ML20077D744

Safety Evaluation Supporting Amend 77 to License NPF-29

ML20077D744
Person / Time
Site:	Grand Gulf
Issue date:	05/21/1991
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20077D742	List: ML20077D735 ML20077D744
References
NUDOCS 9106050011
Download: ML20077D744 (3)

Text

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BFETYEVALUATIONBYTHEOFFICEOFNUCLEARREACTORREGULATION RELATED TO AMENDMENT NO. 77 TO FACILITY OPERATING LICENSE NO.-NPF-29 ENTERGY OPERATIONS. INC.. ET AL.

GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416 l

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1.0 INTRODUCTION

I By letter dated March 15, 1991,- EntergyOperations,Inc..(thelicensee).-

submitted a request for changes to the Grand Gulf Nuclear. Station Unit.1, l

Technical Specifications (TS),

Guidance on.this proposed change to TS wcs provided to all power reactor licensees and ap)1icants by Generic Letter 89-14, dated August 21, 1989. The requested c1anges'would modify TS 4.0.2 by:

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Deleting the 3.25 limitation on extending three successive surveillance intervals; 1

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Utilizing the exact, suggested wording of Generic Letter 89-14 in Specification 4.0.2 for the 25-percent allowance for individual l

surveillance. intervals;-and, 4

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Incorporating the Generic Letter 89-14 wording'in the-Bases for i

Specificetion-4.0.2.

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2.0 EVALUATION SpecificationL4.0.2 includes the provision that allows a surveillance interval y

to-be extended by 25-percent of the:specified time interval.

This extension l'

provides flexibility for. scheduling the performance of surveillances and permits consideration of phnt operating conditions that mey not be suitable for conducting a surveillance during the.specified tinte interval.- Such operat-i ing.conoitions includeltransient plant operation or_ ongoing' surveillance or-maintenance activities.. Specification 4.0.2 further limits the ellowance for extending surveillance ' intervals by requiring that the combined time: interval-for any three consecutive surveillances not exceed-3.25 times the specified time intervel..

The purpose of'this'provisionLis to assure that the'surveill -

ances are'.not extended repeatedly as an operetional convenience.to provide a 4

overall increase in the-surveillance interval, p

i Experience has shown.that the'18-month _. surveillance interval, with the provision-3 to extena it by 25-percent, is'usyally' sufficient to accommodate normal'varia-tions in.the length of a fuel cycle. However, the NRC: staff has routinely

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grented' requests for one-time exceptions to,the 3.25 limit on extending-j 9106050011 910521 ADOCK0500g6 L -

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1 refueling surveillances because the risk to safety is low in contrast to the alternative of a forced shutdown to perform these surveillances.

Therefore, i

the 3.25 limitation on extending surveillance intervals has not been a practical 1

limit on the use of the 25 percent allowance for extending surveillances that are performed on a refueling outage basis.

I Extending surveillance intervals during plant operation can also result in a i

benefit to safety when a scheduled surveillance is due at a time that is not I

suitable for conducting the surveillance.

This may occur when transient plant operating conditions exist or when safety systems are out of service for maintenance or other surveillance activities.

In such cases, the benefit to safety of extending a surveillance interval would exceed any safety benefit derived by lim' ting the use of the 25-percent allowance to extend a surveillance

interval, furthermort, there is the administrative burden associated with tracking the use o' the 25-percent allowance to ensure compliance with the j

3.25 limit.

l In view of these findir.,,s, the staff cont aded that Specification 4.0.2 should be changed to remove the 3.25 limit for all surveill6r;c-i because its removal will have an overall positive ef4 ct on safe +v.

Le guidance provided in d

Generic Letter 89-14 included the follo + g change to this specification and reioves the 3.25 limit on three crasecutive surveill nces with the following l

statement:

• 4.0.2 Each Surveillance Requ ei.a:r,t ri. l', be performed within the specified surveillance inter >,1 with A maximum allowable extension not to exceed 25 percent of the specified surveillance interval."

In addition, the Bases for this specification were changed to reflect this TS L

change and to note that it is not intended that the allowance for extending surveillance intervals be used repeatedly merely as an operational convenience to extend surveillance intervals beyond that specified.

The licensee has proposed changes to Specification 4.0.2 that are consistent with the guidance provided in Generic Letter 89-14, as noted above. On the-l basis of its review of this matter, the staff finds that the above changes to the TS for Grand Gulf Nuclear Station, Unit 1 are acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Mississippi State official was notified of the proposed issuance of the amendment. The State official had 3

no coments.

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4.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within'the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no r

l significant change in the types of any effluents that may be released offsite, and that there is no significant.ncrease in individual or cumulative occupational l

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i radiatiun exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has beec. no public comment on such finding (56 FR 15641). Accordingly, the amer.Jment meets the eligibility criteria for categorical extivsion set forth s

I in10CFR51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact i

statement or environmental assessment need be prepared in connection with the j

issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, 1-that:

(1) there is reasonable assurance that the health and safety of the j

public will not te endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, i

and (3) the issuance of the amendment will not be inimical to the common l

defense and security or to the health and safety of the public.

l Principal Contributors: Thomas G. Dunning Ricky Twigg Date:

May 21, 1991 i

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