ML20059H601

Application for Amend to License NPF-29,consisting of Proposed Amend to OL PCOL-93/15,removing 2,324 Spent Fuel Pool Storage Limit & Allowing Full Use of Spent Fuel Storage Spaces

ML20059H601
Person / Time
Site:	Grand Gulf
Issue date:	01/13/1994
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059H604	List: ML20059H601 ML20059H606
References
GNRO-94-00012, GNRO-94-12, NUDOCS 9401310031
Download: ML20059H601 (10)

Text

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a_ENTERGY--

Entergy Operations,Inc.

eo eo 75c Port Gtson. MS 39150 TM 601437 2800 .

)- C. R. Hutchinson ~

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January 13, 1994 cet* 1 aam os ne swm j U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555  ;

Attention: Document Control Desk

Subject:

Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Spent Fuel Pool Storage Limit Technical Specification Change Proposed Amendment to the Operating License (PCOL-93/15)

References:

1. Entergy Letter dated May 06, 1985, AECM-85/0143 ,

2. Entergy Letter dated June 05, 1986,. -!

AECM-86/0176  :

3. NRC Letter dated August ~18, 1986, ,

MAEC-86/0264 .;

4. Entergy Letter dated November'01, 1991,

GNRO-91/00145

5. NRC Letter dated July 30, 1992, GNRI-92/00163

6. Entergy Letter dated November 08, 1993, GNRO-93/00131 GNRO-94/00012 Gentlemen: j In a letter dated July 30, 1992, the NRC provided a Safety <

Evaluation Report (SER) approving the one pump,'two heat-exchanger mode of operation of the fuel pool cooling i (FPCC) system as a means of insuring sufficient spent fuel pool ~ decay heat removal for a full pool (4348 assemblies) .

The SER placed a.' condition on final approval =. .This condition required ~Entergy Operations to submit

• verification theit the increased standby serviceLwater and FPCC flows required for this mode of operation are within '

the capability of the: systems. . The verification of required flow. rates was submitted in a letter dated.

November 08, 1993. Submittal of.the flow rate ..i verification brings final closureLof the spent fuel pool t cooling issues for Grand Gulf Nuclear Station'(GGNS). i However, a temporary. Technical Specifications (TS) limit-  !

on the number of-spent fuel assemblies to be stored in the~

spent fuel pool: remains. .

G9312081 94013100311940113 ADOCK,05000416- f PDR 4 -

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January 13, 1994 GNRO-94/00012 Page 2 of 4 Amendment 17 to the GGNS TS (August 18, 1986) limited spent fuel pool storage to 2324 of the available 4348 spent fuel storage spaces. With NRC approval of the'one pump, two heat exchanger mode of operation of FPCC as l' adequate for removal.of decay heat generated by a-full fuel pool, and verification of the increased flows ,

necessary for.this mode of operation,'the limit of 2324  ;

spent fuel assemblies is no longer necessary. Therefore, this letter request a change to the GGNS operating license to remove the 2324 limit and allow full use of the spent fuel storage spaces.

Attachment 2 provides a description of the proposed changes, associated justification, and the No Significant Hazards Considerations basis. Attachment 3 is a copy of i the marked-up TS pages, and Attachment 4 is.an information only copy of the proposed TS. Attachment 5 contains an information only copy of the marked-up improved technical specification-page.

In accordance with the provisions of 10CFR50.4, the signed original.of the requested amendment is enclosed. This ,

amendment request has been reviewed and accepted by the Plant Safety Review Committee and the Safety Review Committee.

If you have any questions concerning this PCOL, please contact James'Owens at (601) 437-6483. i Yours trul ,

.AY l l EKI/JEO/tc attachments: 1. Affirmation per 10CFR50.30

2. .GGNS PCOL-93/15 3-. Mark-up of Affected TS Page

4. Proposed TS Page (Information Only)

5. Information Only Copy of Improved TS Page ,

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January'13, 1994 '

GNRO-94/00012 ,

Page 3 of 4

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i cc: Mr. R. H. Bernhard (w/a)

Mr. H. W. Keiser (w/a).

Mr. R. B. McGehee (w/a) _

j Mr. N. S. Reynolds (w/a) ll Mr. H. L. Thomas (w/o)  !

Mr. Stewart D. Ebneter (w/a)'

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Regional Administrator ,

U.S. Nuclear Regulatory Commission l Region II i 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 Dr. Eddie F. Thompson (w/a) I State Health Officer State Board of Health P. O. Box 1700 Jackson, Mississippi- 39205- ,

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Y G9312081.

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION ,

LICENSE NO. NPF-29 -

4 DOCKET NO. 50-416 ,

IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and l SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION "

and ENTERGY OPERATIONS, INC.

IkFFIRMATION ,

I, C. R. Hutchinson, being duly sworn, state that I am Vice President, Operations GGNS of Entergy Operations, .Inc.; that on.

behalf of Entergy Operations, Inc., System Energy Resources, Inc.,

and South Mississippi Electric Power Association I am authorized by .

Entergy Operations, Inc. to sign and file with the Nuclear-Regulatory-Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed-this application as Vice President, Operations GGNS of Entergy Operations, Inc., and that-the statements made and the matters set f rth t ereip te true and correct to the best of my knowledg in Inat , ap8 _ lief.

- / b4 Cf R. Hufchinson STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the Coynty and-State above named, this /Ald day of  ;

(h winLu. , 1994.

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(SEAL) 1 8Af 2 f

• My commission expires:

My Commission Expires November 11.1996 G9312081

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'. i ATTACHMENT 2 TO GNRO-94/00012 i

GGNS PCOL-93/15

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Attachment 2 to GNRO-94/00012

, Page 1 of 5 s t A.

SUBJECT:

1. PCOL-93/15: Modification of Spent Fuel Pool Storage Capacity Limit -

2. Affected Technical Specifications:

a. Spent Fuel Pool Storage Capacity, 5.6.3.a, Page 5-6. '

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b. Footnote, Page 5-6.

B. DISCUSSION:

1. Amendment 17 to the Grand Gulf Nuclear Station (GGNS) Operating License approved the replacement of the existing spent fuel pool ,

storage racks with high density spent fuel

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storage racks. Use of these high density racks.

significantly increased the storage capacity of i the containment and spent fuel storage pools.

The added decay heat load from the. increase in fuel storage capacity raised questions about the capability of the fuel pool cooling and cleanup (FPCC) system to handle the extra heat load without excessive reliance on the residual heat '

removal (RHR) system for fuel pool cooling assist.  ;

2. In order to resolve concerns about adequate heat removal, Entergy Operations committed to propose ,

an engineering solution for adequate heat removal by the third refueling outage (RF03) and i further committed to implement this solution prior to restart from refueling outage five  :

(RF05). Notification of fulfillment of these commitments was provided in two Entergy; Operations-letters dated June 05, 1986 and  ;

November 08, 1991 respectively.

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3. Following several correspondences between the' [

NRC staff and Entergy Operations, the proposed  !

solution was approved pending verification of specified flow rates (Safety Evaluation Report dated July 30, 1992). The flow rates in question-were verified by test conducted during the sixth refueling outage and results of those test submitted in an Entergy Operations letter i dated November 08, 1993. '

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Attachment 2 to GNRO-94/00012 ,

Page 2 of 5 i

C. JUSTIFICATION:

The fuel pool cooling and cleanup system (FPCC) is designed to remove decay heat generated by the spent

• fuel assemblies and maintain the spent fuel pool ,

temperature below 140 F during. normal operation

without excessive reliance on RHR for fuel pool cooling assist. The FPCC is also designed to -

maintain adequate water level in the spent fuel pool to provide proper radiological shielding. The design of FPCC is such that no single active failure of equipment will cause an inability to (1)~ maintain i irradiated fuel submerged in water; or (2) reestablish normal fuel pool level; (3) or remove  !

decay heat from the pool. As outlined below, removal of the 2324 spent fuel assembly storage limit would not compromise the design basis of the FPCC.

Approval to install the high density spent fuel storage racks was provided in the SER contained in a ,

NRC letter dated August 18, 1986. The high density racks increased spent pool storage capability from ,

1270 assemblies to 4348 assemblies. The only  !

remaining NRC question concerning licensing of the 4348 spaces was the ability of the fuel ~ pool cooling system to handle the decay-heat generated by a full ,

fuel pool.

The outstanding question of the adequacy of decay  :

heat removal cap city of the FPCC was addressed in an  ;

Entergy letter dated November 01, 1991, when Entergy  ;

proposed its final solution to the decay heat removal .

question; that being the one pump,.two heat exchange

• mode of operation of the FPCC. An NRC letter dated July 30, 1992 approved Entergy's proposed solutirn j pending submittal of test results to verify that the 'i flow rates required for the solution were practical- i and feasible.. Outstanding questions were brought to final resolution by the Entergy letter dated November  :

08, 1993, which submitted the test results that  !

verified Entergy's solution to the heat removal question to be both practical and valid.

The November 01, 1991 letter also provided information to the effect that no single active  :

failure would prohibit the FPCC from performing its  !

design functions. >

G9312081

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. i Attachment 2 to GNRO-94/00012 >

Page 3 of 5 Based on the above justification, all outstanding questions concerning the adequacy of the decay-heat .

t removal capability of the fuel pool cooling system have been resolved. Therefore the 2324 spent fuel assembly limit should be removed and full use of the 4348 spent fuel assembly storage spaces'should be l allowed.

D. NO SIGNIFICANT HAZARDS CONSIDERATION:

The FPCC is designed to remove decay heat generated by the spent fuel assemblies and maintain the spent  :

fuel pool temperature below 140 F during normal operation without excessive reliance on the residual heat removal (RHR) system for fuel pool cooling

• assist. The FPCC is also designed to maintain adequate water level in the spent fuel pool to provide proper radiological shielding. The design of FPCC is such that no single active failure of equipment will cause an inability to (1) maintain -

irradiated fuel submerged in water; or (2) reestablish normal fuel pool level; (3) or remove decay heat from the pool. As outlined below, removal of the 2324 spent fuel assembly storage limit would i not compromise the design basis of the FPCC.

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 no significant hazards if operation of the facility in accordance with the  !

proposed amendment would not: (1) involve a .

significant increase in the probability of an accident previously evaluated; (2) create the '

possibility of a new or different kind of accident from any accident previously evaluated; (3) involve a significant reduction in a margin of safety.

Entergy Operations has evaluated the no significant hazards consideration in its request for a license amendment. In accordance with 10CFR50.91(a), Entergy  ;

Operations is providing the following analysis of the  ;

proposed amendment against the three standards in 10CFR50.92: ,

b G9312081 t

1 Attachment 2'to GNRO-94/00012  !

Page-4lof 5' g

1. No significant increase in the. probability or  :

consequences of an accident previously evaluated ,

results from this change.

The NRC approved the installation of high density spent fuel storage racks in' Amendment 17 to the Grand Gulf Nuclear Station (GGNS)- i

. Operating License. This amendment also brought  ?

GGNS into compliance with Standard. Review Plan criteria which required maintaining the spent fuel pool at- less than or. equal:140 F. The '

140 F Technical Specifications (TS)-limit i remains in'effect thereby preventing operation at excessive temperatures.

The only outstanding question from Amendment 17,

• which resulted in a 2324 assembly technical specification limit, was whether the' fuel' pool j cooling system could handle the heat load of a full fuel pool without excessive reliance on 6 residual heat removal for extensive fuel pool-cooling assist. Entergy Operations' proposed- t solution to this question was accepted in the NRC's letter dated July 30, 1992.. -The NRC accepted the solution pending submittal of results from tests to verify the specified' -

flows. These results were submitted in a letter-dated November 08, 1993.

With previous approval of the installation of >

the high density spent fuel storage. racks, the. ,

confirmation:of adequate heat' removal j capability, and the .140*F TS temperature" limit, l' rdnc'al of the 2324 limit _to~ allow' full use of-the rpent fuel pool would not cause an increase- 1 in tue probability or consequences'of an ,

,ccident previously evaluated. l

2. 'This change would not createfthe possibility of. '

a new or different kind of accident from any -j previously evaluated.  :

The additional heat load generated by a full spent fuel pool (4348 assemblies) was evaluated.

The evaluation concluded that full use of the spent fuel pool storage spaces would not' exceed the temperature-limits as are currently in place. I with the 2324 limit. The NRC letter dated July 30, 1992 and Entergy Operations letter dated.

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i Attachment 2 to G14RO-94/00012 Page 5 of 5 i

November 08, 1993 resolved all outstanding heat removal questions. Therefore, this change would not create the possibility of a new or different ,

kind of accident from any previously analyzed.

3. This change would not involve'a significant reduction in a margin of safety. '

Entergy Operations demonstrated in their November 01, 1991 letter that the fuel pool temperature could be maintained at or.below 140 F as specified in TS 3/4.7.9. This_ letter -

also demonstrated the ability to handle single  ;

active failures. Approval of measures outlined in this letter was provided in a Safety Evaluation Report contained in an~NRC letter dated July 30, 1992.

Given the 140 F maximum temperature requirement as contained in TS 3/4.7.9 and compliance with single active failure criteria, this change would not involve a significant reduction in a margin of safety.  !

Based on the 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. .

E.

REFERENCES:

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1. Entergy Letter dated May 06, 1985, AECM-85/0143

2. Entergy Letter dated June 05, 1986, AECM-86/0176

3. NRC Letter dated August 18, 1986, MAEC-86/0264

4. Entergy Letter dated November 01, 1991,.GNRO-91/00145 .

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5. NRC Letter dated July 30, 1992, GNRI-92/00163-

6. -Entergy Letter dated November 08, 1993,.'GNRO-93/00131 G9312081 j

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