Text

Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing/
	ML15345A008
Person / Time
Site:	Grand Gulf
Issue date:	12/10/2015
From:	Kevin Mulligan; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GNRO-2015/00091
	Download: ML15345A008 (6)
	v • d • e

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~Entergy GNRO-2015/00091 December 10,2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500

SUBJECT:

Grand Gulf Nuclear Station Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1.

NRC Letter GNRI-2015/00115, "Grand Gulf Nuclear Station, Unit 1 -

Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing (TAC NO. MF6310)," dated September 24,2015 2.

Entergy Letter GNRO-2015/00026, "Application to Revise Technical Specifications for Permanent Extension of Type C Leak Rate Testing Frequency and Reduction of Type Band C Grace Intervals," dated May 27,2015 (ADAMS Accession No. ML15147A599) 3.

NRC Letter, "Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment Regarding Maximum Extended Load Line Limit Analysis PLUS (TAC NO. MF2798), " dated August 31, 2015 4.

Entergy Letter GNRO-2015/00063, "Grand Gulf Nuclear Station Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing," dated October 28, 2015

Dear Sir or Madam:

Entergy Operations, Inc. is providing, in the Attachment, supplemental responses to the Reference 4 Request for Additional Information (RAI). The Significant Hazards Consideration determination provided in Reference 2 is not altered by the additional information provided in the attached supplemental RAI responses.

GNRO-2015/00091 Page 2 of 2 This letter contains no new commitments. If you have any questions or require additional information, please contact Mr. James Nadeau at 601-437-2103.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 10th, 2015.

Sincerely,.

/7 T~JL~L KJM/ras

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Attachment:

Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing cc: with Attachment U.S. Nuclear Regulatory Commission ATTN:

Mr. A. Wang, NRR/DORL Mail Stop OWFN/8 G14 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission ATIN: Mr. Marc L. Dapas Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Mr. B. J. Smith Director, Division of Radiological Health Mississippi Department of Health Division of Radiological Health 3150 Lawson Street Jackson, MS 39213 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2015/00091 Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing

Attachment to GNRO-2015/00091 Page 1 of 3 By application dated May 27, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15147A599), Entergy Operations, Inc. (Entergy or the licensee) requested changes to the technical specifications (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS). The proposed changes would permit the existing Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," Type C Local Leak Rate Test (LLRT) frequency to be extended from 5 years up to 75 months on a permanent basis and a permanent reduction of 10 CFR 50, Appendix J, Type B and Type C test grace intervals.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that supplemental information is needed to complete its review of the subject license amendment request (LAR). The following responses constitute the supplemental information requested by the NRC. GGNS provides its original response followed by the supplemental response subsequent to each NRC RAI question, as follows:

Supplement to RAI# 2-3 Response The staff notes that on July 18, 2012, the NRC approved License Amendment No. 191 (ADAMS Accession No. ML121210020) for GGNS to increase the maximum steady state reactor core power level by approximately 15 percent from the original licensed thermal power level of 3,833 megawatt thermal (Le., extended power uprate (EPU)). The license was also amended to include a new License Condition 2.C.(44), which states, in part, that leak rate tests associated with surveillance requirements required by TS 5.5.12 are not required to be performed until their next scheduled performance dates.

License Condition 2.C.(44) states that the leak rate tests required in refueling outage RF-18 (i.e, spring of 2012) were to be performed at the EPU calculated peak containment pressure or within EPU drywell bypass leakage limits, as appropriate. License Amendment No. 191 changed the license basis "P," of 11.5 pounds per square inch gauge (psig) to the current license basis (CLB) "Pa" of 14.8 psig as reflected in current TS 5.5.12.

The staff requests additional information regarding the LLRT Pavalues used to perform Type B and Type C tests contained in LAR Attachment 1, Table 3.3.1-1 "Types Band C LLRT Combined As-Found/As-Left Trend Summary."

RAI-2-3 How many Type B penetration tests and Type C containment isolation valve test have yet to be performed at the CLB Pavalue of 14.8 psig?

RAI-2-3 Original Response The number of Type B penetration tests yet to be performed at the CLB Pavalue of 14.8 psig is forty-six (46). The number of Type C CIV tests yet to be performed at the CLB Pavalue of 14.8 psig is four (4).

Attachment to GNRO-2015/00091 RAI-2-3 Supplemental Response Page 2 of 3 RAI-2-1 response documents that 143 of the 151 Type C component tests were performed at the CLB Pa value of 14.8 psig by the end of RF19. RAI-2-1 response correctly implies that eight (8) Type C component tests had not been tested at the CLB Pa value of 14.8 psig by the end of RF19. RAI-2-3 response documents that four (4) Type C component tests had not been tested at the CLB Pa value of 14.8 psig as of the date of Reference 1. RAI-2-3 response correctly implies that four (4) Type C component tests, which had not been tested at the CLB Pa value of 14.8 pS,ig by the end of RF19, were tested at the CLB Pa value of 14.8 psig after RF19.

Supplement to RAI# 6-2 Response RAI-6-2 LAR Table 3.3.1-2, "Types Band C LLRT Program Implementation Review," Attachment 1 (page 13 of 26), contains a listing of the respective containment isolation valve LLRT failures from the last two refueling outages (RF-18 in 2012 and RF-19 in 2014):

LAR Section 3.3.2, "Type B and Type C Tested Components on Extended Intervals" reads:

"The percentage of the total number of GGNS Type B tested components (78) that are on 120-month extended performance-based test interval is 65%." Based on this, one could conclude that 35 percent of the total population of Type B penetrations did not successfully pass two consecutive Type B tests without failure. However, Table 3.3.1-2 does not list any failures of Type B penetration tests for the two most recent GGNS refueling outages (RF-18 and RF-19).

The staff requests that Entergy provide the implied additional historical information about the Type B test failures experienced at GGNS since 2005.

RAI-6-2 Original Response The LAR Table 3.3.1-2 delineates the only as-found LLRT failures that have occurred during RF-18 (2012) and RF-19 (2014), all of which were Type C components. Similarly, there have not been any Type B component as-found administrative limit LLRT failures since 2005.

RAI-6-2 Supplemental Response The 35 percent of total population of Type B penetrations were not excluded from the extended performance-based test interval based on Type B component test failures. This population of Type B components is limited to the base test interval of 30 months for the following reasons:

Containment Equipment Hatches are not included in the Performance Based Testing Program due to removal of the hatches during each refueling outage. There is no benefit for placing the hatches on Performance Based Testing frequency (As-Found and As-Left would be required each refueling outage),

Containment Airlock Leak Rate Tests are excluded from Performance Based Testing due to the Technical Specifications interval limitations, and

Attachment to GNRO-2015/00091 Page 3 of 3 Local Leak Rate Tests performed in conjunction with Technical Specification 5.5.2, Primary Coolant Sources Outside Containment,are.performed each refueling cycle due to the Technical Specifications interval limitations.