L-91-004, Supplement to the License Amendment Request for Implementing a 24 Month Fuel Cycle - Addendum
| ML13270A056 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/26/2013 |
| From: | Kevin Mulligan Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-91-004, GNRO-2013/00062 | |
| Download: ML13270A056 (14) | |
Text
-==~ Entergy Entergy Operations, Inc.
P.O. Box 756 Port Gibson, Mississippi 39150 Kevin J. Mulligan Site Vice President Grand GUlf Nuclear Station Tel: 601-437-7500 GNRO-2013/00062 September 26,2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Supplement to the License Amendment Request for Implementing a 24-Month Fuel Cycle - Addendum Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCES:
- 1. License Amendment Request for Implementing a 24-Month Fuel Cycle, dated October 2,2012 (Accession No. ML12277A080, GNRO-2012/00096)
- 2. NRC Generic Letter 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle,"
dated April 2, 1991
- 3. Supplement to the License Amendment Request for Implementing a 24-Month Fuel Cycle", dated April 26, 2013 (Accession No. ML13119A102, GNRO-2013/00023)
Dear Sir or Madam:
On October 2, 2012, Entergy Operations, Inc. (Entergy) submitted a license amendment request (LAR) (Reference 1) to the U.S. Nuclear Regulatory Commission (NRC) to implement a 24-month fuel cycle at Grand Gulf Nuclear Station (GGNS). The proposed changes were evaluated in accordance with guidance contained in NRC Generic Letter (GL) 91-04 (Reference 2).
Reference 3 supplemented the original LAR by requesting a change in the frequency of Technical Specification (TS) Surveillance Requirement (SR) 3.7.7.2 - "Main Turbine Bypass System" from 18 months to 24 months. This change is a non-calibration surveillance frequency change that was inadvertently omitted from the original LAR.
The purpose of this addendum is to augment the justification for extending the surveillance interval for TS 3.7.7.2 from 18 months to 24 months and make editorial corrections to the original 24 LAR that were identified during reviews of the original amendment request.
page page B is TS page 3.7-15 incorporating this change is included in Attachment 4.
Internal Entergy reviews of the original LAR since its initial submittal identified minor editorial errors needing correction. Those corrections are as follows and are also being included as part of this addendum.
- 1. Marked-up TS Page 3.3-78 included with the original LAR is correct as submitted.
However, the mark-ups were not transcribed onto the corresponding clean page correctly. The corrected clean copy TS 3.3-78 is included in Attachment 4.
A typographical error was identified in 3 page 18 B of the original LAR. The Bases for SR 3.3.6.1.8 should have been changed to SR 3.3.6.1 Page 3.3-170a reflects the correct SR notation as SR 3.3.6.1.9. A mark-up of the corresponding TS Bases page is included in Attachment The no significant hazards consideration statement and the regulatory that was submitted with the original LAR has been and continues to bound the changes being prOtpOlsed by this addenda to the LAR.
under penalty of perjury that the foregoing is true and correct; .... A ..... vU\,........ on September 3.
KJM/slw 1 .....rclpOlsea Change 2.
- 4. Proposed Technical Specification Changes next page)
Page 3 of 3 cc:
AnN: Mr. ,1'Oil/on Acting Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission AnN: Mr. Alan Wang, NRR/DORL (w/2)
Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
Attachment 1 to GNRO-2013/00062 Generic Letter 91-04 Evaluation and Review of Proposed Change to GNRO-2013/00062 Page 1 of 2 DETAILED DESCRIPTION OF CHANGE Proposed Change Transitioning to 24 month fuel cycles at Grand Gulf Nuclear Station (GGNS) requires that certain surveillance requirements (SRs) that are currently performed on 18 month frequencies be performed every 24 months.
The following SR frequency was inadvertently omitted from the original 24 Month license amendment request (LAR). This SR is being proposed for revision to convert from an 18 month frequency to a 24 month frequency. The enclosed change has been evaluated in accordance with the guidance provided in U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 91-04 "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle" dated April 2, 1991, consistent with the original GGNS 24 month LAR.
Technical Specification (TS) SR 3.7.7.2 was added to the GGNS in Amendment 191. For extending the surveillance interval of the Main Turbine Bypass Valves, historical functional performance data, associated maintenance records and condition reports were reviewed in evaluating the effect on safety. In addition, the licensing basis was reviewed for functions associated with each revision to ensure it was not invalidated. Based on the results of these reviews, it is concluded that there is no adverse effect on plant safety due to increasing the surveillance test intervals from 18 months to 24 months, with the continued application of SR 3.0.2, which allows a 25% extension (Le., grace period up to 30 months) to SR frequencies.
TS 3.7.7 Main Turbine Bypass System SR 3.7.7.2 - Perform a System Functional Test Technical Specification Bases Changes The revised TS Bases (marked-up page) is provided in Attachment 3 for NRC information. The Bases revisions are implemented pursuant to TS 5.5.11 TS Bases Control Program following issuance of the amendment.
Evaluation of Non-Calibration Changes Based on guidance provided in GL 91-04, this surveillance frequency change meets the criteria of a "Non-Calibration Surveillance Change," which is a surveillance frequency change other than a channel calibration change. GL 91-04 identifies three steps for evaluating changes to non-calibration TS Surveillances:
STEP 1: Licensees should evaluate the effect on safety of the change in surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small.
EVALUATION Technical Specification (TS) 3.7.7 and the corresponding Surveillance Requirement (SR 3.7.7.2) were added to the GGNS TS as part of the Extended Power Uprate (EPU) License Amendment (Amendment 191, approved on July 18, 2012). Therefore, there is a limited to GNRO-2013/00062 Page 2 of 2 surveillance history recorded for performance of this surveillance. This non-calibration SR frequency has been evaluated based on available maintenance and corrective action program data to quantify the effect on plant safety of extending the surveillance frequency. The methodology utilized to justify the conclusion that extending the surveillance interval has a minimal effect on safety was based on the fact that the function/feature is:
(1) Tested on a more frequent basis during the operating cycle by other plant programs; (2) Designed to have redundant counterparts or be single failure proof; or (3) Highly reliable.
STEP 2: Licensees should confirm that historical maintenance and surveillance data do not invalidate this conclusion.
EVALUATION While limited surveillance test history for the Main Turbine Bypass System is available, a review of corrective action documents written against this system does not reveal any significant impacts on plant safety.
STEP 3: Licensees should confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24 month fuel cycle would not invalidate any assumption in the plant licensing basis.
EVALUATION As part of the evaluation of each affected SR, the impact of the changes against the assumptions in the GGNS licensing basis was reviewed. In general, testing interval changes have no impact on the plant licensing basis. In some cases, the change to a 24-month fuel cycle may require a change to licensing basis information as described in the Updated Final Safety Analysis Report (UFSAR). However, since no changes requiring NRC review and approval have been identified, the UFSAR changes associated with fuel cycle extension to 24 months will be drafted in accordance with GGNS procedures that implement Title 10 Code of Federal Regulations (10 CFR) 50.59, "Changes, tests and experiments," and will be submitted in accordance with 10 CFR 50.71, "Maintenance of records, making of reports," paragraph (e).
The performance of surveillances extended for a 24 month fuel cycle will be trended as a part of the Maintenance Rule Program. Degradation in performance will be evaluated to verify that the degradation is not due to the extension of surveillance or maintenance activities.
Based on the results of these reviews, it is concluded that the performance of SRs are the bounding SR interval limit will not invalidate any assumption in the plant licensing basis.
Attachment 2 to GNRO-2013/00062 Proposed Technical Specification Change (Mark-up)
.7.
Attachment 3 to GNRO-2013/00062 Proposed Technical Specification Bases Changes (Mark-up)
Main Turbine Bypass System B 3.7.7 BASES (continued)
If the Main Turbine Bypass System cannot be restored to OPERABLE status or the LHGR and MCPR limits for two or more inoperable Main Turbine Bypass valves are not applied, THERMAL POWER must be reduced to < 70% RTP. As discussed in the Applicability section, operation at <70% RTP results in sufficient margin to the required limits, and the Main Turbine Bypass system is not required to protect fuel integrity during the feedwater controller failure, maximum demand event. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE REQUIREMENTS Cycling each Main Turbine Bypass valve through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. Therefore, the Frequency is acceptable from a reliability standpoint.
The Main Turbine Bypass System is required to actuate automatically to perform its design function. This SR demonstrates that, with the required system initiation gnals, the valves will actuate to their required posi on. The month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown the month Frequency, which is based on the refueling cycle, is acceptable from a reliability standpoint.
REFERENCES None GRAND GULF B 3.7-30 Pri the on overlaps the assumed the Thi SR ensures that the ndividua response times are less than or to the maximum values ssumed in the accident analysis. Testing is only on channels where the sumed me does to the i
B 3.3 170
Attachment 4 to GNRO*2013/00062 Proposed Technical Specification Changes (Clean Copy)
1.
LOP Instrumentation 3.3.8.1
NOTES------------------------------------
. .8.1-
. . .1.1
.3.8 . .
. 3.8. .
. .8. .
GRAND GULF 3.3-78 Amendment No. +/-ray ___