GNRO-2009/00008, Technical Specification Bases Update to the NRC for Period Dated January 23, 2009

Technical Specification Bases Update to the NRC for Period Dated January 23, 2009

ML090230711
Person / Time
Site:	Grand Gulf
Issue date:	01/23/2009
From:	Perino C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2009/00008
Download: ML090230711 (8)

Text

• Entergy

-===- Entergy Operations, Inc.

PO Box 756 Port Gibson, MS 39150 Tel 601 437 2800 GNRO-2009/00008 January 23, 2009 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk SUbject: Technical Specification Bases Update to the NRC for Period Dated January 23, 2009 Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

Pursuant to Grand Gulf Nuclear Station (GGNS) Technical Specification 5.5.11, Entergy Operations, Inc. hereby submits an update of all changes made to GGNS Technical Specification Bases since the last submittal (GNRO-2008/00069 dated October 22, 2008 to the NRC from GGNS) This update is consistent with update frequency listed in 10CFR50. 71 (e).

This letter does not contain any commitments.

Should you have any questions, please contact Michael Larson at (601) 437-6685.

Sincerely, Christina L. Perino Licensing Manager CLP\MJL attachment: GGNS Technical Specification Bases cc: (See Next Page)

GNRO-2009/00008 Page 2 cc:

NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U.S. Nuclear Regulatory Commission ALL LETTERS ATTN: Mr. Elmo E. Collins, Jr. (w/2) 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U.S. Nuclear Regulatory Commission ALL LETTERS -

ATTN: Mr. Carl F. Lyon, NRRlDORL (w/2) COURIER DELIVERY (FEDEX, ETC.)

ATTN: ADDRESSEE ONLY ADDRESS ONLY -

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ATTACHMENT to GNRO-2009/00008 Grand Gulf Technical Specification Bases Revised Pages LDC# BASES PAGES AFFECTED TOPIC of CHANGE 2008-0002 83.1-15,83.1-18,83.1-19, IMPLEMENTS TECHNICAL SPECIFICATION 8 3.1-20, 8 3.3-35, AMENDMENT 180 - TSTF-475 CONTROL ROD NOTCH TESTING

Control Rod OPERABILITY B 3.1.3 BASES ACTIONS A.1. A.2. A.3. and A.4 (continued) control rod can be isolated from scram by isolating the hydraulic control unit from'scra~ and normal drive and withdraw pressure, yet still maintain cooling water to the CRD.

Monitoring of the insertion capability for each withdrawn control rod must also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of Condition A concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the rod pattern controller (RPC). SR 3.1.3.3 performs periodic tests of the control rod insertion capability of withdrawn control rods. Testi ng each wi thdrawn control rod ensures that a generic problem does not exist. This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." The Required Action A.2 Completion Time only begins upon discovery of Condition A concurrent with THERMAL POWER greater than the actual LPSP of the RPC, since the notch insertions may not be compatible with the requirements of rod pattern control (LCO 3.1.6) and the RPC (LCO 3.3.2.1, "Control Rod Block Instrumentation"). The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of Condition A concurrent with THERMAL POWER greater than the LPSP of the RPC provides a reasonable time to test the control rods, considering the potential for a need to reduce power to perform the tests.

To allow continued operation with a withdrawn control rod stuck, an evaluation of adequate SDM is also required within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Should a DBA or transient require a shutdown, to preserve the single failure criterion an additional control rod would have to be assumed to have failed to insert when required. Therefore, the original SDM demonstration may not be valid. The SDM must therefore be evaluated (by measurement or analysis) with the stuck control rod at its stuck position and the highest worth OPERABLE control rod assumed to be fully withdrawn.

The allowed Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to verify SDM is adequate, considering that with a single control rod stuck in a withdrawn position, the remaining OPERABLE control rods (continued)

GRAND GULF B 3.1-15 LBDCR 08002

Control Rod OPERABILITY B 3.1.3 BASES (continued)

SURVEILLANCE SR 3.1.3.1 REQUIREMENTS The position of each control rod must be determined, to ensure adequate information on control rod position is available to the operator for determining control rod OPERABILITY and controlling rod patterns. Control rod position may be determined by the use of OPERABLE position indicators, by moving control rods to a position with an OPERABLE indicator, or by the use of other appropriate methods. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of this SR is based on operating experience related to expected changes in control rod position and the availability of control rod position indications in the control room.

SR 3.1.3.2 Deleted SR 3.1.3.3 Control rod insertion capability is demonstrated by inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves.

The control rod may then be returned to its original position. This ensures the control rod is not stuck and is free to insert on a scram signal. This Surveillance is modified by a Note identifying that the Surveillance is not required to be performed when THERMAL POWER is less than or equal to the actual LPSP of the RPC since the notch insertions may not be compatible with the requirements of BPWS (LCO 3.1.6) and the RPC (LCO 3.3.2.1). This Note also provides a time allowance such that the Surveillance is not required to be performed until the next scheduled control rod testing for control rods of the same class (i .e., fully withdrawn or partially withdrawn). This Note provides this allowance to prevent unnecessary perturbations in reactor operation to perform this testing on a control rod whose surveillance class (i .e., fully withdrawn or partially withdrawn) has changed. Partially withdrawn control rods are tested at a 31 day Frequency, based on the potential power reduction required to allow the control rod movement.

Furthermore, the 31 day Frequency takes into account operating experience related to changes in CRD performance.

At any time, if a control rod is immovable, a determination of that control rod's trippability (OPERABILITY) must be made and appropriate action taken.

(continued)

GRAND GULF B 3.1-18 LBDCR 08002

Control Rod OPERABI LITY B 3.1.3 BASES SURVEI LLANCE SR 3.1.3.4 REQUIREMENTS (continued) Verifying the scram time for each control rod to notch position 13 is $ 7 seconds provides reasonable assurance that the control rod will insert when required during a DBA or transient, thereby completing its shutdown function.

This SR is performed in conjunction with the control rod scram time testing of SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.1.1, "Reactor Protection System (RPS)

Instrumentation," and the functional testing of SDV vent and drain valves in LCO 3.1.8, "Scram Discharge Volume (SDV)

Vent and Drain Valves," overlap this Surveillance to provide complete testing of the assumed safety function. The associated Frequencies are acceptable, considering the more frequent testing performed to demonstrate other aspects of control rod OPERABILITY and operating experience, which shows scram times do not significantly change over an operating cycle.

SR 3.1.3.5 Coupling verification is performed to ensure the control rod is connected to the CRDM and will perform its intended function when necessary. The Surveillance requires verifying that a control rod does not go to the withdrawn overt ravel position when it is fully withdrawn. The overt ravel position feature provides a positive check on the coupling integrity, since only an uncoupled CRD can reach the overtravel position. In addition, during this Surveillance any indicated response of the nuclear instrumentation while withdrawing the control rod is observed as a backup to the withdrawn overt ravel position indication. The verification is required to be performed anytime a control rod is withdrawn to the "full out" (continued)

GRAND GULF B 3.1-19 LBDCR 08002

Control Rod OPERABILITY B 3.1.3 BASES SURVEI llANCE SR 3.1,3.5 (continued)

REQUIREMENTS position (notch position 48) or prior to declaring the control rod OPERABLE after work on the control rod or CRD System that could affect coupling. This includes control rods inserted one notch and then returned to the "full out" position during the performance of SR 3.1.3.3. This Frequency is acceptable, considering the low probability that a cont ro 1 rod wi 11 become uncoupled when it is not being moved and operating experience related to uncoupling events.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 26, GDC 27, GDC 28, and GDC 29.

2. UFSAR, Section 4.3.2.5.5.

3. UFSAR, Section 4.6.1.1.2.5.3.

4. UFSAR, Section 5.2.2.2,3.

5. UFSAR, Section 15.4.1.

6. UFSAR, Section 15.4.9.

7. NEDO-21231, "Banked Position Withdrawal Sequence,"

Section 7.2, January 1977.

8. NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR II)."

9. AECM-90/0146, Proposed Amendment to the Operating license (PCOl-90/07, Revision 1), dated August 15, 1990.

10. MAEC-90/0285, Issuance of Amendment No. 73 to Facility Operating license No. NPF Grand Gulf Nuclear Station, Unit 1, Regarding Fuel Cycle 5 Reload (TAC No.

76992), dated November 15, 1990.

11. GNRI-95/00044, Issuance of Amendment No. 120 to Facility Operating license No. NPF Grand Gulf Nuclear Station, Unit 1, Regarding Improved BWR-6 Technical Specifications (TAC No. 88101), dated February 21, 1995, Safety Evaluation Report, Page 63, Item 40.

GRAND GULF B 3.1-20 lBDCR 08002

SRM Instrumentation B 3.3.1.2 BASES ACTIONS 0.1 and 0.2 (continued) mode switch is locked in the shutdown position to prevent inadvertent control rod withdrawals. The allowed Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is sufficient to accomplish the Required Action, and takes into account the low probability of an event requiring the SRM occurring during this time.

E.1 and E.2 With one or more required SRMs inoperable in MODE 5, the capability to detect local reactivity changes in the core during refueling is degraded. CORE ALTERATIONS must be immediately suspended, and action must be immediately initiated to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

Suspending CORE ALTERATIONS prevents the two most probable causes of reactivity changes, fuel loading and control rod withdrawal, from occurring. Inserting all insertable control rods ensures that the reactor will be at its minimum reactivity, given that fuel is present in the core.

Suspension of CORE ALTERATIONS shall not preclude completion of the movement of a component to a safe, conservative position.

Action (once required to be initiated) to insert control rods must continue until all insertable rods in core cells containing one or more fuel assemblies are inserted.

SURVEILLANCE The SRs for each SRM Applicable MODE or other specified REQUIREMENTS condition are found in the SRs column of Table 3.3.1.2-1.

SR 3.3.1.2.1 and SR 3.3.1.2.3 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to the same parameter indicated on other similar channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect (continued)

GRAND GULF B 3.3-35 LBDCR 08002