ML20086H038

Informs of Deletion of Reporting Requirement for Summary Startup Rept for Plant Startup & Power Escalation to NRC

ML20086H038
Person / Time
Site:	Grand Gulf
Issue date:	07/14/1995
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GNRO-95-00084, GNRO-95-84, NUDOCS 9507170389
Download: ML20086H038 (3)

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C. R. Hutchinson vu Prewcw Opva%ns GWyj G:# Monar S'AM July 14, 1995 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Deletion of the Reporting Requirement for the Summary Startup Report for the Plant Startup and Power Escalation to the NRC.

GNRO-95/ 00084 Gentlemen:

Grand Gulf Nuclear Station has routinely submitted a Startup Summary Report following each refueling outage. However, a Startup Report for Cycle 8 is not required by the reporting criteria. Also, please be advised that Grand Gulf Nuclear Station has eliminated requirements for a summary report as allowed by 10CFR50.59 and does not plan to submit any future Startup Reports. The following discussion provides details of the change.

Since relocation of certain iterns from the Technical Specifications to the Technical Requirement Manual (TRM), Grand Gulf has made changes to the TRM as allowed by 10CFR50.59. A recent change involves deletion of the reporting requirement for plant startup and power escalation testing. The requirement of TRM 7.7.1.1 is based on an FSAR commitment in Appendix 3A to comply with Regulatory Guide (RG) 1.16, " Reporting of Operating information-Appendix A, Technical Specifications." This RG specifies that a summary report of plant startup and power ascension testing be submitted under certain conditions. The purpose of the report is to compare test results to design predictions / specifications and to ensure that the tests addressed in the FSAR have been considered. These tests are routinely performed after each refueling outage.

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be duly 14,1995 GNRO-95/ 00084 Page 2 of 3 The primary justification for deletion of the reporting requirement is that the information being summarized for transmittal to the NRC is adequately contained in plant records of the applicable test procedures. These records are available on site for Staff review. Should there be any significant deviation from expected results, appropriate controls exist to document and resolve non-conformances, including reporting deviations to the Commission when necessary. The report as it is now structured contains only the most basic information on physics testing and refers to other documents and programs available on site. Testing needed for plant and fuel design changes is sufficiently controlled and documented by the Design Change Program, the Safety Evaluation (10CFR50.59) process, Technical Specification surveillance requirements, and in some cases Operating License Amendments.

Each section of the current Startup Test Report, along with a primary source of the information available on site is listed in Attachment 1.

Thus, the Startup Test Report required by the FSAR and TRM is not necessary to ensure plant safety or to document compliance with applicable test requirements.

Please contact Avinash Goel at (601)-437-6296 should you have any questions, or require additional information.

Yours truly, //s

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AJ)/1 cg Attachment %

cc:

Mr. Jeff Tedrow Mr. H. W. Keiser Mr. R. B. McGehee Mr. N. S. Reynolds Mr. H. L. Thomas Mr. Stewart D. Ebneter, Regional Administrator U.S. Nuclear Regulatory Commission Region !!

101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323

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'4 GNRO-95\\00084 ATTACHMENT 1 1.

Test Summary The only significant information in this section is the type and number of reload assemblies. This is available in the reload safety evaluation, as well as in the vendor reload design reports (Ref: Seimens Report EMF-94-188(P)). Finalloading pattem confirmation is available via Reactor Engineering controlled computer files which track j

special nuclear material as well as via item 2 below.

2.

Core Loading Verification Documented per procedure 17-S-02-108, Core Loadino Verification.

3.

Control Rod FunctionalTesting f

Documented per 17-S-02-400, Att. I, Control Rod Movement Sheets and 06-OP-1C11-S/U -0002, Control Rod Couoling Check: 04-S-03-C11-5, Control Rod Stroke Time Testing; 17-S-02-403, CRD Differential Pressure / Friction Testing; and,06-RE-SC11-V-0402, Control Rod Scram Time Testing.

4.

Shutdown Margin Determination Documented by 06-RE-SB13-V-0401, Shutdown Margin Demonstration.

i 5.

TIP Asymmetry Check t

i-Documented per 17-S-02-201, TIP Reoroducibility and Symmetry Uncertainty j

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Calculations.

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6.

Other Tests There are other core and NSSS related tests which could potentially be considered l

pertinent for a particular reload although they are not typically included in routine

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Startup Reports. These are also adequately documented as indicated. They are Egactivity Anomalies (documented per 06-RE-SB13-V-0017), Power Distribution Limits Verification (documented per 06-RE-1J11-V-0001), Jetoumo Functional Test, j

-(documented per 06-RE-1833-D-0001), and Core Monitoring System Verification (documented per 17-S-02-500).

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