ML20210H077
| ML20210H077 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/06/1997 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210H080 | List: |
| References | |
| GL-94-01, GL-94-1, GNRO-97-00055, GNRO-97-55, NUDOCS 9708110220 | |
| Download: ML20210H077 (8) | |
Text
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Entergy Operations,inc, C%? fy3jn o 60n 7%
.L./l ( 0 C Putt Gibson, MS 39160 Tel 601437 f,408 f as 601437 2795 Joseph J. Hagan we n.w.a O[C'8hOf 4 b'Wd C4JH ?JJCWW bldbnft August 6, 1997 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 Change to Technical Specification 3.8.1,_
A.
C.
Sources - Operating
Proposed Amendment to the Operating License (PCOL 97/01)
GNRO-97/00055 Gentlemen:
In accordance with 10 CFR 50.90, Entergy Operations, Inc. (EOI) hereby applies for amendment of Facility Operating License No. NPF-29, Appendix A Technical Specifications, (TS) for Grand Gulf Nuclear Station (GGNS).
This request consists of a proposed change to TS 3.8.1,
A.
C.
Sources Operating.
This submittal proposes to remove accelerated testing requirements for the standby diesel generators as advised by NRC Generic Letter (GL) 94-01.
The proposed
\\
changes to the TS reflect the Model Technical
\\
Specification Changes proposed in Enclosure 2 of GL 94-1
- 01. Additionally, the model TS changes included within Generic Letter 94-01 allow deletion of the special diesel generator reporting requirements that had previously been included as Grand Gulf Nuclear Station d(
0 TS 4.8.1.1.3.
Upon implementation of the Improved l
Technical Specifications at GGNS, the diesel generator reporting requirements were relocated to tne Technical Requirements Manual (TRM).
Upon approval of this amendment, EOI intends to delete the diesel generator reporting requirements consistent with the guidance of GL 94-01 using the provisions of 10 CFR 50.59.
110064 0ER?'lilRJtlllig 9708110220 970006 DR
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_ ADOCK 05000416 J
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August 6, 1997 GNRO-97/00055 A Note of Affirmation is contained in Attachment 1 of I
this letter. provides a description of the proposed changes and the associated justification (including a Basis for No Significant Hazards Consideration).
A marked-up copy of the affected pages from the GGNS Technical Specifications (TS) is provided l
in Attachment 3.
The applicable marked-up Bases pages are included for your information.
The Bases change-will be implemented in accordance with Technical-Specification 5.5.11, Technical Specification Bases l
Control Program, following approval of the requested amendment.
This request has been reviewed and approved by the GGNS Safety Review Committee and the Plant Safety Review Committee.
If you have any questions regarding this request or require additional information, please contact James Owens at (601) 437-6483.
JJH/J10/
attachi nts:
1.
ffirmation per 10 CFR S0.30 71scussion of Justification 3.
Mark-up of Affected Techniedl Specifications and Bases cc:
NRC Senior Resident Inspector (w/a)
Mr. L. J. Smith (Wise Carter) (w/a)
Mr.
N.
S.
Reynolds (w/a)
Mr. H. L. Thomas (w/c)
Mr.
J. W. Yelverton (w/a)
Mr.
J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C.
20555 Mr. E. W. Merschoff (w/a)
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Dr.
E.
F. Thompson (w/a)
State Health Officer State Board of Health P.O.
Box 1700 Jackson, MS 39205
Attachment I to GNRO-97/00055 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 l
IN THE MATTER OF ENTERGY MISSISSIPPI, INC.
and SYSTEM ENERGY RESOURCES, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.
f APPTPMATIOh1 I,
J.
J.
Hagan, 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 Entergy Mississippi, Inc. I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commissicn, 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, information and belief.
_ J.
. Iagan STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State above named, this 3: "
day of TRY 1997.
(SEAL)
NotaryYPublic My commiacion expires:
tC*47PI $7ATIWO! NOTAhY KISLP 1(Y COVW(T!C"mC.'#; 27,23 m u. m a ws;a u.u
' to GNRO-97/00055 Page 1 of 5 ENTERGY OPERATIONS, INC.
GRAND GULF NUCLEAR STATION DOCKET 50-416/ LICENSE NO. NPP-29 PROPOSED CHANGE TO THE OPERATING LICENSE A. Technical Specifications Affected This proposed change affects the following Technical Specification sections:
3.8.1 A.
C.
Sources - Operating B 3.8.1 Bases - A.
C.
Sources - Operating B. Background The standby diesel generator systems consists of three independent, AC power sources.
The diesel generator system is designed so that with loss of any one of three diesel generators, the remaining generators are capable of supplying power to sufficient equipment for a safe shutdown of the unit under normal or accident conditions.
The Divisions I and II standby diesel generators are used to supply power to their respective safety buses when the offsite power system is unavailable.
They are automatically started upon a loss of voltage on their associated 4160 VAC buses, or by a LOCA signal initiated by an abnormally low reactor vessel water level or high drywell pressure.
If offsite power is available to the buses during a LOCA initiation the diesel generators are not automatically connected to the buses but are left running on standby.
If offsite power is not available, the required loads are automatically sequenced onto the diesel generators.
The Division III (HPCS) diesel generator is used to supply power to the HPCS safety bus when offsite power is not available.
It starts automatically on a LOCA signal from the reactor protection system or on a HPCS supply bus undervoltage condition and is automatically connected to the bus when offsite power is not available.
Technical Specification Surveillance Requirements 3.8.1.2 and 3.8.1.3 require that in accordance with the frequency specified in Table 3.8.1-1,
Diesel Generator Test Schedule, (shown in TS marked-up pages of Attachment 3) each standby diesel generator be verified to start from standby conditions and achieve rated voltage and speed within the specified time limits.
The frequer.cy specified for the verification is nominally 31 days.
This frequency increases to every 7 days should a standby diesel generator experience four or more valid failures in the last twenty-five valid tests.
Four valid failures in the last twenty-five valid tests is considered the threshold for acceptable reliability, and hence the test provides an early indication of degrading standby diesel generator reliability.
_= _
- to GNRO-97/00055 Page 2 of 5 C. Description of Propo_ned Changes Consistent with the guidance provided by NRC GL 94-01, this amendment request proposes that the provisions in Technical Specification 3.8.1 for accelerated testing be removed.
This follows implementation of the required maintenance program for monitoring and maintaining diesel generator performance consistent with the provisions of Section 50.65 of Title 10 of the Code of Federal Regulations (10 CFR 50.65), ' ' Rege lrement s for Monitoring the Effectivenens of Maintenance at Nuclear Power Plants," and the guidance (as applicable to EDGs) of Regulatory Guide (RG) 1.160 Revision 1, dated January 1995, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
Specifically, three changes to the applicable diesel generator Technical Specifications are proposed:
1)
SR 3.8.1.2 specified frequency is changed to 31 days; 2) SR 3.8.1.3 specified frequency is changed to-31 days; and 3) Table 3.8.1-1 Diesel Generator Test Schedule is deleted.
D. Justification for Proposed Changes Generic Letter (GL) 94-01 advises licensees that they may request a licens; amendment to remove accelerated testing requirements for the standby diesel generators from their Technical Specifications.
GL 94-01 states, Licensees may request the removal of the TS provisions for accelerated testing and special reporting requirements for EDGs at this time.
However, when requesting this license amendment, licensees must commit to implement within 90 days of the issuance of the license amendment a maintenance program for monitoring and maintaining EDG performance consistent with the provisions of 10 CFR 50.65 and the guidance (as applicable to EDGs) of RG 1.160.
The monitoring performed per 10 CFR 50.65 assures the standby diesel generator reliability and unavailability are maintained within acceptable limits. Grand Gulf Nuclear Station will comply with the guidelines as set forth in GL 94-01 and is already in compliance with the provisions of 10 CFR 50.65 and the guidance of RG 1.160 by implementation of the Maintenance Rule on July 10, 1996.
Therefore, the changes proposed in this amendment request are consistent with the guidance provided by NRC GL 94-01.
E.No Significant Hazards Consideration Entergy Operations Inc.,
(EDI) proposes to change the current Grand Gulf Nuclear Station (GGNS) Technical Specifications (TS) so that the requirements for accelerated testing are removed.
This follows implementation of the required maintenance program for monitoring and maintaining diesel generator performance consistent with the provisions of 10 CFR 50.65 and the saidance as applicable to diesel generators of RG 1.160.
.. < to GNRO-97/00055 Page 3 of 5 In accordance with 10 CFR 50.92, a proposed change to the operating license involves no significant hazards if operation of the facility, in accordance with the proposed change, would not 1) involve a significant increase in the probability or consequences of any accident previously evaluated,
- 2) create the possibility of a new or different kind of accident from previously evaluated, or.3) involve a significant reduction i
in a margin to safety.
This request is evaluated against each of these criteria as follows:
1.
This request does not involve a significant increase in the probability or consequences of an accident previously evaluated.
This change will provide flexibility to structure the standby diesel generator maintenance program based on the risk significance of the structures, systems, and components that are within the scope of the Maintenance Rule.
The removal of the diesel generator accelerated-testing is acceptable as the maintenance rule applies site and system specific performance criteria to monitor diesel generator performance.
This criteria includes a running availability and reliability goal as well as specific goals to monitor maintenance preventable functional failures.
The performance criteria for the diesel generator reliability and unavailability established by the maintenance rule and 1
the causal determinations and corrective actions required for maintenance preventable functional failures are considered to be an acceptable method for monitoring diesel generator performance.
The proposed changa has no effect on the probability of the initiation of an,veident, because the emergency diesel generators do not serve as the initiator of any event.
1 Additionally, as diesel generator performance will continue l
.to-be assured by the maintenance rule, the proposed changes do not affect the ability to mitigate the consequences of an accident previously evaluated.
The changes do not impact the diesel's design sources, operating characteristics, system functions, or system interrelationships.
The failure
. mechanisms for the accidents previously analyzed are not
-affected and no additional failure modes are created that could cause an accident that has been previously evaluated.
Since the diesel generator performance and reliability will continue to be assured byLthe maintenance rule, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously j
evaluated.
{
' to GNRO-97/00055 Page 4 of 5 3.
Thie requent doea not create the possibilicy of a new or different kind of accident from any accident previously evalua ted.
This proposed change does not involve a change to the plant design or operation.
As a result, the proposed change does not affect any of the parameters or conditions that could l
contribute to the initiation of any accidents.
The proposed changes only affect the methods used to monitor and assure diesel generator performanco.
The performance criteria for both the diesel generator reliability and unavailability established by the maintenance rule, and the causal determinations and corrective actions required for maintenance preventable functional failures, is considered by GL 94-01 to be an acceptable method frr monitoring diesel generator performance.
No SSC, method of operating, or system interface is altered by this change.
The changes do not impact the diesel's
(
design sources, operating characteristics, system functions, or system interrelationships.
The failure _ mechanisms for the accidents are not affected, and no additional failure modes are created.
Because the diesel generator performance and reliability will continue to be assured by the maintenance-rule, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
_ This requesc_ does not involve a significant reduction in a margin to safety.
The proposed changes only affect the methods usedito monitor and assure diesel generator performance and reliability.
The performance criteria.for both the diesel generator reliability and unavailability established by the maintenance rule, and the causal determinations and corrective actions required for. maintenance preventable functional failures, is considered'by GL 94-01 to be an acceptable method for monitoring diesel generator performance.
No margin to safety as defined in the basis for any technical specification is impacted by these changes.
This change does not impact any uncertainty in the design, construction, or opercelon of any SSC.
Diesel generator response to accident-initiators is unchanged.
No SSC, method of operating,apr system interface is altered by this change.
The changes do not impact the diesel's design sources, operating characteristics, system functions, or system interrelationships.
Because the diesel generator performance and reliability will continue to be assured by the maintenance rule, the proposed changes do not involve a l
significant reduction in the margin to safety.
' to GNRO-97/00055 Page 5 of 5 Environmental Impact Consideration EOI has reviewed this request against the criteria of 10CFR51.22 for environmental ennuiderations.
Since this request involves (1) no significaat hazards consideration, (ii) no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) no significant increase in individual or cumulative occupational radiation exposure, EOI has concluded that the proposed change meets the criteria given in 10CFR51.22 (c) (9) for a categorical exclusion from the requirement for an environmental impact statement.
.