ML12074A008

Requests for Additional Information for the Review of the Grand Gulf Nuclear Station License Renewal Application

ML12074A008
Person / Time
Site:	Grand Gulf
Issue date:	04/12/2012
From:	Ferrer N License Renewal Projects Branch 1
To:	Mike Perito Entergy Operations
Ferrer N
References
TAC ME7493
Download: ML12074A008 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 April 12,2012 Mr. Michael Perito Vice President, Site Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO. ME7493)

Dear Mr. Perito:

By letter dated October 28, 2011, Entergy Operations, Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54, to renew the operating license for Grand Gulf Nuclear Station, Unit 1 (GGNS) for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Jeff Seiter, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions. please contact me at 301-415-1045 ore-mail nathaniel.ferrer@nrc.gov.

Sinc~_ _ __

Nathaniel Ferrer, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50- 416

Enclosure:

Requests for Additional Information cc w/encl: Listserv

GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION SET 4 RAI 8.1.26-1 Background. The program description of GALL Report AMP XLM38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," states that the program includes internal inspections of metallic ducting. The program description also states that the program includes components exposed to air-indoor uncontrolled, air outdoor, condensation and water systems other than fire water, open-cycle cooling water, and closed treated water system.

The "detection of aging effects" program element of GALL Report AMP XLM38 states that the program is opportunistic, applied when surfaces become accessible during the performance of periodic surveillances or during maintenance activities or scheduled outages. The "detection of aging effects" program element also states that a sample size for manipulation of flexible polymeric components be at least 10 percent of the available surface area.

During the audit of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program, the staff was not able to determine if this program is consistent with the aspects of GALL Report AMP XI.M38 discussed above.

Issue. The LRA and the onsite documentation did not have sufficient detail for the staff to determine if the applicant's Internal Surfaces in Miscellaneous Piping and Ducting Components Program is consistent with GALL Report AMP XLM38.

Reguest. Justify why the Internal Surfaces in Miscellaneous Piping and Ducting Components Program and Updated Final Safety Analysis Report (UFSAR) supplement do not include the following:

• Information on metallic ducting, if applicable

• The environments managed within the program

• Information on if inspections are opportunistic and, if so, when surfaces are anticipated to become accessible for inspection

• The sample size for manipulation of flexible polymers Alternatively, revise LRA Sections A.1.26 and B.1.26 to include the information.

RAI 8.1.26-2 Background. LRA Table 2.3.3-16 states that heat exchanger tubes have both a pressure boundary function and a heat transfer function. LRA Table 3.3.2-16 also includes an item for copper alloy greater than 15-percent zinc (inhibited) heat exchanger tubes exposed to air-indoor (external) with a pressure boundary intended function; however, there is not a parallel item for the intended function of heat transfer.

ENCLOSURE

-2 Issue. It is not clear to the staff why LRA Table 3.3.2-16 does not include an AMR item for copper alloy greater than 15-percent zinc (inhibited) heat exchanger tubes exposed to air-indoor (external) for the intended function of heat transfer, given that LRA Table 2.3.3-16 states that heat exchanger tubes have this intended function.

Request. Justify why LRA Table 3.3.2-16 does not include an AMR item for copper alloy greater than 15-percent zinc (inhibited) heat exchanger tubes exposed to air-indoor (external) for the intended function of heat transfer or revise the LRA to include this item.

RAI 8.1.26-3 Background. GALL Report AMP XI.M38 addresses the aging effects of hardening, loss of strength, cracking and loss of material for polymeric and elastomeric components. The GALL AMP also states that the aging effect of loss of material is part of this program for metallic components.

LRA Sections B.1.26 and A.1.26 state that the program manages hardening and loss of strength for elastomers and polymers. LRA AMR items assigned to the Internal Surfaces in Miscellaneous Piping and Ducting Components Program address the aging effects of change in material properties and cracking for elastomers, and addresses the aging effects of cracking, fouling, and loss of material for the remaining components and structures within the program.

LRA AMR items do not address the aging effects of hardening and loss of strength for elastomers.

Issue. The aging effects included in LRA Sections B.1.26 and A.1.26 are not consistent with those in GALL Report AMP XI.M38 and do not reflect the aging effects addressed in the LRA AMR items associated with the applicant's Internal Surfaces in Miscellaneous Piping and Ducting Components Program.

Request. Revise LRA Sections B.1.26 and A.1.26 to state all aging effects that are being addressed within the program and provide technical justification for inconsistencies with the aging effects managed by GALL Report AMP XI.M38.

RAI 8.1.26-4 Background. SRP-LR Table 3.2-1, item 43 states that elastomers exposed to air-indoor, uncontrolled (internal) will be managed for hardening and loss of strength with GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. If LRA Table 3.2.1, item 3.2.1-43 states that elastomers exposed to air-indoor, uncontrolled (internal) will be managed for hardening and loss of strength with the Internal Surfaces in Miscellaneous Piping and Ducting Components program. LRA Table 3.2.2-6 states that duct "flexible connections, elastomers exposed to air-indoor (internal) will be managed for cracking and change in material properties, referencing LRA Table 3.2.1, item 3.2.1-43.

-3 Issue. The aging effects being managed for the elastomeric duct flexible connections in LRA Table 3.2.2-6 are not consistent with LRA Table 3.2.1, item 3.2.1-43 or SRP-LR Table 3.2-1, item 43.

Request. Justify why the LRA Table 3.2.2-6 item for aging effects for elastomeric duct connections is not aligned with the referenced LRA Table 3.2.1, item 3.2.1-43 and SRP-LR Table 3.2-1, item 43. Alternatively, revise the applicable LRA sections to align these items.

RAI 8.1.26-5 Background. SRP-LR Section A 1.2.3.3, "Parameters Monitored or Inspected," states that this program element should identify the aging effects the program manages and provide a link between the parameters monitored and how the monitoring will ensure adequate aging management. SRP LR Section A 1.2.3.3 also states that parameters monitored or inspected should be capable of detecting the presence and extent of aging effects.

The "parameters monitored/inspected" program element of GALL Report AMP XI.M38 states that the inspection parameters associated with metallic components are surface discontinuities, corrosion and material parameters wastage (loss of material), leakage from or onto internal surfaces (loss of material), and worn, flaking, or oxide-coated surfaces (loss of material). This program element also states that inspection parameters for polymers are surface cracking, crazing, scuffing, and dimensional change (e.g., "ballooning" and "necking"), discoloration, exposure of internal reinforcement for reinforced elastomers, and hardening as evidenced by a loss of suppleness during manipulation.

LRA Section B.1.26 does not identify any parameters monitored or inspected.

Issue. The "parameters monitored/inspected" program element of Internal Surfaces in Miscellaneous Piping and Ducting Components Program does not have sufficient detail on what inspection parameters will be in this program for metallic components and for polymers; therefore, the staff cannot determine if the program is consistent with GALL Report AMP XI.M38 Request. Justify why the "parameters monitored/inspected" program element of Internal Surfaces in Miscellaneous Piping and Ducting Components Program does not include the specific parameters monitored and their related aging effects for this program's metallic and polymeric components, or revise the LRA to include this information.

RAI 8.1.26-6 Background. SRP-LR Section A 1.2.3.6, "Acceptance Criteria," states that this program element should describe the qualitative or quantitative acceptance criteria and those criteria should ensure that the structure and component intended functions are maintained consistent with all current licensing basis (CLB) design conditions during the period of extended operation.

4 The "acceptance criteria" program element of GALL Report AMP XLM38 states the acceptance criteria for the following:

• stainless steel: clean surfaces, shiny with no discoloration

• metals: any abnormal surface

• flexible polymers: a uniform surface texture and color with no cracks, and no unanticipated dimensional change, no abnormal surface with the material in an "as new" condition with respect to hardness, flexibility, physical dimensions, and color

• rigid polymers: no erosion, cracking, crazing, checking, and chalks LRA Section B.1.26 does not identify the acceptance criteria for the components within this program.

Issue. The "acceptance criteria" program element of Internal Surfaces in Miscellaneous Piping and Ducting Components Program does not have sufficient detail on the acceptance criteria that will be in this program for stainless steel, metals, flexible polymers, and rigid polymers, and thus the staff cannot determine if the program is consistent with GALL Report AMP XI.M38.

Request. Justify why the "acceptance criteria" program element of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program does not include specific acceptance criteria for the program's components, or revise the LRA to include this information.

RAI 8.1.26-7 Background. SRP-LR 3.1.2.5 states that the summary description of the programs and activities for managing the effects of aging for the period of extended operation in the final safety analysis report (FSAR) supplement should be sufficiently comprehensive such that later changes can be controlled by 10 CFR 50.59, and the description should contain information associated with the bases for determining that aging effects will be managed during the period of extended operation. In addition, 10 CFR 54.21 (d) states that the FSAR supplement must contain a summary description of the program and the activities for managing the effects of aging.

SRP-LR Table 3.0-1, GALL Chapter XI.M38 states that this program applies to any water system other than open-cycle cooling water, treated water, and fire water. The SRP-LR also states that this program is applied to ensure that these environments are not causing degradation where a component's intended function could be lost, and where visual inspections of internal surfaces may not be possible, a plant-specific program would be applied.

LRA Section A.1.26 states that the program manages the effects of aging using visual inspections of the internal surfaces of piping and components during periodic surveillances or maintenance activities when the surfaces are accessible for visual inspection. LRA Section A.1.26 also states that physical manipulation or pressurization to detect hardening or loss of strength for elastomers and polymers are used.

Issue. The UFSAR supplement for the Internal Surfaces in Miscellaneous Piping and Ducting Components Program does not include key elements of the program description, including

-5 which water systems are included in the scope of the program, whether the programs purpose intends to retain a component's intended function, and does not include a provision for a plant specific program when visual inspections of internal surfaces are not possible.

Request. Justify why LRA Section A.1.26 does not include key elements of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program or revise the LRA to include this information.

RAI 8.1.26-8 Background. The "detection of aging effects" program element of GALL Report AMP XI.M38 states that visual inspections should include all accessible surfaces. The GALL Report also states that if visual inspections of internal surfaces are not possible, then the applicant needs to provide a plant-specific program.

LRA Section B.1.26 does not state if all components and surfaces managed within the program are accessible.

Issue. It is not clear if all the components and surfaces within this program are accessible, or whether some may be inaccessible. GALL Report AMP XI.M38 recommends that inaccessible components would require particular techniques and strategies, defined in a plant-specific program, to manage aging for those components.

Request. Review the surfaces and components within this program and determine if any may be inaccessible for visual inspections. Consider in the review for inaccessible components all items such as elastomers, polymers, and submerged metallic piping and any other inaccessible piping. If there are inaccessible items, ensure the "detection of aging effect" program element of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program is updated to describe the method and inspection techniques that will be used to age manage these components.

SUB..'ECT: REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION, LICENSE RENEWAL APPLICATION DISTRIBUTION:

HARDCOPY:

DLR RF E-MAIL:

PUBLIC [or NON-PUBLIC, if applicable]

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Mr. Michael Perito Vice President, Site Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO. ME7493)

Dear Mr. Perito:

By letter dated October 28, 2011, Entergy Operations, Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54, to renew the operating license for Grand Gulf Nuclear Station Unit 1 (GGNS), for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Jeff Seiter, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301- 415-1045 or e-mail nathaniel,ferrer@nrc.gov.

Sincerely, IRAI Nathaniel Ferrer, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

Requests for Additional Information cc w/encl: Listserv DISTRIBUTION: See following pages ADAMS Accession No ..'ML12074a008 PM:RPB1 :DLR BC:RPB1 :DLR PM:RPB1 :DLR .

OFFICE LA:RPB1:DLR NAME YEdmonds NFerrer wledits DMorey NFerrer DATE 3/23112 4/9/12 4/5/12 4/12/12 OFFICIAL RECORD COpy