GNRO-2011/00004, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation

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License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation
ML110960351
Person / Time
Site: Grand Gulf 
Issue date: 04/06/2011
From: Mike Perito
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2011/00004
Download: ML110960351 (24)
v • d • e


Text

Entergy Operations, Inc.

P. O. Box 756 Port MS 39150 Michael Perito Vice President. Operations Grand Gulf Nuclear Station Tel. (601) 437-6409 GNRO-2011/00004 April 6, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

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. is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS).

The proposed amendment would revise the TS to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; make a minor editorial change to correct a formatting issue to be consistent with the writer's guide and the BWR6 TS format and does not affect the intent of the TSTF or the NRC SE; and make TS Bases changes which reflect the proposed changes and more accurately reflect the contents of the facility design basis related to operability of the RCS leakage detection instrumentation.

These changes are consistent with NRC-approved Revision 3 to TSTF Improved Standard Technical Specification (STS) Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation."

The availability of this TS improvement was announced in the Federal Register on December 17, 2010 (75 FR 79048) as part of the consolidated line item improvement process (CLlIP).

  • provides an evaluation of the proposed changes.
  • provides the markup pages of existing TS to show the proposed changes.
  • provides the markup pages of the existing TS Bases to show the proposed changes.
  • provides revised (clean) TS pages.

GNRO-2011/00004 Page 2 of 3 Entergy Operations, Inc. requests approval of the proposed license amendment by April 6, 2012, with the amendment being implemented within 90 days.

In accordance with 10 CFR 50.91 (a)(1), "Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.

In accordance with 10 CFR 50.91 (b)(1), "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Mississippi Official.

This letter contains no new commitments.

If you have any questions or require additional information, please contact Christina Perino at 601-437-6299.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 6, 2011.

Sincerely, MP/DM Attachments:

1.

Evaluation of Proposed Changes 2.

Proposed Technical Specification Changes (Mark-up) 3.

Proposed Technical Specification Bases Changes (Mark-up) 4.

Revised Technical Specification Changes (Clean Copy)

GNRO-2011/00004 Page 3 of 3 cc:

U. S. Nuclear Regulatory Commission AnN: Mr. A. Wang, NRR/DORL (w/2)

Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 Mr. Elmo E. Collins, Jr. (w/2)

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 State Health Officer Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700 GNRO-2011/00004 Evaluation of Proposed Changes to GNRO-2011/00004 Page 1 of 4 ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES License Amendment Request for Adoption of TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation"

1.0 DESCRIPTION

The proposed amendment would revise the Technical Specifications (TS) to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable and make conforming TS Bases changes. These changes are per Standard Technical Specification (STS) Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on December 17,2010 (75 FR 79048) as part of the consolidated line item improvement process (CUIP).

2.0 PROPOSED CHANGE

S The proposed changes revise and add a new Condition D to TS 3.4.7, "RCS Leakage Detection Instrumentation," and revise the associated bases. New Condition D is applicable when the drywell atmospheric gaseous radiation monitor is the only operable TS-required instrument monitoring RCS leakage, Le., TS-required particulate, sump, and drywell air cooler condensate flow monitors are inoperable. New Condition D Required Actions require monitoring RCS leakage by obtaining and analyzing grab samples of the drywell atmosphere every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; monitoring RCS leakage using administrative means every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; and taking action to restore monitoring capability using another monitor within 7 days.

Additionally, the TS Bases, which summarizes the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in Limiting Condition for Operation (LCO) Bases, delete discussion from the TS Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS 3.4.7.

Entergy Operations, Inc. is not proposing variations or deviations from the TS changes described in TSTF-514, Revision 3, or the NRC staff's model safety evaluation (SE) published in the Federal Register on December 17,2010 (75 FR 79048) as part of the CUIP Notice of Availability.

3.0 BACKGROUND

NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity,"

dated August 3, 2005, informed addressees that the reactor coolant activity assumptions for primary containment atmosphere gaseous radioactivity monitors may be non-conservative. This means the monitors may not be able to detect a one gallon per minute leak within one hour.

Some licensees, in response to IN 2005-24, have taken action to remove the gaseous radioactivity monitor from the TS list of required monitors. However, industry experience has to GNRO-2011/00004 Page 2 of 4 shown that the primary containment atmospheric gaseous radiation monitor is often the first monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRC staff met on April 29, 2008, and April 14, 2009, to develop an alternative approach to address the issue identified in IN 2005-24. The agreed solution is to retain the primary containment atmospheric gaseous radiation monitor in the LCO list of required equipment, revise the specified safety function of the gas monitor to specify the required instrument sensitivity level, to revise the Actions requiring additional monitoring, and provide less time before a plant shutdown is required when the primary containment atmospheric gaseous radiation monitor is the only operable monitor.

4.0 TECHNICAL ANALYSIS

Entergy Operations, Inc. has reviewed TSTF-514, Revision 3, and the model SE published on December 17, 2010 (75 FR 79048) as part of the CLiIP Notice of Availability. Entergy Operations, Inc. has concluded that the technical bases presented in TSTF Traveler-514, Revision 3, and the model SE prepared by the NRC staff are applicable to Grand Gulf Nuclear Station, Unit 1 (GGNS).

As described in Section 3.1.2.4.1 of the GGNS Updated Final Safety Analysis Report (UFSAR)

(Reference 1), the reactor coolant pressure boundary and the leak detection system are designed to meet the requirements of General Design Criterion (GDC) 30, Quality of Reactor Coolant Pressure Boundary." GGNS UFSAR Section 5.2.5.2 provides a description of the leakage detection devices associated with the reactor coolant pressure boundary.

In Appendix 3A of the GGNS UFSAR (Reference 1), GGNS reflects conformance with Revision 0 of Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," with the exception of Regulatory Positions 1.a and 6. GGNS UFSAR Section 7.6.2.4.2.1, "Conformance to Regulatory Guides" provides additional discussion related to conformance with RG 1.45.

The administrative means of monitoring include diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. GGNS will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: drywell pressure, drywell temperature, component cooling water system outlet temperatures, component cooling water system makeup, reactor recirculation system pump seal pressure and temperature, reactor circulation system pump motor cooler temperatures, drywell cooling fan outlet temperatures, control rod drive system flange temperatures, and / or safety relief valve tailpipe temperature.

There are diverse alternative methods for determining that RCS leakage has not increased, from which appropriate indicators may be selected based on plant conditions. GGNS will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: drywell pressure, drywell temperature, component cooling water system outlet temperatures, component cooling water system makeup, reactor recirculation system pump seal pressure and temperature, reactor recirculation system pump motor cooler temperatures, drywell cooling fan outlet temperatures, control rod drive system flange temperatures, and / or safety relief valve tailpipe temperature. Actions to verify that these indications have not increased since the required monitors became inoperable and analyze to GNRO-2011/00004 Page 3 of 4 drywell atmospheric grab samples are sufficient to alert the operating staff to an unexpected increase in RCS leakage.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Entergy Operations, Inc. (Entergy) has evaluated the proposed changes to the GGNS Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

Description of Amendment Request: The proposed amendment would revise TS 3.4.7, RCS Leakage Detection Instrumentation," Conditions and Required Actions and the licensing basis for the drywell atmospheric gaseous radiation monitor, as well as make associated TS Bases changes for TS 3.4.7.

Basis for proposed no significant hazards consideration determinations: As required by 10 CFR 50.91 (a), the Entergy analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the drywell atmospheric gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, it is concluded that this change does not involve a significant increase in the probability of consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the drywell atmospheric gaseous radiation monitor. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

to GNRO-2011/00004 Page 4 of 4 3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the drywell atmospheric gaseous radiation monitor. Reducing the amount of time the plant is allowed to operate with only the drywell atmospheric gaseous radiation monitor operable increase the margin of safety by increasing the likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure. Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on December 17, 2010 (75 FR 79048). Entergy has reviewed the NRC staff's model SE reference in the CUIP Notice of Availability and concluded that the regulatory evaluation section is applicable to GGNS.

6.0 ENVIRONMENTAL CONSIDERATION

S The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1.

Grand Gulf Nuclear Station Updated Final Safety Analysis Report GNRO-2011/00004 Proposed Technical Specification Changes (Mark-up) to GNRO-2011/00004 Page 1 of 2 Res Leakage Detection Instrumentation 3.4.7 ACTIONS C.

CONDITION Drywell air cooler condensate flow rate monitoring system inoperable.

Required drywell atmospheric monitoring system inoperable.

Drywell air cooler condensate flow rate monitoring system inoperable.

Required Action and associated Completion Time of Condition A, B, C, not met.

All required leakage detection systems inoperable.

REQUIRED ACTION

NOTE---------------

Not applicable when the required drywell atmospheric monitoring system is inoperable.

C.1 Perform SR 3.4.7.1.

Restore required drywell atmospheric monitoring system to OPERABLE status.

Restore drywell air cooler condensate flow rate monitoring system to OPERABLE status.

e in MODE 3.

Enter LCO 3.0.3.

COMPLETION TIME Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 30 days 30 days 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours Immediately GRAND GULF 3.4-17 Amendment No.~,

to GNRO-2011100004 Page 2 of 2 Insert 1 Orywell floor drain sump monitoring system AND inoperable.

0.1 Analyze grab samples of the Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> drywell atmosphere.

0.3.1 Restore drywell floor drain 7 days sump monitoring system to OPERABLE status.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 0.3.2 Restore drywell air cooler 7 days condensate flow rate monitoring system to OPERABLE status.

0.2 Monitor ReS Leakage by administrative means.

Orywell air cooler condensate flow rate monitoring system inoperable.

NOTE---------------

Only applicable when the drywell atmospheric gaseous monitoring system is the only OPERABLE monitor.

GNRO-2011/00004 Proposed Technical Specification Bases Changes (Mark-up) to GNRO-2011/00004 Page 1 of 10 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.7 RCS Leakage Detection Instrumentation RCS Leakage Detection Instrumentation B 3.4.7 BASES BACKGROUND

///

GDC 30 of 10 C~R50, Appendix A (Ref. 1), requires means for detecting and, j6the extent practical, identifying the location of t~/sourceof RCS LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Limits on LEAKAGE from the reactor coolant pressure boundary (RCPB) are required so that appropriate action can be taken efore the integrity of the RCPB is impaired (Ref. 2).

e detection systems for the RCS are provided to alert the oper hen leakage rates above normal background levels are detect d also to supply quantitative measurement of rat

. The Bases for LCO 3.4.5, "RCS Operational LEAKAGE," discuss the limits on RCS LEAKAGE rates.

Systems for separating the LEAKAGE of an identified source from an unidentified source are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action.

LEAKAGE from the RCPB inside the drywell is detected by at least one of three independently monitored variables, such as sump level changes and drywell gaseous and particulate radioactivity levels. The primary means of quantifying LEAKAGE in the drywell is the drywell floor drain sump monitoring system.

The drywell floor drain sump monitoring system monitors the LEAKAGE collected in the floor drain sump. This unidentified LEAKAGE consists of LEAKAGE from control rod drives, valve flanges or packings, floor drains, the Closed Cooling Water System, and drywell air cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump.

GRAND GULF B 3.4-1 LDC 99088 to GNRO-2011/00004 Page 2 of 10 BASES BACKGROUND (continued)

RCS Leakage Detection Instrumentation B 3.4.7 The Drywell floor drain in-leakage is monitored by the P45 floor drain sump level transmitters and associated instrumentation. The leakage and change in leakage can be determined by monitoring the associated computer point or recorders which calculate leakage based on the level rate of change.

(continued)

GRAND GULF B 3.4-32a LDC 07044 to GNRO-2011/00004 Page 3 of 10 BASES BACKGROUND (continued)

APPLICABLE SAFETY ANALYSES RCS Leakage Detection Instrumentation B 3.4.7 The drywell atmospheric monitoring systems continuously monitor the drywell atmosphere for airborne particulate and gaseous radioactivity. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water LEAKAGE, is annunciated in the control room.

Condensate from four of the six drywell coolers is routed to the drywell floor drain sump and is monitored by a flow transmitter that provides indication and alarms in the control room. This drywell air cooler condensate flow rate monitoring system serves as an added indicator, but not quantifier, of RCS unidentified LEAKAGE.

A threat of significant compromise to the RCPB exists if the barrier contains a crack that is large enough to propagate rapidly. LEAKAGE rate limits are set low enough to detect LEAKAGE emitted from a single crack in the RCPB (Refs. 4 e).

~aE1fT~Hf*:HeC:l*~~1B1e6OOi~~FAS~~4~~l1Ae Identification of the LEAKAGE allows the operators to evaluate the significance of the indicated LEAKAGE and, if necessary, shut down the reactor for further investigation and corrective action. The allowed LEAKAGE rates are w below the rates predicted for critical crack sizes (Ref. S).

Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

GRAND GULF B 3.4-33 LDC 99088 to GNRO-2011/00004 Page 4 of 10 BASES APPLICABLE SAFETY ANALYSES (continued)

LCO APPLICABILITY ACTIONS RCS Leakage Detection Instrumentation B 3.4.7 RCS leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement.

In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.5. This Applicability is consistent with that for LCO 3.4.5.

With the drywell floor drain sump monitoring system inoperable, no other form of sampling can provide the equivalent information to quantify leakage. However, the drywell atmospheric activity monitor and the drywell air cooler condensate flow rate monitor will provide indications of changes in leakage.

With the drywell floor drain sump monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (SR 3.4.5.1), operation may continue for 30 days. Manual methods, using approved M&TE, can be used to monitor sump fill times and leakage and change in leakage during the 30 day allowed outage time for GRAND GULF B 3.4-34 LDC 07028 to GNRO-2011/00004 Page 5 of 10 BASES ACTIONS RCS Leakage Detection Instrumentation B 3.4.7 A.1 (continued) the drywell floor drain sump monitoring system to ensure compliance with SR 3.4.5.1. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available.

GRAND GULF B 3.4-34a LDC 01041 to GNRO-2011/00004 Page 6 of 10 BASES ACTIONS B.1 (continued)

RCS Leakage Detection Instrumentation B 3.4.7 With both gaseous and particulate drywell atmospheric monitoring channels inoperable, grab samples of the drywell atmosphere shall be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and analyzed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the plant may continue operation since at least one other form of drywell leakage detection (i.e., air cooler condensate flow rate monitor) is available. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval provides periodic information that is adequate to detect LEAKAGE.

With the required drywell air cooler condensate flow rate monitoring system inoperable, SR 3.4.7.1 is performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to provide periodic information of activity in the drywell at a more frequent interval than the routine Frequency of SR 3.4.7.1. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval provides periodic information that is adequate to detect LEAKAGE and recognizes that other forms of leakage detection are available. However, this Required Action is modified by a Note that allows this action to be not applicable if the required drywell atmospheric monitoring system is inoperable. Consistent with SR 3.0.1, Surveillances are not required to be performed on inoperable equipment.

With both the gaseous and particulate drywell atmospheric monitor channels and the drywell air cooler condensate flow rate monitor inoperable, the only means of detecting LEAKAGE is the drywell floor drain sump monitoring system. This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable monitoring systems to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

GRAND GULF B 3.4-35 LDC 99050 to GNRO-2011/00004 Page 7 of 10 BASES RCS Leakage Detection Instrumentation B 3.4.7 ACTIONS (continued)

If any Required Action of Condition A, B, C, cannot be met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions in an orderly manner and without challenging plant systems.

With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires the performance of a CHANNEL CHECK of the required drywell atmospheric monitoring system. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.7.2 This SR requires the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation.

The test ensures that the monitors can perform their function in the desired manner. The test also verifies the relative accuracy of the instrumentation. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

GRAND GULF B 3.4-36 LDC 99050 to GNRO-2011/00004 Page 8 of 10 BASES SURVEILLANCE REQUIREMENTS (continued)

RCS Leakage Detection Instrumentation B 3.4.7 SR 3.4.7.3 This SR requires the performance of a CHANNEL CALIBRATION of the required RCS leakage detection instrumentation channels.

The calibration verifies the accuracy of the instrumentation, including the instruments located inside the drywell. The Frequency of 18 months is a typical refueling cycle and considers channel reliability.

Operating experience has proven this Frequency is acceptable.

2.

Regulatory Guide 1 REFERENCES 1.

10 CFR 50, Appendix 4':"

GEAP-5620, "Failure Behavior in ASTM A106B Pipes Containing Axial Through - Wall Flaws," April 1968.

NUREG-75/067, "Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactor Plants," October 1975.

UFSAR, Section 5.2.5.5.3.

GRAND GULF B 3.4-37 Revision No. 0 to GNRO-2011/00004 Page 9 of 10 Bases Insert 1 This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires three instruments to be OPERABLE.

The drywell floor drain sump monitoring system is required to quantify the unidentified LEAKAGE rate from the RCS. Thus, for the system to be considered OPERABLE, the sump level monitoring portion of the system must be OPERABLE and capable of determining the leakage rate. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the drywell floor drain sump and it may take longer than one hour to detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the drywell, can be detected by the gaseous or particulate drywell atmospheric radioactivity monitor. Only one of the two detectors is required to be OPERABLE. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid response to RCS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. If there are few fuel element cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate drywell atmospheric radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation.

However, the gaseous or particulate drywell atmospheric radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the monitors (Reference 6).

This LCO is satisfied when monitors of diverse measurement means are available. Thus, the drywell floor drain sump monitoring system, in combination with a gaseous or particulate drywell atmospheric radioactivity monitor and a drywell air cooler condensate flow rate monitoring system, provides an acceptable minimum.

to GNRO-2011/00004 Page 10 of 10 Bases Insert 2 D.1, D.2, D.3.1 and D.3.2 With the drywell floor drain sump monitoring system and the drywell air cooler condensate flow rate monitoring system inoperable, the only means of detecting LEAKAGE is the drywell atmospheric gaseous radiation monitor. A Note clarifies this applicability of the Condition. The drywell atmospheric gaseous radiation monitor typically cannot detect a 1 gpm leak within one hour when RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the drywell atmosphere must be taken and analyzed and monitoring of the RCS leakage by administrative means must be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to provide alternate periodic information.

Administrative means of monitoring RCS leakage include monitoring and trending parameters that may indicate an increase in RCS leakage. There are diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. It is not necessary to utilize all of these methods, but a method or methods should be selected considering the current plant conditions and historical or expected sources of unidentified leakage. The administrative methods are drywell pressure and temperature, Component Cooling Water System outlet temperatures and makeup, Reactor Recirculation System pump seal motor cooler temperature indication, Drywell cooling fan outlet temperatures, Control Rod Drive System flange temperatures, and Safety Relief Valves tailpipe temperature. These indications, coupled with the atmospheric grab samples, are sufficient to alert the operating staff to an unexpected increase in unidentified LEAKAGE.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

GNRO-2011/00004 Revised Technical Specification Changes (Clean Copy) to GNRO-2011/00004 Page 1 of 1 ACTIONS (continued)

CONDITION C.

Drywell air cooler condensate flow rate monitoring system inoperable.

REQUIRED ACTION

- - - - - - - - NOTE - - - - - - -

Not applicable when the required drywell atmospheric monitoring system in inoperable.

Res Leakage Detection Instrumentation 3.4.7 COMPLETION TIME C.1 Perform SR 3.4.7.1.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

- - - - - - NOTE- - - - - - - -

Only applicable when the drywell atmospheric gaseous monitoring system is the only OPERABLE monitor.

0.1 Analyze grab samples of the drywell atmosphere.

0.2 Monitor RCS Leakage by administrative means.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> D.

Drywell floor drain sump monitoring system AND inoperable.

D.3.1 Restore drywell floor drain sump monitoring system to OPERABLE status.

7 days Drywell air cooler condensate flow rate monitoring system inoperable.

E.

Required drywell atmospheric monitoring system inoperable.

Drywell air cooler condensate flow rate monitoring system inoperable.

F.

Required Action and associated Completion Time of Condition A, B, C, 0, or E not met.

G.

All required leakage detection systems inoperable.

GRAND GULF 0.3.2 Restore drywell air cooler condensate flow rate monitoring system to OPERABLE status.

E.1 Restore required drywell atmospheric monitoring system to OPERABLE status.

OR E.2 Restore drywell air cooler condensate flow rate monitoring system to OPERABLE status.

F.1 Be in MODE 3.

AND F.2 Be in Mode 4.

G.1 Enter LCO 3.0.3.

3.4-17 7 days 30 days 30 days 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours Immediately Amendment No. ~,.:t42,

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