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Category:Letter type:GNRO
MONTHYEARGNRO-2023/00014, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2023-06-0606 June 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GNRO-2023/00015, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-06-0606 June 2023 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors GNRO-2021/00037, 2021 Annual Report of Changes and Errors to 10 CFR 50.46 Analysis Grand Gulf Nuclear Station, Unit 12021-11-30030 November 2021 2021 Annual Report of Changes and Errors to 10 CFR 50.46 Analysis Grand Gulf Nuclear Station, Unit 1 GNRO-2021/00017, Notification of Readiness for Supplemental Inspection2021-06-22022 June 2021 Notification of Readiness for Supplemental Inspection GNRO-2021/00014, Inservice Testing Program Relief Request VRR-GGNS-2021-1 Pressure Isolation Valve Testing Frequency2021-06-0101 June 2021 Inservice Testing Program Relief Request VRR-GGNS-2021-1 Pressure Isolation Valve Testing Frequency GNRO-2021/00015, Annual Radioactive Effluent Release Report2021-04-28028 April 2021 Annual Radioactive Effluent Release Report GNRO-2021/00011, Revision of Original Report of 10CFR50.59 and Commitments Change Evaluations - July 1, 2018 Through May 21, 20202021-04-19019 April 2021 Revision of Original Report of 10CFR50.59 and Commitments Change Evaluations - July 1, 2018 Through May 21, 2020 GNRO-2021/00012, Annual Report of Individual Monitoring - NRC Form 5 for 2020 Per 10 CFR 20.22062021-04-13013 April 2021 Annual Report of Individual Monitoring - NRC Form 5 for 2020 Per 10 CFR 20.2206 GNRO-2020/00045, 2020 Report of Changes and Errors to 10 CFR 50.46 Analysis2020-12-16016 December 2020 2020 Report of Changes and Errors to 10 CFR 50.46 Analysis GNRO-2020/00034, Notification of Spent Fuel Cask Use2020-10-0808 October 2020 Notification of Spent Fuel Cask Use GNRO-2020/00033, Response to NRC Integrated Inspection Report 05000416/20200022020-09-10010 September 2020 Response to NRC Integrated Inspection Report 05000416/2020002 GNRO-2020/00029, Report of 10 CFR 72.48 Evaluations July 1, 2018 Through June 30, 20202020-08-18018 August 2020 Report of 10 CFR 72.48 Evaluations July 1, 2018 Through June 30, 2020 GNRO-2020/00022, Report of Technical Specification Bases Changes2020-07-21021 July 2020 Report of Technical Specification Bases Changes GNRO-2020/00027, Core Operating Limits Report (COLR) Cycle 23 Revision 1 for Grand Gulf Nuclear Station, Unit 1 (GGNS)2020-07-16016 July 2020 Core Operating Limits Report (COLR) Cycle 23 Revision 1 for Grand Gulf Nuclear Station, Unit 1 (GGNS) GNRO-2020/00023, Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies2020-06-26026 June 2020 Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies GNRO-2020/00020, Core Operating Limits Report (COLR) Cycle 23, and Pressure and Temperature Limits Report (PTLR) Update for Grand Gulf Nuclear Station, Unit 1 (GGNS)2020-05-0505 May 2020 Core Operating Limits Report (COLR) Cycle 23, and Pressure and Temperature Limits Report (PTLR) Update for Grand Gulf Nuclear Station, Unit 1 (GGNS) GNRO-2020/00018, Annual Radiological Effluent Release Report2020-04-30030 April 2020 Annual Radiological Effluent Release Report GNRO-2020/00016, Annual Report of Individual Monitoring -NRC Form 5 for 2019 Per 10 CFR 20.22062020-04-16016 April 2020 Annual Report of Individual Monitoring -NRC Form 5 for 2019 Per 10 CFR 20.2206 GNRO-2020/00015, Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test2020-04-0707 April 2020 Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test GNRO-2020/00007, Spent Fuel Storage Radioactive Effluent Release Report for 20192020-02-20020 February 2020 Spent Fuel Storage Radioactive Effluent Release Report for 2019 GNRO-2020/00006, License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies2020-02-19019 February 2020 License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies GNRO-2019/00052, Report of Changes and Errors to 10 CFR 50.46 Analysis2019-12-13013 December 2019 Report of Changes and Errors to 10 CFR 50.46 Analysis GNRO-2019/00051, Notification of Readiness of 92723 Inspection2019-12-11011 December 2019 Notification of Readiness of 92723 Inspection GNRO-2019/00045, Emergency Plan, Revision 792019-10-29029 October 2019 Emergency Plan, Revision 79 GNRO-2019/00037, Notification of Spent Fuel Cask Use2019-09-20020 September 2019 Notification of Spent Fuel Cask Use GNRO-2019/00036, Correction to Gnro 2019-00017 Emergency Plan Revision 782019-08-0808 August 2019 Correction to Gnro 2019-00017 Emergency Plan Revision 78 GNRO-2019/00027, Notification of Readiness of 95001 Supplemental Inspections2019-07-0303 July 2019 Notification of Readiness of 95001 Supplemental Inspections GNRO-2019/00031, Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 - Corrected Report2019-06-25025 June 2019 Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 - Corrected Report GNRO-2019/00028, Supplement to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation.2019-06-13013 June 2019 Supplement to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation. GNRO-2019/00026, Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval2019-05-0606 May 2019 Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval GNRO-2019/00024, Annual Radioactive Effluent Release Report2019-04-30030 April 2019 Annual Radioactive Effluent Release Report GNRO-2019/00020, Annual Radiological Operating Report (AREOR)2019-04-30030 April 2019 Annual Radiological Operating Report (AREOR) GNRO-2019/00022, Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.22062019-04-22022 April 2019 Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 GNRO-2019/00017, Emergency Plan, Revision 782019-03-14014 March 2019 Emergency Plan, Revision 78 GNRO-2019/00014, Snubber Testing Program for Fourth Inspection Interval2019-03-13013 March 2019 Snubber Testing Program for Fourth Inspection Interval GNRO-2019/00012, Internal Events Probabilistic Risk Assessment (PRA) Sensitivity Study Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program2019-03-0606 March 2019 Internal Events Probabilistic Risk Assessment (PRA) Sensitivity Study Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program GNRO-2019/00016, Spent Fuel Storage Radioactive Effluent Release Report for 20182019-02-21021 February 2019 Spent Fuel Storage Radioactive Effluent Release Report for 2018 GNRO-2019/00003, Application to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation2019-01-23023 January 2019 Application to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation GNRO-2018/00057, Submittal of Revision 17 to the Grand Gulf Nuclear Station Physical Security, Safeguards Contingency, and Training and Qualification Plan2018-12-0404 December 2018 Submittal of Revision 17 to the Grand Gulf Nuclear Station Physical Security, Safeguards Contingency, and Training and Qualification Plan GNRO-2018/00055, Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ...2018-11-30030 November 2018 Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ... GNRO-2018/00054, Relief Request No. GG-ISI-023, Inservice Inspection Impracticality: Limited Coverage Examination During the Third 10-Year Inservice Inspection Interval2018-11-30030 November 2018 Relief Request No. GG-ISI-023, Inservice Inspection Impracticality: Limited Coverage Examination During the Third 10-Year Inservice Inspection Interval GNRO-2018/00052, License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information2018-10-24024 October 2018 License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information GNRO-2018/00051, Supplement to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-10-23023 October 2018 Supplement to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control GNRO-2018/00046, Submittal of 2018 Report of Changes and Errors to 10CFR50.462018-10-16016 October 2018 Submittal of 2018 Report of Changes and Errors to 10CFR50.46 GNRO-2018/00047, Submittal of 2018 Inservice Inspection Summary Report2018-10-16016 October 2018 Submittal of 2018 Inservice Inspection Summary Report GNRO-2018/00048, Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 62018-10-10010 October 2018 Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 GNRO-2018/00042, Core Operating Limits Report Cycle 22, Revision 12018-09-18018 September 2018 Core Operating Limits Report Cycle 22, Revision 1 GNRO-2018/00043, Revised Offsite Dose Calculation Manual2018-09-18018 September 2018 Revised Offsite Dose Calculation Manual GNRO-2018/00039, Report of Technical Specification Bases Changes2018-08-20020 August 2018 Report of Technical Specification Bases Changes GNRO-2018/00040, Report of 10CFR50.59 Evaluations and Commitment Change Evaluations - July 1, 2016 Through June 30, 20182018-08-20020 August 2018 Report of 10CFR50.59 Evaluations and Commitment Change Evaluations - July 1, 2016 Through June 30, 2018 2023-06-06
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML24012A1962024-01-12012 January 2024 Response to 2nd Round Request for Additional Information Concerning Relief Request Number EN-RR-22-001 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and ML23159A2302023-06-0808 June 2023 Response to Request for Additional Information Concerning Request to Update ASME Code Relief Request Safety Evaluations with NRC-Approved Revision of BWRVIP Guidelines (GG-ISI-020, and RBS-ISI-019) ML23111A2132023-04-21021 April 2023 Responses to RAI Concerning Relief Request Number EN-RR-22-001 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities CNRO-2021-00002, Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L2021-01-28028 January 2021 Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L CNRO-2020-00021, Response to Request for Additional Information Regarding Relief Requests GG-ISI-020 and RBS-ISI-0192020-11-0909 November 2020 Response to Request for Additional Information Regarding Relief Requests GG-ISI-020 and RBS-ISI-019 GNRO-2020/00023, Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies2020-06-26026 June 2020 Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies GNRO-2020/00015, Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test2020-04-0707 April 2020 Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test CNRO-2019-00030, Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary2019-12-30030 December 2019 Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary GNRO-2019/00026, Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval2019-05-0606 May 2019 Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval ML19023A3282019-01-23023 January 2019 Response to Request for Additional Information Regarding License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Supplement GNRO-2018/00055, Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ...2018-11-30030 November 2018 Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ... GNRO-2018/00052, License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information2018-10-24024 October 2018 License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information GNRO-2018/00048, Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 62018-10-10010 October 2018 Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 GNRO-2017/00068, Response to Official Requests for Additional Information (RAI) for RR GG-ISI-020 to Use BWRVIP Guidelines2017-10-12012 October 2017 Response to Official Requests for Additional Information (RAI) for RR GG-ISI-020 to Use BWRVIP Guidelines ML17269A0782017-09-22022 September 2017 Response to Request for Additional Information (RAI) for Relief Request GG-ISl-021 Associated with Fourth Interval Inservice Inspection Using Code CAS N-702, Dated August 8, 2017 GNRO-2017/00053, Response to Eseb RAI-1, Results of IWE and Iwl Inspections2017-08-25025 August 2017 Response to Eseb RAI-1, Results of IWE and Iwl Inspections GNRO-2016/00059, Response to Generic Letter 2016-01 Regarding Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools2016-11-0101 November 2016 Response to Generic Letter 2016-01 Regarding Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools GNRO-2016/00040, Response to Request for Additional Information (RAI) on Severe Accident Mitigation Alternatives (SAMA) for Grand Gulf Nuclear Station License Renewal Environmental Review2016-09-0707 September 2016 Response to Request for Additional Information (RAI) on Severe Accident Mitigation Alternatives (SAMA) for Grand Gulf Nuclear Station License Renewal Environmental Review GNRO-2016/00036, Response to Requests for Additional Information (Rais) Regarding Final Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation2016-07-29029 July 2016 Response to Requests for Additional Information (Rais) Regarding Final Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation CNRO-2016-00016, Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated)2016-06-0202 June 2016 Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated) ML16071A4412016-03-0707 March 2016 Entergy Fleet Relief Request No. RR-EN-15-1-Proposed Alternative to Use ASME Code Case N-789-1 - E-mail from G.Davant to R.Guzman - Response to Second RAI (MF6340 - MF6349) GNRO-2016/00013, Supplemental Correction Response to License Renewal Amendment Request for Additional Information Set 472016-02-26026 February 2016 Supplemental Correction Response to License Renewal Amendment Request for Additional Information Set 47 CNRO-2016-00005, Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM)2016-02-25025 February 2016 Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM) CNRO-2016-00002, Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Secti2016-01-29029 January 2016 Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Section Xl, ML15348A4022015-12-14014 December 2015 Amended Response to Request for Additional Information (RAI) 4.2.3-2, Dated October 28, 2015 GNRO-2015/00091, Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing/2015-12-10010 December 2015 Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing/ CNRO-2015-00002, Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 12015-12-0404 December 2015 Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 1 GNRO-2015/00077, Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF) TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours.2015-11-24024 November 2015 Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF) TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours. GNRO-2015/00079, Responses to Request for Additional Information (RAI) Set 53, Dated October 28, 20152015-11-23023 November 2015 Responses to Request for Additional Information (RAI) Set 53, Dated October 28, 2015 GNRO-2015/00063, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing2015-10-28028 October 2015 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Containment Leak Rate Testing GNRO-2015/00064, Response to Electronic Request for Additional Information Regarding Modification of Technical Specification (TS) 3.8.4, DC Sources Operating Surveillance Requirements (Srs) 3.8.4.2 and 3.8.4.5 Amendment Request, 08/28/20152015-10-15015 October 2015 Response to Electronic Request for Additional Information Regarding Modification of Technical Specification (TS) 3.8.4, DC Sources Operating Surveillance Requirements (Srs) 3.8.4.2 and 3.8.4.5 Amendment Request, 08/28/2015 GNRO-2015/00060, Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF) TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours..2015-10-12012 October 2015 Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF) TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours.. GNRO-2015/00058, Response to License Renewal Application (LRA) Request for Additional Information (RAI) Set 47, Question 4.2.1-2c (5) (a) I2015-09-0101 September 2015 Response to License Renewal Application (LRA) Request for Additional Information (RAI) Set 47, Question 4.2.1-2c (5) (a) I GNRO-2015/00042, Response to License Amendment Request for Revision of Five Technical Specification Allowable Value Setpoints Request for Additional Information, Set No. 2, Revision 12015-06-30030 June 2015 Response to License Amendment Request for Revision of Five Technical Specification Allowable Value Setpoints Request for Additional Information, Set No. 2, Revision 1 2024-01-12
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Text
Entergy Operations, Inc.
P.O. Box 756 Port Gibson, Mississippi 39150 Eric A. Larson Site Vice Presidenf Grand Gulf Nuclear Station Tel 601-437-7500 10 CFR 50.90 GNR0-2018/00055 November 30, 2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. 20555
SUBJECT:
Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)
Grand Gulf Nuclear Statiot), Unit 1 Docket No. 50-416 Renewed License No. NPF-29
REFERENCES:
- 1. Letter from E.A. Larson (Entergy) to Document Control Desk (NRC),
"Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)," April 12, 2018 (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML181028445)
- 2. Letter from E.A. Larson (Entergy) to Document Control Desk (NRC),
"Supplement to Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)," June 7, 2018 (NRC ADAMS Accession No. ML18158A514) .
- 3. Electronic mail from L. M. Regner (NRC) to D. A. Neve and J.
Schrage (Entergy),
Subject:
Final Request for Additional Information -
Dear Sir or Madam:
By letter dated April 12, 2018 (Reference 1), as supp,lemented by letter dated June 7, 2018 (Reference 2), Entergy Operations, Inc. (Entergy) requested a license amendment to modify the Grand Gulf Nuclear Station, Unit 1 technical specifications by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute 04-10, "Risk-Informed Technical Specification Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies." By correspondence from Lisa Regner (NRC) to Douglas
GNR0-2018/00055 Page 2 of 3 Neve and John Schrage (Entergy) dated October 31, 2018, (Reference 3), the NRC provided a request for additional inform?tion (RAI) in support of the TSTF-425 license amendment request.
This letter provides Entergy responses to the RAI. The information provided herein does not change the intent or the justification for the requested license amendment (Reference 1) and does not alter the conclusion that the proposed license amendment does not involve a significant hazards consideration as published in Federal Register 74 FR 32000 dated July 6, 2009.
No new regulatory commitments are made in this submittal.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this application, with attachments, is being provided to designated State of Mississippi Official.
If you should have any questions regarding this submittal, please contact Douglas A. Neve, Manager, .Regulatory Assurance, at 601.437.2103.
I declare under penalty of p~rjury that the foregoing is true and correct. Executed on 30th day of November 2018.
Sincerely, Eric A. Larson EAUgwe
Attachment:
Response to Request for Additional Information Supporting License Amendment Request to Relocate Specific Surveillance Frequency Requirements cc: with Attachment Ms. Lisa Regner U.S. Nuclear Regulatory Commission Mail Stop OWFN 8 81 ,
Rockville, MD 20852-2738 Mr. Siva Lingam U.S. Nuclear Regulatory Commission Mail Stop OWFN 8 81 Rockville, MD 20852-2738 Dr. Thomas Dobbs, M.D., M.P.H State Health Officer Mississippi Department of Health
G NR0-2018/00055 Page 3 of 3 P.O. Box 1700 Jackson, MS 39215-1700 Email: Thomas.dobbs@msdh.ms.gov cc: without Attachment Mr. Kriss Kennedy Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 N RC Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
ATTACHMENT to GNR0-2018/00055 Response to Request for*Additional Information Supporting ~icense Amendment Request to Relocate Specific Surveillance Frequency Requirements
Attachment GNRO 2018/00055 Page 1 of 5
- 1. Summary Description By letter dated April 12, 2018 (Reference 1) as supplemented by letter dated June 7, 2018 (Reference 2), Entergy Operations, Inc. (Entergy) requested a license amendment to modify the Grand Gulf Nuclear Station, Unit 1 (GGNS) technical 'specifications by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute 04-10, "Risk-Informed Technical Specification Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." By correspondence from Lisa Regner (NRC) to Douglas Neve and John Schrage (Entergy) dated October 31, 2018, (Reference 3), the NRC provided a request for additional information (RAI) in support of the Technical Specifications Task Force (TSTF) traveler TSTF-425 lice*nse amendment request (LAA). The following provides the Entergy responses to the RAI.
- 2. NRC Staff Request for Additional Information RAl-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.
Entergy Response to RAl-1 :
Please note that the plant-specific data collection time frame specified in F&O 4-14 of the GGNS LAR supplement (Reference 2) is September 1, 2006 through August 31, 2012, not 2010. As stated in Section 3.2.2 of the GGNS PRA Technical Adequacy Report (Attachment 2 of Reference 1), the PRA model was updated to support resolutions of the 2015 peer review findings, which included F&O 4-14. This model update was approved in 2017 following completion of the independent assessment. Use of plant failures that occurred during the six-year time frame of the PRA update was based on the following:
- The data collection period ending in August 2012 coincided with the time frame of update to the data analysis for the PRA revision.
- Regarding the data collection period indicated in F&O 4-14, the peer reviewer suggested being consistent when referencing the plant-specific data timeframe; however, the peer reviewer noted that the time frame selected was appropriate and correctly used in the model. Therefore, additional data collection was not warranted.
Attachment GNRO 2018/00055 Page 2 of 5
- The dpta is representative of multiple refueling cycles, which is also representative of operating practices for the period. ,
- Use of data prior to September 1, 2006 would result in a more substantial overlap with the generic data reference used for the update (i.e., the 2010 update to the component reliability data sheets of NUREG/CR-6928, "Industry-Average Performance for Components and Initiating Events at U.S. Commercial Nuclear Power Plants" (Reference 4), which contains data collected between 1998 and 2010). Extensive overlap between the plant-specific data and the generic data source used for Bayesian update is avoided to minimize double-counting of GGNS failure events that appear in both the generic and plant-specific data set.
To ensure the six-year plant-specific data provided in the PRA model continues to adequately represent the uniformity in plant design, operational practice, and experience, a sensitivity study of plant failure data since August 2012 will be performed to determine if a further PRA update is needed. Entergy will provide the results of this sensitivity study by late first quarter 2019.
RAl-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 58"' 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 ~xternal 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 I PEEE evaluation based on relevant operating experience and additional risk insights obtained since the study was conducted.
Entergy Response to RAl-2:
A fire probabilistic risk assessment (PRA) was developed for GGNS in 2005 to examine fire risks relative to the Individual Plant Examination for External Events (IPEEE). As stated in Section 3.1 of the GGNS LAR (Reference 1) and restated in RAl-2 herein, the GGNS fire
Attachment GNRO 2018/00055 Page 3 of 5 PRA model was not developed in accordance with NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities" (Reference 5). Analyses performed for the I PEEE and the fire PRA do not provide quantitative fire risk information that can be directly compared to the internal events PRA model on a quantitative basis due to conservatisms.
The GGNS fire PRA evaluation was completed in August 2005 and has not been updated since the evaluation was completed. Fire zones provided in the I PEEE evaluation also have not been updated to keep in step with plant changes.
The GGNS plant procedure used to assess risk for maintenance activities has been updated, as necessary, to incorporate operational experience with respect to implementing fire risk management actions (RMAs). Specifically, guidance to qualitatively assess risk of fire zones and provide explicit RMAs to mitigate fire risk was incorporated into this procedure in November 2013, based on the Revision 4A to NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (Reference 6). NRC Regulatory Guide 1.160, Revision 3 (Reference 7) endorses the use of Revision 4A of NUMARC 93-01.
When assessing fire risk, a bounding assessment is performed considering the qualitative aspects of the risk, including the impact of fire initiators in applicable fire zones when one or more structure, system, or component (SSC) in scope is identified as unavailable. Entergy currently offsets fire risk configurations by implementing RMAs in accordance with the plant risk assessment for maintenance activities procedure to minimize the likelihood of a fire.
The equipment-out-of-service (EOOS) monitor does not calculate the impact on risk due to fire but is used to assess fire mitigation risk and indicates if there is a safe shutdown analysis (SSA) risk mitigation success path for risk significant fire areas.
For the Surveillance Frequency Control Program (SFCP), Entergy plans to employ the bounding qualitative analysis for surveillance frequency changes associated with SSCs evaluated in the fire PRA, which includes appropriate RMAs. A detailed qualitative analysis is performed if the affected SSC is not modeled or included in the EOOS monitor. The bounding qualitative method of determining fire risk is sufficient for implementing surveillance frequency changes in accordance with the SFCP. Implementation of RMAs provides: increased risk awareness of appropriate plant personnel; more rigorous planning and control of the activity; and measures to control the duration and magnitude of the increased risk.
RAl-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.
Entergy Response to RAl-3:
Entergy currently utilizes fleet procedures for monitoring the effects of changes to surveillance frequencies in accordance with the SFCP for those plants within the Entergy
Attachment
- GNRO 2018/00055 Page 4 of 5 fleet that have already implemented the program in accordance with their technical specifications and NEI 04-10, Revision 1. This monitoring procedure will be utilized to implement performance monitoring strategies of the GGNS SFCP. GGNS will implement performance monitoring strategies to monitor changes to surveillance frequencies consistent with the requirements of NEI 04-10, Revision 1, as required by proposed TS 5.5.6, "Surveillance Frequency Control Program," in the GGNS LAR (Reference 1). The perfor~ance monitoring strategies include the following:
- Confirmation that no failure mechanisms that are related to the revised STI become important enough to1 alter the failure rates assumed in the justification of the program changes.
- Performance monitoring ensures adequate component capability (i.e., margin) exists, relative to design-basis conditions, so that component operating characteristics do not result in reaching a point of insufficient margin before the next scheduled test.
- Component or train level monitoring is expected for high safety significant structures, systems, and components as defined by the GGNS Maintenance Rule program
- In general, performance will be monitored per the monitoring requirements of the Maintenance Rule program. However, additional monitoring unique to a revised STI may be specified.
- The output of the perfqrmance monitoring will be periodically re-assessed, and appropriate adjustments made to the surveillance frequencies, if needed.
- 3.
References:
- 1. Letter from E.A. Larson (Entergy) to Document Control Desk (NRC), "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)," April 12, 2018 (NRC Agencywide*Documents Access and Management System (ADAMS) Accession No. ML181028445).
- 2. Letter from E.A. Larson (Entergy) to Document Control Desk (NRC), "Supplement to
- Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)," June 7, 2018 (NRC ADAMS Accession No. ML18158A514).
\
- 3. Electronic mail from L. M. Regner (NRC) to D. A. Neve and J. Schrage (Entergy),
Subject:
Final Request for Additional Information -TSTF-425 (L-2018-LLA-0106),
October 31 2018, 3:10 PM.
- 4. Component Reliability 2010 Update to NRC NUREG/CR-6928, "Industry-Average Performance for Components and Initiating Events at U.S. Commercial Nuclear Power Plants," Idaho National Laboratory, September 2012 (Website:
https://nrcoe. inl .gov/resultsdb/Avg Perf/).
- 5. NRC NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities," Volumes 1 and 2, Electric Power Research Institute, September 2005.
Attachment GNRO 2018/00055 Page 5 of 5
- 6. Nuclear Energy Institute NU MARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 4A, April 2011 (NRC ADAMS Accession No. ML11116A198).
- 7. NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3, May 2012 (NRC ADAMS Accession No. ML113610098).