Text

Revision to Letter GNRO-2015/00013 to Change License Condition Number 48 to 49 and to License Condition 48 from Letter GNRO-2013/00012
	ML15063A075
Person / Time
Site:	Grand Gulf
Issue date:	03/04/2015
From:	Kevin Mulligan; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GNRO-2015/00012, GNRO-2015/00013, GNRO-2015/00017
	Download: ML15063A075 (5)
	v • d • e

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~Entergy Entergy Operations, Inc.

P. o. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President, GGNS Tel. (601) 437-7500 GNRO-2015/00017 March 3,2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Revision to letterGNRO-2015/00013 to change License Condition number 48 to 49 and to add License Condition 48 from letter GNRO-2013/00012 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. Entergy Letter, "Maximum Extended Load Line Limit Analysis Plus (MELLLA+) License Amendment Request," GNRO-2013/00012, dated September 25,2013 (ADAMS Accession No. ML13269A140).

2. Entergy Letter, "Response to Item 25 Request for Additional Information Regarding "Maximum Extended Load Line Limit Plus Amendment Request",

GNRO-2015/00003, dated 2/9/15.

3. Entergy Letter, "Request to convert Regulatory Commitments for Time Critical Operator Actions listed in letter GNRO-2015/00003, "Response to Item 25 Request for Additional Information Regarding Maximum Extended Load Line Limit Plus Amendment Request dated 5/19/2014" to a License Condition",

GNRO-2015/00013, dated 2/19/15.

Dear Sir or Madam:

In Reference 1, Entergy Operations Inc. (Entergy) submitted License Condition proposal #47 to prohibit Feedwater Heater Out-of-Service (FWHOOS) while operating in the MELLLA+ domain at the Grand Gulf Nuclear Station (GGNS), Unit 1. This letter proposes revising that License Condition number to 48 as Condition #47 is assigned to TSTF-423.

In Reference 3, Entergy submitted License Condition proposal #48 to require training and reporting of MELLLA+ Time Critical Operator Actions (TCOA) at GGNS, Unit 1. This letter proposes revising that License Condition number to 49 as Condition #48 is assigned to FWHOOS.

GNRO-2015/00017 Page 2 of 2 The proposed changes to the Operating License are attached to this letter.

If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 3rd day of March, 2015.

Sincerely,

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KJM/ras

Attachment:

Proposed License Conditions cc:

u.S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

u. S. Nuclear Regulatory Commission ATTN: Marc L. Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511

Attachment to GNRO-2015/00017 Proposed License Conditions

(h) This license condition shall expire upon satisfaction of the requirements in paragraph (f) provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is caused by fatigue.

(48) Feedwater Heaters Out-of-Service (FWHOOS)

Operation with FWHOOS in the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) region is prohibited.

(49) Time Critical Operator Action Commitments made as required for the MELLLA+ LAR will be converted to a License Condition as follows:

Prior to Operation in the MELLLA+ Domain, Entergy will:

Train all active operating crews to perform the following three MELLLA+ time-critical operator actions:

1. Initiate Reactor Water Level Reduction (90 seconds following failure to scram concurrent with no reactor recirculation pumps in service and CTP> 5%).

2. Initiate Standby Liquid Control Injection (300 seconds if CTP>

5% or before Suppression Pool Temperature reaches 110 degrees F) *

3. Initiate Residual Heat Removal Suppression Pool Cooling (660 seconds) .

GGNS will validate that all active operating crews have met the time requirements for the three MELLLA+ time-critical operator actions during evaluated scenarios.

GGNS will report any MELLLA+ time-critical actions that are converted to "immediate actions" to the NRC Project Manager.

The following are one-time actions which expire after the first report:

The results of the three MELLLA+ time-critical operator actions training will be reported to the NRC Project Manager within 60 days of completion of the training.

The reported results will include the full range of response times for each time-critical action and the average times for each crew.

Any MELLLA+ time-critical operator training failures during evaluated scenarios will be reported to the NRC within 60 days of any failures with a plan for resolution.

D. The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part 100. These include: (a) exemption from General Design Criterion 17 of Appendix A until startup following the first refueling outage, for (1) the emergency override of the test mode for the Division 3 diesel engine, (2) the second level undervo1tage protection for the Division 3 diesel engine, and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (Section 8.3.1 of SSER #7) and (b) exemption from the requirements of Paragraph III.D.2(b) (ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (Section 6.2.6 of SSER #7). These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. In addition, by exemption dated December 20, 1986, the Commission 16f Amendment No. +7G,-1-+8, +86 +9+; ~~, _

exempted licensees from 10 CFR 100.11(a) (1), insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a),

until April 30, 1987 regarding demonstration of authority to control all activities within the exclusion area (safety evaluation accompanying Amendment No. 27 to License (NPF-29).

This exemption is authorized by law, and will not present an undue risk to the public health and safety, and is consistent with the common defense and security. In addition, special circumstances have been found justifying the exemption.

Therefore, these exemptions are hereby granted pursuant to 10 CFR 50.12. with the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act and the rules and regulations of the Commission.

E. The licensee shall fully implement and maintain in effect all provision of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Physical Security, Safeguards Contingency and Training and Qualification Plan," and were submitted to the NRC on May 18, 2006.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP),

including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee's CSP was approved by License Amendment No. 186 as supplemented by a change approved by License Amendment No. 192 and 200.

16g Amendment No.