ML20058P454

Safety Evaluation Supporting Amend 69 to License NPF-29

ML20058P454
Person / Time
Site:	Grand Gulf
Issue date:	08/14/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20058P448	List: ML20058P444 ML20058P454
References
GL-87-09, GL-87-9, NUDOCS 9008170064
Download: ML20058P454 (7)

Text

'=d%,poog)\\

UNITED STATES NUCLE AR REGULATORY COMMISSION

{

0 e

x... *,]

E wAsmncN o.c.rosss e

e j

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION glATED TO AMENDMENT NO. 69 TO FACILITY OPERATING LICENSE NO. NPF-29 ENTERGY OPERATIONS, INC.

GRAND G_ULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-41,6

1.0 INTRODUCTION

-l By letter dated August 19, 1988, the licensee (System Energy Resourcer, Inc., before June 6,1990, and Entergy Operations, Inc., en or after June 6, 1990), requested an amendment to Facility Operating License No. NPF-29 for the Grand Gulf Nuclear Station, Unit 1.

The proposed amendment would change the Technical Specifications =(TS) in accordance with the guidance provided in Generic Letter L ()- 87-09, "!vction 3.0 and 4.0 of_ the Standard Technical Specifications (STS;.n the Applitability of Limiting Conditica. for Operation and Surveillance Requirements.". The general L

requirements in TS 3.0.4 applicable to each Limiting Condition for Operation (LCO) within Section 3.0 are changed to allow operational condition changes vithout meeting the LCO requirements provided the remedial actions in the associated action statements do not require reactor shutdown if the LCO is not met in a spacified time.

For those TSs which previously.had an exception to TS 3.0.4, the cucption has been deleted because the change in TS 3.0.4 achieves the same effect by itself.

For applicable TS which did not previously have an exception to T3 3.0.4, the change in TS 3.0.4 provides

-increased operational flexibility. TS 4.0.3 was changed to allow up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> additional time to run missed surveillance tests.

TS 4.0.4 was changed to clarify thet it does not prevent changing cperational conditions to comply with action requirements.

The Bases for TS 3.0 and 4.0 were changed to.

reflect the changes in the TS.

Generic Ltt.ter 87-09 provides an acceptable solution for three operational problems rencoentered with the general requirements in the Technical Specifications (TS) for reactocs

(1) Change TG 3.0.4 to allow entry into an Operational Condition (OC) whea the Limiting Condition for Operation-(LCO) requirements are not met, provided the associated Action does not requirs reactor shutdown; (2) Change TS 4.0.3 to allow an additional time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,for performing a Surveillance Requirement (SR) wMn a surveillance interval is inadvertently

_.<ceeded; and (3) C'larify TS 4.0.4 by explicitly stating that entry into an OC to comply with action requirements shall not be prevented even though SR test intervah are exceeded.

The staff has.provided certain positions and acceptable changes to the TSs and Bases in Generic Letter 87-09.

?005170064 9nos!4 (DR ADOCK 03000416 F

q FDC i

i m

w

By letters dated October 6, 1988, November 25, 1988 and January 17, 1989, the staf f requested that a safety analysis be provided for each TS that would provide new operating flexibility as a result of the change to TS B 3.0.4.

The staff also requested a description of administrative controls or maintenance to assure that plant outage activities and plant starting would usually be conducted when all equipment required by LCOs in the TS is operable.

In response to these requests, the licensee provided supplemental information by letters dated November 9, 1988, December 14, 1988 and March 28, 1989.

These letters also clarified that the requested changes to TS 3.0.4, TS 4.0.3 and TS 4.0.4 were intended to be identical to those recommended in Generic Letter 87-09.

During its review of the licensee's submittals, it became evident that a large number of new reliefs from Ts 3.0.4 were possible from the change of the general requirements in TS 3.0.4.

The intent cf Generic Letter 87-09 is that such reliefs be used sparingly.

Furthermore, preparation p

and review of a safety analysis for each relief possible under the new TS 3.0.4 wouW require an extensive and unnecessary ef fort by the licensee and staff.

As an alternative, a written safety analysis could be prepared by the licensee prior to each use of a relief made possible l

under the proposed TS 3.0.4, using administrative controls similar to l

l those used for safety analysis pursuant to 10 CFR 50.59.

l By letters dated May 22, 1989, and February 14, 1990, the staff advised l

the licensee that it would not review the safety analysis submitted for

)

each TS 3.0.4 *elief made possible by the proposed license amendment implementing beneric Letter 87-09.

The staff requested the licensee to provide a description of the administrative controls that would be used I

to require safety analyses for each TS 3.0.4 relief prior to its use.

By letters dated July 27, 1989, April 6, 1990, and May 23, 1990, the l

licensee provided information regard:ng its administrative program for l

implement'.ng the proposed amendment.

The staff's review of this program

)

is derer10ed in this safety evaluation.

The staff has not reviewed the h

safety analysis for e u h possible relief contained in the licensee's submittals.

Safety analyses for each TS 3.0.4 relief used should be retained by the licensee for possible NRC audit.

1 c

By letter dated Au;;est 10, 1990, the licensee tsquested deletion of a paragraph in the previouuly proposcd Bases for TS 3.0.3 to clarify this section of the Bases.

l i

Q-L

{

\\

i i. mu mmimummmm-mumme

The licensee's revised application provided additional information regarding-implementation of'the proposed amendment but did not-significantly alter the action previously noticed or affect the description of the action published in the Federal Register on October 19, 1988 (53 FR 40980).

2. 0 EVALUATION The present TS 3.0.4 specifies, in part, that " Entry into an Operational Condition or other specified condition shall not be made unless the conditions fcr the Limiting Conditior, for Operation are met without

-reliance on provisions contained in the Action requirements."- The staff position in GL 87-09 is that this TS, as presently written to exclude reliance on provisions contained in the Action requirements, unduly restricts facility operation when conformance to the Action requirements-provides an acceptable level of safety for continued operation.

For an LCO that has Action requirements permitting continued operation for an unlimited period nf time, entry into an operational condition or other spectiied candition of operation she'Ad bc permitted in accordance with those Action requirements.

The restriction on a change in operational condition or other specified conditions should apply only where the Actics requirements establish a specified time interval in which the LCO must be met or a shutdown of the facility would be required.

However, notSing in the staff position should be interpreted as endorsing or encouraging a plant startup with inoperable equipment.

The staff' believes that good practice should dictate that the plant startup should t

normally be initiated only when all required equipment is operable and

]

that startup with inoperable equipment must be the exception rather than the rule.

In accordance with this position,. the staff recommended in GL 87-09 the

-l following change to replace the first sentence of TS 3.0.4:

" Entry into.an OPERATIONAL CONDITION'or other specified condition

-l shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not mat within a specified time interval.

Entry into an OPERATIONAL CONDITION or other specified condition may be made in accordance with the ACTION requirements when conformance to thein permits continued operation of.the facility for an unlimited

.l period of time."

The licensee's proposed change to TS 3.0.4 conforms to the above staff recommendation.

i l

l

.1

.1

(-

j L

l,

L 4..

x The revised TS 3.0.4 eliminated'the need for exceptions to it in TS for a number of individual systems.

For such systems, the exceptions to TS 3.0.4 are deleted in the proposed TS changes.

Since these deletions are consistent with the revised form of TS 3.0.4, we find that they are c:ceptable.

l The basis for accepting the proposed change to TS 3.0.4 is that the licensee will have administrative controls to assure:

(1) that for each TS 3.0.4 relief to be used, remedial measures prescribed by the TS Action statement provide a sufficient level of protection tu permit entry into L

the Operational Condition and safe long term operation consistent with the Updated Fina) Safety Analysis Report (UFSAR), and (2) that plant startup with inoperable equipment required by the LCO will be the exception rather than the rule.

In its submittals, the licensee stated that prior to the use of the new TS 3.0.4 relief, written 10 CFR 50.59 safety evaluations will be performed in accordance with current l

administrative procedures, and reviewed by the Plant Safety Division Committee.

Present administrative procedures require documentation of the time when an Action statement is entered and when it is left.

This requiremtnt will continue for all Action stateme including those r

which do r.9t require reactor shutdown af ter an J outage time.

Adminircrat!ve procedures are used to control the priority of maintenance.

l l

-Work orders tv repair inoperable equipm.... required by an LCO receive a Priority I or 2. ' Priority 1 is reserved for equipment needed for plant safety oc availability and requires immed' ate continuous action on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l

basis. 'PriFrity 1 maintenance work orders are rare.

Priority'2 is the highest priority for most maintenance and includes work orders for inoperable l

equipment required by LCOs unless assigned Priority 1, Priority 3, 4. and 5 l

are assigned to routine work or long term scheduled modifications.

Present L

administrative procedures require that all equipment required by LCOs are l!

l

operable prior to startup.

The roposed change to TS 3.0.4 will permit startup r

with some inoperable equip 5ent.

However, maintenance work priority assignments will remain the same with the goal of having all equipment required by LCOs l'

to be operable prior to startup.

If any LCOs are not met and startup is not prohibited by the new TS-3.0,4, startup will require a written safety evaluation, concurrence of E

the Plant Safety Review Committee, and continuous effort to return the equipment to operability.

The Entergy Operations Vice President, 1

9perations - Grand Gulf has certified that the administrative controls described above are implemented and that the necessary training of operations personnel has been conducted.

i a -

. - - = -

- The staff concludes that the proposed change to TS 3.0.4 is acceptable because it conforms to GL 87-09. Administrative controls are in place to:

assure that for each TS 3.0.4 relief used,-remedial measures in Action statements will provide a level of safety consistent with the UTSAR and

. administrative controls are in place to ensure that plant startup with_

i inoperable equipment required by LCOs will be the exception rather than routine.

_ i Technical Speciiication'4.0.3 The present TS 4.0.3 state: that failure te perform a surya111cnce Requirement within the specified surveillance interval.shall constitute a

. failure to meet the operability requirements for a Limiting Condition for Operation. Thus, the TS requires the imediate implementation of the shutdown actions of TS 3.0.3.

In GL 87-09, the staff finds that it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. The majority of surveillances performed demonstrate that systems or compenents are operable. 'When a surveillance is missed, operability has not been verified by~the performance of the required surveillance but it is likely

~

that the equipment is operabis. Because the allowaH e outage time limits of sorae Action requiremersts do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the Technical-Specifications should include a time limit that would allow a deley of the required actions to permit the performance of the missed-

-l surveillance. This-time should be based on considerations of plant conditions, adequate planning, availability of per'scrinul, and the time.

required to perform the surveillance, as well as the safety significance delay in completion of the survei_11ance. The staff concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Actior requirements are less'than this time limit or when shutdown Action requirements-i apply.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action requirements before the surveillance can be completed.

On the basis of these considerations, the staff recommended in GL 87-09 1

the.following revised version of TS 4.0.3:

" Failure to perform a Surveillance Requirement within the allowed surveillance interval,-defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY recuirements for a

-Limiting Condition for Operaticn. The time limits for the ACTION requirements are applicable at the time it is identified th3t a Surveillance Requirement has not been performed. The ACTION l

t v

V.

.6-requirements may be delayed for up to 24 houn to pere.it the completion of the surveillance when the allenble outage time' limits of the-ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Surveillance Requirements do not have to be performed on: inoperable equipment."

In GL 67-09, the staff also recommended the deletion of the statement that-exceptions to TS 4.0.3 are stated in individual specifications.

This statement is deleted because TS 4.0.3 is always applicable and there are no exceptions for individual specifications.

The liransee's proposed change-to TS 4.0.3 is identica1'to the above staf f recommendation and is, therefore, acceptable.

Technical Specifications 4.0.4

.The present TS-4.0.4 requires that before a new Operational Condition is entered, Surveillance Requirements pertaining to the new Operational Condition are to be performed within time limits specified by TS 4.0.3.

A' conflict arises when Action requiremants require an Operational Condition change, but the Surveillance Requirements which become L

applicable in the Operational Condition have not been performed within the.specified interval so that TS 4.0.4 does not permit a change.

If an exception to TS 4.0.4 is allowed (e.g., for cases wheri tre Surveillance Requirements can only be completed after entry ' m the Operational Condition to which,they apply), there may still M 4 c>nflict L

~ with TS 4.0.3 if the Surveillance Requirements have not been ptmed l

vithin the allowed surveillance interval.

In GL 87-09, the staff took the position that the potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply with Action requirements.

It is not the intent of TS-4.0.4 to prevent passage through or to operational

~

l conditions to comply with Action requirements and it should not apply when changes are imposed by Action requirements. Accordingly TS 4.0.4 should be modified to note that its provisions shall not prevent passage through or to operational conditions as required to comply with Action requirements.

A similar provision is presently included in TS 3.0.4.

l l'

It-is not the intent of TS 4.0.3 that the Action requirements should preclude the performance of surveillances when an exception to TS 4.0.4 i

i is allowed.

However, since TS 4.0.3 has been changed to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of the Action requirements, an appropriate time limit now exists for the completion of those Surveillance j

requirements Ahat become applicable when an exception to TS 4.0.4 is allowed.

l l

Based on tnse considerations, the staff recommended in GL 87-09 that the L

following sentence be added to TS 4.0.4:

L "This provision shall not prevent through or to OPERATIONAL l

CONDITIONS as required to comply with ACTION requirements."

1 l

l l

- a

'~7-The licensee's proposed change to TS'4.0.4 is identical. to the.NRC staff's recommendation and is, therefore, acceptable.

Bases for TS 3.0 and TS 4.0 The licensee's proposed Bases for TS 3.0 and TS 4.0 are essentially the same as those recommended by the staff in GL 87-09 except for editorial changes to clarify their proper interpretation by licensee's operational personnel and deletion of an ambigious paragraph in the Bases for TS 3.0.3.

The staff has reviewed these differences from GL 87-09 and concludes they are acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.21, 51.32, and 51.35,.an environmental assessment and finding of no significant impact was prepared and published in the Federal Register on August 10, 1990 (55 FR 32712).

Accordingly, based upon the environmental assessment, the Commission has determined that the issuance of this amendment will not have a significant impact on the quality of the human environment.

4.0 CONCLUSION

The Commission has issued a Notice of Consideration of Issuance of Amendment to Facility Operating License and Opportunity for Hearfig which was published in the Federal Register on October 19, 1988 (53 FR 40980).

No petition to intervene or request for hearing has been filed on this action.

The staff 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, and

.(2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to the common defense and the security, or to the health and safety of the public.

Dated: August 14, 1990 Pr.incipal Contributor:

Lester L. Kintner

?

1-

-