ML20114B121
| ML20114B121 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/19/1992 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20114B123 | List: |
| References | |
| GL-88-01, GL-88-1, GNRO-92-00092, GNRO-92-92, NUDOCS 9208250035 | |
| Download: ML20114B121 (10) | |
Text
__
"e Entergy Operations,Inc.
= ENTERGY r
,e
- tr j
I F1 7
W. T. Cotus August 19, 1992 U.S. Nuclear Regulatory Commission liall Station PI-137 Washington, D.C.
20555 Attention:
Document Control E ik
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 hicense No. NPF-29 Technical Specification Changes incorporating the Requirements of Generic het ter (Gh) 88-01 Proposed Amendment t.o the Operating hicense (PCoh-92/06)
GNRD-9?/00092 Gentlemen:
By this letter, Entergy Operations, Inc. is submitting a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License. The proposed amendment requests changes to Technical Specification (TS) 4.0.5, Applicability, and TS 3/4.4.3, React or Coolant System I.eakagn.
Specifically, the proposed amendment. (1) modifies the TS regarding GGNS's inservice inspect.f on (ISI) program to include a statement of compliance wit h t.he NRC sta f f posit ion on schedule, methods, personnel and sample expansion given in Gh 88-01 and (2) revises the reactor coolant system (RCS) leakage monitoring requiremants, By a lett er dated Gctober 1, 1990, t he NRC t ransmitted its sa fety evaluation and associated Technical F. valuation Report of GGNS's response to Gh 88-01.
The October 1, 1990 letter indicated that GGNS had acceptably implemented t he technical aspects of GI. 88-01 by accept ing the St a f f's recommendations on IGSCC inspection, mit igstion and other aspects of 1GSCG det ect ion by incorporat.ing necessary revis ions into the GGNS 181 program.
The sa fety eva lua t.f on a lso identi fled four 1icensing issues for which GGNS was requested to propose license amandments. GGNS responded to these four issues by a lot t er dat ed December 7, 1990.
GL 88-01, Supplement 1, "NRC Pos ition on Intergranular Stress Corros ion Cracking (IGSCC) in BWR Austenttic Stainless Steel Piping" was issued on February 4, 1992.
By a letter dated June 5, 1992, GGNS agreed to propose Technica1 SpenifIcation changes to the ISI section and the henkage Detec t ion System section cons is t ent w it h t he staff >ositions.
g0k G9207211/FNI.ICFhR - 1 e
1\\\\
9208250035 920818 N0007 L
PDR ADOCK 05000416 i
P PDR
August 19, 1992 GNRO-92/00092 Page 2 of 3 In accordance with the provisions of 10CFR50.4, the signed original of the proposed amnndment is enclosod. provides the discussion and justifIcatlon to support the proposed amendment. is a copy of the marked-up TS pages. shows the proposed changos in their final form and is provided for information. This proposed amendment has been reviewed and accepted by the Plant Sa fet y Rev iew Committ ee and the Safety Review Committee.
Based on the guidelines given in 10CFR50.92, Entergy Operations has concluded that this proposed amendmnnt involves no significant hazards consideraLions.
Yours truly, wy CR11~;.
WTC/SBM/mte a L t.a chm en t s :
1.
Affirmation per 10CFR50.30 2.
GGNS PC01-92/06 3.
Marked-up TechnIca1 Specificat. ion Pages 4.
Proposed Technical Specification Pages cc:
Mr. D. C. Mintz (w/a)
Mr. J.
I., Mathis (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. II.
- h. Thomas (w/o)
Mr. Stewat J. Ebneter (w/a)
Regionni Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St.,
N.W.,
Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Mannger tw/2)
Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13113 Washington, D.C.
20555 Dr. Alton B. Cobb (w/n)
State Ilea lth Of f icer State Board of llealth P.O.
Ilox 1700 Jackson, Mississippi 39205 G9207211/SNLICFhR - 2
itEPOPE Tilf.
UNITED STATES NUCl. EAR Kl.GillATokY CO!1MISS10N 1.lCf.NSE NO. NPP 29 DOCKET NO. 50-416 IN Tile M ATYl.R OF HISSISSlPPI POWER & l.lGilT COMPANY and SYSTEtt ENP.RGY RESOURCES, INC.
nwl SOUTil MISSISSIPPI El.ECTRIC POWER ASSGCI ATION 1
ntul ENTERGY OPERATIONS %:.
AEElk /tHDN I
1, W. T. Cottln, bning duly sworn, stnto that I nm Vice President, Operations GGNS of Entergy Operntloes, Inc.; that on behal f of Entorgy Operations, Inc., Syst em Energy Resources, Inc., and Sout h 111ssissippi Elect ric Power Association I am authorized by Entergy Operations, Inc. to sign nni file with thn Nuclent Regulatory Commission, this appliention
)
for amendment of tho Operating I lcenso of the Grand Gulf Nuclear Stntion; that I signed this application as Viro President, Operations CGNS of Futergy Operations, Inc.; and that t he stat ernents mndo and t he mnt t nra wt fort h theircin are true nnr1 cot n ect to t he best of my knowledge, information onr1 belief.
e L-3?1i A4"~
W. T. Cottle STATE OF MISSISSIPPI COUNTY OF Cl.A100RNr.
SUBSCRIDED AND SWORN TO bnforn en e, n Notary Public, in nwl for the Count y and State 'bove named, this M day of Qe u tky-1992.
(SEAL)
_h akok b %
Notary Pibli My commission _ expires:
5']Dr c hiD'MJ.iU
___ __.._ ___..S \\.% p q % - WD Q
G9207211/SNLICFLR - 4
. to GNRO-92/00092
+
PROPOSED Cl ANGE TO Tile OPERATING LICENSE INCORPORATING Tile RE9"tREMENTS OF GENERIC LETTER 88-01 (GGNS PCOL-92/06) t i
o
, to GNRO-92/00092 Page 1 of 6 A.
SUBJECT:
Technical Specification (TS) Changes incorporating the Requirements of Generic Letter (GL) 88-01 i
e Affected Pages:
TS 4.0.5 - page 3/4 0-3 TS 3.4.3.2 - page 3/4 4-9 and 3/4 4-10 t
D.
DISCUSSION AND JUSTIFICATION:
Cn January 25,'1988, the NRC issued Generic letter (GL) 88-01, "NRC Position on IGSCC in DWR Austenitic Stainless Steel Piping." Grand Gulf Nuclear Station (GGNS) responded to GL 88-01 on August 8,1988 (Reference 1). Additional information was provided to the Staff on July 14,1989 (Reference 2) and April 23,1990 (Reference 3).
'Ihe NRC transmitted its_ Safety Evaluation and associated Technical Evaluation Report on GGNS's response to GL 88-01 on October 1,1990. This letter indicated that GGNS had acceptably implemented the technical aspects of GL 88-01 by accepting the Staff's recommendations on IGSCC inspection, mitigation and other aspects of 1GSCC detection by incorporating necessary revisions into the GGNS Inservice Inspection (ISI) Program.
GGNS was also requested to propose license amendments for four licensing issues.
By a letter dated December 7,1990 (Reference 4), GGNS responded to each of the four licensing issues and stated that the current TS provided reasonable assurance of maintaining the long term structural integrity of austenitic stainless steel piping in GGNS.
On February 4,1992, the NRC issued Supplement I to GL 88-01. Supplement 1 provided acceptable alternative staff positions to some of those delineated in GL 88-01 with regard to the leak detection requirements for leakage measurement instrument operability and the frequency of monitoring leakage rates. The supplement also clarified the staff positions regarding the technical specification (TS) amendments needed to incorporate the inservice inspection statement and leak detection requirements.
- By a letter dated June 5,1992 (Reference 5), GGNS agreed to propose changes to the
.GGNS TS consistent with the guidance in GL 88-01 and GL 88-01, Supplement 1 (1) tu
.. modify the frequency of reactor coolant leakage measurement from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, (2) to include a statement in the 'section that the ISI program for piping covered by GL 88-01 will. conform to the sta, sitions on ahedule', methods, personnel and sample expansion, and (3) to modify the leakage detection TS consistent with the staff position in GL 88-01.
L i
i,
~
_,.,-._,_.._,,._.-_._,___..=,,r
__~.- _.- __-._.- - - -.-.-
. to GNRO-92/00092 Page 2 of 6 De proposed changes are:
i 1) include a nanment u YS 4.0.5.f which states:
De Iriservice inspection program for piping identified in NRC Generic letter 88-01 shall be performed in accordance with the NRC staff positions on schedule, methods, personnel, and sample expansion included in Generic letter 88-01 or in accordance with alternate measures approved by the NRC staff.
t Justl0catiom The wording of this proposed statement corresponds to that specified in the NRC's Safety Evaluation Report dated October 1,1990.
Incorporation of the above paragraph into TS 4.0.5 provides a formal endorsement of the staff position. We current GGNS ISI program complies with this staff position. Therefore, this change is administrative in nature and has no impset on plant safety, 2)
Change TS 3.4.3.2.e to specify that reactor coolant leakage shall be limited to a 2 gpm increase in unidentified leakage within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or less. This change is also reflected in TS 3.4.3.2 Action e for consistency. The changes are proposed as follows:
Limitine Condition for 03eration 3.4.3.2.e Reactor coolant system leakage shall be limited to 2 gpm increase in UNIDENTIFIED LEAKAGE within any 24-hour period or less.
Action :.4.3.2.t With any reactor coolant system UNIDENTIFIED LEAKAGE increase greater than 2 gpm within any 24-hour period or less, identify the source of leakage increase as not service sensitive Type 304 or 316 austenitic stainless steel within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least liOT SliUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SliUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Justificatiom This proposed change is consistent with GL 88-01. leakage detection systems for the reactor coolant systems (RCS)'are provided to monitor the leakage from the RCS and alert the operator when leakage rates above normal levels are detected. The proposed limit is more stringent than the current limit (2 gpm in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) and will require operator action at a lower limit. Changing the limit will ensure that small leaks in the RCS are detectedi This change may actually have a positive impact on plant safety No new safety concerns are introduced.
1.
p
. to GNRO-92/00092 Page 3 of 6 3)
Change the surveillance requirement in TS 4.4.3.2.1.a b, and c to specify eat leakage measurements shall be monitored at least once per twelve (12) hours.
Surveillance Reculrement 4 A.3.2.1 The reactor coolant system leakage shall be demonstrated to be within each of the above limits by:
a.
Monitoring the drywell atmospheric particulate and gaseous radioactivity at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, b.
Monitoring the drywell floor and equipment drain sump level and flow rate at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, L
c.
Monitoring the drywell air coolers condensate Dow rate at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and...
Justification: This proposed change is consistent with GL 88-01, Supplement 1.
TS 3.4.3.1 requires several systems for monitoring the RCS leakage to be operable: (1) the drywell atmosphere particulate radioactivity monitoring system, (2) the drywell atmosphere gaseous radioactivity monitoring system or the drywell air coolers condensate flow rate monitoring system and (3) the drywell floor and equipment drain sump level and flow monitoring systems, in combination, these systems monitor leakage of the RCS. The leakage rates determined from these systems are compared to the leakage limits of TS 3.4.3.2. Presently, leakage
- monitoring is performed every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
in GL 88-01, Supplement 1, the Staff found that monitoring RCS leakage every 4
. hours creates an unnecessary administrative hardship for plant operators and that leakage measurements should be taken at least once per shift, not to exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
L GGNS agrees that monitoring RCS leakage every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> creates an unnecessary operator burden and proposes to change the frequency of RCS leakage measurement from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. TS Table 1.1 defines "S" frequency as once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; GGNS believes "S" is intended to denote shiftly. Therefore, this proposed change is consistent with GL 88-01, Supplement 1.
o L
This proposed change will enhance safety by reducing an unnecessary operator l
burden. RCS leakage will continue to be monitored frequently (every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).
l
. to GNRO-92/00092 Page 4 of 6 C.
NO SIGNIFICANT HAZARDS CONSIDERATIONS:
Entergy Operations, Inc. proposes to change the current Grand Gulf Nuclear Station (GGNS) Technical Specifications (TS) ta (1) modify the TS regarding GGNS's inservice inspection program to include a statement of compliance with the NRC staff position on schedule, methods, personnel and sample expansion given in Generic letter (GL) 88-01 and (2) revise the reactor coolant system leakaga monitoring requirements. The specific proposed changes are:
1) include a statement in the inservice inspection section (TS 4.0.5) which states:
The inservice inspection program for piping identified in NRC Generic letter 88-01 shall be performed in accordance with the NRC staff positions on schedule, methods, personnel, and sample expansion included
- in Generic letter 88-01 or in accordance with alternate measures approved by the NRC staff.
2)
Change TS 3.4.3.2.e to specify that reactor coolant leakage shall be limited to a 2 gpm increase in unidentified leakage within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or less. This change is also reflected in TS 3,4.3.2 Action e. for consistency.-
I l
3)
Change the surveillance requirement in TS 4.4.3.2.1 to specify that leakage measurements shall be monitored at least once per twelve (12) hours.
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 l
license' involves a 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 evahmted; or (2) create the possibility of a new or different kind of accident from any acewnt previously eva':'ated; or (3) involve a significant reduction ir the margin of safety.
Entergy Operations, Inc. has evaluated the no significant hazards considerations in its L
. request for a license amendment, in accordance with 10CFR50.91(a), Entergy Operatiens, Inc. is providing the analysis of the proposed amendment against the three j
standards in 10CFR50.92(c). A description of the no significant hazards considerations -
determination follows:
I 1.
No significant increase in the probability or consequences of an accident previously evaluated results from these changes.
I
'l
, - -. ~.. - -,. -. _, _ _
's e to GNRO-92/00092 Page 5 of 6 he proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. These changes do not involve a physical change or addition to any plant comp'nient or system. The proposed changes do not result in any change to the plant design or its operating modes, ne proposed changes to TS 4.0.5, Applicability, and TS 3/4.4.3, Reactor Coolant System leakage, are consistent with NRC Generic Letter (GL) 88-01 and GL 88-01, Supplement 1.
The proposed change to TS 4.0.5 is administrative in nature and does not affect any accident initiators or initial assumptions used in the accident analyset The inservice inspection program at Grand Gulf Nuclear Stations (GGNS) currently conforms to the staff position in GL 88-01. The proposed change provides a i
formal endorsement of the staff position.
leakage detection systems for the reactor coolant system are provided to alert the operator when leakage rates above normal are detected. The proposed changes to TS 3/4.4.3 provide more stringent requirements for the detection of leakage within the primary containment and will require operator action at a lower limit.
Changing the ilmit for an increase in unidentified leaksge from 2 gpm in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 2 gpm in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensures that small leaks in the reactor coolant system are detected. This proposed change does not adversely affect any of the accident initiators or initial assumptions used in the accident analyses.
The proposed change to the frequency of leakage detection monitoring is consistent with GL 88-01, Supplement 1. The NRC Staff found that monitoring reactor coolant system leakage every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> created an unnecessary administrative hardship for plant operators. A leakage monitoring frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that leakage measurements are checked frequently withott creating an unnecessary operator burden.
Based on the above, these changes do not result in a significant increase in the probability or consequences of an accident previously evaluated.
2.
Dese changes would not create the possibility of a new or different kind of accident ' rom any previously analyzed.
The proposed changes do not involve a change in the design, maintenance, or methods of operation or testing of any plant system or component. Werefore, no new failure mode is created. - The proposed changes to TS 4.0.5, Applicability, and TS 3/4.4.3, Reactor Coolant System leakage, are consistent with NRC GL 88-01 and GL 88-01, Supplement 1. Therefore, these changes will not create the possibility of a new or different kind of accident from any previously analyzed.
. to GNRO-92/00092 Page 6 of 6 3.
These changes would not involve a significant reduction in the margin of safety.
%e proposed changes do not involve a significant reduction in the margin of safety. The proposed changes to TS 4.0.5, Applicability, and TS 3/4.4.3, Reactor Coolant System Leakage, are consistent with NRC GL 88-01 and GL 88-01, Supplement 1.
The proposed change to TS 4.0.5 is administrative !n nature and does not affect the margin of safety.
He proposed change to TS 3/4.4.3 on the RCS leakage limit is more stringent than the current ilmit. His restriction will require operator action at a lower lirnit. The change in the limit will ensure that small leaks in the RCS will be detected.
The change to the leakage detection frequency will reduce unnecessary administrative hardship for the operator. The enhanced ability for early detection of unidentified leakage and the reduction of operator burden may actually increase the margin of safety.
The proposed changes do not modify the actuation setpoints, function or the method of operation and testing of any plant system or component; therefore, these changes will not involve a significant reduction in the margin of safety.
Based on the above evaluation, operation in accordance with the proposed amendment involves no significant hazards considerations.
D.
REFERENCES:
1.
AECM 88/0153 dated August 8,1988 regarding Generic Letter 88-01 2.
AECM 89/0130 dated July 14,1989 regarding Request ur Additional Information on Generic letter 88-01: NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping 3.
AECM-90/0063 dated April 23,1990 regarding Additional Information regar(11ng GGNS IGSCC Program 4
AECM-90/0198 dated December 7,1990 regarding Revisions to Tecanical Specification per Generic Letter 88-01 5.
GNRO-92/00070 dated June 5,1992 regarding Response to Generic Letter 88-01, Supplement 1 -
_ _ _ _ _ _ _ _ _ _ _ _