ML20211E706

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Application for Amend to License NPF-29,incorporating Many of Generic Improvements Agreed Upon Between Industry & NRC Since GGNS Conversion to ITS
ML20211E706
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 08/20/1999
From: Eaton W
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20211E711 List:
References
RTR-NUREG-1434 GNRO-99-00060, NUDOCS 9908300081
Download: ML20211E706 (33)
v • d • e


Text

. - . -

v-EntIrgy operttions, Inc.

- P. O Box 756

~

Pvt Gibson. MS 39150 Tel 601437 6409 Fax 001437 2795 William A. Eaton vic e heudent.

o w anons August 20, 1999 Grand Gulf fJuclear Station U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Implementation of NRC Accepted Generic Changes to the Technical Specification Proposed Amendment to the Operating License, LDC1999-050 GNRO-99/00060 l -Gentlemen:

Entergy Operations, Inc. (EOI) is submitting by this letter a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License. GGNS converted to the improved Technical Specifications (ITS) in 1995 as an industry lead plant. Due to the timing of the GGNS conversion, GGNS essentially _

converted to Revision 1 of the BWRE> ITS NUREG-1434 with some additional generic issues addressed plant specifically. Since that time the Industry and the NRC Staff have been working to improve the ITS NUREGs and as a result generic changes have been developed. This request incorporates many of the generic improvements agreed upon between the industry and the NRC since the GGNS conversion.

l Attachment 2 provides a detailed description of the proposed changes, justification, and the No Significant Hazards Considerations. Attachment 3 is a copy of the marked-up Technical Specification pages. Attachment 4 is a copy of the Attachment 3 mark-ups with TSTF numbers added to aid the NRC reviewer, Based on the guidelines in 10 CFR 50.92, Entergy Operations has concluded that this proposed amendment involves no significant hazards considerations. Attachment 2 details the basis for this determination.

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9908300081 990820 PDR ADOCK 05000416-e eDe.

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GNRO-99/00060 Page 2 of 2 The proposed changes included in this submittal contain clarifications and less restrictive changes that would be beneficial to GGNS. However, the review of these changes should not take priority over proposed changes already on the docket that are needed for the next refueling outage (RF10).

Yours truly, WAE/JCR/BSF/MJL attachments: 1. Affirmation per 10 CFR 50.30 (2 pages)

2. Discussion and Justification (27 pages)
3. Mark-up of Affected Technical Specifications and Bases for GGNS (66 pages)
4. Mark-up of Affected Technical Specifications and Bases with Reference to TSTF Numbers for GGNS (66 pages) cc: Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)

Mr. L. J. Smith (Wise Carter) (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. J. L. Blount Mr. C. M. Dugger Mr. W. A. Eaton Mr. R. K. Edington Mr. C. R. Hutchinson Mr. J. R. McGaha Mr. N. S. Reynolds Mr. L. J. Smith Mr. H. L. Thomas Dr. Eddie F. Thompson Mr. S. P. Sekerak, NRR/DLPM/PD IV-1 (w/2)

State Health Officer U.S. Nuclear Regulatory Commission State Board of Health One White Flint North, Mail Stop 13D18 P.O. Box 1700 11555 Rockville Pike Jackson, Mississippi 39205 Rockville, MD 20852-2378 Mr. E. W. Merschoff (w/a) U.S. Nuclear Regulatory Commission Regional Administrator Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Region IV Arlington, TX 76011 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011

r l

i i GNRO-99/00060 -

l bec: Mr. W. B.' Abraham (GGNS)

Mr. R. W. Byrd (GGNS)

Ms. P. L. Campbell (RBS)

Mr. E. C. Ewing (WF-3)

Mr. B. Ferrell (PERRY PLANT) - bsferrell@firstenergycorp.com Mr. W. K. Hughey (GGNS)

Mr. D. E. James (ANO) -

Mr. R. J. King (RBS)

Mr. M. A. Krupa (ECH)

Mr. M. J. Larson (GGNS)

Ms.~ J. M. Manzella (W3)

Ms. E. A. Means (ANO)

Mr. G. P. Norris (RBS)

Ms. M. B. Padgett (RBS)

Mr. C. P. Stafford (GGNS)

Mr. J. D. Vandergrift (ANO)

File (LCTS/RPTS) (w/a)

File (Hard Copy) (w/a)

File (Central)(w/a)( )

1 GNRO-99/00060 Attachment 1 Page 1 i l

l Attachment 1 i Affirmation per 10 CFR 50.30 l

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GNRO-99/00060 Attachment 1 Page 2 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 1 DOCKET NO. 50-416 IN THE MATTER OF ENTERGY MISSISSIPPI, INC.

and i

SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.

AFFIRMATION 1, W. A. Eaton, 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 South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this application; 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.

W. A. Eatdn 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 cAo day of Ausarr .1999.

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InesssmsTAttWDENOTRY PLmue Notary Public I

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wf connest:01c:P,.!3JAN.27 20yj l My commission expires: DONDID THW $TECA'.L K0Tay SEnVCE l

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GNRO-99/00060 Attachment 2 Page 1 l

Attachment 2 1

Discussion and Justification i

GNRO-99/000SO Attachment 2 Page 2 A. AFFECTED TECHNICAL SPECIFICATIONS The following Technical Specifications are affected by the proposed change.

SL 2.2 SL Violations 3.0.4 LCO Applicability 3.0.6 LCO Applicability 3.1.1 Shutdown Margin (SDM) 3.1.3 Control Rod OPERABILITY 3.1.4 Control Rod Scram Times 3.4.7 RCS Leakage Detection Instrumentation 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown 3.4.10 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown 3.6.1.2 Primary Containment Air Locks 3.6.1.3 Primary Containment Isolation Valves (PCIVS) 3.6.4.1 Secondary Containment 3.8.1 AC Sources - Operating 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.4 DC Sources - Operating 3.8.6 Battery Cell Parameters 3.9.8 Residual Heat Removal (RHR)- High Water Level 3.9.9 Residual Heat Removal (RHR)- Low Water Level 5.5.6 inservice Testing Program 5.5.9 Diesel Fuel Oil Testing Program 5.6.5 Core Operating Limits Report (COLR)

The proposed Technical Specifications (TS) and the associated TS Bases changes to be implemented following NRC approval of the proposed Technical Specification changes are detailed in Attachment 3.

B. BACKGROUND Grand Gulf Nuclear Station (GGNS) converted to the improved Technical Specifications (ITS) in 1995 as an industry lead plant. Due to the timing of the GGNS conversion, GGNS essentially converted to Revision 1 of the BWR/6 ITS NUREG-1434 with some additional generic issues addressed plant specificaHy. Since that time the Industry and the NRC Staff have been working to improve the ITS NUREGs and as a result generic changes have been developed.

Generic changes to the ITS NUREGs are proposed to the NRC by the Nuclear Energy

Institute (NEI) sponsored Technical Specification Task Force (TSTF). The TSTF i includes representatives from the four U.S. commercial nuclear power plant owners groups and NEl. Generic changes are reviewed and prepared using a TSTF process that the TSTF and NRC have developed to correct and improve the ITS NUREGs. Each of these proposed changes are assigned a 'TSTF" number for tracking purposes (e.g.,

F GNRO-99/00060 Attachment 2 Page 3 .

(

TSTF-2). After NRC approval, generic changes are available for adoption by plants. A l listing of generic changes approved by the NRC which are applicable to the BWR/6 ITS l NUREG are identified in Table 1. This request incorporates many of the generic improvements agreed upon between the Industry and the NRC since the GGNS i conversion.

J C. REQUESTED CHANGES l

The following are the NRC approved generic changes which are requested to be I implemented at GGNS. For each of the changes requested the following is provided:

the associated TSTF number, the specific changes requested for GGNS, a comparison between the requested change and the TSTF, the justification for the change (based upon the justification for the TSTF with plant specific information added as needed), and an identification of the specific affected Technical Specifications and Bases.

1. TSTF 2 Relocate the 10 year sediment cleaning of the fuel oil storage tank to licensee control
a. Recuested Chance Relocate Surveillance Requirement (SR) 3.8.3.6, the requirement to I perform a 10-year sediment cleaning of the fuel oil storage tank, to licensee control.
b. Consistency with TSTF The proposed change is consistent with the TSTF.
c. Justification SR 3.8.3.6 is a preventative maintenance type SR. As stated in the current Bases for SR 3.8.3.6, sediment in the tank does not necessarily result in an inoperable storage tank. Preventative maintenance SRs generally have been relocated from the TS to licensee control. This SR is similar to the diesel generator inspection SR which was in the TS prior to conversion to the ITS and was allowed to be relocated to plant controlled documents. Performance of SR 3.8.3.3 (fuel oil testing) and the limits of the Diesel Fuel Oil Testing Program help ensure tank sediment is minimized. Performance of SR 3.8.3.1 (fuel oil volume verification) once per 31 days ensures that any significant degradation of the tank wall surface that results in a fuel oil volume reduction (i.e., leakage) is detected and corrected in a timely manner. As a result, adequate controls exist to allow relocation of this requirement to plant controlled documents.

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GNRO-99/00060 Attachment 2 Page 4 This change is a relocation of a Technical Specification requirement to I the Updated Final Safety Analysis Report (UFSAR) and the change controls of 10CFR50.59.

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d. Technical Specifications Affected TS Pages Bases Pages SR 3.8.3.6 3.8-25 B 3.8-49 REFERENCES B 3.8 50 l
2. TSTF5 Delete notification, reporting, and restart requirements if a safety limit is violated t
a. Reauested Chance ]

Delete the notification, reporting, and restart requirements if a sarety limit is violated as outlined in TS Section 2.2, SL Violations,

b. Consistency with TSTF The proposed change is consistent with the TSTF.
c. Justification This change deletes requirements from the Technical Specifications that are purely administrative or adequately addressed by other regulatory controls. The following are the regulatory controls which address each item removed from the TS.

. Safety Limit (SL) 2.2.1 is addressed by 10 CFR 50.36(c)(1)(i)(A) and 10 CFR 50.72.

. SL 2.2.3 is addressed by 10 CFR 50.36(c)(1)(i)(A) and by the 1 inclusion in the Quality Assurance Program Manual of the l requirements for on-site safety review committee and off-site safety )

review committee review of reportable events (The management positions identified in SL 2.2.3 have reporting responsibility for these committees.). The 24-hour reporting time frame is not required in the proposed controls. This reduction in requirements is acceptable since it is only reasonable to expect management to be promptly informed of a safety limit violation considering that the plant has been required l to shutdown and restart of the plant must be authorized by the NRC.

. SL 2.2.4 is addressed by 10 CFR 50.36(c)(1)(i)(A) and 10 CFR 50.73.

. SL 2.2.5 is addressed by 10 CFR 50.36(c)(1)(i)(A).

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GNRO-99/00060 Attachment 2 Page 5

d. Technical Specifications Affected TS Pages Bases Pages SL 2.2 2.0-1 B 2.0-5 2.0-2 B 2.0-6 8 2.0-8 8 2.0-9 B 2.0-10
3. TSTF 9 Relocate values for shutdown margin to COLR
a. Reauested Chanae Relocate the values for shutdown margin (SDM) in LCO 3.1.1 and SR 3.1.1.1 to the Core Operating Limits Report (COLR).
b. Consistency with TSTF The proposed change is consistent with the TSTF with the following clarification:

. GGNS TS 5.6.5, Core Operating Limit Report (COLR) has a list of items, which must be documented in the COLR. LCO 3.1.1, Shutdown Margin (SDM), is added to this list as a result of this change. The TS 5.6.5 change was not noted as a required change in

, the TSTF, however it is needed to ensure consistency between the NUREG-1434 (Draft Rev 2. 08/26/97) STS and GGNS TS.

c. Justification SDM can change on a cycle-specific frequency similarly to other limits, which are currently contained in the COL 3. In addition, there is a NRC-approved methodology for calculating the acceptability of the SDM limits.

Relocating SDM to the COLR will provide core design and operational flexibility that can be used for improved fuel management and to solve plant specific issues. Current reload design efforts and the resolution of plant specific issues are restricted by the guidelines to not change the SDM, since it would result in a License Amendment request.

Following this change the SDM limits will be contained in the COLR and controlled in accordance with TS 5.6.5. The controls of TS 5.6.5 will ensure that adequate limits are maintained and reported to the NRC.

GNRO-99/00060 Attachment 2 Page 6

d. TechnicalSpecifications Affected TS Paggs Bases Pages LCO 3.1.1 3.1-1 None SR 3.1.1.1 3.1-4 TS 5.6.5 5.0-18 _]
4. TSTF 17 Extension of testing frequency of containment airlock interlock mechanism from 184 days to 24 months
a. Reauested Chanae Extend the testing frequency of SR 3.6.1.2.3 for testing the primary containment airlock interlock mechanism from 184 days to 24 months.

Also, since the primary need for the associated SR Note has been addressed by the requested frequency extension, the SR Note is requested to be deleted.

b. Consistency with TSTF The proposed change is consistent with the TSTF with one minor exception for the Bases of SR 3.6.1.2.3. During the TSTF review process, one of the "184 day" phrases was not changed to 24 months.

We have corrected this error since the TSTF mark-up, if accepted totally, would cause our Bases words to be incorrect. The owners group TSTF update committee was notified and will correct the error,

c. Justification Typically, the primary containm'ent airlock interlock is installed after each refueling outage, verified operable with this surveillance and not disturbed until the next refueling outage. If the need for maintenance arises when the interlock is required, the performance of the interlock surveillance would be required following the maintenance. In addition, when an air lock is opened during times the interlock is required, it is required that personnel first verify that one door is completely shut and the door seals pressurize before attempting to open the other door. Therefore, the interlock is not challenged except during actual testing of the interlock.

Consequently, it should be sufficient to ensure proper operation of the interlock by testing the interlock on a 24-month interval.

Testing the airlock interlock mechanism is accomplished through having one door not completely engaged in the closed position, while attempting to open the second door. Failure of this surveillance effectively results in

n. ..

GNRO-99/00060 Attachment 2 Page 7 a loss of containment integrity. Procedures and training do not allow this interlock to be challenged for ingress and egress. During normal use of the airlock one door is opened, personnel and equipment as necessary are placed into the airlock and then the door is completely closed prior to attempting to open the second door. This surveillance is contrary to processes and training of conservative operation when the interlock function is required. The door interlock mechanism cannot be readily bypassed; linkages must be removed which are under the control of station processes such as temporary modifications, containment closure procedures, and out-of-service practices. The failure rate of this physical device is very low based on the design of the interlock.

Historically, this interlock verification has had its frequency chosen to coincids with the frequency of the overall airlock leakage test. According to 10 CFR 50, Appendix J, Option A, this frequency is once per 6 months.

However, Appendix J, Option B, allows for an extension of the overall airlock leakage test frequency to a maximum of 30 months.

For the above reasons, EOl proposes to change the required frequency for this surveillance to 24 months. In this fashion, the interlock can be tested in a Mode where the interlock is not required. With this frequency l change, the Note is rot needed, because testing can be conducted during a plant shutdown and will not be required to be performed again until the following plant shutdown for refueling.

d. Technical Specifications Affected T

TS Pages Bases Pages SR 3.6.1.2.3 3.6-8 83.612

5. TSTF 18 Require only one secondary containment access door per access opening to be closed
a. Reauested Chance Reword and clarify the current SR 3.6.4.1.2 secondary containment access door closure requirements and associated Bases.
b. Consistency with TSTF The proposed change is consistent with the TSTF with the following clarification:

. BWR/6 SR 3.6.4.1.3 is covered in GGNS SR 3.6.4.1.2.

GNRO-99/00060 Attachment 2 Page 8

c. Justification TSTF-18 made the requirements for the BWR/4's, BWR/5's, and Pressurized Water Reactors (PWRs) consistent with the generic requirements for the BWR/6's and the current GGNS requirements. It also made wording changes for clarity. For GGNS this change only results in rewording of the current SR 3.6.4.1.2 requirements and associated Bases.
d. Technical Specifications Affected TS Pages Bases Pages

_SR 3.6.4.1.2 3.6-43 8 3.6-86

6. TSTF 32 Slow / Stuck Control Rod Separation Criteria 1
a. Reauested Chanae )

Move the requirement to ensure that " slow" and withdrawn stuck control rods are appropriately separated from the LCO 3.1.4 requirements to LCO 3.1.3 Condition A Required Actions.

b. Consistency with TSTF The proposed change is consistent with the TSTF with the following clarifications and exceptions:

. The proposed Bases are modified to reflect the current separation requirements.

. The LCO 3.1.4 change was not noted as a required change in the TSTF, however it is needed to ensure consistency between the NUREG-1434 (Draft Rev 2,08/26/97) STS and GGNS TS and to reflect the relocation of the information to LCO 3.1.3. l

c. Justification This change does not change any technical requirements for GGNS. l During the conversion to the ITS, GGNS added a requirement to LCO 3.1.3 to insure the appropriate separation of " slow" and withdrawn stuck control rods. When this requirement was added to the BWR/6 ITS NUREG it was added with a different presentation.

This change r.1 oves the requirement to ensure that " slow" and withdrawn stuck control rods are appropriately separated from the LCO 3.1.4 requirements to LCO 3.1.3 Condition A Required Actions which is an administrative change. The change also relocates the specific separation

GNRO-99/00060 Attachment 2 Page 9 requirements from the TS to the TS Bases where it will be controlled by the requirements of the Bases Control Program (TS 5.5.11). The controls of the Bases Control Program provide adequate assurance that appropriate separation criteria are imposed.

d. Technical Specifications Affected TS Pages Bases Pages LCO 3.1.3 3.1-7 8 3.1-14 3.1-8 B 3.1-15 LCO 3.1.4 3.1-12 8 3.1-23
7. TSTF 33 Specification 3.1.3, Required Action A.2 Completion Time Note
a. Reauested Chanae Editorially reword and clarify the Completion Time for LCO 3.1.3 Required Action A.2 (Note that the Required Action is renamed in the markups from A.2 to A.3 as the result of proposed change C.6).
b. Consistency with TSTF The proposed change is consistent with the TSTF with the term Rod Pattem Control System (RPCS) used instead of RWM to conform with plant nomenclature.
c. Justification This change does not change any technical requirements for GGNS.

During the conversion to the ITS, GGNS addressed the issue addressed by this TSTF. When this change was made to the BWR/6 ITS NUREG it was made with a slightly different presentation. This is an administrative change only.

d. Technical Specifications Affected TS Pages Bases Pages LCO 3.1.3 3.1-8 8 3.1-15

GNRO-99/00060 Attachment 2 Page 10 I

8. TSTF 38 Revise visual surveillance of batteries to specify inspection is for performance degradation
a. Reauested Chance l I

Clarify the requirements of SR 3.8.4.3, battery visual inspection, to be consistent with the intent and the present wording of the Bases, by identifying that the inspection is for items, which could potentially degrade battery performance.

b. Consistency with TSTF The proposed change is consistent with the TSTF.
c. Justification The Bases of SR 3.8.4.3 in NUREG-1434 states that this SR "provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance" As a result, it is interpreted that physical damage or abnormal deterioration has to be of a type that could degrade battery performance before the SR would fail to be met. The presence of physical damage or deterioration dces not necessarily represent a failure of SR 3.8.4.3, provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of the battery (its ability perform its design function). Therefore, for consistency with the Bases for SR 3.8.4.3 in NUREG-1434, SR 3.8.4.3 is proposed to be revised to add, "that could degrade battery performance."

The Bases for SR 3.8.4.3 are also proposed to be revised to clarify measures to be taken in the event physical damage or abnormal deterioration is discovered.

+

This is an administrative change only since it only clarifies the intent of the SR.

d. Technical Specifications Affected ,

TS Pages _

Bases Pages SR 3.8.4.3 3.8-28 8 3.8-56 ,

GNRO-99/00060 Attachment 2 Page 11

9. TSTF 45 Exempt verification of Containment isolation Valves (CIVs) that are locked, sealed or otherwise secured i
a. Reauested Chance Revise SR 3.6.1.3.2 and SR 3.6.1.3.3 to specify that only Primary Containment isolation Valves (PCIVs) which are not locked, sealed, or otherwise secured are required to be verified closed.
b. Consistency with TSTF l

The proposed change is consistent with the TSTF with the following clarifications:

. BWR/6 SR 3.6.1.3.4 is covered in GGNS SR 3.6.1.3.3.

c. Justification SRs 3.6.1.3.2 and 3.6.1.3.3 require verification that the PCIVs required to be closed during accident conditions are indeed closed. The proposed wording clarifies that the intent of the SR is to provide verification for those valves not somehow secured in the closed position. The proposed change is consistent with the Emergency Core Cooling System (ECCS)

Specifications; e.g., SR 3.5.1.2, which do not require verification of valves that are " locked, sealed, or otherwise secured in position." This is acceptable, because the subject valves were verified to be in the correct position prior to locking, sealing, or securing, and are periodically checked as deemed necessary by management.

d. Technical Specifications Affected TS Pages Bases Pages SR 3.6.1.3.2 3.6-14 8 3.6-22 SR 3.6.1.3.3 3.6-15
10. TSTF 60 Make LCO 3.0.4 not applicable to all actions of LCO 3.4.7
a. Reauested Chanae LCO 3.0.4 which restricts entry into MODES or specified conditions with required equipment inoperable is requested to be made not applicable to all of the Conditions in LCO 3.4.7, RCS Leakage Detection Instrumentation.

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GNRO-99/00060 Attachment 2 Page 12

b. Consistency with TSTF The proposed change is consistent with the TSTF.
c. Justification i

Currently Condition A (drywell floor drain sump monitoring system inoperable) and Condition D (required drywell atmospheric monitoring system inoperable) have specific Notes identifying that the LCO 3.0.4 mode change restrictions are not applicable. Additionally, since the unit can operate for an unlimited period of time in Condition B (required i drywell atmospheric monitoring system inoperable) and in Condition C (drywell air cooler condensate flow rate monitoring system inoperable),

LCO 3.0.4 does not restrict changing modes while in Condition B or Condition C. Therefore, in the current TS requirements only apply the LCO 3.0.4 mode restriction while in Cundition E or Condition F. Both of these Conditions require that the unit be shutdown. Prudent judgement is sufficient to insure that the unit will not startup into an immediate shutdown statement. Therefore, this change does not result in any change in the TS requirements and is an administrative change.

d. Technical Specifications Affected TS Pages Bases Pages J LCO 3.4.7 3.4-16 B 3.4-34 3.4-17 8 3.4-35 B 3.4-36
11. TSTF 104 Relocates discussion of exceptions from LCO 3.0.4 to the Bases
a. Reouested Chanoe This change removes the additional discussion provided in LCO 3.0.4 with respect to the use of exceptions and provides the necessary discussion in the Bases.
b. Consistency with TSTF The proposed change is consistent with the TSTF.
c. Justification This change provides consistency with LCO 3.0.3 by moving the discussion of exceptions from the LCO to the Bases. In addition, this change reduces the potential for confusion by revising the discussion to

GNRO-99/00060 Attachment 2 Page 13 eliminate the repeated use of the phrase " Modes or other specified conditions in the Applicability" to increase clarity. This change is administrative only.

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d. Technical Specifications Affected TS Pag.es Bases Pages l LCO 3.0.4 3.0-2 B 3.0-6 l i
12. TSTF 118 Administrative Controls Program Exceptions .

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a. Reauested Chance Revise Administrative Controls 5.5.9 to add the following sentence, "The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program testing frequencies."
b. Consistency with TSTF l

The proposed change is consistent with the TSTF.

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c. Justification This sentence provides consistency with the current application of these requirements as provided in other programs (e.g.,5.5.7, " Ventilation Filter Testing program"). SR 3.0.2 and SR 3.0.3 are already applicable to the surveillance's which reference these programs, and, therefore, the lack of an applicability statement in this program introduces confusion. Further,

! the applicability of SR 3.0.2 and SR 3.0.3 to the program surveillance's is 1

consistent with the pre-ITS conversion licensing basis and the old STS.

This change is an administrative clarification only,

d. Technical Specifications Affected r TS Pages Bases Pages TS_5.5.9 5.0-14 None
13. TSTF 153 Clarify Exception Notes to be Consistent with the Requirement Being Excepted
a. Reauested Chanae Several LCOs have Notes which contain exceptions to the LCOs and have wording which is inconsistent with the wording of LCO. The Notes

GNRO-99/00060 l

Attachment 2 Page 14 are revised to provide consistent wording with the requirement being excepted. LCO's 3.4.9, 3.4.10, 3.9.8, and 3.9.9 are revised to correct inconsistent wording.

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b. Consistency with TSTF The proposed change is consistent with the TSTF with the following clarification:

GGNS LCO 3.4.10 has a Note 3 that is not in the BWR/6 ITS NUREG.

This Note has the same wording problem that is corrected by this TSTF. The wording of this LCO Note is also proposed to be corrected by this proposed change.

c. Justification The Residual Heat Removal specifications (LCO 3.4.9, LCO 3.4.10, LCO 3.9.8, and LCO 3.9.9) require subsystem (s) to be operable and one subsystem "to be in operation." These LCOs contain LCO Notes which exempt this requirement for a period of time. However, these Notes are incorrectly worded. These Notes say that the subsystem be " removed from operation" which could imply that although the subsystem could be removed from operation it must be immediately placed back in operation

)

to meet the LCO requirements. The same problem exists with the associated Bases which use the term "be shut down." The intent of the Notes is to allow the subsystem to "not be in operation" for a period of time. The differences between the wording of the LCO requirement and the associated Notes adds potential confusion. This potential confusion is removed by making the LCO Notes consistent with the LCO being excepted. This is an administrative change.

d. Technical Specifications Affected TS Pages Bases Pages

_LCO 3.4.9 3.4-21 B 3.4-43 LCO 3.4.10 3.4-24 B 3.4-48 LCO 3.9.8 3.9-10 B 3.9-26 LCO 3.9.9 3.9-12 B 3.9-30 l

14. TSTF 163 Minimum vs. Steady State Voltage and Frequency
a. Reauested Chanae l All of the 10 second DG start tests (SR's 3.8.1.2,3.8.1.12,3.8.1.15, and 3.8.1.20) are modified to provide minimum volt /Hz limits for the 10-second l acceptance and then detail the current volt /Hz range as " steady state" l l

GNRO-99/00060 Attachment 2 Page 15 acceptance criteria.

b. Consistency with TSTF The proposed change is consistent with the TSTF with the following clarifications:

BWR/6 SR 3.8.1.7 is GGNS SR 3.8.1.2 since GGNS does not have the ability to perform the modified DG start method.

. Since GGNS does not have the ability to perform the modified DG start method discussions of this method are not included in the proposed Bases.

. Plants with the modified DG start method are allowed to only take the data discussed in the proposed Bases once per 6 months when the DG is fast started. GGNS fast starts the DGs for every monthly SR since GGNS does not have the ability to perform the modified DG start method. To ensure that the Bases commitment to periodically take the data is not misunderstood, an additional Bases statement is added that states data is taken once per 6 months during the performance of SR 3.8.1.2. GGNS is not committing to take the data every monthly test since taking the data requires connecting recorders inside the DG control cabinets which increases the potential for adverse interactions.

c. Justification The intent of the 10-second start tests is to confirm the ability of the DG to l reach the minimum conditions to accept load. This is consistent with the revised minimum volt /Hz. A new range of acceptable voltage and frequency are provided which are applicable only to steady state operation. In addition to the SR requirements, the time for the DG to reach steady state operation is periodically monitored (data is taken at least once per 6 months during the performance of SR 3.8.1.2) and the trend evaluated to identify degradation cf govemor and voltage regulator performance. The appropriateness of this change has been discussed by the NRC Staff in the SER for Amendment 120 to the Clinton Power Station Technical Specifications. This SER states:

"In their letter dated July 31,1998, IP has stated that when a test is performed that does not result in tying the DG to the bus, a momentary voltage or frequency overshoot (and/or subsequent undershoot) can occur because no loads are being tied to the DG. IP indicates that loading tends to minimize the overshoot, whereas the unloaded overshoot might momentarily exceed the specified limit (s) within the 12-second time limit. The NRC staff agrees. The voltage and frequency tolerance band currently specified in the subject surveillance's are more appropriate for steady state limits than transient limits, as evidenced by the l

1 l

l l

GNRO-99/00060 Attachment 2 Page 16 recommendations in NRC Regulatory Guide 1.9 which allow a larger band for transient voltage and frequency deviations. The changes IP has proposed appropriately specify the original voltage and frequency

)

tolerance band as steady state values while, in the transient region within 12 seconds, they specify only minimum values. In addition, the LOOP and the LOCA/ LOOP load sequencing tests required by SR 3.8.1.11 and SR 3.8.1.19 in the Clinton Technical Specifications will continue to verify (on an 18-month frequency) the capability of the Clinton DGs to provide power at a voltage and frequency adequate to start and operate the safety loads."

This change is a clarification for the intent of the current requirements.

d. Technical Specifications Affected TS Pages Bases Pages SR 3.8.1.2 3.8-5 B 3.8-15 SR 3.8.1.12 3.8-10 SR 3.8.1.15 3.8-13 SR 3.8.1.20 3.8-16
15. TSTF 166 Correct inconsistency Between LCO 3.0.6 and the SFDP Regarding Performance of an Evaluation
a. Reauested Chanae Revise LCO 3.0.6 to explicitly require an evaluation per the Safety Function Determination Program (SFDP). Delete statement " additional .

. limitations may be required" from LCO 3.0.6.

b. Consistency with TSTF The proposed change is consistent with the TSTF.
c. Justification There is an inconsistency between LCO 3.0.6, the LCO 3.0.6 Bases, and ,

the SFDP. This change resolves the inconsistency. As currently written, l LCO 3.0.6 does not explicitly require an evaluation in accordance with the SFDP, rather it states that additional evaluations may be required. Both the SFDP and the LCO 3.0.6 Bases state that upon entry into LCO 3.0.6, an evaluation shall be made to determine if a loss of safety function l exists. In addition, because LCO 3.0.6 states that the evaluation be done l in accordance with the SFDP and the SFDP states that other appropriate I actions may be taken, there is no need for the statement " additional .

i

I GNRO-99/00060 Attachment 2 Page 17 limitations may be required"in LCO 3.0.6. This is an administrative change.

d. Technical Specifications Affected TS Pages Bases Pages LCO 3.0.6 3.0-2 None
16. TSTF 278 Battery Cell Parameters (LCO 3.8.6) includes more than Table 3.8.6-1 limits
a. Reauested Chanae LCO 3.8.6 is revised to require that battery cell parameters be "within limits." The reference to " Table 3.8.6-1" was deleted. Additionally, changes are made to the Actions Table to make the references to the Table 3.8.6-1 Category A, B, and C limits consistent.
b. Consistency with TSTF The proposed change is consistent with the TSTF with the following clarifications:

. The TSTF addition of reference in Condition A to Table 3.8.6-1 was already included in GGNS Condition A.

c. Justification LCO 3.8.6 requires the cell parameters for the batteries to be within the limits specified in Table 3.8.6-1. This requirement is not inclusive of all the limits specified in the applicable SRs. In addition to the limits specified in Table 3.8.6-1, a limit regarding the average electrolyte temperature is contained within a SR. Therefore, the LCO is in conflict with the SR requirements. LCO 3.8.6 is revised to require the battery cell parameters to be within limits. This change resolves the conflict between the LCO and SRs.

Additionally, the references in the Actions Table to the Table 3.8.6-1 Category A, B, and C limits were made consistent.

These changes do not impact the requirements of the Technical Specifications. This is an administrative change.

l

GNRO-99/00060 Attachment 2 Page 18

d. Technical Specifications Affected TS Pages Bases Pages

_LCO 3.8.6 3.8-34 None 3.8-35

17. TSTF 279 Remove " applicable supports" from inservice Testing Program
a. Reauested Chance Delete the reference to the " applicable supports" from the description of the " Inservice Testing Program" contained in Section 5.5.6.
b. Consistency with TSTF The proposed change is consistent with the TSTF.
c. Justification The inservice Testing Program (IST) provides controls for testing Code Class 1,2 and 3 components. The discussion of the IST Program in i Section 5.5.6 of the STS was revised by the NRC to include the l

" applicable supports"in February 1992 due to concems related to the relocation of the snubber LCO from the ITS NUREGs. However, this is inappropriate; supports are addressed under the Inservice Inspection (ISI) Program not the IST Program. Thus, the reference to the applicable supports in the IST Program description in Section 5.5.6 is deleted.

Additionally, in the last six years, sixteen plants have impleme.nted ITS with no known issues related to testing of snubbers or supports. ASME has developed OM-5 and other guidance to provide appropriate testing requirements for supports and snubbers.

Since supports are addressed under the ISI Program not the IST Program, these changes do not impact the requirements of the Technical Specifications. This is an administrative change.

d. TechnicalSpecifications Affected l TS Pages Bases Pages TS 5.5.6 5.0-11 None 1 l

l

GNRO-99/00060 Attachment 2 Page 19 g%

~

s ' p64 g (TAR,Rh 1 ;jps ,

._ g J +M SiglWS Of Apletowed TWRwelerS 9ht Apply 40 SM5tf8 planis  %

ggyp , g ~w +% '

magn; 4< ->%' mn m, s &qg cQ : fk ' ?" QQ&pegg lg; ,

2 ; Relocate the 10 year sediment cleaning of the Requested in this submittal as C.1

__ [fue.lp.il storage tan.k to li_cens_ee cont.rol [_ _ __ ___

5 : Delete safety limit violation notification  ; Requested in this submittal as C.2

! l requirements.___

L _ _ __g 8 ; Revise the SR 3.0.1 Bases to allow credit for iOwners Group activity is ongoing on this '

L .. .junplanned events to_ meet any Surveillance _ _jissue. N_ot. requested at this_ time . _ ,

' ._.91 R eloc. ate value for_ shutdown margin to COLR [Requeste.d..in this submittal as C.3_ ,

i 17 IExtension of testing frequency of containment: Requested in this submittal as C.4

, iairlock interlock mechanism from 184 days to

!24 months  !

~ ~ ~

18] Require ordy~one] secondary] containrneni~ ~ lRequested in'ihis submittal as Cl '

.__ j access dopr per access opeg.ing to be_ closed,,J... _ _ _ _ _ ,

30 l Extend the Completion Time for inoperable l Change is still being reviewed. Not i.ji_ solation valve to a clos _ed_ system to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> _ jrequested at ! th s ti_m_e.____ .

...32j SlowlSt_uck Control Rod Separation, Criteria jReguested in this submittal as_C.6 33 ISpecification 3.1.3, Required Action A.2 ' Requested in this submittal as C.7 L.._..jCqmp.letion Time Note }

! 34 ; Delete Requirements to Disarm the associated lGGNS requirements are consistent with

CRD when two or more withdrawn control rods ;this TSTF.

_.._. ..j a!.e stuck _ _ _ _ . ..__.__ _ _ L __ _ __ _ . _ _ . _ _

35 (Recirculation pump start RPV temperature limits ;GGNS requirements are consistent with

> f verification note ithis TSTF. ~

"381 Revise visual suiveillance of batteries to !Requesfedin this submittal as C.i specify inspection is for performance }

[ degradation _ _ _ _ _ ____ L_ __ _ _ _ _ _ . . .

' 45 Exempt verification of CIVs that are locked, ' Requested in this submittal as C.9

'._.._ jsea!edpr otherwise secured _.

,J __ _ _ . _ _

> 46 iClarify the CIV surveillance to apply only to :GGNS requirements already address the lautomaticisolation valves issue raised in this TSTF. Not requested l ~

!at this time. ~

ICMake l~CO101 applicable ida~liaitio~ns of TS" Requested 'irithis submittafas"C30~ l

, .. .. __.J3.4.15 _ _ _ _ _ !___ _ _ _ _ ___

65 lUse of generic titles for utility positions l Generic titles are already used in the

L _ ...... J .._.. .. _ .. _ . _ . _ . . . _ . _ _

iG .GNS TS. ._ ._

_._.j i 71 ! Add example of SFDP to the 3.0.6 Bases iBases change only. NRC approvalis not '

_.._ d.....

76 { Remove references to the _onsite review function [Tequested at

. . _ _ . GGNS requirements are consistent with._

~~

YO Relocates dis ~cudiod ofix~ciptions iromfCO st d j~nihis subriUttails'C.'1'1

. . - i3.0.4 to the Bases . - - ,

.- --.-. . a

GNRO-99/00060 Attachment 2 Page 20

~

3 TABLE A - m ygyp W GONS p <y , gg hV T Ma M M k N PN4

g ~ ,,

.- iM;L E & MkMd w; p 106 . Change to Diesel Fuel Oil Testing Program  ; Change is still being reviewed. Not

_ . . . _ . _ . . _ _ . _ _ . _ _ . . _ . _ . _ . . . . . ___ _-requested at this time._ _ ... .__.... ___ ,

118 Administrative Controls Program _Ex,c,eptions , Requested in this submittal as C.12 l 122 Revise LCO 3.0.2 Bases to Remove Possible  ; Bases change only. NRC approvalis not i

. . _ _ _ [C.onfusion , _ ._ _._ __ _ . _ . .

_ [ requested at_this time. _

l 137 ; Relocation of the 3.4.16 Action Note A Bases (GGNS requirements are consistent with_..._ _ _

~

this TSTF. ~

l

[d9 incorrect" Criteria Definedin5U.56 'PAses 'claiiiication.~5RC"approvafis not~

L _. 1. _._ _. _.. . _ . .._.. ..._ ._ _ . _ .jreque_sted at this time. .._ _.

, 152 l Revise Reporting Requirements to be Consistent iChange is still being reviewed. Not l _.

with 10.CFR 20 ' requested at this time .._ _ _ _ . _

,153 Clarify Exception Notes to be Consistent with ; Requested in this submittal as C.13

. ._ _ . .the Require _ ment _B.eing Excepted 163 ; Minimum vs. Steady State Voltage and  ; Requested in this submittal as C.14 .

... _ jFrequency__ _ _

i 165 ! Revise the LCO 3.0.5 Bases to Refer to Testing ; Bases wording change. NRC approval is ;

._ . land Not.SRs _ . . . . . _ . _ _ _ _ _ _ . . . not reques.ted. at this time. ._ ._

,166

Correct inconsistency Between LCO 3.0.6 and ; Requested in this submittal as C.15

.the SFDP Regarding Performance of an l  ; Evaluation

~

l ~ ~ '

206] ppiicabilities of Suppression ~ Pool Average lGGS'Siequirements are consistent with

.; Temperature _ Limits ._ _ .[th.i.s TSTF. _ _. _ _ .._ _ _ _.

207 ; Completion Time for Restoration of MSIV_ _ . _ _ . Change is still being reviewed. Not Eileakage_ Rate _ _ _ ._ _ . _ . _

irequested at this time. .__. _

l 1 222 ! Control Rod Scram Time Testing . Change is still being reviewed. Not

. re. quested at this time.

225 iFuel movement with inoperable refueling  ;GGNS requirements are consistent with

_ . [e_quipment interlocks _ _ . . _ . _ _ _ _ _ _ [this TSTF. . ___ _ _ _ _ _ _

230 ! Add new Condition B to LCO 3.6.2.3, "RHR 1 GGNS requirements are consistent with

.JSuppression Po_ol_ Cooling"_____ .this TSTF._ _ _ _ _ _ _ . _

i 253 ' Omit Note which indicates that performance of Change is still being reviewed. Not _

_ _lo.ne SR_s_atisfies a.noth_er _ __ _ _ _ _ _ _ _ ir_e. quested at this time. .._ ..

269 i Allow administrative means of position verification; Change is still being reviewed. Not L .. _ [fgrJg.cked. or. sealed vajves _ .. _ _._ _ _..._ f requested..at.this time _ _ _ .

278 l Battery Cell Parameters (LCO 3.8.6) includes l Requested in this submittal as C.16_ _ .  !

more than Table 3.8.6-1 limits

~

~

~

[279 Remove'" applicable supportFfrom Inservice Requestedin this suimittal as C.17 l [ _ jTesting Program __ , _ _ _ _ __ _ _ _ _

l t - -

I l

l GNRO-99/00060 Attachment 2 Page 21 D. NO SIGNIFICANT HAZARDS CONSIDERATION Entergy Operations, Inc. proposes to change the current Grand Gulf Nuclear Station (GGNS) Technical Specifications to incorporate many of the generic improvements l agreed upon between the Industry and the NRC since the GGNS conversion to the improved Technical Specifications.

The Commission has provided standards for determining whether a no significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license involves 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 evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. The requested changes are evaluated below group with respect to the type of change being evaluated.

1. ADMINISTRATIVE CHANGES These changes involve reformatting, renumbenng, and rewording of Technical Specifications, with no change in intent. Since they do not change the intent of the Technical Specifications they are considered to be administrative in nature.

The GGNS is adopting NRC approved TSTF-5, TSTF-18, TSTF-33, TSTF-38, TSTF-104, TSTF-118, TSTF-153, TSTF-163, TSTF-166, TSTF-278, and TSTF-279, generic changes to the improved Standard Technical Specifications (ISTS) as outlined in NUREG-1434, " Standard Technical Specifications, BWR/6 Plants."

In accordance with the criteria set forth in 10 CFR 50.92, EOI has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.

a. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

l The proposed change involves reformatting, renumbering, and rewording the existing Technical Specifications. The reformatting, renumbering, and rewording process involves no changes in intent to the Technical Specifications. The proposed changes also involve Technical Specification requirements, which are purely administrative in nature. As such, this change does not effect initiators of analyzed events or assumed mitigation of accident or transient events. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

b. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

l s

l

E GNRO-99/00060 Attac.hment 2 Page 22 The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods goveming normal plant operation. The proposed change will not impose any now or eliminate any old requirements. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

c. Does this change involve a significant reduction in a margin of safety?

The proposed change will not reduce a margin of safety because it has no effect on any safety analyses assumptions. This change is administrative in nature. Therefore, the change does not involve a j significant reduction in a margin of safety. I

2. LESS RESTRICTIVE CHANGES - REMOVED DETAIL GGNS is adopting NRC approved TSTF-2, TSTF-9, and TSTF-32 generic changes to the Improved Standard Technical Specifications (ISTS) as outlined in NUREG-1434, " Standard Technical Specifications, BWR/6 Plants." The proposed changes involve moving details out of the Technical Specifications and into the Technical Specifications Bases, the UFSAR, or the Core Operating i Limits Report (COLR). The removal of this information is considered to be less  !

restrictive because it is no longer controlled by the Technical Speciucation change process. Typically, the information moved is descriptive in nature and its )

removal conforms with NUREG-1434 for format and content.

In accordance with the criteria set forth in 10 CFR 50.92, the EOl has evaluated I these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.

a. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change relocates certain details from the Technical Specifications to other documents under regulatory control. The Bases and UFSAR will be maintained in accordance with 10 CFR 50.59. In addition to 10 CFR 50.59 provisions, the Technical Specification Bases are subject to the change control provisions in the Administrative Controls Chapter of the Technical Specification. The UFSAR is subject to the l change control provisions of 10 CFR 50.71(e). The COLR is controlled in accordance with TS 5.6.5. The controls of TS 5.6.5 will ensure that adequate limits are maintained and reported to the NRC. Since any changes to these documents will be evaluated, no significant increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, this change does not involve a significant l

GNRO-99/00060 Attachment 2 Page 23 increase in the probability or consequences of an accident previously evaluated.

b. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change will not impose or eliminate any requirements, and adequate control of the information will be maintained. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

c. Does this change involve a significant reduction in a margin of safety?

The proposed change will not reduce a margin of safety because it has i no effect on any safety analysis assumptions. In addition, the details to be moved from the Technical Specifications to other documents remain the same as the existing Technical Specifications. Since any future changes to these details will be evaluated, no significant reduction in a margin of safety will be allowed. A significant reduction in the margin of safety is not associated with the elimination of the 10 CFR 50.92 requirement for NRC review and approval of future changes to the relocated details. The proposed change is consistent with the BWR/6 Standard Technical Specifications, NUREG-1434, issued by the NRC Staff, revising the Technical Specifications to reflect the approved level of detail, which indicates that there is no significant reduction in the margin of safety.

3. LESS RESTRICTIVE CHANGES- RELAXATION OF REQUIRED ACTION GGNS is adopting NRC approved TSTF-60 generic changes to the Improved Standard Technical Specifications (ISTS) as outlined in NUREG-1434, " Standard Technical Specifications, BWR/6 Plants." The proposed changes involve relaxation of the Required Actions in the current Technical Specifications (TS).

Upon discovery of a failure to meet an LCO, the TS specifies Required Actions to l

be completed for the associated Conditions. Required Actions of the associated i Conditions are used to establish remedial measures that must be taken in l response to the degraded conditions. These actions minimize the risk associated with continued operation while providing time to repair inoperable features. Some of the Required Actions are modified to place the plant in a MODE in which the LCO does not apply. Adopting Required Actions from this l change is acceptable because the Required Actions take into account the

i GNRO-99/00060 Attachment 2 Page 24 l operability status of redundant systems of required features, the capacity and l capability of the remaining features, and the compensatory attributes of the Required Actions as compared to the LCO requirements. These changes have been evaluated to not be detrimental to plant safety.

In accordance with the criteria set forth in 10 CFR 50.92, the EOl has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.

a. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change relaxes Required Actions. Required Actions and their associated Completion Times are not initiating conditions for any accident previously evaluated and the accident analyses do not assume that required equipment is out of service prior to the analyzed event.

Consequently, the relaxed Required Actions do not significantly increase the probability of any accident previously evaluated. The Required Actions in the change have been developed to provide assurance that appropriate remedial actions are taken in response to the degraded condition considering the operability status of the redundant systems of i

required features, and the capacity and capability of remaining features while minimizing the risk associated with continued operation. As a result, the consequences of any accident previously evaluated are not significantly increased.. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

b. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant I (no new or different type of equipment will be installed) or a change in the methods goveming normal plant operation. The Required Actions and associated Completion Times in the change have been evaluated to ensure that no new accident initiators are introduced. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

c. Does this change involve a significant reduction in a margin of safety?

The relaxed Required Actions do not involve a significant reduction in the margin of safety. As provided in the justification, this change has been evaluated to minimize the risk of continued operation under the specified

l GNRO-99/00060 Attachment 2 Page 25 Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Therefore, this change does not involve a significant reduction in a margin of safety.

4. LESS RESTRICTIVE CHANGES - DELETION OF SURVEILLANCE REQUIREMENT GGNS is adopting NRC approved TSTF-45 which is a generic change to the improved Standard Technical Specifications (ISTS) as outlined in NUREG-1434,

" Standard Technical Specifications, BWR/6 Plants." The proposed changes l involve deletion of Surveillance Requirements in the current Technical l

Specifications (TS). l The TS require safety systems to be tested and verified Operable prior to l

entering applicable operating conditions. These changes eliminate unnecessary TS Surveillance Requirements that do not contribute to verification that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety j function. These changes have been evaluated to not be detrimental to plant safety.

In accordance with the criteria set forth in 10 CFR 50.92, the EOl has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.

a. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change deletes Surveillance Requirements. Surveillance's are not initiators to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be Operable and capable of performing the accident mitigation functions assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly effected. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

b. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

l

I GNRO-99/00060 Attachment 2 Page 26 The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods goveming normal plant operation. The remaining Surveillance Requirements are consistent with industry practice and are considered to be sufficient to prevent the removal of the subject Surveillance's from creating a new or different type of amident. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

c. Does this change involve a significant reduction in a margin of safety?

l The deleted Surveillance Requirements do not result in a significant reduction in the margin of safety. As provided in the justification, the change has been evaluated to ensure that the deleted Surveillance Requirements are not necessary for verification that the equipment used l to meet the LCO can perform its required functions. Thus, appropriate i

equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Therefore, this change does not involve a significant reduction in a margin of safety.

5. LESS RESTRICTIVE CHANGES - RELAXATION OF SURVEILLANCE FREQUENCY l

GGNS is adopting NRC approved TSTF-17 which is a generic change to the Improved Standard Technical Specifications (ISTS) as outlined in NUREG-1434, " Standard Technical Specifications, BWR/6 Plants." The proposed changes involve the relaxation of Surveillance Frequencies in the current Technical Specifications (TS).

Surveillance Frequencies specify time interval requirements for performing surveillance testing. Increasing the time interval between Surveillance tests results in decreased equipment unavailability due to testing which also increases equipment availability. Reduced testing can result in a safety enhancement because the unavailability due to testing is reduced and; in tum, reliability of the effected structure, system or component should remain constant or increase. Reduced testing is acceptable where operating experience, industry practice or the industry standards such as manufacturers' recommendations have shown that I these components usually pass the Surveillance when performed at the ,

specified interval, thus the frequency is acceptable from a reliability l standpoint. These changes have been found to be acceptable based on a combination of the above criteria and have been evaluated to not be I detrimental to plant safety.

l

GNRO-99/00060 Attachment 2 Page 27 in accordance with the criteria set forth in 10 CFR 50.92, the EOl has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration.

The following is provided in support of this conclusion.

a. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

l The proposed change relaxes Surveillance Frequencies. The relaxed Surveillance Frequencies have been established based on achieving acceptable levels of equipment reliability.

Consequently, equipment which could initiate an accident previously evaluated will continue to operate as expected and the probability of the initiation of any accident previously evaluated will not be significantly increased. The equipment being tested is still required to be Operable and capable of performing any accident mitigation functions assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly effected. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

b. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods goveming normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

c. Does this change involve a significant reduction in a margin i

of safety?

The relaxed Surveillance Frequencies do not result in a significant l reduction in the margin of safety. As provided in the justification, the relaxation in the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Thus, appropriate equipment continues to be tested at a Frequency that gives confidence that the equipment can perform its assumed safety function when required. Therefore, this change does not involve a significant reduction in a margin of safety.

L

GNRO-99/00060 Attachment 3 Mark-up of Affected Technical Specifications and Bases for Grand Gulf Nuclear Station TS pages TS Bases Pages 2.0-1 B 2.0-5 2.0-2 B 2.0-6 3.0-2 B 2.0-8 3.1-1 B 2.0-9 3.1-4 B 2.0-10 3.1-7 B 3.0-6 3.1-8 8 3.1-14 3.1-12 B 3.1-15 3.4-16 B 3.1-23 3.4-17 8 3.4-34 3.4-21 B 3.4-35 3.4-24 8 3.4-36 3.6-8 B 3.4-43 3.6-14 B 3.4-48 3.6-15 B 3.6-12

~

3.5-43 83.622 3.5-5 B 3.5-86 3.8-10 B 3.8-15 3.8-13 B 3.8-49 3.8-16 B 3.8-60 3.8-25 B 35-56 3.8-28 B 3.9-26 3.5-34 B 3.9-30 3.8-35 l 3.9-10 3.9-12 5.0-11 5.0-14 5.0-18

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