ML20086E111
| ML20086E111 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/30/1995 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-95-00075, GNRO-95-75, NUDOCS 9507110219 | |
| Download: ML20086E111 (7) | |
Text
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m 'ENTERGY Entsrgy epsrgtisns,Inc.
eo eox 758 Tbrt Gbson, MS 39150 Tel 601437 2800 C. R. Hutchinson
' Vce Pnndent June 30, 1995 EU nan S'ami U.S. Nuclear Regulatory Commission Nail Station P1-37 l
Washington, D.C.
20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Response to GNRI-95/00086 concerning NRC's I
Review of Revision 27 to GGNS Emergency Plan GNRO-95/00075 Gentlemen:
The attached information is submitted in response to your letter dated April 21, 1995 (GNRI-95/00086) which requested clarification of comments concerning Rev. 27 of the Grand Gulf Emergency Plan.
The attached response provides the criteria, including justification, for the selection of Technical Specifications used as the EAL for NUREG-0654, Notification of Unusual Eve'lt, Example Initiating Condition
- 8, " Loss of containment ir cogrity requiring shutdown by Technical Specifications".
An evaluation of the Technical Specifications to that criteria has been completed.
As a result of the investigation GGNS concludes the EAL's are appropriate as submitted.
Should you have any questions or concerns regarding the attached, please contact Nr. A. C. Norgan at (601) 437-2721.
Yours truly, CRE/WBA/ams attachment:
Response to GNRI-95/00086 cc (See Next Page) l lloc00 G9506221 9507110219 950630 y/i ADOCK0500g6 PDR
June 30, 1995 GNRO-95/00075 Page 2 of 3 cc Mr. J. F
"'edrow (w/a)
Asiser (w/a)
Mr. H.
Mr. R. E. UcGehee (w/a)
Mr. N. d. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. Stewart D. Ebneter (w/2)
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St.,
N.W.,
Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager (w/a)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C.
20555 l
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G9506223 i
RESPONSE TO GNRI-95/00086 Criteria for selection of Technical Specifications for NUREG-0654, Notification of Unusual Event, Example Initiating Condition #8, " Loss of containment integrity requiring shutdown by Technical Specifications":
1.
Technical Specification must contain shutdown requirement in required actions.
2.
Containment integrity is defined to be the immediate ability of the containment to contain radioactivity within allowable technical rpecification leakage limits.
j Justification: A technical specification, associated with the containment, without a shutdown requirement obviously does not meet the criteria of the referenced initiating condition. Only those Technical Speci6 cations with shutdown requirements based on the immediate physical ability of the containment to contain radioactivity provide an appropriate threshold for Notification of Unusual Event. A technical specification that requires shutdown based only on operability parameters which, if not maintained within the LCO limit, could result in a potential loss of containment under very limited conditions is not considered appropriate for the EAL. A technical specification that requires shutdown, based on operability of systems that only affect leakage down stream ofisolation valves included in the LLRT program, is not considered appropriate for the EAL.
Evaluation of technical specifications to criteria:
TS 3.6.1.1 TS contains a shutdown requirement and deals directly with containment integrity.
TS meets criteria for inclusion in EAL.
i TS 3.6.1.2 TS does not contain shutdown requirement. TS does not meet criteria for inclusion in EAL.
TS 3.6.1.3 TS contains shutdown requirement and deals directly with containment integrity. TS 3.6.1.1 requires the airlocks to be operable per TS 3.6.1.3 to meet its LCO. TS meets criteria for inclusion in EAL.
TS 3.6.1.4 TS contains shutdown requirement and deals only with MSIV Leakage Control. This is a system that only affects leakage, if any, past the MSIVs. The MSIVs are included in the LLRT program as required by TS 3.6.4. This provides a high degree of confidence that if called upon to perform their intended function, the MSIVs will limit leakage to a value which is less than the allowed containment leakage limit. TS does not meet the criteria for inclusion in the EAL.
TS 3.6.1.5 TS contains shutdown requirement and deals only with FW Leakage Control. This is a system that only affects leakage, if any, past the feed water isolation check valves.
The feed water isolation check valves are included in the LLRT program as required by TS 3.6.4. This provides a high degree ofconfidence that if called upon to perform their intended function, the feed water isolation check valves will limit leakage to a value which is less than the allowed containment leakage limit. TS does not meet the criteria for inclusion in the EAL.
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RESPONSE 'IO GNRI-95/00086 TS 3.6.1.6 TS contains a shutdown requirement and deals directly with containment integrity. TS meets criteria forinclusion in EAL.
TS 3.6.1.7 TS contains a shutdown requirement and deals with a parameter that could result in a potential loss of containment under very limited conditions. Shutdown under this LCO is required because continued operation would be beyond analyzed conditions.
Containment pressure is one of the parameters in the initial assumptions of the analyses for a Design Basis Accident. The analyses show that if the parameters are as ammM the containment will maintain its integrity. This is not to imply that if the initial pressure assumed in the analyses is exceeded, that containment integrity would not be maintained in an otherwise identical event. It simply means that operation in this area is beyond the existing analyses. Considering the conservatism used in the analyses, it is not likely that the containment would fail as a result of pressure in excess of the LCO. TS does not meet criteria for inclusion in EAL.
. TS contains a shutdown requirement and deals with a parameter that could result in a potential loss of containment under very limited conditions. Shutdown under this LCO is required because continued operation would be beyond analyzed conditions.
Containment temperature is one of the parameters in the initial assumptions of the analyses for a Design Basis Accident. The analyses show that if the parameters are as assumed, the containment will maintain its integrity. This is not to imply that if the initial temperature assumed in the analyses is exceeded, that containment integrity would not be maintained in an otherwise identical event. It simply means that operation in this area is beyond the existing analyses. Considering the conservatism used in the analyses, it is not likely that the containment would fail as a result of temperature in excess of the LCO. TS does not meet criteria for inclusion in EAL.
TS 3.6.1.9 TS contains a shutdown requirement and deals with maximum operating time limits for the containment ventilation purge system. The normal position of the isolation valves for this system is closed, except when in operation. The operability of the isolation valves is covered under TS 3.6.4. TS does not meet criteria for inclusion in EAL.
TS 3.6.2.1 TS contains a shutdown requirement and deals directly with drywellintegrity thus containment integrity. TS meets criteria for inclusion in EAL.
TS 3.6.2.2 TS does not contain shutdown requirement. TS does not meet criteria for inclusion in EAL.
TS 3.6.2.3 TS contains a shutdown requirement and deals directly with drywell integrity thus containment integrity. TS meets criteria for inclusion in EAL.
. TS contains a shutdown requirement and deals directly with drywell integrity thus containment integrity. TS meets criteria for inclusion in EAL.
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RESPONSE 'IO GNRI-95/00086 TS 3.6.2.5 TS contains a shutdown requirement and deals with a parameter that could result in a potential loss of containment under very limited conditions. Shutdown under this LCO is required because continued operation would be beyond analyzed conditions.
Diywell pressure is one of the parameters in the initial assumptions of the analyses for a Design Basis Accident. The analyses show that if the parameters are as assumed, the containment will maintain its integrity. This is not to imply that if the initial pressure assumed in the analyses is exceeded, that containment integrity would not be maintained in an otherwise identical event. It simply means that operation in this area is beyond the existing analyses. Considering the conservatism used in the analyses, it is not likely that the containment would fail as a result of pressure in j
excess of the LCO. TS does not meet criteria for inclusion in EAL.
TS 3.6.2.6 TS contains a shutdown requirement and deals with a parameter that could result in a potential loss of containment under very limited conditions. Shutdown under this LCO is required because continued operation would be beyond analyzed conditions.
Drywell temperature is one of the parameters in the initial assumptions of the analyses for a Design Basis Accident. The analyses show that if the parameters are as
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assumed, the containment will maintain its integrity. This is not to imply that if the initial temperature assumed in the analyses is exceeded, that containment integrity i
would not be maintained in an otherwise identical event. It simply means that operation in this area is beyond the existing analyses. Considering the conservatism
- -j' used in the analyses, it is not likely that the containment would fail as a result of l
temperature in excess of the LCO. TS does not meet criteria for inclusion in EAL.
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TS 3.6.2.7 TS contains a shutdown requirement and deals with maximum operating time limits for the drywell ventilation purge system. The normal position of the isolation valves for this system is closed, except when in operation. The operability of the isolation i
valves is covered under TS 3.6.4. TS does not meet criteria for inclusion in EAL.
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TS 3.6.3.1 TS contains a shutdown requirement and deals with a system required for the pressure l
suppression function of the containment. The suppression pool is required to suppress the energy released in a Design Basis Accident as well as the energy released j'
form SRV lifts. TS 3.6.1.1 and TS 3.6.2.1 require the suppression pool to be l
operable per TS 3.6.3.1 to meet its LCO. TS meets criteria for inclusion in EAL.
l (Note: TS 3.5.3 also deals with suppression pool operability but from an ECCS operability perspective and not a containment integrity perspective. TS 3.5.3 only requires a lower level limit for the pool. TS 3.6.3.1 provides the same lower level limit as well as an upper level limit and a temperature limit. TS 3.6.3.1 bounds TS 3.5.3 in all cases. TS 3.5.3 does not meet the criteria for inclusion in the EAL) 4 TS 3.6.3.2 TS contains a shutdown requirement and deal with a system that is considered an Engineering Safety Feature. TS does not meet criteria for containment LCO but does meet criteria for ESF technical specification.
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RESPONSE TO GNRI-95/00086
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TS 3.6.3.3 TS contains a shutdown requirement and deals with a system that provides cooling to the suppression pool. Suppression pool cooling operability is not required for i
containment integrity. Establishing and maintaining adequate core cooling has a higher priority than suppression pool cooling. This is evident by the fact that the LPCI function of the RHR system is required to ie maintained in standby and will automatically start and inject into the RPV under LOC /wonditions. The suppression pool cooling function of the RHR system is a manual operation and if the RHR system is needed to maintain adequate core cooling by LPCI injection would not be overridden and placed in the suppression pool cooling mode. It should be noted that in the event of a LOCA, the emergency operating procedures direct injection through the RHR heat exchangers as soon as possible. Under these conditions, the suppression pool cooling is effectively cooled by cooling the heat source of the pool.
TS does not meet criteria for inclusion in the EAL.
TS 3.6.3.4 TS contains a shutdown requirement and deal with a system that is considered an Engineenng Safety Feature. TS does not meet criteria for containment LCO but does meet criteria for ESF technical specification.
TS 3.6.4 TS contains a shutdown requirement and deals directly with containment integrity.
TS meets criteria for inclusion in EAL.
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TS 3.6.5 TS contains a shutdown requirement and deals with a system that is designed to minimize weir wall overflow, from the containment back into the drywell, following a LOCA event. Weir wall overflow, while not necessarily desirable, does not affect j
drywellintegrity thus does not affect containment integrity. TS does not meet criteria for inclusion in the EAL.
i TS 3.6.6.1 TS contains a shutdown requirement and deals directly with secondary containment i
integrity. TS meets criteria for inclusion in the EAL.
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TS 3.6.6.2 TS contains a shutdown requirement and deals directly with secondary containment integrity. TS meets criteria for inclusion in the EAL.
TS 3.6.6.3 TS contains a shutdown requirement and deals directly with secondary containment j
integrity. TS meets criteria for inclusion in the EAL.
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TS 3.6.7.1' TS contains a shutdown requirement and deals with a system designed to control hydrogen concentration in the containment. Loss of this system does not cause an immediate loss of containment capability as evidenced by the 30 day INOP grace period before plant shutdown is required. If the DBA event occurred with the e
hydrogen recombiners INOP, the HCOG Emergency Operating Procedures provide h
guidance to ensure continued containment integrity. TS does not meet criteria for inclusion into EAL.
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RESPONSE TO GNRI-95/00086 TS 3.6.7.2 TS contains a shutdown requirement and deals with a system designed to control hydrogen concentration in the containment and drywell. The function of this system is to remove hydrogen following a beyond design bases degraded core event. This system is not included in the analysis for Design Basis Accidents because the amount of hydrogen generated from a DBA can be maintained below the flammability limit j
by the hydrogen recombiners. TS does not cause an immediate loss ofcontainment capability as evidenced by the 7 day INOP grace period before requiring plant shutdown. TS does not meet criteria for inclusion in the EAL.
TS 3.6.7.3 TS contains a shutdown requirement and deals with a system that is designed to assist in the control of hydrogen concentration in the drywell. Loss of this system does not threaten the integrity of the drywell. The hydrogen igniter system will function to control hydrogen both in the drywell and containment with or without this system.
TS does not cause an immediate loss of containment capability as evidenced by the 30 day INOP grace period before requiring plant shutdown. TS does not meet criteria for inclusionin EAL.
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