GNRO-2004/00013, Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process, LDC-2003/102

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process, LDC-2003/102

ML040570652
Person / Time
Site:	Grand Gulf
Issue date:	02/18/2004
From:	Gerald Williams Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2004/00013
Download: ML040570652 (11)

Text

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Entergy Box 756 Port Gibson, MS 39150 Tel 601 437 6409 George A. Williams Vice President - Operations Grand Gulf Nuclear Station GNRO-2004/00013 February 18, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk:

Washington, DC 20555-0001

Subject:

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process, LDC-2003/102 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 to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS).

The proposed amendment will delete the TS requirements related to hydrogen recombiners and hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors, that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler, TSTF-447,"Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors" The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

Attachment I provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Implementation of TSTF-447 also involves various changes to the TS Bases. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.11,"Technical Specifications (TS) Bases Control Program."

GNRO-2004/00013 Page 2 The proposed change includes a new commitment as summarized in Attachment 3.

Entergy requests approval of the proposed amendment by June 1, 2004. Once approved, the amendment shall be implemented within 120 days.

If you have any questions or require additional information, please contact Ron Byrd at 601-368-5792.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 18, 2004.

Sincerel GAWRWB/a t Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. List of Regulatory Commitments cc: U.S. Nuclear Regulatory Commission ATTN: Mr. Bruce S. Mallett (w/2)

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 (w/2)

ATTN: ADDRESSEE ONLY ATTN: U.S. Postal Delivery Address Only Mail Stop OWFN/7D-1 Washington, D.C. 20555-0001 Mr. Brian W. Amy, MD, MHA, MPH Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector (w/o)

Grand Gulf Nuclear Station Port Gibson, MS 39150 Levanway D. E. (Wise Carter) (w/o)

Reynolds N. S. (w/o)

Smith L. J. (Wise Carter) (w/o)

Thomas H. L. (w/o)

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l + t b b Attachment 1 GNRO-2004/0001 3 . .

Analysis of Proposed Technical Specification Change I .  :

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to GNRO-2004/00013 Page 2 of 3 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

Entergy has reviewed the Safety Evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staff's SE, as well as the supporting information provided to support TSTF-447. Entergy has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to GGNS and justify this amendment for the incorporation of the changes to the GGNS TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, Entergy is making the following verifications and regulatory commitments:

1. Entergy has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at GGNS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual (TRM). This regulatory commitment will be implemented within 120 days of amendment issuance.

2. GGNS does not have an inerted containment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Entergy has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) 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).

8.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. Entergy has concluded that the staffs findings presented in that evaluation are applicable to GGNS and the evaluation is hereby incorporated by reference for this application.

to GNRO-2004/00013 Page 3 of 3 9.0 PRECEDENT This application is being made in accordance with the CLIIP. Entergy is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staff's model SE published on September 25, 2003 (68 FR 55416).

10.0 REFERENCE Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003, (68 FR 55416).

Attachment 2 GNRO-2004/00013 Proposed Technical Specification Changes (mark-up) to GNRO-2004/000 13 Page 1 of 3 PAM Instrumentation 3.3.3.1

?&b$t 3.3.3.1-1 (page 1 of 1) fast Acciqnt P.'Itedri Initr~tawl.on IEIEIEn:£D FROM tEOUIRED REQUIRED fL£TICd t"ADlhELS ACTIOW 0.1

1. uerctor Vessel Pressure 2 C

2. teactor vessel Uater Level - lide Vange 2 E

3. Reactor Vassal Wear Level - fuel Zorw 2 E

4. Supra"slon Pact Wster Level 2 1

5. Suppression Potd Sector Yawts Taverturi 2 tc) E

6. crywt I Proessaw 2 C

7. crywelt 1.4atur.e 2 E

6. CAc Cedtiy leiVersturv 2 E

9. Prlmry Co.trlnt Pressure - twide tarve 2 t

10. Prleery Comtsfrmne Prtesure - Marrow RtvoI 2

11. Prirzy Contetrment Air Twpeittuvr 2 E

12. Primary Ceiwn-se4,t Area Radiatlon 2 f 13 0tt IAres 'medistion e., PetatI --- ---

F Xt on etleet PCIVAM PotIton 1O-2pP MJ E

(a) kot required for isolation valels ho*se Iaceoceted pw*tts:Ion flow path Is isolated.

Cb) Onty oe poelelen Iidletlon c~ehreto 1s reqired for poetration flow paths with enly one Installed control ream indication channel.

tc) Potltrinip eacA of six c ctOrs.

GRANo GULF 3.3-22 Amendment No. 120 to GNRO-2004/0001 3 Page 2 of 3 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 rr Containment Hydrogen Reoobiners GRAND GULF 3.6-35Ai1 Am~endment No. 120 to GNRO-2004/00013 Page 3 of 3 Primary Contaimient Hydrogen Recombine 3 .

SURVEILLA REQUIREEMSHS SURVEILLANCE FREQUENCY SR 3.6.3.1.3 Perfo system functional test cach 18 months primary c anmbent hydrogen r mbiner.

SR 3.6.3.1.2 Visually examine irmary containment 28 months hydrogen reco er c ure and verify there is no dence of abn Ii conditic SR 3.6.3.1.3 Perforn a resistance to ground test for 18 months each heater phase.

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Attachment 3 GNRO-2004/0001 3 List of Regulatory Commitments to GNRO-2004/0001 3 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Entergy has verified that a hydrogen monitoring X Within 120 system capable of diagnosing beyond design-basis days of accidents is installed at GGNS and is making a amendment regulatory commitment to maintain that capability. issuance.

The hydrogen monitors will be included in the Technical Requirements Manual (TRM).

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