating below via adhesion testing endorsed by RG 1.54.
(5) ultrasonic testing is performed to ensure the component meets the minimum wall thickness requirements. (6) an evaluation is performed within two years and every two years until the coating is repaired. replaced or removed.
Inspections occur at least once every five years during the period of extended operation.
with the exception of inspections of MIG and coating inspections for which frequency is based on inspection results. Visual or other NDE inspections of components in the low pressure core spray. residual heat removal. pressure relief. reactor core isolation cooling. high pressure core spray. and floor and equipment drains systems and the containment building gaskets/seals are performed every five years. Visual or other NDE inspections of a representative sample of internal surfaces of components in the control rod drive. circulating water. and floor and equipment drains systems are performed every five years.
UT or RT wall thickness measurements of selected components of the circulating water.
standby service water. plant service water and fire protection systems are performed periodically as necessary to assure minimum pipe wall thickness is maintained. The most susceptible locations will be selected for inspection based on pipe configuration.
flow conditions. and operating history. A minimum of five MIG degradation inspections in the collective set of systems will be performed per cycle until MIG no longer meets the criteria for recurring internal corrosion. The scope of MIG examinations will be expanded if substantial MIG is detected during inspections. Scope expansion includes consideration of other locations for additonal sampling such as similar components in the same or redundant trains. Substantial MIG is considered an increased rate of detection of new MIG sites. increased rates of wall thinning at known sites. or unexpected piping wall loss that results in wall thickness near or below code minimum wall thickness.
During the 10-year period prior to the period of extended operation, visual inspections will be performed of internally coated surfaces for components in this program. A qualified coating specialist will determine which of the following methods should be used to determine the condition of the coating and the condition of the component under the degraded coating when conditions such as cracking. peeling. blisters. delamination. rust or flaking are identified during the visual examination.
: 1. Lightly tapping and scraping the coating to determine the coating integrity.
: 2. Wet-sponge testing or dry film testing to identify holidays in the coating.
: 3. Adhesion testing in accordance with ASTM D3359. ASTM D4541. or equivalent testing endorsed by RG 1.54 at a minimum of three locations adjacent to the defective area ..
: 4. Ultrasonic testing to determine if the component's wall thickness meets the minimum thickness criteria.

Attachment to GNRO-2015/00079 Page 18 of 25 Coating inspections will cover all accessible internal coated surfaces of applicable tanks and heat exchangers. For areas not readily accessible for direct inspection, such as small pipe lines, heat exchangers and other equipment consideration will be given to the use of remote or robotic inspection tools. For internal coatings of piping inspections will cover 50 percent of coated piping within the system or a minimum of 73 locations of 360 degrees of one linear foot for each combination of type of coating, material the coating is protecting, and environment. Inspection locations of coated piping will be based on coating degradation susceptibility, operating experience, vendor recommendation and safety significance.
Individuals performing coating inspections are certified to ANSI N45.2.6, "Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants," and shall be required to review at least two previous inspection report is available. A nuclear coatings subject matter expert specialist qualified in accordance with ASTM D 7108-05, "Standard Guide for Establishing Qualifications for a Nuclear Coatings Specialist" wiU evaluate inspection findings and prepare post-inspection reports. Coating inspection reports will include lists of locations identified with coating degradation including, where possible, photographs indexed to inspection location, and a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where coating repair can be postponed to a subsequent inspection or repair opportunity.
: 5. Monitoring and Trending Preventive maintenance activities provide for monitoring and trending of aging degradation. Inspection intervals are established such that they provide for timely detection of component degradation. Inspection intervals are dependent on component material and environment and take into consideration industry and plant-specific operating experience and manufacturers' recommendations. Prerequisites for coating inspections include review of the results of previous inspections. The coating inspection report will include a list of locations identified with coating degradation including, where possible, photographs indexed to inspection location, and a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where coating repair can be postponed to a subsequent inspection or repair opportunity.
: 6. Acceptance Criteria Periodic Surveillance and Preventive Maintenance Program acceptance criteria are defined in specific inspection procedures. The procedures confirm that the structure or component intended function(s) are maintained by verifying the absence of aging effects or by comparing applicable parameters to limits established by plant design basis.
Acceptance criteria include 1) for elastomer components, no significant change in material properties or cracking while visually observing and flexing components. and 2) for metallic components, no unacceptable loss of material such that component wall thickness remains above the required minimum.
Loss of coating integrity acceptance criteria are: (1) peeling and delamination are not acceptable, (2) cracking is not acceptance if accompanied by delamination or loss of

Attachment to GNRO-2015/00079 Page 19 of 25 adhesion, and (3) blisters are limited to intact blisters that are completely surrounded by sound coating bonded to the surface.
: 1. Indications of peeling and delamination are not acceptable.
: 2. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate.
Blister size and frequency should not be increasing between inspections (e.g..
reference ASTM 0714-02, "Standard Test Method for Evaluating Degree of Blistering of Paints'').
: 3. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: 4. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: 5. As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
: 6. Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.
In the event peeling delamination, cracking, or loss of adhesion is identified rollooN up evaluations such as knife adhesion test, or adhesion test will be performed. In the event base metal is exposed and the visual inspection identifies corrosion, a volumetric examination will be performed to ensure there is sufficient wall thickness so that the component can perform its intended function until the next inspection or repair opportunity.

Attachment to GNRO-2015/00079 Page 20 of 25
: 7. Corrective Actions Corrective actions, including root cause determination and prevention of recurrence, are implemented in accordance with requirements of 10 CFR Part 50, Appendix 8. In the event peeling, delamination, cracking, or loss of adhesion is identified, follow-up evaluations such as knife adhesion test or adhesion test will be performed. Coatings that do not meet the acceptance criteria will be repaired or replaced. In the event the base metal is exposed and the visual inspection identifies corrosion, this inspection finding will be entered into the Corrective Action Program. An evaluation will confirm the component remains acceptable for continued service. As necessary, a volumetric examination will be performed to ensure there is sufficient wall thickness so that the component remains capable of performing its intended function. If repair or replacement of the coating is postponed, the evaluation will consider the minimum wall thickness requirements and the rate of corrosion and confirm the component remains acceptable for continued service until the next inspection or repair opportunity.
: 8. Confirmation Process This element is discussed in Section 8.0.3.
: 9. Administrative Controls This element is discussed in Section 8.0.3.
: 10. Operating Experience Typical inspection results of this program include the following.
NDE measurements were made on Division II diesel generator exhaust piping in 2005 to check wall thickness. Analysis of the data showed acceptable results. There was no other indication of aging such as erosion or corrosion. Preventive maintenance test results confirming the absence of significant wall loss provides evidence that the program is effective for managing loss of material.
In 2006, visual inspection of the internal surfaces of a check valve in the component cooling water system found significant wear. The affected parts were replaced and the valve was returned to service. There was no other indication of aging such as erosion or corrosion. Identification of signs of possible degradation and corrective action prior to loss of intended function provides evidence that the program is effective for managing aging effects for components.
The process for review of future plant-specific and industry operating experience for this program is discussed in Section 8.0.4.

Attachment to GNRO-2015/00079 Page 21 of 25 Enhancements The following enhancements will be implemented prior to the period of extended operation:
Elements Affected                             Enhancements
: 1. Scope of Program                            The Periodic Surveillance and
: 3. Parameters Monitored or Inspected           Preventive Maintenance Program will
: 4. Detection of Aging Effects                  be enhanced to revise program
: 5. Monitoring and Trending                     guidance documents as necessary to
: 6. Acceptance Criteria                         include all activities as described
: 7. Corrective Actions                           above.
Conclusion The Periodic Surveillance and Preventive Maintenance Program has been effective at managing aging effects. The Periodic Surveillance and Preventive Maintenance Program assures the effects of aging are managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.
LRA Section A.1.35 Periodic Surveillance and Preventive Maintenance Program Loss of coating integrity acceptance criteria are (1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to intact blisters that are completely surrounded by sound coating bonded to the surface. In the event peeling, delamination, cracking, or loss of adhesion is identified, follo\'1 up evaluations including an adhesion test, endorsed by RG 1.54 will be performed. Coatings that do not meet the acceptance criteria will be repaired or replaced.
: 1. Indications of peeling and delamination are not acceptable.
: 2. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g., reference ASTM 0714-02.
    "Standard Test Method for Evaluating Degree of Blistering of Paints").
: 3. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.

Attachment to GNRO-2015/00079 Page 22 of 25
: 4. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: 5. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: 6. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coatingllining and substrate.

Attachment to GNRO-2015/00079 Page 23 of 25 RAI4.2.2-1

===Background===
For the current licensing basis, updates of the P-T limits for Grand Gulf Nuclear Station, Unit I (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.
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 plant's PTLR are mandated by therequirements 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.] .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 ofLRA 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 4.2.2-1 Response LRA Section A.2.1.2 is amended to specify that updates of the P-T limits will be performed in accordance with TS 5.6.6 as follows. Additions are underlined and deletions are lined through.
A.2.l.2 Pressure-Temperature Limits Appendix G of 10 CFR 50 requires that the reactor vessel remain within established pressure-temperature (P-T) limits during boltup, hydro-test, pressure tests, normal operation, and anticipated operational occurrences. These limits are calculated using materials and fluence data, including data obtained through the Reactor Vessel Surveillance Program.
The P-T limit curves will continue to be updated, as required by Appendix G of 10 CFR Part 50 and in accordance with Grand Gulf Technical Specification 5.6.6, assuring that limits remain valid through the period of extended operation.
The time-limited aging analyses for reactor vessel pressure-temperature limits will be managed for the period of extended operation in accordance with 10 CFR 54.21(c)(l)(iii).

Attachment to GNRO-2015/00079 Page 24 of 25 RAI4.2.3-2

===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.
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 ofLRA Table 4.2-2) was submitted and approved by the NRC. If so, identify the date of the staff's 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 4.2.3-2 Response (1) The reference to an Equivalent Margin Analysis (EMA) in Note 10 ofLRA Table 4.2-2 refers to a verification performed to show that the referenced RPV shell plate remains qualified for use through the PEO in accordance with BWRVIP-74-A Table B-4, Equivalent Margin Analysis Plant Applicability Verification Form for BWR/3-6 Plate. BWRVIP-74-A Appendix B presents an EMA for the upper shelf energy that can be used generically for all types of RPV plate materials and welds in all BWR plants to bound the license renewal period of 54 effective full power years (EFPY).
No other analyses were performed related to the referenced RPV shell plate; therefore no EMA was submitted and approved by the NRC apart from NRC approval of BWRVIP-74-A. The phrase "a USE EMA was performed" in Note 10 of LRA Table 4.2-2 is revised. This approach complies with

Attachment to GNRO-2015/00079 Page 25 of 25 Applicant Action Item 10 of the staff's safety evaluation for BWRVIP-74-A dated October 18, 2001, included as Appendix C ofBWRVIP-74-A.
Note 10 of LRA Table 4.2-2 is revised as follows. Deletions are lined through.
Table 4.2-2 GGNS Upper Shelf Energy Data for 54 Effective Full-Power Years Notes to Table 4.2-2:
[10] Due to the lack of sufficient unirradiated data, the unirradiated USE is based on 50% shear results equal to 52 ft-lbs. Reducing this value by 9.5% results in a 54 EFPY USE less than 50 ft-lbs.
Therefore, a USE E~4:A was performed. Considering the necessary adjustment resulting from the A1224-1 ISP results, the reduction remains at 9.5%. As this is less than the maximum permitted reduction of23.50/0 from BWRVIP-74-A, this material remains qualified.
(2) The USE value for the shell plate made from Heat No. C2779-1 at 54 EFPY is 47 ft-lbs.

Q
~Entergy                                                                        Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2015/00079 November 23,2015 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Responses to Request for Additional Information (RAI) Set 53, dated October 28, 2015 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

==REFERENCES:==
: 1. Entergy Letter GNRO-2014/00076, "Response to Request for Additional Information (RAI) Set 51" dated November 6,2014
: 2. U.S. NRC Letter, "Request for Additional Information for the Review of Grand Gulf Nuclear Station, License Renewal Application, Set 52" dated April 6, 2015 (GNRI-2015/00020)
: 3. Entergy Letter GNRO-2015/00034, "Response to Request for Additional Information (RAI) Set 52" dated May 20, 2015
: 4. U.S. NRC Letter, "Summary of Telephone Conference Call Held On June 18, 2015, Between The U.S. NRC And Entergy Concerning Request For Additional Information Responses, Pertaining To The Grand Gulf Nuclear Station License Renewal Application (TAC NO. ME7493)
: 5. Entergy Letter GNRO-2015/00048, "Response to License Renewal Amendment Request for Additional Information (RAI) Set 47, Question 4.2.1-2c (5) (b)", dated July 29,2015
: 6. Entergy Letter GNRO-2015/00055, "Responses to Request for Additional Information (RAI) Set 52, RAls 3.0.3-1-FWS-2a and 3.0.3-2b", dated August 19, 2015
: 7. U.S. NRC Letter, "Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application (TAC NO.
ME7493) - SET 53", dated October 28,2015 (GNRI-2015/00125)

==Dear Sir or Madam:==

Entergy Operations, Inc. is providing, in the Attachment, responses to the referenced Request for Additional Information, Set 53, dated October 28, 2015.
This letter contains changes to the License Renewal Application and changes to existing commitments as documented in the Attachment.

GNRO-2015/00079 Page 2 of2 If you have any questions or require additional information, please contact James Nadeau at 601-437 -2103.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23 rd day of November, 2015.
Sincerely,
~)lio"'----
KJM/ras

==Attachment:==
Response to Requests for Additional Information (RAI), Set 53 cc: with Attachment U.S. Nuclear Regulatory Commission ATTN: Ms. Rebecca Richardson, NRR/DLR Project Manager Office of License Renewal Mail Stop 0-11 F1 Washington, DC 20555 cc: without Attachment U.S. Nuclear Regulatory Commission ATTN: Mr. Mark Dapas 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 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2015/00079 Response to Requests for Additional Information (RAI), Set 53

Attachment to GNRO-2015/00079 Page 1 of 25 The format for the Requests for Additional Information (RAI) responses below is as follows: The RAI is provided 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 questions.
RAI 3.0.3 1 FWS-9

===Background===
By letter dated August 19,2015, the first enhancement shown on Attachment 2, page 11 of21, 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.
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.
RAt 3.0.3 1 FWS-9 Response The basis for revising the wording in the subject enhancement to "inspecting the charcoal filter deluge fire water distribution piping" instead of "inspecting the charcoal filter deluge nozzles" is the wording in the vendor manuals for in-scope charcoal filtration units. It was determined that the phrase "fire water distribution piping" within the charcoal filter units was more appropriate than "nozzles" based on vendor manual wording. Regardless of the configuration, a visual observation of the fire water distribution piping within the charcoal filter units is performed whenever the charcoal is replaced, and air testing every refueling cycle ensures there is no flow blockage.

Attachment to GNRO-2015/00079 Page 2 of 25 RAt 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.
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.
RAt 3.0.3 1 FWS-10 Response The 3rd enhancement in Attachment 2 of the August 19, 2015 (reference 6) letter (Page 13 of
: 21) has been replaced with the enhancement in Attachment 2 of the May 20, 2015 (reference
: 3) letter (page 8 of 10). The LRA revisions are provided below with additions underlined and deletions marked through. The revisions are shown as changes from the version included in the August 19, 2015 letter.
LRA Appendix A.1.21
* Revise the Fire Water System Program procedures to-add-include the following acceptance criteria for loss of coating integrity: (1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to a few intact small blisters that are completely surrounded by sound coating bonded to the surface. Coatings that do not meet the acceptance citeria 'Nill be repaired or replaced.
: 1. Indications of peeling and delamination are not acceptable.
: 2. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g .. reference ASTM 0714-02. "Standard Test Method for Evaluating Degree of Blistering of Paints'').

Attachment to GNRO-2015/00079 Page 3 of 25
: 3. Indications such as cracking. flaking. and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: 4. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: 5. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: 6. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.
LRA Appendix A.4 Commitment #12 Revise the Fire Water System Program procedures to aeainclude the following acceptance criteria for loss of coating integrity(1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to a few intact small blisters that are completely surrounded by sound coating bonded to the surface. Coatings that do not meet the acceptance citeria will be repaired or replaced.
: a. Indications of peeling and delamination are not acceptable.
: b. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g .. reference ASTM 0714-02. "Standard Test Method for Evaluating Degree of Blistering of Paints").
: c. Indications such as cracking. flaking. and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: d. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: e. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: f. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coatingllining and substrate.

Attachment to GNRO-2015/00079 Page 4 of 25 LRA Appendix 8.1.21
: 6. Acceptance Criteria Revise the Fire Water System Program procedures to addinclude the following acceptance criteria for loss of coating integrity(1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to a te'"fJ intact small blisters that are completely surrounded by sound coating bonded to the surface. Coatings that do not meet the acceptance citeria 'I/ill be repaired or replaced.
: a. Indications of peeling and delamination are not acceptable.
: b. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coatingllining bonded to the substrate.
Blister size and frequency should not be increasing between inspections (e.g.,
reference ASTM 0714-02, "Standard Test Method for Evaluating Degree of Blistering of Paints").
: c. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: d. Minor cracking and spalling of cementitious coatingsllinings is acceptable provided there is no evidence

Attachment to GNRO-2015/00079 Page 5 of 25 that the coatingllining is debonding from the base material.
: e. As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
: f. Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.

Attachment to GNRO-2015/00079 Page 6 of 25 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.
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 ofLR 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 1 FWS-11 Response The LRA is revised to state that a coating specialist will evaluate the acceptability of blisters.
The LRA revisions are provided below with additions underlined and deletions marked through.
The revisions are shown as changes from the version included in the August 19, 2015 letter.
LRA Appendix A.1.21
* Revise the Fire Water System Program procedures to ensure a fire water tank is not returned to service after identifying interior coating blistering, delamination or peeling unless there are only a few small intact blisters surrounded by coating bonded to the substrate as determined by a qualified coating specialistinspector, or the following actions are performed.
: 1. Any blistering in excess of a few small intact blisters, or blistering not completely surrounded by coating bonded to the substrate is removed,
: 2. Any delaminated or peeled coating is removed,
: 3. The exposed underlying coating is verified to be securely bonded to the substrate as determined by an adhesion test endorsed by RG 1.54 at a minimum of three locations,
: 4. The outermost coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via an adhesion test endorsed by Reg.

Attachment to GNRO-2015/00079 Page 7 of 25 Guide 1.54 at a minimum of three locations adjacent to the defective area,
: 5. Ultrasonic testing is performed where there is evidence of pitting or corrosion to ensure
      .the tank meets minimum wall thickness requirements,
: 6. An evaluation is performed to ensure downstream flow blockage is not a concern, and
: 7. A follow-up inspection is scheduled to be performed within two years and every two years after that until the coating is repaired, replaced, or removed.
LRA Appendix A.4 Commitment #12
* Revise the Fire Water System Program procedures to ensure a fire water tank is not returned to service after identifying interior coating blistering, delamination or peeling unless there are only a few small intact blisters surrounded by coating bonded to the substrate as determined by a qualified coating specialistinspectoF, or the following actions are performed.
: 8. Any blistering in excess of a few small intact blisters, or blistering not completely surrounded by coating bonded to the substrate is removed,
: 9. Any delaminated or peeled coating is removed,
: 10. The exposed underlying coating is verified to be securely bonded to the substrate as determined by an adhesion test endorsed by RG 1.54 at a minimum of three locations,
: 11. The outermost coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via an adhesion test endorsed by Reg.
Guide 1.54 at a minimum of three locations adjacent to the defective area,
: 12. Ultrasonic testing is performed where there is evidence of pitting or corrosion to ensure the tank meets minimum wall thickness requirements,
: 13. An evaluation is performed to ensure downstream flow blockage is not a concern, and
: 14. A follow-up inspection is scheduled to be performed within two years and every two years after that until the coating is repaired, replaced, or removed.
LRA Appendix 8.1.21
: 4. Detection of Aging Effects            Revise the Fire Water System Program procedures to ensure a fire water tank is not returned to service after identifying interior coating blistering, delamination or peeling unless there are only a few small intact blisters surrounded by coating bonded to the substrate as determined by a qualified coating specialistinspectoF, or the following actions are performed.
: 1. Any blistering in excess of a few small intact blisters, or blistering not completely

Attachment to GNRO-2015/00079 Page 8 of 25 surrounded by coating bonded to the substrate is removed,
: 2. Any delaminated or peeled coating is removed,
: 3. The exposed underlying coating is verified to be securely bonded to the substrate as determined by an adhesion test endorsed by RG 1.54 at a minimum of three locations,
: 4. The outermost coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via an adhesion test endorsed by Reg. Guide 1.54 at a minimum of three locations adjacent to the defective area,
: 5. Ultrasonic testing is performed where there is evidence of pitting or corrosion to ensure the tank meets minimum wall thickness requirements,
: 6. An evaluation is performed to ensure downstream flow blockage is not a concern, and
: 7. A follow-up inspection is scheduled to be performed within two years and every two years after that until the coating is repaired, replaced, or removed.

Attachment to GNRO-2015/00079 Page 9 of 25 RAI3.0.3-3

===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."
The changes to LRA Section A.l.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 Attachment 3 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.
RAI 3.0.3-3 Response LRA Section 8.1.35 is revised to update the description of the Periodic Surveillance and Preventive Maintenance Program. The changes conform to the changes to LRA Section A.1.35 provided in the August 19, 2015 letter (reference 6). The revisions are shown as changes from the version included in the May 13, 2014 and November 16, 2014 letters with additions underlined and deletions marked through.
In addition to the above, acceptance criteria are added to LRA Section A.1.35 (see page 21 of this attachment) with additions underlined and deletions marked through.
8.1.35 Periodic Surveillance and Preventive Maintenance Program Program Description There is no corresponding NUREG-1801 program.
The Periodic Surveillance and Preventive Maintenance Program is an existing program that manages aging effects not managed by other aging management programs, including loss of material due to erosion, loss of coating integrity, cracking, loss of material due to recurring' internal corrosion, and change in material properties.

Attachment to GNRO-2015/00079 Page 10 of 25 Inspections occur at least once every five years during the period of extended operation. with the exception of inspections of MIC and coating inspections for which frequency is based on inspection results. Visual or other NDE inspections of components in the low pressure core spray, residual heat removal. pressure relief, reactor core isolation cooling, high pressure core spray. and floor and equipment drains systems and the containment building gaskets/seals are performed every five years. Visual or other NDE inspections of a representative sample of internal surfaces of components in the control rod drive. circulating water. and floor and equipment drains systems are performed every five years.
UT or RT wall thickness measurements of selected components of the circulating water, standby service water, plant service water and fire protection systems are performed periodically as necessary to assure minimum pipe wall thickness is maintained. The most susceptible locations will be selected for inspection based on pipe configuration, flow conditions, and operating history. A minimum of five MIC degradation inspections in the collective set of systems will be performed per cycle until MIC no longer meets the criteria for recurring internal corrosion. The scope of MIC examinations will be expanded if substantial MIC is detected during inspections. Scope expansion includes consideration of other locations for additonal sampling such as similar components in the same or redundant trains. Substantial MIC is considered an increased rate of detection of new MIC sites. increased rates of wall thinning at known sites, or unexpected piping wall loss that results in wall thickness near or below code minimum wall thickness.
During the 10-year period prior to the period of extended operation, visual inspections will be performed of coated internal surfaces. Subsequent coating inspections will be performed based on inspection results as follows.
: i.      If no peeling, delamination. blisters, or rusting are observed, and any cracking and flaking has been found acceptable, subsequent inspections will be performed at least once every 6 years. If the coating is inspected on one train and no indications are found.
and if the redundant train has the same coating and turbulent flow is not present. then the redundant train need not be inspected during that inspection interval.
ii. If the inspection results do not meet 0) and a coating specialist has determined that no remediation is required, then subsequent inspections will be conducted on an every other refueling outage interval.
iii. If the inspection results do not meet 0) and a coating specialist determines remediation is required, then the coated components can only be returned to service if the following actions are performed (1) any blistering in excess of a few small intact blisters. or blisters not completely surrounded by coating bonded to the substrate is removed. (2) any delaminated or peeled coating is removed, (3) the exposed underlying coating is verified to be securely bonded to the substrate at a minimum of three locations as determine by adhesion testing endorsed by Regulatory Guide (RG) 1.54 adjacent to the defective area. (4) the outer most coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via adhesion testing endorsed by RG 1.54. (5) ultrasonic testing is performed to ensure the component meets the

Attachment to GNRO-2015/00079 Page 11 of 25 minimum wall thickness requirements. (6) an evaluation is performed within two years and every two years until the coating is repaired, replaced or removed.
During the 10-year period prior to the period of extended operation, visual inspections will be performed of internally coated surfaces for components in this program. A qualified coating specialist will determine which of the following methods should be used to determine the condition of the coating and the condition of the component under the degraded coating when conditions such as cracking, peeling, blisters, delamination, rust or flaking are identified during the visual examination.
: 1. Lightly tapping and scraping the coating to determine the coating integrity.
: 2. Wet-sponge testing or dry film testing to identify holidays in the coating.
: 3. Adhesion testing in accordance with ASTM 03359, ASTM 04541, or equivalent testing endorsed by RG 1.54 at a minimum of three locations adjacent to the defective area ..
: 4. Ultrasonic testing to determine if the component's wall thickness meets the minimum thickness criteria.
Coating inspections will cover all accessible internal coated surfaces of applicable tanks and heat exchangers. For areas not readily accessible for direct inspection, such as small pipe lines, heat exchangers and other equipment consideration will be given to the use of remote or robotic inspection tools. For internal coatings of piping. inspections will cover 50 percent of accessible coated piping within the system or a minimum of 73 locations of 360 degrees of one linear foot for each combination of type of coating, material the coating is protecting, and environment.
Inspection locations of coated piping will be based on coating degradation susceptibility, operating experience, vendor recommendation and safety significance.
Individuals performing coating inspections are certified to ANSI N45.2.6. "Qualifications of Inspection, Examination. and Testing Personnel for Nuclear Power Plants," and shall be required to review at least two previous inspection report is available. A nuclear coatings subject matter experts qualified in accordance with ASTM 07108-05. "Standard Guide for Establishing Qualifications for a Nuclear Coatings Specialist." evaluate inspection findings and prepare post-inspection reports. Coating inspection reports will include lists of locations identified with coating degradation including, where possible, photographs indexed to inspection location, and a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where coating repair can be postponed to a subsequent inspection or repair opportunity.
Loss of coating integrity acceptance criteria:
: 7. Indications of peeling and delamination are not acceptable.
: 8. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with

Attachment to GNRO-2015/00079 Page 12 of 25 use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coatingllining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g.. reference ASTM D714-02. llStandard Test Method for Evaluating Degree of Blistering of Paints").
: 9. Indications such as cracking. flaking. and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: 10. Minor cracking and spalling of cementitious coatingsllinings is acceptable provided there is no evidence that the coatingllining is debonding from the base material.
: 11. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: 12. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coatingllining and substrate.
In the event the base metal is exposed and the visual inspection identifies corrosion, this inspection finding will be entered into the Corrective Action Program. An evaluation will confirm the component remains acceptable for continued service. As necessary. a volumetric examination will be performed to ensure there is sufficient wall thickness so that the component remains capable of performing its intended function. If repair or replacement of the coating is postponed. the evaluation will consider the minimum wall thickness requirements and the rate of corrosion and confirm the component remains acceptable for continued service until the next inspection or repair opportunity. which will be within two years.
Credit for program activities has been taken in the aging management review of the following systems and structures.
Containment                Visually inspect and manually flex the rubber gasket/seal for Building                   upper containment pool gates to verify the absence of cracks and significant change in material properties.
Low pressure core          Use visual or other NDE techniques to inspect external spray system               surface of LPCS piping passing through the waterline region (LPCS)                     of suppression pool to manage loss of material.
Residual heat              Use visual or other NDE techniques to inspect external removal (RHR)              surface of RHR piping passing through the waterline region system                     of suppression pool to manage loss of material.
Pressure relief            Use visual or other NDE techniques to inspect external system                     surface of pressure relief system piping passing through the waterline region of the suppression pool to manage loss of material.

Attachment to GNRO-2015/00079 Page 13 of 25 Reactor core        Use visual or other NDE techniques to inspect external isolation cooling   surfaces of RCIC system piping passing through the (RCIC) system       waterline region of the suppression pool to manage loss of material.
Non-safety-related  Visually inspect the internal surfaces of a representative systems affecting   sample of piping in the control rod drive (CRD) system to safety-related      manage loss of material.
systems             Visually inspect the internal surfaces of a representative sample of piping and valve bodies in the circulating water system (N71) to manage loss of material.
Visually inspect the internal surfaces of a representative sample of piping and valve bodies in the floor and equipment drain system (P45) to manage loss of material.
Use visual or other NDE techniques to inspect the internal surfaces of the piping adjacent to the high pressure, intermediate pressure, and low pressure condenser shells in the circulating water system (N71) to manage loss of material due to erosion.
Use visual or other NDE techniques to inspect the internal surfaces of the moisture separator-reheater in the moisture separator-reheater vents and drains system (N35) to manage loss of material due to erosion.
High pressure core  Use visual or other NDE techniques to inspect HPCS piping spray (HPCS)        passing through the waterline region of the suppression pool system              to manage loss of material.
Floor and equipment Use visual or other NDE techniques to inspect piping below drain system        the waterline in the in-scope sumps to manage loss of material.
Visually inspect the internal surfaces of a representative sample of piping, drain housings, and valve bodies in the floor and equipment drain system (P45) to manage loss of material.

Attachment to GNRO-2015/00079 Page 14 of 25 Circulating water    Perform wall thickness measurements using UT or RT at system               selected locations to identify loss of material due to Standby service      microbiologically influenced corrosion (MIC) in piping water system         components of these systems that are included in the scope Plant service water  of license renewal.
system               Select for inspection the most susceptible locations based Fire protection      on pipe configuration, flow conditions and operating history.
system               Periodically review the selected locations to validate their relevance and usefulness, and modify accordingly. Compare wall thickness measurements to determine rates of corrosion degradation. Compare wall thickness measurements to code minimum wall thickness plus margin for corrosion during the refueling cycle(T marg) to determine acceptability of the component for continued use. Perform subsequent wall thickness measurements as needed for each selected location based on the rate of corrosion and expected time to reach (T marg). Perform a minimum of five MIC degradation inspections in the collective set of systems per refueling cycle until MIC no longer meets the criteria for recurring internal corrosion. The scope of MIC examinations will be expanded if substantial MIC is detected during inspections. Scope expansion includes consideration of other locations for additional sampling such as similar components in the same or redundant trains. Substantial MIC is considered an increased rate of detection of new MIC sites, increased rates of wall thinning at known sites, or unexpected piping wall loss that results in wall thickness near or below code minimum wall thickness.
Prior to the period of extended operation, select a method (or methods) from available technologies for inspecting internal surfaces of buried piping that provides suitable indication of piping wall thickness for a representative set of buried piping locations to supplement the set of selected inspection locations.
Internally Coated Components Fire protection      Visually inspect internal coated surfaces of piping and tanks system               to manage loss of coating integrity.
Reactor water        Visually inspect internal coated tank surfaces to manage cleanup system       loss of coating integrity.
CRD maintenance      Visually inspect internal coated tank surfaces to manage facility, flush tank loss of coating integrity.
filter and leak test Condensate and       Visually inspect internal coated tank surfaces to manage feedwater system     loss of coating integrity.
Condensate cleanup   Visually inspect internal coated tank surfaces to manage system               loss of coating integrity.
Component cooling    Visually inspect internal coated tank surfaces to manage water system         loss of coating integrity.

Attachment to GNRO-2015/00079 Page 15 of 25 Turbine building          Visually inspect internal coated tank surfaces to manage cooling water             loss of coating integrity.
Domestic water            Visually inspect internal coated tank surfaces to manage system                    loss of coating integrity.
Plant chilled water       Visually inspect internal coated tank surfaces to manage system                    loss of coating integrity.
Drywell chilled water     Visually inspect internal coated tank surfaces to manage system                    loss of coating integrity.
Standby diesel            Visually inspect internal coated tank surfaces to manage generator system          loss of coating integrity.
HPCS diesel               Visually inspect internal coated tank surfaces to manage generator system          loss of coating integrity.
Combustible gas           Visually inspect internal coated heat exchanger surfaces to control system            manage loss of coatina integrity.
Drywell chilled water     Visually inspect internal coated heat exchanger surfaces to system                     manage loss of coating integrity.
Control room HVAC         Visually inspect internal coated heat exchanger surfaces to system                    manage loss of coating integrity.
Evaluation
: 1. Scope of Program The Periodic Surveillance and Preventive Maintenance Program, with regard to license renewal, include the specific structures and components identified in the aging management reviews as listed in the table above.
: 2. Preventive Actions Similar to other condition monitoring programs described in NUREG-1801, the Periodic Surveillance and Preventive Maintenance Program does not include preventive actions.
: 3. Parameters Monitored/Inspected The GGNS Periodic Surveillance and Preventive Maintenance Program a) monitors cracking and change in material properties for elastomeric components, and b) monitors the surface condition of internal and external surfaces of components to manage loss of material c) monitors the wall thickness of piping components to manage loss of material due to recurring internal corrosion d) monitors the condition of internal coated surfaces of components to manage loss of coating integrity

Attachment to GNRO-2015/00079 Page 16 of 25
: 4. Detection of Aging Effects Preventive maintenance activities and periodic surveillances provide for periodic component inspections to detect aging effects and loss of coating integrity. Inspection intervals are established such that they provide timely detection of degradation prior to loss of intended functions. Inspection intervals, sample sizes, and data collection methods are dependent on component material and environment and take into consideration industry and plant-specific operating experience and manufacturers' recommendations.
Established techniques such as visual inspections are used. Each inspection occurs at least once every five years with the exception of inspections for MIC and coating inspections, for which frequency is based on inspection results. The selection of components to be inspected will focus on locations which are most susceptible to aging, where practical. Established inspection methods to detect aging effects include: (1) visual inspections and manual flexing of elastomer components and (2) visual inspections or other NDE techniques for metallic components. Inspections are performed by personnel qualified to perform the inspections.
For each activity that refers to a representative sample, 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.                                .
During the 10-year period prior to the period of extended operation, visual inspections will be performed of coated internal surfaces. Subsequent coating inspections will be performed based on inspection results as follows.
: i.      If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking has been found acceptable, subsequent inspections will be performed at least once every 6 years. If the coating is inspected on one train and no indications are found, and if the redundant train has the same coating, and turbulent flow is not present, then the redundant train need not be inspected during that inspection interval.
ii.      If the inspection results do not meet (i),;tetand a coating specialist has determined that no remediation is required, then subsequent inspections will be conducted on an every other refueling outage interval.
iii. If the inspection results do not meet (i) and a coating specialist determines remediation is required. then the coated components can only be returned to service if the following actions are performed (1) any blistering in excess of a few small intact blisters. or blisters not completely surrounded by coating bonded to the substrate is removed. (2) any delaminated or peeled coating is removed. (3) the exposed underlying coating is verified to be securely bonded to the substrate at a minimum of three locations as determine by adhesion testing endorsed by Regulatory Guide (RG) 1.54 adjacent to the defective area. (4) the outer most coating is feathered and the remaining outermost coating is determined to be

Attachment to GNRO-2015/00079 Page 17 of 25 securely bonded to the coating below via adhesion testing endorsed by RG 1.54.
(5) ultrasonic testing is performed to ensure the component meets the minimum wall thickness requirements. (6) an evaluation is performed within two years and every two years until the coating is repaired. replaced or removed.
Inspections occur at least once every five years during the period of extended operation.
with the exception of inspections of MIG and coating inspections for which frequency is based on inspection results. Visual or other NDE inspections of components in the low pressure core spray. residual heat removal. pressure relief. reactor core isolation cooling. high pressure core spray. and floor and equipment drains systems and the containment building gaskets/seals are performed every five years. Visual or other NDE inspections of a representative sample of internal surfaces of components in the control rod drive. circulating water. and floor and equipment drains systems are performed every five years.
UT or RT wall thickness measurements of selected components of the circulating water.
standby service water. plant service water and fire protection systems are performed periodically as necessary to assure minimum pipe wall thickness is maintained. The most susceptible locations will be selected for inspection based on pipe configuration.
flow conditions. and operating history. A minimum of five MIG degradation inspections in the collective set of systems will be performed per cycle until MIG no longer meets the criteria for recurring internal corrosion. The scope of MIG examinations will be expanded if substantial MIG is detected during inspections. Scope expansion includes consideration of other locations for additonal sampling such as similar components in the same or redundant trains. Substantial MIG is considered an increased rate of detection of new MIG sites. increased rates of wall thinning at known sites. or unexpected piping wall loss that results in wall thickness near or below code minimum wall thickness.
During the 10-year period prior to the period of extended operation, visual inspections will be performed of internally coated surfaces for components in this program. A qualified coating specialist will determine which of the following methods should be used to determine the condition of the coating and the condition of the component under the degraded coating when conditions such as cracking. peeling. blisters. delamination. rust or flaking are identified during the visual examination.
: 1. Lightly tapping and scraping the coating to determine the coating integrity.
: 2. Wet-sponge testing or dry film testing to identify holidays in the coating.
: 3. Adhesion testing in accordance with ASTM D3359. ASTM D4541. or equivalent testing endorsed by RG 1.54 at a minimum of three locations adjacent to the defective area ..
: 4. Ultrasonic testing to determine if the component's wall thickness meets the minimum thickness criteria.

Attachment to GNRO-2015/00079 Page 18 of 25 Coating inspections will cover all accessible internal coated surfaces of applicable tanks and heat exchangers. For areas not readily accessible for direct inspection, such as small pipe lines, heat exchangers and other equipment consideration will be given to the use of remote or robotic inspection tools. For internal coatings of piping inspections will cover 50 percent of coated piping within the system or a minimum of 73 locations of 360 degrees of one linear foot for each combination of type of coating, material the coating is protecting, and environment. Inspection locations of coated piping will be based on coating degradation susceptibility, operating experience, vendor recommendation and safety significance.
Individuals performing coating inspections are certified to ANSI N45.2.6, "Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants," and shall be required to review at least two previous inspection report is available. A nuclear coatings subject matter expert specialist qualified in accordance with ASTM D 7108-05, "Standard Guide for Establishing Qualifications for a Nuclear Coatings Specialist" wiU evaluate inspection findings and prepare post-inspection reports. Coating inspection reports will include lists of locations identified with coating degradation including, where possible, photographs indexed to inspection location, and a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where coating repair can be postponed to a subsequent inspection or repair opportunity.
: 5. Monitoring and Trending Preventive maintenance activities provide for monitoring and trending of aging degradation. Inspection intervals are established such that they provide for timely detection of component degradation. Inspection intervals are dependent on component material and environment and take into consideration industry and plant-specific operating experience and manufacturers' recommendations. Prerequisites for coating inspections include review of the results of previous inspections. The coating inspection report will include a list of locations identified with coating degradation including, where possible, photographs indexed to inspection location, and a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where coating repair can be postponed to a subsequent inspection or repair opportunity.
: 6. Acceptance Criteria Periodic Surveillance and Preventive Maintenance Program acceptance criteria are defined in specific inspection procedures. The procedures confirm that the structure or component intended function(s) are maintained by verifying the absence of aging effects or by comparing applicable parameters to limits established by plant design basis.
Acceptance criteria include 1) for elastomer components, no significant change in material properties or cracking while visually observing and flexing components. and 2) for metallic components, no unacceptable loss of material such that component wall thickness remains above the required minimum.
Loss of coating integrity acceptance criteria are: (1) peeling and delamination are not acceptable, (2) cracking is not acceptance if accompanied by delamination or loss of

Attachment to GNRO-2015/00079 Page 19 of 25 adhesion, and (3) blisters are limited to intact blisters that are completely surrounded by sound coating bonded to the surface.
: 1. Indications of peeling and delamination are not acceptable.
: 2. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate.
Blister size and frequency should not be increasing between inspections (e.g..
reference ASTM 0714-02, "Standard Test Method for Evaluating Degree of Blistering of Paints'').
: 3. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.
: 4. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: 5. As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
: 6. Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.
In the event peeling delamination, cracking, or loss of adhesion is identified rollooN up evaluations such as knife adhesion test, or adhesion test will be performed. In the event base metal is exposed and the visual inspection identifies corrosion, a volumetric examination will be performed to ensure there is sufficient wall thickness so that the component can perform its intended function until the next inspection or repair opportunity.

Attachment to GNRO-2015/00079 Page 20 of 25
: 7. Corrective Actions Corrective actions, including root cause determination and prevention of recurrence, are implemented in accordance with requirements of 10 CFR Part 50, Appendix 8. In the event peeling, delamination, cracking, or loss of adhesion is identified, follow-up evaluations such as knife adhesion test or adhesion test will be performed. Coatings that do not meet the acceptance criteria will be repaired or replaced. In the event the base metal is exposed and the visual inspection identifies corrosion, this inspection finding will be entered into the Corrective Action Program. An evaluation will confirm the component remains acceptable for continued service. As necessary, a volumetric examination will be performed to ensure there is sufficient wall thickness so that the component remains capable of performing its intended function. If repair or replacement of the coating is postponed, the evaluation will consider the minimum wall thickness requirements and the rate of corrosion and confirm the component remains acceptable for continued service until the next inspection or repair opportunity.
: 8. Confirmation Process This element is discussed in Section 8.0.3.
: 9. Administrative Controls This element is discussed in Section 8.0.3.
: 10. Operating Experience Typical inspection results of this program include the following.
NDE measurements were made on Division II diesel generator exhaust piping in 2005 to check wall thickness. Analysis of the data showed acceptable results. There was no other indication of aging such as erosion or corrosion. Preventive maintenance test results confirming the absence of significant wall loss provides evidence that the program is effective for managing loss of material.
In 2006, visual inspection of the internal surfaces of a check valve in the component cooling water system found significant wear. The affected parts were replaced and the valve was returned to service. There was no other indication of aging such as erosion or corrosion. Identification of signs of possible degradation and corrective action prior to loss of intended function provides evidence that the program is effective for managing aging effects for components.
The process for review of future plant-specific and industry operating experience for this program is discussed in Section 8.0.4.

Attachment to GNRO-2015/00079 Page 21 of 25 Enhancements The following enhancements will be implemented prior to the period of extended operation:
Elements Affected                             Enhancements
: 1. Scope of Program                            The Periodic Surveillance and
: 3. Parameters Monitored or Inspected           Preventive Maintenance Program will
: 4. Detection of Aging Effects                  be enhanced to revise program
: 5. Monitoring and Trending                     guidance documents as necessary to
: 6. Acceptance Criteria                         include all activities as described
: 7. Corrective Actions                           above.
Conclusion The Periodic Surveillance and Preventive Maintenance Program has been effective at managing aging effects. The Periodic Surveillance and Preventive Maintenance Program assures the effects of aging are managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.
LRA Section A.1.35 Periodic Surveillance and Preventive Maintenance Program Loss of coating integrity acceptance criteria are (1) peeling and delamination are not acceptable, (2) cracking is not acceptable if accompanied by delamination or loss of adhesion, and (3) blisters are limited to intact blisters that are completely surrounded by sound coating bonded to the surface. In the event peeling, delamination, cracking, or loss of adhesion is identified, follo\'1 up evaluations including an adhesion test, endorsed by RG 1.54 will be performed. Coatings that do not meet the acceptance criteria will be repaired or replaced.
: 1. Indications of peeling and delamination are not acceptable.
: 2. Blisters are evaluated by a coating specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g., reference ASTM 0714-02.
    "Standard Test Method for Evaluating Degree of Blistering of Paints").
: 3. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with the use of a particular standard.

Attachment to GNRO-2015/00079 Page 22 of 25
: 4. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
: 5. As applicable. wall thickness measurements. projected to the next inspection. meet design minimum wall requirements.
: 6. Adhesion testing results. when conducted. meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coatingllining and substrate.

Attachment to GNRO-2015/00079 Page 23 of 25 RAI4.2.2-1

===Background===
For the current licensing basis, updates of the P-T limits for Grand Gulf Nuclear Station, Unit I (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.
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 plant's PTLR are mandated by therequirements 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.] .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 ofLRA 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 4.2.2-1 Response LRA Section A.2.1.2 is amended to specify that updates of the P-T limits will be performed in accordance with TS 5.6.6 as follows. Additions are underlined and deletions are lined through.
A.2.l.2 Pressure-Temperature Limits Appendix G of 10 CFR 50 requires that the reactor vessel remain within established pressure-temperature (P-T) limits during boltup, hydro-test, pressure tests, normal operation, and anticipated operational occurrences. These limits are calculated using materials and fluence data, including data obtained through the Reactor Vessel Surveillance Program.
The P-T limit curves will continue to be updated, as required by Appendix G of 10 CFR Part 50 and in accordance with Grand Gulf Technical Specification 5.6.6, assuring that limits remain valid through the period of extended operation.
The time-limited aging analyses for reactor vessel pressure-temperature limits will be managed for the period of extended operation in accordance with 10 CFR 54.21(c)(l)(iii).

Attachment to GNRO-2015/00079 Page 24 of 25 RAI4.2.3-2

===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.
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 ofLRA Table 4.2-2) was submitted and approved by the NRC. If so, identify the date of the staff's 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 4.2.3-2 Response (1) The reference to an Equivalent Margin Analysis (EMA) in Note 10 ofLRA Table 4.2-2 refers to a verification performed to show that the referenced RPV shell plate remains qualified for use through the PEO in accordance with BWRVIP-74-A Table B-4, Equivalent Margin Analysis Plant Applicability Verification Form for BWR/3-6 Plate. BWRVIP-74-A Appendix B presents an EMA for the upper shelf energy that can be used generically for all types of RPV plate materials and welds in all BWR plants to bound the license renewal period of 54 effective full power years (EFPY).
No other analyses were performed related to the referenced RPV shell plate; therefore no EMA was submitted and approved by the NRC apart from NRC approval of BWRVIP-74-A. The phrase "a USE EMA was performed" in Note 10 of LRA Table 4.2-2 is revised. This approach complies with

Attachment to GNRO-2015/00079 Page 25 of 25 Applicant Action Item 10 of the staff's safety evaluation for BWRVIP-74-A dated October 18, 2001, included as Appendix C ofBWRVIP-74-A.
Note 10 of LRA Table 4.2-2 is revised as follows. Deletions are lined through.
Table 4.2-2 GGNS Upper Shelf Energy Data for 54 Effective Full-Power Years Notes to Table 4.2-2:
[10] Due to the lack of sufficient unirradiated data, the unirradiated USE is based on 50% shear results equal to 52 ft-lbs. Reducing this value by 9.5% results in a 54 EFPY USE less than 50 ft-lbs.
Therefore, a USE E~4:A was performed. Considering the necessary adjustment resulting from the A1224-1 ISP results, the reduction remains at 9.5%. As this is less than the maximum permitted reduction of23.50/0 from BWRVIP-74-A, this material remains qualified.
(2) The USE value for the shell plate made from Heat No. C2779-1 at 54 EFPY is 47 ft-lbs.}}