GNRO-2009/00028, Technical Specification Bases Update to the NRC for Period Dated April 22, 2009

Technical Specification Bases Update to the NRC for Period Dated April 22, 2009

ML091140332
Person / Time
Site:	Grand Gulf
Issue date:	04/22/2009
From:	Perino C Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2009/00028
Download: ML091140332 (8)

Text

~Entergy Entergy Operations, Inc.

7003 Bald Hill Road P.O. Box 756 Port Gibson, MS 39150 Tel 601 437 6299 Christina L. Perino Manager Licensing GNRO-2009/00028 April 22, 2009 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Technical Specification Bases Update to the NRC for Period Dated April 22, 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-2009/00017 dated March 4, 2009 to the NRC from GGNS) This update is co::::;istent 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.

Sin~~

CLP\MJL attachment: GGNS Technical Specification Bases cc: (See Next Page)

GNRO-2009/00028 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/2) 612 East Lamar Blvd, Suite 400 Arlington, TX 76011-4005 U.S. Nuclear Regulatory Commission ATTN: Mr. Carl F. Lyon, NRR/DORL (w/2)

ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378

ATTACHMENT to GNRO-2009/00028 Grand Gulf Technical Specification Bases LDC# BASES PAGES AFFECTED TOPIC of CHANGE 2009-009 B 3.3-102, B 3.3-128 IMPLEMENTS TECHNICAL SPECIFICATION AMENDMENT 181 2009-010 B 3.8-15, B 3.8-15a, B 3.8-33 IMPLEMENTS TECHNICAL SPECIFICATION AMENDMENT 182

ECCS Instrumentation B 3.3.5.1 BASES APPLICABLE 3.d. Condensate Storage Tank Level-Low (continued)

SAFETY ANALYSES, LCO, and HPCS injection would be taken from the CST. However, if the APPLICABILITY water level in the CST falls below a preselected level, first the suppression pool suction valve automatically opens, and then the CST suction valve automatically closes.

This ensures that an adequate supply of makeup water is available to the HPCS pump. To prevent losing suction to the pump, the suction valves are interlocked so that the suppression pool suction valve must be open before the CST suction valve automatically closes. The Function is implicitly assumed in the accident and transient analyses (which take credit for HPCS) since the analyses assume that the HPCS suction source is the suppression pool.

Condensate Storage Tank Level-Low signals are initiated from two level transmitters. The logic is arranged such that either transmitter and associated trip unit can cause the suppression pool suction valve to open and the CST suction valve to close. The Condensate Storage Tank Level-Low Function Allowable Value is high enough to ensure adequate pump suction head while water is being taken from the CST.

Two channel s of the Condensate Storage Tank Level- Low Function are only required to be OPERABLE when HPCS is required to be OPERABLE to ensure that no single instrument failure can preclude HPCS swap to suppression pool source.

Thus, the Function is required to be OPERABLE in MODES 1, 2, and 3. In MODES 4 and 5, the Function is required to be OPERABLE only when HPCS is required to be OPERABLE to fulfill the requirements of LCO 3.5.2, HPCS is aligned to the CST and the CST water level is not within the limits of SR 3.5.2.2. With CST water level within limits, a sufficient supply of water exists for injection to minimize the consequences of a vessel draindown event. Refer to LCO 3.5.1 and LCO 3.5.2 for HPCS Applicability Bases.

3.e. Suppression Pool Water Level-High Excessively high suppression pool water level could result in the loads on the suppression pool exceeding design values should there be a blowdown of the reactor vessel pressure through the SjRVs. Therefore, signals indicating high suppression pool water level are used to transfer the suction source of HPCS from the CST to the suppression pool (continued)

GRAND GULF B 3.3-102 LBDCR 09009

RCIC System Instrumentation B 3.3.5.2 BASES APPLICABLE 3. Condensate Storage Tank Level-Low (continued)

SAFETY ANALYSES, LCO, and Allowable Value is set high enough to ensure adequate pump APPLICABILITY suction head while water is being taken from the CST.

Two channels of Condensate Storage Tank Level-Low Function are available and are required to be OPERABLE when RCIC is required to be OPERABLE to ensure that no single instrument failure can preclude RCIC swap to suppression pool source.

Refer to LCO 3.5.3 for RCIC Applicability Bases.

4. Suppression Pool Water Level-High Excessively high suppression pool water level could result in the loads on the suppression pool exceeding design values should there be a blowdown of the reactor vessel pressure through the safety/relief valves. Therefore, signals indicating high suppression pool water level are used to transfer the suction source of RCIC from the CST to the suppression pool to eliminate the possibility of RCIC continuing to provide additional water from a source outside primary containment. This Function satisfies Criterion 3 of the NRC Policy Statement. To prevent losing suction to the pump, the suction valves are interlocked so that the suppression pool suction valve must be open before the CST suction valve automatically closes.

Suppression pool water level signals are initiated from two level transmitters. The Allowable Value for the Suppression Pool Water Level-High Function is set low enough to ensure that RCIC will be aligned to take suction from the suppression pool before the water level reaches the point at which suppression design loads would be exceeded.

Two channels of Suppression Pool Water Level-High Function are available and are required to be OPERABLE when RCIC is required to be OPERABLE to ensure that no single instrument failure can preclude RCIC swap to suppression pool source.

Refer to LCO 3.5.3 for RCIC Applicability Bases.

(continued)

GRAND GULF B 3.3-128 LBDCR 09009

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.21 REQUIREMENTS (continued) These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.

To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by Notes (the Note for SR 3.8.1.21 and Note 2 for SR 3.8.1.2) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading.

For the purposes of this testing, the DGs are started from standby conditions. Standby conditions for a DC mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations for DG 11 and DG 12. For DG 13, standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation.

In order to reduce stress and wear on diesel engines, the manufacturer recommends that the DCs be gradually accelerated to synchronous speed prior to loading. These modified start procedures are the intent of Note 3 of SR 3.8.1.2, which is only applicable when such procedures are used.

SR 3.8.1.21 requires that, at a 184 day frequency, the DC starts from standby conditions and achieves required voltage and frequency within 10 seconds. The DG's ability to maintain the required voltage and frequency is tested by those SRs which require DG loading. The 10 second start requirement supports the assumptions in the design basis LOCA analysis (Ref. 5). The start requirements may not be applicable to 3.8.1.2 (see Note 3 of SR 3.8.1.2), when a modified start procedure as described above is used. If a modified start is not used, the start requirements of SR 3.8.1.21 apply. Since SR 3.8.1.21 does require a 10 second start for each DG, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. This is the intent of Note 1 of SR 3.8.1.2. Similarly, the performance of SR 3.8.1.12 or SR 3.8.12.19 also satisfies the (continued)

GRAND GULF B 3.8-15 LBDCR 09010

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.21 (continued)

REQUIREMENTS requirements of SR 3.8.1.2 and SR 3.8.1.21. In addition to the SR requirements, the time for the DG to reach steady state operation is periodical)y monitored (data is taken once per 6 months during the performance of SR 3.8.1.21) and the trend evaluated to identify degradation of governor and voltage regulator performance.

The DGs are started for this test by using one of the following signals: manual, simulated loss of offsite power by itself, simulated loss of offsite power in conjunction with an ESF actuation test signal, or an ESF actuation test signal by itself.

The 31 day Frequency for SR 3.8.1.2 is consistent with the industry guidelines for assessment of diesel generator performance (Ref. 14). The 184 day frequency for SR 3.8.1.21 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.

SR 3.8.1. 3 This Surveillance demonstrates that the DGs are capable of synchronizing and accepting greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.

(continued)

GRAND GULF B 3.8-15a LBDCR 09010

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.20 (continued)

REQUIREMENTS This surveillance is performed when the unit is shut down and its 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3).

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DG 11 and DG 12. For DG 13, standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation.

SR 3.8.1. 21 (See SR 3.8.1. 2)

(continued)

GRAND GULF B 3.8-33 LBDCR 09010