GNRO-2011/00072, Technical Requirements Manual and Technical Specification Bases Update

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Technical Requirements Manual and Technical Specification Bases Update
ML112570181
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 09/12/2011
From: Perino C
Entergy Operations
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
GNRO-2011/00072
Download: ML112570181 (49)
v • d • e


Text

C. L. Perino GNRO-2011/00072 September 12, 2011 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

SUBJECT:

Technical Requirements Manual and Technical Specification Bases Update Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

Pursuant to Grand Gulf Nuclear Station (GGNS) Technical Requirements Manual Section 1.04, Entergy Operations, Inc. hereby submits an update of all changes made to the GGNS Technical Requirements Manual since the last submittal (GNRO 2010-00042 dated May 27,2010).

Additionally, Technical Specification Bases are submitted, for all changes made since the last submittal (GNRO 2010-00042 dated May 27,2010), in accordance with GGNS Technical Specification 5.5.11. These updates are consistent with update frequency listed in 10CFR50.71 (e).

This letter does not contain any commitments.

Should you have any questions, please contact Dennis M. Coulter at (601) 437-6595.

Sincerely, CLP/DMC

Attachment:

GGNS Technical Requirements Manual and Technical Specification Bases Revised Pages cc: (See Next Page)

GNRO-2011/00072 Page 2 of 2 cc: NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. Elmo Collins, Jr. (w/2)

Regional Administrator, Region IV 612 East Lamar Blvd, Suite 400 Arlington, TX 76011-41 U.S. Nuclear Regulatory Commission ATTN: Mr. Alan Wang, NRR / DORL (w/2)

Mail Stop OWFN 8 B1 Washington, D.C. 20555-0001

Attachment to GNRO 2011-00072 GGNS Technical Requirements Manual and Technical Specification Bases Revised Pages

Grand Gulf Technical Requirements Manual (TRM)

LBDCR#

05015

= ReVlse d Pages Affected TRM Pages 3.3-8-11 3.3-28-1 Topic of Change Redefined the turbine stop valve closure scram bypass, the turbine control valve fast closure scram bypass and end-of-cycle recirculation pump trip bypass allowable values in terms of percent rated thermal power instead of percent valves wide open steam flow 05027 3.6-8-1 Revised the primary containment airlock low pressure set point from 61 to 60 psig.

Revises minimum allowable pressure from 59.1 to 59 pSig 05080 3.3-18-11 Revised control rod block instrumentation (low power and high power) trip set points 09033 6.8-10 Added On Line Noble Chemistry circuit breaker to table of primary containment penetration conductor over current protective devices 10042 7-1 Changed title of shift supervisor to control room supervisor 11010 6.3-18 Changed frequency of turbine mechanical over-speed operability surveillance 11047 3.3-43-11, 3.3-43-111, Implemented TS Amendment 185 3.3-43-lIla, 3.3-47-1 incorporating TSTF 493 clarifying condensate storage tank level-low set-point methodology

Grand Gulf Technical Specification Bases ReVlse dP ages LBDCR# Affected Bases Pages Topic of Change 05015 83.3-15, 83.3-16,83.3-70 Redefined the turbine stop valve closure scram bypass, the turbine control valve fast closure scram bypass and end-of-cycle recirculation pump trip bypass allowable values in terms of percent rated thermal power instead of percent valves wide open steam flow 10030 8 3.6-78, 8 3.6-79, 83.6-79a, Revised the use of hydrogen 8 3.6-80, 8 3.6-81 recombiners as detailed in the current technical specifications and allowed by Tech Spec Traveler Form (TSTF) 478 10031 83.6-104 Revised the 8ases to allow a pressure decay test of drywell bypass leakage and allow a nominal start pressure of 3.0 +/-

0.05 psid for conducting the test 11003 83.6-8,8 3.6-8a, 83.6-108, Clarified that the bulkheads associated 83.6-108a with Containment and Orywell Airlock doors are considered part of the doors 11044 83.4-9 Added note concerning minor drifting of recirculation flow control valves 11047 8 3.3-87, 8 3.3-87a, 8 3.3-87b, Implementation of TS Amendment 185 8 3.3-87c, 8 3.3-93, 8 3.3-94, incorporating TSTF 493 clarifying 83.3-122, 83.3-122a, condensate storage tank level-low 8 3.3-122b, 83.3-123, 8 3.3-124, set-point methodology 83.3-125, 83.3-125a, 8 3.3-125b, 83.3-125c, 83.3-134,8 3.3-134a, 83.3-135 11049 83.8-58 Added the letter "8" to the page number indicating a TS bases page

Shutdown NA The numerical value is the acceptance criterion In is refurbished, a response be determine a revised value for Tx. Note: In EPRI NP-7243, the failure modes and effects (FMEA) for Rosemount differential pressure transmitters and pressure transmitters states, "For transmitters without the variable feature, no electronic failure modes were found that could affect the sensor response time." Therefore, for transmitters without variable response time is not of the electronics.

(c) values for Function 2.d are in the COLR.

(d) Not simulated thermal power time constant.

  • See Bases B 3.3.1.1
  1. time shall be measured from detector output or from the of the first electronic component in the channel.

TRM 3.3 II LBDCR 05015

TRM 3.3-18 II LBDeR 05080 Valve

2. Turbine Control Valve - 46.0 (a) 190 Fast Closure at or below an pressure.

TRM 3.3-28 I LBDeR 05015

1.

g.

5; 1.39 Start - Time ~ 5 seconds d.

e. Pump (Bypass) 11
f. Manual Initiation NA Spray (HPCS)

Low, Level * ~ -41.

b. Pressure - 5; 1.
c. Reactor Vessel Water Level - Level 8 5; 53. inches Tank - Low .0 **

5; 5.

Pump Pressure - (Bypass) 120. ps 1227.0

.3-4

Reactor Vessel Water Level Low Low, 50.

LPCI A Di Pressure - H ADS Bypass Timer Pressure) $ 9.2 minutes Manual Initiat NA B

Reactor Vessel Water Level - Low Low Low, Level ~ -150.

b. Pressure - High $ 1.39
c. ADS Initiation Timer $ 105 seconds
d. Reactor Vessel Level - Low, 3 ~ 1 .4 B &

Timer $ 9.2

g. Manual Initiation NA
  • See 3.3 . .
    • next

- III 7

      • Per Tech Table 3.3.5.1-1 3.d note the below as-found tolerance and as-left tolerance to this sel-DOllnl in accordance with documented in GIN 2011-00252 per TSTF 493:

For the Unit AFT-TU= +/-0.113 FT ALT-TU= +/-0.113 FT For the AFT-L= +/-OAI4 FT ALT-L +/-O.207FT TRM II LBDeR 047

Tank 4.0 **

4.

For Unit (TU)

AFT-TU= +/-0.113 FT ALT-TU= /-0.113 FT For AFT-L= .414 ALT-L /-0.207 TRM 3.3-47 1104

SURVEILLANCE REQUIREMENTS

.6.1. . TEST .

. 6 LBDCR

6.3.8.

devices us 8 weeks manual test.

6.3.8.3 the 40 months disks and flaws. If all other valves of

1) Four high pressure turbine stop valves,
2) Four high pressure turbine control valves,
3) Six low pressure turbine stop valves, and
4) Six low pressure turbine control valves.

TRM 6.3-18 LBDeR 11010

Molded Type NZM TRIP RESPONSE SYSTEM/

BREAKER SET POINT TIME COMPONENT 1-26 .100 XFMR lXl12 (N1R18S112-D) 0.100 STM INLET (N1P72F150B-N) 60 0.100 DRYWELL FLOOR DRAIN SUMP PUMP (N1P45C001B-N) 14 0.100 MOV VESSEL (Q1B2 52- 412-01 7.5 0.100 REAC RECIRC HPU OIL PUMP FAN (N1B33D003B3-N) 52-1412-02 60 0.100 CNTMT CHEM WASTE SUMP PUMP (N1P45C027B-N) 52-1412-03 60 0.100 DRYWELL FLOOR DRAIN SUMP PUMP (N1P45C001A-N) 52-1412-05 12.5 0.100 MOV CRD COOL WTR PRESS CONTROL (N1C11F003-N) 52-1412-08 105 0.100 MOV REAC RECIRC PUMP B SUCTION (Q1B33F023B-N) 52-1412-09 175 0.100 RWCU DEMIN PRECOAT PUMP (N1G36C002-N) 52-1412-12 90 0.100 RWCU DEMIN HOLDING PUMP (N1G36C001B-N) 52-1412-15 600 0.100 REAC RECIRC HPU OIL PUMP (N1B33D003B1-N) 52-1412-14 20 0.100 Monitor Pump Panel (lP87P004)

TRM 6.8- 0 LDBCR 09033

o 50. fications 5. . .

and 5.2.2.g as allowed fication 5.2.2.c, each shall be shift crew shown in Table Licensed Personnel shall meet or exceed the criteria of the accredited license program.

7.2. As 0 CFR 50.54, all CORE ALTERATIONS shall be by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel who no other concurrent this 7.2.4 Shift Managers, and Control Room , shall each hold Senior License.

7.2.5 Not Used 7.2.6 Deleted 7-

RPS Instrumentation B 3.3.1.1 BASES Turbine Stop Valve Closure, are initiated by the fluid pressure at each stop valve. pressure transmitters are associated with each stop valve. One of the two transmitters to RPS system A; the other, to RPS system B. Thus, each RPS system receives an from four Turbine Stop Valve Closure, Oil Pressure - Low channels, each of one pressure transmitter. The for the Turbine Stop Valve Closure, Oil Pressure- Low Function is such that three or more TSVs must be closed to produce a scram.

This Function must be enabled at THERMAL POWER ~ 40% RTP.

This is by pressure transmitters turbine first stage pressure; therefore, to consider this Function OPERABLE, the turbine must remain shut at THERMAL POWER ~ 40% RTP.

feedwater temperature as a result that affect the turbine first GRAND GULF B 3.3-15 LBDeR 05015

RPS Instrumentation B 3.3.1.1 BASES The Turbine Oil Pressure-Allowable Value is selected to detect imminent TSV closure of the pressure transient.

channels of Turbine Valve Closure, Oil Pressure - Low Function, with four channels in each system, are to be OPERABLE ensure that instrument failure will a scram from this if any three TSVs should close. This Function is consistent with , whenever THERMAL is 40% RTP. This Function is not when THERMAL POWER is < 40% RTP Reactor Vessel Steam Dome Monitor Fast closure of the TCVs results in the loss of a heat sink that reactor pressure, neutron flux, and heat flux transients that must be limited. Therefore, a reactor scram is initiated on TCV fast closure in of the transients that would result from the closure of these valves. The Turbine Control Valve Fast Closure, Oil Pressure - Low Function is the scram for the generator load ection event in Reference 4. For this event, the reactor scram reduces the amount of energy to be absorbed and, with the actions of the EOC-RPT ensures that the MCPR SL is not exceeded.

Turbine Control Valve Fast Closure, Oil Pressure-Low are initiated the EHC fluid pressure at each control valve. There is one pressure transmitter associated GRAND GULF B 3.3-16 LBDCR 05015

EOC-RPT Instrumentation B I BASES Fast closure of the TCVs a generator load ection results in the loss of a heat sink that reactor pressure, neutron flux, and heat flux transients that must be limited. Therefore, an RPT is initiated on TCV Fast Closure, Oil Pressure-Low in of the transients that would result from the closure of these valves. The EOC-RPT decreases reactor power and aids the reactor scram in that the MCPR SL is not exceeded the worst case transient.

GRAND GULF B 3.3-70 LBDCR05015

ECCS on B 3.3.S.1 B 3.3 INSTRUMENTATION B 3.3.S.1 Emergency Core Cooling System (ECCS) Instrumentation BASES BACKGROUND The purpose of the ECCS instrumentation is to initiate appropriate responses from the systems to ensure that fuel is adequately cooled in the event of a design basis accident or transient.

This is achieved by specifying limiting safety system ngs (LSSS) in terms of parameters directly monitored by the ECCS, as well as LCOs on other reactor system parameters and equipment performance.

Techni Specifications are required by 10 CFR SO.36 to include LSSSs for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded.

However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.

The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g.,

repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the trip setpoint ensures that SLs are not exceeded. Therefore, for Function 3.d, Condensate Storage Tank Level-Low, the trip setpoint meets the definition of an LSSS (Ref. S).

GRANO GULF B 3.3-87 LBDeR 11047

ECCS Instrumentation B 3.3.5.1 BASES BACKGROUND The All e Value fied in the Table 3.3.5.1-1 serves as the LSSS such that a channel is OPERABLE if the trip nt is found not to exceed the Allowable As

, the Allowable Value trip nt an amount primarily equal to the expected instrument loop uncertainties, such as dri ,during the surveillance interval. In this manner, the actual setting of the device will still meet the lSSS definition and ensure that a Sl is not exceeded at any given point of time as long as the device has not drifted beyond that expected during the surveillance interval.

Technical Specifications contain values related to the OPERABILITY of equipment required for operation of the lity. OPERABLE is defined in Techni Specifications as

..... being capable of performing its fied safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Techni Specifications would be an overly restrictive rement if it were applied as an OPERABILITY limit the value of a channel setting during a Surveillance. This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety. For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected. This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the "as-found" setting of the protection channel. Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around trip setpoint to account for further drift during the next surveillance interval. Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).

GRAND GULF B 3.3-87a LBDCR 11047 I

ECCS Instrumentation B 3.3.5.1 BASES BACKGROUND However, there is also some point beyond which the channel (continued) may not be able to perform its function due to, for example, greater than expected drift. This value needs to be specified in the Technical Specifications in order to define OPERABILITY of the channels and is designated as the Allowable Value. If the actual setting (as-found setpoint) of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE, but degraded. The degraded condition will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the trip setpoint (within the allowed tolerance), and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance.

After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

For most anticipated operational occurrences (AOOs) and Design Basis Accidents (DBAs), a wide range of dependent and independent parameters are monitored.

The ECCS instrumentation actuates low pressure core spray (lPCS), low pressure coolant injection (lPCI) , high pressure core spray (HPCS), Automatic Depressurization System (ADS),

and the diesel generators (OGs). The equipment involved with each of these systems is described in the Bases for lCO 3.5.1, "ECCS-Operating. II low Pressure Core Spray System The lPCS System may be initiated by either automatic or manual means. Automatic initiation occurs for conditions of Reactor Vessel Water level-low low low, level 1 or Drywell Pressure - Hi gh. Each of these di verse vari ab1es is monitored by two redundant transmitters, which are, in turn, connected to two trip units. The outputs of the four trip units (two trip units from each of the two variables) are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic. The high drywell pressure initiation signal is a sealed in signal and must be manually reset. The logic can also be initiated by use of a manual push button. Upon receipt of an initiation signal, the LPCS pump is started immediately after power is available.

GRAND GULF B 3.3-87b LBDeR 11047 I

ECCS BASES ow is monitored pump is running ow is GRAND B 3.3-87c LBDCR 11047 I

Eees Instrumentation 8 3.3.5.1 BASES BACKGROUND (continued)

Feature (ESF) buses if a loss of offsite power occurs.

(Refer to 8ases for leo 3.3.8.1.)

APPLICABLE The actions of the EeeS are explicitly assumed in the safety SAFETY ANALYSES, analyses of References 1, 2, and 3. The EeeS is initiated leo, and to preserve the integrity of the fuel cladding by limiting APPLICABILITY the post LOCA peak cladding temperature to less than the 10 CFR 50.46 limits.

ECCS instrumentation satisfies Criterion 3 of the NRC Policy Statement. Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.

The OPERABILITY of the instrumentation is dependent upon the OPERABILITY of the individual instrumentation channel Functions specified in Table 3.3.5.1-1. Each Function must have a required number of OPERABLE channels, with their setpoints set within the setting tolerances of the trip setpoint, where appropriate. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. Each Eecs subsystem must also respond within its assumed response time. Allowable Values are specified for each EeCS Function specified in Table 3.3.5.1-1. For Function 3.d, Condensate Storage Tank Level-Low, the nominal trip setpoint and methodologies for calculation of the as-left and as-found tolerances are described in the Technical Requirements Manual. The trip setpoints are selected to ensure that the setpoints remain conservative to the as-left tolerance band between CHANNEL CALIBRATIONS. After each calibration the trip setpoint shall be left within the as-left band around the nominal trip setpoint. Table 3.3.5.1-1 is modified by two footnotes. Footnote (a) is added to clarify that the associated functions are required to be OPERABLE in MODES 4 and 5 only when their supported Eees are required to be OPERABLE per LCO 3.5.2, EeeS-Shutdown. Footnote (b) is added to show that certain Eecs instrumentation Functions also perform DG initiation.

Nominal trip setpoints are those predetermined values of output at which an action should take place. The setpoints are compared to the actual process parameter (e.g., reactor vessel water level), and when the measured output value of GRAND GULF B 3.3-93 lBDCR 11047

ECCS Instrumentation B 3.3.5.1 BASES APPLICABLE the process parameter exceeds the setpoint, the associated SAFETY ANALYSES, device (e.g., trip unit) changes state. The analytical LCO, and limits are derived from the limiting values of the process APPLICABILITY parameters obtained from the safety analysis. The Allowable (continued) Values are derived from the analytical limits, corrected for calibration, process, and some of the instrument errors.

The nominal trip setpoints are then determined, accounting for the remaining instrument errors (e.g., drift). The trip setpoints derived in this manner provide adequate protection because instrumentation uncertainties, process effects, calibration tolerances, instrument drift, and severe environment errors (for channels that must function in harsh environments as defined by 10 CFR 50.49) are accounted for.

In general, the individual Functions are required to be OPERABLE in the MODES or other specified conditions that may require ECCS (or DG) initiation to mitigate the consequences of a design basis accident or transient. To ensure reliable ECCS and DG function, a combination of Functions is required to provide primary and secondary initiation signals.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

Low Pressure Core Spray and Low Pressure Coolant Injection Systems 1.a. 2.a. Reactor Vessel Water Level-LOW Low Low. Levell Low reactor pressure vessel (RPV) water level indicates that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result.

The low pressure ECCS and associated DGs are initiated at Level 1 to ensure that core spray and flooding functions are available to prevent or minimize fuel damage. The Reactor Vessel Water Level-Low Low Low, Levell is one of the Functions assumed to be OPERABLE and capable of initiating the ECCS during the transients and accidents analyzed in References 1, 2, and 3. The core cooling function of the ECCS, along with the scram action of the Reactor Protection System (RPS) , ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46.

GRANO GULF B 3.3-94 LBDCR 11047

ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) The calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be not within its required Allowable Value specified in Table 3.3.5.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analyses. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology_

The Frequency of 92 days is based on the reliability analysis of Reference 4.

SR 3.3.5.1.3 for Function 3.d, Condensate Storage Tank Level

-Low, is modified by two Notes as identified in Table 3.3.5.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note applied to SR 3.3.5.1.3 for Function 3.d, Condensate Storage Tank Level -Low, requires that the as-left setting for the channel be within the as-left tolerance of the Nominal Trip Setpoint (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the GRAND GULF B 3.3-122 LBDeR 11047

ECCS on B 3.3.5.1 BASES SURVEILLANCE (continued)

REQUIREMENTS NTSP, then the channel 1 be declared i e. The second Note also requires that NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the TRM.

A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy_ CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency SR 3.3.5.1.4 and SR 3.3.5.1.5 is upon the assumption the magnitude dri in the setpoint analysis.

SR 3.3.5.1.5 for Function 3.d, Condensate Storage Tank Level

-Low, is modified by two Notes as identified in Table 3.3.5.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note applied to SR 3.3.5.1.5 for Function 3.d, Condensate Storage Tank Level -Low, requires that the as-left setting for the channel be within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analyti GRAND GULF B 3.3-122a LBDeR 11047 I

ECCS on B 3.3.5.1 BASES SURVEILLANCE L is ng cannOL be reLurned LO a ng wiLhin the erance of NTSP, then the channel shall be ared inoperable. The second Note also requires thaL NTSP and Lhe methodologies for calculating the and the tolerances be in the TRM.

GRAND GULF B 3.3-122b LBDeR 11047 I

ECCS on B 3 3.S 1 BASES SURVEILLANCE REQUIREMENTS nued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a fic channel. The system functional testing performed in LCO 3.5.1, LCO 3.5.2, LCO 3.8.1, and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety function.

The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage (except for Divi on III which can be tested in any operational condition) and the potential for unplanned transients if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency.

REFERENCES 1. UFSAR, Section 5.2.

2. UFSAR, Section 6.3.
3. UFSAR, Chapter 15.
4. NEOC-30936-P-A, "BWR Owners' Group Technical Specification Improvement Analyses for ECeS Actuation Instrumentation, Part 2," December 1988.
5. Regulatory Guide 1.105, "Setpoints for Safety-Related Instrumentation," Revision 3.

GRAND GULF B 3.3-123 LBDeR 11047

RCIC System Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation BASES BACKGROUND The purpose of the RCIC System instrumentation is to initiate actions to ensure adequate core cooling when the reactor vessel is isolated from its primary heat sink (the main condenser) and normal coolant makeup flow from the Reactor Feedwater System is unavailable, such that initiation of the low pressure Emergency Core Cooling Systems (ECCS) pumps does not occur. A more complete discussion of RCIC System operation is provided in the Bases of lCO 3.5.3, "RCIC System."

This is achieved by specifying limiting safety system settings (lSSS) in terms of parameters directly monitored by the RCIC instrumentation, as well as lCOs on other reactor system parameters and equipment performance.

Technical Specifications are required by 10 CFR 50.36 to include lSSSs for variables that have significant safety functions. lSSS are defined by the regulation as "Where a lSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety limit (Sl) is exceeded." The Analytical limit is the limit of the process variable at which a safety action is initiated, as established by the safety analysis, to ensure that a Sl is not exceeded. Any automatic protection action that occurs on reaching the Analytical limit therefore ensures that the Sl is not exceeded.

However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.

The trip setpoint is a predetermined setting for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical limit and thus ensuring that the SL would not be exceeded. As such, the trip setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g.,

repeatability), changes in the point of action of the GRAND GULF B 3.3-124 LBDeR 11047

BASES BACKGROUND (continued) channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the trip setpoint ensures that SLs are not exceeded. Therefore, for Function 3, Condensate Storage Tank Level- Low, the trip setpoint meets the definition of an LSSS (Ref. 2).

The Allowable Value specified in Table 3.3.5.2-1 serves as the LSSS such that a channel is OPERABLE if the trip setpoint is found not to exceed the Allowable Value. As such, the Allowable Value differs from the trip setpoint by an amount primarily equal to the expected instrument loop uncertainties, such as drift, during the surveillance interval. In this manner, the actual setting of the device will still meet the LSSS definition and ensure that a SL is not exceeded at any given point of time as long as the device has not drifted beyond that expected during the surveillance interval.

Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as

" ... being capable of performing its specified safety function(s)." Relying solely on the trip setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as-found" value of a protection channel setting during a Surveillance. This would result in Technical Specification compliance problems, as well as reports and corrective actions required by the rule which are not necessary to ensure safety. For example, an automatic protection channel with a setting that has been found to be different from the trip setpoint due to some drift of the setting may still be OPERABLE because drift is to be expected. This expected drift would have been specifically accounted for in the setpoint methodology for calculating the trip setpoint and thus the automatic protective action would still have ensured that the SL would not be exceeded with the "as-found" setting of the protection channel. Therefore, the channel would still be OPERABLE because it would have performed its safety function and the only corrective action required would be to reset the channel within the established as-left tolerance around trip setpoint to account for further drift during the next surveillance interval. Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the GRAND GULF B 3.3-125 LBDCR 11047

BACKGROUND (conti referenced setpoint methodology (as-left criteria), and confirmed to be operating within the stical allowances of the uncertainty terms assigned (as-found criteria).

However, there is also some point beyond which the channel may not be able to perform its function due to, for e, greater than expected drift. This ue needs to be specified in the Speci in order to define OPERABILITY of the channels and is designated as Allowable Value. the actual ng (as-found setpoint) of the channel is found to be conservative with respect to the Allowable Value but is beyond the as-found tolerance band, the channel is OPERABLE, but degraded. The degraded condition will further evaluated during performance of the SR. This evaluation will consist of resetting the channel nt to the trip setpoint n the al tolerance), and evaluating the channel response. the is functioning as required to pass the next surveillance, then the channel is OPERABLE and can restored to service at the completion the surveillance.

After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation.

The RCIC System may be initiated by ther automatic or manual means. Automatic initiation occurs for conditions of Reactor Vessel Water Level-Low Low, Level 2. The variable is monitored by four transmitters that are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic arrangement. Once initiated, the RCIC logic seals in and can be reset by the operator only when the reactor vessel water level signals have cleared.

The RCIC test line isolation valves close on a RCIC initiation signal to allow full system flow.

The RCIC System also monitors the water levels in the condensate storage tank (CST) and the suppression pool, since these are the two sources of water for RCIC operation.

Reactor grade water in the CST is the normal source. Upon receipt of a ReIe initiation signal, the CST suction valve is automatically signaled to open (it is normally in the open position) unless the pump suction from the suppression pool valve is open. If the 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. Two level transmitters are used GRAND GULF B 3.3-12Sa LBDeR 11047 I

RCIC on B 3.3.5.2 BASES BACKGROUND to low water level in the CST. Either switch can (continued) cause the suppression pool suction valve to open and the CST suction valve to close. The suppression pool suction ve also automatically opens and the CST suction valve oses if high water level is detected in the suppression pool (one-out-of-two logic similar to the CST water level logic). To prevent losing suction to the pump, the suction valves are interlocked so that one suction path must be open before the other automatically closes.

The RCIC System provides makeup water to the reactor until the reactor vessel water level reaches the high water level (Level 8) trip (two-out-of-two logic), at which time the RCIC steam supply valve closes (the injection valve also closes due to the closure of the steam supply valves) to prevent overflow into the main steam lines. The RCIC restarts if vessel level again drops to low 1 ini ation point (Level 2).

APPLICABLE The function of the RCIC System is to provide makeup SAFETY ANALYSES, coolant to the reactor in response to transient events.

LCO, and The RCIC System is not an Engineered Safety Feature APPLICABILITY System and no credit is taken in the safety analysis for RCIC System operation. Based on its contribution to the reduction of overall plant risk, however, the RCIC System, and therefore its instrumentation, are included as required by the NRC Policy Statement. Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.

The OPERABILITY of the RCIC System instrumentation is dependent on the OPERABILITY of the individual instrumentation channel Functions specified in Table 3.3.5.2-1. Each Function must have a required number of OPERABLE channels with their setpoints set within the setting tolerance of the trips setpoints where appropriate.

The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. Each channel must also respond within its assumed response time.

Allowable Values are specified for each RCIC System instrumentation Function specified in Table 3.3.5.2-1. For Function 3, Condensate Storage Tank Level- Low, the nominal trip setpoint and methodologies for calculation of the as-left and as-found tolerances are described in the Technical Requirements Manual. The trip setpoints are selected to ensure that the setpoints remain conservative to the as-left GRAND GULF B 3.3-125b LBDCR 11047 I

RCIC Instrumentation B 3.3.5.2 BASES APPLICABLE tolerance band between CHANNEL CALIBRATIONS. After each SAFETY ANALYSES calibration the trip setpoint shall be left within the as-LCO, and left band around the nominal trip setpoint. Nominal trip APPlICABIITY setpoints are those predetermined values of output at which (continued) an action should take place. The setpoints are compared to the actual process parameter (e.g., reactor vessel water level), and when the measured output value of the process parameter exceeds the setpoint, the associated device (e.g.,

trip unit) changes state. The analytical limits are derived from the limiting values of the process parameters obtained from the safety analysis. The Allowable Values are derived from the analytical limits, corrected for calibration, process, and some of the instrument errors. The nominal trip setpoints are then determined, accounting for the ning instrument errors .g., drift). The trip setpoints derived in this manner provide adequate protection because instrumentation uncertainties, process effects, calibration tolerances, instrument drift, and severe environment errors (for channels that must function in harsh environments as defined by 10 CFR 50.49) are accounted for.

Note that, although the channel is OPERABLE under these circumstances, the trip setpoint must be left adjusted to a value within the as-left tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology (as-left criteria), and confirmed to be operating within the statistical allowances of the uncertainty terms assigned (as-found criteria).

GRANO GULF B 3.3-125c LBDCR 11047 I

RCIC on B 3.3 5.2 BASES SURVEILLANCE A CHANNEL FUNCTIONAL TEST is required to ensure that the entire will perform intended function. Any setpoint adjustment shall be consistent with the assumptions of current plant specific setpoint methodology.

The Frequency of 92 days is based on the reliability analysis of Reference 1.

The ibration of trip units provides a check of the actual trip setpoints. channel must be declared inoperable if the trip setting is discovered to be less ve than the Allowable Value ed in e 3.3.5.2-1.

p ng is discovered to be less conservative than for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be re-adjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Frequency of 92 days is based on the reliability analysis of Reference 1.

CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter with the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Frequency is based on the assumption of the magnitude of equipment drift in the setpoint analysis.

SR 3.3.5.2.4 for Function 3, Condensate Storage Tank Level-Low, is modified by two Notes as identified in Table 3.3.5.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for GRAND GULF B 3.3-134 LBDCR 11047

RCIC B 3 3 5.2 BASES SURVEILLANCE (continued)

REQUIREMENTS the channel its but corlse~rVia.'[, ve wi th A1 Evaluation of channel will fy that channel will nue to behave in accordance with safety ysis assumptions and the channel performance assumptions in the setpoint methodology. of the assessment is to ensure dence in the performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Program will ensure red ew tiona

~~\~VIIIU Note applied to SR 3.3.5.2.4 for

~T"~~ln4 Tank Low, requires ng for the be within the as-left erance of the Nominal Trip (NTSP). Where a conservative than the NTSP is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that the NTSP and the methodologies for calculating the as-left and the as-found tolerances be in the TRM.

GRAND GULF B 3.3-134a LBDeR 11047 I

RCIC Instrumentation B 3 3 5.2 BASES SURVEILLANCE The LOGIC SYSTEM FUNCTIONAL TEST OPERABILITY required initiation 1 c channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.

The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency.

REFERENCES 1. NEDE-770-06-2, "Addendum to Bases Surveillance Test Intervals and Allowed ce for Instrumentation Techni Specifications," February 1991.

2. Regulatory Guide 1.105, "Setpoints for Safety-Related Instrumentation,U Revision 3.

GRAND GULF B 3.3-135 LBDCR 11047

FCVs B 3.4.2 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.2 Flow Control Valves (FCVs)

BASES BACKGROUND The Reactor Coolant Recirculation System is described section of the Bases for LCO 3.4.1,

" which discusses the and how this basis transient and The pumps and the FCVs are part of the Reactor Coolant Recirculation The jet pumps are described in the Bases for LCO .4.3, "Jet Pumps."

The Recirculation Flow Control System consists of electronic and necessary for the actuated FCVs. The rate can be flow range, in response system demand. Limits on the system response to minimize the on core flow response accidents and transients. Solid state control generate an FCV "motion inhibit" in response to any one of several power unit or control circuit failure The "motion inhibit" causes power shutdown and isolation such that the FCVs fail "as is." A minor amount of FCV drift may occur upon internal and friction.

APPLICABLE The FCV stroke rate is limited to ~ 11% per second in SAFETY ANALYSES the and directions on a control failure demand. This stroke rate is an of the recirculation flow control failures on flow (Refs. 1 and 2) .

Flow control valves satis Criterion 2 of the NRC Statement.

LCO An Fev in each must be OPERABLE to ensure that basis transient and accident GRAND GULF B 3.4-9 LBDeR 11044

~lmlill"'V Containment Air B

ACTIONS or at any inner door/bulkhead is breached, is then the associated air lock door may be declared and LeO

.6. . shall entered.

A.3 ensures that the affected air lock with the use of a locked Grand Gulf B 3.6-8 LBOCR 11003

Primary Containment Air Locks B3.6.1.2 BASES (continued)

Action A.3 is modified by a Note that air lock doors located in radiation areas and allows these doors to be verified locked closed use of administrative controls. verification administrative controls is considered since access to these areas is restricted. Therefore, the of the door, once it has been verified to be in the proper is small.

The Actions have been modified two Notes. Note 1 ensures that the Actions and associated Times of Condition C are if both doors in the air lock are With both doors in the air lock , an OPERABLE door is not available to be Actions C. and C.2 are the remedial actions. The exception of Note does not affect the from the initial entry into Ai to with the GRANO GULF B 3.6-Sa LBDeR 11003

function with a worst case active an accident, the is due to the release of steam into the environment. This pressure is relieved by the the water level within the weir wall, the mixture of steam and noncondensibles the from the steam.

condense.

containment pressure.

GRAND GULF B 3.&-78 LBDeR 10030

DryweU The ensures a to coolant more recent studies have from a DBA LOCA to may in accident as a result of:

a. A metal steam reaction between the zirconium fuel rod and the reactor coolant; and
b. of water in the Reactor To evaluate the accumulation in the as a function the initiation of the accident is calculated. Evaluation recommended Reference 1 are used to of the actions to the event.

The calculation confirms systems are actuated in accordance with the concentration in the remains

< 4 v/o.

The Purge satisfies Criterion 4 of the NRC Statement.

LCO purge must be OPERABLE to ensure of at least one containment purge event of a worst with at least one the the the GRAND GULF B 3.6-79 LBOCR 10030

GRAND GULF B 3.6-79a LBDeR 10030 B 3.6.3.3 the pressure Therefore, these GRAND GULF B 3.6-80 LBDeR J0030

B 3.6.3.3 operat conditions in an systems.

SURVEILLANCE REQUIREMENTS Performance of GRAND GULF B 3.6-81 LBDeR J0030

Drywell B 3.6.5.1 BASES ACTIONS In the event the drywell is inoperable, it must be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining the drywell OPERABLE during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring drywell OPERABILITY) occurring during periods when the drywell is inoperable is minimal. Also, the Completion Time is the same as that applied to inoperability of the primary containment in LCO 3.6.1.1, "Primary Containment."

If the drywell cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.5.1.1 REQUIREMENTS The analyses in Reference 2 are based on a maximum drywell bypass leakage. This Surveillance ensures that the actual drywell bypass leakage is less than or equal to the acceptable A/~k design value of 0.9 ft 2 assumed in the safety analysis. The testing is performed with one airlock door open (the airlock door remaining open is changed for the performance of each required test). As left drywell bypass leakage, prior to the first startup after performing a required drywell bypass leakage test, is required to be ~

10% of the drywell bypass leakage limit. At all other times between required drywell leakage rate tests, the acceptance criteria is based on design A/~k. At the design A/~k the containment temperature and pressurization response are bounded by the assumptions of GRAND GULF B 3.6-104 LBDCR 10031

Air Lock B

BASES (cOIltmIJed)

With one air lock door I the OPERABLE door must be fied closed ( red Action A. ).

order for a door to be considered OPERABLE, all of its associated seals must be OPERABLE.

Therefore, door device/mechanism barrier is maintained by air lock door. This action must be within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> consistent with the ACTIONS of Leo .6. ," which that the be to OPERABLE status within A.3, considered to lock door may valve become to treat the associated bulkhead as of the door because the bulkhead no GRAND GULF B 3.6-108 LBDeR 11003

Drywell Air Lock B 3.6.5.2 BASES ACTIONS (continued) than leak path past door seals. The OPERABLE door/bulkhead the necessary barrier between the containment and the environs.

must be isolated air lock door within the 24 The Time considered the OPERABLE air lock door, the OPERABLE door maintained GRAND GULF B 3.6-108a LBDCR 11003

DC Sources - operati ng B 3.8.4 BASES SURVEILLANCE SR 3.8.4.7 REQUIREMENTS (continued) A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system.

The discharge rate and test length (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Division 1 and Division 2 and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Division 3) correspond to the design duty cycle requirements as specified in Reference 4.

The surveillance Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 (Ref. 10), which state that the battery service test should be performed during refueling operations or at some other outage, with intervals between tests not to exceed 18 months.

This SR is modified by two Notes. Note 1 allows the once per 60 months performance of SR 3.8.4.8 in lieu of SR 3.8.4.7. This substitution is acceptable because SR 3.8.4.8 represents a more severe test of battery capacity than SR 3.8.4.7. The reason for Note 2 is that performing the surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. The Division 3 test may be performed in MODE 1, 2, or 3 in conjunction with HPCS system outages. credit may be taken for unplanned events that satisfy the surveillance.

SR 3.8.4.8 A battery performance test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test.

The test is intended to determine overall battery degradation due to age and usage.

The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 8) and IEEE-485 (Ref. 11). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

GRAND GULF B 3.8-58 LBDCR 11049 I

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