GNRO-2014/00078, Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month

Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month

ML14351A069
Person / Time
Site:	Grand Gulf
Issue date:	12/15/2014
From:	Kevin Mulligan Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2014/00078
Download: ML14351A069 (15)

Text

Q

~Entergy Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Tel. (601) 437-7500 GNRO-2014/00078 December 15,2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Application To Revise Technical Specifications To Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month" Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

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

The proposed amendment would modify TS requirements to operate ventilation systems with charcoal filters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month in accordance with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."

Attachment 1 provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides existing TS Bases pages marked up to show the proposed changes (for information only).

Approval of the proposed amendment is requested by July 31, 2015. Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, 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 James Nadeau at 601-437-2103.

GNRO-2014/00078 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 15th day of December, 2014.

Sincerely,

~~{-----

KJM/ram Attachment(s): 1. Description and Assessment of the Proposed Change

2. Marked-up Copies of Technical Specification Pages

3. Clean Copies of Technical Specification Pages

4. Marked-up Copies of Technical Specification Bases Pages (For Information Only) cc: with Attachment(s)

Mr. John P. Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555 cc: without Attachment(s)

Mr. Mark Dapas Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission AnN: Mr. M. Orenak, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 to GNRO-2014/00078 Description and Assessment of the Proposed Change

GNRO-2014/00078 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises the Surveillance Requirements which currently require operating ventilation systems with the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days.

The Surveillance Requirements are revised to require operation of the systems for 15 continuous minutes every 31 days.

The proposed amendment is consistent with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy has reviewed the model safety evaluation dated September 13,2012 as part of the Federal Register Notice for Comment. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-522. As described in the subsequent paragraphs, Entergy has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to GGNS Unit 1 and justify this amendment for the incorporation of the changes to the GGNS TS.

2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the TS changes described in the TSTF-522, Revision 0, or the applicable parts of the NRC staffs model safety evaluation dated September 13, 2012. Entergy is proposing the following variations from the TS changes described in the TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation dated September 13, 2012.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination GGNS Unit 1 requests adoption of an approved change to the standard technical specifications (STS) and plant specific technical specifications (TS), to revise Technical Specification (TS) 3.6.4.3, "Standby Gas Treatment (SGT) System," and TS 3.7.4, "[Control Room Air Conditioning (AC) System," in the BWRl6 SGT System and CRFA System with the electric heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days. The Surveillance Requirement is revised to require operation of the systems for 15 continuous minutes every 31 days.

As required by 10 CFR 50.91 (a), an analysis of the issue of no significant hazards consideration is presented below:

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

Response: No.

GNRO-2014/00078 The proposed change replaces an existing Surveillance Requirement to operate the BWRl6 SGT System and CRFA Systems equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating, if needed.

These systems are not accident initiators and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function which may include mitigating accidents. Thus the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this change does not involve a significant increase in the probability or 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 replaces an existing Surveillance Requirement to operate the BWRl6 SGT System and CRFA Systems equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating, if needed.

The change proposed for these ventilation systems does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the BWRl6 SGT System and CRFA Systems equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating, if needed.

The design basis for the ventilation systems' heaters is to heat the incoming air which reduces the relative humidity. The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will perform their design function. The proposed change is consistent with regulatory guidance.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety. Based on the above, [LICENSEE] concludes that the proposed change 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.

GNRO-2014/00078 4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or 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 change.

Attachment 2 to GNRO-2014/00078 Marked-up Copies of Technical Specification Pages

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for ~ +/-e 31 days 15 continuous ~ minutes with heaters operating.

SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an 24 months actual or simulated initiation signal.

t GRAND GULF 3.6-51 Amendment No. 1Ze, I9T, _

CRFA System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRFA subsystems E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

F. Two CRFA subsystems F.1 Initiate action to Immediately inoperable during suspend OPDRVs.

OPDRVs.

OR One or more CRFA subsystems inoperable due to inoperable CRE boundary during, OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRFA subsystem for ~ fa 15 31 days continuous ~ minutes with the heaters operating.

SR 3.7.3.2 Perform required CRFA filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.7.3.3 Verify each CRFA subsystem actuates on an 24 months actual or si mul at ed i ni ti ati on si gna1 .

SR 3.7.3.4 Perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Room Envelope Habitability Control Room Program. Envelope Habitability Program GRAND GULF 3.7-8 Amendment No. 178. +/-97, ___

Attachment 3 to GNRO-2014/00078 clean Copies of Technical Specification Pages

seT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each seT subsystem for 31 days

~ 15 continuous minutes with heaters operating.

SR 3.6.4.3.2 Perform required seT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3. 6. 4..3. 3 Verify each seT subsystem actuates on an 24 months actual or simulated initiation signal.

GRAND GULF 3.6-51 Amendment No. +/-re, +/-97, _

CRFA System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRFA subsystems E.l Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

F. Two CRFA subsystems F.l Initiate action to Immediately inoperable during suspend OPDRVs.

OPDRVs.

OR One or more CRFA subsystems inoperable due to inoperable CRE boundary during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CRFA subsystem for ~ 15 31 days continuous minutes with the heaters operating.

SR 3.7.3.2 Perform required CRFA filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.7.3.3 Verify each CRFA subsystem actuates on an 24 months actual or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Room Envelope Habitability Control Room Program. Envelope Habitability Program GRAND GULF 3.7-8 Amendment No. 178, f9T, ___

Attachment 4 to GNRO-2014/00078 Marked-up Copies of Technical Specification Bases Pages (For Information Only)

SGT System B 3.6.4.3 BASES ACTIONS E.l and E.2 (continued) suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until OPDRVs are suspended.

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating each SGT subsystem from the control room for > +/-G 15 continuous ~ minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation ~:ith the heaters on (automatic heater cycling to maintain temperature) for ~ 10 continuous hours every 31 days eliminates moisture on the absorbers and HErA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specified test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR requires verification that each SGT subsystem starts upon receipt of an actual or simulated initiation signal.

(continued)

GRAND GULF B 3.6-100 LDC 99069, ___

CRFA System B 3.7.3 BASES (continued)

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts from the control room on demand and continues to operate.

Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system. Operation with the heaters on for ~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures heat heater failure, blockages fan or motor failure, or excessive vibration can be detected for corrective action. Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.

SR 3.7.3.2 This SR verifies that the required CRFA testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, and minimum system flow rate. Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.3.3 This SR verifies that each CRFA subsystem starts and operates and that the isolation valves close in ~ 4 seconds on an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.1 overlaps this SR to provide complete testing of the safety function. While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency, which is based on the refueling cycle.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

(continued)

GRAND GULF B 3.7-16a LBDCR 13043