View source for GNRO-2014/00058, Letter GNRO-2012/00146, Technical Requirements Manual and Technical Specification Bases Update (ML12361A330)

{{Adams
| number = ML14241A309
| issue date = 08/29/2014
| title = Letter GNRO-2012/00146, Technical Requirements Manual and Technical Specification Bases Update (ML12361A330)
| author name = Mulligan K
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000416
| license number = NPF-029
| contact person = 
| case reference number = GNRO-2014/00058
| document type = Letter type:GNRO, Manual, Technical Specification, Bases Change
| page count = 80
}}

=Text=
{{#Wiki_filter:~
~Entergy                                                                          Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2014/00058 August 29,2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Technical Specification Bases Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

==REFERENCE:==
Entergy Letter GNRO-2012/00146, Technical Requirements Manual and Technical Specification Bases Update (ML12361A330)

==Dear Sir or Madam:==

Pursuant to 10 CFR 50.71 (e), Entergy Operations Inc. herby submits an update of all changes made to the Grand Gulf Nuclear Station Technical Specification Bases since the last submittal (GNRO-2012/00146, dated December 21,2012).
This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.
I declare under penalty of perjury that the foregoing is true and cor-recl. Executed on the 29th day of August 2014.
Sincerely,
 ~----
KJM/ram Attachment(s):     1. Technical Specification Bases Change Summary
: 2. Technical Specification Bases Changes

GNRO-2014/00058 Page 2 of 2 cc: without Attachment(s)
U.S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRR/DORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 U.S. Nuclear Regulatory Commission AnN: Mr. Nathaniel Ferrer NRR/DLR Mail Stop OWFNI 11 F1 11555 Rockville Pike Rockville, MD 20852-2378 (
NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 GNRO-2014/00058 Technical Specification Bases Change Summary of GNRO-2014-00058 LBDCR              Topic of Change            Affected Technical Specification Bases Number                                                          Pages 12052   Revision of technical specification 83.3-6a (TS) bases page to correct typographical error (Amendment 188).
13004   TRM to correct typographical errors 83.1-41, 83.1-43 in technical requirements manual (TRM) and TS bases.
13029   Revision of TS bases to address     83.0-9a, 83.0-9b non-seismic snubbers.
13043   Implementation of TS Amendment      83.1-43, 83.1-49, 83.3-26, 83.3-27a, 197 for 24 month fuel cycle.        83.3-28, 83.3-29a, 83.3-38, 83.3-47, 83.3-60, 83.3-66, 83.3-75, 83.3-76, 83.3-86,83.3-123,83.3-135,83.3-169, 83.3-170, 83.3-170a, 83.3-182, 83.3-183, 83.3-194, 83.3-207, 83.3-213, 83.3-217, 83.3-231, 83.3-237, 83.3-238, 83.4-11, 83.4-12, 83.4-20, 83.4-37, 83.5-11, 83.5-12, 83.5-14, 83.5-25, 83.5-26, 83.6-13, 83.6-25, 83.6-35, 83.6-39, 83.6-40,83.6-46,83.6-47,83.6-65, 83.6-76, 83.6-82, 83.6-87a, 83.6-94, 83.6-95, 83.6-101, 83.6-119, 83.6-130, 83.7-7,83.7-10, 83.7-16a, 83.7-21, 83.8-18, 83.8-18a, 83.8-20, 83.8-22, 83.8-23, 83.8-24, 83.8-25a, 83.8-27, 83.8-28, 83.8-30, 83.8-30a, 83.8-31, 83.8-56a, 83.8-57, 83.8-58

Attachment 2 GNRO-2014/00058 Technical Specification Bases Changes

LCO Applicability B 3.0 BASES   (continued)
LCO   3.0.8         LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s).       This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s).       This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control.        The snubber requirements do not meet the criteria in 10 CFR 50.36 (c), (2) (ii), and, as such, are appropriate for control by the licensee.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.
LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours to restore the snubber(s) before declaring the supported system inoperable.
The 72 hour Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.
LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated function(s) to more than one train or subsystem of a multiple train or subsystem supported system.      LCO 3.0.8.b allows 12 hours to restore the snubber(s) before declaring the supported system inoperable.      The 12 hour Completion Time is reasonable based on the low probability of a seismic event concurrent with an (continued)
GRAND GULF                                B 3.0-9a                         LBDCR 13029

LCO Applicability B 3.0 BASES LCO 3.0.8      event that would require operation of the supported system (continued) occurring while the snubber(s) are not capable of performing their associated support function.
LCO 3.0.8 requires that risk be assessed and managed.
Industry and NRC guidance on the implementation of 10 CFR SO.6S(a) (4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.
LCO 3.0.8 does not apply to non-seismic snubbers. The provisions of LCO 3.0.8 are not to be applied to supported TS systems unless the supported systems would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.
The risk impact of dynamic loadings other than seismic loads was not assessed as part of the development of LCO 3.0.8.
These shock-type loads include thrust loads, blowdown loads, water-hammer loads, steam-hammer loads, LOCA loads and pipe rupture loads. However, there are some important distinctions between non-seismic (shock-type) loads and seismic loads which indicate that, in general, the risk impact of the out-of-service snubbers is smaller for non-seismic loads than for seismic loads. First, while a seismic load affects the entire plant, the impact of a non-seismic load is localized to a certain system or area of the plant. Second, although non-seismic shock loads may be higher in total force and the impact could be as much or more than seismic loads, generally they are of much shorter duration than seismic loads. Third, the impact of non-seismic loads is more plant specific, and thus harder to analyze generically, than for seismic loads. For these reasons, every time LCO 3.0.8 is applied, at least one train of each system that is supported by the inoperable snubber(s) should remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.
GRAND GULF                        B 3.0-9b                         LBDCR 13029

SLC System B 3.1.7 BASES SURVEILLANCE SR   3.1.7.3 and SR 3.1.7.5 REQUIREMENTS The requirements of 10 CFR 50.62 are met by the use of a sodium pentaborate solution enriched in the boron-10 (B-10) isotope. SR 3.1.7.3 determines whether the sodium pentaborate concentration, in conjunction with the boron enrichment, is within limits to meet the requirements of 10 CFR 50.62. SR 3.1.7.5 ensures that the parameters used in the determination of sodium pentaborate concentration are within limits. The available solution volume is the solution volume above the pump suction penetration. This surveillance requires an examination of the sodium pentaborate solution by using chemical analysis to ensure the proper weight of B-10 exists in the storage tank. SR 3.1.7.5 must be performed anytime boron or water is added to the storage tank solution to establish that the weight of 8-10 is within the specified limits. This SR must be performed anytime the solution temperature is restored to ~ 45'F, to ensure no significant boron precipitation occurred.
The 31 day Frequency of these surveillances is appropriate because of the relatively slow variation of boron concentration between surveillances.
SR   3.1.7.4 and SR  3.1.7.6 SR 3.1.7.4 verifies the continuity of the explosive charges in the injection valves to ensure proper operation will occur if required.
(continued)
GRAND GULF                     B 3.1-41                        LBDCR 13004

SLC System B 3.1.7 BASES SURVEILLANCE                   SR    3.1.7.7 REQUIREMENTS (continued)                Demonstrating each SLC System pump develops a flow rate
                                                   ~   41.2 gpm at a discharge pressure ~ 1340 psig without actuating the pump's relief valve ensures that pump performance has not degraded during the fuel cycle. This minimum pump flow rate requirement ensures that, when combined with the sodium pentaborate solution concentration requirements, the rate of negative reactivity insertion from the SLC System will adequately compensate for the positive reactivity effects encountered during power reduction, cooldown of the moderator, and xenon decay. This test confirms one point on the pump design curve, and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this Surveillance is in accordance with the Inservice Testing Program.
This Surveillance ensures that there                   is a functioning flow path from the boron solution storage                   tank to the RPV, including the firing of an explosive                   valve. The replacement charge for the explosive valve shall                   be from the same
                                                  --man'ufactffred----ba:tch**--a-s-*th-e--*one-*-f,yed*-or---f-r-om-~anotne-roatch--'-'
that has been certified by having one of that batch successfully fired. Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed. The pump and explosive valve tested should be alternated such that both complete flow paths are tested every 48 months, at alternating 24 month intervals.
The Surveillance may be performed in separate steps to prevent injecting boron into the RPV. An acceptable method
                                                  -for--veri-fying---flow-ffom*thepUmp-tothe-RPVis-*-to pump _ __. . _ ._._.              ._
------------.----- -.--.------.--.----.--- -.------**-aenffner-aTfzea-wa t er-from a test tan k th rough one SLC subsystem and into the RPV. The 24 month Frequency is based I on the need to perform this Surveillance unqer the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance test when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
GRAND GULF                                               B 3.1-43                                       LBDCR 13043

SDV Vent and Drain Valves B 3.1.8 BASES SURVEILLANCE SR  3.1.8.3   (continued)
REQUIREMENTS reset signal, the opening of the SDV vent and drain valves is verified. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.1.1 and the scram time testing of control rods in LCO 3.1.3, "Control Rod OPERABILITY," overlap this Surveillance to provide complete testing of the assumed safety function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency; therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 4.6.1.1.2.4.2.6.
: 2. 10 CFR 50.67, AAccident Source Terms.@
: 3. NUREG-0803, "Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping,"
August 1981.
GRAND GULF                     B 3.1-49                        LBDCR 13043

RPS Instrumentation B 3.3.1.1 BASES APPLICABLE       The APRM subsystem is divided into four APRMjOPRM channels SAFETY ANALYSES, and four 2-0ut-Of-4 Voter channels. Each APRMjOPRM channel LCO, and         provides inputs to each of the four voter channels. The APPLICABILITY    four voter channels are divided into two groups of two each, (continued)    with each group of two providing inputs to one RPS trip system. The system is designed to allow one APRMjOPRM channel, but no voter channels, to be bypassed. A trip from anyone un-bypassed APRMjOPRM channel will result in a "half-trip" in all four of the voter channels, but no trip inputs to either RPS trip system. Since APRM Functions 2.a, 2.b, 2.d, and 2.f are implemented in the same hardware, these functions are combined with APRM Inop Function 2.c.
Any Function 2.a, 2.b, 2.c, or 2.d trip from any two un-bypassed APRMjOPRM channels will result in a full trip in each of the four 2-0ut-Of-4 Voter channels, which in turn results in two trip inputs to each RPS trip system logic channel (AI, A2, B1, and B2). Similarly, any Function 2.c or 2.f trip from any two un-bypassed APRMjOPRM channels will result in a full trip from each Voter channel. Three of the four APRMjOPRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal. In addition, to provide adequate coverage of the entire core, consistent with the design bases for APRM Functions 2.a, 2.b, and 2.d, at least 20 LPRM inputs, with at least three LPRM inputs from each of the four axial levels at which the LPRMs are located, must be operable for each APRMjOPRM channel. For the OPRM Upscale, Function 2.f, LPRMs are assigned to "cells" of four detectors. A minimum of 30 cells, each with a minimum of two LPRMs, must be OPERABLE for the OPRM Upscale Function 2.f to be OPERABLE.
(continued)
GRAND GULF                         B 3.3-6a                         LBDCR 12052

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE   SR   3.3.1.1.7 REQUIREMENTS (continued) LPRM gain settings are determined from the Core power distribution calculated by the Core Performance Monitoring system based on the local flux profiles measured by the Traversing Incore Probe (TIP) System. This establishes the relative local flux profile for appropriate representative input to the APRM System. The 2000 MWD/T (megawatt days/ton) Frequency is based on operating experience with LPRM sensitivity changes. For the purpose of calculating this surveillance frequency, the* ton (T) unit of weight is expressed in terms of metric tons of uranium fuel residing in the reactor core.
SR   3.3.1.1.8 and SR  3.3.1.1.11 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The 92 day Frequency of SR 3.3.1.1.8 is based on the reliability analysis of Reference 9.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.
(continued)
GRAND GULF                       B 3.3-26                         LBDCR 13043

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.10. SR    3.3.1.1.12 and SR 3.3.1.1.17 REQUIREMENTS (continued)
Note 3 to SR 3.3.1.1.10 states that the APRM recirculation flow transmitters are excluded from CHANNEL CALIBRATION of Function 2.d, Average Power Range Monitor Flow Biased Simulated Thermal Power - High. Calibration of the flow transmitters is performed on an 18-month frequency (SR 3.3.1.1.17).
SR 3.3.1.1.10 for the designated function is modified by two notes identified in Table 3.3.1.1-1. The first note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluating channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in channel performance prior to returning the channel to service. Performance of these channels will be evaluated under the Corrective Action Program. Entry into the Corrective Action Program ensures required review and documentation of the condition to establish a reasonable expectation for continued OPERABILITY.
The second note requires that the as-left setting for the channel be within the as-left tolerance of the Nominal Trip Setpoint (NTSP). Where a setpoint more conservative than the NTSP issued in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NSP, then the channel shall be declared inoperable. The second note also requires the NTSP and the methodologies for calculating the as-left and the as-found tolerances to be in the Technical Requirements Manual The Frequency of 24 months for SR 3.3.1.1.12 and SR 3.3.1.1.17 is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.
(continued)
GRAND GULF                    B 3.3-27a                         LBDCR 13043

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE   SR  3.3.1.1.13 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The functional testing of control rods, in LCO 3.1.3, "Control Rod OPERABILITY," and SDV vent and drain valves, in LCO 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves," overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.
SR  3.3.1.1.14 This SR ensures that scrams initiated from the Turbine Stop Valve Closure, Trip Oil Pressure - Low and Turbine Control Valve Fast Closure, Trip Oil Pressurec Low Functions will not be inadvertently bypassed when THERMAL POWER is
               ~ 35.4% RTP. This involves calibration of the bypass channels. Adequate margins for the instrument setpoint methodology are incorporated into the actual setpoint.
Because main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from turbine first stage pressure), the main turbine bypass valves must remain closed at THERMAL POWER ~ 35.4% RTP to ensure that the calibration remains valid.
If any bypass channel setpoint is nonconservative (i.e., the Functions are bypassed at ~ 35.4% RTP, either due to open main turbine bypass valve(s) or other reasons), then the affected Turbine Stop Valve, Trip Oil Pressure-Low and Turbine Control Valve Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable. Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition, this SR is met and the channel is considered OPERABLE.
The Frequency of 24 months is based on engineering judgment and reliability of the components.
(continued)
GRAND GULF                       B 3.3-28                         LBDCR 13043

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR   3.3.1.1.15  (continued)
REQUIREMENTS RPS RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST BASIS. Note 3 requires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per trip system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function. This Frequency is based on the logic interrelationships of the various channels required to produce an RPS scram signal.
Therefore, staggered testing results in response time verification of these devices every 24 months. This Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious time degradation, but not channel failure, are infrequent.
SR   3.3.1.L.16 and SR 3.3.1.1.18 Deleted (continued)
GRAND GULF                     B 3.3-29a                       LBDCR 13043

SRM Instrumentation B 3.3.1.2 BASES SURVEILLANCE SR   3.3.1.2.5  (continued)
REQUIREMENTS The Note to the Surveillance allows the Surveillance to be delayed until entry into the specified condition of the Applicability. The SR must be performed in MODE 2 within 12 hours of entering MODE 2 with IRMs on Range 2 or below.
The allowance to enter the Applicability with the 31 day Frequency not met is reasonable, based on the limited time of 12 hours allowed after entering the Applicability and the inability to perform the Surveillance while at higher power levels. Although the Surveillance could be performed while on IRM Range 3, the plant would not be expected to maintain steady state operation at this power level. In this event, the 12 hour Frequency is reasonable, based on the SRMs being otherwise verified to be OPERABLE (i.e., satisfactorily performing the CHANNEL CHECK) and the time required to perform the Surveillances.
SR   3.3.1.2.6 Performance of a CHANNEL CALIBRATION verifies the performance of the SRM detectors and associated circuitry.
The Frequency considers the plant conditions required to perform the test, the ease of performing the test, and the likelihood of a change in the system or component status.
The neutron detectors are excluded from the CHANNEL CALIBRATION because they cannot readily be adjusted. The detectors are fission chambers that are designed to have a relatively constant sensitivity over the range, and with an accuracy specified for a fixed useful life.
The Note to the Surveillance allows the Surveillance to be delayed until entry into the specified condition of the Applicability. The SR must be performed in MODE 2 within 12 hours of entering MODE 2 with IRMs on Range 2 or below.
The allowance to enter the Applicability with the 24 month Frequency not met is reasonable, based on the limited time' of 12 hours allowed after entering the Applicability and the inability to perform the Surveillance while at higher power levels. Although the Surveillance could be performed while on IRM Range 3, the plant would not be expected to maintain steady state operation at this power level. In this event, the 12 hour Frequency is reasonable, based on the SRMs being (continued)
GRAND GULF                     B 3.3-38                        LBDCR 13043

Control Rod Block Instrumentation B 3.3.2.1 BASES SURVEILLANCE SR   3.3.2.1.6  (continued)
REQUIREMENTS in the nonbypassed condition, the SR is met and the RWL would not be considered inoperable. Because" main turbine bypass steam flow can affect the HPSP nonconservatively for the RWL, the RWL is considered inoperable with any main turbine bypass valve open. The Frequency of 92 days is based on the setpoint methodology utilized for these channels.
SR   3.3.2.1.7 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Frequency is based upon the assumption of the magnitude of equipment drift in thesetpoint analysis.
SR   3.3.2.1.8 The CHANNEL FUNCTIONAL TEST for the Reactor Mode Switchc Shutdown Position Function is performed by attempting to withdraw any control rod with the reactor mode switch in the shutdown position and verifying a control rod block occurs.
As noted in the SR, the Surveillance is not required to be performed until 1 hour after the reactor mode switch is in the shutdown position, since testing of this interlock with the reactor mode switch in any other position cannot be performed without using jumpers, lifted leads, or movable limits. This allows entry into MODES 3 and 4 if the 24 month Frequency is not met per SR 3.0.2.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency.
(continued)
GRAND GULF                     B 3.3-47                         LBDCR 13043

PAM Instrumentation B 3.3.3.1 BASES SURVEILLANCE SR  3.3.3.1.1   (continued)
REQUIREMENTS Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the si~nal processing equipment has drifted outside its limit.
The Frequency of 31 days is based upon plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given function in any 31 day interval is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of those displays associated with the required channels of this LCO.
SR  3.3.3.1.2   Deleted SR  3.3.3.1.3 For all Functions a CHANNEL CALIBRATION is performed every 24 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. The Frequency is based on operating experience and consistency with the typical industry refueling cycles.
For Functions 12 and 13 the CHANNEL CALIBRATION consists of an electronic calibration of the channel, not including the detector, for range decades above 10R/hr and a one point calibration check of the detector below 10R/hr with an installed or portable gamma source. The neutron detectors are excluded from the CHANNEL CALIBRATION because they cannot readily be adjusted. The detectors are fission (continued)
GRAND GULF                     B 3.3-60                        LBDCR 13043

Remote Shutdown System B 3.3.3.2 BASES SURVEILLANCE SR   3.3.3.2.1  (continued)
REQUIREMENTS The Frequency is based upon plant operating experience that demonstrates channel failure ;s rare.
SR   3.3.3.2.2 SR 3.3.3.2.2 verifies each required Remote Shutdown System transfer switch and control circuit 'performs the intended function. This verification is performed from the remote shutdown panel and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations. However, this Surveillance is not required to be performed only during a plant outage.
Operating experience demonstrates that Remote Shutdown System control channels usually pass the Surveillance when performed at the 24 month Frequency.
SR   3.3.3.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies the channel responds to measured parameter values with the necessary range and accuracy.
The 24 month Frequency is based upon operating experience and is consistent with the typical industry refueling cycle.
REFERENCES   1. 10 CFR 50, Appendix A, GDC 19.
GRAND GULF                     B 3.3-66                         LBDCR 13043

EOC-RPT Instrumentation B 3.3.4.1 BASES SURVEILLANCE  SR  3.3.4.1.4 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is included as a part of this test, overlapping the LOGIC SYSTEM FUNCTIONAL TEST, to provide complete testing of the associated safety function. Therefore, if a breaker is incapable of operating, the associated instrument channel would also be inoperable.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance test when performed at the 24 month Frequency.
SR  3.3.4.1.5 This SR ensures that an EOC-RPT initiated from the TSV Closure, Trip Oil Pressure-Low and TCV Fast Closure, Trip Oil PressurecLow Functions will not be inadvertently bypassed when THERMAL POWER is ~ 35.4% RTP. This involves calibration of the bypass channels. Adequate margins for the instrument setpoint methodologies are incorporated into the actual setpoint. Because main turbine bypass flow can affect this setpoint nonconservat;vely (THERMAL POWER is derived from first stage pressure), the main turbine bypass valves must remain closed at THERMAL POWER ~ 35.4% RTP to ensure that the calibration remains valid. If any bypass channel's setpoint is nonconservative (i.e., the Functions are bypassed at ~ 35.4% RTP either due to open main turbine bypass valves or other reasons), the affected TSV Closure, Trip Oil PressurecLow and TCV Fast Closure, Trip Oil Pressure-Low Functions are considered inoperable.
Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition, this SR is met and the channel considered OPERABLE.
The Frequency of 24 months has shown that channel bypass failures between successive tests are rare.
(continued)
GRAND GULF                     B 3.3-75                         LBDCR 13043

EOC-RPT Instrumentation B3.3.4.1 BASES SURVEILLANCE   SR   3.3.4.1.6 REQUIREMENTS (continued) This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The EOC-RPT SYSTEM RESPONSE TIME acceptance criteria are included in the applicable plant procedures.
A Note to the Surveillance states that breaker interruption time may be assumed from the most recent performance of SR 3.3.4.1.7. This is allowed since the time to open the contacts after energization of the trip coil and the arc suppression time are short and do not appreciably change, due to the design of the breaker opening device and the fact that the breaker is not routinely cycled.
EOC-RPT SYSTEM RESPONSE TIME tests are conducted on an 24 month STAGGERED TEST BASIS. Each test includes two turbine control valve channels from one trip system and two turbine stop valve channels from the other trip system.
Response times cannot be determined at power because operation of final actuated devices is required. Therefore, this Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components that cause serious response time degradation, but not channel failure, are infrequent occurrences.
SR   3.3.4.1.7 This SR ensures that the RPT breaker interruption time is provided to the EOC-RPT SYSTEM RESPONSE TIME test. Breaker Interruption time is defined as Breaker Response time plus Arc Suppression time. Breaker Response is the time from application of voltage to the trip coil until the main contacts separate. Arc Suppression is the time from main contact separation until the complete suppression of the electrical arc across the open contacts. Breaker Response shall be verified by testing and added to the manufacturer's design Arc Suppression time of 12 ms to determine Breaker Interruption time. The breaker arc suppression time shall be validated by the performance of periodic contact gap (continued)
GRAND GULF                       B 3.3-76                        LBDCR 13043

ATWS-RPT Instrumentation B 3.3.4.2 BASES SURVEILLANCE   SR   3.3.4.2.4 REQUIREMENTS (continued) A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency is based upon the assumption of the magnitude of equipment drift in the setpo;nt analysis.
SR   3.3.4.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers, included as part of this Surveillance, overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore, if a breaker is incapable of operating, the associated instrument channel(s) would be inoperable.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency.
REFERENCES     1. UFSAR, Section 5.4.1.7.10.
: 2. NEDE-770-06-1, "Bases For Changes To Surveillance Test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specifications,"
February 1991.
GRAND GULF                       B 3.3-86                         LBDCR 13043

ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE   SR  3.3.5.1.6 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.1, LCO 3.5.2, LCO 3.8.1, and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage (except for Division III which can be tested in any operational condition) and the potential for unplanned transients if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
REFERENCES     1. UFSAR, Section 5.2.
: 2. UFSAR, Section 6.3.
: 3. UFSAR, Chapter 15.
: 4. NEDC-30936-P-A, "BWR Owners' Group Technical Specification Improvement Analyses for ECCS Actuation Instrumentation, Part 2," December 1988.
: 5. Regulatory Guide 1.105, "Setpoints for Safety-Related Instrumentation," Revision 3.
GRAND GULF                      B 3.3-123                         LBDCR 13043

RCIC System Instrumentation B 3.3.5.2 BASES SURVEILLANCE   SR   3.3.5.2.5 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.
REFERENCES     1. NEDE-770-06-2, "Addendum to Bases for Changes to
                     'Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," February 1991.
: 2. Regulatory Guide 1.105, USetpoints for Safety-Related Instrumentation," Revision 3.
GRAND GULF                        B 3.3-135                        LBDCR 13043

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANCE   SR   3.3.6.1.2 REQUIREMENTS (continued) A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.
Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Frequency is based on reliability analysis described in References 5 and 6.
SR   3.3.6.1.3 The calibration of trip units consists of a test to provide a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.1-1. For Function l.c, Main Steam Line Flow High, there is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found settings are consistent with those established by the setpoint methodology. If the trip         _
setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Frequency of 92 days is based on the reliability analysis of References 5 and 6.
SR   3.3.6.1.4. SR  3.3.6.1.5. and SR  3.3.6.1.7 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for ins~rument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency of SR 3.3.6.1.4, SR 3.3.6.1.5, and SR 3.3.6.1.7 is based on the assumption of the magnitude of equipment drift in the setpoint analysis.
(continued)
GRAND GULF                       B 3.3-169                        LBDCR 13043

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANCE   SR   3.3.6.1.6 and SR 3.3.6.1.8 REQUIREMENTS (continued) The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on isolation valves in LCO 3.6.1.3 and LCO 3.6.5.3 overlaps these Surveillances to provide complete testing of the assumed safety function. The 24 month Frequency for SR 3.3.6.1.8 is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 18 month Frequency for SR 3.3.6.1.6 is based on the current frequency for performing this Surveillance.
Operating experience has shown these components usually pass the Surveillance when performed at the listed month Frequency.
SR   3.3.6.1.8 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. Testing;s performed only on channels where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to respond within the DG start time. sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test.
Testing of the closure times of the MSIVs is not included in this Surveillance since the closure time of the MSIVs is tested by SR 3.6.1.3.6. ISOLATION SYSTEM RESPONSE TIME acceptance criteria for this instrumentation is included in the applicable plant procedures.
As Noted, the channel sensor may be excluded from response time testing. This allowance to not perform specific response time testing of the sensors is applicable when the alternate testing requirements and restrictions of Reference 7 are performed. As stated in Reference 7, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS. and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in (continued)
GRAND GULF                       B 3.3-170                        LBDCR 13043

Primary Containment and Drywell Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANCE SR   3.3.6.1:9 (continued)
REQUIREMENTS instrument response times and assure operation of the analyzed instrument loops within acceptable limits.
Reference 7 also identifies that there are no known channel sensor failure modes identified that can be detected by response time testing that cannot also be detected by other Technical Specification required surveillances. Therefore, when the requirements, including sensor types, of Reference 7 are complied with, adequate assurance of the response time of the sensors is provided. This assurance of the response time of the sensors when combined with the response time testing of the remainder of the channel ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The calibration shall be performed such that fast ramp or step change to system components during calibrations is performed to verify that the response of the transmitter to the input change is prompt. Technicians shall monitor for response time degradation during the performance of calibrations.
Technicians shall be appropriately trained to ensure they are aware of the consequences of instrument response time degradation. These items are commitments made per Reference
: 8. If the alternate testing requirements of Reference 7 are not complied with then the entire channel will be response time tested including the sensors.
ISOLATION SYSTEM RESPONSE TIME tests for this instrumentation are conducted on an 24 month STAGGERED TEST BASIS. This test Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience that shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent.
Analysis has shown that with the upper containment pool cavity flooded and the gates removed, adequate time exists to allow operator action necessary to terminate the inventory loss prior to reaching reactor level 3. This analysis takes credit for the pool level being greater than or equal to 22 feet 8 inches above the reactor vessel flange. Verifying the upper containment pool level is greater than or equal to 22 feet 8 inches on a four hour frequency provides assurance that the operators have enough time to detect and terminate a drain down event.
(continued)
GRAND GULF                   B 3.3-170a                        LBDCR 13043

Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES SURVEILLANCE   SR   3.3.6.2.3 REQUIREMENTS (continued) Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.2-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpo;nt methodology, but is not beyond the Allowable Value, performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Frequency of 92 days is based on the reliability analysis of References 3 and 4.
SR   3.3.6.2.4 and SR   3.3.6.2.5 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency of SR 3.3.6.2.4 and SR 3.3.6.2.5 is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.
SR   3.3.6.2.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing, performed on SCIVs and the SGT System in LCO 3.6.4.2 and LCO 3.6.4.3, respectively, overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the (continued)
GRAND GULF                       B 3.3-182                         LBDCR 13043

Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES SURVEILLANCE SR   3.3.6.2.6   (continued)
REQUIREMENTS Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
SR   3.3.6.2.7 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to respond within the DC start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test.
Testing of the closure times of the isolation dampers is not included in this Surveillance since the closure time of the isolation dampers is tested by SR 3.6.4.2.2. ISOLATION SYSTEM RESPONSE TIME acceptance criteria for this instrumentation is included in the applicable plant procedures.
A Note to the Surveillance states that the radiation detectors may be excluded from ISOLATION SYSTEM RESPONSE TIME testing. This Note is necessary because of the difficulty of generating an appropriate detector input signal and because the principles of detector operation virtually ensure an instantaneous response time. Response time for radiation detector channels shall be measured from detector output or the input of the first electronic component in the channel.
ISOLATION SYSTEM RESPONSE TIME tests are conducted on an 24 month STAGGERED TEST BASIS. This Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.
(continued)
GRAND GULF                         B 3.3-183                LBDCR 13043

RHR Containment Spray System Instrumentation B 3.3.6.3 BASES SURVEILLANCE SR   3.3.6.3.3  (continued)
REQUIREMENTS trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Frequency of 92 days is based upon the reliability analysis of Reference 3.
SR   3.3.6.3.4 and SR   3.3.6.3.5 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency of SR 3.3.6.3.4 and SR 3.3.6.3.5 is based on the assumption of the magnitude of equipment drift in the setpoint analysis.
SR  3.3.6.3.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.6.1.7, "Residual Heat Removal (RHR) Containment Spray," overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
(continued)
GRAND GULF                     B 3.3-194                        LBDCR 13043

SPMU System Instrumentation B 3.3.6.4 BASES SURVEILLANCE   SR  3.3.6.4.4 and SR   3.3.6.4.5 REQUIREMENTS (continued) A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency of SR 3.3.6.4.4 and SR 3.3.6.4.5 is based on the assumption of the magnitude of equipment drift in the setpoint analysis.
SR  3.3.6.4.6 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.6.2.4, "Suppression Pool Makeup (SPMU) System,"
overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
REFERENCES     1. UFSAR, Section 7.3.1.1.9.
: 2. UFSAR, Section 6.2.7.3.
: 3. GENE-770-06-1, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications,"
February 1991.
GRAND GULF                      B 3.3-207                        LBDCR 13043

Relief and LLS Instrumentation B 3.3.6.5 BASES SURVEILLANCE SR  3.3.6.5.2  (continued)
REQUIREMENTS equal to or more conservative than accounted for in the appropriate setpoint methodology.
The Frequency of 92 days is based on the reliability analysis of Reference 2.
SR  3.3.6.5.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency is based upon the assumption of the magnitude of equipment drift in the setpoint analysis.
SR  3.3.6.5.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed fot SjRVs in LCO 3.4.4 and LCO 3.6.1.6 overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
REFERENCES   1. UFSAR, Section 5.2.2.
: 2. GENE-770-06-1, "Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications,"
February 1991.
GRAND GULF                    B 3.3-213                        LBDCR 13043

CRFA System Instrumentation B 3.3.7.1 BASES ACTIONS        B.1 (continued)
With the required action and completion time not met, the associated isolation dampers must be closed. This effectively establishes the isolation made of CRFA operation.
The I-hour completion time is intended to allow the operator time to establish this mode of operation. It is acceptable because it minimizes risk while allowing time to establish the CRFA subsystem in operation.
SURVEILLANCE   The Surveillance is also modified by a Note to indicate REQUIREMENTS   that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours, provided the associated Function maintains CRFA System initiation capability. Upon completion of the Surveillance, or expi~ation of the 6 hour allowance, the channel must be returned ;to OPERABLE status I
or the applicable Condition entered and Required Actions taken.
SR  3.3.7.1.1 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.7.3, "Control Room Fresh Air (CRFA) System," overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
(continued)
GRAND GULF                      B 3.3-217                        LBDCR 13043

LOP Instrumentation B 3.3.8.1 BASES SURVEILLANCE SR  3.3.8.1.1  (continued)
REQUIREMENTS The Frequency of 31 days is based on plant operating experience with regard to channel OPERABILITY and drift that demonstrates that failure of more than one channel of a given Function in any 31 day interval is rare.
SR  3.3.8.1.2 and SR 3.3.8.1.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency of these Surveillances is based on the assumption of the magnitude of equipment drift in the setpoint analysis, and the current Surveillance performance.
SR  3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actu~tion logic for a specific channel. The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency.
REFERENCES   1. UFSAR, Section 8.3.1.
: 2. UFSAR, Section S.2.
: 3. UFSAR, Section 6.3.
: 4. UFSAR, Chapter IS.
(continued)
GRAND GULF                    B 3.3-231                        LBDCR 13043

RPS Electric Power Monitorlng B 3.3.8.2 BASES ACTIONS      0.1   (continued)
All actions must continue until the applicable Required Actions are completed.
SURVEILLANCE SR   3.3.8.2.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each overvoltage, undervoltage, and underfrequency channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
As noted in the Surveillance, the CHANNEL FUNCTIONAL TEST is only required to be performed while the plant is in a condition in which the loss of the RPS bus will not jeopardize steady state power operation (the design of the system is such that the power source must be removed from service to conduct the Surveillance). The 24 hours is intended to indicate an outage of sufficient duration to allow for scheduling and proper performance of the Surveillance. The 184 day Frequency and the Note in the Surveillance are based on guidance provided in Generic Letter 91-09 (Ref. 2).
SR   3.3.8.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency is based upon the assumption of an 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
(continued)
GRAND GULF                     B 3.3-237                      LBDCR 13043

RPS Electric Power Monitoring B 3.3.8.2 BASES SURVEILLANCE   SR  3.3.8.2.3 REQUIREMENTS (continued) Performance of a system functional test demonstrates a required system actuation (simulated or actual) signal. The discrete relays/logic of the system will automatically trip open the associated power monitoring assembly circuit breaker. Only one signal per power monitoring assembly is required to be tested. This Surveillance overlaps with the CHANNEL CALIBRATION to provide complete testing of the safety function. The system functional test of the Class IE circuit breakers is included as part of this test to provide complete testing of the safety function. If the breakers are incapable of operating, the associated electric power monitoring assembly would be inoperable.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.
REFERENCES     1. UFSAR, Section 8.3.1.1.5.
: 2. NRC Generic Letter 91-09, "Modification of Surveillance Interval for the Electric Protective Assemblies in Power Supplies for the Reactor Protection System."
GRAND GULF                      B 3.3-238                        LBDeR 13043

FCVs B 3.4.2 BASES ACTIONS        B.1 (continued)
If the FCVs are not deactivated (locked up) and cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours. This brings the unit to a condition where the flow coastdown characteristics of the recirculation loop are not important. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE   SR  3.4.2.1 REQUIREMENTS Hydraulic power unit pilot operated isolation valves located between the servo valves and the common "open" and "close" lines are required to close in the event of a loss of hydraulic pressure. When closed, these valves inhibit FCV motion by blocking hydraulic pressure from the servo valve to the common open and close lines as well as to the alternate subloop. This Surveillance verifies FCV lockup on a loss of hydraulic pressure.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.4.2.2 This SR ensures the overall average rate of FCV movement at all positions is maintained within the analyzed limits.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the (continued)
GRAND GULF                       B 3.4-11                        LBDeR 13043

FCVs B 3.4.2 BASES SURVEILLANCE SR  3.4.2.2   (continued)
REQUIREMENTS Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 15.3.2.
: 2. UFSAR, Section 15.4.5.
GRAND GULF                     B 3.4-12                       LBDeR 13043

5/RVs B 3.4.4 BASES SURVEILLANCE SR   3.4.4.1  (continued)
REQUIREMENTS lift settings must be performed during shutdown, since this is a bench test, and in accordance with the Inservice Testing Program. The lift setting pressure shall correspond to ambient conditions of the valves at nominal operating temperatures and pressures. The safety lift setpoints will still be set within a tolerance of V 1 percent, but the setpoints will be tested to within V 3 percent to determine acceptance or failure of the as-found valve lift setpoint.
If a valve is tested and the lift. setpoint is found outside the 3 percent tolerance, two additional valves are to be tested (Reference 4).
The Frequency was selected because this Surveillance must be performed during shutdown conditions and is based on the time between refuelings.
SR   3.4.4.2 The required relief function .S/RVs are required to actuate automatically upon receipt of specific initiation signals.
A system functional test is performed to verify the~
mechanical portions of the automatic relief function operate as designed when initiated either by an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.5.4 overlaps this SR to provide complete testing of the safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation.
This prevents an RPV pressure blowdown.
SR  3.4.4.3 A manual actuation of each required S/RV (those valves removed and replaced to satisfy SR 3.4.4.1) is performed to (continued)
GRAND GULF                     B 3.4-20                        LBDeR 13043

RCS Leakage Detection Instrumentation B 3.4.7 BASES SURVEILLANCE   SR   3.4.7.3 REQUIREMENTS (continued) This SR requires the performance of a CHANNEL CALIBRATION of the required RCS leakage detection instrumentation channels.
The calibration verifies the accuracy of the instrumentation, including the instruments located inside the drywell. The Frequency of 24 months is a typical refueling cycle and considers channel reliability.
Operating experience has proven this Frequency is acceptable.
REFERENCES     1. 10 CFR 50, Appendix A, GDC 30.
: 2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection System." May 1973.
: 3. GEAP-5620, "Failure Behavior in ASTM AI06B Pipes Containing Axial Through C Wall Flaws," April 1968.
: 4. NUREG-75/067, "Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactor Plants," October 1975.
: 5. UFSAR, Section 5.2.5.5.3.
: 6. UFSAR, Section 5.2.5.2.
GRAND GULF                       B 3.4-37                          LBDeR 13043

ECCS - Operati ng B 3.5.1 BASES SURVEILLANCE SR  3.5.1.4   (continued)
REQUIREMENTS losses, and RPV pressure present during LOCAs. These values may be estabiished during pre-operational testing.
The Frequency for this Surveillance is in accordance with the Inservice Testing Program requirements.
SR  3.5.1.5 The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance test verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required positions. This Surveillance also ensures that the HPCS System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS)
Instrumentation," overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage (except for Division III which can be tested in any operational condition) and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.
(continued)
GRAND GULF                   B 3.5-11                         LBDCR 13043

ECCS - Ope rati ng B 3.5.1 BASES SURVEILLANCE   SR  3.5.1.6 REQUIREMENTS (continued) The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals.
A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,
solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.7 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation. This prevents an RPV pressure blowdown.
SR  3.5.1.7 A manual actuation of each required ADS valve (those valves removed and replaced to satisfy SR 3.4.4.1) is performed to verify that the valve is functioning properly. This SR can be demonstrated by one of two methods. If performed by method 1), plant startup is allowed prior to performing this test because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements (Ref. 19), prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours after reactor steam pressure and flow are adequate to perform the test .. The 12 hours allowed for manual actuation after the required pressure is reached is sufficient to achieve stable conditions for testing and (continued)
GRAND GULF                     B 3.5-12                          LBDCR 13043

ECCS - Operati ng B 3.5.1 BASES SURVEILLANCE SR  3.5.1.8  (continued)
REQUIREMENTS HPCS System ECCS SYSTEM RESPONSE TIME tests are conducted every 24 months. This Frequency is consistent with the typical industry refueling cycle and is based on industry operating experience.
REFERENCES   1. UFSAR, Section 6.3.2.2.3.
: 2. UFSAR, Section 6.3.2.2.4.
: 3. UFSAR, Section 6.3.2.2.1.
: 4. UFSAR, Section 6.3.2.2.2.
: 5. UFSAR, Section 15.6.6.
: 6. UFSAR, Section 15.6.4.
: 7. UFSAR, Section 15.6.5.
: 8. 10 CFR 50, Appendix K.
: 9. UFSAR, Section 6.3.3.
: 10. 10 CFR 50.46.
: 11. UFSAR, Section 6.3.3.3.
: 12. Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
(NRC), "Recommended Interim Revisions to LCD's for ECCS Components," December 1, 1975.
: 13. UFSAR, Section 6.3.3.7.8.
: 14. UFSAR, Section 7.3.1.1.1.4.2.
: 15. GNRI-96/00229, Amendment 130 to the Operating License.
: 16. NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements,1I October 1995.
(continued)
GRAND GULF                   B 3.5-14                         LBDCR 13043

RCIC System B 3.5.3 BASES SURVEILLANCE   SR   3.5.3.3 and SR  3.5.3.4 REQUIREMENTS (continued) The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated. The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow is tested both at the higher and lower operating ranges of the system. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Since the required reactor steam pressure must be available to perform SR 3.5.3.3 and SR 3.5.3.4, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs. Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time to satisfactorily perform the Surveillance is short.
The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure test has been satisfactorily completed and there is no indication or reason to believe that RCIC is inoperable. Therefore, these SRs are modified by Notes that state the Surveillances are not required to be performed until 12 hours after the reactor steam pressure and flow are adequate to perform the test.
A 92 day Frequency for SR 3.5.3.3 is consistent with the Inservice Testing Program requirements. The 24 month Frequency for SR 3.5.3.4 is based on the need to perform this Surveillance under the conditions that apply just prior to or during startup from a plant outage. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueli"ng cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR   3.5.3.5 The RCIC System is required to actuate automatically to perform its design function. This Surveillance verifies that with a required system initiation signal (actual or simulated) the automatic initiation logic of RCIC will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence, (continued)
GRAND GULF                          B 3.5-25                 LBDCR 13043

RCIC System B 3.5.3 BASES SURVEILLANCE SR   3.5.3.5  (continued)
REQUIREMENTS automatic pump startup and actuation of all automatic valves to their required positions. This Surveillance test also ensures that the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2, "Reactor* Core Isolation Cooling (RCIC) System Instrumentation," overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.
REFERENCES   1. 10 CFR 50, Appendix At GDC 33.
: 2. UFSAR, Section 5.4.6.2.
: 3. Memorandum from R. L. Baer (NRC) to V. Stello, Jr.
(NRC), "Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.
GRAND GULF                        B 3.5-26                 LBDCR 13043

Primary Containment Air Locks B 3.6.1.2 SURVEILLANCE   SR  3.6.1.2.4 REQUIREMENTS (continued) A seal pneumatic system test to ensure that pressure does not decay at a rate equivalent to > 2 psig for a period of 48 hours from an initial pressure of 90 psig is an effective leakage rate test to verify system performance.
The 24 month Frequency is based on the fact that operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES     1. UFSAR, Section 3.8.
: 2. 10 CFR 50, Appendix J.
: 3. UFSAR, Table 6.2-13.
GRAND GULF                     B 3.6-13                         LBDCR 13043

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR  3.6.1.3.7   (continued)
REQUIREMENTS each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.7 overlaps this SR to provide complete testing of the safety function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.6.1.3.8 The analyses in Reference 2 is based on leakage that is less than the specified leakage rate. Leakage through any single main steam line must be s 100 scfh when tested at a pressure of 11.9 psig. Leakage through all four steam lines must be ~ 250 scfh when tested at P a (11.9 psig).
The MSIV leakage rate must be verified to be in accordance with the leakage test requirements of Reference 3, as modified by approved exemptions. A Note is added to this SR which states that these valves are only required to meet this leakage limit in MODES 1, 2 and 3. In the other conditions, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required.
SR  3.6.1.3.9 Surveillance of hydrostatically tested lines provides assurance that the calculation *assumptions of Reference 2 is met.
This SR is modified by a Note that states these valves are only required to meet the combined leakage rate in MODES 1, 2, and 3 since this is when the Reactor Coolant System is (continued)
GRAND GULF                  B 3.6-25                     LBDeR 13043

LLS Valves B 3.6.1.6 BASES SURVEILLANCE SR   3.6.1.6.1  (continued)
REQUIREMENTS The STAGGERED TEST BASIS Frequency ensures that both solenoids for each LLS valve relief-mode actuator are alternatively tested. The Frequency of the required relief-mode actuator testing is based on the tests required by ASME' OM Part 1 (Ref. 3), as implemented by the Inservice Testing Program of Specification 5.5.6. The testing Frequency required by the Inservice Testing Program is based on operating experience and valve performance.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. (Reference 4)
SR   3.6.1.6.2 The LLS designed S/RVs are required to actuate automatically upon receipt of specific initiation signals.
A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the automatic LLS function operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.5.4 overlaps this SR to provide complete testing of the safety function.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation. This prevents a reactor pressure vessel pressure blowdown.
REFERENCES   1. GESSAR-II, Appendix 3B, Attachment A, Section 3BA.8.
: 2. UFSAR, Section 5.2.2.2.3.3.
: 3. ASME Code of Operation and Maintenance of Nuclear Power Plants, Part 1.
: 4. GNRI-96/00229, Amendment 130 to the Operating License.
GRAND GULF                    B 3.6-35                       LBDCR 13043

RHR Containment Spray System B 3.6.1.7 BASES SURVEILLANCE SR   3.6.1.7.1  (continued)
REQUIREMENTS A Note has been added to this SR that allows RHR containment spray subsystems to be considered OPERABLE during alignment to and operation in the RHR shutdown cooling mode when below the RHR cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable. At these low pressures and decay heat levels (the reactor is shut down in MODE 3), a reduced complement of subsystems should provide the required containment pressure mitigation function thereby allowing operation of an RHR shutdown cooling loop when necessary.
SR   3.6.1.7.2 Verifying each RHR pump develops a flow rate ~ 7450 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded below the required flow rate during the cycle. It is tested in the pool cooling mode to demonstrate pump OPERABILITY without spraying down equipment in primary containment. Flow is a normal test of centrifugal pump performance required by the ASME Code, Section XI (Ref. 2). This test confirms one point on the pump design curve and is indicative of overall performance.
Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.
SR   3.6.1.7.3 This SR verifies that each RHR containment spray subsystem automatic valve actuates to its correct position upon receipt of an actual or simulated automatic actuation signal. Actual spray initiation is not required to meet this SR. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.6 overlaps this SR to provide complete testing of the safety function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at (continued)
GRAND GULF                        B 3.6-39                LBDCR 13043

RHR Containment Spray System B 3.6.1.7 BASES SURVEILLANCE SR  3.6.1.7.3  (continued)
REQUIREMENTS the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 6.2.1.1.5.
: 2. ASME, Boiler and Pressure Vessel Code, Section XI.
GRAND GULF                        B 3.6-40               LBDCR 13043

MSIV LCS B 3.6.1.9 BASES ACTIONS        C.1 and C.2 (continued)
If the MSIV LCS subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE   SR  3.6.1.9.1 REQUIREMENTS Each outboard MSIV LCS blower is operated for 2 15 minutes to verify OPERABILITY. The 31 day Frequency was developed considering the known reliability of the LCS blower and controls, the two subsystem redundancy, and the low probability of a significant degradation of the MSIV LCS subsystem occurring between surveillances and has been shown to be acceptable through operating experience.
SR  3.6.1.9.2 Deleted SR  3.6.1.9.3 A system functional test is performed to ensure that the MSIV LCS will operate through its operating sequence. This includes verifying that the automatic positioning of the valves and the operation of each interlock and timer are correct, that the blowers start and develop the required flow rate and the necessary vacuum. The 24 month (continued)
GRAND GULF                     B 3.6-46                    LBDeR 13043

MSIV LCS B 3.6.1.9 BASES SURVEILLANCE SR  3.6.1.9.3   (continued)
REQUIREMENTS Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 6.7.1.
: 2. UFSAR, Section 15.6.5.
GRAND GULF                   B 3.6-47                     LBDCR 13043

SPMU System B 3.6.2.4 BASES SURVEILLANCE SR   3.6.2.4.4  (continued)
REQUIREMENTS the gates installed if the Suppression Pool Low Level limit is increased to 18 ft 5 1/12 inches.    (See Reference 3).
The 31 day Frequency is appropriate because the gates are moved under procedural control and only the infrequent movement of these gates is required in MODES 1, 2, and 3.
The provision to allow gate installation in MODES 1, 2, and 3 results in isolating a portion of the SPMU System dump volume. This provision does not apply to the separator pool weir wall extension gates. These gates are not readily accessible with the upper containment pool at its required level. Supporting analyses have shown that increasing the minimum suppression pool level adequately compensates for water trapped by isolating the fuel storage and/or fuel transfer canal areas.
SR   3.6.2.4.5 This SR requires a verification that each SPMU subsystem automatic valve actuates to its correct position on receipt of an actual or simulated automatic initiation signal.
This includes verification of the correct automatic positioning of the valves and of the operation of each interlock and timer. As noted, actual makeup to the suppression pool may be excluded. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.4.6 overlaps this SR to provide complete testing of the safety function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a NOTE that excludes makeup to the suppression pool. Since all active components are testable, makeup to the suppression pool is not required.
(continued)
GRAND GULF                    B 3.6-65                         LBDCR 13043

Primary Containment and Drywell Hydrogen Igniters B 3.6.3.2 BASES   (continued)
SURVEILLANCE        SR  3.6.3.2.1 and SR   3.6.3.2.2 REQUIREMENTS These SRs verify that there are no physical problems that could affect the igniter operation. Since the igniters are mechanically passive, they are not subject to mechan~cal failure. The only credible failures are loss of power or burnout. The verification that each required igniter is energized is performed by circuit current versus voltage measurement.
The Frequency of 184 days has been shown to be acceptable through operating experience because of the low failure occurrence, and provides assurance that hydrogen burn capability exists between the more rigorous 18 month Surveillances. Operating experience has shown these components usually pass the Surveillance when performed at a 184 day Frequency. Additionally, these surveillances must be performed every 92 days if four or more igniters in any division are inoperable. The 92 day Frequency was chosen, recognizing that the failure occurrence is higher than normal. Thus, decreasing the Frequency from 184 days to 92 days is a prudent measure, since only one more inoperable igniters (for a total of five) will result in an inoperable igniter division. SR 3.6.3.2.2 is modified by a Note that indicates that the Surveillance is not required to be performed until 92 days after four or more igniters in the division are discovered to be inoperable.
SR  3.6.3.2.3 and SR   3.6.3.2.4 These functional tests are performed every 18 months to verify system OPERABILITY. The current draw to develop a surface temperature of $ 1700EF is verified for igniters in inaccessible areas, e.g., in a high radiation area.
Additionally, the surface temperature of each accessible igniter is measured to be $ 1700EF to demonstrate that a temperature sufficient for ignition is achieved. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
GRAND GULF                            B 3.6-76                       LBDCR 13043

Drywell Purge System B 3.6.3.3 BASES SURVEILLANCE SR   3.6.3.3.2  (continued)
REQUIREMENTS that all associated controls are functioning properly. It also ensures that blockage, compressor failure, or excessive vibration can be detected for corrective action.
The 92 day Frequency is consistent with Inservice Testing Program Frequencies, operating experience, the known reliability of the compressor and controls, and the two redundant subsystems available.
SR   3.6.3.3.3 Operating each drywell purge subsystem for ~ 15 minutes and verifying that each drywell purge subsystem flow rate is
             > 1000 scfm ensures that each subsystem is capable of maintaining drywell hydrogen concentrations below the flammability limit. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage when the drywell boundary is not required. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR   3.6.3.3.4 This SR verifies that the pressure differential required to open the vacuum breakers is ~ 1.0 psid ,and that the isolation valve differential pressure actuation instrumentation opens the valve at 0.0 to 1.0 psid (drywell minus containment). This SR includes a CHANNEL CALIBRATION of the isolation valve differential pressure actuation instrumentation. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. Regulatory Guide 1.7, Revision 1.
: 2. UFSAR, Section 6.2.5.
: 3. Technical Specification Amendment 145 to GGNS Operating License.
GRAND GULF                      B 3.6-82                  LBDeR 13043

Secondary Containment B 3.6.4.1 BASES SURVEILLANCE SR 3.6.4.1.3 and SR 3.6.4.1.4   (continued)
REQUIREMENTS these SRs is to ensure that the SGT subsystem, being used for the test, functions as designed. There is a separate LCO 3.6.4.3 with Surveillance Requirements which serves the primary purpose of ensuring OPERABILITY of the SGT system.
SRs 3.6.4.1.3 and 3.6.4.1.4 need not be performed with each SGT subsystem. The SGT subsystem used for these Surveillances is staggered to ensure that in addition to the requirements of LCO 3.6.4.3, either SGT subsystem will perform this test. The inoperability of the SGT system does not necessarily constitute a failure of these Surveillances relative to the secondary containment OPERABILITY. Operating experience has shown the secondary containment boundary usually passes these Surveillances when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 15.6.5.
: 2. UFSAR, Section 15.7.4.
GRAND GULF                   B 3.6-87a                        LBDCR 13043

SCIVs B 3.6.4.2 BASES SURVEILLANCE SR  3.6.4.2.1   (continued)
REQUIREMENTS relatively easy, the 31 day Frequency was chosen to provide added assurance that the SCIVs are in the correct positions.
Two Notes have been added to this SR. The first Note applies to valves, dampers, rupture disks, and blind flanges located in high radiation areas and allows them to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons.
Therefore, the probability of misalignment of these SCIVs, once they have been verified to be in the proper position, is low.
A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open.
SR  3.6.4.2.2 Verifying the isolation time of each power operated, automatic SCIV is within limits is required to demonstrate OPERABILITY. The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses. Generally, SCIVs must close within 120 seconds to support the functioning of the Standby Gas Treatment System. SCIVs may have analytical closure times based on a function other than secondary containment isolation, in which case the more restrictive time applies.
The Frequency of this SR is in accordance with the Inservice Testing Program.
SR  3.6.4.2.3 Verifying that each automatic SCIV closes on a secondary containment isolation signal is required to prevent leakage of radioactive material from secondary containment following a DBA or other accidents. This SR ensures that each automatic SCIV will actuate to the isolation position on a secondary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.6 overlaps this SR to provide complete testing of the safety function. The 24 month (continued)
GRAND GULF                     B 3.6-94                       LBDCR 13043

SCIVs B 3.6.4.2 BASES SURVEILLANCE SR  3.6.4.2.3  (continued)
REQUIREMENTS Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 15.6.5.
: 2. UFSAR, Section 6.2.3.
: 3. UFSAR, Section 15.7.4.
GRAND GULF                   B 3.6-95                        LBDCR 13043

SCIVs B 3.6.4.3 BASES SURVEILLANCE SR  3.6.4.3.3   (continued)
REQUIREMENTS The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.6 overlaps this SR to provide complete testing of the safety function.
While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. 10 CFR 50, Appendix A, GDC 41.
: 2. UFSAR, Section 6.5.3.
GRAND GULF                  B 3.6-101                    LBDCR 13043

Drywell Isolation Valve(s)
B 3.6.5.3 BASES SURVEILLANCE   SR  3.6.5.3.3 REQUIREMENTS (continued) Verifying that the isolation time of each power operated, automatic drywell isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.
SR  3.6.5.3.4 Verifying that each automatic drywell isolation valve closes on a drywell isolation signal is required to prevent bypass leakage from the drywell following a DBA. This SR ensures each automatic drywell isolation valve will actuate to its isolation position on a drywell isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.7 overlaps this SR to provide complete testing of the safety function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power, since isolation of penetrations would eliminate cooling water flow and disrupt the normal operation of many critical components. Operating experience has shown these components usually pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES     1. OFSAR, Section 6.2.4.
: 2. GNRI-96/00162, Issuance of Amendment No. 126 to Facility Operating License No. NPF Grand Gulf Nuclear Station, Unit 1 (TAC No. M94176), dated August 1, 1996.
GRAND GULF                    B 3.6-119                         LBDCR 13043

Drywell Vacuum Relief System B 3.6.5.6 BASES SURVEILLANCE SR   3.6.5.6.2  (continued)
REQUIREMENTS This Surveillance includes a CHANNEL FUNCTIONAL TEST of the isolation valve differential pressure actuation instrumentation. This provides assurance that the safety analysis assumptions are valid. The Frequency of this Surveillance is in accordance with Inservice Test Program.
SR   3.6.5.6.3 Verification of the opening pressure differential is necessary to ensure that the safety analysis assumption that the vacuum breaker or isolation valve will open fully at a differential pressure of 1.0 psid is valid. This SR verifies that the pressure differential required to open the vacuum breakers is ~ 1.0 psid and that the isolation valve differential pressure actuation instrumentation opens the valve at 0.0 to 1.0 psid for the drywell purge vacuum relief subsystem and -1.0 to 0.0 psid for the post-LOCA vacuum relief subsystems (drywell minus containment). This SR includes a CHANNEL CALIBRATION of the isolation valve differential pressure actuation instrumentation. This Surveillance includes a calibration of the position indication as necessary. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for violating the drywell boundary. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 6.2.
GRAND GULF                   B 3.6-130                     LBDCR 13043

SSW System and UHS B 3.7.1 BASES SURVEILLANCE SR  3.7.1.4  (continued)
REQUIREMENTS is demonstrated by use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the SSW pump and cooling tower fans in each subsystem. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function.
Operating experience has shown that these components usually pass the SR when performed on the 24 month Frequency.
Therefore, this Frequency is concluded to be acceptable from a reliability standpoint.
REFERENCES   1. Regulatory Guide 1.27, Revision 2, January 1976.
: 2. UFSAR, Section 9.2.1.
: 3. UFSAR, Table 9.2-3.
: 4. UFSAR, Section 6.2.1.1.3.3.
: 5. UFSAR, Chapter 15.
: 6. UFSAR, Section 6.2.2.3.
: 7. UFSAR, Table 6.2-2.
GRAND GULF                     B 3.7-7                         LBDCR 13043

HPCS SWS B 3.7.2 BASES SURVEILLANCE SR  3.7.2.1   (continued)
REQUIREMENTS those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
Isolation of the HPCS SWS to components or systems may render those components or systems inoperable, but may not affect the OPERABILITY of the HPCS SWS. As such, when all HPCS SWS pumps, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the HPCS SWS needs to be evaluated to determine if it ;s still OPERABLE.
The 31 day Frequency ;s based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
SR  3.7.2.2 This SR verifies that the automatic isolation valves of the HPCS SWS will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the HPCS SWS pump. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.5.1.6 overlaps this SR to provide complete testing of the safety function.
Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency.
Therefore, this Frequency is concluded to be acceptable from a reliability standpoint.
REFERENCES   1. UFSAR, Section 9.2.1.
: 2. UFSAR, Chapter 6.
: 3. UFSAR, Chapter 15.
GRAND GULF                     B 3.7-10                       LBDCR 13043

CRFA System B 3.7.3 BASES   (continued)
SURVEILLANCE        SR   3.7.3.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts from the control room on demand and continues to operate.
Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system. Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available.
SR   3.7.3.2 This SR verifies that the required CRFA testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, and minimum system flow rate. Specific test frequencies and additional information are discussed in detail in the VFTP.
SR   3.7.3.3 This SR verifies that each CRFA subsystem starts and operates and that the isolation valves close in # 4 seconds on an actual or simulated initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.1 overlaps this SR to provide complete testing of the safety function. While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR   3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.
(continued)
GRAND GULF                           B 3.7-16a                        LBDCR 13043 I

Control Room AC System B 3.7.4 BASES ACTIONS        E.1 (continued)
During OPDRVs if the Required Action and associated Completion Time of Condition B is not met, action must be taken to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.
If applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.
SURVEILLANCE   SR   3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analysis. The SR consists of a combination of testing and calculation. The 24 month Frequency is appropriate since significant degradation of the Control Room AC System is not expected over this time period.
REFERENCES     1. UFSAR, Section 6.4.
: 2. UFSAR, Section 9.4.1.
GRAND GULF                       B 3.7-21                        LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR   3.8.1.6  (continued)
REQUIREMENTS The design of the fuel transfer systems is such that pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tanks during or following DG testing. Therefore, a 31 day Frequency is specified to correspond to the maximum interval for DG testing.
SR   3.8.1.7 Under accident conditions, loads are sequentially connected to the bus by the load sequencing panel. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the bus power supplies due to high motor starting currents. The load sequencing ensures that sufficient time exists for the bus power supply to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.
This Surveillance is a manual test of the load shedding and sequencing panels and verifies the load shedding and sequencing panels respond within design criteria to the following test inputs: LOCA, bus undervoltage, bus undervoltage followed by LOCA, and LOCA followed by bus undervoltage.
The Frequency of 31 days is based on engineering judgment, taking into consideration plant conditions required to perform the Surveillance. Operating experience has shown that these components usually pass the SR when performed at the 31 day Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR   3.8.1.8 Transfer of each 4.16 kV ESF bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit. The 24 month Frequency of the Surveillance is based on engineering judgment taking into consideration the plant conditions required to perform the Surveillance, and is (continued)
GRAND GULF                        B 3.8-18               LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR  3.8.1.8   (continued)
REQUIREMENTS intended to be consistent with expected fuel cycle lengths.
Operating experience has shown that these components usually pass the SR when performed on the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
GRAND GULF                     B 3.8-18a                       LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR   3.8.1.9   (continued)
REQUIREMENTS
: 2)     tripping its associated single largest load with the DG solely supplying the bus.
If this load were to trip, it would result in the loss of the DG. As required by IEEE-308 (Ref. 13), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%
above synchronous speed, whichever is lower. For the Grand Gulf Nuclear Station the lower value results from the first criteria.
The 24 month Frequency is consistent with the recommendation of Regulatory Guide 1.9 (Ref. 3).
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
This SR has been modified by two Notes. Note 1 states; Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)     Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)     Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible.
When synchronized with offsite power, testing should be performed at a power factor of ~ 0.9 for DG 11 and DG 13 and ~ 0.89 for DG 12. These power factors are representative of the actual inductive loading the DGs would see under design (continued)
GRAND GULF                      B 3.8-20                        LBDCR 13043

AC Sou rces - Operati ng B 3.8.1 BASES SURVEILLANCE SR   3.8.1.10   (continued)
REQUIREMENTS The 24 month Frequency is consistent with the recommendation of Regulatory Guide 1.9 (Ref. 3) and is intended to be consistent with expected fuel cycle lengths.
Testing performed for this SR is normally conducted with the DC being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
This SR has been modified by a two Notes. Note 1 states that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)     Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)     Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible.
When synchronized with offsite power, testing should be performed at a power factor of ~ 0.9 for DG 11 and DG 13 and ~ 0.89 for DG 12. These power factors are representative of the actual inductive loading the DGs would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the surveillance to be conducted at a power factor above the limit. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to within the limits results in voltages on the emergency busses that are too high. Under these conditions, the power factor should be maintained as close as practicable to the limit while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage (continued)
GRAND GULF                      B 3.8-22                         LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR  3.8.1.11   (continued)
REQUIREMENTS The Frequency of 24 months is  consistent with the recommendations of Regulatory  Guide 1.9 (Ref. 3) takes into consideration unit conditions  required to perform the Surveillance, and is intended  to be consistent with expected fuel cycle lengths.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations for DG 11 and DG 12. For DG 13, standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through'a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation. Note 2 is not applicable to DG 13.
The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems. Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)     Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with- maintenance required to maintain OPERABILITY or reliability.
(continued)
GRAND GULF                     B 3.8-23                         LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE   SR   3.8.1.12 REQUIREMENTS (continued) This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for ~ 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d ensures that emergency loads are energized from the offsite electrical power system on an ECCS signal without loss of offsite power.
The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the loading logic for loading onto offsite power. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.
In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the offsite power system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
Testing performed for this SR is normally conducted with the DC being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
(continued)
GRAND GULF                      B 3.8-24                         LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR   3.8.1.13  (continued)
REQUIREMENTS minor problems that are not immediately detrimental to emergency operation of the DG.
The 24 month Frequency is based on engineering judgment, taking into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
(continued)
GRAND GULF                    B 3.8-25a                        LBDCR 13043

AC Sou rces - Operati ng B 3.8.1 BASES SURVEILLANCE SR   3.8.1.14   (continued)
REQUIREMENTS
             ~  0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience. During the test the generator voltage and frequency is 4160 +/- 416 volts and ~ 58.8 Hz and ~ 63 Hz within 10 seconds after the start signal and the steady state generator voltage and frequency is maintained within 4160 +/- 416 volts and 60 +/- 1.2 Hz for the duration of the test.
The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3) takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. The DG 11 and 12 load band is provided to avoid routine overloading of the TDI DG.
Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 2 stipulates that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)     Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)     Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible.
When synchronized with offsite power, testing should be performed at a power factor of ~ 0.9 for DG 11 and DG 13 and ~ 0.89 for DG 12. These power factors are representative of (continued)
GRAND GULF                   B 3.8-27                        LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR   3.8.1.15  (continued)
REQUIREMENTS and frequency within 10 seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA.
The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3).
This SR has been modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The requirement that the diesel has operated for at least 1 hour at full load conditions or until operating temperatures stabilized prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. The DG 11 and 12 load band is provided to avoid routine overloading of the TDI DG.
Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts *to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.
SR  3.8.1.16 As required by Regulatory Guide 1.9 (Ref. 3) this Surveillance ensures that the manual synchronization and load transfer from the DC to each required offsite source can be made and that the DG can be returned to ready-to-load status when offsite power is restored. It also ensures that the undervoltage logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs.
The DG is considered to be in ready-to-load status when the DG is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus undervoltage, and the load sequence logic is reset.
The Frequency of 24 months is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3) and takes into consideration plant conditions required to perform the Surveillance.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related (continued)
*GRAND GULF                 B 3.8-28                          LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR  3.8.1.17   (continued)
REQUIREMENTS The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3) takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related systems are aligned to another offsite source. This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)     Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)     Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
SR  3.8.1.18 Under accident conditions, loads are sequentially connected to the bus by the load sequencing panel. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the bus power supplies due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the bus power supplies to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provide~ a summary of the automatic loading of ESF buses.
(continued)
GRAND GULF                     B 3.8-30                         LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR  3.8.1.18  (continued)
REQUIREMENTS The Frequency of 24 months is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3) takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
(continued)
GRAND GULF                    8 3.8-30a                        LBDCR 13043

AC Sources - Operati ng B 3.8.1 BASES SURVEILLANCE SR   3.8.1.18   (continued)
REQUIREMENTS This SR is modified by a Note. The reason for the Note ;s that performing the Surveillance during these MODES would challenge plant safety systems. Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)     Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate'documentation of the required performance is available; and
: 2)     Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
SR   3.8.1.19 In the  event of a DBA coincident with a loss of offsite power,  the DGs are required to supply the necessary power to ESF  systems so that the fuel, RCS, and containment design  limits are not exceeded.
This Surveillance demonstrates the DG operation, as discussed in the Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. For the purposes of this Surveillance the DG 13 autoconnected emergency loads are verified to be energized in s 20 seconds. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of 24 months.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related (continued)
GRAND GULF                      B 3.8-31                        LBDCR 13043

DC Sou rces - Operati ng B 3.8.4 BASES SURVEILLANCE SR  3.8.4.3   (continued)
REQUIREMENTS The 24 month Frequency of the Surveillance is based on engineering judgement, taking into consideration the desired unit conditions to perform the Surveillance.
Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
GRAND GULF                    B 3.8-56a                         LBDCR 13043

DC Sou rces - Operati ng B 3.8.4 BASES SURVEILLANCE   SR   3.8.4.4 and SR  3.8.4.5 REQUIREMENTS (continued) Visual inspection and resistance measurements of inter-cell, inter-rack, inter-tier, and terminal connections provides an indication of physical damage or abnormal deterioration that could indicate degraded battery condition. The anti-corrosion material is used to ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection.
The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR, provided visible corrosion is removed during performance of this Surveillance. For the purposes of this SR oxidation is not considered corrosion provided the resistance of the connection(s) is within limits.
The 24 month Frequency of the Surveillance is based on engineering judgement, taking into consideration the desired unit conditions to perform the Surveillance.
Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR   3.8.4.6 Battery charger capability requirements are based on the design capacity of the chargers (Ref. 4). According to Regulatory Guide 1.32 (Ref. 9), the battery charger supply is required to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensure that these requirements can be satisfied.
The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.
(continued)
GRAND GULF                    B 3.8-57                            LBDCR 13043

DC Sou rces - Operati ng B 3.8.4 BASES SURVEILLANCE   SR  3.8.4.7 REQUIREMENTS (continued) A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system.
The discharge rate and test length (4 hours for Division 1 and Division 2 and 2 hours for Division 3) correspond to the design duty cycle requirements as specified in Reference 4.
The Surveillance Frequency of 24 months is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 (Ref. 10), which state that the battery service test should be performed during refueling operations or at some other outage, with intervals between tests not to exceed 24 months.
This SR is modified by two Notes. Note 1 allows the once per 60 months performance of SR 3.8.4.8 in lieu of SR 3.8.4.7. This substitution is acceptable because SR 3.8.4.8 represents a more severe test of battery capacity than SR 3.8.4.7. The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. The Division 3 test may be performed in MODE 1, 2, or 3 in conjunction with HPCS system outages. Credit may be taken for unplanned events that satisfy the Surveillance.
SR  3.8.4.8 A battery performance test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test.
The test is intended to determine overall battery degradation due to age and usage.
The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 8) and IEEE-485 (Ref. 11). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.
(continued)
GRAND GULF                      B 3.8-58                           LBDCR 13043  I}}