ML12076A009
| ML12076A009 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/17/2012 |
| From: | Ferrer N License Renewal Projects Branch 1 |
| To: | Mike Perito Entergy Operations |
| Ferrer N | |
| References | |
| TAC ME7493 | |
| Download: ML12076A009 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 17, 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. IVIE7493)
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.
s~~_____________
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 6 RAI B.1.20-1 Background. The "scope of program" program element of GALL Report AMP XI.M26, "Fire Protection," states that the program includes visual inspections of fire barrier penetration seals, walls, ceilings, floors, doors, and other fire resistant materials that perform a fire barrier function.
During its audit of the applicant's Fire Protection Program, the staff noted that the applicant has fire barriers constructed of the materials Thermo-lag and 3M Interam, and that these materials are included in the fire barrier inspection procedures.
The license renewal application (LRA) does not include aging management results for any components constructed of the materials Thermo-lag or 3M Interam.
Issue. The LRA does not include Thermo-Lag and 3M Interam fire barrier materials; however.
these materials are used at the plant and are included in the plant's inspection procedures.
Request. Justify why there are no fire barriers constructed of Thermo-Lag and 3M Interam being managed for aging in the LRA, or revise the LRA to include aging management of these materials.
RAI B.1.20-2 Background. The "scope of program" program element of GALL Report AMP XI.M26, "Fire Protection," states that the program manages aging effects for the halon and CO2 fire suppression systems. GALL Report AMP XLM26 relies on visual inspections and functional tests to manage aging for halon and CO2 fire suppression system components.
During its audit of the applicant's Fire Protection Program, the staff noted that the applicant's CO2 fire suppression system includes an outdoor CO2 tank (License Renewal Drawing 35E, location H3). The staff also noted that the exterior surface of the tank is not readily accessible for visual inspection, as it is covered with an outer steel housing and an intermediate insulation layer.
The program description of GALL Report AMP XLM29, "Aboveground Metallic Tanks," states that it manages the effects of loss of material on the outer surfaces of aboveground tanks constructed on concrete or soil. The "preventive actions" program element of GALL Report AMP XLM29 recommends that sealant of caulking be applied at the external surface interface between the tank and concrete or earthen foundations. The "detection of aging effects" program element of GALL Report AMP XLM29 recommends that (a) the exterior surfaces of aboveground tanks be periodically inspected to monitor degradation of coatings because it is a condition directly related to the potential loss of materials and (b) that thickness measurements of tank bottoms that sit directly on concrete or soil be performed to ensure that loss of material is not occurring at locations that are inaccessible for inspection.
ENCLOSURE
- 2 Issue. Based on a review of LRA Table 3.3.2-13 and a search of all tanks contained in the LRA, it appears that there is no aging management review (AMR) item for this tank. It is unclear to the staff why the LRA does not include the outdoor CO2 tank and how this tank will be managed for aging during the period of extended operation.
Request.
- a. Justify why there is no AMR item in the LRA for the outdoor CO2 tank or revise the LRA to include the item.
- b. If the tank sits directly on concrete or soil, state whether sealant or caulking is utilized at the external surface interface between the tank and concrete or earthen foundation, or state the basis for why sealant or caulking is not used.
- c. If the tank sits directly on concrete or soil and the tank is not being managed for aging using the Aboveground Metallic Tanks program, state the basis for why there is reasonable assurance that the tank will perform its current licensing basis functions throughout the period of extended operation.
- d. If the tank does not sit directly on concrete or soil, state the inspection methodology and frequency of inspections that will be used to manage aging given that the exterior surface of the tank is not readily accessible.
RAI 8.1.20-3 Background. SRP-LR Table 3.0-1, "FSAR Supplement for Aging Management of Applicable Systems," states that the Updated Final Safety Analysis Report (UFSAR) Supplement for GALL Report AMP XI.M26, "Fire Protection," should include visual inspection and functional tests of fire-rated doors to ensure that their operability is maintained.
The UFSAR Supplement for the applicant's Fire Protection Program provided in LRA Section A.1.20 discusses only visual inspection of components with a fire barrier intended function.
Issue. LRA Section A.1.20 does not state that the program includes functional tests of fire-rated doors. The inclusion of fire door functional tests in the UFSAR supplement is necessary to ensure proper aging management of fire-rated doors during the period of extended operation.
Request. Justify why the UFSAR supplement for the Fire Protection Program does not include functional tests of fire-rated doors, or revise LRA Section A.1.20 to include this information.
RAI 8.1.21-1 Backqround. The recommended description of the UFSAR supplement for GALL Report AMP XI.M27, "Fire Water System" provided in SRP-LR Table 3.0-1 states that the program includes full-flow flush tests, system performance tests, testing or replacement of sprinkler heads, and can be modified to include full flow tests of sprinkler systems and internal visual inspections.
SRP-LR Table 3.0-1 also states that testing is performed in accordance with applicable National Fire Protection Association (NFPA) Codes. SRP-LR Table 3.0-1 further states that the system
- 3 is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated.
The UFSAR supplement for the Fire Water System Program provided in LRA Section A.1.21 does not state that the program includes system performance tests and monitoring of operating pressure, or that testing is performed in accordance with NFPA Codes.
The description of the Fire Water System Program provided in LRA Section B.1.21 does not state that the program includes aging management for water-based fire protection systems, what type of inspections are performed by the program (such as visual examinations of external/internal surfaces, hydrant flow tests, piping flow tests, flushing. and system functional tests). what type of preventive activities are included (such as pressure monitoring). or that testing is performed in accordance with NFPA codes.
Issue. LRA Sections A.1.21 and B.1.21 do not provide adequate descriptions of the Fire Water System Program, consistent with the recommendations in the GALL Report and SRP-LR.
Request. Justify why LRA Sections A.1.21 and 8.1.21 do not include a comprehensive description of the activities in the Fire Water System Program, or revise the sections to include the description.
RAI 8.1.21-2 Background. GALL Report AMP XI.M27, "Fire Water System." applies to water-based fire protection systems that consist of sprinklers. nozzles. fittings, valves, fire pump casings.
hydrants. hose stations, standpipes, water storage tanks, and aboveground, buried. and underground piping and components that are tested in accordance with the applicable NFPA codes and standards. The buried fire main piping and sprinkler heads exposed to both air and water are included within the scope of GALL Report AMP XI.M27. LRA Section B.1.21 states that the Fire Water System Program is an existing program, with enhancements, that is consistent with GALL Report AMP XI.M27 and includes enhancements to test sprinkler heads per NFPA 25 and inspect buried fire protection piping.
LRA Section 2.3.3.12 states that the fire water system includes both wet-pipe and dry-pipe sprinkler systems. However, there are no AMR items for sprinklers heads in the LRA and no AMR items for copper alloy components exposed to air which are being managed for aging using the fire water system. There are AMR items for copper alloy (with greater than 15 percent zinc or 8 percent aluminum) nozzles exposed to indoor air, but the AMR items state that the components have no aging effects requiring management.
LRA Section 2.3.3.12 states that the underground yard loop is constructed of cement-lined cast iron piping. However. there are no AMR items in the LRA for cast iron or carbon steel piping exposed to cement or for cement-lined piping.
Issue. It is not clear to the staff how the cement-lined cast iron yard loop and sprinkler heads will be managed for aging. There are activities in the Fire Water System Program capable of managing aging for these components. but there do not appear to be AMR items that reference the Fire Water System Program to manage aging for these components.
-4 Reguest. Provide AMR items for the sprinkler heads and cement-lined cast iron yard loop which reference the Fire Water System Program to manage aging or provide justification for why an alternative or no program will be used to manage aging.
RAI8.1.21-3 Background. GALL Report AMP XI.M27 recommends flow testing or wall thickness evaluations to ensure that the system maintains its intended function. GALL Report AMP XI.M27 states that wall thickness evaluations may be performed using either non-intrusive techniques or visual inspections of the internal surfaces of the piping and that inspections should be performed prior to the end of the period of extended operation and at plant-specific intervals thereafter.
LRA Section B.1.21 states an enhancement to the "detection of aging effects" program element to include either wall thickness evaluations using non-intrusive techniques or visual inspections of the internal surfaces of fire protection piping upon each entry to the system for routine or corrective maintenance. The LRA further states that maintenance history will be used to demonstrate that the inspections have been performed on a representative number of locations and additional inspections will be performed as needed to obtain a representative sample prior to the period of extended operation.
Issue. The LRA states that the inspections will be performed on a representative sample of components prior to the period of extended operation, but does not discuss whether the inspections will be performed periodically during the period of extended operation.
Reguest. Clarify if the visual inspections will be performed periodically during the period of extended operation and the basis for the frequency of inspections.
RAI 8.1.21-4 Background. GALL Report AMP XI.M27 recommends flow testing or wall thickness evaluations to ensure the system maintains its intended function. GALL Report AMP XI.M27 states that wall thickness evaluations may be performed using either non-intrusive techniques or visual inspection of the internal surfaces of the piping and that inspections should be performed prior to the end of the period of extended operation and at plant-specific intervals thereafter.
LRA Section B.1.21 states an enhancement to the "detection of aging effects" and "acceptance criteria" program elements to include visual inspection of the interior surface of below grade fire protection piping for a representative number of locations at least once every ten years during the period of extended operation.
NFPA 25, "Inspection Testing and Maintenance of Water-Based Fire Protection Systems,"
recommends that underground and exposed aboveground private fire service mains be flow tested at least once every 5 years to determine the internal condition of the piping.
- 5 Issue. It is unclear if flow testing and visual inspections will be used to manage aging for the below grade fire protection piping. If only visual inspections will be performed, it is unclear if the inspections will be performed on a reasonable interval basis, as recommended by the GALL Report.
Request. Clarify if flow testing and visual inspections will be used to manage aging for the below grade fire protection piping. If only visual inspections will be performed, state the basis for the frequency of inspections, including any past inspection results which support the chosen inspection frequency.
RAI B.1.21-5 Backqround. GALL Report AMP XI.M27 recommends that sprinklers that have been in place for 50 years be replaced or a representative sample of sprinklers be field service tested at a recognized testing laboratory in accordance with NFPA 25, "Inspection Testing and Maintenance of Water-Based Fire Protection Systems." GALL Report AMP XI.M27 also recommends that sampling be performed at 1 a-year intervals after the initial field service testing.
LRA Section B.1.21 states an enhancement to the "detection of aging effects" program element to include testing or replacement of a representative sample of sprinkler heads prior to the end of their 50-year service life and at 1 a-year intervals thereafter during the period of extended operation.
Issue. If the option to replace the sprinklers is chosen, it is unclear to the staff whether the applicant intends to replace all sprinklers that have been in place for 50 years, or only replace a representative sample of sprinklers. If the option to test sprinkler heads is chosen, it is unclear to the staff whether the testing will be performed in accordance with the guidance in NFPA 25.
Request. If the option to replace the sprinklers is chosen, clarify whether all sprinkler heads that have been in place for 50 years will be replaced or if only a representative sample will be replaced. If the option to test sprinkler heads is chosen, clarify whether sprinkler head testing will be performed in accordance with NFPA 25. If replacement or testing will not be performed consistent with the GALL Report recommendations, provide justification for the chosen testing and replacement methods.
SUBJECT:
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]
RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource NFerrer DDrucker DWrona DMorey AWang RSmith, RIV BRice, RIV DMclntyre,OPA
'ML12076a009 OFFICE LARPB1 :DLR PM:RPB1 :DLR BC:RPB1 :DLR PM:RPB1 :DLR NAME YEdmonds NFerrer DMorey NFerrer DATE 03/30/12 041 11 112 04 113/12 04/17/12