ML16140A133

Issuance of Amendment Revision of Technical Specifications to Remove Inservice Testing Program and Clarify Surveillance Requirement Usage Rule Application

ML16140A133
Person / Time
Site:	Grand Gulf
Issue date:	08/04/2016
From:	James Kim Plant Licensing Branch IV
To:	Entergy Operations
Kim J, NRR/DORL 415-4125
References
CAC MF6733
Download: ML16140A133 (26)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 4, 2016 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: REVISION OF TECHNICAL SPECIFICATIONS TO REMOVE INSERVICE TESTING PROGRAM AND CLARIFY SURVEILLANCE REQUIREMENT USAGE RULE APPLICATION (CAC NO. MF6733)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 211 to Facility Operating License No. NPF-29 for the Grand Gulf Nuclear Station, Unit 1 (GGNS).

This amendment consists of changes to the technical specifications (TSs) in response to your application dated September 15, 2015 (Agencywide Documents Access and Management System Accession No. ML15259A042).

The amendment revises the GGNS TS to eliminate the "lnservice Testing [IST] Program,"

specification in Section 5.5, "Programs and Manuals," which is superseded by Code Case OMN-20. A new defined term, "INSERVICE TESTING PROGRAM," is added to TS Section 1.1, "Definitions." This is consistent with TS Task Force (TSTF)-545, Revision 1, "TS lnservice Testing Program Removal & Clarify SR [Surveillance Requirement] Usage Rule Application to Section 5.5 Testing." Also, existing uses of the term "lnservice Testing Program" in the TSs are capitalized throughout the TS to indicate that it is now a defined term.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, James Kim, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Amendment No. 211 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. 211 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 September 15, 2015, 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. 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. 211 are hereby incorporated into this 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

/--11£----

Shaun M. Anderson, Acting Chief Plant Licensing IV-2 and Decommissioning Transition Branch 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 4, 2o1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 211 GRAND GULF NUCLEAR STATION, UNIT 1 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 INSERT 4 4 Technical Specifications REMOVE INSERT 1.0-3 1.0-3 3.1-23 3.1-23 3.4-10 3.4-10 3.4-15 3.4-15 3.5-4 3.5-4 3.5-9 3.5-9 3.6-15 3.6-15 3.6-17 3.6-17 3.6-23 3.6-23 3.6-32 3.6-32 3.6-48 3.6-48 3.6-61 3.6-61 5.0-11 5.0-11

(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 part 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 10 CFR 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 Power 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) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 211 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. 211

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT I-131 be those listed in Federal Guidance Report (FGR)

(continued) 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion,n 1989.

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

END OF CYCLE The EOC-RPT SYSTEM RESPONSE TIME shall be that RECIRCULATION PUMP TRIP time interval from initial movement of the (EOC-RPT) SYSTEM RESPONSE associated turbine stop valve or the turbine TIME control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured, except for the breaker arc suppression time, which is not measured but is validated to conform to the manufacturer's design value.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time (continued)

GRAND GULF 1.0-3 Amendment No. -+/--4-9-, -+/--8-S-, 211

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.6 Verify each SLC subsystem manual, power operated, 31 days and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position, or can be aligned to the correct position.

SR 3.1.7.7 Verify each pump develops a flow rate 2 41.2 gpm at In accordance with a discharge pressure 2 1370 psig. the INSERVICE TESTING PROGRAM SR 3.1.7.8 Verify flow through one SLC subsystem from pump 24 months on a into reactor pressure vessel. STAGGERED TEST BASIS Determine Boron-10 enrichment in atom percent (E). Once within 24 SR 3.1.7.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> after boron is added to the solution.

Once within 24 SR 3.1.7.10 Verify piping between the storage tank and the pump hours after suction is not blocked.

solution temperature is restored to

~ 45°F GRAND GULF 3.1-23 Amendment No. WO, 49-7, 2-0a, 211 Next page is 3.1-26.

S/RVs 3.4.4 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 Safety/Relief Valves (S/RVs)

LCO 3.4.4 The safety function of nine S/RVs shall be OPERABLE The relief function of six additional S/RVs shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One or more required A.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> S/RVs inoperable.

AND A.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify the safety function lift setpoints of the required In accordance with S/RVs are as follows: the INSERVICE TESTING Number of Setpoint PROGRAM S/RVs _(Qfil9}

8 1165 +/- 34.9 6 1180 +/- 35.4 6 1190 +/- 35.7 (continued)

GRAND GULF 3.4-10 Amendment No.~.~ 4-94-, 211

RCS PIV Leakage 3.4.6 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2 Isolate the high pressure 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> portion of the affected system from the low pressure portion by use of a second closed manual, deactivated automatic, or check valve.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 ----------------NOTE------------------------

Only required to be performed in MODES 1 and 2.

Verify equivalent leakage of each RCS PIV is s 1 gpm, at an RCS pressure ~ 1040 psig and s 1060 In accordance with psig. INSERVICE TESTING PROGRAM GRAND GULF 3.4-15 Amendment No. 42-0, m_

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, 31 days locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.1.2 ---------------------------N 0 TE-----------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem manual, 31 days power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.1.3 Verify ADS accumulator supply pressure is 31 days

?: 150 psig.

SR 3.5.1.4 Verify each ECCS pump develops the specified flow In accordance with rate with the specified total developed head. the INSERVICE TESTING TOTAL PROGRAM SYSTEM FLOW RATE DEVELOPED HEAD LPCS  :?: 7115 gpm  :?: 290 psid LPCI  :?: 7450 gpm  :?: 125 psid HPCS  :?: 7115 gpm  :?: 445 psid (continued)

GRAND GULF 3.5-4 Amendment No. 42G, 499, ~. 211

ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the specified In accordance with flow rate with the specified total developed head. the INSERVICE TESTING TOTAL PROGRAM SYSTEM FLOW RATE DEVELOPED HEAD LPCS ~ 7115 gpm ~ 290 psid LPCI ~ 7450 gpm ~ 125 psid HPCS ~ 7115 gpm ~ 445 psid SR 3.5.2.6 ---------------------------N 0 TE-----------------------------------------

Vesse I injection/spray may be excluded.

Verify each required ECCS injection/spray subsystem 24 months actuates on an actual or simulated automatic initiation signal.

GRAND GULF 3.5-9 Amendment No. ~ . .w+, 211

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.3 -------------------------N 0 TES-------------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation manual valve and blind flange that is located inside primary Prior to entering containment, drywell, or steam tunnel and not MODE 2 or 3 from locked, sealed, or otherwise secured and is MODE 4, if not required to be closed during accident conditions is performed within closed. the previous 92 days SR 3.6.1.3.4 Verify the isolation time of each power operated, In accordance automatic PCIV, except MSIVs, is within limits. with the INSERVICE TESTING PROGRAM (continued)

GRAND GULF 3.6-15 Amendment No.~. 16Q, 211

PC!Vs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Verify the isolation time of each MSIV is ~ 3 In accordance with seconds and :s; 5 seconds. the INSERVICE TESTING PROGRAM SR 3.6.1.3.7 Verify each automatic PCIV actuates to the 24 months isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 -------------------------N 0 TE----------------------------------

0 n Iy required to be met in MODES 1, 2, and 3.

Verify leakage rate through each main steam line In accordance is :s; 100 scfh when test at ~ Pa, and the total with 10 CFR 50, leakage rate through all four main steam lines is :s; Appendix J, 250 scfh when test at~ Pa Testing Program SR 3.6.1.3.9 -------------------------N 0 TE----------------------------------

0 nly required to be met in MODES 1, 2, and 3.

Verify combined leakage rate of 1 gpm times the total number of PCIVs through hydrostatically In accordance tested lines that penetrate the primary containment with 10 CFR 50, is not exceeded when these isolation valves are Appendix J, tested at~ 1.1 Pa. Testing Program GRAND GULF 3.6-17 Amendment No.+§, +9+, 211

RHR Containment Spray System 3.6.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.7.1 --------------------------------N 0 TE---------------------------

1. RHR containment spray subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the RHR cut in permissive pressure in MODE 3 if capable of being manually realigned and not otherwise inoperable.

2. Not Required to be met for system vent flow paths opened under administrative 31 days control.

Verify each RHR containment spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.1.7.2 Verify RHR containment spray subsystem locations 31 days susceptible to gas accumulation are sufficiently filled with water.

SR 3.6.1.7.3 Verify each RHR pump develops a flow rate of In

<:: 7450 gpm on recirculation flow through the accordance associated heat exchanger to the suppression with the pool. INSERVICE TESTING PROGRAM SR 3.6.1.7.4 Verify each RHR containment spray subsystem 24 months automatic valve in the flow path actuates to its correct position on an actual or simulated automatic initiation signal.

SR 3.6.1.7.5 Verify each spray nozzle is unobstructed. At first refueling AND 10 years GRAND GULF 3.6-23 Amendment No. 20, 4-9-7, 2G2, 211

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling 31 days subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

SR 3.6.2.3.2 Verify RHR suppression pool cooling subsystem 31 days locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.6.2.3.3 Verify each RHR pump develops a flow rate In accordance with

7450 gpm through the associated heat the INSERVICE exchangers to the suppression pool. TESTING PROGRAM GRAND GULF 3.6-32 Amendment No.~.~. 211

SC IVs 3.6.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 --------------------------N 0 TES-------------------------------

1. Valves, dampers, rupture disks, and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for SCIVs that are open under administrative controls.

Verify each secondary containment isolation manual valve, damper, rupture disk, and blind flange that is required to be closed during accident 31 days conditions is closed.

SR 3.6.4.2.2 Verify the isolation time of each power operated, In accordance automatic SCIV is within limits. with the INSERVICE TESTING PROGRAM SR 3.6.4.2.3 Verify each automatic SCIV actuates to the 24 months isolation position on an actual or simulated automatic isolation signal.

GRAND GULF 3.6-48 Amendment No. +eQ, ~. 211

Drywell Isolation Valves 3.6.5.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.5.3.3 Verify the isolation time of each power operated, In accordance automatic drywell isolation valve is within limits. with the INSERVICE TESTING PROGRAM SR 3.6.5.3.4 Verify each automatic drywell isolation valve 24 months actuates to the isolation position on an actual or simulated isolation signal.

GRAND GULF 3.6-61 Amendment No. +09, -+W, 211

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.5 Component Cyclic or Transient Limit This program provides controls to track the cyclic and transient occurrences identified on UFSAR Table 3.9-35 to ensure that the reactor vessel is maintained within the design limits.

5.5.6 Deleted (continued)

GRAND GULF 5.0-11 Amendment No.~. 142, 211

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 211 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 September 15, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15259A042), Entergy Operation, Inc. (the licensee), requested changes to the technical specifications (TSs) for Grand Gulf Nuclear Station Unit 1 (GGNS).

Specifically, the licensee requested to adopt Technical Specifications Task Force (TSTF)

Standard Technical Specifications (STS) Change Traveler TSTF-545, Revision 1, "TS lnservice Testing [IST] Program Removal & Clarify SR [Surveillance Requirement] Usage Rule Application to Section 5.5 Testing, dated March 4, 2014 (ADAMS Accession No. ML14063A334).

TSTF-545, Revision 1 was revised, and by letter dated October 21, 2015 (ADAMS Accession No. ML15294A555), TSTF-545, Revision 3 (final version) was submitted for U.S. Nuclear Regulatory Commission (NRC) review and approval. Revision 3 was made available to the TSTF via NRC letter dated December 11, 2015 (ADAMS Accession No. ML15317A071), as part of the consolidated line item improvement process. Note that the proposed TS changes in TSTF-545, Revision 1 are consistent with those in TSTF-545, Revision 3. In its September 15, 2015, submission, the licensee also proposed alternative to the testing periods in the OM Code. The NRC staff found that the proposed alternatives provided reasonable assurance that the affected components would be operationally ready and authorized alternative request GG-IST-2015-1 on June 16, 2016 (ADAMS Accession No. ML16160A092).

The proposed change requests a revision to the TS to eliminate TS 5.5.6, "lnservice Testing Program." A new defined term, "INSERVICE TESTING PROGRAM, is requested to be added to TS Section 1.1, "Definitions." Also, existing uses of the term "lnservice Testing Program" in the TS are requested to be capitalized throughout the TS to indicate that it is now a defined term.

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 Background The purpose of TS 5.5.6 is to provide a table defining some of the IST frequencies and to describe the relationship between the TS and the IST requirements. Specifically, the purpose of TS 5.5.6 is to provide controls for IST of American Society of Mechanical Engineers (ASME)

Code Class 1, 2, and 3 components including specific testing frequencies, and to provide exceptions to these frequencies based on SR 3.0.2 and SR 3.0.3.

On August 23, 2012, the NRC issued Regulatory Issue Summary (RIS) 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests" (ADAMS Accession No. ML12079A393). The RIS stated that the NRC staff had determined that restructuring TS chapters during the development of the improved STS resulted in unintended consequences when SR 3.0.2 and SR 3.0.3 provisions were made applicable to the IST program. The NRC staff concluded that SR 3.0.2 and SR 3.0.3 cannot be applied to TS Section 5.5 tests that are not associated with SRs.

2.2 Regulatory Requirements The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The Commission's regulatory requirements related to the content of the TS are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36. Section 50.36(c) of 10 CFR, requires the TSs to include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; and (5) administrative controls.

The regulations at 10 CFR 50.55a(f), "lnservice testing requirements," require, in part, that systems and components of boiling and pressurized water-cooled nuclear power reactors meet the requirements of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code). The applicable requirements of 10 CFR 50.55a are conditions in every nuclear power reactor operating license issued under 10 CFR Part 50. The regulation at 10 CFR 50.55a(f)(5)(ii) requires that if a revised IST program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised IST program.

The NRC staff's guidance for review of the TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, "Standard Review Plan (SRP)," Revision 3, dated March 201 O (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STS (NUREG 1430 to NUREG 1434) for each of the light-water reactor nuclear steam supply systems. Accordingly, the NRC staff's review includes consideration of whether the proposed TSs are consistent with the applicable reference TSs (i.e., the current STS), as modified by NRG-approved TSTF Travelers, such as TSTF-545.

3.0 TECHNICAL EVALUATION

3.1 Licensee's Requested Changes The licensee proposed to delete TS 5.5.6, "lnservice Testing Program," which currently states:

This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components. The program shall include the following:

a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and Applicable Addenda as follows:

ASME Boiler and Pressure Vessel Code and Applicable Addenda terminology for lnservice Required Frequencies for testing activities inservice testing activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

b. The provisions of SR 3.0.2 are applicable to the above required frequencies for performing inservice testing activities;

c. The provisions of SR 3.0.3 are applicable to inservice testing activities; and

d. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any TS.

In addition, the existing references to the IST program are requested to be revised to reference a new TS Section 1.1 defined term, "INSERVICE TESTING PROGRAM," which states: "The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f)." This change, in capitalization of the term, is also requested to be made throughout the TSs as referenced.

3.2 NRC Staff Evaluation 3.2.1 Deletion of TS 5.5.6 "lnservice Testing Program" 3.2.1.1 Deletion of TS 5.5.6.a TS 5.5.6.a requires that testing frequencies, applicable to the ASME OM Code and the applicable addenda, be implemented in the IST Program. The regulations at 10 CFR 50.55a(f) require, in part, that a plant-specific IST program for pumps and valves be developed and

implemented by the nuclear facility owner in accordance with the applicable edition and addenda of the ASME OM Code. Therefore, the NRC staff finds that the proposed deletion of TS 5.5.6.a is acceptable on the basis that each licensee has its self-contained IST program developed and implemented in accordance with the requirements of ASME OM Code as required by 10 CFR 50.55a(f), and TS 5.5.6.a is duplicative of the requirements in the ASME OM Code.

3.2.1.2 Deletion of TS 5.5.6.b TS 5.5.6.b provides an allowance to apply SR 3.0.2 to certain IST requirements, as specified in the ASME OM Code, and with test frequencies of 2 years or less. SR 3.0.2 states that an SR is considered met within its specified frequency if the surveillance is performed within 1.25 times the interval specified. IST programs establish testing requirements and frequencies in accordance with the requirements of 10 CFR 50.55a(f) and the ASME OM Code. However, the NRC regulations and ASME OM Code did not make available test allowances similar to SR 3.0.2.

The regulation in 10 CFR 50.55a(f)(5)(ii) states, in part, that if a revised inservice test program for a facility conflicts with the TS for the facility, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised program. Therefore, the NRC staff finds the proposed deletion of TS 5.5.6.b acceptable on the basis that the changes eliminate the conflict between TS and IST program, as required by 10 CFR 50.55a and the ASME OM Code, and are in compliance with 10 CFR 50.55a(f)(5)(ii).

3.2.1.3 Deletion of TS 5.5.6.c TS 5.5.6.c allows SR 3.0.3 to be used when IST is not performed within its required period.

SR 3.0.3 states that if a surveillance requirement was not performed within its specified frequency, then compliance with the requirement to declare the limiting condition for operation not met may be delayed, from time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. NRC regulations and the ASME OM Code do not make available test delays similar to SR 3.0.3. Therefore, the NRC staff finds the proposed deletion of TS 5.5.6.c acceptable on the basis that the changes eliminate an inconsistency between TSs and IST program with regard to test delays and are in conformance with 10 CFR 50.55a(f)(5)(ii).

The allowance permitted by SR 3.0.3 will continue to apply to tests associated with TS SRs unless otherwise stated. Nonconformances with the regulations and the ASME Code will need to be evaluated to determine operability of TS-required SSCs.

3.2.1.4 Deletion of TS 5.5.6.d TS 5.5.6.d states that nothing in the ASME OM Code shall be construed to supersede the requirements of any TS. The statement is contrary to 10 CFR 50.55a(f)(5)(ii). The regulation at 10 CFR 50.55a(f)(5)(ii) states, in part, that if a revised inservice test program for a facility conflicts with the TSs for the facility, the licensee shall apply to the Commission for amendment of the TSs to conform the TSs to the revised program. Therefore, the NRC staff finds the proposed amendment of deleting TS 5.5.6.d acceptable on the basis that the TS cannot supersede any requirements of ASME OM Code and the changes eliminate the inconsistency between the TS and the IST program, which is in conformance with 10 CFR 50.55a(f)(5)(ii).

In summary, the NRC staff finds that the proposed deletion of TS 5.5.6 is acceptable since TS 5.5.6 is duplicative of 50.55a(f), which requires each licensee to have its own self-contained IST program developed and implemented in accordance with the requirements of ASME OM Code. In addition, the proposed changes eliminate inconsistencies between the TS and the IST program. Furthermore, the NRC staff finds that the proposed deletions are consistent with the NRG-approved TSTF-545, Revision 3 and are acceptable.

3.2.2 Addition of Defined Term in TS Section 1.1 A new defined term, "INSERVICE TESTING PROGRAM," is requested to be added to TS Section 1.1, "Definitions." It states, "The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f)." In addition, the existing uses of the term "lnservice Testing Program" are requested to be capitalized throughout the TS to indicate that it is a defined term. The NRC staff finds the proposed addition of the defined term, "INSERVICE TESTING PROGRAM," acceptable on the basis that it is consistent with the format of the licensee's TSs. Furthermore, the NRC staff finds that the proposed addition is consistent with the NRG-approved TSTF-545, Revision 3 and is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Mississippi State official was notified of the proposed issuance of the amendment. The State official had no comments.

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 and changes SRs.

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 March 1, 2016 (81 FR 10679). The amendment also relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: J. Huang Date: August 4, 2016

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRA/

James Kim, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Amendment No. 211 to NPF-29

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDorlDpr Resource LPL4-2 R/F RidsNrrLAPBlechman Resource RidsACRS_MailCTR Resource RidsNrrDeEpnb Resource RidsNrrDorllpl4-2 Resource RidsNrrDssStsb Resource RidsNrrPMGrandGulf Resource JHuang, NRR RidsRgn4MailCenter Resource CTilton, NRR ADAMS A ccess1on No. ML16140A133 *b1y memo d at ed OFFICE NRR/DORL/LPL4-2/PM NRR/DORL/LPL4-2/LA NRR/DE/EPNB/BC* NRR/DSS/STSB/BC NAME JKim PBlechman DAiiey AKlein DATE 6/16/2016 6/16/2016 5/6/2016 7/21/2016 OFFICE OGC- NLO NRR/DORL/LPL4-2/BC(A) NRR/DORL/LPL4-2/PM NAME BMizuno SAnderson JKim DATE 7/26/2016 8/3/16 8/4/16 OFFICIAL RECORD COPY