GNRO-2006/00036, License Amendment Request, Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process (TSTF-372)

License Amendment Request, Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process (TSTF-372)

ML063130353
Person / Time
Site:	Grand Gulf
Issue date:	11/01/2006
From:	Brian W Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2006/00036, TSTF-372
Download: ML063130353 (16)

Text

QEntergy Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Tel 601 437 2800 GNRO-2006/00036 November 1, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License Amendment Request Application For Technical Specification Change To Add LCO 3.0.8 On the Inoperability Of Snubbers Using the Consolidated Line Item Improvement Process (TSTF-372)

REFERENCES:

1) Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-372, "Addition of LCO 3.0.8, Inoperability of Snubbers," Revision 4.

2) Federal Register Notice 70 FR 23252, "Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding The Addition of Limiting Condition for Operation 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process," dated May 4, 2005.

Dear Sir or Madam:

Pursuant to 10 CFR 50.90 Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station (GGNS), Unit 1.

The proposed amendment would modify TS requirements for inoperable snubbers by adding LCO 3.0.8. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) change TSTF-372, "Addition of LCO 3.0.8, Inoperability of Snubbers," Revision 4. The availability of this TS improvement was published in the FederalRegister on May 4, 2005 as part of the Consolidated Line Item Improvement Process (Reference 2).

ý-C)01

GNRO-2006/00036 Page 2 Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides summary of the regulatory commitments made in this submittal. Attachment 4 provides the existing TS Bases pages marked up to show the proposed change (for information only).

Entergy requests approval of the proposed amendment by January 3, 2007. Once approved, the amendment shall be implemented within 90 days. Although this request is neither exigent nor emergency, your prompt review is requested.

If you have any questions or require additional information, please contact Mr. Matt Crawford at (601) 437-2334.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 1, 2006.

Sincerely,

_, William R. Brian Acting GGNS Vice President, Operations MLC/amt Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes

3. Regulatory Commitments

4. Proposed Technical Specification Bases Changes cc: (See Next Page)

GNRO-2006/00036 Page 3 cc: NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Dr. Bruce S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. Bhalchandra Vaidya, NRR/DORL (w/2)

ATTN: ADDRESSEE ONLY Mail Stop OWFN/O-7D1A Washington, DC 20555-0001 Mr. Brian W. Amy, MD, MHA, MPH Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 Mr. D. E. Levanway (Wise Carter)

Mr. L. J. Smith (Wise Carter)

Mr. N. S. Reynolds Mr. J. N. Compton

Attachment 1 GNRO-2006/00036 Description and Assessment to GNRO-2006/00036 Page 1 of 2

1.0 DESCRIPTION

The proposed amendment would modify Technical Specification (TS) requirements for inoperable snubbers by adding LCO 3.0.8 for the Grand Gulf Nuclear Station (GGNS), Unit 1.

The changes are consistent with Nuclear Regulatory Commission (NRC) apprcved Industry/Technical Specification Task Force (TSTF) change TSTF-372, "Addition of LCO 3.0.8, Inoperability of Snubbers," Revision 4. The availability of this TS improvement was published in the FederalRegister on May 4, 2005 as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy has reviewed the safety evaluation published on May 4, 2005 (70 FR 23252) as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-372. Entergy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to GGNS, Unit 1 and justify this amendment for the incorporation of the changes to the GGNS, Unit 1 TS.

2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the TS changes described in the TSTF-372 Revision 4 or the NRC staff's model safety evaluation published on May 4, 2005 (70 FR 23252).

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Entergy has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the FederalRegister as part of the CLIIP. Entergy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to GGNS, Unit 1 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on May 4, 2005 for this TS improvement, plant-specific verifications were performed as follows:

Entergy has established TS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements. LCO 3.0.8 requires that risk be managed and assessed. The Bases also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk to GNRO-2006/00036 Page 2 of 2 assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. provides the regulatory commitment made in this submittal.

4.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model safety evaluation dated May 4, 2005 as part of the CLIIP. Entergy has concluded that the staff's findings presented in that evaluation are applicable to GGNS, Unit 1 and the evaluation is hereby incorporated by reference for this application.

Attachment 2 GNRO-2006/00036 Proposed Technical Specification Changes

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the except as provided in LCO 3.0.2 LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a. MODE 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

b. MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and

c. MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES or other (continuedl GRAND GULF 3.0-1 Amendment No. 120

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

GRAND GULF 3.0-3 Amendment No. 120

INSERT I (Applicable to Technical Specification Page 3.0-3 for GGNS, Unit 1)

LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

Attachment 3 GNRO-2006/00036 Regulatory Commitments to GNRO-2006/00036 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 SCHEDULED ONE-ck One) COMPLETION TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (IfRequired)

ENTERGY will establish the Technical X 90 days following Specification Bases for LCO 3.0.8 as NRC approval of the adopted with the applicable license License amendment. Amendment Request

Attachment 4 GNRO-2006/00036 Proposed Technical Specification Bases Changes

I LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES OS LCOs LCO 3.0.1 through LCO 3.0 establish the general requirements applicable toAll Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the (continued)

GRAND GULF 8 3.0-1 Revision No. 0

I LCO Applicability B 3.0 BASES LCO 3.0.6 exists, the appropriate Conditions and Required Actions of (continued) the LCO in which the loss of safety function exists are required to be entered.

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the -unit.

These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions. Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS. Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO's ACTIONS may direct the other LCO's ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.

GRAND GULF B 3.0-9 Revision No. 1

INSERT 2 (Applicable to Technical Specification Page B 3.0.9 for GGNS, Unit 1)

LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.

If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system.

LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.