ML20066E742

Application for Amend to License NPF-29,authorizing Deletion of Tech Spec 4.8.2.1.d.2 Re Specific Dc Battery Load Profiles

ML20066E742
Person / Time
Site:	Grand Gulf
Issue date:	01/11/1991
From:	Cottle W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20066E743	List: ML20066E742 ML20066E748
References
GNRO-91-00004, GNRO-91-4, NUDOCS 9101220226
Download: ML20066E742 (8)

Text

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l January 11. 1991 w. T. cotu.

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i i r U.S. Nuclear Regulat_ory Commission i

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Washington, D.C. 20555 j Attention: Document Control Desk {

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 f License No. NPF-29 <

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Removal of D.attery Load Profile Requirements '

Preposed Amendment to the Operating License (PCOL-90/11)-  ;

GNRO-91/00004 Gentlemen Entergy operations, Inc. is submitting by this: letter a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License.-

This proposed amendment requests a deletion from-the GGNS Technical Specifications (TS) of the specific DC battery load profiles specified in TS 4.8.2.1.d.2. The equivalent load profiles _are explicitly defined'in_ i the GGNS Updated Final Safety Analysis Report (UFSAR)._ By removing the- s battery load profiles from the TS TS-changes will not be required each time an emergency load is added_or deleted while the requirement to test to the design basis load profiles will still be preserved in the TS.

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.The proposed amendment is part of the corrective _ action discussed'in LER 90-012-00, submitted in AECM-90/0151, dated August 23, 1990..and a GGNS/NRC meeting held in the NRC's Rockville Maryland Offices on November 6, 1990,- 4 In accordance with the provisions of 10CFR50.4, the signed original ~of the requested amendment is enclosed. Attachment 2-provides the discussion and justification =to-support the requested amendment. This ,

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

• Based on the guidelines-presented in 1_0CFR50.92. Entergy Operations has concluded that this proposed amendment involves no significant hazards considerations.

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.G9012131/SNLICFLR - 1 ' '

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, January 11, 1991  ;

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i Entergy Operations. Inc. Is requesting action on this submittal by August 2. 1991 in order to complete the LER 90-012-00 corrective actions. ,

Yours truly, e o Nu:

J WTC/PRSimte i

attachments: 1. Affirmation per 10CFR$0.30

2. GGNS PCOL-90/11 cci Mr. D. C. Hints (w/a)

Mr. J. Mathis (w/a)

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

Mr. N. S. Reyncids (w/a)

Mr. H. L. Thomas (w/o)

Mr. Stewart D. Ebneter (w/a)

Regional Administrater U.S. Nuclear Regulatory Commission Region II 101 Harletta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner Project Manager (w/a)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Hall Stop 11D21 Washington, D.C. 2055$

Dr. Alton B. Cobb (w/a)

State Health officer State Board of Health P.O. Box 1700 Jackson, Mississippi 39205 l

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BEFORE Tile i UNITED STATES NUCl, EAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. $0-416 IN Tilt MATTER OF MISSISSIPPI POWER 6 LIGilT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTil MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.

6.EEIRHAIIDN 1, W. T. Cottle, being duly sworn, stato that. I am Vice President.

Operations GONS 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 Commisalon, thin application for amendment of the Operat.ing License of the Grand Gulf Nuclear Station;

, that I signed this application as Vice President, Operations GGNS of l Entergy Operations, Inc.; and that the statomonta made and the matters set forth thoroin are true and correct to the best of my knowledge, information and bollof. ,

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_ w f~~~~C= w W. T. Cottle STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIt!ED AND SWORN TO before me, a Notary iblic, in and for the County and Stato abovo named, thin 119 day of U n>>>>w u( . , 1990.

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Q Notary Pudlic Hy commission expiros:

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09012131/SNLICFLR - 4

Attachoont 2 to GNRG-91/00004' )

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l A. SUBJECT 1 1

1. NL-90/07 Removal of Battery Lond Profile Requirements

2. Affected Technical Speciffentionst

a. Surveillance Rog'11romont 4.8.2.1.d - Page 3/4 8 12

! b. Bases 3/4.8.2 .Page B 3/4 8-2 B. DISCUSSION

1. The requested change rovlsos Survoillanco Requirement 4.8.2.1.d of the Grand Gulf Nuclear Station (GGNS) Technical' ,

Specifications (TS). The DG battery load profiles speciflod in TS 4.8.2.1.d are doloted and replaced with a statement in .the Bases for TS 3/4.8.2 that states _the DC battery load profiles are defined in the GONS Updated Final Safety Anelysis Report (UFSAR).

2. On July 24, 1990 during a design basis review of the Division.III 125 volt DC system, it was discovered that calculations currently in progress did not demonstrate-t. hat the GGNS TS load profile for the Division III battery was greater than the actual load for.all periods. This condition was reported pursuant to 10CPRSO.73(a)(2)(1)(B) In LER 90-012-00 via AECH-90/0151,- dated August 23, 1990.

3. It was determined that the Division'III load profilo currently stated in TS 4.8.2.1.d.2.c (> 16 amporos: for the next 59 minutos) is non-conservative when compared w1th the actual ~

omorgoney load profile during the 1-60 minuto interval. As correctivo action, GGNS Immediately corrected the load profile-and successfully performed TS surveillance 4.8.2.1.d.2.c_ using the corrected profilo.

4. Part of the followup action associated with' the condition reported is to-amond the TS to remove the battery > load profiles.

• This proposed TS chango is in response to the correctivo. action-associated with LER 90-012-00 and -as discussed with the Staff at the November 6, 1990 GGNS/NRC mooting.

5. It should he noted that the ievision of the TS is not necessary to address any safety concerns associated with the reported condition. The interim administrativo controls which have been 1.nplemented ensure that the correct-load profile is used to test the operability of the Division III battery, i

6. :The load profilos for all three divisional batterles aro speci fied in TS 4. 8. 2.1.d. 2. . To eliminato the need to reviso

-those TS load profiles each_timo an emergency load is added or--

doloted, it is proposed that .the detallod'11 sting of the load' profiles be doloted from the TS.

09012131/SNh1CFLR - 5

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Attachment 2 to GNRO-91/00004 ]

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7. Specifically, the following TS changes are proposou

n. Survo111ance Requirements 4.8.2.1.d.1 nd 4.8.2.1.d.2 are combined into one Surveillanco Roquf* ent and the battery i load proflies are deleted.

b. Bases 3/4.8.2 la revised to define the simulated load profile that is used in combined TS 4.8.2.1.d. The simulated load picfile is doffned as the equivalent to the actual emergency load ptaillo and is based on anticipated  :

operations requi ed after an AC power loss during accident conditions as described in the UFSAR. In addition, a atatement is added specifying ihat the UFSAR defines the simulated emergency load profiles for the throc divisional batteries. The UFSAR was revised December 1, 1990 to reflect the corrected Division III battery load profile.

8. The affected TS pagos are attached and marked up to reflect the proposed changes describnd above.

9. The requested licenso amendment. has been developed in a manner consistent with other recent license amendments approved by the:

NRC (e.g. , Commonwealth 1:dison's LaSalle County Station, Units .1 and 2 and Alabama Power's Fariny Nuclear Plant,-Units 1 and 2).

As with these other facilities, the deletion of tho battery load-profiles from the TS contributos to .ngoing efforts to upgrade the TS into a more usable and loss cumbersomo document, while maintaining control over changes made to the profiles.

C. JUST1FICATION 1, 125 volt DC power is required for emergency lighting; diesel generator field flashingt control and switching functions; control rolays; and annunciators and the Class 1E invert. ors as well as power to DC components used in the reactor core isolation cooling system. The divisions that are essential to ,

the safe shutdown of the reactor are supplied from throo independent 125 volt DC systems, A, B and C. The 125 volt DC systems A. B and C are for supplying DC power to Divisions 1, 2 and 3 respectively. UFSAR Tables 3.3.-6, 8.3-7 and 8.3-8 list the peak amporage requirements per time interval af ter an AC power loss during' accident conditions for each of the three DC systems.

2. The TS changes proposed involvo no changes to the operability requirements currently reflected'in the GGNS TS. - The frequencies of current TS Surveillance Requirements remain unchanged by the proposed amendment. -- The deletion of the TS battery' load profiles and the use instead of the UFSAR to contain the load profile information constitutes an administrativo revision to the TS. The operability and l surveillanco requirements for the DC electrical power sources

remain in the TS. The dolotion of the TS battery load profiles

( and the uso-of the UFSAR removes an administrativo burdon from -

the NRC and GGNS by no longer requiring that-n license amondment.

bo sought to change information In' the battery load profilos.

09012131/SNLICFLR - 6 l

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Attachment 2 to CNRO-91/00004 Pego-3

3. As with all information in the UFSAR, changos to information in UFSAR Tables 8.3-6, 8.3-7 and 8.3-8 raquire a documented review i in accordance with 10CFR$0.59. Those changes must be reported to the NRC in the annual report submitted pursuant to

- 10CFR50.59, as well as the annual UFS/R updato required by 10CFR50.71(c).

4. There are no UFSAR changes associated with the proposed TS changen. All necessary changes were included in UFSAR Revision 5 which was submitted December 1, 1990. Listings of the battery load profiles will continue to be maintained in the UFSAR Tables 8.3-6, 8.3-7 and 8.3-8. Those tables are updetod annually as changes are made in accordance uith 100FR$0.71(c).

5. Except for the Division III 1-60 minuto interval, the difforences between the current TS profiles and the UFSAR load profiles is tho allowanco that was added to the TS numbers to allow for any minor equipment changes or additions without -

nooding to revise the TS. With the profiles removed from the TS the additional allowanco is no longer nteded since the UFSAR can be changed under the provisions of 10CFR50.59. Thoroforo, t.ho UFSAR can contain the calculated profilo values without including any allowanco for load changos.

6. No design changes are associated with the proposed TS changes.

The design basis of the DC power system and Its interfaces with other systems remain unchanged. Design changes which potentially affect the loading of the batto. fos are forwarded to the approprinto work groups for review to determino the impact upon the battery load profiles. The process for controlling changes to the battery load proflies has not boon changed and remains the same regardless of the locat.fon of the load profiles (UFSAR or TS).

7. Deletion of the load profiles from the TS will not change the survoillance testing of the bat,teries as currently being performed. The proposed TS states that the batteries shall be subjected to surveillance testing using an equtvalent load profile based on anticipated-operatJons as described in the UFSAR. Referencing the UFSAR load profiles in the TS Basos will ensure that the bottorios are subjected to a design basis load profile service test. As battery service testing will still br required to ho performed in a mannor which will demonstrato their operability for design basis events, the proposed changes are considorod administrativo in nature and do not -Impact the technien1 basis used to support the safe operaticn of the facility.

D. NO SIGNIFICANT llAZARDS CONSIDERATIONS The proposed amonilment revises the TS by doloting the 150 batter, load profiles shown in TS 4.8.2.1.d.2. in addition, the Bases are revised to include a description of the simulated omergency load profit , and their definition In t.be UFSAR.

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Attacnment 2 to GNRO-91/00004 i Pege 4  :

The Commission has provided standards for determining whether a no significant harards consideration exists as stated in 10CFR50.92(c).

A proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance ,

with the proposed amendment would not: (1) involvo a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a now or i dif ferent kind of accident from any accident previously evaluated; or (3) involvo a significant reduction in a margin of safety.

Entergy Operations has ovaluated the no significant hazards '

considerations in its request for a licenso amendment. In accordance with 10CFR50.91(a). Entorgy Operations is providing the analysis of the proposed amendment against the throo standards in 100FR50.92:

1. No significant increase in the probability or consequences of an accident previously evaluated results from this chango.

a. Because battery tost.ing will still be required to bo performed in a manner which will demonstrate their 4

operability for the design basis event and that the process for controlling design chantis to the load profiles-remains unchanged, thoso TS changes do not impact operation of the facility,

b. Thorofore, the probability or consequences of previously -

analyzed accidents ato not increased, i

2. The chango would not create tt.s possibility of n'now or different kind of accident from any previously analyzed,

n. The proposed chango does not reflect the addition or delot. ion of any plant hardware. In addition, no new modos of plant operation or testing are introduced.

b. Thoroforo, operating the plant with the proposed chango will not create the possibility of a now or different kind of accident from any accident previously evaluated.

3. This chango would not involvo a significant reduction in the margin of safety,

n. Safety margin is established through the GGNS safety analyses as reflected in.tho TS, Limiting Conditions for Operations, and the Bases.

The proposed change preserves all assumptions and'results of the. safety analyses,

b. Surveillance requirements for demonstrating.the operability of the station batteries are still based on tho" recommendations of Regulatory Guide 1.129 and IEEE-Standard 450-1980. The batteries are still required to

.iomonstrate the abillty to carry loads required under design basis emergoney conditions.

09012131/ENhlCFLR - 8

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Attachment 2 to GNRO 91/00004 Page 5

c. In addition, the requirements of 10CFR50.59 will continuo to i ensure that changos that are modo to the UFSAR load profilos '

will be reviewed and a safety evaluntwn completed in accordance with 1001 R50.59.

d. Thorofore, this change will not involvo a reduction in the mnrain of safety. ,

Thorofore, based on the abovo ovaluation, operation in accordance with the proponod-nmondment involves no nignificant harards considorntionn.

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