ML20206R927

Application for Amends to Licenses NPF-29 & NPF-47,proposing Required Actions Consistent with NRC Accepted Change to BWR Improved TS NUREG-1433 & NUREG-1434

ML20206R927
Person / Time
Site:	Grand Gulf, River Bend
Issue date:	01/12/1999
From:	Kansler M ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206R932	List: ML20206R927 ML20206R935
References
RTR-NUREG-1433, RTR-NUREG-1434 CNRO-99-00003, CNRO-99-3, NUDOCS 9901210334
Download: ML20206R927 (13)

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! a 6 Entergy operations. inc.

- - - . - {h PO Bon 31995 Jackson. MS 39280 1995 Tel 601368 5760 Michael R. Kansler V C f P*t Vlt nl operanonssuppon January 12,1999 U.S. Nuclear Regulatory C'mmission I

. Mail Station P1-37 Washington, D.C. 20555 ATTENTION: Document Control Desk l

SUBJECT:

. Grand Gulf Nuclear Station and River Bend Station Docket No. 50-416 and 50-458 i License No. NPF-29 and NPF-47 )

Technical Specification Refueling Equipment interlocks' Required Actions l Proposed Amendment to the Operating License l

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REFERENCE:

1. GNRO-96/OOO62 and RBG-42764, Technical Specification Refueling Equipment Interlocks' Required Actions Proposed Amendment to the  ;

Operating License, dated May 31,1996. l

2. GNRO-96/OO112, Technical Specification Refueling Equipment Interlocks' ,

Required Actions Proposed Amendment to the Operating License  !

Additional Information, dated September 30,1996.

3. Letter from William D. Beckner, Chief Technical Specifications Branch, Office of Nuclear Reactor Regulation, to James Davis, Nuclear Energy  ;

Institute, dated May 19,1998.  ;

CNRO-99/00003 i

Gentlemen:

Entergy Operations, Inc. (EOl)is submitting by this letter a revision to a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License and a proposed amendment to the River Bend Station (RBS) Operating License. The original request was submitted by Reference 1 with additional information provided by Reference 2. This revision to the proposed change is provided to make the proposed Required Actions consistent with the NRC accepted change to the BWR improved Technical Specification NUREGs 1433 and 1434. The proposed generic change to the NUREGs was submitted to the NRC by the NEl Technical Specifications Task Force as change request TSTF-225. The NRC Technical Specifications branch indicated their acceptance of the proposed generic change in a meeting with the NEl Technical Specifications Task Force on April 22,1998 (Reference 3). The associated Bases are also being modified consistent with TSTF-225 and modified to reflect plant specific needs as allowed by the generic change conversion guidelines. ,

9901210334 990112 CO \ i PDR ADOCK 05000416'.

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.. l l0 Technical specification Refueling Equipment Interlocks' Required Action Proposed Amendment to the Operating License I

Janruary 12,1999 CNRO-99/00003 Page 2 of 3 The proposed change adds additional acceptable Required Actions to Technical Specification Limiting Condition for Operation (LCO) 3.9.1," Refueling Equipment Interlocks." The additional Required Actions provide an attemate method to compensate for inoperable refueling interlocks instead of halting fuel movement. The addition of these Required Actions will allow a reduction in refueling critical path time. The proposed change provides the same level of safety as the curretit requirements.

Attachment 2 provides a detailed description of the proposed changes, justification, and the No Significant Hazards Considerations. Attachment 3 is a copy of the marked-up TS pages for GGNS and Attachment 4 is a copy of the marked-up TS pages for RBS.

Based on the guidelines in 10 CFR 50.92, Entergy Operations has concluded that this proposed  ;

amendment involves no significant hazards considerations. Attachment 2 details the basis for this determination.

Yours truly, 1

l JB/BSF/baa attachments: 1. Affirmation per 10 CFR 50.30 (3 pages)

2. Discussion and Justification (7 pages)

3. Mark-up of Affected Technical Specifications and Bases for GGNS (5 pages)

4. Mark-up of Affected Technical Specifications and Bases for RBS (5 pages) cc: (See Next Page) a l

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T . Technical Speicification Refueling Equipment interlocks' Required Action

Proposed Amendment to the Operating License

, January 12,1999 CNRO-99/00003

. Page 3 of 3 i pe q L i

cc: Mr. J. L. Blount '!

i L Mr. C. M. Dugger .

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Mr. W. A. Eaton  !

. Mr. R. K. Edington  !

Mr. C. R. Hutchinson t c

Mr. J. R. McGaha

~ Mr.' N. S. Reynolds Mr. L. J. Smith

l. Mr. H. L. Thomas Mr. George F. Dick, Jr. Mr. George D. Replogie U. S. Nuclear Regulatory Commission NRC Resident inspector l Mail Stop 13-D-1 - P.O. Box 1051 l Washington, D.C. 20555. St. Francisville, LA 70775 j Ms. Jennifer Dixon-Nemty Dr. Eddie F. Thompson p f NRC Senior Resident inspector State Health Officer i Grand Gulf Nuclear Station State Board of Health Route 2, Box 399 P.O. Box 1700 Port Gibson, MS 39150 Jackson, Mississippi 39205 i

L Mr. J. D. Donohew. Project Manager Department of Environmental Quality I l Office of Nuclear Reactor Regulation Radiation Protection Division . i

[- U.S. Nuclear Regulatory Commission P.O. Box 82135  ;

Mail Stop 13-H-3 Baton Rouge, LA 70884-2135 i Washington, D.C. 20555 . ATTN: Administrator ,

t Mr. R. J. Fretz U.S. Nuclear Regulatory Commission >

L U. S. Nuclear Regulatory Commission Region IV Mail Stop OWFN/13-H-3 611 Ryan Plaza Drive, Suite 400 Washington, DC 20555 Arlington, TX 76011 L

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! Attachment 1 Affirmation per 10 CFR 50.30 l

Grand Gulf Nuclear Station and  ;

l River Bend Station

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BEFORE THE l l UNITED STATES NUCLEAR REGUl.ATORY COMMISSION >

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LICENSE NO. NPF-29 DOCKET NO. 50416 IN THE MATTER OF  ;

l, ENTERGY MISSISSIPPI, INC.

and '

L SYSTEM ENERGY RESOURCES, INC.

and i i: SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION i l and  !

ENTERGY OPERATIONS, INC. j i

! AFFIRMATION L

I I, W. A. Eaton, being duly swom, state that I am Vice President, Opershons Grand Gulf Nuclear 1, - Station, of Entergy Operations, Inc.; that on behalf of Entergy Operabons, Inc., System Energy ..

I Resources, Inc., and South Mississippi Electric Power Associaton I am authonzed by Entergy )

l Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this apphcotion; that I signed l l this applicabon as the Vice President, Operabons Grand Gulf Nuclear Staten, of Entergy Operations, )

l. - Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my kr-;;f: f-;+, information and behef.

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W. A. Eatod i STATE OF MISSISSIPPI COUNTY OF CLAIBORNE

, SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State above l named, this 27 d day of AM/u . 1998.

i-i (SEAL) bd!ud A Y Notary Public l

I My commission expires:

i GNSSSStPPI STAT!6TE NOTA?.1 XP' .!C MY C0tiMISSON EXPlRIS DCT. 27 2000 BONDED THRU STEGALL NOTARY SlRVICE L  ;

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i i BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION (

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l- LICENSE NO. NPF-47

! DOCKET NO. 50-458 1

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IN THE MA' ITER OF i

ENTERGY GULF STATES INC.

ENTERGY OPERATIONS, INC.

AFFIRMATION

1. Randall K. Edington, state that I am Vice President-Operations of Eneergy Operations, Inc., at River Bend Station; i that on behalf of Entergy Operations, Inc., I am authorized by Einergy Operations, Inc. to sign and file with the Nuclear l l Regulatory Commission, this License Amemhnent Request, that the statemems made and the matters set forth therein are  !

L true asyl correct to the best of my knowledge, information, and belief. l 1

e Randall K. Edington l

1 STATE OF LOUISIANA WEST FELICIANA PARISH 1

l SUBSCRIBED AND SWORN TO before me, Notary Public, in and for the Parish azul State alxwe named, this  ;

l XA- day of . ,

/999.

F 00nndEA/kuot Claudia F. Hurst i

I Notary Public l

My Commbsion expires with life.

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4 CNRO-99/00003 Attachment 2 page 1 of 7 1

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Attachment 2 Discussion and Justification Grand Gulf Nuclear Station i and River Bend Station l

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< CNRo-99/00003 Attachment 2 page 2 of 7 A. AFFECTED TECHNICAL SPECIFICATIONS The following Technical Specifications are affected by the proposed change.

Limiting Condition for Operation (LCO) 3.9.1 Refueling Equipment Interlocks The proposed Technical Specifications and the associated Technical Specification Bases changes to be implemented following NRC approval of the proposed Technical Specification changes are detailed in Attachment 3 for Grand Gulf Nuclear Station (GGNS) and A.ttachment 4 for River Bend Station (RBS).

B. BACKGROUND The refueling equipment interlocks restrict the operation of the refueling equipment or the withdrawal of control rods to reinforce unit procedures in preventing the reactor from achieving criticality during refueling. The refueling interlock circuitry senses the conditions of the refueling equipment and the control rods. Depending on the sensed conditions, interlocks are actuated to prevent the operation of the refueling equipment or the withdrawal of control rods.

Two channels of instrumentation are provided. The following provide input to one or both channels: the position of the refueling platform, the loading of the refueling platform main hoist, and the full insertion of all control rods. With the reactor mode switch in the shutdown or refueling position, the indicated conditions are combined in logic circuits to determine if all restrictions on refueling equipment operations and control rod insertion are satisfied.

A control rod not at its full-in position interrupts power to the refueling equipment and prevents operating the equipment over the reactor core when loaded with a fuel assembly. Conversely, the refueling equipment located over the core and loaded with fuel inserts a control rod withdrawal block to prevent withdrawing a control rod.

The refueling platform has two mechanical switches that open before the platform and the fuel grapple are physically located over the reactor vessel. The main hoist has two switches that open when the hoist is loaded with fuel. The refueling interlocks use these indications to prevent operation of the refueling equipment with fuel loaded over the core whenever any control rod is withdrawn, or to prevent control rod withdrawal whenever fuel loaded refueling equipment is over the core. The hoist switches open at a load lighter than the weight of a single fuel assembly in water.

The refueling platform location switches activate at a point outside of the reactor core, such that, considering switch hysteresis and maximum platform momentum toward the l

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CNRo-99/00003 Attachment 2 page 3 of 7 l

core at the time of power loss with a fuel assembly loaded and a control rod withdrawn, the fuel is not over the core.

The refueling interlocks are explicitly assumed in the GGNS Updated Final Safety Analyses Report (UFSAR) and RBS Updated Safety Analyses Report (USAR) analysis of the control rod removal error or fuelloading error during refueling. This analysis evaluates the consequences of control rod withdrawal during refueling. A prompt reactivity excursion during refueling could potentially result in fuel failure with subsequent release of radioactive material to the environment.

Criticality and, therefore, subsequent prompt reactivity excursions are prevented during the insertion of fuel, provided all control rods are fully inserted during the fuel insertion.

The refueling interlocks accomplish this by preventing loading fuel into the core with any control rod withdrawn, or by preventing withdrawal of a rod from the core during fuel loading.

Refueling equipment interlocks satisfy Criterion 3 of the NRC Technical Specification Policy Statement.

C. CURRENT TECHNICAL SPECIFICATION REQUIREMENTS To prevent criticality during refueling, the refueling interlocks are required to ensure that fuel assemblies are not loaded with any control rod withdrawn (LCO 3.10.6," Multiple Control Rod Withdrawal - Refueling," provides an exception to this and enforces additional controls as a result). To prevent these conditions from developing, the all-rods-in, the refueling platform position, and the refueling platform main hoist fuel loaded inputs are required to be OPERABLE.

With one or more of the required refueling equipment interlocks inoperable, the unit is required to be placed in a condition in which the LCO does not apply. Currently LCO 3.9.1 Required Action A.1 requires that in-vessel fuel movement with the affected refueling equipment be immediately suspended. This action ensures that operations are not performed with equipment that would potentially not be blocked from unacceptable operations (e.g., loading fuel into a cell with a control rod withdrawn). Suspension of in-vessel fuel movement shall not preclude completion of movement of a component to a safe position.

i l In addition to the LCO 3.9.1 requirements, LCO 3.9.3," Control Rod Position Indication,"

l requires that all control rods be verified to be fully inserted when loading fuel into the core (LCO 3.10.6 provides an exception to this and enforces additional controls as a l

I result). With one or more of the control rods not fully inserted LCO 3.9.3 Required Action A.1 requires that loading of fuel assemblies be immediately suspended.

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i CNRo-99/00003 ,

Attachment 2 page 4 of 7

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l D. PROPOSED TECHNICAL SPECIFICATION CHANGE l The proposed change adds additional acceptable Required Actions to the Actions of LCO 3.9.1. The additional Required Actions will add an aitemative to suspending fuel movement in the reactor vessel when the refueling interlocks are inoperable. The I requested attemative is to block control rod withdrawal immediately and to perform an additional verification that all of the control rods required to be inserted are fully inserted.

E. JUSTIFICATION I As discussed in the Technical Specificat;on Bases for the current Required Action, the purpose of the current requirement is to ensure that operations are not performed with equipment that would potentially not be blocked from unacceptable operations (e.g.,

loading fuel into a cell with a control rod withdrawn). The method that the refueling equipment interlocks perform their function whenever fuel is being moved in the reactor vessel is to block control rod withdrawal. Conversely, when a control rod is withdrawn (except as allowed by LCO 3.10.6) the refueling interlocks prevent fuel from being moved in the vessel. The proposed change will allow the refueling interiocks to be inoperable and fuel movement to continue if a control rod withdrawal block is in effect and all required control rods are verified to be fully inserted thereby ensuring that fuel loading will not occur with a control rod inappropriately withdrawn.

The first refueling equipment interlock safety function is to block control rod withdrawal whenever fuelis being moved in the reactor vessel. The proposed attemative Required Actions will perform this function by requiring that a control rod block be placed in effect.

The second refueling equipment interlock safety function is to prevent fuel from being loaded into the vessel when a control rod is withdrawn. This function will continue to be performed by the proposed requirements. LCO 3.9.1 Required Action A.2.1 will require that a control rod block be placed in effect thereby ensuring that control rods are not subsequently inappropriately withdrawn. Following placing the control rod withdrawal block in effect, Required Action A.2.2 wil! require that all control rods be verified to be fully inserted in core cells containing one or more fuel assemblies. This verification is in addition to the requirements to periodically verify control rod position in Surveillance Requirement (SR) 3.9.3.1 and SR 3.10.6.2. These proposed requirements will ensure that control rodc are not withdrawn and cannot be inappropriately withdrawn because an electrical or hydraulic block to control rod withdrawal is in place. Like LCO 3.9.1 Required Action A.1 this will ensure that unacceptable operations are blocked (e.g.,

loading fuelinto a cell with a control rod withdrawn).

As discussed previously, proposed LCO 3.9.1 Required Action A.2.2 will require that all control rods be verified to be fully inserted in core cells containing one or more fuel assemblies. This proposed Required Action does not include control rods associated with defueled cells but works in conjunction with the requirements of LCO 3.9.3 to allow refueling activities to continue with control rods withdrawn from defueled cells in

CNRo 99/00003 Attachment 2 page 5 of 7 accordance with LCO 3.10.6. These requirements are not a relaxation from the current refueling equipment interiock OPERABILITY requirements, since LCO 3.10.6 currently allows the control rod position inputs to the refueling equipment interlocks be bypassed and fuel movement to continue. The current allowance of LCO 3.10.6 is justified by the associated LCO 3.10.6 requirement that the fuel assembles associated with the withdrawn control rod be removed from the core and the LCO 3.10.6 restrictions on fuel loading. The requested change does not affect the suitability of the LCO 3.10.6 controls.

(Note: Modification of the LCO 3.10.6 requirements has been proposed by separate submittal. The LCO 3.10.6 changes proposed do not affect the changes requested by this submittal nor do the changes to LCO 3.10.6 affect the justification for this submittal.)

F. SAVINGS ASSOCIATED WITH THE REQUESTED CHANGE As discussed previously, when the refueling equipment interlocks are inoperable in-vessel fuel movement is currently required to be suspended. Therefore, due to equipment inoperability or to perform Technical Specification SR 3.9.1.1, in-vessel fuel movement is suspended during the outage to meet the current Technical Specification requirements. This results in approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of extension in refueling operations every outage. The requested change will allow a control rod withdrawal block to be inserted and the required control rods verified to be inserted instead of suspending fuel movement if refueling equipment interlocks are inoperable removing this extension in the time required for refueling activities.

As a result, the proposed change provides a savings of approximately $125,000 per outage in reduced critical path time resulting.

l G. NO SIGNIFICANT HAZARDS CONSIDERATION Entergy Operations, Inc. proposes to change the current Grand Gulf Nuclear Station (GGNS) and River Bend Station (RBS) Technical Specifications. The specific proposed change adds additional acceptable Required Actions to the Actions of LCO 3.9.1,

" Refueling Equipment Interlocks". The additional Required Actions will add an alternative to suspending fuel movement in the reactor vessel when the refueling interlocks are inoperable. The requested altemative is to insert a control rod withdrawal block immediately and verify all control rods required to be inserted are fully inserted.

The Commission has provided standards for determining whether a no significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license involves no significant hazards consideration if operation of the i facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)invc!ve a significant reduction in a margin of safety.

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CNRo-99/00003 Attachment 2 page 6 of 7

( Entergy Operations, Inc. has evaluated the no significant hazards consideration in its request for this license amendment and determined that no significant hazards '

l consideration results from this change. In accordance with 10 CFR 50.91(a), Entergy i Operations, Inc. is providing the analysis of the proposed amendment against the three j standards in 10 CFR 50.92(c). A description of the no significant hazards consideration determination follows:

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1. The proposed change does not significantly increase the probability or consequences of an accident previously evaluated.

The refueling interlocks are explicitly assumed in the GGNS Updated Final Safety Analyses Report (UFSAR) and RBS Updated Safety Analyses Report (USAR)

! analysis of the control rod removal error or fuel loading error during refueling.

This analysis evaluates the probability and consequences of control rod withdrawal during refueling. Criticality and, therefore, subsequent prompt re' activity excursions are prevented during the insertion of fuel, provided all-required control rods are fully inserted during the fuel insertion. The refueling interlocks accomplish this by preventing loading fuel into the core with any control rod withdrawn, or by preventing withdrawal of a rod from the core during fuel loading.

When the refueling interlocks are inoperable the current method of preventing the insertion of fuel when a control rod is withdrawn is to prevent fuel movement.

This method is currently required by the Technical Specifications. An altemate j method to ensure that fuel is not loaded into a cell with the control rod withdrawn i is to prevent control rods from being withdrawn and verify that all control rods required to be inserted are fully inserted The proposed actions will require that a control rod block be placed in effect thereby ensuring that control rods are not subsequently inappropriately withdrawn. Additionally, following placing the control rod withdrawal block in effect, the proposed actions will require that all required control rods be verified to be fully inserted. This verification is in addition to the requirements to periodically verify control rod position by other Technical Specification requirements. These proposed actions will ensure that control rods are not withdrawn and cannot be inappropriately withdrawn because an electrical or hydraulic block to control rod withdrawalis in place. Like the current requirements the proposed actions will ensure that unacceptable operations are blocked (e.g., loading fuel into a cell with a control rod withdrawn except following the requirements of LCO 3.10.6,

• Multiple Control Rod Removal- Refueling,"

which is unaffected by this change).

The proposed additional acceptable Required Actions provide an equivalent level of assurance that fuel will not be loaded into a core cell with a control rod withdrawn as the current Required Action or the Technical Specification Surveillance Requirement. Therefore, the proposed change does not i

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CNRo-99/00003 Attachment 2 page 7 of 7

! . significantly increase the probability or consequences of an accident previously evaluated.

II. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The change in the Technical Specification requirements does not involve a change in plant design. The proposed requirements will continue to ensure that fuel is not loaded into the core when a control rod is withdrawn except following the requirements of LCO 3.10.6," Multiple Control Rod Removal- Refueling,"

which is unaffected by this change.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

111. The proposed change does not involve a significant reduction in a margin of safety.

' As discussed in the Bases for the affected Technical Specification requirements ,

inadvertent criticality is prevented during the insertion of fuel provided all required control rods are fully inserted during the fuel insertion. The refueling interlocks function to support the refueling procedures by preventing control rod withdrawal during fuel movement and the inadvertent loading of fuel when a control rod is withdrawn.

The proposed change will allow the refueling interlocks to be inoperable and fuel movement to continue only if a control rod withdrawal block is in effect and all ,

l required control rods are verified to be fully inserted. These proposed Required Actions provide an equivalent level of protection as the refueling interlocks by preversting a configuration which could lead to an inadvertent criticality event.

The refueling procedures will continue to be supported by the proposed required )

, actions because control rods cannot be withdrawn and as a result fuel cannot be  !

inadvertently loaded when a control rod is withdrawn except following the l requirements of LCO 3.10.6," Multiple Control Rod Removal- Refueling," which is j unaffected by this change.

Therefore, the proposed changes do not cause a significant reduction in the i margin of safety, i

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