ML20198N394
| ML20198N394 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/28/1997 |
| From: | ENTERGY OPERATIONS, INC. |
| To: | |
| Shared Package | |
| ML20198N391 | List: |
| References | |
| NUDOCS 9711040115 | |
| Download: ML20198N394 (18) | |
Text
. . .
GNRO 97/00103 Attachment 3 GGNS PCOL 97-04 Mark-up of Affected Technical Specification Pages
$[d TD P PDR;
Primary Containment 3.6.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1.1 Perform required visual examinations and -----NOTE-----
leakage rate testing except for primary [SR3.0.2isnot containment air lock testing, in tpplicable accordance with 10 CFR 50, Appendix J, ---------------
as modified by approved exemptions, in accordance The leakage rate acceptance criterion is with 10 CFR 50, s 1.0 La. However, during the first unit endix J, -at startup following testing performed in accordance with 10 CFR 50, Appendix J, as apprcved modified by approved exemptions, the ex=pt i cr,s -
lee. age rate acceptance criteria are N's / J%
< 0.6 La for the Type B and Type C tests, and < 0.75 La for the Type A test.
9 GRAND GULF 3.6-2 Amendment No. 120
Primary Containment Air Locks 3.6.1.2 SURVEILLANCE REQUIRENENTS SURVEILLANCE FREQUENCY SR 3.6.1.2.1 ------ -----------NOTES------------------
- 1. An inoperable air-lock door does not invalidate the-previous successful performance of the overall air lock leakage test.
- 2. Results shall be evaluated against acceptance criteria of SR 3.6.1.1.1..
in accordance with 10 CFR 50, Appendix J, as modified by-approved
-exemptions.
Perform required primary containeer,c air ,-----NOTE------
lock leakage rate testing in accordance LSR 3.0.2'is not with 10 CFR 50, Appendix J, as modified applicable by approved exemptions. ------------ y The acceptance criteria for air lock In accordance testing are: with 10 CFR 50, endix J, as
- a. Overall air lock leakage rate is s 2 d i..;. vy scfh when tested at ;c Pa- W
, ,_ m ...
b.- For each door, leakage rate is s 2 scfh when the_ gap between the door Q555
. seals is. pressurized to a Pa-SR 3.6.1.2.2 Verify primary containment air lock seal 7 days air flask pressure is a 90 psig.
(continued)
GRAND GULF- 3.6 Amendment No. 120
, 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.1.3.5 ----------------NOTE--------- ---------
Only required to be met in MODES 1, 2, and 3.
Perform leakage rate testing for each 36 months with primary containment purge valve with at least 2 resilient seals. pairs of valves tested every 18 months AND
.....-Note-----
SR 3.0.2 is not applicable In accordance with 10 CFR 50, A endjx J, s-fiec tif appr4ved m"t rdsriisns J' f"y*"'
AND
Note-----
Not applicable to valves tested within 92 days prior to any purge valve failing to meet its acceptance criteria
.- Once within 92 days, test all remaining purge valves, if any purge valve fails to meet its acceptance criteria (continued)
GRAND GULF 3.6-16 Amendment No. 4 E 128
, . 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Verify the isolation time of each MSIV is In accordance
= 3 seconds and s 5 seconds. with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to 18 months the isolation position on an actual or simulated isolation signal.
SR 3.6.1.3.8 ------------------NOTE-------------------
Only required to be met in MODES 1, 2, and 3.
Verify leakage rate through all four main a----NOTE-----
steam lines is :s; 100 scfh when tested at JR 3.0.2 is a Pa. not applicable (
, Q. . . . . . . . . . .y In accordance with 10 CFR 50, Appen M _ dix r::: J, 4
4ppra"ad pra rtica::
\ res ri.,s prew w
4 SR 3.6.1.3.9 ---
NOTE-------------------
Only required to be met in MODES 1, 2, and 3.
Verify combined leakage rate of I gpm -
times the total number cf PCIVs through ----NOTE-----
hydrostatically tested lines that SR 3.0.2 is penetrate the primary containment is not '
not applicable exceeded when these isolation valves are e------------
tested at = 1.1 Pa-In accordance with 10 CFR 50,
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- f VhQD Y GRAND GULF 3.6-17 Amendment No. 444 128 l
, a'
- Programs and Manuals 5.5 5.5 Programs _ and Manuals (continued) 5.5.11 Technical Specifications (TS) Bases Control Proaram This program provides a means for processing changes to the Bases of these Technical Specifications,
- a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
- b. Licensees may make changes to Bases without prior NHC approval provided the changes do not involve either of the following:
- 1. A change in the TS incorporated in the license; or
- 2. A change to the UFSAR or Bases that involves an unreviewed safety question as defineo in 10 CFR 50.59.
- c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.
- d. Proposed changes that do not meet the criteria of either Specification 5.5.11.b.1 or Specification 5.5.11.b.2 above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
- ~ _ _ . __
- I n S e8 h P
GRAND GULF 5.0-16 Amendment No. 120
TABLE OF CONTENTS 5.0 ADMINISTRATIVE CONTROLS (continued) 5.5.7 Ventilation Testing Program (VFTP) 5.0-12 5.5.8 Explosive Gas and Storage Tank 5.0-13 Radioactivity Monitoring Program 5.5.9 Diesel Fuel Testing 011 Program 5.0-14 5.5.10 Safety Function Determination Program 5.0-14 (S FDP) 5.5.11 Technical Specifications (TS) Bases 5.0-16 Control Program
/n $e/Tg 5.6 Reporting Requirements 5.0-17 5.6.1 Occupational Radiation Exposure Report 5.0-17 5.6.2 Annual Radiological Environmental 5.0-17 Operating Report 5.6.3 Radioactive Effluent Release Report 5.0-18 5.6.4 Monthly Operating Reports 5.0-18 5.6.5 Core Operating Limits Report (COLR) 5.0-19 5.7 High Radiation Area 5.0-22 6.0 LIMITING CONDITION FOR OPERATION (LCO) 6.0-1 APPLICABILITY 6.1 REACTIVITY CONTROL SYSTEMS 6.1-1 6.1.1 Control Rod Drive Housing Support 6.1-1 6.2 FIRE SYSTEMS 6.2-1 6.2.1 Fire Detection Instrumentation 6.2-1 6.2.2 Fire SuppresJion Water System 6.2-14 6.2.3 Spray and Sprinkler Systems 6.2-18 6.2.4 CO2 Systems 6.2-21 6.2.5 Halon Systems 6.2-24 6.2.6 Fire Hose Stations 6.2-26 6.2.7 Yard Fire Hydrants and Hydrant Hose Houses 6.2-30 6.2.8 Fire Rated Assemblies 6.2-33 6.3 INSTRUMENTATION 6.3-1 6.3.1 Radiation Monitoring Instrumentation 6.3-1 6.3.2 Seismic Monitoring Instrumentation 6.3-6 6.3.3 Meteorological Monitoring Instrumentation 6.3-9 6.3.4 Traversing In-Core Probe System 6.3-11 6.3.5 Loose-Part Detection System 6.3-12 6.3.6 Main Condenser Offgas - Explosive Gas 6.3-13 Monitoring Instrumentation 6.3.7 Feedwater/ Main Turbine Trip 6.3-15 Instrumentation 6.3.8 Turbine Overspeed Protection System 6.3-17 GNWD GULF 3/20/95 Vi
. ONRO-97/00103 Insert A 5.5.12 10 CFR 50 Appendix J Testing Program This program establishes the leakage rate testing program of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J. Option B, as modified by approved exemptions.
This program shall be implemented in accordance with the Safety Evaluation issued by the Office of Nuclear Reactor Regulation dated April 20,1995 (GNRI 95/00087) as modified by GNRI 9x/xxx, Amendment to the Opetating 1.icense, insert B 5.5.12 10 CFR 50 Appendix J, Testing Program 5.0-16
(
- e, :. - ONRO 97/00103_:
4 4
J d
Attachment 4'
. GGNS PCOL 97-04
- Mark-up of Affected Technical Specification Bases t :
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4 3
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Primary Containmert B 3.6.1.1 tBASES~-(continued)
. SURVEILLANCE: SR 3.6.1.1.1 REQUIREMENTS Maintaining the primary containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of 10 CFR 50, Appendix J (Ref. 3), as modified by approved exemptions. Failure to meet air lock leakage testing (SR 3.6.1.2.1 and SR 3.6.1.2.4), resilient seal primary containment purge valve leakage testing SR 3.6.1.3.5), main steam isolation valve leakage SR 3.6.1.3.8), or hydrostatically tested valve leakage (SR 3.6.1.3.9) does not necessarily result in a failure of this SR. The-impact of the failure to meet these SRs must be evaluated against the Type A, B, and C acceptance-criteria of 10 CFR 50, Aspendix J, as modified by approved exemptions (Ref. 3). As left leakage prior to the first startup after performing a required 10 CFR 50, Appendix-J, leakage test is required to be < 0.6 La for combined Type B and C leakage, and < 0.75 La for overall Type A leakage. At all other times between required leakage rate. tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 La. At s 1.0 La the offsite dose consequences are boushulby the_-_assum)tions of the safety analysis. Tile Frequency ls required )y 10 CFR 50,N' ppe J, as modified by approved exemptions. Thus, SR 3.0.2 (which allows Frequenc ,y extensions) does not apply - -
REFERENCES 1. UFSAR, Section 6.2.
- 2. UFSAR, Sec' tion 15.6.5.
- 4. UFSAR,' Section 6.2.6.
'/Y ,-
yw __
- 5. - of(r hl 10Rt 78L- 95~/000 50, tlff e8d7X:EKtent'% 3 ee ra T'om 1Ae k llT. O ret"i mea,Ts
_ I (o, h NIS T ~ X Yl LXX, ,6m errelsv, es,Tm 7b The.
'N ofer by Lic es.s e N, s GRAND GULF B 3.6-4 Revision No. 0
, - - - ,_y m- , , , - . - - - - -
, l
.3 . Pricary Containment-Air _ Locks =
a_ -s -
B 3.6.1.2'
_. 3ASES. ,
= a
=
ACTIONS ( D.1 and 0.2- (continued)=
~
does-not apply. - To achieve this. status,: the plant must be t
-brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to-MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are-reasonable, based on operati_ng experience. -to reach the-
-required plant:. conditions from full power conditionsEin an<
orderly manner and without challenging plant _ systems.
-i SURVEILLANCE- SR' 3.6.1.2.1 REQUIREMENTS:
Maint'aining. primary containment airflocks OPERABLE- requires compliance with the leakage rate test requirements of 10 CFR _50, Appendix J (Ref. 2), as modified by approved exemptions.- This SR-reflects the--leakage rate testing: - _ '
-requirements with _ regard to air lock leakage (Type d-leakage The= acceptance criteria ~were established during
^
tests)llair.
initia lock-and primary containment OPERABILITYJ .-
testing. -The periodic testing requirements verify that the U
air lock leakage does not exceed-the allowe action of the overall. primary conthnt leakage rate.- he Frequency is '
[requirid by 10'CFR 30, Appendix J as modified'by approved exemptions. Thus, SR 3.0.2 (which allows Frequencyf s not app 1& -- -
The SR has been modified by two_ Notes. Nott I states that
-an-inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test..
This is considered reasonable-since either air lock door is capable of providing.a fission product barrier in the event--
of:a DBA.' Note 2 has been added to this SR, requiring the-results to.be: evaluated against'the; acceptance criteria of SR 3.6.I'.l.1. -This ensures that air lock-leakage is -
properly accounted for in determining the overall primary containment leakane rate. Since the overall- primary containment leakage rate is only applicable in MODES 1, 2,.
and 3 operation, the Note 2 requirement is imposed only during these' MODES.
.6.1.2.2'
~
SR? 3-The: seal air. flask pressure is verified to be at a: 90 psig every 7_ days to ensure that the. seal system remains _ viable,
'It must be checked because it could bleed down during or-
- (continued)~
e
~
, LGRAND GULF ~B-3.6-11 Revision No. Oi 1
l
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+ -, v , e ..+.-, . . , ,. .i-- ,. ,, s-~e- , - . - , , , , - - v-,a . -na ~ ,,--.n.. . , , - - ,a
PCIVs B 3.6.1.3 BASES SURVEILLANCC SR 3.6.1-3.5
. i REQUIREMENTS (continued) For primary containment. purge valves with resilient seals, I additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J (Ref. 3), is required to ensure OPERA 8ILITY. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation, and-the importance of maintaining this penetration leak tight (due to the direct path between :
primary containment and the environment), a Frequency of 36 months, with consideration given to operational experience and safety significance. Additionally, this SR must be performed for all purge valves within 92 days following any purge valve failing to meet it's acceptance criteria. This ensures that any common mode seal degradation is-identified.
The Fr ency for this SR is modified b~M net:n Th:-
Mt e ;Sc:tes thei. 3G.G.2 i: ;r.ly :pplic:ble ts-t
" - nth" stei-- c^ - the_fi;G; rad . The itt e t :t:
a M/h%T ates that all valves do not h~ ave to be~reitested due to the failure of another valve, provided they have been tested within 92 days prior to any valve failing to meet it's acceptance criteria.
The SR is modified by a Note stating that the primary e
containment purge valves are only required to meet leakage rate testing requirements in MODES 1, 2, and 3. If a LOCA inside primary containment occurs in these MODES, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times when the purge valves are required.to be capable of closing (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.
SR- 3.6.1.3.6 Verifying that the full closure isolation time of-each MSIV is within the specified limits is required to dehionstrate OPERABILITY. The full closure isolation time test ensures that the MSIV will isolate in a time period that does not (continued)
GRAND GULF -
B 3.6-24 Revision No. 24 2--.____.m -
- m - - , , - .- , - - - -- w = = e
PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.7 (continued)
REQUIREMENTS each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.7 overlaps this SR to provide complete testing of the safety function. The 18 month Frequency is based on tne need to perform this Surveillance under the conditions that apply during a plant outage and the potentiai for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month frequency.
Therefore, the Frequency was concluded to be acceptable from a relitbility standpoint.
SR 3.6.1.3.8 The analyses in Reference 2 is based on leakage that is less than the specified leakage rate. Leakage through all four steam lines must be :s; 100 scfh when tested at Pt (11.5 psig). The MSIV leakage rate must be verified to be in accordance with the leakage test requirements of Reference 3, as modified by approved exemptions. A Note is added to this SR which states that these valves are only required to meet this leakage limit in MODES 1, 2 and 3. In the other conditions, the Reactor Coolant System is not pressurized and s eci rim y conlainment n leaka te limits are not re requencyisrequiredby10CFR5'0,)j Appendix J ( 3), as modified by approved exemptions; thus, SR 3.0.2 (which allows Frequency extensions) does not pply. -
_ - - M SR 3.6.1.3.9 Surveillance of hydrostatically tested lines provides e f Ref_gra deis assuranc Gthathe ca cu ation assum ti met.[Thecombine leakage rat ~es m s e demonstrated at the_
TFebency e of the leakage test requirements of Reference 3, as mod *fied by approved exemptions; thus, SR 3.0.2 (which allows Frequency extensions) does not_ap 1 This SR is modified by a Note that states these valves are only required to meet the combined leakage rate in MODES 1, 2, and 3 since this is when the Reactor Coolant System is (continued)
GRAND GULF B 3.6-25 Revision No. 1
-7
- SR Applicability B 3.0 BASES SR 3.0.2 The 25% extension does not significantly degrade the (continued) reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These xcepti_ons are stated in the individual Specifications. xample c; d ri SR 3.0 t oois actT@Tjr-44-e, wry 4th-: Frequency 1 f-"in~
x ceeden;e with 10 C P % Appendix J. 2em_od44ted4
- proved-enoptdede requireiiiiin'rs of regu a ions take N d " Y j h rece O ence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations.
Therefore, there is a Note in the Frequency stating, "SR 3.0.2 is not applicable."
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per..." basis. The 25%
extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%
extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the fleribility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less, applies from the point in time that it is discovered that the Surveillance has not been oerformed in accordance with SR 3.0.2, and not at the time (continuedl GRAND GULF B 3.0-12 Revision No. 0
. GNRO-97/00103 -
bec: File (LCTS/RPTS)(wla)
File (Hard Copy)(wla)
File (Central)(w/a) (29)
- Atways include on distribution l
. GNRO 97/0010) ccmailf, Mr. W. B. Abraham Mr. C. C. Hayes Mr. S. J. Bethay (ECH - LIC) Mr. C. D. Holifield Mr. J. G. Booth Mr. W. K. Hughey Mr. D. G. Bost Mr. M. G. Hurley Mr. C. A. Bottemiller Mr. C. R. Hutchinson (ANO - J)
Mr. P. W. Brewer IEA (ANO - OE)
Mr. C. E. Brooks Mr. R. D. Ingram Mr. O. P. Bulich (RB - OE) Mr. D. L. Janecek
- Mr. R. W. Byrd Mr.R.S. Johnson Mr. W. C. Cade Mr. M. L. Jones Ms. T. M. Carter Mr. R. J. King (RB - LIC)
Mr. W. F. Clark Mr. T. A. Kriesel Mr. J. P. Czaika Ms. S. B. Mahoney Mr. L. F. Dale Ms. J. M. Manzella (W3 - QP)
Mr. L. F. Daughtery Mr. M. D. McDowell Mr. G. G. Davie (W3 - LIC) Mr. J. R. McGaha (RB - VP)
Mr. D. R. Denton (ANO) Mr. D. C. Mims (ANO - LIC)
Mr. J. G. Dewease (ECH) Mr. R. V. Moomaw Mr. M. A. Dietrich (RB - QP) Mr. J. E. Owens Mr. J. P. Dimmette (RB) Mr. J. L. Robertson Mr. C. M. Dugger (W3 - VP) Mr. C. F. Smith Mr. W. A. Eaton Mr. M. A. Smith (ANO - LIC)
Mr. C. W. Elisaesser Mr. C.'D. Stafford Mr. J, L. Ensley (ESl) Mr. G. D. Swords Mr. E. C. Ewing (W3 - LIC) Mr. R. L. Thomas (ECH)
Mr. T. W. Gates (RB - LIC) Mr. T. H. Thurmon Mr. T. J. Gaudet (W3 - LIC) Mr. J. E. Venable Ms. C. W. Gunn Mr. D. H. Wells (RB)
Mr. J. J. Hagan Mr. J. W. Yelverton (Ech)
,- _ GNRO 97/00101_
section iv
~~""
M- e /4/zrd?
l Vr t tions _ /[ Date
% l / f9 Director, Nuclear hafety & Regulatory Affairs ! Date t Yf GGNS Gebral Manager- Date
-\ l0lnl4]
PSRC' Date r
SRC Date Date 4 ;
s Date Date
- l. ONRO 97/0010)
CONClJRRENCE REVIEW FORM SECTION 1 RESPONSE L'IE:
GNRO Rev. (NRC Target)
SUBJECT:
Adoption of Option B opf 10 CFR 50, Appendix J.
W. B. Brice 4/M M 100 92 R. D. Ingram .
,- ~/8 2 NRC Document Preparer Date Responsible Section # Date Manager / Superintendent Commitment Concurrence SECTION 11 Responsible Organization Due Locations Commitment Primary / Secondary Date None This letter contains commitments requiring procedural implementation YES ( ) NO (X)
UFSAR Potential Impact Classification SECTION lil UFSAR impact: No XX Yes if Yes:
A) List UFSAR sections / tabled figures affected and describe nature of UFSAR impact.
B) UFSAR revision affected: Current Future C) Additional comments:
I