ML20077H084

Application for Amend to License NPF-29,requesting Extension of Instrumentation Surveillance Intervals & Allowed Outage Times.Proprietary GE Topical Rept RE-027 Encl.Rept Withheld

ML20077H084
Person / Time
Site:	Grand Gulf
Issue date:	06/26/1991
From:	Cottle W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19302E732	List: ML20077H084 ML20077H088
References
GNRO-91-00083, GNRO-91-83, NUDOCS 9107050139
Download: ML20077H084 (20)

Text

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A E=* ENTERGY W. T, C ottie June 26, 1991 U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Extension of Instrumentation Surveillance Intervals and Allowed Outage Times Proposed Amendment to the Operating License (PCOL-91/12)

References:

1) GE Topical Report NEDC-30936P-A, "BWR Owners Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation)

Part 1", December 1988

2) GE Topical Report NEDC-30936P-A. " Technical Specification Improvement Methodology (With Demonstration for BVR ECCS Actuation Instrumentation)

Part 2", December 1988

3) GE Topical Report NEDC-30851P-A, Supplement 1

" Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation", October 1988

4) GE Topical Report NEDC-30851P-A, Supplement 2

" Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation", March 1989

5) GE Topical Report NEDC-31677P-A, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation", July 1990

6) Letter, A. C. Thadani (NRR) to D. N. Grace (BWROG),

" General Electric Company (GE) Topical Report NEDC-30936P, 'BWR Owners Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation), Part l'", dated December 9, 1968 G9105101/SNLICFLR - 1 tj_

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June 26, 1991 GNRO-91/00083 Page 2 of 5 I l

7) Letter, C. E. Rossi (NRR) to D. N. Grace (BWROG),

" General Electric Company (GE) Topical Report NEDC-30936P, 'BWR Owners Group Technical Specification Improvement Methcxlology (With Demonst ration for BWR ECCS Actuntton Instrumentatlon) Part 2'". dated December 9, 1188

8) Le t t.o r , C. E. Rossi (NRR) to D. N. Grace (BWROG).

" General Electric Company (GE) Topical Report NEDC-30851p, Supplement. 1, ' Technical Specificat.fon Improvement Anr. lysis for UWR Cont rol Rod lllock Inst rumen t a t lon'", da ted Sept ember 22, 1988

9) 1.etter, C. E. Rossi (NRR) to D. N. Grace (BWROG),

" General Electric Company (GE) Topical Report NEDC-30851P, Supplement 2, ' Technical Specification improvement Analysis for BWR lsolation instrumentation Common to RPS and ECCS Instrumentation'", dated January 6, 1989

10) Letter, C. E. Rossi (NRR) to S. D. Floyd (BWROG).

" General Electric Company (GE) Topical Report NEDC-316/7P, ' Technical Specification Improvement Analysis for BWR lsolation Actuat ion Inst rument at ion'",

dated June 18, 1990 l

GNRO-91/00083 Gentlemen:

Entergy Operations. Inc., as encouraged by t he NRC in Rnferences 6 through 10, in subc. et ing by t his Int ter a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License. The proposed GGNS Technical Specification (TS) amendment consists of changes to selectet TS l Instrumentation surveillanen test intervals and allowed outage times.

l These TS changes are based upon General Electric Company (GE) Topical l

i Report s (References 1 through 5) previously reviewed and approvnd generically by the NRC (References 6 throngh 10).

Attachment 2 of thin Intter provides a detailed description of t he proposed TS changns and justificntion for t hn changes. Attachment 2 also details the basis for thn Entergy Operations, Inc. determination that the proposed amnndment involves no significant hazards considerations based on t.he guidellocs presented in 10CFR50.92.

The affected TS pages marked up indicating thn proposed changes are included as Attachment 3.

G9105101/SNLICFLR - 2

Y June 26, 1991 GNRO-91/00083 Page 3 of 5 GE report RE-027, dated December 1986 is submitted as Attachments 4 and 5 to support the proposed TS changes. This document contains information which GE considers confidential and proprietary. Consequently, it is requested that this report (Attachments 4 and 5 to this letter) be withheld from public disclosure in accordance with 10CFR2.790. An executed af fidavit by D. J. Robare of GE is included as part of Attachments 4 and 5 in support of this request.

Attachment 5 is an addendum documenting changes in the plant specific model evaluated by GE in report RE-027.

Attachment 6 provides trip unit drif t data to support the justification contained in Attachment 2 for the proposed TS changes.

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.

The proposed changes to the TS conform with the guidance provided by the NRC in References 6 through 10. Therefore, Entergy Operntlons, Inc. is requesting expeditions review of this submittal in accordance with References 6 through 10.

Yours truly, c z > *Y~' C a';uc;;

WTC/ PRS /be attachments: 1. Affirmation per 10CFR50.30

2. GGNS PCOL-91/12

3. Mark-up of Affected Technical Specification Pages

4. GE Report RE-027 (Proprietary)

5. Addendum to GE Repcrt RE-027 (Proprietary)

6. GGh!, Trip Unit Drift Data in Support of PC0b-91/12 cc: (See Next Page) l G9105101/SNLICFLR - 3 l ,

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.g June 26.-1991 y

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UNRO-91/00083 i

. Page 4 of 5 -

cci Mr. D. C. Illntz (w/a)

Mr. J. l. .

Mathis (w/1,2,3,6)

Mr. R. B. McGehen (w/1,2,3,6)

Mr. N. S. Reynolds-(w/1,2,3,6)

Mr.11. I.. Thomas (w/o) .

Mr. F. W. Titus (w/n) '

Mr. Stewart D. Ebnet er (w/1,2,3,6)

Regional Administrator U.S. Nuc1 car Regulatory Commission-Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. i..-L. Kintner. Project Manager (w/1,2,3,6)'

Offico of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Hall Stop 11D21 Washington, D.C.- 20555

- Dr. Alton Ib Cobb (w/1,2,3,6) +

State.Ilealth~ Officer State Board- of floalth P.O. Box 1700-Jackson, Mississippi 39205

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l '- G9105101/SNLICFLR - 4 r91 7 y y & V gf e-- e -w%t-w- y'wp y*-*g --

BEFORE Tile UNITED STATES NUCIIAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN Tile MATTER OF MISSISSIPPI POWER & LIGitT COMPANY and SYSTEM ENERGY RESOURCES. INC.

and SOUTil MISSISSIPPI ELECTRIC POWER ASSOCI ATION and ENTERGY OPERATIONS, INC.

AFFI RM AI.l(LN I, W. T. Cottle, being duly sworn, state that I am Vice PresidenL, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., r.nd South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nucient Regu lt, t ory Cornm iss ion , this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this applicat ion as Vice President, Operat ions GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct o the best of my knowledge, information and helief.

m F CJm;C W. T. Cottle STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN To before me, a Notary Public, in and for the County and State above named, this M day of 4wM , 1991.

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(SEAL) 6h e Sht.nhuh

Notary P lic My commission expires:

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..._- . _ . . . . - . . , _ _ - . _ . _ . _ _ . _ _ _ . . . ~ . . _ . . . _ _ . - . . _ _ . . _ . _ . . . . .

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--Attachment. 2 to GNRO-91/00083;

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9 GGNS PCOL 91/12 f

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G9105101/SNLICFLR - 7

3 Attachment 2 to GNRO-91/00083 A. SUBJECT

1. NL-91/10 Extension of Instrumentation Surveillance Intervals and Allowed Outage Times

2. Affected Technical Specifications:

a. Cont rol Rod Operability, Surveillance 4.1.3.1.4 -

Page 3/4 1-5

b. Isolation Actuation Instrumentation, Limiting Condition for Operation, 3.3.2 - Page 3/4 3-9

c. Isolation Actuation Instrumentation Tabla 3.3.2 Pages 3/4 3-10, 3-11, 3-13, 3-14 and 3-15

d. Isolation Actuation Instrumentation Surveillance Requirements Table 4.3.2.1 Pages 3/4 3-22 through 3/4 3-26

e. Isolation Actuation Instrumentation Bases, 3/4,3.2 -

-Page B 3/4 3-1

f. Emergency Core Cooling System Actuation Instrumentation.

Table 3.3.3 Pages 3/4 3-29 and 3-30

g. Emergency Core Cooling System Actuation Instrumentation Surveillance Requirements. Table 4.3.3.1 Pages 3/4 3-34, 3-34a, 3-35, and 3-36

h. Emergency Core Cooling System Actuation Instrumentation Bases, 3/4.3.3 - Page B 3/4 3-2

-1. Control Hod Block Instrumentation Surveillance Requirements. Table 4.3.6 Page 3/4 3-56 l j. Control Rod Block Instrumentation Bases, 3/4.3.6 -

Page B 3/4 3-3a B. DISCUSSION l 1. This license amendment request proposes - to- revise the Grand Gulf Nuclear. Station (GGNS) Technical Specifications (TS) 3/4.3.2, 3/4.3.3, 3/4.3.6 and associated Bases-to increase the surveillance test intervals (STIs) and allowed outage times (A0Ts). The proposed'TS changes have been justified using. 1 probabilistic analytical methods and are based on BWR Owners' Group (BWROG), of which Entergy Operations, Inc. is a member, sponsored General Electr ic Company (GE) generic; Topical Reports

-(References 1 through 5) which have' received NRC review and 1 L approval (References 6 through 10). This proposed amendment-l applies those generic Topical Reports to GGNS.

C9105101/SNLICFLR - 8

l Attachment 2 to GNRO-91/00083 l

2. Topical Report, "BWR Owners Group Response t o NRC Generic Letter 83-28, item 4.5.3." (Reference 11) provided justification for the acceptability cf current React or Protection System (RPS) STis, in ad tion Reference 11 ostablished a basis f~ avt anding ST: and AUTs for RPS based on reliability analyses which estimate RPS failure frequency.

3. In response to growing concerns over i he a Iv?rse impact of current testing and maintenance requirements on safety and plant operation, particularly as related tc insttumentation systems, the BWROG initiat ed a progran to di velop s justification to be used to revise ins rumentation TS.

Operating plants have experienced many inadvertent reactor t rips and safeguards actuations during .ier formance of instrumentation surveillances, causing t unec *saaty transients and challenges of safety systems. Signi f ica it time and effort on the part of operat ing staf fs have teen devot ed to performing, reviewing, documenting and track'.og the various surveillance activit ies, which in many instat:es seemed unwarr anted based on the high reliability of s he equipment.

Therefore, significant benefits for operating 11 ants appeared to be achievable through revision of inst rumern at.lon t est and maintenance requirements.

4. Consequently, the analyses of Reference 11 were furthn developed in other Topical Report s (References 1 through 5 and

12) to prov.ide justification for extending TS STIs and A0Ts for the RPS, Emergency Core Cooling Systems (ECCS), Cor. trol kod Block, and Isolation actuation instrumentation. References 1 through 5 and 12 also included proposed TS changes t o facilitate implewntaticn of the analyses results. References 1 through 5 and 12 were submitted to t he NRC by the BWROG and '

subsequently apptoved as detailed in NRC Sa fety Evaluat Ion Report.s (SERs) (References 6 through 10 and 13). These SERs describe the accept ability of both the anslyses and thn proposed TS changes provided to the NRC. In addition, References 6 through 10 and 13 provided criteria tor plant specific implementation of the generically approved TS changes.

GGNS compliance with these criterin is discussed in the Justification sect ion of this Attachment.

5. The NRC has already reviewed and approved the TS changes applicable to the RPS for GGNS in Amendment No. 67 (References 14 through 16).

6. This amendment requnst proposes TS changes to the actuation instrumentat.lon support ing the ECCS, Control Block function and Isolation functlon. These changes are specifically discussed and designated in the TS mark ups of References 1 through 5 and therefore are not further discussed here.

G9105101/SNhlCFI.R - 9

Attachment 2 to GNRO-91/00083

7. The_ proposed TS changes to TS Section 3/4.3.3 on page 3/4 3-30

-provide a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> A0T for RCCS instrumentation which is consistent with the analysis in Reference 2. The proposed wording-differs from the TS mark up of Reference'2 which implies an allowance of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before taking the action of TS Table 3.3.3-2.- Reference 18-provides a clarification on the intent of the Reference 2 TS mark up and also provides revised wording. The proposed TS change is consistent with Reference 18.

8. The TS pages af fected by this proposed amendment are included as Attachment 3 and are marked up to reflect the proposed changes.

C. JUSTIFICATION

1. The effect on safety of the proposed extensions to the STis and ACTS of the actuation instrumentation supporting the ECCS, the Control Rod Block function (CRBF), and the Isolation instrumentation has been addressed in References 1 through 5.

Further, the NRC has detailed their acceptance of the analyses and conclusions of References 1 through 5 in SERs (References 6 through 10). The SERs conclude that-implementation of the TS changes proposed in References 1 through 5 would provide an overall enhancement to plant safety and that the proposed changes to TS are acceptable sub.)cet to the Licensee documenting 1) plant-specific applicability and 2) that instrument drif t is bounded by the generic analysis

-assumptions. The NRC also issued Reference 17 which provided clarification for the SERs condition concerning instrument drift. These acceptance conditions are addressed below for each generic Topical Report.

NEDC-30851P-A, Supplement 2, " Technical Specification Improvement

-Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrurentation" and NEDC-31677P-A, " Technical Specification Improvement Analysis for BWR Isolation Instrumentation"

2. NEDC-30851P-A, Supplemnnt 2 provides a hasis for extending STis and A0Ts.for. Isolation actuation . instrumentation common to RPS and ECCS~ Instrumentation. To gain the full safety benefits of the revised RPS and ECCS instrumentation requirements corresponding STI and A0T extensions for the common isolation actuation instrumentation is necessary. The necessary generic analysis was performed by GE for the BWROG and resulted in this Topical Report. The NRC Staff has reviewed and approved this Topical Report in Reference'9.

3. NEDC-31677P-A provides a basis for extending STIs and A0Ts for isolation actuation instrumentation not covered by

-NEDC-30851P-A Supplement 2. The necessary generic analysis was performed by GE for the BWROG and resulted in this Topical Report. The NRC Staf f has reviewed and approved this Topical Report in Reference 10.

G9105101/SNLICFLR - 10

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'Attachaent 2 to GNRO-91/00083 4.- The technical basis for the isolation actuation instrumentation TS improvements-is based on the reliability approach established in support of changes proposed byLthe BWROG for

-RPS, ECCS, Reactor Core Isolation Cooling (RCIC) and Rod Block-Instrumentation. 11n application of _ thei BWROG methodology, the isolation' actuation instrumentation-fault trees were developed to'model the isolation system of each'BWR plant line. ,The-affect of the proposed changes in STI and A0Ts on the isolation signal could then be compared to the availability of the

. isolation signal without the proposed changes in the fault tree. The not change in the failure of the system isolation function was then used to determine the acceptability of the.

proposed changes. As shown in Table 2 of Reference 4 for BWR 5/6 relay plants (ECCS and RCIC instrumentation), the increase in probability lof-isolation failure due to an STI increase to 92 days is negligible. Further, Reference 4 Section-3.5 provides a sensitivity analysis showing that an A0T increase to 24-hours.has a less than 2% effect on the probability of failure of'the isolation function given a demand. For Actuation Instrumentation not used for ECCS and RCIC, Reference 5 stated that STI and A0T changes were assessed to be acceptable if the calculated ' change in -isolation failure frequency was less than IE-07/ year on an absolute basis-or 10%

on a relative basis. As stated in References 9 and 10, the Staff.found.the analysis an acceptable basis for extending _the '

STIs:and A0Ts of_the subject instrumentation. Because:of more restrictive-A0T. requirements on RPS instrumentation established-in Reference 12, the test and repair A0Ts for isolation

. instrumentation-common to'RPS is constrained to 6 and 12_ hours respectively. A0Ts established in Reference 2 for ECCS equipment are 6 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.(for test and repair A0Ts) which are the values proposed by this submittal for th. isolation actuation instrumentation. Where an isolation actuation instrument is common to both RPS and'the isolation actuation

instrumentation, the more restrictive A0T is-proposed.

5. _Entergy Operations, Inc.'has applied the generic analyses to-GGNS completing the-conditions for plant specific application of the 1

TS changes contained in the NRC's SERs (References 9 and

-10). Two conditions must be met:

a.

~

Confirm the applicability of the generic analyses to the

(~ plant.

NEDC-30851P-A, Supplement 2, Appendix A and

.NEDC-31677P-A, Appendix A identify GGNS as a p participating plant-in the development of the generic

j. . analyses. 'Entergy operations, Inc. confirms that the-l- generic analyses apply to GGNS.-

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Attachment 12 to GNRO-91/00083 ,

- s References 4 and .5 provide boutIding analyses of the-Impact of the proposed TS changes for isolation actuat ion

~ instrumentation. Section 5.5 of Reference 5'provides verification that the results of the generic analysos of -

.the_various product if nes are applicable _ to the individual plant TS requirements. This evaluation included a comparinon of isolation actuation inst.rumentation.STIs and calibrat ion intervals given in the current plant-specific TS to thoso.cyaluated for the four product _ lines. Identified diffnrences werc_then 1 evaluated to verify that the product line analyses ;l envelope theso_ differences.- '

, Appendix _C-? of Reference 5 provides a matrix listing of'

• STIs and enlibration intervals given in current TS of

-individual DWRS/6 plants included in this study. Thn.  :

first column. lists the isointion trips 'for GGNS, the plant _that was used in the generic analyses. The succeeding columna list the isolation trips for the remaining plants in the product lion. Since GGNS was used as the generic model. plant,'the generic analyses of NEDG-30851P- A and NEDC-31677p-A are applicable to GGNS '

and provide an adequate basis for TS changes to extend the STIs and A0Ts for GGNS isolation actuation instrumentation.-

b.- Confirm that any increase in instrument drift due to tho  ;

extended STIs is proporly accounted for in the satpoint calculation methodology. (For-additional information on this' Issue, see Roference 17).

The Isolation-actuation instrumentation channel drif t

• characteristics are considered when the TS trip sotpoints

~

are cstablished. The setpcint calculations for GGNS conservatively assume that the channel sotpoint drif t

- occurs witbcat correction during the entiro 18-nonth channni calibration interval. Extensien of the functional test. Intervals, as proposed berein, will

'therefore-havo~no'effect on thn isolation actuation instrumentation sotpoint. calculations. The GGNS sotpoint methmiology - thus enntinues to properly account for instrument drif t.

Additionally,--further information concerning the drif t.

cxperience for Rosemount trip units at GGNS in included

in Attachment 6 of this submittal. iost of the Linstrument channels-covered-by this proposal utilize Rosemount trip units. This informat.fon supports tho conclusion'that_ instrument drift is not a significant concern in extending the- functional test int erval from monthly to quarterly.

G9105101/SNh1CFLR - 12 2.... ,. ,- . _ _ . . , ,,_ , _-

Attachment 2 to GNRO-91/00083

6. Enclosuro 3 to Reference 9 provided an acceptablo format for TS changes to implement. the approved STI extensions justified in NEDC-30851P-A, Suppinment 2. The TS pages in Attachment 3 of

-this submittal for TS 3/4.3.2 includo changes consistent with this format an. subsequently modified by the changos for NEDC-31677p- A, as approved in Reference 10.

NEDC-30936P-A, "DWR Owners Group Technical Specification Improvement Ifethodology (With Demonstration for BWR ECCS Actuation Instrumentation), Parts 1 and 2"

7. The proposed changes irnplemnnt the TS revisions supported by the analyses contained in these Topical Reports. Part 1 presented the methodology for extension of STis and ADTs for ECCS TS requirements and application of the methodology to a single functional unit ns a demonst ration case. The Staff has reviewed and approved Part 1 in Reference 6. Plant specific application of the methodology was indicated in this SER to be dependent upon thn completion of more detailed analyses to account for interrelat ions between the various ECCS actuntion instrumentation functional units. Part 2 of thn Topical Report presented this f urther analysis. The Staff has reviewed and approved Part 2 in Reference 7.

8. The ^roposed changes optimize STis for improved ECCS re bility and increase A0Ts. As shown in Reference 2 t he it' >

. In A0Ts has negligible impact on ECCS failurn ratuency yet allows more time for repair and decreases the rment tal for unnecessary plant shutdown. Further, the heference 2 evaluat.lon of the ef fect of other contributing factors from these changes indicatns that those changes represent a not improvement in overall plant safnty.- Briefly the contributing factors include:

o Avoidance of inadvertent scrams

o. Decreased equipment degradation due to excessive test.ing o Decreased diversion of plant personnel o Avoid inndequate allowance for repair timo and the concomitant r.isk of working to overly restrictivo deadlines o Avoidanco of test caused failures o Avoidance of shutdown (and t.ho inherent risk in plant shutdowns) dun to restrictive limiting conditions of operation Additionally as noted in Reference 1, incorporation of these changns represents a not cost savings of over $40,000 por i,lant per year.

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+ i C' 1 Attcchment 2 to GNRO-91/00083-m 9.- - Entergy Operations, Inc. as a member of the BWROG endorses the analysis submitted in References 1 and 2. Referenen 1 provided BWR reliability. models and methodology with the demonst ration case to perform plant specific nyaluations of TS STis and A0Ts for' ECCS ' actuation instrument ation. The evaluation utilized reliability data, fault trees, accident sequences and computer h analysis of system unavailabilities to determine changes in system unavailability due to changes in ECCS STI and A0T-intervals. Since ECCS is used to inject into the core for cooling when feedwater is lost, system unavailability challenges core coolf.ng and might lead to corn damage. Corn damage frequency and plant safety are then bounded in the j analysis by water injection function unavailability. llence ,

insignificant changes in water inloction unavailability due to

_ECCS ST1 and ADT interval changes would have insignificant-impact on core damagn frequency and plant safety. As described in Reference I several baseline and scoping casos worn used in concert with computer codes to doterminn the ef fect of STI and A0T changes on system unavailability. Where the system

. unavailability-cha_ngn was found to be less than 1 pntcent_tha TS change was acceptable. This methodology was utilized-in '

Refnrenen I for the single demonstration caso and found acceptable by the Staff in Reference 6.

-10. Referenco 2,-hownver, had to include a summation of changes and resultant impact onlinjection availability and account for '

dif ferent plant configurations. The Reference 1 methodology

. remained the-same but several modifications were mado to strnaaline the analysis, account for the interaction of system changos, and account for different plant configurations. As a result Reference 2 justified and usnd an acceptance criterion of 47. change :In-injection unavailability or an-absolute value of 1.0 E-f per ynar as -an acceptanto criterion. Roforenta 2-concluded that despite the less restrictive acceptanco '

critnrion resulting from the modified methodology, the incrensa in unavailability was insignificant and bounded by the net increase in safety. Additionally, becanse tho:RCIC and'ECCS

have instrumentation in commun thn ef fect of increased. STI and A0T periods of the common instrumantation on RCIC availability

- was accounted for in the Reference 2 evaluat ion. This changs in acceptance critorion and the Reference 2 evaluation worn found necept.able by the Staf f in Refernnce 7..

11. -Entergy Operations, Inc. has applied the gnneric-analysis complnted by tho BWROG.to GGNS by.completlug the required plant specific-analysis. As stated in the NRC's SER (Reference 7) for NEDC-30936P-A, Part 2, two issues must bn addressed to justify the applicability of the generic analysis to individual plants when: specific _ facility TS are considered:

4

a. Confirm the applicability of the generic analyses to the 1 plant.

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' Attachment 2_to GNRO-91/00083

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In GE Report RE-027, dated December 1986, Reference 19 (Attachment 4 of this submittal), tl. generic. study completed in these Topical Reports modifying the ECCS actuation instrumentation TS requirements was extended to-GCNS. The GE report ~ utilizes the procedures of-

-NEDC-30936P-A, Part 2, Appendix-F-to identify and' evaluate the differences between the GGNS ECCS configuration and the ECCS-configuration used in the generic analysis. Attachment 5 of this submittal identifies additional changes which have occurred since the plant specific analysis was originally completed and their effect upon the GGNS plant specific analysis. The results indicate that while the ECCS configuration for GGNS has several differences compared to the generic '

configuration, the differences and their impact do not af fect the_ applicability of the TS changes dnveloped by the generic efforts of these Topical Reports. Therefore, the conclusions reached in NEDC-30936P-A, Parts 1 and-2 apply to GGNS and the plant specific changes contained in this request are bounded by both the generic analysis and the NRC's SERs.

b.- Confirm that any increase in instrument drif t due to the extended STIs is properly accounted for in the setpoint -

calculation methodology. '(For. additional information on this issue, see Reference 17),

i The ECCS actuation instrumentation channel drif t -

characteristics are considered when the TS trip setpoints

-are! established. The.setpoint calculations for.GGNS conservatively assume that the channel setpoint drift:

occurs without correction during the entire 18-month channel-calibration luterval. Extension of the functional. test-intervals, as proposed herein,'will

.therefore have no effect on the ECCS actuation p -instrumentation setpoint calculations. The GGNS setpoint ,

methodology thus continues to properly account for instrument drift.

-Additionally, ffurther 'information concerning the drif t-experience for Rosemount trip units at GGNS is . included-

.in Attachment--6 of this submittal. Most of the i: instrument channelsEcovered by this proposal utilize L Rosemount trip units. This!information supports the p -conclusion that instrument drift is not a significant

concern in extending the functional test interval from L -monthly to quarterly.

l-U t

l G9105101/SNh1CFLR - 15

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Attachment 2 to GNRO-91/00083

_y

12. As noted previously, a TS change is also proposed which is not.

specifically referenced in the NRC SERs (References 6 through 10). The following discussion addresses the acceptability of

'this proposed TS change.

Appendix n of NEDC-30936P-A, Part 2 provided guidanen for TS changes covered by the Topical Report. These changes are those implementing the approved extensions of STis and AUTs contnined in Tablo 2 of the NRC's SER of NEDC-30936P-A, Part 2. GE subsequently provided porticipating BWR utilitics with clarifications concerning *he impicmentation of thnso TS changes. GE also provided these clarifications to the NRC in Reference 18.

The item of interest in Reference 18 provided clarification on the application of the extended repair A0T. In NEDC-30936P-A, Part 2 Appendix A, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> timo period was inclnded as a change to Action b of TS 3/4.3.3. GE subsequently indicated that this could inappropriately delay action requirements not covered by the analysis. Instead, tho changes need to be made to the Action requirements for each applicable functional nnit which are part of TS Tablo 3.3.3-1.

Thn intent of the change is to precludn the allownnco of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before taking the Action specified in TS Table-3.3.3-1.

Action b of TS 3/4.3.3,, as written in Reference 2, implies a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AUT before taking any action in TS Table 3.3.3-1. The change GGNS has proposed accurately reflects the intent. of the Rnference 2 analysis. This changn thereforn is necessary to obtain the overall enhancement to safety that is possible by extending ECCS instrumentation STis and A0Ts.

13. Tho format. of the proposed changes for TS 3/4.3.3 is consistent with the format inclnded in the NRC's SER (Reference 7) for NEDC-30936P-A, Pa rt 2.

1 NEDC-308151P-A, Supplement 1, "Tochnical Specification Improvement "

Analysis for BWR Control Rod Block Instrumentation" 14 This Topical Report provides a basis for extending STIs for thn )

CRBF-justrumentation. The CRHP shares common instrumentation with the RPS. To gain the full safety benefits of the RPS instrumentation improvements of Reference 12 corresponding STI extensions for-the CRBF are necessarye The necessary generic analysis was performed by GE for the BWROG and resulted in'this Topical Report. The NRC Staff has reviewed and approved this

-Topical Report in Reference 8.

i l-f G9105101/SNLICFLR - 16 2

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t Attachment 2 to GNRO-91/00083

- 15. ' Entergy Operations,-Inc. has applied the generic analysis to GGNS by completing the conditions for. plant specific

application of the CRBF instrumentation TS changes contained in- l Table 1 of the NRC's SER. Two conditions must. be met:

~ a.. Confirm the applicability of the generic analyses to the plant.

' NEDC-30851P-A, Supplement 1, Appendix B identifies GGNS as'a participating plant in the development of the generic analysis. Entergy Operations, Inc. has reviewed the assumptions and design details contained la <

NEDC-30851P-A, Supplement I and concluded that the report 18 applicable to and bounds the design of GGNS, Entergy Operations, Inc. therefore confirms that the generic analysis applies to GGNS.

b. -Confirm that any increase in instrument drif t duo to the '

extended STIs-is properly accounted for in the setpoint ca lcu la t ion . met hodology. (For additional information on this issue, sco' Reference 17),

f The CRBF actuation inst rumentation channel drif t

-characteristics are considered when the TS trip setpoints '

are establithed. The setpoint calculations for GGNS conservatively assume that the channel setpoint drift occurs without correction during the entire 18-month channel calibration interval. Extension of the functional test-intervals, as proposed herein, will therefore have no effect on the CRBF actuation instrumentation'setpoint calculations. The GGNS'setpoint

. methodelogy thus continues to properly account .for instrument drif t.

16. Enclosure 3 to the NRC's SER-(Reference 8) provided an_ ,

acceptabic format for TS changes to implement the approved STI extensions justified in NEDC-30851P-A, Supplement 1. The TS pages 'in Attachment 3 'of this submittal for TS 3/4.3.6 include changes in mordance with this format.

SUMMARY

l

~

17. Referrocas 6 through 10 provided TS changes based on Staf f review of the Topical Reports-(References 1 through 5). '

Entergy_ Operations,-Inc. has proposed TS changes consistent with thosa previously approved and=specifically designated in References 6 through 10. In addition, a change _Is proposed which is not explicitly referenced in the NRC SERs,_ but is

! covered by the analyses. detailed in Reference 2 and is L acceptable. as ' discussed above. ,

L In conclusicn, the. NRC criteria for demonstrating the L applicability and acceptability of all proposed TS changes has been shown to be mot, as detailed above. Entergy Operations, Inc. thornfore concludes that the TS changes proposed will G9105101/SNLICFLR_- 17

,-.-a- _- - . - -- .

Attachment 2 to GNRO-91/00083 minimizo unnecessary testing and relax excessively restrictive-A0Ts, and will provide an overall enhancement to plant safety.

D, NO SIGNIFICANT HAZARDS CONSIDERATIONS

1. Entergy Operations, Inc. is proposing that the GGKS TS be amended to extend surveillance test intervals and allowed outage times for the actuation instrumentation support ing the ECCS, CRBF and Isolation instrumentation. The proposed TS changes minimize unnecessary testing and remove excessively l restrictive allowed outage times that could potentially degrade overall plant safety and availability.

2. 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 involyns no significant hazards if operation of the facility 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 dif ferent kind of accident from any accident previously nyaluated; or (3) involve a significant reduction in a margin of safety.

-3, GGNS has evaluated the no significant hazards considerations in its request fot a license amendment, in accordance_ with 10CFR50.91(a), GGNS is provic*ing the following analys.is of the proposed amendment against the three standards in 10CFR50.92:

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

The proposed TS changes increase the STIs and A0Ts for actuation instrumentation supporting ECCS, the CR11F, and isolation functions. There are no physical changes in any of the af fectrd systems themselves. Regarding the probability of mt Ifunction of equipment. Topical Reports prepared by GE showed that for the ECCS, there is a small incronce in the unavailability of the water injectlon function which may result in a slight increase in the consequences of previously evaluated accidents which rnly spon ECCS for mitigation. This increase in ut availability was judged acceptable by GE. The NMC, in its review of the Topical Reports (References 1 thr4 ;h

5) concurred with this conclusion. The changes proposed arm onsistent with these SERs (References 6 through 10)

, with one addition. The additional change is bounded by L the analyses cf Reference 2 es detailed in this amendment request.

Further, given the resulting reduction in test related plant scrams and test induced wearout of equipment, the not offect of these changes represent a net improvement to overall plant safety.

G9105101/SNhlCFLR - 18 p 9 +ar-- t v y---gy+1rv-t' rsvg er+- sweu--, ---yse-s> r=..e e.,y. R es, +c- m e -y , tce,--w ,- pir as w .,wv'

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I L' Attachment 2 to GNRO-91/00083

s.  :

Therefore, there is nol increase in:the probability.or consequences of a previously evaluated accident due to the proposed changes, i

b. This' change would not create the possibility of a new or j different kind _of accident from any previously analyzed. l Neither the design nor the functional (operation of the affected instrumentation is being changed. The proposed changes only involve a change in the STIs and A0Ts.

These changes will not impact the function of monitoring system variables over their anticipated ranges for-normal operation, anticipated-operational occurrences, or accident conditions.

As stated in References l'through 5, reliability is not degraded by the proposed changes.

The proposed changes do not introduce any new modes of -

plant operation, make any physical changes, or alter any operational-setpoints.

Therefore, the possibility of s new or different kind of accident from any previously evaluated is not created, c,; This change would not involve a significant reduction in '

the margin of safety.

The proposed' changes do notl alter the manner in which:

safety -limits, limiting safety system settings, or

.. limiting conditions for operation are determined. The impact of reduced testing, other than as- addressed above, is to allow a longer time interval over which instrument uncertainties (e.g., drift) may act._ The current ,

-af fected instrumentation setpoints already account for the effects of drif t and include a sufficient allowance .

to tolerate extensions of the STIs. Implementation of-the_ proposed-changes is expected to-result-in an overall improvement in safety, as follows:

1. Reduced testing will result in _ fewer Inadvertent reactor trips, less' frequent actuation of ESF components, and less frequent distraction of operations personnel.

.11. Improvements In theLeffectiveness of the operating

-staf f _In monitoring and controlling plant operation will be realized. This is due to less frequent distraction of the operators to' attend to instrumentation testing.

111. Longer repair times associated with increased A0Ts' will lead to higher quality repairs and improved

_rel! ability.

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Attachment 2 to GNRO-91/00083

4. Based on the above evaluation, Entergy Operations, Inc. has concluded that operation in accordance with the proposed ,

amendment involves no significant har.ards considerations.  !

E. REFERENCES

1) GE Topical Report NEDC-309'*6P-A, "BWR owners Group Technical Specificat ion improvement Met hodology (With Demonst rat ion it -

BWR ECCS Actuation Instrumentation) Part 1", December 1988

2) GE Topical Report NEDC-30936P-A, " Technical Specification f improvement Methcdology (With Demonstration for BWR ECCS Actuation _ Instrumentation) Part 2", December 1988

3) GE Topical Report NEDC-30351P-A, Supplement 1 " Technical Specification Improvement Analysis for BWR Control Rod Block '

Instrument'tlon", October 1988

4) GE Topical Re,> ort NEDC-30851P-A, Supplement. 2. " Technical Specification improvement Analysis for BWR isolation Instrumentation Common to RPS and ECCS Instrumentation", March '

1989

5) GE Topical Report NEDC-31677P-A, " Technical Specificatson Improvement Analysis for BWR isolation Actuation Instrumentation", July 1990

6) Letter, A. C. Thadani (NRR) to D. N. Grace (BWROG), " General .

Electric Company (GE) Topical Report NPDC-30936P, 'BWR Owners Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation), Part l'", dated December 9, 1988

7) Letter, G. E. Rossi (NRR) to D. N. Grace (BWROG), " General Elect.ric Company (GE) Topical Report NEDC 30936P, 'BWR Owners Group Technical Specification Improvement Methodology (With Den.onstration for BWR ECCS Act ntion Instrumentation) Part 2'".

dated December 9, l'188

8) Letter, C. E. Rossi (NRR) to D. N. Grace (BWROG), " General Electric Company (GE) Topical Report NEDC-30851P, Supplemnnt 1,

' Technical Specificat.fon Improvement Analysis for BWR Control Rod Block Instrumentation'", dated September 22, 1988

9) . Letter, C. E. Rossi (NRR) to D. N. Grace (BWROG), " General Electric Company (GE) Topical Report NEDC-30851P, Supplement ?,

' Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation'", dated e January 6, 1989 t

10) Letter, C. E. Rossi (NRR) to S. D. Floyd (BWROG), " General Electric Company (GE) Topical Report NEDC-31677P, ' Technical '

Specification Im rovement Analysis for BWR Isolation Actuation i

-Instrumentation'p' dated June 18, 1990 G9105101/SNLICFLR - 20

[

Attachment 2 to GNRO-91/00083 4

11) -GE Topical Report NEDC-30844P-A," BWR Owners Group Response to NRC Generic Letter 83-23,:ltem 4.5.3", March '088

12) GE Topical Report NEDC-30851P- A, "liWR Owners Group Technical Specification improvement Analyses for DWR Reactor Protection bystem", March 1988

13) -Letter, A. C. Thadani (NRR) to T. A. Pickens (BWROG), " Review of BWR Owners Group Reports NEDC-308440 and NEDC-30851P on Justification for an Extension of on-Lino Test -intervals and  !

Allowable Out-of-Service Time for BWR Reactor Protection '

Systems", dated July 15, 1987

14) Letter, O. D. Kingsley, Jr. (GGNS) to USNRC, " Extension of RPS f Instrumentation Surveillance Intervals and Allowed Outage Times .,

-(PCOL-88/09)", dated June 30, 1988 j

15) Letter,'W. T. Cottle (GGNS) to USNRC, " Extension of RRS  !

Iristrumentation Surveillance Intervals and Allowed Outage Times L

- Supplemental Information for PCOL-88/09", dated  :

Febs:ary 19, 1990 i

16) Letter, L.'L. Kintner (NRR) to W. T. Cottle (CGNS), " Issuance j

_ of Amendment No. 67 to Pacility Operating License No. NPF l Grann Gulf Nuclear Station, Unit 1, Regarding Reactor Protection System (TAC No. 68692)", dated April 24, 1990 17)' Letter, C. E. Rossi (NRR) to R. F. Janecek (BWROG), " Staff Guidance For Licensco Determination t. hat the Drift CharMteristics for Instrumentation Used-in RPS Channels are i 5 Bounded by NEDC-30851P Assumptions When the Functional Test '

Interval in Extended from Monthly to Quarterly", dated i April 27, 1988  ;

18) Letter, W. P. - Sullivan and J. F. Klapproth (GE) to M. L. Wohl $

(USNRC), " Clarification of Technical Specification Changes .

Given f u ECCS A .tuaticr. f r.::tru::entation Analysis. dated March

- I 22, 1990 19). GE Report RE-027. "Tochnical Specification Improvement Analysis ,

for the Emergency Core Cooling System Actuat ion Instrumentat ion for Grand Gulf Nuclear Generating- Station, Units 1 and 2",

December 1986 ,!

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