ML12101A360
| ML12101A360 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/26/2012 |
| From: | Ferrer N License Renewal Projects Branch 1 |
| To: | Mike Perito Entergy Operations |
| Ferrer N | |
| References | |
| TAC ME7493 | |
| Download: ML12101A360 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 26, 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 or e-mail nathaniel.ferrer@nrc.gov.
Sincerely, 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 9 RAI 8.1.41-1 Background. SRP-LR Section A.1.2.3.4, "Detection of Aging Effects," states that for condition monitoring programs, the frequency of inspections may be linked to plant-specific operating experience and the discussion should provide justification that the frequency is adequate to detect the aging effects before the loss of an intended function.
Procedure 07-S-07-211, "Service Levell Coatings Condition Assessment," Section 6.0, "Frequency of Inspection," states that the time between inspections of pipe coating in the standby service water basin will not exceed 36 months.
Issue. Plant-specific operating experience in condition reports CR-GGN-201 0-05825 and CR-GGN-2010-03814 describe instances where underwater coating inspections identified loss of material ranging from 0.134 inch to 0.200 inch, which occurred after approximately 12 months. It is not clear to the staff that the frequency specified in the coatings inspection procedure is adequate based on the amount of material loss in piping that can occur between inspections due to coating degradation.
Reguest. Provide the justification for the 36-month inspection frequency specified in the Procedure 07-S-07-211, "Service Levell Coatings Condition Assessment," or modify the procedure to reflect the current inspection frequency which appears to be less than 36 months.
RAI8.1.41-2 Background GALL Report AMP XI.M20, "Open-Cycle Cooling Water System," states that the program uses a combination of activities including condition monitoring to manage various aging effects including corrosion.
The Open Loop Strategic Plan, Section 4.2 "Sampling and Monitoring," states that Procedure 08-S-03-10, "Chemistry Sampling Program," governs the sampling parameters for the standby service water system. The strategic plan notes that corrosion coupon testing and trending is done quarterly with a target value of less than 5 mils per year for mild steel.
Procedure 08-S-03-10, Attachment VII, "Standby Service Water A & B," includes a corrosion coupon test every 6 months, but the table does not specify any control limit value and does not have any discussion or notes related to the corrosion coupon test. The staff noted that Grand Gulf Nuclear Station (GGNS) Updated Final Safety Analysis Report (UFSAR) Section 9.2.1.2 states long-term corrosion for the service water piping is compensated for by appropriate corrosion allowances.
Issue. Since corrosion coupon testing and trending were not discussed in the license renewal application (LRA), it is unclear to the staff how long-term corrosion of the piping is being managed and whether corrosion coupon testing and trending is being performed without any purpose or limit.
ENCLOSURE
-2 Request. Provide the bases for long-term corrosion of the standby service water piping.
Include a discussion regarding corrosion allowances provided for this piping and the lack of a need to include corrosion coupon testing and trending as part of Service Water Integrity Program. If corrosion coupon testing will be included in the program, for Procedure 08-S-03-10, provide the control limit value and its bases.
RAI B.1.41-3 Background. GALL Report AMP XI.M20, "Open-Cycle Cooling Water System," states that the program manages aging effects caused by various mechanisms including erosion. However, this aging management program (AMP) only considers solid particle erosion, and if an applicant identifies and chooses to manage a different form of erosion they should describe and explain this enhancement to the AMP.
Plant-specific operating experience CR-GGN-201 0-01344 discusses loss of material due to minor erosion/corrosion at the flanged connection to a discharge check valve, and proposes the inclusion of this section of standby service water piping in an "appropriate piping program (i.e.,
MS-46, Moderate Energy Piping)."
Issue. Although the program basis document indicated that loss of material in standby service water piping was also being managed by a Microbiologically-Influenced Corrosion Monitoring Program, it was not clear to the staff whether components in the standby service water system were also being managed for loss of material by a moderate energy piping program, which has not been described.
Reguest. Provide information regarding whether components that are being managed for loss of material by the Service Water Integrity Program are also being managed for loss of material by the MS-46, Moderate Energy Piping program. If components are being managed by a moderate energy piping program, provide information that addresses each of the program elements described in SRP-LR Appendix A.1.2.3, or provide the reference to previously docketed information that contains substantially the same information.
RAJ B.1.41-4 Background. GALL Report AMP XI.M20 states that the program addresses loss of material due to various corrosion mechanisms as described in the applicant's response to Generic Letter (GL) 89-13. LRA Section A.1.41 is consistent by stating the Service Water Integrity Program manages loss of material as described in the GGNS response to GL 89-13.
In its response to GL 89-13 (AECM-90/0007), GGNS stated that, as a result of microbiological activity in the standby service water system, it had implemented a Small Bore and Deadleg Pipe Inspection Program directed at piping with stagnant or low flow conditions. However, the LRA did not specifically discuss this program, and although Procedure EN-DC-340, "Microbiologically Influenced Corrosion (MIG) Monitoring Program," contains references to AECM-90/0007 and GL 89-13, the MIC Monitoring Program procedure did not specifically discuss implementation of GL 89-13.
-3 Issue. Since the Small Bore and Oeadleg Pipe Inspection Program, which is referenced in the GGNS response to GL 89-13, had not been described, it was not clear to the staff whether all aspects of that program are incorporated into the Service Water Integrity Program. In addition, although cited in the Service Water Integrity Program, the MIC Monitoring Program procedure only provided a general discussion for susceptible environments and MIC-susceptible system characteristics. As a result, it was not clear to the staff which components, other than those in the raw water environments, were within the scope of the MIC Monitoring Program procedure, and whether MIC Monitoring Program procedure supplemented any other AMP.
Request. Confirm that all aspects of the Small Bore and Oeadleg Pipe Inspection Program, which is referenced in the GGNS response to GL 89-13, have been incorporated into the Service Water Integrity Program. In addition, confirm if the MIC Monitoring Program procedure supplements any AMPs, other than the Service Water Integrity Program, to manage loss of material due to microbiologically-influenced corrosion.
RAI8.1.41-5 Background. SRP-LR Section A.1.2.3.1 0, "Operating Experience," states that operating experience including past corrective actions should be considered.
Plant operating experience identified in CR-GGN-2003-00919 describes an issue with the standby service water basin siphon line and states that numerous nodules and or areas of corrosion were visible on the internal surfaces of this piping and that the internal surfaces are inaccessible with respect to applying protective coatings. The condition report also states that this piping does not benefit from the water treatment program for the standby service water system. The staff noted that this line is discussed in UFSAR Section 9.2.1.3, which states that the interconnecting line between the two standby service water basins is required to ensure the availability of a 30-day water supply, and depending on the water level, the line either equalizes or siphons water from one basin to the other.
Issue. Since the siphon function may be affected by a pin-hole leak in the upper portion of interconnecting line, and given the lack of protective coatings and the lack of benefit from the water treatment program, it is not clear to the staff whether the inspections of this line are sufficient to ensure that the effects of aging will be adequately managed such that the intended function of the siphon line will be maintained.
Request. Provide justification that the current inspection program for the interconnecting line between the two standby service water basins is adequate to provide reasonable assurance that the intended functions will be maintained during the period of extended operation for the effect that pin-hole leaks may have on the siphon function of the line and for the effect that internal nodules will have equalizing flow rate.
RAI 8.1.43-1 Background. GALL Report AMP XI.M2, "Water Chemistry," program element for "parameters monitored or inspected,>> states that water quality is maintained in accordance with Electric Power Research Institute (EPRI) water chemistry guidance and chemical species and water quality are monitored in-process or through sampling.
-4 The LRA states that the Water Chemistry Control Program is consistent with the GALL AMP XI.M2, Water Chemistry, and that it uses the EPRI water chemistry guidelines.
Site procedure 01-S-08-29, "EPRI Water Chemistry Guidelines," Revision 009, Attachment I, "Chemistry Limits for Power Operation (greater than 1 0 percent power)," refers to Table 6-5a hydrogen water chemistry (HWC) of EPRI BWRVIP-190, "BWR Water Chemistry Guideline, 2008 Revision," and specifies the appropriate parameters for conductivity, chlorides and sulfates. However, BWRVIP-190 specifies a parameter for electrochemical corrosion potential (ECP), which is not specified in the applicant's procedure and is not discussed in the LRA. The staff noted that the GGNS Strategic Chemistry Plan, Revision 6, states Grand Gulf is a Category 2 plant with no ECP probes and no sister plant.
In addition, site procedure 08-S-03-10, "Chemistry Sampling Program," Revision 048, Attachment IV, for final feedwater power operation greater than 10 percent power, specifies a control limit for soluble zinc and refers to BWRVIP-190. The notes in BWRVIP-190, associated with the specified control limit for zinc, discuss this parameter as it relates to noble metal chemical addition (NMCA).
Issue. Based on the information provided by the applicant in the LRA and during the AMP Audit, it was unclear to the staff how the applicant determined the effectiveness of HWC and if the parameter specified in the EPRI guideline, for electrochemical potential, was being met. In addition, it was not clear whether NMCA is used at GGNS.
Request. Provide the following information with respect to the implementation of HWC in the Water Chemistry Control-BWR Program:
- a. Confirm the method of controlling hydrogen water chemistry in the reactor vessel.
- b. Confirm whether NMCA + hydrogen is used at GGNS, and if it is used to confirm whether on-line NMCA methodology is used
- c. Confirm that all conditions imposed in the staff's safety evaluation for the BWRVIP-62 report are met
- d. Provide details on the methods for determining the effectiveness of HWC by using the following parameters:
- electrochemical potential (ECP)
- main steam oxygen content
- hydrogen/oxygen molar ratio
- in-situ measurement of platinum deposit on the coupons per BWRVIP-62 RAJ 8.1.43-2 Background. SRP-LR, Table 3.0-1, "FSAR Supplement for Aging Management of Applicable Systems," for GALL AMP XI.M2 states that the water chemistry program monitors and controls
-5 contaminants below the system-specific limits based on EPRI guidelines, BWRVIP-190, "BWR Water Chemistry Guidelines - 2008 Revision," for BWRs.
LRA Section A.1.43, "Water Chemistry Control - BWR Program," states that the program uses EPRI water chemistry guidelines to manage aging effects by monitoring and controlling water chemistry. However, LRA Section A.1.43 does not refer to BWRVIP-190.
Issue. The program summary description in LRA Section A.1.43 is not complete and/or consistent with the program description in the LRA and guidance provided in SRP-LR Table 3.0-1.
Request. Provide further information showing why a reference to the specific EPRI water chemistry guideline is not required or revise LRA Section A. 1.43 to reflect the appropriate reference.
RAI 8.1.44-1 Background. The "parameters monitored/inspected" program element of GALL Report AMP XI.M21A, "Closed Treated Water Systems," recommends that the specific water chemistry parameters monitored and the acceptable range of values for these parameters should be in accordance with industry standard guidance documents, such as those described in EPRI Technical Report 1007820.
During its audit of the applicant's Water Chemistry Control - Closed Treated Water Systems Program, the staff noted that water chemistry in closed treated water systems is to be maintained in accordance with EPRI guidelines. However, the staff also noted that the plant's water chemistry control parameters were not always consistent with these guidelines.
Deviations from the EPRI 1007820 include, but are not necessarily limited to, missing control limits and control limits with undefined action levels.
Issue. It is unclear if water chemistry in the plant's closed treated water systems is being maintained in accordance with EPRI 1007820. Therefore, it is not clear if the control parameters are sufficient to ensure that corrosion can be effectively mitigated.
Request. Provide an enhancement to the Water Chemistry Control - Closed Treated Water Systems program to align the plant's water chemistry control parameters with those of EPRI 1007820 or state the technical justification for why the deviations from EPRI 1007820 will not adversely affect the ability of the water chemistry controls to mitigate corrosion.
RAI 8.1.44-2 Backqround. The "detection of aging effects" program element GALL Report AMP XI.M21A, "Closed Treated Water Systems," recommends that water testing intervals should be in accordance with the selected industry standard, but in no case should the testing interval be greater than quarterly unless justified with additional analysis. The guidelines in EPRI Technical Report 1007820 state that water chemistry testing of intermittently-used closed cooling water systems be performed monthly or as operated for all treatment programs except those based on
- 6 glycol. For glycol-based programs, EPRI 1007820 recommends quarterly (Tier 1 systems) or annual (Tier 2 systems) testing due to the stability of glycol and high concentrations of inhibitors.
An enhancement associated with the "detection of aging effects" program element of the LRA states that testing of the engine jacket water for the engine-driven fire water pump diesels will be performed at least once per refueling cycle. During its audit of the applicant's Water Chemistry Control-Closed Treated Water Systems Program, the staff noted that the justification for the testing interval was based on meeting the coolant supplier's guideline of servicing the coolant every 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> of operation.
Issue. It is unclear if the applicant's proposed testing frequency is sufficient to ensure that the jacket water chemistry remains effective in mitigating corrosion. Servicing guidelines based only on time of operation are not consistent with EPRI guidelines and do not account for changes in water chemistry, or the potential for corrosion, that could occur when the engine is not in use.
Request. State the technical justification for why testing of the engine jacket water for the engine-driven fire water pump diesels at an interval of at least once per refueling cycle is adequate to ensure that the ability of water chemistry to mitigate corrosion is maintained.
Alternatively, revise the testing frequency to be consistent with EPRI 1007820 guidelines.
RAI8.1.44-3 Background. In its review of the applicant's documentation on the NRC GL 89-13 Service Water Program, the staff noted that the program states that it is also applied to closed cooling loops, due to the potential for in-leakage, inadequate chemistry controls, or aging that may have occurred before the current chemistry control program became effective. The staff also noted that GL 89-13 program activities were not included in the onsite documentation of the Water Chemistry Control-Closed Treated Water Systems Program.
Issue. It is unclear to the staff which activities associated with the GL 89-13 program are applied to the aging management of closed treated water systems and what, if any, operating experience prompted the application of this program to closed cooling loops.
Request.
- a. State what aging management activities associated with the NRC GL 89-13 Service Water Program are applied to systems managed by the Water Chemistry Control Closed Treated Water Systems Program.
- b. State any operating experience that prompted the application ofthe NRC GL 89-13 Service Water Program to systems managed by the Water Chemistry Control - Closed Treated Water Systems Program.
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
'ML12101a360 OFFICE LARPB1 :DLR PM:RPB1 :DLR BC:RPB1 :DLR PM: RPB1 :DLR NAME YEdmonds NFerrer DMorey NFerrer DATE 4/19/12 4/25/12 4/25/12 4/26/12