ML20081K776
| ML20081K776 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/25/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20081K778 | List: |
| References | |
| GNRO-91-00086, GNRO-91-86, NUDOCS 9107020016 | |
| Download: ML20081K776 (12) | |
Text
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~_<tX 4370473 W. T. Cottle is 2
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h June 25, 1991 U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. 20555 Attention: Document Control Desk I
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Extension of Interval Between Containment Integrated Leak Rate Tests Proposed Amendment to the Operating License (PCOL-91/14)
GNRO-91/00086 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 revision of the Technical Specifications (TS) to allow a one-time extension of the required test interval for Overall Integrated Containment Leakage Rate Tests (Type A tests) as specified in TS 4.6.1.2.a. The amendment also requests that the TS 4.6.1.2.a requirement coupling the third Type A test to the plant shutdown for the 10-year Inservice Inspection outage be permanently ,
deleted.
Also included in thic submittal is an application for the appropriate exemption from 10CFR50 Appendix J regulations under the provisions of 10CFR50.12(a). The requested exemption corresponds to the proposed TS changes and is necessary to allow the license amendment.
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 TS changes, and Attachment 3 contains the application and justification for the requested Appendix J exemption.
t Based on the guidelines presented in 10CFR50.92, Entergy Operations, Inc. j has concluded-that this proposed amendment involves no significant ll hazards considerations. In addition, Entergy Operations has concluded that the requested Appendix J exemption meets the criteria of 10CFR50.12(a) and should be granted.
G9105161/SNLICFLR - 1 .
9107020016 910625 ghU'\
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June 25, 1991 GNRO-91/00086 Page 2 of 3 j l
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Due to the significant lead time required to schedule and prepare for Type A containment leak rate testing, Entergy Operations, Inc. is :
requesting action on this submittal by October 2, 1991. This is necessary to support the schedule for the fifth refueling outage set to begin in April, 1992.
.Yours truly, 44> Pd% tex::-
WTC/KLW/mtc attachments: 1. Affirmation por 10CFR50.30
- 2. GGNS PCOL-91/14
- 3. Request for Exemption cc: Mr. D. C. Hintz (w/a)
Mr. J. Mathis (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. S Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. F. W. Titus (w/a)
Mr. Stewart D. Ebneter (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta 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 Mail Stop 11D21 Washington, D.C. 20555 Dr. Alton B. Cobb (w/a)
State Health Officer State Board of Health P.O. Box 1700 Jackson, Mississippi 39205 G9105161/SNLICFLR - 2
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BEFORE THE i
UNITED STATES NUCLEAR REGULATORY COM'ilSSION l LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGilT COMPANY and SYSTEM ENERGY RESOURCES, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.
AFFIRMATION I, W. T. Cottle, 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 forth therein are true and correct to the best of my knowledge, informetion.and belief.
ca;> r r ~
W. T. Cottle STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TG before me, a Notary Public, in and for the County and-State above named, this 3% day of Gum , 1991.
(SEAL) b ehy 6 (bo onm Notary {p' lic My commission expires:
My e m u bn b p c M 1. u n G9105161/SNLICFLR - 4
Attschment 2 to GNRO-91/00086 GGNS PCOL-91/14 G9105161/SNLICFLR - 5
, Attachment 2 to GNRO-91/00086 Page 1 A. SUBJECT
- 1. PS-91/02 Extension of Interval Between Containment Integrated i Leak Rate Tests '
- 2. Affected Technical Specifications:
- a. Surveillance Requirement 4.6.1.2.a - Page 3/4 6-3
- b. Bases 3/4.6.1.2 - Page B 3/4 6-1 B. DISCUSSION
- 1. The requested change revises Surveillance Requirement 4.6.1.2.a ;
of the Grand Gulf Nuclear Station (GGNS) Technical Specifications l (TS). This Surveillance specifies the frequency of periodic Type A Containment Integrated Leakage Rate Tests (ILRT) as defined in 10CFR50, Appendix J. The proposed change allows a one-time extension of the test interval to accommodate performance of the third Type A test during the sixth refueling outage (RF06). Also, the requirement to conduct the third ILRT ,
while the plant is shutdown for the 10-year Inservice Inspection '
(ISI) is deleted.
(Figure 1 presents a time-line depicting the past and planned !
test and outage schedule.) The first periodic ILRT was completed on November 4, 1985, during a maintenance outage. The last (second peric,dic) ILRT at GGNS was performed in conjunction with the third refueling outage (RF03) during the period April 15-16, 1989. In accordance with current TS 4.6.1.2.a. the next (third periodic) ILRT must be performed 40 + 10 months later, or between October, 1991, and June 1993. This TS also requires that the e third periodic test in a 10-year service period be conducted during the shutdown for the 10-year ISI. Since GGNS entered l commercial operation _on July 1, 1985, the first 10-year ISI will not be conducted until the seventh refueling outage (RF07) tentatively planned for April, 1995.
- 3. As a result of the timing of the events above, it is not possible to simultaneously meet all of the test interval requirements of TS 4.6.1.2.a as currently written. For example, performing the third periodic test during the fifth refueling outage (RF05) planned for April, 1992, would meet the allowed interval (approximately 36 months elapsed), but would not be dono during the 10-year ISI.
Under the current requirements,. testing during RF06 planned for October, 1993, would not coincide with either the allowed interval (approximately 54 months elapsed) or the 10-year ISI outage. Conducting the third periodic ILRT during RF07 planned for AprII,1995, would satisfy the 10-year ISI outage requirement, but would not meet the interval requirement since it would fall approximately 72 months af ter the previous test (see Figure 1).
G9105161/SNLICFLR - 6
Attachment 2 to GNRO-91/00086 Page 2
- 4. GGNS proposes to perform the third ILRT during RF06. The proposed TS revision provides for a one-time extension of the 40
+ 10 month interval via a footnote to TS 4.6.1.2.a. This footnote stipulates that testing is to be performed prior to unit restart following the sixth refueling outage. The extension thus expires at the end of that outage. The footnote is also noted as an exemption to Appendix J requirements.
The proposed TS revision also deletes the second wentence of TS 4.6.1.2.a which requires conduct of the third test during plant shutdown for the 10-year ISI. This is requested as a permanent TS change. Bases 3/4.6.1.2 is also being revised to include the exemption to Appendix J corresponding to this proposed TS change.
- 5. The affected TS and Bases oages are attached and marked up to reflect the proposed changes described above.
- 6. The appropriate request for an exemption to the requirements of 10CFR50, Appendix J to accommodate the proposed changes is presented in Attachment 3.
- 7. The requested license amendmenc has been developed in a manner consistent with recent comparable license amendments approved by the NRC. These include Public Service Electric and Gas Company's Salem Nuclear Generating Station, Unit 1; Tennessee Valley Authority's Sequoyah Nuclear Plant, Units 1 and 2; GPU Nuclear Corporation's Three Mile Island Nuclear Station, Unit 1; Toledo Edison's Davis-Br.sse Nuclear Power Station, Unit 1; and Duke Power Company's McGuire Nuclear Station, Unit 1. These facilities requested changes that were, in total or in part, similar to those requested herein. These revisions are necessary to allow GGNS to meet the intent of Appendix J regarding periodic Type A testing within the constraints imposed by operating history and the planned refueling outage schedule, and wichout undue hardship and cost.
- 8. The requested license amendment is niso consistent with contemporary containment leak rate testing philosophy as reflected in proposed revisions to Appendix J currently under development. This philosophy has evolve <1 through several years of discussion among industry groups, including the NRC, who have been closely involved with containment leakage testing. Two of the pending changes to Appendix J would separate the ILRT schedule from the 10-year ASME Section XI Inservice Inspections, and would specify a 4 year interval between Type A tests with an extensic.n of up to 5 years (60 months) to be allowed by TS.
l G9105161/SNLICFLR - 7
l Attachment 2 to GNRO-91/00086 page 3 C. JUSTIFICATION
- 1. As described in B.3 above, there is no testing r.cenario consistent with the planned refueling outage schedule that would allow GGNS to meet the ILRT frequency constraints imposed by TS 4.6.1.2.a as written. The past timing of the Type A tests has been the result of complying with TS requirements given plant operating history which included an unanticipated delay of approximately 42 months between the Preoperational ILRT and completion of power ascension testing. Further, a forced plant shutdown anlely for the purpose of conducting the third periodic ILRT wcaid also not meet the TS provisions since any test performed prior to RF07 would not be during the 10-year ISI outage. Thus, the existing TS must be revised to enable compliance.
- 2. The proposed changes extend the allowed test interval beyond the current maximum of 50 months to permit ILRT performance during RF06. The intent of the established test interval is to conduct three approximately equally spaced Type A tests within a given 10-year Inservice period. The proposed extension remains consistent with that intent. In fact, the extension provides for a more uniform spacing of the three ILRTs during the first 10 years. Also, the alternative of conducting the third periodic ILRT during RF05 in order to meet the 49 + 10 month requirement would necessitate conducting another test during RF07. This would result in four Type A tests during the first 10 year inservice period, which is clearly not the intent of Appendix J regulations.
It is estimated that performance of an additional test would add 2 days to the outage schedule and cost approximately $2,125,000 for labor, equipment, and replacement power. It would also result in an estimated 9 man-rem of exposure to test personnel, GGNS feels that such additional costs are in excess of those contemplated when the regulation was adopted.
- 3. There is no trend in previous test results which would indicato that an extension of the maximum test interval by approximately 4 months would jeopardize the ability of the containment to maintain the leakage rate at or below the required Type A limits.
The three previous tests conducted at GGNS resulted in leakage rates of 42%, 57%, and 54%, respectively, of the allowable leakage rate 0.75 L . (The second ILRT, or first period!c test, was initially cons 10ered to be an as-found failure, however this was solely due to identified local penetration leakage which ras corrected.) Also, industry data indicate that most ILRT failures are due to leakage through penetrations which are Type B or C local leak rate tested (LLRT). These LLRTs are conducted on all penetrations every refueling outage at GGNS (and more f requently on some penetrations), and provide sufficient verification of acceptable containment leakage rates between ILRTs. The previous Type B and C tests at GGNS were conducted during RF04 and were satisfactorily completed in accordance with TS 4.6.1.2. Similar j LLRT testing will be conducted during RF05. l G9105161/SNLICFLR - 8
Attachment 2 to GNRO-91/00086 Page 4
- 4. There have been no permanent modifications to the containment structure, liner, or penetrations which would adversely affect the Type A test results sJace the last successful ILRT.
Likewise, there have beer, no Temporary Alterations to containment features which might insalidate previous ILRT results.
Presently, no such modi fications to the containment boundary are planned prior to PF06 when the next ILRT will be conducted under the proposed TS revis,on. Major modifications to the containment prior to the next se'.ieduled ILRT would be subject to the special testing requirements of Section IV.A of Appendix J.
- 5. The proposed modification of the Type A test schedule is a one-time extension. Following RF06, the ILRT schedule will be appropriately planned to meet the required test interval in the future.
- 6. Due to the dif ferences in scheduling requirements of ASME Section XI and TS 4.6.1.2.a, Entergy Operations believes that the connection of the third ILRT to a 10 year plant inservice inspection is inappropriate and impractical, and should be removed.
GGNS is committed to ASME Section XI, 1977 Edition, through and including the Summer 1979 Addenda for performing inservice inspections and associated examinations and tests. The GGNS Inservice Inspection Program, SERI-M-489.1 implements Inspection Program B of IWB-2412. This provides for three 40 month periods equaling a 120 month (10 year) interval. Inservice inspections, including pressure testing, are performed within each of the 40 nalendar month periods and not at 40 month elapsed intervals.
TS 4.6.1.2.a requires performance of ILRTs at 40 1 10 month intervals af ter the initial ILRT. The need to meet both of these requirements within the restrictions imposed by the plant operating cycle creates a virtually unavoidable scheduling conflict between the two programs. For example, at GGNS the initial ILRT was performed early in the 10 year inspection period to meet TS requirements and operating constraints at that time.
Therefore, ta be within the required TS interval, the third ILRT must be scheduled two outages prior to the 10-year inservice inspection outage, which is inconsistent with the coupling criterion.
Additionally, TS 4.6.1.2.a places emphasis on the 10-year inservice inspection process. A review of ASME Section XI and the GGNS Inservice Inspection Program does not identify any specific requirements that make the last inspection of a 10-year period unique. The only possible connection between performing ,
the third ILRT at the 10 year inservice inspection outage involves the assumption that the Class 1 hydrostatic tests are deferred to the end of the 10-year period as allowed by ASME Section XI. In that case, Class 1 components penetrating the containment would be hydrostatically tested at elevated pressures during the outage. Even then, no added benefit to conducting an ILRT at this time could be identi fied .
G9105161/SNLICFLR - 9
Attachment 2 to GNRO-91/00086 page 5
- 7. In addition to there being no practical need to couple the ,
Appendix J and ASME Section XI inspection programs in the same '
outage, there is no safety significance to doing so. The original purpose of the TS 4.6.1.2.a requirement to perform the third periodic Type A test during the 10-year ISI outage was to provide a concur ent milestone to ensure that the three tests are approximately evenly spaced during the 10-year inservice period. i As discussed in C.2 above, this will remain the case with the i proposed extension.
The two programs evaluate different plant characteristics, and the methods for complying with each program are considerably different. The purpose of the containment leak rate test program as described in the introduction to 10CFR50 Appendix J in to ensure that leakage through the primary reactor containment, and systems and components penetrating the primary containment, does not exceed allowable leakege rate limits. These limits help to ensure compliance with the guidelines of 10CFR100. The ASHE Section XI inspection program is intended to separately ensure !
that the situctural integrity of Class 1, 2. and 3 components is maintained in accordance with the regulrements of the code, depending upon the safety function of those components.
Coupling the third periodic ILRT to the 10-year ISI thus does not enhance the purpose of Type A testing nor does it provide further assurance of containment integrity above that which is already being demonstrated. Therefore, the requirement of TS 4.6.1.2.a linking the Type A test to the 10-year ISI outage may be deleted without negatively impacting plant safety.
- 8. The proposed changes are exceptions to the language of Appendix J as currently written. Attachment 3 provides the Request for Exemption from the provisions of Appendix J to allow the TS changes requested.
D. NO SIGNIFICANT !!AZARDS CONSIDERATIONS The proposed amendment n.
- cs the TS by providing a footnote to TS 4.6.1.2.a allowing a one-Lite extension of t he Appendix J Type A test interval, in addition, the requirement to perform the third per!ndic ILRT is deleted and the Bases are revised to identify these changes as. exemptions from Appendix J regulations.
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 consideration 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 evaluated; or (3) involve a significant reduction in a margin of safety.
G9105161/SNLICFLR - 10 ym-y w w y--e w--,- w
Attachment 2 to GNRO-91/00086 page 6 Entergy Operations has evaluated the no significant hazatdn considerntions in its request for a license amendment. In accordance with 10CPR50,91(a), Entergy Operations is providing the analysis of the propsed amendment against the thren standards in 10CFR50.92:
- 1. No significant increase in the probability or consequences of an accident previously evaluated results from this change.
- a. The proposed extension of the surveillanco interval does not increase the chances of an accident occurring. Containment integrity is related only to the mitigntion of accident consequences, and containment leakage in not the precursor to any analyzed event. Regarding accident consequences, extension of the interval will not af fect. the containment's ability to maintain leakagn below that nasumed in the safety analyses. The previous Type A tests were completed successfully, and there have been no plant modifications since the last test (other than thoso requiring Type B or C testing) which would directly affect the test results.
Type B and C testing of individuni penetrations has been satisfactory, and there ha.c been no pressure or temperature excursions in the containment which could have advereely affected containment integrity. Th-re is no change to the testing methodology or acceptance criterin. No pinnt modifications which could degrade the ability of the containment to mnintain leakage within the assumptiens of the safety analyses are associated with this change, nor are any planned.
- b. The proposed decoupling of the Appendix J Typo A tests from the 10-year ISI outnge also does not affect the probability of aa accident occurring or the consequences of any analyzed event. The coupling of the ILRT to the ISI is not dun to any known technical requirements, and does not enhance the purpose of the Type A test or provide additional assuranco of containment integrity above that already being demonstrated.
This coupling is not assumed in any safety analysis,
- c. Thus, the proposed revision will not significantly increase the probability or consequences of any accident previously evalunted.
- 2. The change would not create the possibility of a new or different kind of accident from any previously analyzed,
- n. The proposed one-time extension of the test frequency does not affect the ILRT methodology or acceptanco criteria nor does it alter the physical containment structure or boundary in any way. There is no addition or rcmoval of plant hardwarn or any caanges to test methodology. No new plant operating modes are being introduced. Results of previous ;
Appendix J tests remain well below allowable limits, and j there have been no plant modifications since the last tests which could affect these results.
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Attachment 2 to GNRO-91/00086 Pnge 7
. 8
- b. The decoupling of Appendix J testing from the 10-yont ISI outage does not impono any new requirements on plant operation or testing. The test methods, hardware, and acceptance criterin remain unchanged. There in no identiflod anfoty significanco annoeinted with the coupling of the two tont/ inspection programs during the name tefueling outogo.
- c. Therefoto, the proposed changen to the Type A test interyn) will not create the possibility of a new or dif ferent kind of accident from any accident previously evnlunted.
- 3. This change would not involve a significant reduction in the margin of nnfaty.
- a. Safety margin in established through the GGNS nafety annlynon an reflected in the TS 1.imiting conditionn for operation.
Containment leak raten annumed in the nafety analynen are not incronned by the proposed changen to the surveillance interval. The acceptence criterin which must be met to verify that lonk rates remain within the annumod valuon are also not changed. Although the tent frequency in reinxod for the one-timo extension, no plant h.odificctions have been made which would invalidato pant lonk tent resulta confirming acceptablo containment integr.ity. Further, no nuch modifications are pinnned. Appendix J tonting and 181 nro unreinted with respect to any nafety margin, and decoupling of those two programs from the name outni.o in no way reduces the margin of snfoty annociated with olther program,
- b. Thus, thin chango will not involve a significant reduction in :
the margin of nafety.
Based on the abovo evaluation, Entergy Operations, Inc. han concluded that operetion in accordance with the proposed amendment involven no significant har.ards considerations.
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Figure 1 t
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GGNS REFUELING OUTAGE AND ILRT SCHEDULE t
i Actual Planned !;
2 Beginning of t i
Commercial
! '. Operation t 1
L (7/1/85) 10-vr ist
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- i i Pre-Op 1st LRT >
LRT 2nd LRT 3rd LRT =
(11/4/85) {4/ 16/89) (10/ 93)
(1/4/82) $ -
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- LRT = Integrated Leak Rote Test m o (
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, RFO = Refueling Outoge e l
l 151 = Inservice inspection $O g [
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