ML18304A460

NRR E-mail Capture - Final Request for Additional Information - TSTF-425 (L-2018-LLA-0106)

ML18304A460
Person / Time
Site:	Grand Gulf
Issue date:	10/31/2018
From:	Lisa Regner Plant Licensing Branch IV
To:	Neve D, Schrage J Entergy Nuclear Operations
References
L-2018-LLA-0106
Download: ML18304A460 (3)

Text

NRR-DMPSPEm Resource From: Regner, Lisa Sent: Wednesday, October 31, 2018 3:10 PM To: Neve, Douglas A; Schrage, John (jschrag@entergy.com)

Cc: Regner, Lisa

Subject:

Final Request for Additional Information - TSTF-425 (L-2018-LLA-0106)

Final Request for Additional Information (L-2018-LLA-0106)

On October 3, 2018, the U.S. Nuclear Regulatory Commission (NRC) staff sent Entergy Operations, Inc. (the licensee) a draft Request for Additional Information (RAI). The RAI questions relate to a license amendment request (LAR) that proposes to modify the technical specifications to allow risk-informing specific surveillance frequency requirements and allowing their relocation to a licensee controlled program (TSTF-425).

Entergy informed the NRC staff that a clarification call was needed, and this call was held on October 10, 2018.

Subsequently. the NRC staff eliminated one question since the information is provided in the LAR, and provided additional clarification to question number 2 below. PSEG then informed the NRC staff that the questions were understood and Mr. John Schrage agreed to provide a response to this final RAI on or before 30 days from the date of this email. If Entergy does not respond by this date, the requested completion date for the LAR decision may not be met by the NRC.

The NRC staff also informed the licensee that a publicly available version of this final RAI would be placed in the NRCs Agencywide Documents Access and Management System (ADAMS).

By letter dated April 12, 2018, as supplemented by letter dated June 11, 2018 (ADAMS Accession Nos. ML18102B445 and ML18158A514, respectively), the licensee requested an amendment to the Operating License for Grand Gulf Nuclear Station, Unit 1. The proposed amendment requests to implement TSTF-425 Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b. The NRC staff requires additional information to complete its review of this request as detailed in the attached document.

Lisa M. Regner Senior Project Manager Branch 4, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission OWFN 9E01

' 301-415-1906 Lisa.Regner@nrc.gov REQUEST FOR ADDITIONAL INFORMATION RELATED TO AN AMENDMENT TO IMPLEMENT TECHNICAL SPECIFICATION TASK FORCE-425 REVISION 3 ENTERGY OPERATIONS, INC 1

GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416

1. In letter dated June 7, 2018, Entergy provided a supplement (U.S. Nuclear Regulatory Commission (NRC) Agencywide Documents Access and Management System Accession No. ML18158A514) in response to NRC Acceptance Review request for additional information. This supplement provides a list of facts and observations (F&Os) for the Grand Gulf Nuclear Station (GGNS) Internal Events Probabilistic Risk Assessment (PRA) Model from the 2015 full-scope industry peer review that were closed by an independent assessment conducted August 23-31, 2017.

F&O 4-14 addresses the bases for not including prior plant failures into plant specific data. The resolution states all failures included in the PRA must have occurred during the time frame for the PRA update (Sept 1, 2006 through Aug 31, 2010) and must meet the definition of a PRA functional failure. Provide the justification for only including plant failures that have occurred during the time frame for PRA update or revise the plant-specific data consistent with uniformity in design, operational practices, and experience.

2. Section 3.1 of the GGNS license amendment request (LAR) states GGNS does not currently have a Fire PRA model developed in accordance with NUREG/CR-6850. A bounding fire risk evaluation, based on information from the IPEEE and other available insights for fire risk will be performed for STI changes Memo from S. Rosenberg titled Comments on the Technical Specifications Task Force Letter 09 titled Clarification on Information Needed from Licensees Adopting TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B dated December 15, 2015 (ADAMS:

ML15280A318) Enclosure 1 Page 3 provides clarification that licensees using qualitative or bounding methods to evaluate external events, fire risk, or shutdown events in accordance with NEI 04-10, Revision 1, should identify that fact in their submittal and summarize the method. Technical Specifications Task Force (TSTF) 14-09 titled Clarification of Information Needed from Licensees Adopting TSTF-425, Revision 3 dated April 21, 2016 (ADAMS: ML18051A833) Resolution #1 states Licensees using qualitative or bounding methods to evaluate external events, fire risk, or shutdown events in accordance with NEI 04-10, Revision 1, will identify that fact in their submittal and summarize the method. In addition, for bounding methods, TSTF 14-09 provides a footnote that specifies the analysis should incorporate relevant operating experience and additional risk insights obtained since the IPEEE study, in the context of the current plant configuration and operation.

As specified in TSTF-14-09, provide a summary of the method employed for evaluating fire risk for SFCP and provide a description of updates to the fire IPEEE evaluation based on relevant operating experience and additional risk insights obtained since the study was conducted.

3. The NEI 04-10, Section 3.0, Key Safety Principles outlines the key safety principles to be addressed in risk-informed change applications. The fifth principle addresses monitoring changes using performance monitoring strategies. The LAR provides a brief statement in Section 2.1, Surveillance Frequency Change Process that indicates the integrated decision making panel is responsible for reviewing the performance monitoring results. Describe how GGNS intends to implement performance monitoring strategies to monitor changes to surveillance frequencies.

2

Hearing Identifier: NRR_DMPS Email Number: 647 Mail Envelope Properties (BN6PR09MB149195F189CB909B5F12CCB4E5CD0)

Subject:

Final Request for Additional Information - TSTF-425 (L-2018-LLA-0106)

Sent Date: 10/31/2018 3:09:30 PM Received Date: 10/31/2018 3:09:30 PM From: Regner, Lisa Created By: Lisa.Regner@nrc.gov Recipients:

"Regner, Lisa" <Lisa.Regner@nrc.gov>

Tracking Status: None "Neve, Douglas A" <dneve@entergy.com>

Tracking Status: None "Schrage, John (jschrag@entergy.com)" <jschrag@entergy.com>

Tracking Status: None Post Office: BN6PR09MB1491.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5798 10/31/2018 3:09:30 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: