AECM-88-0118, Application for Amend to License NPF-29,changing Reactor Protection Sys Instrumentation Surveillance Test Intervals & Allowable Outage Times.Proprietary MDE-80-0485 Encl.Rept Withheld (Ref 10CFR2.790).Fee Paid

Application for Amend to License NPF-29,changing Reactor Protection Sys Instrumentation Surveillance Test Intervals & Allowable Outage Times.Proprietary MDE-80-0485 Encl.Rept Withheld (Ref 10CFR2.790).Fee Paid

ML20150D549
Person / Time
Site:	Grand Gulf
Issue date:	06/30/1988
From:	Kingsley O SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML19292J046	List: AECM-88-0118, Application for Amend to License NPF-29,changing Reactor Protection Sys Instrumentation Surveillance Test Intervals & Allowable Outage Times.Proprietary MDE-80-0485 Encl.Rept Withheld (Ref 10CFR2.790).Fee Paid ML20150D563
References
AECM-88-0118, AECM-88-118, NUDOCS 8807140044
Download: ML20150D549 (6)

Text

_

Om D KtGLEt Jr2 ggl. June 30, 1988 U. S. Nuclear Regulatory Comission Mail Station P1-137 Washington, D. C. 20555 Attention: Document Control Desk Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Extension of RPS Instrumentation Surveillance Intervals and Allowed Outage Times Proposed Amendment to the Operating License (PCOL-88/09)

AECM-88/0118 System Energy Resources, Inc. (SERI) is submitting by this letter a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License. This proposed amendment consists of changes to the Reactor Protection System (RPS) instrumentation curveillance test intervals and allowable outage times. These changes are based upon General Electric Company (GE) Topical Report NEDC-30851P and the corresponding plant specific report (MDE-80-0485). These reports provided the analytical bases supporting an extension of the functional test interval for RPS instrumentation from monthly to quarterly. Tne NRC generic Safety Evaluation Report (SER) approving NEDC-30851P was issued July 15, 19P7 The SER contained three conditions requiring each applicant for proposed RF instrumentation Technical Specifications changes to address on an individual plant basis. Subsequent to the generic SER's issuance, the NRC issued a letter dated April 27, 1988 providing guidance and clarification regarding the NRC's requirement for confirmation of instrument drift all'wances, which is one of the three conditions each applicant must address.

Attachment III of this letter provides the plant specific response to the three conditions contained in the NRC generic SER of NEDC-30851P, as modified by an NRC letter dated April 27, 1988.

GE report MDE-80-0485, dated April 1985 is submitted as Attachment IV to support the above GGNS plant specific response. This document contains infonnation which GE considers confidential and proprietary. Consequently, it ,

is requested that this report (Attachment IV) be withheld from public disclosure in accordance with 10 CFR 2.790. An executed affidavit by Ricardo Artigas, Manager, Licensing and Consulting Services of GE, is included as part of (

Attachment IV in support of this request.

8807140044 890630 i I I PDR ADOCK 05000416 I PDC P

w - poscms-m wm geeg[Lh3 0N

" ' " " " " " g0 J16AECM88060201 - 1

<a AECM-88/0117

'w Page 2 Attachment.V is an addendum documenting changes in the plant specific model evaluated by GE in report MDE-80-0485.

Attachment . provides a detailed description of the. proposed Technical Specification changes and justification for the changes. Attachment.VI also details the basis for the SERI determination that the proposed amendment involves no 1gnificant hazards considerations based on the guidelines presented in 10 CFR 50.92. The proposed changed Technical Specification pages follow Attachment VI.

In accordance with the provisions of 10 CFR 50.4, the original of the requested amendment is enclosed and the appropriate copies will be distributed.

Both this proposed amendment and the consideration of no significant hazards have been reviewed and accepted by the Plant Safety Review Comittee and the Safety Review Committee.

In accordance with the requirements of 10 CFR 170.21, an application fee

(

of $150 is attached to this letter.

The proposed amendment is needed by December 16, 1988 to allow adequate time for schedule development and resource planning for the third refueling outage. Approval of the proposed amendment will allow the affected RPS surveillances to be performed outside of the outage window. This will permit a better focus on outage related work activities that cannot be perfonted with the plant at power.

You ruly,

/

9 n '

ODK:bms Attachments: 1. Remittance of $150 Application Fee II. Affirmation per 10 CFR 50.30 III. GGNS Response to NEDC-30851P NRC Generic SER Conditions IV. General Electric Company Report MDE-80-0485 (Proprietary)

V. Addendum to General Electric Company Report MDE-80-0485 VI. GGNS PCOL-88/09 cc: (See Next Page)

J16AECM88060201 - 2

r,

[. - AECM-88/0117-

"C ,

Page 3'

- cc: ~ .'Mr. . T; H. Cloninger (w/a)

Mr. N.R.-B.-McGehee Mr. S. Reynolds (w/a (w/a))

Mr. H. L. Thomas'(w/o)

Mr. R. C. Butcher (w/a)

Dr. J. Nelson Grace, Regionhl Administrator (w/a)

U. S. Nuclear Regulatory Comission

. Region II 101-Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323  ;

.Mr. L. L. Kintner, Project Manager (w/a)

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Mail Stop 14820 Wishington, D.C. 20555-Dr. Alton B. Cobb (w/a)

State Health Officer State Board of Health Box 1700 Jackson, Mississippi 39205 o

J16AECM88060201 - 3

y o :e BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE N0 NPF-29 DOCKET N0. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT-COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, 0. D. Kingsley, Jr., being duly sworn, state that I am Vice President, Nuclear Operations of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by System Energy Resources, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of System Energy Resources, Inc.; and that the statements made and the matters set f therein are true 1 ef.

and correct to the best of my knowledge, information anI

/, '

.\ ./ /,

' V. W Kirvis1gy .

STATE OF. ISSISSIPPI (

COUNTY OF dINDS SUBSCRIBED AND SWORN T0 before me, a No ar Public, in and for the County and State above named, this 1 day of - , 1988.

{l (SEAL)

Notary Public My commission expires:

vg comminha Exti ns sept. 2r, Ltu J16AECM88060201 - 5 a-- e . - m - - - -

n k

Attachment III to

.o. AECM-88/0118

-Grand Gulf Nuclear Stt. tion Unit 1 Response to Conditions Specified in t,h_e NRC SER of NEDC-30851P Enclosure 1 of the letter from'A. C. Thadani (NRC) to T. A. Pickens

.(BWROG)datedJuly 15, 1987 is the NRC's Safety-Evaluation Report (SER) on General. Electric Company (GE) Topical Reports NEDC-30844, "BWR Owners' Group Response to NRC Generic Letter 83-28, Item 4.5.3," and NEDC-30851P, "Technical Specification Improvement Analyses for BWR' Reactor Protection System." The SER concluded that the analyses presented in the BWR Owners' Group Report, NEDC-30851P provided an acceptable generic basis for supporting plant specific Technical Specification changes related to the Reactor Protection System (RPS) for plants using a relay RPS. The SER contained the following conditions that an individual licensee must address on a plant specific basis:

1. Confirm the applicability of the generic analyses to its plant.

2. Demonstrate, by use of current drift information provided by the equipment vendor or plant specific data, that the drift characteristics for instrumentation used in RPS channels in the plant are bounded by the assumption used in NEDC-30851P when the functional test interval is extended from monthly to quarterly.

3. Confirm that the differences between the parts of the RPS that perform the trip functions in the plant and those of the base case plant were included-in the analysis for its plant done using the procedures of Appendix K of NEDC-30851P (and the results presented in Enclosure 1 to letter 0G5-491-12 from L. Rash (GE) to T.' Collins (NRC) dated November 25,1985), or present plant specific analyses to demonstrate no appreciable change in RPS availability or public risk.

In a letter from Charles E. Rossi (NRC) to Robert F. Janecek (BWROG) dated April 27, 1988, the NRC provided clarification for licensees on how to address the setpoint drift issue of the second SER condition described above.

The NRC stated licensees need only confirm that the setpoint drift which could be expected under the extended surveillance test intervals (STIs) has been studied and either (1) has been shown to remain within the existing allowance in the RPS instrument setpoint calculation or (2) that the allowance and setpoint have been adjusted to account for the additional expected drift.

These items are addressed below:

1. A plant specific review of the applicability of NEDC-30851P to Grand Gulf Nuclear Station (GGNS) has been conducted. The review compared the GGNS RPS configuration and surveillance procedures with the generic RPS evaluated in NEDC-30851P.

J16AECM88060201 - 6

4

+

Attachment'III to

.i AECM-88/0118 Differences between the two were identified and the reliability effect of the differences was assessed. The differences and their effect are documented in GE report MDE-80-0485, "Technical Specification Improvement Analysis for the Reactor Protection  :

System for Grand Gulf Nuclear Station Units 1 and 2", dated April 1985 -(Attachment IV). The report identifies three differences which were dispositioned by either an engineering assessment or additional analyses. The report concluded that the generic analysis is applicable to GGNS.

2. The NRC provided guidance as to how to' address Condition 2 as stated in the SER_in an April 27, 1988 letter. Based on the guidance provided by the NRC the following information is submitted with respect to this condition:

The additional tinie interval between tests resulting from the changes described in NEDC-30851P, and requested in Attachment VI of this submitt 1, is already factored into the instrument setpoint calculations-for the affected instruments. As stated in the Bases to Technical Specification 2.2.1, the difference between each RPS instrument trip setpoint and the allowable value is equal to or greater than the drift allowance assumed for each trip in the plant-safety analyses. The setpoint calculations conservatively assume an eighteen month calibration interval and the drift based upon vendor supplied values associated with that interval with no credit taken for the currently specified 31 day functional test. This assumption in the setpoint calculations therefore bounds any drift which could be expected.over the 92 day functional test interval proposed.

As such, revised instrument setpoints or allowable values are not required to accomodate the longer test intervals requested ,

in Attachment VI.

3. System Energy Resources, Incorporated has reviewed the enclosed GE plant specific report for GGNS (MDE-80-0485) and has verified that the differences between the GGNS and generic RPS were included in the plant. specific analysis. However, since the plant specific analysis was done (April 1985), four changes have occurred which make GGNS more similar to the generic plant. These four changes have no effect upon the GE plant specific analysis results and are discussed in Attachment V of this submittal. Therefore, the generic analysis in NEDC-30851P is applicable to GGNS.

J16AECM88060201 - 7

--