ML12286A024

RAI for the Review of the Grand Gulf Nuclear Station LRA

ML12286A024
Person / Time
Site:	Grand Gulf
Issue date:	10/19/2012
From:	Ferrer N License Renewal Projects Branch 1
To:	Mike Perito Entergy Operations
Ferrer N, 415-1045
References
TAC ME7493
Download: ML12286A024 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 19, 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, UNIT 1 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.

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

Enclosure:

As stated cc w/encl: Listserv

GRAND GULF NUCLEAR STATION LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION SET 40 RAI3.5.1-1 Background. License renewal application (LRA) Table 3.5.1 identifies several items as "not applicable" with a further discussion stating that the "listed aging effects do not require management at GGNS. Nonetheless, components are included in the [GALL recommended program(s)] to verify the absence of other aging effects, such as..." The table below contains two examples:

Item Component Aging Aging Further Discussion Number Effect!

Management Evaluation Mechanism Programs Recommended 3.5.1-55 Building Reduction in Structures No Not applicable.

concrete at concrete Monitoring Listed aging locations of anchor Program effects do not expansion capacity due require and grouted to local management at anchors; concrete GGNS.

grout pads degradation!

Nonetheless, for support service components are base plates induced included in the cracking or Structures other Monitoring concrete Program to verify aging the absence of mechanisms other aging effects, such as cracking, for components in this listing.

3.5.1-30 Pressure-Loss of lSI (IWE) and No Not applicable.

retaining preload due 10 CFR Part Listed aging bolting to self 50, Appendix effects do not loosening J

require management at GGNS.

Nonetheless, bolting components are included in the Containment Inservice Inspection - IWE and Containment Leak Rate Programs to verify ENCLOSURE

- 2 the absence of other aging effects, such as loss of materials, for the listed components.

Issue. For these items that the applicant has identified as "not applicable," but stated that the components are included in the GALL recommended program(s) to verify the absence of other aging effects, sufficient information has not been provided to verify the applicant's assertion that the aging effect(s) identified in the GALL Report would not require management at GGNS. It is not clear if the identified aging effect will be managed for the listed component(s) as recommended in the GALL Report. Although the LRA states that the components are included in the program, the staff's concern is that the applicant proposes to verify the absence of other aging effects, which is not equivalent to managing the identified aging effect(s) for the component, material, and environment combination.

In accordance with § 54.21 (a)(3), for each structure and component subject to an aging management review, the applicant must demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation. For all items where the GALL Report does not recommend further evaluation (i.e., the Further Evaluation Recommended column in LRA Table 3.5.1 is populated with the word "no"), the staff is seeking clarification and sufficient technical justification for excluding the listed aging effects from management.

Request.

a. For each item in Table 3.5.1 where no further evaluation is recommended that the applicant has identified as "not applicable," but stated that the components are included in the GALL recommended program(s) to verify the absence of other aging effects, provide the technical justification as to why the aging effect recommended in the GALL Report and specified in Table 3.5.1 line item does not apply, to GGNS, and/or why that aging effect does not require management.

b. If it is determined that components will be age-managed as recommended in the GALL Report, identify which aging management program(s) will be used to manage the identified aging effect during the period of extended operation.

RAI3.5.1-2 Background. LRA Table 3.5.1 identifies several items as "Consistent with NUREG-1801,"

however, in the Discussion column, the applicant states that the "listed aging effects do not require management at GGNS." The discussion further states, "Nonetheless, components are included in the [GALL recommended program(s)] to verify the absence of [other aging effects],

for components in this listing." Those components are identified in LRA Table 3.5.2, classified as generic note I with a plant-specific note 501, indicating that the aging effect is not applicable because the GGNS environment is not conducive to the listed aging effects. The table below contains an example:

- 3 Item Component Aging Aging Further Discussion Number Effect!

Management Evaluation Mechanism Programs Recommended 3.5.1-24 Concrete Increase in lSI (lWL) or No Consistent with (inaccessible porosity and Structures NUREG-1801.

areas):

permeability, Monitoring Listed aging dome; wall;

cracking, Program

• effects does not basemat;

. loss of require ring girders;

! material management at buttresses, (spalling, GGNS.

Concrete scaling) due Nonetheless, (inaccessible to components are areas):

aggressive included in the

• base mat, chemical Structures Concrete attack Monitoring (accessible Program to verify areas):

the absence of

• dome; wall; aging effects, such basemat as cracking and loss of material, for components in this I listing.

Issue. For the LRA Table 3.5.2 items that the applicant has classified as generic note I, plant-specific note 501, the GALL Report identifies the aging effect requiring management for the listed component, material, and environment combination. The applicant does not provide a technical basis for the statement that the aging effect requiring management, recommended by the GALL Report, is not applicable at GGNS. The applicant's statement that the GGNS environment is not conducive to the listed aging effects does not provide an adequate justification. Sufficient information has not been provided to verify the applicant's assertion.

In accordance with § 54.21 (a)(3), for each structure and component subject to an aging management review, the applicant must demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. Verifying the absence of other aging effects is not equivalent to managing the identified aging effect.

Request. For each LRA Table 3.5.2 item that cites generic note I, plant-specific note 501:

a. Clarify if the listed aging effect will be managed by the proposed program when the Discussion column states that listed aging effects does not require management at GGNS, but nonetheless, the components are included in the GALL recommended program to verify the absence of other aging effects.

b. If the aging effect will not be managed, provide technical justification as to why the GGNS environment would not be conducive to the listed aging effects.

ML12286A024 OFFICE LA:RPB1 :DLR PM:RPB1 :DLR BC: RPB 1:DLR PM: RPB1 :DLR NAME YEdmonds NFerrer DMorey NFerrer DATE 10/18/12 10/18/12 10/19/12 10/19/12

Letter to M. Perito from N. Ferrer dated October 19, 2012

SUBJECT:

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

HARDCOPY:

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