ML13260A006

Email, Request for Additional Information, Round 3, Request to Revise Technical Specifications and Surveillance Requirements to Support Operation with a 24-Month Fuel Cycle in Accordance with Generic Letter 91-04

ML13260A006
Person / Time
Site:	Grand Gulf
Issue date:	09/16/2013
From:	Wang A Plant Licensing Branch IV
To:	Robinson C Entergy Operations
Wang A
References
GL-91-004, TAC ME9764
Download: ML13260A006 (2)

Text

Burkhardt, Janet From: Wang, Alan Sent: Monday, September 16, 2013 4:38 PM To: Robinson, Christopher Cc: Burkhardt, Janet

Subject:

Grand Gulf Nuclear Station Request for Additional Information Regarding 18 to 24 Month License Amendment Request (TAC ME9764)

Jeff and Chris, By letter dated October 2, 2012 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12277A080), as supplemented by letter dated August 15th, 2013, Entergy Operations, Inc.

(the licensee) submitted a license amendment request (LAR) to amend the technical specifications (TS) of Grand Gulf Nuclear Station (GNNS), Unit 1. The LAR proposes to extend certain 18-month TS surveillance requirement (SR) frequency to 24-months SR frequency to accommodate a 24-month fuel cycle.

The NRC staff has determined that additional information is needed to complete our review of this request. The following request for additional information (RAIs) are related to your letter dated August 15th, 2013:

1. In response to the RAI number 2a, you stated the lack of failures in any other battery charger indicated that this was not a generically repetitive or common mode failure. Additionally, you stated the fact that no other charger exhibited similar failures indicated that there was no time-based failure mechanism.

Please confirm whether the battery charger 1A4 is tracked under the maintenance rule program. Discuss the corrective actions taken to prevent the failure of the battery charger 1A4 current limit amperes or minimize the probability of occurrence of that failure.

2. In response to the RAI number 3a you stated: The reference to SR 3.8.4.3 was a typographical error.

The intent of the statement was to perform the SR 3.8.4.8 performance discharge test, or a modified performance discharge test at the 30 month interval rather than the service test at the 18-month interval.

The NRC staff notes that the licensee did not request a change to the frequency of SR 3.8.4.8 and the statement in Attachment 5, Section 3.8.4 of the LAR is related to the licensees commitments to RG 1.32, RG 1.129, and IEEE-450 that recommend the battery service test (SR 3.8.4.7) to be performed during refueling operations or at some other outage with intervals between tests not to exceed 18 months.

a. Confirm that the correct SR in the statement is SR 3.8.4.7 and provide the complete regulatory commitment statement with the correct reference.

b. Update the TS bases to reflect that the change to 24 months is made in accordance with the GL 91-04 and is approved in the safety evaluation that will be issued.

3. In response to the RAI number 4a you stated: The 25% grace period and the 1.25 times interval in SR 3.0.2 refer to the same time interval, and allow for a margin for surveillance performance when required by plant operating conditions. This margin allows the plant to optimize fuel use during reactor coast 1

down, and gives the plant the option to not shutdown the reactor to complete surveillance within the defined frequency when the mode requirement is 3, 4 or 5.

Clarify how Entergy will perform the SRs for mode requirements 3, 4, and 5, 1) after the refueling/outage period when SR 3.0.2 applies to these SRs and 2) after the 30 month-extended period if these SRs are missed.

These RAIs were discussed with Mr. Christopher Robinson on September 16, 2013, and it was agreed that a response would be provided within 30 days of receipt of this email. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1445 or via e-mail at Alan.Wang@nrc.gov.

Alan Wang Project Manager (Grand Gulf Nuclear Station)

Nuclear Regulatory Commission Division of Operating Reactor Licensing Alan.Wang@NRC.gov Tel: (301) 415-1445 Fax: (301) 415-1222 2