GNRO-2008/00044, Report of 10CFR50.59 Evaluations and Commitment Changes - April 1, 2007 Through March 31, 2008

Report of 10CFR50.59 Evaluations and Commitment Changes - April 1, 2007 Through March 31, 2008

ML081420444
Person / Time
Site:	Grand Gulf
Issue date:	05/19/2008
From:	Larson M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2008/00044
Download: ML081420444 (16)

Text

Entergy Operations, Inc.

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GNRO-2oo8/00044 May 19, 2008 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk SUbject: Report of 10CFR50.59 Evaluations and Commitment Changes-April 1, 2007 through March 31, 2008 Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

Pursuant to 10CFR50.59(d)(2) Entergy Operations, Inc. hereby submits a summary of 50.59 evaluations for the period of April 1,2007 through March 31, 2008. Also attached is the summary of commitment changes for the same period in accordance with NEI 95-07 Guidelines.

If you have any questions or require additional information, please contact Dennis Coulter at 601-437-6595.

This letter does not contain any commitments.

Yours Truly, Michael J. Larson Acting Licensing Manager MJUDMC:dmc Attachments: 1. Table of Contents

2. 10CFR50.59 Evaluations and Commitment Change Evaluations cc: (See Next Page)

G080044

GNRO-2008/00044 Page 2 cc: NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. Elmo E. Collins, Jr. (w/a)

Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. Jack N. Donohew, Jr., NRR/APROI DORL (w/2)

ATTN: ADDRESSEE ONLY ATTN: U. S. Postal Delivery Address Only Mail Stop OWFN/O-8G14 Washington, DC 20555-0001 G080044

Attachment 1 Table of Contents Grand Gulf Nuclear Station 10CFR50.59 Evaluation and Commitment Change Evaluation Report for the Period April 1, 2007 through March 31, 2008 Acronyms ARt Alarm Response Instruction LOP Loss of Power ASTM American Society for Testing and Materials MAPLHGR Maximum Average Planar linear Heat Generation Rate CCE Commitment Change Evaluation MCPR Minimum Critical Power Ratio CMWT Core Megawatts Thermal MNCR Material Non-Conformance Report CR Condition Report MOV Motor Operated Valve DCP Design ChanQe PackaQe MS Mechanical Standard EP Emergency Procedure MSIV-LCS Main Steam Isolation Valve Leakage Control System EPI Equipment Performance Instruction NPE Nuclear Plant Engineering EPRI Electric Power Research Institute NSSS Nuclear Steam Supply System ER Engineering Request PDMS Plant Data ManaQement System ES Electrical Standard PPM Parts per Million ESF Engineered Safety Feature PRA Probabilistic Risk Assessment GE General Electric PSW Plant Service Water GG Grand Gulf RCIC Reactor Core Isolation CoolinQ GGN Grand Gulf Nuclear RFO RefuelinQ Outage GPM Gallons per Minute RHR Residual Heat Removal 101 Integrated Operating Instruction RPV Reactor Pressure Vessel lSI In Service Inspection SCN Standard Change Notice 1ST In Service TestinQ SERI System Energy Resources, Inc.

LBDC License Basis Document Change SGTS Standby Gas Treatment System LDC License Document Change SOER Significant Operating Experience Report LHGR Linear Heat Generation Rate SSW Standby Service Water LLRT Local Leak Rate Test TRM ITS Technical Requirements Manual I Technical Specifications LOCA Loss of Coolant Accident UHS Ultimate Heat Sink Page 1 of 3 GOB0044

Attachment 1 Table of Contents Grand Gulf Nuclear Station 10CFR50.59 Evaluation and Commitment Change Evaluation Report for the Period April 1, 2007 through March 31, 2008 Safety Evaluations Evaluation Number Initiating Document Summary SE 2007-0002-ROO EC 1553 Modification to disable the trip logic of the generator terminal box liquid level automatic trip function circuit Page 2 of 3 G080044

Attachment 1 Table of Contents Grand Gulf Nuclear Station 10CFR50.59 Evaluation and Commitment Change Evaluation Report for the Period April 1, 2007 through March 31, 2008 Commitment Change Evaluations Commitment Source Document Summary Number CCE 2007-0001 AECM 90/0007 Revision to air-to-water heat exchanger performance verification methodology to allow inspections in lieu of thermal performance testina Page 3 of 3 G080044

Attachment 2 10CFR50.59 Evaluations and Commitment Change Evaluations G080044

GGNS 50.59 Safety Evaluation Number SE 2007-0002-ROO

, G080044

10 CFR 50.59 EVALUATION FORM Sheet 1 of 3 I. OVERVIEW I SIGNATURES' I ;:;::¥"t* . 1 l~q:;*~~~~'2.:.:

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Proposed Change I Document: EC 1553 Description of Change: The Deviation alarm is in for the liquid level detection for the Generator Terminal box. The O~?

problem is the circuit card for IN43N107. This change will defeat the trip logic. This modification wiD disable the Liquid Level Automatic Trip function of this circuit. This modification will prevent spurious deviation alarms and also spurious trips that might be caused by an uncontrolled failure of IN43NI07 were it to be left in the system.

Is the validity of this Evaluation dependent on any other change? 0 Yes t8I No If "Yes," list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be Implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action Is completed.

, does the proposed change 0 Yes t8I No Ol/S stem En ineerin 5-24-2007 pany / Department / Date Reviewer: Robert W. Fuller / ~lj/t.I!k EOI/ Design Engineering/5-25-07 Name (print) / Signature / Company / Department / Date OSRC: / 0ol1'P W* THo~TOf'J (~ W. ~ / -S;/ZS/07 Chairman's Name (print) / Signature / Date ~ ~ ,

OSRe Meeting # <' I q - 2.(:)07 II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of evaluation ONLY? If "Yes," Questions 1 - 7 are not applicable; answer only Question 8. If "No," answer all questions below. 0 Yes t8I No Does the proposed Change:

1. Resuh in more than a minimal increase in the frequency of occurrence of an accident 0 Yes previously evaluated in the UFSAR? t8I No BASIS: The described change is intended to reduce the likelyhood of an inadvertent turbine trip due to the faiiure of an electrical component. Turbine trip is an accident included in USFAR Section 15.8.1 ATWS. The main accident of concern when dealing with the turbine/generator is the generator load reject with failure of bypass flow (UFSAR 15.2.2). This is a moderate frequency event. The liquid level trips are used to protect the non safety related generator from equipment damage. With the trips bypassed, operators will be relied on to monitor liquid level parameters associated with the trip being bypassed. With the trips bypassed, the system will not initiate any action or event that would increase the frequency of occurrence of an accident previously evaluated in the FSAR.

1 Signatures may be obtained via electronic processes (e.g., peRS, ER processes), manual methods (e.g., ink signature),

e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

10 CFR 50.59 EVALUATION FORM Sheet 2 of 3

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a DYes structure, system, or component important to safety previously evaluated in the UFSAR? 181 No BASIS: The Generator Terminal Box Liquid level detection system is not safety related or important to safety and is not evaluated in the UFSAR. The effect of bypassing the liquid level trip are limited to the trip circuit of the generator. This change will not affect any equipment used to mitigate radiological consequences of an accident since the generator is not safety related equipment. Since this change will not effect any equipment important to safety it can not increase the likelihood of occurrence of an equipment malfunction important to safety.

3. Result in more than a minimal increase in the consequences of an accident previously DYes evaluated in the UFSAR? 181 No BASIS: The proposed modification has no function in controlling the consequences of any accident described in the UFSAR. The Generator Terminal Box Liquid level detection system is not safety related or important to safety and is not evaluated in the UFSAR. The effect of bypassing the liquid level trip are limited to the trip circuit of the generator. This change will not affect any equipment used to mitigate radiological consequences of an accident since the generator is not safety related equipment. Since this change will not effect safety related functions associated with an accident, there is no impact to any accident consequences previously evaluated in the UFSAR.

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, DYes system, or component important to safety previously evaluated in the UFSAR? 181 No BASIS: The proposed change does not affect any SSC that is important to safety. The Generator Terminal Box Liquid level detection system is not safety related or important to safety and is not evaluated in the UFSAR. The effect of bypassing the liquid level trip are limited to the trip circuit of the generator.

This change will not affect any equipment used to mitigate radiological consequences of an accident since the generator is not safety related equipment. Since this change will not effect any equipment important to safety it can not increase the consequences of an equipment malfunction previously evaluated in the UFSAR.

5. Create a possibility for an accident of a different type than any previously evaluated in the DYes UFSAR? 181 No BASIS: The proposed change reduces the Iikelyhood of an inadvertent turbine trip, which is described in section 15.8.1 of the UFSAR. The bypassed level deviation trip affects the generator trip and will not introduce a new mode of generator/tripping failure. The trips listed in UFSAR section 10.2.2.5.1 are also used to supply protection to the generator. If the bypassed trip failed to function and one of the events occurred that this trip is designed to protect the generator against, the resulting conditions would still be bounded by the load rejection evaluation in the UFSAR. The non-safety related generator will not cause any accidents different than previously evaluated in the UFSAR.

6. Create a possibility for a malfunction of a structure, system, or component important to safety DYes with a different result than any previously evaluated in the UFSAR? 181 No BASIS: The proposed change does not affect any SSC that is important to safety. The generator tripping from a load rejection and no bypass flow was evaluated in the UFSAR as the most limiting accident involving the generator. THis change will affect the trip circuit of the generator only. The tripping of the generator has been already evaluated and this change is bounded by that evaluation. Since this change is bounded by previous evaluation there is no possibility of creating a malfunction of equipment important to safety with different results than previously evaluated.

7. Result in a design basis limit for a fission product barrier as described in the UFSAR being DYes exceeded or altered? 181 No BASIS: The proposed modification does not affect any fission product barrier. The equipment is non safety related and is not relied upon to mitigate the consequences of an accident. No fission product barrier described in the UFSAR in affected.

8. Result in a departure from a method of evaluation described in the UFSAR used in establishing DYes the design bases or in the safety analyses? 181 No BASIS: The proposed modification does not result in or stem from any change to any method of evaluation

10 CFR 50.59 EVALUATION FORM Sheet 3 of 3 If any of the above questions Is checked "Yes," obtain NRC approval prior to Implementing the change by Initiating a change to the Operating License In accordance with NMM Procedure EN*LI*103.

GGNS Commitment Change Evaluation Number CCE 2007-001 G080044

- COMMITMENT CHANGE EVALUATION FORM Sheet 1 of 5 NOTE Forward completed form to Plant Licensing.

eMS 10: ...;..P.;;2:..;.45..;;.;0::....;7 Plant Licensing Tracking Number: CCE 2007-0001 Source Document/Date: AECM*90/0007 Commitment: Deletion 0 Revision Has the original commitment been implemented? !2J YES o NO, Notify Plant Licensing Original Commitment

Description:

Commitment description based on AECM*90/0007, Attachment I,Section II.B, Page 5 Air-to-Water Heat Exchangers The following heat exchangers are included in this category:

ESF Switchgear Room Coolers RHR Room Coolers LPCS Room Cooler HPCS Room Cooler RCIC Room Cooler Fuel Pool Cooling and Cleanup Room Coolers Sufficient instrumentation is installed or will be provided to measure SSW flows and all process temperatures. The room cooler air flows will be determined by calculation.

Performance testing of these heat exchangers will be performed. Temperature and flow compensation of test results to the design conditions will be included as part of the planned testing program. If, due to insufficient heat loads, it is not possible to obtain statistically significant extrapolated results, then visual inspections of both the air and water sides of the heat exchangers will be performed, where possible, to ensure cleanliness. The test results will be trended to monitor degradation of cooling water flow.

Revised Commitment

Description:

Air-to-Water Heat Exchangers Mechanical Standard MS 39.0 delineates the testing program to verify the heat transfer capability of the air-to-water heat exchangers. The air-to-water heat exchangers in MS 39.0 included in this category are:

ESF Switchgear Room Coolers RHR Room Coolers LPCS Room Cooler HPCS Room Cooler RCIC Room Cooler Fuel Pool Cooling and Cleanup Room Coolers EN-U-110-ATI-9.4

COMMITMENT CHANGE EVALUATION FORM Sheet 2 of 5 Performance testing of these heat exchangers will be performed. Sufficient instrumentation is:.

installed to measure SSW flows and all process temperatures. The room cooler air flows will Ibe determined by calculation. Temperature and flow compensation of test results to the design condItions will be included as part of the planned testing program.

If, due to insufficient heat loads. it is not possible to obtain statistically significant extrapolated test results, then performance testing will consist of monitoring of SSW flows and measuring air f1~w rates. Visual inspections of both the air and water sides of the heat exchangers will be performed, where possible, to ensure cleanliness. The test results will be trended to monitor degradation of cooling water and air flow rates.

Summary of Justification for Change or Deletion:

Generic Letter 89-13 required licensees to conduct a test program to verify the heat transfer capability of all safety-related heat exchangers cooled by service water. Enclosure 2 of GL 89-13 described a program that would be acceptable for heat exchanger testing. In regards to air-to-water heat exchangers.

Section I1.B of Enclosure 2 states:

B. If it is not possible to test the heat exchanger to provide statistically significant results (for example, if error in the measurement exceeds the value of the parameter being measured), then

1. Trend test results for both air and water flow rates in the heat exchanger.

2. Perform visual inspections, where possible, of both the air and water sides of the heat exchanger to ensure cleanliness of the heat exchangers.

Thermal pertormance testing of the air-to-water heat exchangers has not provided consistent, qualitative data on which to trend heat transfer capability. This is due to the small heat load at test conditions and SUbsequent large uncertainty in the data calculations. As a result, MS 39.0 provides for an acceptable alternative to thermal performance testing in accordance with Section II.B of Enclosure 2 to Generic Letter 89-13.

Prepared By: Alex Howard I ~~ Date:

Print~

Management Approval: ~B~iIIU~~~.!J,d~~L~~~~~... Date:

Plant Licensing Management Co ncurrence: . .; .D.;.;re;.;w~B. ; o.;,;t .; .em;.;.;,;,;i1;.; le;.;.r.;. 1~~o::;;......;;..

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Print Name/Signature EN-L1-110-ATT-9.4

COMMITMENT CHANGE EVALUATION FORM Sheet 3 of 5 PART I 1.1 Is the existing commitment located in the Updated Final Safety Analysis Report, Emergency Plan, Quality Assurance Program, Fire Protection Program, or Security Plan?

o YES STOP. Do not proceed with this evaluation. Instead use appropriate codified process (e.g., 10 CFR 50.71 (e), 10 CFR 50.54, 10 CFR 50.59,10 CFR 50.55) to evaluate commitment.

rgj NO Go to Part II.

PART II 2.1 Could the change negatively impact the ability of a System, Structure, or Component (SSC) to perform its safety function or negatively impact the ability of plant personnel to ensure the SSC is capable of performing its intended safety function?

o YES Go to Question 2.2.

rgj NO Continue with Part III. Briefly describe rationale:

The original commitment provided for allowance of visual inspections and cooling water monitoring and trending as an alternative if significant data could not be extrapolated from air-to-water heat exchanger testing. MS 39.0 will now describe an acceptable alternative to thermal performance testing of air-to-water heat exchangers as allowed by Generic Letter 89-13, Enclosure 2,Section II.B.

2.2 Perform a safety evaluation using the following 10 CFR 50.92 criteria to determine if a significant hazards consideration exists:

- Does the revised commitment involve a significant increase in the probability or consequences of an accident previously evaluated?

DYes 0 No Describe basis below:

- Does the revised commitment create the possibility of a new or different kind of accident from any previously evaluated?

DYES 0 NO Describe basis below:

- Does the revised commitment involve a significant reduction in a margin of safety?

DYES 0 NO Describe basis below:

If any of the above questions are answered Yes. STOP. Do not proceed with the revision, OR discuss change with NRC and obtain neCEssary approvals prior to implementation of the proposed change. If all three questions are answered NO, go to Part III. (Attach add jtionaJ sheets as necessary.)

EN-L1-110-ATT-9,4

COMMITMENT CHANGE EVALUATION FORM Sheet 4 of 5 PART III 3.1 Was the original commitment (e.g., response to NOV, etc.) to restore an obligation (e.g., rule, regulation, order or license condition)?

o YES Go to question 3.2.

r8J NO Go to Part IV.

3_2 Is the proposed revised commitment date necessal)' and justified?

D YES Briefly describe rationale (attach additional sheets as necessary) and notify NRC of revised commitment date prior to the orioinal commitment date.

DNO STOP. Do not proceed with the revision, OR apply for appropriate regulatol)' relief.

PART IV 4.1 Was the original commitment: (1) explicitly credited as the basis for a safety decision in an NRC SER, (2) made in response to an NRC Bulletin or Generic Letter, or (3) made in response to a request for information under 10 CFR 50.54(f) or 10 CFR 2.204?

r8J YES Go to Question 4.2.

ONO Go to PartV.

4.2 Has the original commitment been implemented?

r8J YES STOP, You have completed this evaluation. Revise the commitment and notify NRC of revised commitment in summaI)' report.

ONO Go to Question 5.1.

PART V 5.1 Was the original commitment made to minimize recurrence of a condition adverse to quality (e.g.,

a long-term corrective action stated in an LER)?

DYES Go to Question 5.2.

ONO STOP. You have completed this evaluation. Revise the commitment. No NRC notification required.

5.2 Is the revised commitment necessary to minimize recurrence of the condition adverse to quality?

o YES Revise the commitment and notify NRC of revised commitment in next annuallRFO interval summary report.

o NO Revise commitment. No NRC notification is required.

EN -Ll-110-ATT-9.4

COMMITMENT CHANGE EVALUATION FORM Sheet 5 of 5 REFERENCES

1. NRC Generic Letter 89*13 List below the documents (e.g., procedures NRC submittals etc.) affected by this change.

Doc. Number/lD Description A ECM-9010007 Response to Generic Letter 89-13; Service Water System Problems Affecting Safety-Related Equipment MS-39 Mechanical Standard for Thermal Performance Testing of Safety-Related Standby Service Water Heat Exchangers CeE 2004-0002 Commitment Change Evaluation stating methodology for air-to-water heat exchanger testing.

EN -Ll-110-ATT-9.4