GNRO-2003/00053, Application for Technical Specification (TS) Improvement to Revise TS 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves, Using the Consolidated Line Item Improvement Process.

Application for Technical Specification (TS) Improvement to Revise TS 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves, Using the Consolidated Line Item Improvement Process.

ML033090453
Person / Time
Site:	Grand Gulf
Issue date:	10/24/2003
From:	Forbes J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2003/00053, LDC 2003-090
Download: ML033090453 (10)

Text

'~~~~~~~~Ente-r01, rEn terV Entergy Box 756 P0~~~~~~~~~~.

Port Gibson, MS 39150 Tel 601 437 6409 Jeffrey S. Forbes Vice President-Operations Grand Gulf Nuclear Station GNRO-2003/00053 October 24, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Application for Technical Specification Improvement to Revise Technical Specification 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves",

Using the Consolidated Line Item Improvement Process (LDC 2003-090)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following Amendment for Grand Gulf Nuclear Station, Unit 1 (GGNS).

The proposed changes would revise the required action within TS 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves' for the condition of having one or more SDV vent or drain lines with one valve inoperable. These changes are based on Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404 (Revision 0) that has been approved generically for the BWR 6 Standard Technical Specifications (STS), NUREG-1434, Revision 2. The availability of this TS improvement was announced in the Federal Register on April 15, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP). In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of Mississippi. provides a description of the proposed change and the requested confirmation of applicability. The existing TS pages annotating the proposed changes are provided in . Changes to the TS Bases associated with the proposed changes to TS 3.1.8 are provided in Attachment 3 for your information and will be implemented in accordance with TS 5.5.11, Technical Specification Bases Control Program. There are no new regulatory commitments associated with this proposed change.

Entergy requests approval of the proposed amendment by March 1, 2004. Once approved, the amendment shall be implemented within 60 days.

4A91

I ; !. ,, 1 October 24, 2003 GNRO-2003/00053 Page 2 of 2 If you have any questions or require additional information, please contact Matt Crawford at 601-437-2334.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 24, 2003.

Sincerely, JSF/MLC/amt Attachments:

1. Analysis of Proposed Technical Specification Change 2: Proposed Technical Specification Changes (mark-up)

3. Changes to Technical Specification Bases Pages - For Information Only cc: U. S. Nuclear Regulatory Commission ATTN: Mr. Bruce Mallett Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. Bhalchandra Vaidya, NRR/DLPM ATTN: ADDRESSEE ONLY ATTN: U. S. Postal Delivery Address Only Mail Stop OWFNI7-D1 Washington, DC 20555-0001 Mr. Brian W. Amy, MD, MHA, MPH Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 Mr. T. L. Hoeg, GGNS Senior Resident Mr. D. E. Levanway (Wise Carter)

Mr. L. J. Smith (Wise Carter)

Mr. N. S. Reynolds Mr. H. L. Thomas

Attachment I GNRO-2003100053 Analysis of Proposed Technical Specification Change to Letter GNRO-2003/00053 Page 1 of 2

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-29 for Grand Gulf Nuclear Station (GGNS). The proposed changes would revise the required action within TS 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves" for the condition of having one or more SDV vent or drain lines with one valve inoperable.

These changes are based on Technical Specifications Task Force (TSTF) change traveler TSTF-404 (Revision 0) that has been approved generically for the BWRI6 Standard Technical Specifications (STS), NUREG-1434, Revision 2. The availability of this Technical Specification improvement was announced in the Federal Register on April 15, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Operations, Inc., (Entergy) has reviewed the safety evaluation published on April 15, 2003 (68 FR18294) as part of the CLIIP. This verification included a review of the NRC staffs evaluation as well as the supporting information provided to support TSTF-404. Entergy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to GGNS and justify this amendment for the incorporation of the changes to the GGNS Technical Specifications.

2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the Technical Specification changes described in TSTF-404 or the NRC staff's model safety evaluation published on April 15, 2003.

3.0 REGULATORY ANALYSIS

3.1 Applicable Regulatory Requirements/Criteria Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any General Design Criterion (GDC) differently than described in the Updated Final Safety Analysis Report (UFSAR).

3.2 No Significant Hazards Consideration Entergy has reviewed the proposed no significant hazards consideration determination published on April 15, 2003 as part of the CLIIP. Entergy has concluded that the proposed determination presented in the notice is applicable to GGNS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

to Letter GNRO-2003/00053 Page 2 of 2 3.3 Environmental Considerations Entergy has reviewed the environmental evaluation included in the model safety evaluation published on April 15, 2003 as part of the CLIIP. Entergy has concluded that the NRC staffs findings presented in that evaluation are applicable to GGNS and the evaluation is hereby incorporated by reference for this application.

4.0 COMMITMENTS There are no new regulatory commitments associated with this proposed change.

Il; Attachment 2 GNRO-2003/00053 Proposed Technical Specification Changes (mark-up) to GNRO-2003/00053 Page 1 of 1 sl'^. II SDV Vent and Drain Valves 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 Scram Discharge Volume (SOV) Vent and Drain Valves LCO 3.1.8 Each SOV vent and drain valve shall be OPERABLE.

APPLICABILITY: MODES I and 2.

ACTIONS /-

-h----------------------------------- NOTE -----------------------------------

Separate Condition entry is allowed for each SDY vent and drain line.

/ CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SDV vent A.lI re 7 days or drain lines with (

one valve noperable.

B. One or ore So vent hours or draln lines wth 2. An olated ltnI ay be unisolated under

\ 1noperable. ~~administrative

\ ~~~~~~~~~control to allow

_ draining andvetn

------3-- -----

8.1 Isolate the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> assoctated line.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

GRAND GULF 3.1-26 Amendment No. 120

Attachment 3 GNRO-2003100053 Changes to Technical Specification Bases Pages For Information Only

-~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~I 0sW§It

) .1 ; J Attachment 3 to .

GNRO-2003/00053 IX Page 1 of 2 SDY Vent and Drain Valves B 3.1.8 BASES APPLICABLE allow continuous drainage of the S during normal plant SAFETY ANALYSES operation to ensure the SDV has sufficient capacity to (continued) contain the reactor coolant discharge during a full core scram. To automatically ensure this capacity, a reactor scram (LCO 3.3.1.1, 'Reactor Protection System (RPS)

Instrumentation') s initiated f the SDY water level exceeds a specified setpoint. The setpoint is chosen such that all control rods are inserted before the SV has insufficient volume to accept a full scram.

SOY vent and drain valves satisfy Criterion 3 of the NRC Policy Statement.

LCO The OPERABILITY of all S vent and drain valves ensures that, during a scram. the SDV vent and drain valves will close to contain reactor water discharged to the SY piping.

Since the vent and drain lines are provided with two valves in series, the single failure of one valve in the open position will not impair the isolation function of the system. Additionally, the valves are required to be open to ensure that a path is available for the SOY piping to drain freely at other times.

APPLICABILITY In MODES and 2, scram may be required. and therefore, the SDY vent and drain valves must be PERABLE. In MODES 3 and 4, control rods re not able to be withdrawn since the reactor mode switch is n shutdown and a control rod block I is applied. This provides adequate controls to ensure that only a single control rod can be withdrawn. Also, during "ODE only a single control rod can be withdrawn from a core cell containing fuel assemblies. Therefore. the SV vent and drain valves are not required to be OPERABLE n these MODES since the reactor is subcritical and only one rod may be withdrawn and subject to scram.

ACTIONS The ACTIONS table is modified by Note'indicating that a separate Condition entry is all oIed for each SDY vent and drain line. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each noperable SDY line. Complying with the Required c + Droned Actions may allow for continued operation, and subsequent Jn

._jAzcns r t o T inoperable SDY lines are governed by subsequent Condition nfKi P-* entry and application of associated Required Actions.

- -en-.- --. tn

. . L GRAND GULF 31-46 Revision No. I to -r"' 4 ' z' , "

GNRO-2003/00053 Page 2 of 2 SDY Yent and Drain Valves B 3.1.8 it PrLJ re ACTIONS A.1 wU 11riidai\\e )oe ;tio@ °CJe S (continued) "esc -10O- Xch J When oSWveto rnvae noiloeai_

ro g rore lines ther~-

tU9Tf1i~zZ;5frb~ The9oleton Time is reasonable, lehe Ii-Tl of redundancy in the lines and the ow rob ity o7 a scra occurrinuring the trie valve(s) the aresered IX\

oe 3<

sa1ntreE The SY s still solable'since the redudn o~~~~~~~

fete ne is OPERABE.gJ Since-th E f li~2

_ ~*4 SWI16 tsoabJe,.the btwectea 3VJn yse p~rd\t tp~'bea ?ector-scram oa SYba ee ~r these pefTrMs, the single'tallur criterion may not be preserved, and a higher risk exists to llow reactor water out of the primary system during a scram.

8.1 Ifboth valves ina line are inoperable, the line must be

_isolated to contain the reactor coolant during a scram.

When a llne is isolated, the potential for an inadvertent-scram due to high SOY level _IsincreasedSR~fi7 )N trra$bnqf oftheDVj L.ie 5nif olted1 'During these periods. the I1ne may be nisolated under administrative control. This allows any accumulated water in the line to be drained, to preclude a reactor scram on SOY high level.

This is acceptable, since the administrative controls ensure the valve can be closed quickly, by a dedicated operator if a scram occurs with the valve open.

The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion ime to isolate the line is based on the low probability of a scram occurring while the line is not solated and unlikelihood of significant CRD seal leakage.

C.]

If any Required Action and associated Completion Time is not met, the plant must be brought to a WOE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion (cont1nuedl GRAND GULF 8 3.1-47 Revision No.

Insert -

The ACTIONS table Is modified by a second Note stating that an soalted line may be unisolated under administrative control to allow draining and venting of the SDV.