ML20046D204
| ML20046D204 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/11/1993 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20046D205 | List: |
| References | |
| RTR-NUREG-1434 GNRO-93-00088, GNRO-93-88, NUDOCS 9308160315 | |
| Download: ML20046D204 (10) | |
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U. S. Nuclear Regulatory Commission Mail Stop P1-37 Washington, D.C. 20555 Attention: Document Control Desk
Subject:
Grand Gulf Nuclear Station l
Docket No. 50-416 l
License No. NPF-29 Relocation of Loose Part Detection Instrumentation Proposed Change to the Operating License (PCOL-93/07)
Reference:
NUREG-1434, Revision 0 of the improved Standard Technical Specifications i
GNRO-93/00088 l
Pursuant to 10CFR50.90, Entergy Operations, Inc. is hereby proposing to amend Operating License NPF-29 for the Grand Gulf Nuclear Station (GGNS) by incorporating j
the enclosed changes into the plant Technical Specifications. Specifically, the proposed changes would amend Technical Specification Section 3/4.3.7.10, entitled " Loose Part Detection System" by relocating Loose Part Detection Instrumentation from the Technical Specifications to our administrative control.
Guidance from the improved Standard Technical Specifications (NUREG-1434, Revision
- 0) recommends that the Loose Part Detection instrumentation and their associated LCO i
l and surveillances may be relocated from the Technical Specifications to other controlled i
plant documents. Consistent with this guidance, we propose to relocate the Loose.
Parts Detection Instrumentation currently listed in the Technical Specifications to our l-administrative control.
This proposed amendment is being submitted as part of the cost beneficiallicensing action (CBLA) program established within NRR where increased priority is granted to license requests for changes requiring staff review that involve high costs without a commensurate safety benefit. Ultimately, our goal is to evaluate the Loose Part Detection Instrumentation against regulatory and safety requirements and eliminate overly restrictive redundancy under 10CFR50.59 while maintaining an equivalent level of protection.
Since the proposed changes are consistent with the improved Standard Technical Specifications, we believe that the NRC resources necessary to review this proposal are l
. not significant. Nonetheless, in order to provide the NRC with a means to prioritize the Entergy Operations CBLA requests, should a resource conflict occur between this I
request and any other Entergy Operations CBLA proposal, the other proposal should take precedence.
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-9308160315 930811-E h{
PDR _ADOCK 05000416
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GNRO-93/00088 Page 2 of 5
- provides a detailed description of the proposed changes, justification for the changes, and the No Significant Hazards Consideration in accordance with I
10CFR50.92. As stipulated by the provisions of 10CFR50.4, Attachment 3 contains i
the original marked up Technical Specification and bases pages reflecting the proposed changes. A copy of the proposed changes is provided for information in Attachment 4.
l The proposed changes have been reviewed and accepted by the Plant Safety Review Committee and the Safety Review Committee. A copy of this proposed change to the operating license has been provided to the State of Mississippi in compliance with the -
requirements of 10CFR50.91(B)(7)(b).
This amendment request is being filed without the required affirmation. The affirmation referenced in Attachment 1 will be provided promptly.
1 Should you have any questions, please contact C. E.' Brooks at (601)437-6555.
H/R J/rsj a
ments:
- 1. Affirmation per 10CFR50.30 (Not included)
- 2. GGNS PCOL-93/07
- 3. Marked Up Technical Specification Pages
- 4. Information Copy of PCOL-93/07 cc:
(See Next Page)
i August 11, 1993 I
GNRO 93/00088 Page 3 of 5 cc:
Mr. R. H. Bernhard (w/a)
Mr. H. W. Keiser (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. Stewst D. Ebneter (w/a)
Regional Adniinistrator U.S. Nuclear Regulatory Commission Region ll 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 Mr. L. T. Marsh (w/a)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 Dr. Eddie F. Thompson (w/a)
State Health Officer State Board of Health P.O. Box 1700 Jackson, MS 39205
4 to GNRO-93/00088 Page 1 of 1
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I This amendment request is being filed without the required affirmation. ' We will follow up promptly with the required affirmation.
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' PROPOSED CHANGE TO THE OPERATING LICENSE LOOSE PART DETECTION SYSTEM (GGNS PCOL-93/07).
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- to GNRO-93/00088 Page 2 of 6 A.
SUBJECT:
Loose Part Detection System Affected Technical Specifications: 3/4.3.7.10, B 3/4.3.7.10 Affected Technical Specification Pages: 3/4 3-90, B 3/4 3-6 B. DISCUSSION:
The Loose Part Detection System (LPDS) is a non-safety related system used to monitor and detect loose parts within primary plant systems which interface with the reactor vessel. As discussed by GGNS FSAR section 4.4.6.1.4, the LPDS is intended to be used for informational purposes only by Plant Operations personnel.
The system is not solely relied upon for performance of any safety related activities.
The present system consists of sixteen sensors (accelerometers) located at various points on the extemal surface of the primary system. Eight of the sensor locations are designated as " active" channellocations, and are continuously monitored on-line by the system. The " active" sensors are supplemented by eight " passive" sensors, which are located in equivalent locations.
The current LPDS surveillance requirements implemented by Technical Specifications consist of the following:
- a. CHANNEL CHECK at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
- b. CHANNEL FUNCTIONAL TEST at least once per '31 days
- c. CHANNEL CAllBRATION at least once per 18 months The associated LCO 3.3.7.10 does not require entry into an Action Statement but requires submittal of a Special Report to the Commission within ten days if one or more LPDS channels are inoperable for more than thirty days.
The proposed change consists of relocating the stated surveillance requirements in its entirety to our administrative control as complemented by the improved Standard Technical Specifications, NUREG 1434, Revision O. Our ultimate goal is to evaluate the LPDS and eliminate overly restrictive redundant monitoring capability under 50.59. Implementation of the proposed change would maintain an LPDS testing program and an LPDS preventative maintenance program, which uses the vendor manual instructions as a bases for the remaining monitors.
C. JUSTIFICATION:
The LPDS testing program currently implemented by GGNS Technical Specifications is based on Regulatory Guide (RG) 1.133, The Regulatory Guide requires LPDS sensors to be strategically located on the exterior surface of the Reactor Coolant
- Pressure Boundary (RCPB).
, to GNRO-93/00088 i
Page 3 of 6
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i The FSAR defines the RCPB as the area containing the following components:
Nuclear boiler system Main steam j
Feedwater Reactor recirculation Reactor water cleanup Control rod drive Reactor core isolation cooling Standby liquid core spray j
Low pressure core spray l
High Pressure core spray Residual heat removal Main steam isolation valve leakage control Feedwater leakage control The sensor locations equivalent to the systems described above installed at GGNS l
include the following:
Reactor vessel bottom control rod
( 2 Active,2 Passive )
Recirculation Water 'A' Pump suction
( 1 Active )
Recirculation Water 'B' Pump suction
( 1 Active )
Recirculation Water 'A' Pump discharge
{ 1 Passive )
Recirculation Water 'B' Pump discharge
( 1 Passive )
Feedwater 'A' inlet pipe
( 1 Passive )
i Feedwater 'B' inlet pipe
( 1 Passive ).
High Pressure Core Spray (HPCS)
( 1 Active )
inlet pipe-Low Pressure Core Spray (LPCS)_
_ ( 1 Active )
inlet pipe-Steam Outlet 'A' pipe
( 1 Active )
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Steam Outlet 'B' pipe
( 1 Active )
Steam Outlet 'C' pipe-( 1 Passive )
l Steam Outlet 'D' pipe
( 1 Passive )
i Conformance to RG 1.133 is discussed by AECM-86/0335 dated November 25, 1986 which was provided in response to GGNS Operating License Condition 2.C(14).
ii The functional capability of the LPDS systern components as discussed by the GGNS.
FSAR conforms to necessary seismic qualifications and functional operability i
requirements in harsh environments considering scceptability of equipment located in the drywell or other areas of high temperature / humidity although the system is not included in the Equipment Qualification ~ Program.
The functional reliability of the system has been demonstrated by the_systern maintenance history which normally_ utilizea approximately 120 man-hours of
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maintenance time per year. Past history 'also reveals a limited number of system j
failures since commercial operation of GGNS.
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Page 4 of 6 e
Although the reliability of the system components reveals a low failure rate, the i
system indications are not always indicative of a loose part due to sensor sensitivity l
which may detect other system noise.
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On February 6,1987, the NRC published its Interim Policy Statement on Technical Specification improvements for Nuclear Power Plants in the Federal Reoister (52 FR 3788). In late 1987, based on the Interim policy Statement, each of the four nuclear steam supply system (NSSS) owners groups submitted proposals identifying requirements in the existing Standard Technical Specifications (STS) that could be relocated from the TS to licensee controlled documents.
.i The staff reviewed these submittals and published its conclusion in the report "NRC Staff Review of Nuclear Steam Supply Vendors Owners Groups' Application of the Commission's Interim Policy statement Criteria to Standard Technical Specifications" (Split Report) dated May 9,1988.
The NRC Interim Policy Statement provides criteria to be utilized in determining which requirements need to be governed by TS. The goal is to assure that TS requirements are consistent with 10CFR50.36 and have a sound safety basis. The split report identified which STS requirements must be retained in the new STS (having met one or more criteria) and those requirements which could be relocated i
(having met none of the criteria).
i Following the guidance of the split report, the owners groups proposed improved STS which were subsequently approved and published by the staff as improved STS NUREG reports.
j NEDO-31466 " Technical Spacification Screening Criteria Application and Risk l
Assessment" dated November 1987, designated the Loose Part Detection System instrumentation LCO as a TS which may be relocated. This was reviewed and approved by the staff in the Split report. Therefore, GGNS proposes to relocate Loose Part Detection System Instrumentation requirements consistent with the NRC.
approved TS improvements. Upon approval of this change, LPDS currently located in the TS will be relocated to our administrative control and governed under the rigorous provisions of 10CFR50.59.
D. NO SIGNIFICANT HAZARDS CONSIDERATIONS:
Surveillance requirement 4.3.7.10 would be revised to relocate the present operability testing, channel check, and calibration requirements as stipulated in the improved Standard Technical Specifications, NUREG 1434, Revision O.
The testing requirements relocated to our administrative control will continue to be j
implemented by administrative procedures and the preventative maintenance program. The relocated requirements will be adequately controlled via the administrative requirements of Technical Specification 6.5.3. Those requirements i
include review of changes for unreviewed safety questions in accordance with the provisions of 10CFR50.59.
I
~ to GNRO-93/00088 Page 5 of 6 The Commission has provided standards for determining whether a no significant hazards consideration exists as stated in 10CFR50.92(c). A proposed amendment to an operating license involves a no significant hazards consideration if operation of the !acility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
Entergy Operations Inc. has evaluated the no significant hazards considerations in its rcquest for a license amendment. In accordance with 10CFR50.91(a), Entergy Operations Inc. is providing the analysis of the proposed amendment against the three standardt in 10CFR50.92(c). A description of the no significant hazards considerations determination follows:
- 1. The roposed change does not significantly increase the probability or con ences of an accident previously evaluated.
The proposed change relocates Loose-Part Detection System instrumentation requ;tements from the TS to plant administrative control consistent with the NRC Interim Policy Statement on Technical Specification improvements. Criterion 1 of the Policy Statement indicates that the TS should include installed instrumeatation that is used to detect, and indicate in the control room, a significant degradation of the reactor coolant pressure boundary. This criterion is intended to ensure that the TS control those instruments specifically installed to detect excessive reactor coolant system leakage. This criterion is not interpreted to include instrumentation used to detect precursors to reactor conlant pressure boundary leakage (e.g., Loose Part Detection Instrumentation). The proposed-change does not affect any rrv srial condition of the plant that could directly contribute to causing or mitiv e g the effects of an accident. Therefore, the proposed change will not invoi a significant increase in the probability or consequences of any accident ;aeviously evaluated.
- 2. This change would not create the possibility of a new or different kind of accident from any previously aralyzed.
The proposed change which does not involve any plant design changes (i.e.,
administrative only) will be adequately controlled by the 10CFR50.59 process which would not allow requirement or system modifications which would place the plant in an unanalyzed condition. The proposed change will not alter the operation of the plant nr the manner in which it is operated. Therefore, the proposes change will create the possibility of a new or different kind of accident from any previously evaluated.
Further, the evaluation summarized in NEDO-31466 determined the loss of this instrumentation to be a non-significant risk contributor to core damage frequency and offsite release.
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- 3. This change would not involve a significant reduction in the margin of safety.
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l The system maintenance history reveals that the reliability of the system is adequately demonstrated by the low failure rate of system components.
The proposed change will relocate Loose Part Detection System instrumentation from the TS to our administrative control. The proposed change will have no l
adverse impact on the reactor coolant system pressure boundary nor will any
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other system protective boundary or safety limit be affected. Therefore, the proposed change will not involve a significant reduction in a margin of safety.
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Based on above evaluation in accordance with 10CFR50.92(c), Entergy Operations, Inc.
has concluded that operation in accordance with the proposed amendment involves no significant hazards considerations.
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