ML22235A118

10 CFR 50.59 Evaluations, Commitment Change Evaluations, and 10 CFR 72.48 Evaluations Completed from May 21, 2020 to May 21, 2022

ML22235A118
Person / Time
Site:	Grand Gulf
Issue date:	08/23/2022
From:	Hardy J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO2022-00019
Download: ML22235A118 (9)

Text

entergy Entergy Operations, Inc.

P.O. Box 756 Port Gibson, Mississippi 39150 Jeffery A. Hardy Manager Regulatory Assurance Grand Gulf Nuclear Station Tel: 802-380-5124 10 CFR 50.59 10 CFR 72.48 GNRO2022-00019 August 23, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

10 CFR 50.59 Evaluations, Commitment Change Evaluations, and 10 CFR 72.48 Evaluations Completed from May 21, 2020 to May 21, 2022 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Pursuant to 10 CFR 50.59(d)(2}, Entergy Operations, Inc. hereby submits a summary of the approved 10 CFR 50.59 Evaluations and the approved Commitment Change Evaluations for the period of May 21, 2020 to May 21, 2022.

In accordance with 10 CFR 72.48(d)(2), Entergy Operations, Inc. hereby submits a summary of 72.48 Evaluations for the period of July 1, 2020 through June 30, 2022. There were no 72.48 Evaluations for the indicated period. contains the 10 CFR 50.59 Evaluation Summary Report. Attachment 2 contains the Commitment Change Evaluation Summary Report. There are no commitments contained in this submittal. If you have any questions or need additional information, please contact Jeff Hardy at 802-380-5124.

Since9~

Jeffery Hardy JAH/ram

Attachment:

1) 10 CFR 50.59 Evaluation Summary Report

2) Commitment Change Evaluation Summary Report cc: NRC Region IV - Regional Administrator NRC Senior Resident Inspector, Grand Gulf Nuclear Station NRR Project Manager

GNRO2022-00019 Attachment 1 10 CFR 50.59 Evaluation Summary Report Evaluation Initiating Summary Number Document Cycle 23 Reload and Core Operating Limits Report (COLR):

The core reload is a recurring activity for each fuel cycle. At the end of each fuel cycle, depleted fuel assemblies are discharged from the core and replaced by fresh reload assemblies. The remaining bundles resident in the core are shuffled to new locations and fresh fuel is loaded in accordance with the next cycle's core design and reference loading pattern. This evaluation addresses the [Cycle] C23 related reload design changes and the C23 operation of the core. This evaluation will justify the updates to the COLR to reflect the new core operating limits for the Cycle 23 core.

The EC85716 evaluation addresses Cycle 23 Reload Licensing Design implementation using Global Nuclear Fuel's (GNF) new GNF3 fuel design for the fresh reload batch. The Cycle 23 core is designed and will be operated in conformance with the cycle-specific analyses, with GESTAR 11, its fuel design specific reports, and will be bounded by the results of the Grand Gulf Nuclear Station (GGNS) applicable GNF3 and GNF2 Cycle Independent Analyses in the New Fuel Introduction (NFI) process. The reload design and safety analyses for the Cycle 23 core have been prepared using the approved methods as described in GESTAR II. GESTAR II is the licensing basis for the fuel as described in the UFSAR.

2020-002-01 GGNS Cycle 23 introduces the GNF3 fuel design as the fresh reload fuel. GNF3 will be loaded with the once and twice burned GNF2 reload fuel. EC85716 documents details of the GNF3 design and its acceptability for EC85716 GGNS application. The vendor used the NRC approved fuel design methods and documented that the GNF3 fuel design meets all design and licensing criteria in Section 1.1 of GESTAR-II (currently referenced in TS 5.6.5).

The GNF3 fuel design, through the approved Amendment 22 process which constitutes the NRC acceptance and approval of the fuel design without specific NRC review, complies with all GESTAR-11 design and the reload licensing acceptance criteria.

The impact to fuel operating limits and licensing analyses as a result of the application of the GNF3 fuel design is detailed in EC85716. Cycle specific analyses for Cycle 23 were performed in accordance with UFSAR Chapter 15 and the resulting cycle specific limits are documented in the Cycle 23 COLR in accordance with TS 5.6.5. The evaluation of the GNF3 fuel design for GGNS application identified that the changes to the design basis core radionuclide inventory did not result in increases in accident doses listed in the Chapter 15 of the UFSAR.

A core radionuclide inventory that bounds the Cycle 23 reload core design with GNF3 was provided by the vendor as part of the NFI analysis. The radionuclide inventory provided was developed using ORIG EN 2 which is approved by the NRC for this application in Regulatory Guide 1.183. The GGNS design basis dose calculations described in UFSAR Chapter 15 were then updated to account for the increase in core inventory consistent with the existing methodology.

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GNRO2022-00019 Attachment 1 10 CFR 50.59 Evaluation Summary Report Evaluation Initiating Summary Number Document As discussed in EC85716, the changes to the GGNS Cycle 23 core design resulting from the replacements of failed fuel are not adverse and are therefore not addressed by this 10 CFR 50.59 evaluation. However, because 2020-002-01 the safety analyses were performed as part of the normal BWR reload process, the cycle specific analyses for Cycle 23 require a 50.59 Evaluation per EN-NF-105, 5.4.10, and are therefore addressed in this 10 CFR 50.59 evaluation.

Remove Single Point Vulnerability with Turbine Thrust Wear Bearing:

The turbine trip logic associated with excess thrust bearing wear is designed to operate using a two-out-of-three logic. Due to only the 'C' and 'D' probes available, this condition presents a potential single point vulnerability (SPV) to the turbine trip circuit if one of the two remaining probes should happen to fail. The intent of this temporary modification is to force the Ovation input points related to Proximity Probe 1N30N200A to a GOOD status to provide assurance that failure of either of the remaining instruments will not cause an inadvertent turbine trip. Additionally, the turbine thrust wear bearing detection trip signal point will also force to a GOOD status to eliminate its function in the down-stream logic. Disablement of the turbine trip due to excessive thrust 2020-003-00 bearing wear is a change with respect to the design function of this trip as described in Section 10.2.2 of the EC87731 UFSAR. However, the change does not affect the ability of the design to safely shutdown the plant and maintain in a safe condition. The change was evaluated consistent with the requirements of 10 CFR 50.59 and found to be acceptable. Specifically, the evaluation concluded that the change would not result in an increased frequency of previously evaluated accidents, malfunctions, or consequences of these accidents or malfunctions (i.e., radiological consequences). Tripping of the main turbine is an accident evaluated explicitly in Section 15.2.3 of the UFSAR. However, as described in Section 15.2.3.1.1 of the UFSAR, the sequence of events and radiological consequences associated with the main turbine trip evaluated in the UFSAR are independent of the turbine trip initiator.

Removal of Pump Trips from Fuel Pool Cooling and Clean Up Pumps:

This change will remove three trip functions from the Fuel Pool Cooling and Cleanup System (FPCCU) and Leakage Detection System (LOS), to trip harden the FPCCU pumps (1G41C001A/B) and ensure cooling is maintained to the spent fuel pool, while retaining the automatic isolation of the non-safety and non-seismic EC91792 portions of the piping when a leak is detected.

EC91793 2022-001-00 Three trip conditions:

1) Pump suction pressure low;;: 8 inches Hg vacuum

2) LOS Differential Pressure (DP) low flow HI > 141 GPM after 45 seconds

3) LOS Fast Fill/Low Flow Standpipe pump trip to detect leaks in the Filter/ Demineralizer Page 2 of 4

GNRO2022-00019 Attachment 1 10 CFR 50.59 Evaluation Summary Report Evaluation Initiating Summary Number Document The results of this evaluation determine that the bypass of the three trips for both of the FPCCU pumps are not adverse to the design function of the FPCCU.

The two issues that were evaluated in this evaluation are:

1) Elimination of one of the two suction trips results in loss of redundancy for pump suction protection.

a) Spurious trip results in loss of a train b) Failure to automatically trip could result in pump damage if they are not manually tripped resulting in loss of a train 2022-001-00 However, loss of a train does not challenge the single failure criteria established for the FPCCU in UFSAR 9.1.3.3.

2) Fuel Pool Inventory Loss: Makeup water for normal operation could be made unavailable, but emergency water will continue to be available from SSW or the RHR systems.

Enabling Open Phase Detection (OPD) Trips:

An Open Phase Condition (OPC) is a new failure mode of offsite power that was communicated to GGNS in Bulletin 2012-01. EC52500 installed a PCS2000 Open Phase Detection (OPD) system at transformers ST11, ST21 and ESF12. EC90198 will enable the trip functions associated with the Open Phase Detection (OPD) system (installed under EC 52500) to protect Engineered Safety Features (ESF) electrical distribution system by isolating the ESF transformers from degraded offsite power sources. EC90198 proposes to enable the trip features of the OPD system by closing in the test switches, allowing automatic transfer to healthy sources upon an OPD event. Enabling the trip functions will protect ESF equipment from potential overheating due to the imbalanced, open phased, offsite electrical system.

2022-002-00 EC90198 The OPD system is designed to detect an open phase on the lines feeding the transformers ESF11, ESF12, and ESF21 and provides alarm and trip signals to isolate the ESF buses from the degraded offsite source. The plant response to postulated accidents is not impacted by the proposed activity. The redundant design in the one out of two taken twice trip logic ensures that the activity does not result in a more than minimal increase in the frequency of occurrence of an accident. The microprocessor relays installed in the OPD system can perform self-diagnostics and identify a relay malfunction which prevents spurious trips. The use of microprocessor relays, system testing and system monitoring along with the redundancy in design ensures that the activity does not result in a more than minimal increase in the likelihood of malfunction and ensures compliance with the method of evaluation.

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GN RO2022-00019 Attachment 1 10 CFR 50.59 Evaluation Summary Report Evaluation Initiating Summary Number Document Per Section 4.3 .1 of NEI 96-07 Rev 1, the effect of a proposed activity on the frequency of an accident must be discernible and attributable to the proposed activity to exceed the more than minimal increase standard. These 2022-002-00 features ensure the modification meets the minimal standard as defined in NEI 96-07.

Cycle 24 Reload / COLR:

The BWR reload process requires that the vendor perform calculations to confirm the new core design meets the licensing acceptance criteria and the 'Analysis of Record' (AOR) continues to bound by the reload core design. Therefore, the core design features requiring the performance of reload transient analysis activity are considered adverse changes that must be evaluated under the 50.59 process.

There is no impact on fuel operating limits or licensing analyses because of the application of the GNF2 or GNF3 designs. The GGNS Cycle 24 specific operating limits are addressed as a part of the changes to the Cycle 24 COLR.

The GGNS Cycle 24 Reference Loading Pattern (RLP) was developed using approved methods (GESTAR II, currently referenced in TS 5.6.5). An objective of the GGNS Cycle 24 core shuffle was to find & remove a fuel leaker from the GGNS Cycle 23 core. This effort resulted in a change to the GGNS Cycle 24 RLP, called the Updated Loading Pattern (ULP). The ULP design was also developed using approved methods 2022-003-00 EC90704 (GESTAR II). When a proposed core loading is not identical to the Reference Loading Pattern (RLP), it is first evaluated per GESTAR Section 3.4.2, "Acceptable Deviation from Reference Core Design". If the core loading conforms to all the requirements of this section, then no further review or analysis is required (Tier 1). If it cannot meet all the restrictions of GESTAR Section 3.4.2, then all the affected licensing parameters must be re-examined to assure there is no adverse impact. The re-examination procedure is described in GESTAR Section 3.4.3, "Re-Examination of Bases" (Tier 2). For the evaluation of the ULP, the requirements of Section 3.4.2 were reviewed per the GESTAR II methodology, and the ULP design was found to remain bound by the original core design with no further analyses required (i.e., Tier 1 screening criteria were met, no further analysis required).

An engineering evaluation was performed in EC90704 to document that operation of the GGNS Cycle 24 ULP would continue to meet all applicable core design and licensing criteria. The GGNS Cycle 24 COLR has been prepared and verified to continue to provide adequate protection of core design related safety limits after implementation of the ULP design.

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GNRO2022-00019 Attachment 2 Commitment Change Evaluation Summary Report Commitment Original Commitment New Commitment and Justification for Change Number GGNS will volumetrically examine 3 percent, with a maximum of 10, of the socket welds and 3 percent, With a maximum of 10, of the butt welds within the population of ASME class 1 small bore piping welds.

GGNS will volumetrically examine 10%, with a maximum of 25, of the socket welds and 10%, with a NUREG-1801, rev. 2, section XL.M.35, one-time inspection of ASME code maximum of 25, of the butt welds within the population 36196 class 1 small-bore piping, allows the smaller sampling for a plant that "has of ASME class 1 small bore piping welds. See program never experienced a failure in its ASME code class 1 piping (a through-wall description in UFSAR section a.1.34, based on license crack detected in the subject component by evidence of leakage, or through renewal application appendix a.

nondestructive or destructive examination) and has extensive operating history (more than 30 years of operation at time of submitting the application) ... " GGNS now has 30 years of operating experience without experiencing a failure.

Enhance the oil analysis program to provide a formalized analysis technique for particulate counting.

The commitment was made to manage the effects of aging on these non-Enhance the oil analysis program to provide a safety-related components under the oil analysis program because it was formalized analysis technique for particulate counting thought that the components normally contain oil and that corrosion caused 36194 and to include piping and components within the main by oil that is not sampled to ensure it does not contain water could result in generator system (N41) with an internal environment of an adverse impact to safety-related systems or components through spatial lube oil.

interaction due to leakage or spray. However, this was an incorrect, assumption and due to GGNS procedures requiring that any liquid is drained so that only a minimal amount is nominally present and makes an aging management program on the N41 system unnecessary.

UFSAR A.4, item 25: enhance the periodic surveillance License renewal FSAR 50.59 and preventive maintenance program to revise program UFSAR A.4, item 25: enhance the periodic surveillance and preventive guidance documents as necessary to include all maintenance program to revise program guidance documents as necessary activities as described in LRA section B.1.35. This LRA to include all activities as described in LRA section B.1.35, with the section included site-specific requirements for coating exception of internal coating integrity inspections (see UFSAR section integrity inspections for license renewal that were made A.1 .45, coating integrity program).

36197 during the NRCs review of the license renewal Implement a coating integrity program consistent with the recommendations application. The detailed requirements are included in of LR-ISG-2013-01 to manage the effects of aging on internal coatings.

UFSAR section A.1.35. These requirements were Section A.1.35, PSPM program: this change removes the coating integrity based on a draft version of LR-ISG-2013-01. inspection description in UFSAR section A.1.35. A new UFSAR section UFSAR A.4, item 35: the service water integrity A.1 .45, coating integrity program, is added instead. Section A.1.45 is program will be enhanced as follows. consistent with the ISG.

During the 10-year period prior to the period of extended UFSAR A.4, item 35: revise service water integrity program documents to operation, visual inspections will be performed of coated include inspections for loss of material due to erosion. This existinq Page 1 of 4

GNRO2022-00019 Attachment 2 Commitment Change Evaluation Summary Report Commitment Original Commitment New Commitment and Justification for Change Number internal surfaces of standby service water system enhancement in item 35 will be the only enhancement listed. Coating components. Subsequent coating inspections will be inspection details are deleted. Internal coating inspections for service water performed based on inspection results as follows. This components will be conducted under the coating integrity program.

commitment includes details for coating inspections Section A.1.41, service water integrity program, will be revised to refer to 36197 based on the draft ISG. The detailed requirements are UFSAR section A.1.45 for internal coating inspections.

also in UFSAR section A.1.41. Section A.1.45, coating integrity program, will be added.

This change replaces commitments to perform coating inspections as part of the PSPM and SWI programs with a commitment to implement a coating inteqrity program consistent with later NRG-issued recommendations.

UFSAR Section A.1.4 and Section A.4, Item 4 license UFSAR Section A.1.4 and Section A.4, Item 4 license renewal commitments renewal commitments for the Boraflex Monitoring for the Boraflex Monitoring Program as shown below. Item 4-1: Enhance the Program. Boraflex Monitoring Program for GGNS to perform periodic surveillances of Item 4-1: Enhance the Boraflex Monitoring Program for the Boraflex neutron absorbing material in the spent fuel pool at least once GGNS to perform periodic surveillances of the Boraflex every 5 years using Boron-10 Areal Density Gage for Evaluating Racks neutron absorbing material in the spent fuel pool and (BADGER) testing. Item 4-2: RACKLIFE analysis, or an equivalent upper containment pool at least once every 5 years methodology, will continue to be performed each cycle. This analysis will using Boron-10 Areal Density Gage for Evaluating include a comparison of the RACKLIFE predicted silica to the plant Racks (BADGER) testing. Item 4-2: RACKLIFE analysis measured silica. This comparison will determine if adjustments to the 36177 will continue to be performed each cycle. This analysis RACKLIFE loss coefficient are merited. The analysis will include projections will include a comparison of the RACKLIFE predicted to the next planned RACKLIFE analysis date to ensure current Region I silica to the plant measured silica. This comparison will storage locations will not need to be reclassified as Region II storage determine if adjustments to the RACKLIFE loss locations in the analysis interval. The upper containment pool is used only coefficient are merited. The analysis will include for temporary storage during refueling operations, not for long-term storage projections to the next planned RACKLIFE analysis date of spent fuel, the dose received by the Boraflex panels in the upper to ensure current Region I storage locations will not containment pool (and the resulting boron loss) is many times lower than need to be reclassified as Region II storage locations in that of the panels in the spent fuel pool. This change also allows an the analysis interval. equivalent methodoloqy to RACKLIFE to be used for analysis.

Enhance the Water Chemistry Control - Closed Treated Water Program to (Excerpt) ... Enhance the Water Chemistry Control - revise the water chemistry procedure for closed treated water systems to Closed Treated Water Program to revise the water align the water chemistry control parameter limits with those of EPRI Closed chemistry procedure for closed treated water systems to Cooling Water Chemistry Guidelines.

36202 align the water chemistry control parameter limits with EPRI reports are identified by a title and report number/revision. New those of EPRI 1007820. revisions of EPRI reports typically change the report number but not the title.

The UFSAR should not have a commitment to a specific revision of the quidelines.

Enhance the water chemistry control-closed treated Enhance the water chemistry control-closed treated water program to water program to provide testing of the engine jacket 36202 provide replacement of the engine jacket water for the engine-driven fire water for the engine-driven fire water pump diesels at water pump diesels at least annually.

least annually Page 2 of 4

GNRO2022-00019 Attachment 2 Commitment Change Evaluation Summary Report Commitment Original Commitment New Commitment and Justification for Change Number This coolant replacement activity performed in lieu of coolant testing is adequate to ensure that the intended function of these components is maintained. The commitment is therefore changed to credit the annual engine jacket water (coolant) replacement in place of testing.

The Compressed Air Monitoring Program will be enhanced as follows.

• Apply a consideration of the guidance of ASME OM-S/G-1998, Part Enhance the Compressed Air Monitoring Program for 17; American National Standards Institute (ANSl)/ISA-S7.0.01-1996; EPRI GGNS to apply a consideration of the guidance of NP-7079; and EPRI TR-108147 to the limits specified for air system ASME OM-S/G-1998, Part 17; American National contaminants.

Standards Institute (ANSl)/ISA-S7.0.01-1996; EPRI NP-

• Revise Compressed Air Monitoring Program procedures to include 7079; and EPRI TR-108147 to the limits specified for air opportunistic visual inspections of components downstream of system air system contaminants.

dryers. Inspections consist of visual examination of accessible component Enhance the Compressed Air Monitoring Program to internal surfaces.

36180 include periodic and opportunistic A review of ASME OM-S/G-1998 Part 17 found that it does not include a inspections of accessible internal surfaces of piping, requirement for periodic inspection. The absence of periodic compressed air compressors, dryers, aftercoolers, and filters and to component inspections will not diminish the ability of compressed air apply consideration of the guidance of ASME OM-S/G-systems to perform their intended function since periodic testing for moisture 1998, Part 17 for inspection frequency and inspection and opportunistic inspections will ensure that loss of material is not methods of these components in the following occurring. In support of this conclusion, the latest NRC guidance for license compressed air systems,,: 1) ADS, 2) Division 1, 2, & 3 renewal, the XI.M24 Compressed Air Monitoring program description in DG Starting Air, 3) Instrument Air NUREG-2191 does not specify periodic inspections but does include opportunistic inspections.

Implement the Buried Piping and Tanks Inspection Program for GGNS to be Implement the Buried Piping and Tanks Inspection consistent with the program as described in LR-ISG-2015-01. Soil testing will Program for GGNS as described in LRA Section B.1.5 be performed at two locations near the SS condensate storage system Soil testing will be performed at two locations near the piping that is subject to aging management review. Measure parameters will SS condensate storage system piping that is subject to include soil resistivity, bacteria, pH, moisture, chlorides, and redox potential.

aging management review. Measure parameters will If the soil is determined to be corrosive, then the number of inspections will 36178 include soil resistivity, bacteria, pH, moisture, chlorides, be increased from one to two prior to and during the period of extended and redox potential. If the soil is determined to be operation.

corrosive, then the number of inspections will be These changes were made by the NRC staff based on industry OE gained increased from one to two prior to and during the period during the implementation of the Buried Piping Initiative described in NEI 09-of extended operation. 14 as well as license renewal buried piping inspections and the review of additional industry standards related to buried piping.

36167 Site severe accident management guidelines (SAMG) Site severe accident management guidelines (SAMG), which includes the will be updated to future revisions of the boiling water emergency procedures and the severe accident procedures at GGNS, will reactor owner's group generic severe accident technical be updated to future revisions of the boiling water reactor owner's group guidelines, and the SAMGs will be integrated with other generic severe accident technical guidelines, and the SAMGs will be emergency response guideline sets and symptom- integrated with other emergency response guideline sets and symptom-Page 3 of 4

GNRO2022-00019 Attachment 2 Commitment Change Evaluation Summary Report Commitment Original Commitment New Commitment and Justification for Change Number based emergency operating procedures, and validated, based emergency operating procedures, and validated, using the guidance using the guidance in NEI 14-01, emergency response in NEI 14-01, emergency response procedures and guidelines for beyond procedures and guidelines for beyond design basis design basis events and severe accidents, excluding BWROG SAMG events and severe accidents. revision 4 which will be incorporated into the sites SAMG by July 31, 2022.

36167 Delaying GGNS implementation of SAMG revision 4 will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident, or involve a significant reduction in a margin of safety as this guidance is for beyond design basis events, and GGNS has already implemented BWROG SAMG revision 3, which gives adequate guidance for beyond design basis events. This extension is necessary to ensure that GGNS operators are adequately trained on SAMG revision 4.

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