ML20072S787

Revised TS 4.7.4.e,6.7.1.c,6.9.1,6.9.1.10 & 6.9.2 Re Functional Tests,Safety Limit Violation & Routine Reporting Requirements

ML20072S787
Person / Time
Site:	Grand Gulf
Issue date:	04/11/1991
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20072S784	List: ML20072S781 ML20072S787
References
NUDOCS 9104170074
Download: ML20072S787 (7)

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Attachment 2 to GNRO-91/00053 4

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'r PROPOSED CHANGE TO THE OPERATING LICENSE REVISIONS TO  ;

TS 4.7.4.e 6.7.1.c.-6.9.1, 6.9.1.10 & 6.9.2

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-PCOLBAB/SCMPFLR - 5 9104170074 910411 PDR ADOCK 05000416

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Attachment 2 to'ONRO-91/o0053 A. SUBJECT

1. NL-91/06 Compliance with Reporting Requirements 2.- Affected Technical Specifications:

a. -4.7.4.e -

Page 3/4 7-11

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b. 6.7.1.c -

'Page 6-14

c. 6.9.1 --Page 6-15 d._ 6.9.1.10 - Page 6-19 e . -- 6.9.2 -

Page 6-19 B. DISCUSSION-Entergy_ Operations, Inc. is requesting revision to the Grand Gulf '

Nuclear Station (GGNS) Technical' Specifications to remove recognized inconsistencies-between-the GGNS Technical Specifications (TS) and Section 50.4 of 10 CFR 50. The inconsistency was brought-about by a revision to Section 50.4 which superseded-the requirements contained

-in:tne GGNS TS. _ The specific requirements by the Comission were contained in Federal Register 51FR40303 and focused on reporting-

. reo ai renients.

The proposed amendment specifies.that submittal of reports-required =

by GGNS Technical Specific'tions e 4.7.4.e, 6.7.1.c, 6.9.1, and-6.9.2:

shall'be made pursuant to Section 50.4-~of 10 CFR 50. The addressee-presently specified-in~6.9.1;10 has been deleted to-. complement the D proposed change.to 6.9.1.

_ C. JUSTIFICATION' The details 'asipublished in 51FR40303 require that written communications;to the Commission pursuant to requirements of' 10 CFR 50 be submitted-in accordance with Section-50.4. This requirement was stated'to supersede all: existing' requirements in any license conditions or-technical specifications in effect on January.

Sc 1987.1 The proposed amendment has changed the former submittal-requirements to-specify that these written communications be submitted in accordance with Section 50.4. This change will: remove  !

the recognized inconsistency'between GGNS.TS and 10 CFR 50.4.

~Furthermore, specifying the submittal-requirement in this manner will preempt future amendment prornals necessary as a consequence ,

of chhnges to 10 CFR 50.4.-

D .- - SIGNIFICANT HAZARDS CONSIDERATION

-1. Entergy Operation, Inc. is proposing amendment to GGNS Technical Specifications in order to comply with reporting requirements of Section 50.4 of 10 CFR 50 as' detailed.in 51FR40303.

PCoLBAB/SCMPP R - 6 l ., L '. . , - - _.L,, - , :, -

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Attachment 2 to GNRO-91/00053

2. The Commission has provided standards for determining whether a no significant hazards consideration exists as stated in 10 CFR 50.92(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 sionificant increase in th probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident form any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

3. GGNS has evaluated the no significant hazards considerations in its request for a license amendment. In accordance with 10 CFR 50.91(a), GGNS is providing the following analysis of the proposed amendment against the three standards in 10 CFR 50.92:

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

The proposed changes are purely administrative in that they remove an administrative inconsistency between GGNS TS and 10 CFR 50.4 where the Commission has clearly stated that Section 50.4 takes precedent over_ existing technical specifications. Therefore, the proposed change cannot increase the probability or consequences of an accident previously evaluated,

b. This change would not create the possibility of a new or different kind of accident from any previously analyzed.

The proposed changes are editorial in nature and have no impact on plant equipment or operation other than reporting certain events to the Commission. Therefore, the requested revisions will not create the possibility of a new cr different accident from any previously analyzed.

< c. This change would not involve a significant reduction in the margin of safety.

The margin of safety is not reduced since the proposed changes are administrative in nature and do not impact plant equipment. No change to plant equiament will occur due to this proposal. These changes are aeing proposed to comply with the requirements of Section 50.4 of 10 CFR 50.

4. Based on the above evaluction, Entergy Operations, Inc. has concluded that operation in accordance with the proposed amendment involves nc significant hazards considerations.

PCoLBAB/SCMPFLR - 7

' PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) e, Functional Tests I writon nont 1r<2w s cAt d

.-N.caA EmpC 4 topucrm Sae.etb. pa shall W. wbWid During the first refueling shutdown and at eaIt r 18 months thereafter during shutdown, a representative sample of snubbers shall be tested using one of the following sample plans for each type of -

snubber. The sample plan shall be selected prior talha riod and cannot be changed during the test period. NRG-Aeg+ona

-Adm+ninea to e-sh*H-be-not444 e44n-writ 4 ng-o f-@the-s &ap 4 plen-s ele prior to the test teriod or the sample plan used in the prior test period shall be in.plemented:

1) At least 10% of the total of each type of snubber shall be functionally tested either in place or in a bx:h test. For each snubber of a type that does not meet the functional test acceptance criteria of Specification 4.7.4 f, an additional 5%

of that type of snubber shall be functionally tested until no more failures are found or until ali snubbers of that type have been functionally tested; or

2) A representative sample of each type of snubber shall be func-tionally tested in accordance with Figure 4.7.4-1. "C" is the total number of snubbers of a type found not meeting the accept-ance requirements of Specification 4.7.4.f. The cumulative num-ber of snubbers of a type tested is denoted by "H". At the end of each day's testing, the new values of "N" and "C" (previous day's total plus current day's increments) shall be plotted on Figure 4.7.4-1. If at any time the point plotted falls in the

" Accept" region, testing of snubbers of that type may be termi-nated. When the point plotted lies in the " Continue Testing" region, additional snubbers of that type shall be tested until the point falls in the " Accept" region or all the snubbers of that type have been tested.

t ,, OR, C SWJ .llMT I 3/4 7-11 Amendment No. A5, # ._

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ADMINISTRATIVE-CONTROLS SAFETY LIMIT VIOLATION (Continued) c.

The Safet Limit Violation Report shall be submitted to the Commissio 14 days o the SRC and the Vice President, Operations GGNS within the violation, l d.

Critical by operation of the unit shall not be resumed until authorized the Commission.

6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

b. Refueling operations, c.

Surveillance and test activities of safety related equipment,

d. Security Plan implementation.

e. Emergency Plan implementation.

f. Fire Protection Program implementation.

g. PROCESS CONTROL PROGRAM implementation.

h. OFFSITE DOSE CALCULATION MANUAL implementation.

i.

Quality Assurance Program for effluent and environmental monitoring, using the guidance in Regulatory Guide 4.15, February 1979.

6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed as required by 6.5, above, prior to implomentation and shall be reviewed periodically as set forth in administrative procedures.

6.8.3 The following programs shall be established, implemented, and maintained:

a. Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systeea include the:

1. RCIC system outside containment containing steam or water, except the drain line to the main condenser.

2. RHR system outside containment containing steam or water, except the line to the LRW system and headers that are isolated by manual valves.

3. HPCS system.

4. LPCS system.

Hydrogen analy:ers of the combustibir gas control system.

GRAND GULF-UNIT 1 6-14 AmendmentNo.[f

ADMINISTRATIVE CONTROLS ,

PROCEDURES AND PROGRAMS (Continued)

6. Feedwater leakage control system.

7. Post accident sanpling system.

8. Suppression pool level detection po-tion of the suppression pool makeup system.

The program shall include the following:

1. Preventive maintenance and periodic visual inspection requirements, and

2. Integrated leak test requirements for each system at refueling cycle intervals or less,

b. In-Plant Radiation Monitorine A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:

1. Training of personnel,

2. Procedures for monitoring, and

3. Provisions for maintenance of sampling and analysis equipment,

c. Dest-accident samplino -

A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shall include the following:

1. Training of personnel,

2. Procedures for sampling and analysis,

3. Provisions for maintenance of sampling and analysis equipment,

, 6.9 REPORTING RE0tJIREMENTS ROUTINE REPOR_TS, T 6.9.1 In addition to the applicable reporting requirements of Title 10 Ode -

of Federal Regulations, the following reports shall be submitted F the-

"--'--" ^ ^ *Mstr:ter Of th: *gMaMJf r(srsetedr-STARTUP REPORTS ecbf50.4 4 l0 cFR. so 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (1) receipt of an operating license (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, therisal, or, hydraulic performance of the unit.

GRANO CU'3-UNIT 1 6-15 6A,t S. _

! ADMINISTRATIVE CONTROLS SEM1 c.

ANNUAL RADICACTIVE EFFLUENT RELEASE REPORT (Con

.. Principal estimate), radionuclide (specify whether determined by sensurement or d.

Type of waste (e.g., spent resin, compact dry weste, evaporator bottoms),

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f. Type of container (e.g., LSA, Type A, Type B. Large Quantity), and Solidification agent (e.g. , cement, vres formaldehyde).

the site to the UNRESTRICTED AREA cf owie ef fluents on a evarterly basis, radioactive m he radioactive effluent Mlease reports shal) include any changes to the PROCESS CONTROL PROGRAM (PCP), OFFSITE 005E CALCULATION active waste systems made during the reporting period. o-MN MONTHLY OPERATING REPORTS 6.9.1.10- Routine reports of operating statistics and shu valves, shall be submitted on a monthly basis the-9 fretter r0 f-f4 eea"---

-Manage **n-and -PM = ',Miy&i6r-Vr&r-MueleeF4egw14644 r Menel-ofMee calendar month covered no later by than the 15th of each month following the the Mport.

$pfCIAt REPORTS m

-~~-~~v 6.9.2 Special reports shall be hat b Seen SoA ed to triSco th: A hg4ed 0"icEwithin the time period specified for each report.M 4 n it tf* * * " b 6.10 RECORD RETENTION in addition to the-applicable record retention reouirements of, Code Title 10 of Federal Regulations, the miniawe period indicated. the following records shall be retained for at least 6.10.1 The following records shall be retained for at least five years:

a.

Records power and logs of unit operation covering time interval at each level, b.

Records and legs of principal maintenance activities, inspections, Mpair and nuclear replacement of principal iteen.of equipment Misted to safety.

c. All REPORTABLE EVENTS.

GRAND CULF-UNIT 1 6-19 hrncndiud .-

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