GNRO-2013/00074, Response to Electronic Request for Additional Information Regarding 18 to 24 Month License Amendment Request, Dated September 16, 2013

Response to Electronic Request for Additional Information Regarding 18 to 24 Month License Amendment Request, Dated September 16, 2013

ML13288A179
Person / Time
Site:	Grand Gulf
Issue date:	10/14/2013
From:	Kevin Mulligan Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2013/00074, TAC ME9764
Download: ML13288A179 (15)

Text

~Entergy Entergy Operations, Inc.

P.o. Box 756 Port Gibson, Mississippi 39150 Kevin J. MUlligan Site Vice President Grand Gulf Nudear Station Tel: 601-437-7500 GNRO-2013/00074 October 14,2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Electronic Request for Additional Information Regarding 18 to 24 Month License Amendment Request, dated September 16, 2013 (TAC ME9764)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. License Amendment Request for Implementing a 24-Month Fuel Cycle, dated October 2,2012 (Accession No. ML122770130, GNRO-2012/00096)

2. Electronic Request for Additional Information Regarding 18 to 24 Month License Amendment Request (TAC ME9764), dated September 16,2013 (GNRI-2013/00153)

Dear Sir or Madam:

On October 2, 2012, Entergy Operations, Inc. (Entergy) submitted a license amendment request (Reference 1) to the U.S. Nuclear Regulatory Commission (NRC) to implement a 24-month fuel cycle at Grand Gulf Nuclear Station (GGNS). On September 16,2013, the NRC provided GGNS with an electronic request for additional information (Reference 2). Entergy is providing, in the Attachment, the response to the request for additional information.

This letter contains no new commitments. If you have any questions, please contact Mr.

Christopher Robinson at (501) 437-7326.

I declare under penalty of perjury that the foregoing IS true and correct. Executed on the 14th day of October, 2013.

Sincerely,

)L r _

KJM/slw Attachment and CC: (see next page)

cc: Nuclear Regulatory Commission ATIN: Mr. Marc Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011 1 U.S. Nuclear Regulatory Commission ATIN: 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 to GNRO-2013/00074 Response to Request for Additional Information

GRAND GULF NUCLEAR STATION, UNIT NO.1 50-416 The format for the Request for Additional Information (RAI) responses below is as follows.

RAI is listed in its as from the U.S. Nuclear Regulatory Commission (NRC).

This is followed the Grand Gulf Nuclear Station (GGNS) RAI response to the individual question.

1. In response to the of failures in any other battery

....h ..~,....... ~~r tn(Ucate~C1 that was a or common mode failure. Additionally, you stated the fact that no other charger exhibited similar indicated that there was no time-based failure mechanism.

Please confirm whether the battery charger 1A4 is tracked under the maintenance rule program. Discuss the corrective taken to failure of the battery I"'h~2rn":::lr 1A4 current limit the probability of occurrence of that The official equipment identification "Battery Charger is 1L51S001A-1DA4 BATTERY CHARGER 1A4. This battery charger is installed in the GGNS System identified as the 125V BATTERY CHARGERS (L51) System.

'\lC:!'T'OI'T'l is scooea following paragraphs of 'IUvl'-'UI Paragraph 8.2.1.5 (Nonsafety-Related SSCs Whose Failure vau;;;>~"i;;;>

Scram or Actuates Safety Systems).

Maintenance

- HC'T""'rn rYll"\inl'trl,rCn at Plant S\Jc::tT,::lITi are as follows:

a) L51S001A-1DA4 (BATTERY CHARGER 1A4 - Division I)

L51S001B-1 (BATTERY CHARGER 1A5 - Division I)

L ..n . J \ . " L . T > - DB4 1 II) d) L51S002B-1DB5 (BATTERY CHARGER 1B5 - Division II) e) L51S003A-1DC4 (BATTERY CHARGER 1C4 - Division III) f) L51S003B-1DC5 (BATTERY CHARGER 1C5 - Division III)

nQl"tnf"rY\,Q.1'i in 5 (September 2008 - September 2013) was for the event documented in Condition Report (CR) CR-GGN-2010-1426 for component 1L51S001A-1004. The 1004 is a non-safety related Balance of Plant battery charger in the L51 system. It was concluded that this event was not a Maintenance Rule Functional Failure event The applicable Performance Criteria for the L51 System is as follows:

• Plant Level Performance Criteria

• No Repetitive Functional Failures

• or to 2 18 "",,1"'l,n1't'.e-

• Since the L51 System is a Low Risk Significant System, unavailability is not tracked for this system.

The L51 System is performing at a level to warrant its current (a){2) status. The L51 System has maintained the (a)(2) status for the September 2008 through September 2013 frame and currently has no Maintenance Rule Functional Failures.

Pr~'\1~,,,t~i*i\l~ Maintenance (PM) template chargers includes a 10 year replacement frequency for printed circuit cards and capacitors installed on Low 1A4 is and Safety Related. PMRQ No. 50024582-02 is in place to replace capacitors used on the 1L51S001A 10A4 Charger. Similar PM Tasks are in place for the other similar chargers.

PM Tasks are adequate to maintain the battery chargers in an acceptable condition when considering age sensitive failures. Corrective actions taken to recover from the 1A4 current were in Order (V\IO) No. 51690933 where the (cards) were recalibrated in April 2009. In 2010, during performance of Surveillance L51-R-0001, an issue was observed and the in charger 1A4 were replaced along with reCilacement of WO No. Since the 1"t"\,::u"rU:llr and

2. In response to the RAI number 3a you stated: "The reference to SR 3.8.4.3 was a typographical error. The intent of the statement was to perform the SR performance discharge test, or a modified performance discharge test interval rather than the test at the 18-month interval.

The NRC staff notes that the licensee did not request a change to the frequency of SR 3.8.4.8 and the statement in Attachment 5, Section 3.8.4 of the LAR is related to the commitments to RG 1 RG 1.129, and that recommend the battery service test (SR 3.8.4.7) to be performed during refueling operations or at some other outage with intervals between tests not to exceed 18 months.

a.

b. Update the TS bases to reflect that the change to 24 months is made in accordance with the GL 91-04 and is approved in the safety evaluation that will be issued.

Response a):

The LAR requested the extension of SR 3.8.4.7 "Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery test" to a 24 month interval. This surveillance may be extended to 30 months under the provisions SR 3.0.2, which allows of an at 1 times interval specified in the The text in the second paragraph on page 29 of Attachment 5 of the 24 Month Fuel Cycle License Amendment Request is revised to state:

Additionally, upon approval of this amendment request, commitments outlined in the Grand Gulf UFSAR related to RG 1 for Nuclear Plants," RG 1. 1 "Maintenance, Testing, and Replacement of Large Lead Storage Nuclear Power Plants, and IEEE-450, "Recommended Maintenance, Testing, and Replacement of Vented Lead-Acid to I"",,!::'l""tnl"i!'n SR 3.8.4.7) during refueling outages, or at some other outage, with intervals between tests "not to exceed 18 months, will be revised to reflect intervals between tests Unot to exceed 24 months.

TS 2 contains a clean copy of this a mark-up copy of TS Od:::lt::;:s

< J - .....' ..... CO. which include the mark-ups to the of the TS bases for information This revision incorporates references to Generic Letter 91-04 "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Cycle" and the forthcoming Safety Evaluation Report for a 24 month fuel

3. In response to the RAt number 4a you stated: "The 25% grace period and the 1.25 times UI1'JC:.nJ*~. in SR to the same time and allow for a margin for surveillance performance when required by plant operating conditions. This margin allows the plant to optimize fuel use during reactor coast down, and gives plant the

Attachment Page 4 of4 the rt01*ln4::.t"'l Clarify how Entergy will perform SRs for mode requirements 3, 4, and 5, 1) after the refueling/outage period when SR 3.0.2 applies to these SRs and 2) after the 30 month-extended period if these SRs are missed.

Grand Gulf (i.e., Entergy) is required to perform all necessary surveillance requirements (SRs) within their specified time intervals, not to exceed 1.25 times the interval specified in the Frequency permitted by SR 3.0.2. If a SR is not satisfied within 1.25 times the interval specified in the Frequency, then SR 3.0.3 requires the licensee to declare the limiting condition for operation (LCO) not without Grand Gulf would then perform the required actions of the LCO or, if unable to satisfy the required actions of the LCO, take additional prescribed measures which may ultimately require a plant shutdown (depending on the LeO).

to a month period of 30 months (1.25 times), then licensee to declare the LCO not met without delay. Grand Gulf would then perform the required actions of the LCO or, if unable to satisfy the required actions of the LCO, additional prescribed measures which may ultimately a plant shutdown (depending on the

Enclosure 1 to the Attachment to GNRO-2013/00074 Proposed Technical Specification Changes (mark-up)

Note, markup deletions identified by strikethrough (Gelete) and additions identified by underline (addition).

DC Sou ng 3 8.4

1. SR 3.8.4.8 may be performed in lieu SR 3.8.4.7 once per 60 months.

2. This Surveillance shall not be performed in MODE 1, 2, or 3 (not appl cable to vision However, credit may be taken for unplanned events that this SR.

is to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subj to a battery service test.

GRAND GULF 3.8-29 No.

Enclosure 2 to the Attachment to GNRO-2013/00074 Proposed Technical Specification Changes (clean)

DC Sou ng 3.8.4 SURVEILLANCE SR .8.4. ---NOTES--

1 SR 3.8.4.8 may be in lieu of SR 3.8.4.7 once per 60 months.

2. llance 1 not in MODE 1, 2, or 3 (not e to vision However, may be taken for unplanned that sfy this SR.

to 24 status, gn GRAND 3.8-29 No. __

Enclosure 3 to the Attachment to GNRO-2013/00074 Proposed Technical Specification Bases Changes (mark-up)

Note, markup deletions identified by strikethrough (Getete) and additions identified by underline (addition).

rces the's gn requirements power 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 Divi on 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 speci ed in 4.

Frequency of 18-24 months is consistent

. 9) ce test should performed during refueling operations or at some other with intervals between tests not to exceed This SRis modi two Notes. Note 1 per 60 months performance of SR 3.8.4.8 lieu MODE 1, 2, or 3 Credit may Su 11 ance.

A battery performance test is a constant current capacity in the as found condi on, ce, to any in the test.

The test is 1 on The a this llance is stent with IEEE-450 (Ref. 8) and IEEE-485 (Ref. 11). These recommend that the battery be rep1 if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the rate on is i ng, even if is ample to meet load rements.

GRAND GULF B 3.8-58 LBDCRtBE t:tj1:1tTf_ _

DC Sources ng B 3.8 4 BASES The Surveillance Frequency for this test is normally 60 months. the battery shows degradation, or if battery has reached 85% of its expected li and capacity is

< 100% of the manufacturer's rating, the Surveillance Frequency is to 12 However, if no degradation but has reached 85% of its Su llance is only es n ng. on is indi 10%

rel ve to its capacity on the previous performance test or is below 90% of the manufacturer's ng. These Frequencies are on the recommendations in (Ref.

Note is DC unction with unplanned events REFERENCES 1. 10 CFR 50 x A, GDC 17.

2 10, 1971.

3 IEEE 1978.

4. UFSAR, on 8.3.2.

5. 6.

6.

7 atory Guide 1.93, December 1974.

8. IEEE Standard 450, 1987.

9 1.32 1977.

10. Regulatory Guide 1.129, 1974.

11. IEEE Standard 485.

GRAND GULF B 3 8-59

DC Sources ng B 3.

8.4 REFERENCES

GRAND B 3.8- LBDCR _ _