GNRO-2015/00024, Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Technical Specification Task Force TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month
| ML15127A583 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/06/2015 |
| From: | Kevin Mulligan Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GNRO-2015/00024 | |
| Download: ML15127A583 (12) | |
Text
Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2015/00024 May 6,2015 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Request for Additional Information Regarding Application To Revise Technical Specifications To Adopt Technical Specification Task Force (TSTF) TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month" Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCE:
- 1. Letter: Grand Gulf Nuclear Station Unit 1, Application To Revise Technical Specifications To Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month" (GNRO-2014/00078) (ML14351A059)
- 2. NRC Electronic Letter: Grand Gulf Nuclear Station, Unit 1, Request for Additional Information Regarding Technical Specification Task Force Traveler (TSTF) - 522 (Dated April 1, 2015) (TAC No. MF5504)
Dear Sir or Madam:
Entergy Operations, Inc. is providing in the Attachment 1, the response to Reference 2, Request for Additional Information Regarding Technical Specification Task Force Traveler (TSTF) - 522.
This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Mississippi Official.
th I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6 day of May, 2015.
GNRO-2014/00024 Page 2 of 2 Sincerely,
'11""'1-----
--.......L L _
KJM/ram Attachments: 1. Response to Request for Additional Information
- 2. Revised Page 1 of Attachment 1 of Letter GNRO-2014/00078 cc:
u.S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRR/DORL 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
GNRO-20 15/00024 OUTLOOK MAIL: DISTRIBUTION IS ALL ELECTRONIC Brumfield N. T. (RB-R&PI)
Busick R. D. (GG-OPS)
Chase M.L. (Acting - W3-R&PI)
Clark J. A. (RB-RA)
Coutu T. (GG-R&PI)
Ford B. S. (ECH-NS&L)
Fallacara V. (GG-GMPO)
Meaders E.A. (GG-TRNG)
OTHER - Licensing Files LRS_DOCS (GNRI or GNRO)
GGN CENTRAL FILE (12)
GGN PLANT LICENSING GGN\RBS SRC ALL LER's ALL RESPONSE TO VIOLATIONS James D. E. (ANO-R&PI)
Ellis D. R. (Acting - GG-EP)
McCann J. F. (WP-VP)
Mulligan K. J. (GG-VP)
Jarrell J. P. (W3-RA)
Pyle S.L. (ANO-RA)
Nadeau J. J. (GG-RA)
Milly M. (GG-MAINT)
Wiles D.P (GG-ENG)
SRC ALL OSRC Approved License Amendment Requests
Attachment 1 to GNRO-2015/00024 Response To Request For Additional Information
GNRO-2015/00024 Request for Additional Information
RAI-1
The LAR states that the justifications presented in the TSTF-522 Traveler and the model Safety Evaluation (SE) prepared by the U.S. Nuclear Regulatory Commission (NRC) staff are applicable to Grand Gulf Nuclear Station, Unit 1 (GGNS).
The NRC guidance in the model SE states that at least 15 continuous minutes of ventilation system operation with heaters every 31 days is acceptable for those plants that test ventilation system charcoal adsorption at a relative humidity of less than 95 percent. The model SE also states that plants that test ventilation system absorption at a relative humidity of 95 percent do not require heaters for the ventilation system to perform its specified safety function. Based on the TS Program and Manuals, Section 5.5.7 "Ventilation Filter Testing Program (VFTP), the SGTS is an Engineered Safety Feature (ESF) filter ventilation system and it contains charcoal adsorbers. However, the VFTP and the GGNS Updated Final safety Analysis Report (UFSAR) indicate that there are no charcoal adsorbers in the CRFA. Therefore, it is not clear to the NRC staff the correlation between the LAR for the CRFA and the adoption of TSTF-522 or to the NRC staff's model SE for the TSTF. Please provide the safety basis for the heaters in the CRFA and additional information to support the requested TS change for the CRFA.
Response
System Design Criteria SDC-Z51 Rev 002 Section 4.15.4 describes the Heaters as it relates to the Control Room Fresh Air (CRFA) Subsystem of the Z51 System. The standby fresh air units is equipped with heating elements to reduce the relative humidity of incoming air at 95 degrees Fahrenheit from 100 percent to 70 percent. The heater controls is designed to minimize malfunction and is shielded from upstream and downstream components so as to not pose a potential source of ignition to the adsorbent. Air flow is required to be established prior to the heating coils being energized.
The charcoal adsorbers are no longer installed in the CRFA Subsystems because the intake air is filtered through charcoal adsorbers installed in the Safeguard Switchgear and Battery Room Outside Air Intake system.
Based on the System Design Criteria, the LAR is acceptable to adopt for the Control Room Fresh Air Subsystem of the Z51 System. The 15 minutes of operation with the Heater energized is sufficient to meet the Ventilation Filter Test Program and the Updated Final Safety Analysis Report. The Heaters are installed upstream of where the charcoal filters were installed, and GGNS would be testing the adsorption of the charcoal filters at a relative humidity of less than 95 percent. Since the charcoal filters have been removed, it is acceptable to still apply the Safety Evaluation and TSTF-522 Traveler to the CRFA Subsystem.
GNRO-2015/00024 Request for Additional Information
RAI-2
Section 2.2, Optional Changes and Variations, in Attachment 1 to the LAR states the following:
"Entergy is not proposing any variations or deviations from the TS changes described in the in the TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation dated September 13, 2012. Entergy is proposing the following variations from the TS changes described in the in the TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation dated September 13, 2012."
Please clarify the apparently conflicting statements above and provide any additional information if the second part of the paragraph were to be applicable.
Response
The second sentence contained in Attachment 1, "Description of Assessment," of GNRO-2014/00078 was part of the generic format for Section 2.2 provided in TSTF-522.
The submittal developer failed to remove this sentence during the submittal preparation process prior to the license amendment request being submitted to the NRC. This page was revised to remove this sentence from the section. The revised page is attached to this letter in Attachment 2 for NRC consideration.
Request for Additional Information
RAI-3
Attachment 4 to the LAR provides a mark-up of the proposed changes to TS Bases for staff information. The staff suggests that Bases changes related to SR 3.7.3.1 be modified to convey a better understanding of the intended information.
Response
Entergy reviewed the wording to ensure clarity of the bases pages for SR 3.7.3.1 and has concluded no changes are required.
Attachment 2 to GNRO-2015/00024 Revised Page 1 of Attachment 1 of Letter GNRO-2014/00078
GNRO-2014/00078 DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
The proposed change revises the Surveillance Requirements which currently require operating ventilation systems with the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days.
The Surveillance Requirements are revised to require operation of the systems for 15 continuous minutes every 31 days.
The proposed amendment is consistent with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy has reviewed the model safety evaluation dated September 13, 2012 as part of the Federal Register Notice for Comment. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-522. As described in the subsequent paragraphs, Entergy has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to GGNS Unit 1 and justify this amendment for the incorporation of the changes to the GGNS TS.
2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the TS changes described in the TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation dated September 13, 2012.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination GGNS Unit 1 requests adoption of an approved change to the standard technical specifications (STS) and plant specific technical specifications (TS), to revise Technical Specification (TS) 3.6.4.3, "Standby Gas Treatment (SGT) System," and TS 3.7.4, "[Control Room Air Conditioning (AC) System," in the BWR/6 SGT System and CRFA System with the electric heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days. The Surveillance Requirement is revised to require operation of the systems for 15 continuous minutes every 31 days.
As required by 10 CFR 50.91 (a), an analysis of the issue of no significant hazards consideration is presented below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
Q NUCLEAR 'QUALITY RELATED EN-Ll-106 I REV. 13
~Entergy MANAGEMENT MANUAL INFORMATIONAL USE NRC Correspondence ATTACHMENT 9.4 NRC SUBMITTAL REVIEW Sheet 1 of 2 {Typical}
Letter#: GNR02015/00024 Response Due: May 1, 2015 Su~ject: Request for Additional Information DatelssuedforRevlew: April 2, 2015 Regarding Application To Revise Technical Specifications To Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month" Correspondence Preparer I Phone#: ,Richard Meister/6685 S ectlon L etter C oncurrence an dA~greement to Pe rf orm A ctlons .
, POSITION I NAME Action Signature (concurrence, certification, etc.) (sign, interoffice memo, e-mail; ortelecorn)
Wesley Johnson Certification See Attachment 9.5 Engineering Kenneth Boudreaux Engineering Concurrence
- ~c-e-t4~ D~' (
Mark Goodwin Concurrence Operations i1tWI?~
COMMENTS Response to RAI received on April 1, 2015 S ection I Correspon d ence S creenmg Does this letter contain commitments? If "yes," identify the commitments with due Yes 0 dates in the submittal and in Section III. When fleet letters contain commitments, a No 181 PCRS LO (e.g., LO-LAR, LO-WT) should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.
Does this letter contain any information or analyses of new safety issues performed at NRC Yes 0 request or to satisfy a regulatory requirement? If "yes," reflect requirement to update the No 181 UFSAR in Section III.
EN-LI-106 REV 13
Q EN-Ll-106
~Entergy NUCLEAR MANAGEMENT QUALITY RELATED I REV. 13 INFORMATIONAL USE MANUAL NRC Correspondence Does this letter require any document changes (e.g., procedures, DBDs, FSAR, TS Bases, Yes D etc.), if approved? If "yes," indicate in Section III an action for the responsible No ~
department to determine the affected documents. (The Correspondence Preparer may indicate the specific documents requiring revision, if known or may initiate an action for review.)
Does this letter contain information certified accurate? If "yes," identify the information Yes ~
and document certification in an attachment. (Attachment 9.5 must be used.) No D EN-LI-106 REV 13
Q QUALITY RELATED
~Entergy NUCLEAR MANAGEMENT EN-Ll-106 I REV. 13 MANUAL INFORMATIONAL USE NRC Correspondence ATTACHMENT 9.4 NRC SUBMITTAL REVIEW Sheet 2 of 2 Section III Actions and Commitments Required Actions Due Date Responsible Dept.
Note: Actions needed upon approval should be captured in the appropriate action tracking system N/A N/A N/A Commitments Due Date Responsible Dept.
Note: When fleet letters contain commitments, a PCRS LO should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.
Nt'" Nt'"
N/A Section IV Final Document Si noff for Submittal Correspondence Preparer Richard Meisterl Final Submittal Review (optional) N/A Responsible Department Head James Nadeaul EN-LI-106 REV 13
Q NUCLEAR QUALITY RELATED EN-Ll-106 I REV. 13
~Entergy MANAGEMENT MANUAL INFORMATIONAL USE NRC Correspondence ATTACHMENT 9.5 CERTIFICATION REFERENCE FORM Sheet 1 of 1 Letter Number: I GNRO-2015/00024
Subject:
Request for Additional Information Regarding Application To Revise Technical Specifications To Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month" Certifiable Statement(s): Use one of the following methods to identify certifiable statements in the table below:
1 Identify location in submittal (e.g., page 3, para 2, sentence 1) OR, 2 Paste in the exact words of the statement(s) OR, 3 State "see attachment" and attach a copy of the correspondence with the certifiable statements indicated (e.g., by redlining, highlighting, or underlining, etc.).
Each statement or section of information being certified should be uniquely numbered to correspond with the supporting documentation listed below.
Objective Evidence or Basis of Peer Review: List the supporting documents in the table below and attach a copy of the documents OR give basis of peer review. Large documents need not be attached.
Certifiable Statement(s) Objective Evidence or Basis of Peer Review RAI-1 and RAI-3 Response Statements Contained in Attachment 1 Reference LR-LAR-2014-00226 CAs 8&9 of GNRO-2015/00024 Individual certifying the statement(s): Certification may be documented using e-mail, telecom, "sign off' sheet, or inter-office memorandum. The form of documentation should specifically identify the information being certif d.
Patrick Griffith Sys Eng Name Department Date Peer Review: Prior to signing for certification, determine if a Peer Review is required per section 5.4[2](c). Indicate "N/A" if not required.
N/A Name Department Date EN-LI-106 REV 13