GNRO-2006/00056, License Amendment Request, Application for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities Using the Consolidated Line Item Improvement Process

License Amendment Request, Application for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities Using the Consolidated Line Item Improvement Process

ML063240095
Person / Time
Site:	Grand Gulf
Issue date:	11/13/2006
From:	Brian W Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2006/00056
Download: ML063240095 (15)

Text

Entergy Operations, Inc.

P O Box 756 Port Gibson, MS 39150 Tel601 437 2800 GNR&2006/00056 November 13,2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Grand Gulf Nuclear Station, Unit I Docket No. 50-416 License Amendment Request Application for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities Using the Consolidated Line Item Improvement Process

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station (GGNS), Unit 1.

The proposed amendment would revise LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 200°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in MODE 4.

This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF- 484, Use of TS 3.10.1 for Scram Time Testing Activities. The availability of the model safety evaluation for this TS improvement was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the Consolidated Line Item Improvement Process (CLIIP).

GNRO-2006/00056 Page 2 of 3 provides a description of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides summary of the regulatory commitments made in this submittal. Attachment 4 provides the existing TS Bases pages marked up to show the proposed change (for information only).

Entergy requests approval of the proposed amendment by February 15,2007. Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

If you have any questions or require additional information, please contact Mr. Matt Crawford at (601) 437-2334.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 13,2006.

SincereIy, \

William R. Brian GGNS Vice President, Operations MLC/amt Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes

3. Regulatory Commitments

4. Proposed Technical Specification Bases Changes cc: (See Next Page)

GNRO-2006/00056 Page 3 of 3 cc: NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Dr. Bruce S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. Bhalchandra Vaidya, NRWDORL (w/2)

ATTN: ADDRESSEE ONLY Mail Stop OWFN/O-7DIA Washington, DC 20555-0001 Mr. Brian W. Amy, MD, MHA, MPH Mississippi Department of Health P.0. Box 1700 Jackson, MS 39215-1700 Mr. D. E. Levanway (Wise Carter)

Mr. L. J. Smith (Wise Carter)

Mr. N. S. Reynolds Mr. J. N. Compton

Attachment 1 GNRO-2006100056 Description and Assessment to GNRO-2006/00056 Page 1 of 3 License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for SCRAM Time Testing Activities I .O Description 2.0 Proposed Change

3.0 Background

4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Determination 5.2 Applicable Regulatory RequirementsICriteria 6.0 Environmental Consideration 7.0 References 1.O DESCRIPTION The proposed amendment would revise Grand Gulf Nuclear Station (GGNS), Unit 1 Technical Specification (TS) LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 200°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in MODE 4.

This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF- 484, Use of TS 3.10.1 for Scram Time Testing Activities. The availability of the model safety evaluation for this TS improvement was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 PROPOSED CHANGE

Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, lnservice Leak and Hydrostatic Testing Operation. Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS Amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

This application is being made in accordance with the CLIIP. Entergy is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the NRC staffs model Safety Evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLllP Notice of Availability.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability of Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1 published on October 27, 2006 (71 FR 63050).

to G NRO-2006/00056 Page 2 of 3

4.0 TECHNICAL ANALYSIS

Entergy has reviewed the Safety Evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLllP Notice of Availability of the Model Safety Evaluation. Entergy has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Grand Gulf, Unit 1 and therefore justify this amendment for the incorporation of the proposed changes to the Grand Gulf, Unit 1 TS.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Determination Entergy has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Regisfer as part of the Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1 published on August 21, 2006 (71 FR 48561). Entergy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to GGNS, Unit 1 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability of the Model Safety Evaluation published on October 27, 2006 (71 FR 63050).

6.0 ENVIRONMENTAL CONSIDERATION

Entergy has reviewed the environmental evaluation included in the safety evaluation published on October 27, 2006 (71 FR 63050) as part of the CLllP Notice of Availability of the Model Safety Evaluation. Entergy has concluded that the staffs findings presented in that evaluation are applicable to GGNS, Unit 1 and the evaluation is hereby incorporated by reference for this application.

7.0 REFERENCES

1. Federal Register Notice (71 FR 48561), dated August 21, 2006, "Notice of Opportunity to Comment on Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1,Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process."

2. Federal Register Notice (71 FR 63050), dated October 27, 2006, "Notice of Availability of Model Safety Evaluation on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1,Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process."

to GNRO-2006/00056 Page 3 of 3

3. Federal Register Notice (71 FR 55807), dated September 25, 2006, Notice of Opportunity to Comment on Model Application on Technical Specification Improvement to Modify Requirements Regarding LCO 3.10.1,Inservice Leak and Hydrostatic Testing Operation Using the Consolidated Line Item Improvement Process.

4. Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-484 Use of TS 3.10.1 for Scram Time Testing Activities, Revision 0.

Attachment 2 GNRO-2006/00056 Proposed Technical Specification Changes

Inservice Leak and Hydrostatfc Testing Operation 3.10.1 3.10 SPECIAL O P E R A T I W 3.10.1 Inservice Leak a d Hydrostatic Tn%ting flperation LCO 3.10.1 The average reactor coolant temperature specified i n Table 1.1-1 for WIDE 4 my be changed to 'HA,' m d operatfon considered not to be I n MOM 3; and the requfrmentr of

a. LCO 3.3.6.2, "Secondary Contalmnt lsolrtlon Instrusentitlon,' Functions 1, 2, 3, 4, and 5 o f Table 3.3.6.2-1;

b. CCO 3.6.4.11 '%Ond&\r COnt*tWRt" j

c. LCO 3.6.1.2, "Secondary ContiiMant Isolatfon Valwr (SCIVs)'; and

d. LCO 3.6.4.3, 'Standby 6as Treatment (S6T) System.'

APPtICABtLlfY: HODE 4 with average reactor coolant teDperrture s 200'F.

For performance of an inservice leak or hydrostatic test, 0 As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, C W D WLF 3.10-1

Attachment 3 GNRO-2006/00056 Regulatory Commitments to GNRO-2006/00056 List of Regulatory Commitments The following table identifies those actions committed to by ENTERGY in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

1 ypE 1 ONE-(Check One SCHEDULED COMPLETION 1

TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (If Required)

ENTERGY will establish the Technical X 60 days following Specification Bases for LCO 3.10.1 as NRC approval of the adopted with the applicable license License amendment. Amendment Request

Attachment 4 GNRO-2006100056 Proposed Technical Specification Bases Changes to GNRO-2006/00056 Page 1 of 2 fnservice leak and Hydrostatic Testing Operatlon B 3.10.1 8 3.10 SPECIAL OPERATIONS 6 3.10.1 inservice Leak and Hydrostatk Tettfng Operation EASES BACKGROMD The purpose of this Special Operations LCO i s to allow certaln reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics o f the reactor pressure vessel (RFV) require the pressure testi teaperaturet > 200'F ( n a m l l y correspondlng to %?3) .f(lNsERT11 fnsewice hydrostatic testing a d system leakage pressure tests required by Section XI o f the A w r k a n Society o f kchanical kngineers (ASHE) Boiler aM1 PrerfUre Vessel Cbde (Ref. 1) are performed prior to the reactor going crttlcal after (I rehellng outage. Reclrculakiun urry u p r & l o n dnd a water solid RPIl (except for an air bubbre for pressure eontrul) rn used to achieve the necessary teaperatwas md pressures required for these tests. Tha ainlsAa ttnpttaturas ( a t the required pressures) allowad f o r there tests are detemined frola the RPV pressure and temperature (P/T) lirilts required by LCO 3.4.11, 'Reactor Coolant System (RCS) Pressure and Temperature (P/T) Llmits.' These liuits P ~ conrervat4vsly B based on the fracture toughness nf the reactor vessel, taking into account anticipated vessel nru t ron flupnco .

Ufth increased reactor vessel fluence over tine, the m i n l q m allowable vessel temperature Increases at I given pressure.

Periodlc updates to the RCS Pfl limit CUPVBS are p e r f o d as necessary, based on the results o f analyses of irradfated surveillance specimens renrtrved frbp the vessel. Hydrostatic reactor coo1int"tmperaturer > h 0 . F . 9 and leak testina wfll evantuallv k mired with R i n i m INSERT 2 APPL ICABtE SAFETY AMLYSES nsidered I n WE 4

@F=-

h e n the reactor coo ant tlvely provldes an exception to

' during or as a consequence OPERABILITY of prlmary ersent of redundant Emergency 1 of, hydrostatic or leak testing, or as a consequence of Core Cooling Systems (ECCS), Since the hydrostatic or leak tests are performed nearly water solid, a t low dtcay heat control rod scram lime testing values, and near WE 4 conditions, the stored energy In the initiated in conjunction with reactor core will be very low. Under these conditions, the an inservice leak or potential for failed fuel and a subsequent increase I n hydrostatic test, (cont inuedl GRAM) GULF 8 3.10-1 Revision No. 0 to GNRO-2006/00056 Page 2 of 2 Inservice Leak and Hydrostatic Testing Operation 8 3.10.1 RASES crxl > ?tlO'F, uhilc the AglE inservice t e s t i t s e l f rewires the (continued) rafety/relief valves t o be gagged, prevarrting their I , , OPfRA6)t'*TYp

,,,,,l- I I I f i t i s desired to pcrforn these tests wbfle colrglying uith t h l s Soeciol Owrationo LCO. then the W#tE 4 aoalicabla LCOs and s p k i f t w i ~UWE3 LCOS Gst be at. This S k i a t Operations LCO allows chrtqing Table 1.1-1 temperature linits f o r KKE I t o *M* aad suspewlltq the roquireaents o f LCO 3.4.10, 'Residual Heat R-al (RHO) SWtdMn Coollng SystecCold Ywtdorn." Tke additforrrl wquireaeats for I , and for control rod secondary contairrrneat LU?s to be met wlll wovlde sufficlent scram time testing protectfort for opsritfmr a t rwctor t tqwmwi?s initiated in conjunction > Z W F For tM purposes 6f perfmr8i~- r insewke with an inservice leak or 1

hydrostatic test.

' unobstructed m i s s to-prtrfsrr irspectioas,-and to k o m forfor freauertt outage actlvittes on v l r l o u t systems coatiart csnslstmt with the EloM 4 rippliuble requimmaetr that i n effect i6edlrtely prior t o and irsdlrtely a f t e r this operation.

~ __ ~ ~-

ray aalp be r d l f i e d fer

,or as a consequence of, mi-t fw c m t a i - t t wDuBIcrTy actoding t o the f.posed RQof 3 requirevfitr provtdor consenatira i n the response crf tbe w i t t o my e w t tlut occur.

Operotianr i n a11 othar blob~sam mrffecteii9 Bit LM.

ACT IONS A htt has been pnw4Bcd to vrdifsl tk M T W S relrtad t o laservice leak and hydmstatit testflrg ogeratfm.

SectSon 1.3, Cwpletfon Thrtr, specifies a tondittol, has been entered, sub- dIvIs1oAs, wbsystems, caaponents, QT variables expressad in the Conditba discovered t o bc Inoperable e r Rot w i t h i n l i m i t s , w i l t nut result I n separate entry iate the Coaditioe. Section 1.3 also specifics t h a t Required k t i o a s o f tha Cmditim continue to apply for each additional failure, with Collplatfon T i m 5 b a r d on i n i t i d amtry Cnto the Condition.

However, the Requfmd Actloas fw cwA requireaert e f tbe LCO not met provide appropriate -*tory measures for kantinudl GRAND MLF B 3.10-3 Itcvirion h. 0 testing initiated in conjunction with an insewice

Bases Inserts (Applicable to Technical Specification Pages B 3.10-1 & B 3.10-3)

INSERT I or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 200°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 200°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.

INSERT 2 However, even with required minimum reactor coolant temperatures < 200"F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor steam dome pressure >

950 psig. The hydrostatic and/or RCS leakage tests require pressure of approximately 1,000 psig.

Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

INSERT 3 Additionally, even with required minimum reactor coolant temperatures < 200"F, RCS temperatures may drift above 200°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.