ML21039A264
| ML21039A264 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/27/2021 |
| From: | Entergy Operations |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21039A278 | List:
|
| References | |
| GNRO2021/00002 | |
| Download: ML21039A264 (6) | |
Text
GRAND GULF NUCLEAR GENERATING STATION Updated Final Safety Analysis Report (UFSAR)
TABLE OF CONTENTS CHAPTER 16 TECHNICAL SPECIFICATIONS 16.1 Technical Specifications .................................. 16.1-1 16.1.1 Technical Specification Task Force (TSTF)
Required Implementation Commitments ............ 16.1-1 16.2 Relocated Technical Specification Requirements ............ 16.1-5 16-i Revision 2016-00
GRAND GULF NUCLEAR GENERATING STATION Updated Final Safety Analysis Report (UFSAR) 16.0 TECHNICAL SPECIFICATIONS 16.1 TECHNICAL SPECIFICATIONS The Technical Specifications are located in the OPERATING LICENSE MANUAL.
16.1.1 Technical Specification Task Force (TSTF) Required Implementation Commitments TSTF-423, Technical Specification End States Commitment Implementation Entry into the shutdown modes The Bases for each modified approved in this SE shall be Required Action which allows for the primary purpose of remaining in MODE 3 is modified accomplishing short-duration to include the following repairs which necessitated statement, Remaining in the exiting the original operating Applicability of the LCO is mode. In response to the staffs acceptable because the plant questions, the BWROG stated risk in MODE 3 is similar to or that The BWRs are most likely lower than the risk in MODE 4 to stay in hot shutdown for no and because the time spent in more than 2 to 3 days and MODE 3 to perform the necessary definitely, not more than a repairs to restore the system week. The staff expects that to OPERABLE status will be the licensees will follow this short. Regarding the specific guidance. time limits, a BWR in MODE 3 only generates sufficient decay heat to remain in MODE 3 for 2 to 3 days, and for not more than a week. Therefore, this is not an administrative limitation, but a physical limitation. As a result, there is no need for a licensee to incorporate these specific times in the Technical Specifications or Bases.
16.1-1 Revision 2016-00
GRAND GULF NUCLEAR GENERATING STATION Updated Final Safety Analysis Report (UFSAR)
Appropriate plant procedures Licensees will implement and administrative controls appropriate plant procedures will be used when the plant is and administrative controls to operated in the proposed end be used when the plant is states. operated in the proposed end states as required by Technical Specification 5.4, Procedures, and 10 CFR 50, Appendix B. Appropriate plant procedures and administrative controls must be used when the plant is operated in any plant operating MODE. The MODE 3 end states are not unique in this regard. Therefore, this stipulation is not appropriate for inclusion in the Technical Specifications or Bases as it is does not provide guidance to the operator that is unique to the conditions to be entered.
16.1-2 Revision 2016-00
GRAND GULF NUCLEAR GENERATING STATION Updated Final Safety Analysis Report (UFSAR)
Entry into and use of the Use of the new MODE 3 end proposed end states shall be states will be accompanied by in accordance with the the performance of maintenance requirements of 10 CFR to restore the inoperable 50.65(b)(4). The licensee system or component. When should do a risk assessment performing maintenance, with respect to performance of licensees are required to the key shutdown safety perform a risk assessment by functions, as described in 10 CFR 50.65(a)(4). This risk Section 4 of this SE. assessment is in accordance with the plant procedures in place to implement 10 CFR 50.65(a)(4) and envelopes the situation where entering a MODE or other specified condition in the applicability is contemplated with plant equipment inoperable. Those plant procedures will follow the guidance in NUMARC 93-01, Assessment of Resulting from Performance of Maintenance Activities, Section 11, as revised in February 2000 and as endorsed by NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. The risk evaluations performed in accordance with these documents consider the key shutdown safety functions. Therefore, implementation of these end state changes imposes no new requirements with regard to implementation of 10 CFR 50.65(a)(4). As a result, this stipulation is not appropriate for inclusion in the Technical Specifications or Bases as it is contrary to the content and format of the Improved Standard Technical Specifications to repeat regulatory requirements in the Technical Specifications.
16.1-3 Revision 2016-00
GRAND GULF NUCLEAR GENERATING STATION Updated Final Safety Analysis Report (UFSAR)
The purpose of the BWROG Use of the new MODE 3 end request is to allow corrective states will be accompanied by maintenance in a safe operating the performance of maintenance mode after an CT has been to restore the inoperable exceeded and minimize the system or component. When corrective action time so that performing maintenance the plant can be restored to licensees are required to power operation. Ordinarily the perform a risk assessment by failures result in a degraded 10 CFR 50.65(a)(4). This risk plant condition. Consequently, assessment must consider all with respect to additional maintenance being performed, licensee outage activities that regardless of whether the could affect the safe conduct maintenance is related to of operations and that are not restoring the inoperable directly required for equipment which lead to the use correction of the failure or of the new MODE 3 end state.
failures that caused the CT to Therefore, the inclusion of be exceeded, a licensee must stipulation 4.a in the make two commitments: Technical Specifications or Bases is not needed as it is
- a. The licensee will perform a unnecessary for a licensee to safety assessment in accordance commit to follow the with the maintenance rule prior requirements in 10 CFR to undertaking such additional 50.65(a)(4). The requirements activities. of 10 CFR 50 are imposed by regulation.
- b. If conditions change so that the safety assessment is no If plant conditions change longer valid, the licensee will during performance of suspend all such additional maintenance, 10 CFR 50.65(a)(4) activities via a process requires the new condition to consistent with safety until evaluated, and if necessary, the assessment has been risk management actions to be revalidated. The staff expects taken. The actions may include the licensee to make a stopping the maintenance contingency plan to address activity, taking other risk this situation. The contingency management actions, or plan may require such actions completing the activity. These as (1) suspending the activity actions are implemented in until conditions are again plant procedures. Therefore, appropriate, (2) terminating inclusion of stipulation 4.b in the activity and starting over the Technical Specifications or when conditions are again Bases is not needed as it is appropriate, and (3) continuing unnecessary for a licensee to the activity if safety is best commit to having a contingency plan to follow the requirements in 10 CFR 50.65(a)(4). The requirements 16.1-4 Revision 2016-00
GRAND GULF NUCLEAR GENERATING STATION Updated Final Safety Analysis Report (UFSAR) ensured by completing the of 10 CFR 50 are already activity. The staff recognizes imposed by regulation.
that such decisions may have to be made on the basis of In addition, it is contrary to engineering judgment should an the content and format of the unforeseen situation arise. Improved Standard Technical Specifications to repeat regulatory requirements in the Technical Specifications.
The requested end state changes The Bases for each modified do not prohibit licensees from Required Action which allows entering cold shutdown if they remaining in MODE 3 is modified wish to do so for operational to include the following reasons or maintenance statement, Voluntary entry requirements. In such cases, into MODE 4 may be made as it the specific requirements is also an acceptable low-risk associated with the requested state. As stated above, the end state changes do not apply. specific requirements associated with the MODE 3 end states are not unique to implementation of this change.
Therefore, it not necessary to implement the qualification that these requirements do not apply if cold shutdown is entered. Once MODE 4 is entered, the subject Technical Specifications do not apply.
Therefore, any requirements associated with the modified Required Actions are not applicable. As a result, it is not necessary to implement this stipulation in the Technical Specifications or Bases.
16.2 RELOCATED TECHNICAL SPECIFICATION REQUIREMENTS The relocated Technical Specifications are located in either the Technical Requirements Manual (TRM) or the Offsite Dose Calculation Manual (ODCM) of the OPERATING LICENSE MANUAL.
16.1-5 Revision 2016-00