GNRO-2013/00023, Supplement to the License Amendment Request for Implementing a 24-Month Fuel Cycle

Supplement to the License Amendment Request for Implementing a 24-Month Fuel Cycle

ML13119A102
Person / Time
Site:	Grand Gulf
Issue date:	04/26/2013
From:	Kevin Mulligan Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GNRO-2013/00023
Download: ML13119A102 (8)

Text

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--~ Entergy Entergy Operations, Inc.

P. 0. Box 756 Port Gibson, MS 39150 Kevin J. Mulligan Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2013/00023 April 26, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Supplement to the License Amendment Request for implementing a 24-Month Fuel Cycle Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCE:

GNRO-2012/00096: Letter, Michael Perito (Entergy) to the U. S. Nuclear Regulatory Commission, License Amendment Request for implementing a 24-Month Fuel Cycle, dated October 2, 2012 (Accession Number ML12277AO80)

Dear Sir or Madam:

In the referenced letter, Entergy Operations, lnc. (Entergy) submitted a license amendment request (LAR) to the NRC to amend the Grand Gulf Nuclear Station, Unit 1 (GGNS) Technical Speci"cations (TS) to support operation with 24-month fuel cycles in accordance with guidance contained in NRC Generic Letter (GL) 91-04. Entergy inadvertently omitted TS Surveillance Requirement SR 3.7.7.2 Main Turbine Bypass System from the LAR. This letter supplements the referenced LAR by incorporating SR 3.7.7.2 into the request.

The change in frequency for SR 3.7.7.2 from 18 months to 24 months has minimal, if any, impact on system capability, consistent with other such changes presented in the referenced LAR. A mark-up of SR 3.7.7.2 (TS page 3.7-15) is included in Attachment 1. A mark-up of the corresponding TS BASES page is also included for information only. A Clean TS page incorporating this change is included in Attachment 2.

Also included in Attachment 2 is a clean page replacement for TS page 3.3-78 that was included in the original LAR. Marked-up page 3.3-78 included with the original LAR is correct.

However, the mark-ups were not transcribed into the corresponding clean TS page correctly.

Please replace the current TS page 3.3-78 with this corrected page.

The no signi"cant hazards consideration statement that was submitted with the original LAR has been reviewed and continues to bound this supplement.

In accordance with 10 CFR 50.91(b) (1), State Consultation, a copy of this supplement is being provided to the designated Mississippi Of"cial.

GNRO-2013/00023 Page 2 of 2 There are no new commitments in this letter. lf you have any questions or require additional information, please contact Mr. Christopher R. Robinson at 601- 437-7326.

l declare under penalty of perjury that the foregoing is true and correct. Executed on April 26 201 3.

Sincerely, KJM/ceb .

Attachments: 1. GGNS TS and BASES Marked-Up Pages

2. GGNS TS Clean Pages cc: U.S. Nuclear Regulatory Commission ATTN: Mr. Arthur T. Howell, (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 7601 1-4511 U. S. Nuclear Regulatory Commission ATTN: Mr. Alan Wang, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Washington, DC 20555-0001 NRC Senior Resident inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 GNRO-2013/00023 GGNS TS and BASES Marked-Up Pages

Main Turbine Byp ass System 3.7 PLANT SYSTEMS 3.7.7 Main Turbine Bypass System LCO 3.7.7 a. The Main Turbine Bypass System shall be OPERABLE with two Main Turbine Bypass Valves.

b. The following limits are made applicable:

1. LCO 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR), limits for an inoperable Main Turbine Bypass System, as specified in the COLR.

9&2

2. LCO 3.2.3, LINEAR HEAT GENERATION RATE (LHGR), limits for an inoperable Main Turbine Bypass System, as specified in the COLR.

APPLICABILITY: THERMAL POWER 2 70% RTP ACTION CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.l Satisfy the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> not met or Main Turbine Requirements of the Bypass System is LCO or restore the inoperable. Main Turbine Bypass System to OPERABLE status.

B. Required Action and B.l Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion to < 70% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS =:

i l E ~

SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify one complete cycle of each main turbine 31 days bypass valve.

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SR 3.7.7.2 Perform a system functional test. at? months vi it4 S

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nv rti at GRAND GULF 3.7~l5 Amendment N0. &9%mW

Main Turbine Bypass System B 3.7.7 BASES (continued)

§_-_l If the Main Turbine Bypass System cannot be restored to OPERABLE status or the LHGR and MCPR limits for two or more inoperable Main Turbine Bypass valves are not applied, THERMAL POWER must be reduced to < 70% RTP. As discussed in the Applicability section, operation at <70% RTP results in sufficient margin to the required limits, and the Main Turbine Bypass system is not required to protect fuel integrity during the feedwater controller failure. maximum demand event. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.7.;

REQUIREMENTS Cycling each Main Turbine Bypass valve through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.7.2 The Main Turbine Bypass System is required to actuate Nebula. automatically to perform its design function. This SR 5 ,/".§#W~% demonstrates that, with the required system initiation

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resignals, the valves will actuate to their required position.

"rr* Thé§18'month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and because of the potential for an unplanned transient if the Surveillance were performed with the f reactor at power. Operating experience has shown thefa"f Sear month Frequency, which is based on the refueling cycle, is acceptable from a reliability standpoint. .?gWWm. "R__J,,,m,>> no/~"

V/FMMWM l qvwvmwwl ftliai REFERENCES None GRAND GULF B 3.73O LBDCR 12035

Attachment 2 GNRO-201 3100023 GGNS TS Clean Pages

Main Turbine Bypass System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Main Turbine Bypass System LCO 3.7.7 a. The Main Turbine Bypass System shaTT be OPERABLE with two Main Turbine Bypass Vaives.

QR

b. The foiiowing Timits are made appiicabiez

1. LCO 3.2.2, MINIMUM CRITICAL PONER RATIO (MCPR), Timits for an inoperabie Main Turbine Bypass System, as specified in the COLR.

AND

2. LCO 3.2.3, LINEAR HEAT GENERATION RATE <LHGR)," Timits for an inoperabie Main Turbine Bypass System, as specified in the COLR.

APPLICABILITY: THERMAL POWER 2 70% RTP ACTION ___

CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.I Satisfy the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> not met or Main Turbine Requirements of the Bypass System is LCO or restore the inoperabie. Main Turbine Bypass System to OPERABLE status.

B. Required Action and 8.1 Reduce THERMAL POWER 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Compietion to < 70% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify one compiete cycie of each main turbine 31 days bypass vaive.

SR 3 7.7.2 Perform a system functionai test. 24 months l GRAND GULF 3.7-I5 Amendment No. %9%

LOP Instrumentation 3.3.8.1 SURVEILLANCE REQUIREMENTS

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _-NOTES----_-__.__-____-------___________-_

1. Refer to Tabie 3.3.8.I~1 to determine which SR5 apply for each LOP Function.

2. when a channei is piaced in an inoperabie status soTeTy for performance of required Surveiiiances, entry into associated Conditions and Required Actions may be deiayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function maintains DO initiation capabiiity.

SURVEILLANCE FREQUENCY SR 3 3 8 1.1 Perform CHANNEL FUNCTIONAL TEST. 31 days SR 3.3.8.1.2 Perform CHANNEL CALIBRATION. I8 months SR 3.3.8.1.3 Perform CHANNEL CALIBRATION. 24 months SR 3.3.8.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months GRAND GULF 3.378 Amendment No. 1267 ___