ML13157A029
| ML13157A029 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/05/2013 |
| From: | Wang A Plant Licensing Branch IV |
| To: | Entergy Operations |
| Wang A | |
| References | |
| TAC ME9910 | |
| Download: ML13157A029 (16) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 5, 2013 Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 -ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATIONS CHANGES RELATED TO ALLOWABLE VALUE FOR PRIMARY CONTAINMENT AND DRYWELL ISOLATION INSTRUMENTATION FUNCTION 3.c, "RCIC STEAM SUPPLY LINE PRESSURE - LOW" (TAC NO. ME9910)
Dear Sir or Madam:
The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 194 to Facility Operating License No. NPF-29 for the Grand Gulf Nuclear Station, Unit 1. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 9,2012, as supplemented by letter dated January 30,2013.
The amendment will increase the Allowable Value (AV) for Function 3.c, "RCIC [Reactor Core Isolation Cooling} Steam Supply Line Pressure - Low," in TS Table 3.3.6.1-1, "Primary Containment and Drywell Isolation Instrumentation," from greater than or equal to 53 pounds per square inch gauge (psig) to greater than or equal to 57 psig. No modification was required for the TS for the nominal trip setpoint (NTSP) for Function 3, "RCIC System Isolation in Technical Requirements Manual," in Table 3.3.6.1-1, "Technical Specification Isolation Instrumentation Trip Setpoints and Response Times." The enclosed safety evaluation is not applicable for a 24-month fuel cycle.
- 2 A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
~\J Alan Wang, prOj~er Plant Licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosures:
- 1. Amendment No. 194 to NPF-29
- 2. Safety Evaluation cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY OPERATIONS, INC.
SYSTEM ENERGY RESOURCES, INC.
SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION ENTERGY MISSISSIPPI, INC.
DOCKET NO. 50-416 GRAND GULF NUCLEAR STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 194 License No. NPF-29
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Entergy Operations, Inc. (the licensee), dated November 9, 2012, as supplemented by letter dated January 30, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-29 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 194 are hereby incorporated in the license. Entergy Operations. Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License No. NPF-29 and the Technical Specifications Date of Issuance: August 5, 2013
ATTACHMENT TO LICENSE AMENDMENT NO. 194 FACILITY OPERATING LICENSE NO. NPF-29 DOCKET NO. 50-416 Replace the following pages of the Facility Operating License No. NPF-29 and the Appendix A, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Facility Operating License Remove
-4 Technical Specifications Remove 3.3-56 3.3-56
(b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as of the above authorized financial transactions, (ii) the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment NO. 54.
In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.
C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 4408 megawatts thermal (100 percent power) in accordance with the conditions specified herein.
(2) Teclmical Speci;ications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 194 are hereby incorporated into this license. Entergy Operations, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1 1) will be disabled and operated in an "indicate only" mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function; no further operating with this function in an "indicate only" mode will be conducted.
4 Amendment No. 194
Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 5 Primary Containment and Drywell Isolation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS RE~UIRED SUR VEILLANCE ALLOWABLE FUNCTION CONDITIONS PER TRIP ACT ON C.! REQUIREMENTS VALUE SYSTEM
- 3. Reactor Core Isolation Cooling (RCIC) System Isolation
- a. RCIC Steam Line 1,2,3 F SR 3.3.6.1.1 ::;64 inches Flow-High SR 3.3.6.1.2 water SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7
- b. RCIC Steam Line Flow 1,2,3 F SR 3.3.6.1.2 ~ 3 seconds and Time Delay SR 3.3.6.1.4 ::; 7 seconds SR 3.3.6.1.7
- c. RCIC Steam Supply 1,2(dl,3(d) F SR 3.3.6.1.1 ~ 57 psig Line Pressure Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7
- d. RCIC Turbine Exhaust 1,2,3 2 F SR 3.3.6.1.1 ::;20 psig Dimhragm Pressure SR 3.3.6.1.2
- igh SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7
- e. RCIC Equipment Room 1,2,3 F SR 3.3.6.1.1 ::;191°F Ambient SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.7
- f. Main Steam Line 1,2,3 F SR 3.3.6.1.1 ::; 191 0 F Tunnel Ambient SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.7
- g. Main Steam Line 1,2,3 F SR 3.3.6.1.2 ::; 30 minutes Tunnel Temperature SR 3.3.6.1.4 Timer SR 3.3.6.1.7
- h. RHR Equipment Room 1,2,3 I per room F SR 3.3.6.1.1 ::; 171°F Ambient SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.5 SR 3.3.6.1.7
- i. RCICIRHR Steam Line 1,2,3 F SR 3.3.6.1.1 ::;43 inches Flow-High SR 3.3.6.1.2 water SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 (continued)
(d) Not required to be OPERABLE in MODE 2 or 3 with reactor steam dome pressure less than 150 psig during reactor startup.
GRAND GULF 3.3-56 Amendment No. +W,~ 194
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BYTHE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 194 TO FACILITY OPERATING LICENSE NO. NPF-29 ENTERGY OPERATIONS, INC., ET AL.
GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416
1.0 INTRODUCTION
By letter dated November 9, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12318A119), as supplemented by letter dated January 30,2013 (ADAMS Accession No. ML13031A352), Entergy Operations, Inc. (Entergy, the licensee),
submitted a license amendment request (LAR) for Grand Gulf Nuclear Station (GGNS), Unit 1.
The proposed change will revise the Technical Specifications (TSs) related to the Allowable Value (A V) for Function 3.c, "RCIC [Reactor Core Isolation Cooling] Steam Supply Line Pressure - Low," in TS Table 3.3.6.1-1, "Primary Containment and Dryweilisolation Instrumentation." Specifically, the proposed TS change will increase the AV for Function 3.c from greater than or equal to (~) 53 pounds per square inch gauge (psig) to ~ 57 psig.
The supplemental letter dated January 30,2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register (FR) on February 5, 2013 (78 FR 8200).
2.0 REGULATORY EVALUATION
The NRC staff considered the following regulatory items.
2.1 Regulatory Reguirements The regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," establish the fundamental regulatory requirements. Specifically, Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, provides criteria for the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components (SSCs) important to safety.
Enclosure 2
- 2 Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of SSCs that are required to protect the health and safety of the public. The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR Section 50.36, "Technical specifications," which requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings (LSSS), and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in TSs.
The regulations in 10 CFR 50.36(c)(3), "Surveillance requirements," state that Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
General Design Criterion (GDC) 13, "Instrumentation and control," of Appendix A to 10 CFR Part 50 requires, in part, that instrumentation be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.
GDC 20, "Protection system functions," of Appendix A to 10 CFR Part 50 requires, in part, that the protection system be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.
The NRC staff reviewed the proposed TS changes against these requirements to ensure reasonable assurance that the systems affected by the proposed TS changes will perform their required safety functions.
2.2 Regulatory Guidance NRC Regulatory Guide (RG) 1.105, Revision 3, "Setpoints for Safety-Related Instrumentation,"
December 1999 (ADAMS Accession No. ML993560062), describes a method that the NRC staff considers acceptable for complying with the agency's regulations for ensuring that setpoints for safety-related instrumentation are initially within and remain within the TS limits. In particular, RG 1.105 states that ill order to meet the referenced regulatory requirements, instrument setpoints should account for uncertainty allowances (e.g., a region of calibration tolerance).
such that at the end of a surveillance interval (i.e., when drift is considered) instrument readings will still be within the limiting conditions of operation specified in the TSs (i.e., the allowable value). RG 1.105 established that the trip setpoint and the allowable values are met at the 95/95 confidence level.
-3 RG 1.105 endorses Part I of Instrument Society of America (ISA) Standard 67.04-1994, "Setpoints for Nuclear Safety-Related Instrumentation," subject to NRC staff clarifications. The staff used this guide to evaluate the licensee's setpoint calculation methodologies and the related plant surveillance procedures.
In Regulatory Issue Summary (RIS) 2006-17, "NRC Staff Position on the Requirements of 10 CFR 50.36, 'Technical Specifications,' regarding Limiting Safety System Settings during Periodic Testing and Calibration of Instrument Channels," dated August 24,2006 (ADAMS Accession No. ML051810077), the NRC addresses requirements on LSSS that are assessed during the periodic testing and calibration of instrumentation. RIS 2006-17 discusses issues regarding the testing of LSSS and that could have an adverse effect on equipment operability, and presents an approach to resolves these issues acceptable to the NRC staff.
RIS 2006-17 states, in part, that:
As one measure of instrument operability, the NRC staff expects licensees to verify during testing or calibration that the change in the measured TSP [trip setpoint] since the last test or calibration is within predefined limits (double-sided acceptance criteria band) and to take appropriate actions if the change is outside these limits. The acceptance criteria band should be derived from the licensee>
- Power supply (PS) variation of +/-0.005 percent span (3a),
- Overpressure (OVP) effect of +/-3 percent upper range limit (URL) (3a)
- Device drift (DR) +/-1.34 percent span for 30 months (3a)
- Seismic +/-0.25 percent URL (3a)
Trip Unit Vendor Data:
- Repeatability +/-0.25 percent span (3a)
The licensee calculated the As-Found Tolerance (AFT) as SRSS of RA, MTE, and DR.
Then the licensee calculated the LU as SRSS of RA, TE, PS, SE, and OVP and then adding the process measurement (PM) uncertainty as a bias term. The licensee used a reduction factor of 1.645/2 in calculating LU because the setpoint is approached in one direction only. With this revised value of LU the licensee arrived at an AV of ~ 56.21 psig and revised the AV in TS as ~ 57 pSig. By letter dated November 6, 1995, titled "Revision to Safety Evaluation Report on NEDC-31336, Instrument Setpoint Methodology (NEDC-31336P)" (ADAMS Legacy Accession No. 9511140068), the NRC approved this factor (Le., 1.645/2) in calculating total loop uncertainty.
-6 The licensee calculated the TLU as a summation of the LU and DR. With the revised value of TLU, the licensee calculated the NTSP to be 56.73 psig which is conservative for the specified setpoint of 60 psig in the calibration procedure. This conservative NTSP value ensures compliance to GDC 13 and GDC 20 and is, therefore, acceptable.
By letter dated January 30, 2013, in response to the NRC staff's request for additional information, the licensee provided vendor's documents supporting +/-3O' probability distribution for the transmitter and trip unit tolerances which comply with the 95/95 (20') confidence level specified in RG 1.105. The licensee also stated that TE, OVP, Static Pressure Effect, and Power Supply Effects tolerances were tested to verify compliance to satisfy +/-3O' probability distribution.
TSTF-493 specifies the procedural criteria that should be addressed for each of the functions covered by the TSTF owner's group letter dated April 23, 2012 (ADAMS Accession No. ML101160026), regardless of whether or not the channel is an LSSS. To demonstrate compliance with TSTF-493, in its letter dated January 30,2013, the licensee also provided Calculation JC-Q1111-09019, "Drift Calculation for Rosemount Range Codes 5-8 Gage Pressure Transmitters," which provided a statistical analysis of the plant drift data for this function. In this calculation, the licensee determined the drift values for the subject instrumentation by analysis of the historical AFT and ALT data. This data was drawn from calibration records for approximately 12 years currently calibrated on an 18-month basis and extrapolating the drift parameter for a maximum of 30 months including 25 percent allowance over a 24-month nominal calibration. The drift for a given device was determined by subtracting the previous as-left setting from the more recent as-found setting.
In October 1998, EPRI issued Revision 1 to technical report TR-1 03335, "Guidelines for Instrument Calibration Extension 1 Reduction-Revision 1, Statistical Analysis of Instrument Calibration Data." This EPRI report includes commonly used statistical methods and procedures for data, outlier, and time-dependency analyses as they are applied to setpoint and calibration problems. Described in this EPRI report is a "t-Test" to detect outliers. As a result of this "t-Test" the licensee identified two outliers. However, only one of these outliers was excluded as the licensee also uses other criteria to determine if outliers could be removed from the data set. Basic statistical values including Mean, Standard Deviation, Count, Median, Minimum, and Maximum were derived in the calculation. The licensee performed normality tests using a Coverage Analysis because from D-Prime test the licensee was unable to support normality analysis. Then, the licensee performed the time dependency test and did not find noticeable time dependency and hence used moderate time dependency for 30-months drift calculation resulting in a drift of +/-1.346 percent span for the function affected by the LAR. The mathematical computation of the statistical analysis was performed with an Excel spreadsheet.
The licensee plotted the drift data which shows that the actual percentage of drift population within the +/-2O' distribution to be slightly above normal distribution confirming that the drift conforms to 95/95 confidence level specified in RG 1.105. This drift evaluation was based on field data, which is generally more reliable than vendor-provided data often used in drift determination.
The NRC staff reviewed this drift evaluation and concludes that the drift values used in this calculation meet the 95/95 confidence level specified in RG 1.105. The NRC staff also
-7 concludes that this drift information complies with the TSTF-493, which includes procedural criteria regarding exceeded limits when a channel cannot be set within ALT limit.
As noted earlier the recent revision of Calculation JC-Q1 E31-N685-1 "RCIC Turbine Isolation on Low Inlet Steam Pressure" updated the methodology and assumptions used in the above calculation. The NRC staff has reviewed this calculation revision and concludes that:
- 1. The licensee found that the revision of the calculation did not result in a change to the NTSP value. The current setpoint of 60 pSig as delineated in Function 3.
of RCIC System Isolation in TRM Table 3.3.6.1-1, "Technical Specification Isolation Instrumentation Trip Setpoints and Response Times," remains conservative with a calculated setpoint of 56.73 psig, and
- 2. This revision resulted in a new calculated AV value of - 56.21 psig versus the current allowable value of - 53 psig.
Based on the above, the NRC staff concludes that the NTSP did not change; therefore, the system remains capable of performing its specified safety function in accordance with applicable design requirements and associated analyses. The NRC staff also concludes that the new AV of 57 pSig assures that the instrument loops will isolate the RCIC Turbine on low inlet steam pressure to protect the turbine and is conservative. The NRC staff concludes that the above evaluations ensure that the plant procedures comply with TSTF-493 requirements and hence, comply with RIS 2006-17 recommendations, and, therefore, the proposed TS change is acceptable.
In addition the NRC staff notes the following regarding this LAR approval:
- 1. TSTF-493, Revision 4, identifies those functions that are LSSS and need to be annotated with TSTF-493 Footnotes. However, TS Table 3.3.6.1-1, "Primary Containment and Drywell Isolation Instrumentation," Function 3.c, "RCIC Steam Supply Line Pressure - Low," is not listed in the TSTF list. Since this function is not an LSSS, no change to the TS is required with respect to the TSTF-493 Footnotes.
- 2. The licensee calculated the drift for a 24-month fuel cycle even though the currently applicable surveillance requirement for calibration of the channels affected by this LAR is for 18 months. In the LAR, the licensee did not request a 24-month fuel cycle extension. However, the NRC staff concludes that the use of the 24-month drift value is conservative for the calculation of the TLU and hence is acceptable for this particular LAR.
4.0 STATE CONSULTATION
In accord 9 nce with the Commission's regulations, the Mississippi State official was notified of the proposed issuance of the amendment. The State official had no comments.
- 8
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on February 5,2013 (78 FR 8200). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c )(9).
Pursuant to 10 CFR 51.22{b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: S. Mazumdar N. Carte Date: August 5, 2013
ML13157A029 OFFICE INRRlDORLlLPL4/PM NRRlDORLlLPL4/PM J\lRRlDORLlLPL4/L~E/E1CB/BC NAME MBartlett AWang MBarlett for JBurkhardt JThorp*
iDATE 06/18/13 06/19/13 6117113 5/22/13
!OFFICE NRRlDSS/STSB/BC OGC-NLO l'NRRIDORLlLPL4/BC NRRlDORLlLPL4/PM NAME RElliott BMizuno MMarkley AWang DATE 6/19/13 7/17/13 8/5/13 8/5/13