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n : * $ 8(pm Mo f - u d Io UNITED STATES g T t )e g NUCLEAR REGULATORY COMMISSION 3 .' .t WASHINGTON, D. C. 20S55 ] %, November 15, 1989 , ' Docket No. 50-416 LICENSEE: System Energy Resources,-Inc. (SERI) FACILITY: Grand Gulf Nuclear Station, Unit 1 (GGhS-1) SUBJECT: SUMMARY OF SEPTEMBER 19, 1989 MEETING AND TRIP ' TO GGNS-1 t The NRC staff niet with the licensee at the GGNS-1 Site to discuss future ! licensing activities. On September 20 and 21, 1989, the NRC Project Manager ! discussed selected activities with the SERI licensing and engineering staff, . Enclosure 1 provides a list of participants in the meeting. Enclosure 2 is a , copy of the agenca for the meeting. The licensee provided adoitional information cn several activities as follows: i o Regarding followup on the loss of main condenser vacuum event and associated equipn:ent failures, General Electric Company is preparing a report on the failure of one control rod to fully insert. o Regarding the requirement for secondary containment integrity when handling loaos over spent fuel, the licensee plans to put curves of load allowable height versus weight in procedures and change the Technical Specifications (TS) regarding secondary containment integrity to specify the impact energy above which integrity will be requireo. The licensee aavised that revised application would be submitted, o The license amendment request for GGNS-1 1mproved TS is planned to be submitted in April 1990. A markup of the present GGNS-1 TS is schdcleo for January 1990. A task force of four disciplines and operations personrel is working on the improved TS, including 5-7 engineers from Nuclear Plant Engineering, core physics and licensing. A procedure and quality control are in place. Training and surveillance procedures to use the improved TS have not yet been included in detaileo planning. The submittal will identify the location in the updated FSAR where TS requirements have been placed anc will cescribe administrative controls, o A new TS for engineered safety feature rocm coolers is planned. The TS would define allowed outage tines (A0Ts), if room coolers become -inoperable, that are consistent with A0Ts for ecuipment in the rooms. This would be a follow up to LER 86-29, which describes corrective actions for low flows in room coolers due to corrosion induced flow restrictions in pipes. A BWR Owners Group is discussing this subject with hRC the similar Technical Specification Branch. Licensee is consicering(Letter odted situation at Clinton for guidance in preparing the TS. August 21, 1989 from Murley). o The licensee advised that in response to staff's request for information regarding prying action on base plates for pipe supports, they had b 8911230074 891115 ;" W - y ^ " " _ .

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* $ 8(pm Mo f -u

d Io UNITED STATESgT t )e g NUCLEAR REGULATORY COMMISSION3 .' .t WASHINGTON, D. C. 20S55

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%, November 15, 1989,

' Docket No. 50-416

LICENSEE: System Energy Resources,-Inc. (SERI)

FACILITY: Grand Gulf Nuclear Station, Unit 1 (GGhS-1)

SUBJECT: SUMMARY OF SEPTEMBER 19, 1989 MEETING AND TRIP'

TO GGNS-1t

The NRC staff niet with the licensee at the GGNS-1 Site to discuss future !

licensing activities. On September 20 and 21, 1989, the NRC Project Manager !

discussed selected activities with the SERI licensing and engineering staff,.

Enclosure 1 provides a list of participants in the meeting. Enclosure 2 is a,

copy of the agenca for the meeting.

The licensee provided adoitional information cn several activities as follows: i

o Regarding followup on the loss of main condenser vacuum event andassociated equipn:ent failures, General Electric Company is preparing areport on the failure of one control rod to fully insert.

o Regarding the requirement for secondary containment integrity whenhandling loaos over spent fuel, the licensee plans to put curves of loadallowable height versus weight in procedures and change the TechnicalSpecifications (TS) regarding secondary containment integrity to specifythe impact energy above which integrity will be requireo. The licenseeaavised that revised application would be submitted,

o The license amendment request for GGNS-1 1mproved TS is planned to besubmitted in April 1990. A markup of the present GGNS-1 TS is schdcleofor January 1990. A task force of four disciplines and operationspersonrel is working on the improved TS, including 5-7 engineers fromNuclear Plant Engineering, core physics and licensing. A procedure andquality control are in place. Training and surveillance procedures to usethe improved TS have not yet been included in detaileo planning. Thesubmittal will identify the location in the updated FSAR where TSrequirements have been placed anc will cescribe administrative controls,

o A new TS for engineered safety feature rocm coolers is planned. The TSwould define allowed outage tines (A0Ts), if room coolers become-inoperable, that are consistent with A0Ts for ecuipment in the rooms.This would be a follow up to LER 86-29, which describes corrective actionsfor low flows in room coolers due to corrosion induced flow restrictionsin pipes. A BWR Owners Group is discussing this subject with hRC

the similarTechnical Specification Branch.Licensee is consicering(Letter odtedsituation at Clinton for guidance in preparing the TS.

August 21, 1989 from Murley).

o The licensee advised that in response to staff's request for informationregarding prying action on base plates for pipe supports, they had

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provided staff reviewers with 240 revised baseplate evaluations, using ^

current methods. The staff confirmed that reviewers are considering thosecalculations. Subsequent to the meeting, staff advised licensee that itsreport on pipe support calculations is due November 30, 1989.

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o The licensee is planning to submit a proposed TS change to allow the useof water leakege tests rather than air. tests for feedwater isolationvalves.- Water would be maintained in the feedwater line following anaccident by its keep fill system. Perry uses this methoa of containmentisolation. Maintaining leakage within TS limits using air tests requiresreplacement of resilient seals every outage,

'o The licensee will respond to GL 88-20 regarding an IPE by October 31,

1989. SERI is planning to use the same technology as that used inNUREG-1150. A tentative scheoule for getting an operational tool is 3years.

o Regarding GL 89-10 on M0 VATS, licensee said because of the large numberof safety related MOVs in the Mark III containment (300) the reconnendedschedule in GL 89-10 for completing all design basis reviews, analyses,-verifications, tests and inspections woulc significantly extend outageschedules. The licensee will propose an alternative schedule based onprioritization according to safety function,

o The licensee stated that its schedule to implement its new method ofclarifyirg safety related equipment per Generic Letter 83-28 position2.1.1 was changed from June 1989 to November 1989 (Item 15, Page 7 oflicensee's June 17, 1988 letter).

o The li m re: :tci.6 diat it has revised its procedures for 10 CFR 50.59reviews. The procedures have been reissued with NSAC - 125, the NUi4 ARCguideline document, enclosed. Training is according to INP0 guidelines.A subcommittee of the SRC reviews 10 CFR 50.59 safety evaluations. Thestaff notes that the' revised procedures do not specify qualifications forperforming screening or safety evaluations and that screening does notdetermine whether a change affects nuclear safety. Screening onlydetermines whether the equipment or procedure changed is in the FSAR.Previous staff reviews of procedures reconsnended these two changes to theprocedures.

The staff provided information regaraing the following matters:

o Regarding the proposed TS change to the stendby liquid control system,the licensee questioned why TS 4.1.5.6.3 specifies determination of boththe weight of sooium pentaborate and the concentration of boron insolution, since the weight is calculated from the concentration asdetermined by chemical analysis of a sample of solution. Subsequent tothe meeting, the staff advised the licensee that deletion of weightdetermination is acceptable.

o The proposed TS change allowing larger surveillance test internals forthe reactor protection system is scheduled to be issued December 31, 1989.

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o Regarding the proposed TS change to delete local leak rate testing of,

small (1 inch diameter or less) test, vent and drain valves, the licensee<

.. . stated that other utilities do not have such requirements in the TS.' ' Integrity is verified by inspection. Subsequent to the meeting, the staff

advised the licensee that this matter is being considereo generically andwill be resolved in the TS Improvement Program. Therefore, the proposed TSchange will be rejected,-

o The proposed TS change regarding PSRC and SPC composition and combiningthe STA and SR0 responsibilities under one person was scheduled to beissued. September 30, 1989. Licensee stated that a new TS proposal todelete the site director position and change the radiation protection '

manager ano. training supervisor positions wculd be filed shortly.

.o The staff said it would give the review of the revised application for aTS change per GL 87-09 a higher priority. This amendment would change

- TS 3.0.4. to allow mode changes while in action statenents, provided '

administrative procedures-are in place to assure proper use of the change.The staff said it expected such mode changes to have a written safetyevaluation prior to the mode change. The licensee said it planned to havethe PSRC review such operations and document the evaluation in PSRC-minutes. Licensee will provide this information by letter to supplementits application.

o In response to the licensee's request for clarification of Generic Letter69-09_ regarding ASME Section III component replacements, the staffcommented on licensee's proposed clarification (Enclosure 3). Staffagrees with three of the four clarifications. However, the staff does notagree with licensee's proposed alternative to listing the GL 89-09replacements in the FSAR.

o Subsequent to the meeting, the staff adviseo that the containment purgeprogram review by Jack Kuorick would be ccmpleteo by January 31, 1990.

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| o The staff said its review of the General Electric topical report regardingI neutron flux monitoring to meet the requirements of Regulatory Guide 1.97

would be completed by December 31, 1989. The licensee indicated itsalternative of installing an encore detector by the fourth refuelingrequires a decision by January 1990,

o The staff requested that 10CFR 2.790 proprietary information included inL applications be properly identified in the letter of transmittal ano that| an affidavit requesting withholding be enclosed (per August 1, 1989 memo

of John T Larkins to NRR Project Directors).

o The staff requested information regarding the licensees measures tocontrol the spread of hot particles. The licensee described its procedurein the plant operations manual for controlling hot particle contamination(Procedure 08-8-02-21 Revision 1, oated March 10,1989).

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L o The staff questioned why the chemistry TS Surveillance Requirement 4.4.4.cdoes not limit outage of the continuous conductivity monitor

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to 31 days as in the Stancard TS and in other plants. The licensee stated 1that SSER Supplement 6 acc00ted the deletion (Page 16-103). Also, from a ;practical view point, the aiternative of sampling every 4 hours is too i;

burdensome to continue for long periods of time._ Subsequent to the j

meeting, the staff advised the licensee that it will not be necessary to- make the TS like the Standard TS.

o 'The staff discussed its review of the revised fire protection program.The licensee said staff's conclusion that only two safety relief valveswould be damaged by any one fire is not supported by its submittals.Staff will arrange a meeting to discuss the fire protection program andthe proposed license condition per Generic Letters 86-10 and 88-12.

Original Signed By:

L. L. Kintner, Senior Project ManagerProject Directorate II-1Division of Reactor Projects 1/II

Enclosures:As Stated

cc w/ enclosuresSee next page

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.....:...,2 J '...:... __..: .....______:....______.........___.............____ _

.NAME :PArde on LK1 er:d A e sam__...:.__.... ___:_ ___...... :.____.......:__.... ___..:.._____...__.____.....___...___ ...DATE 11/ J b /89 11/|5/89 114ji/89

0FFICIAL RECORD COPY. Document flame: SYSTEM ENERGY RESOURCES INC.

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' hr.: W. T.- Cottle-

. System Energy Resources, Inc. Grand Gulf tiuclear Station (GGNS) l1

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4: Mr. T. H. Cloninger fir. C. R. HutchinsonVice' President, huclear Engineering GGNS General Manager,

'

& Support.

System Energy Resources, Inc. -System Energy Resources, Inc. P. O. Box 756

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P. O. Box 31995 Port Gibson, Mississippi 39150, Jackson, Mississippi 39286

Rcbert B. McGehee, Esquire The Honorable William J. Guste, Jr.Wise, Carter, Child, and Attorney General J

Caraway Department of JusticeP. O. Box 651 State of Louisiana

~ Jackson, Mississippi- 39205 Baton Rouge, Louisiana 70804

Nicholas S. Reynolos. Esquire Office of the GovernorBishop, Cook, Purcell State of Mississippi

and Reynolds Jackson, Mississippi 39201| 1400 L Street, N.W. - 12th Flocr

Washington, D.C. 20005-3502' Attorney GeneralGartin Builoing

Mr. Ralph T. Lally Jackson, Mississippi 39205-Manager of Quality AssuranceEntergy Services, Inc. Mr. Jack licMillan, DirectorP. O. _ Box 31995 Division of Solio Waste ManagementJackson, Mississippi 39286 Mississippi Department of Natural

ResourcesP. O. Box 10385

Mr. John G., Cesare Jackson, Mississippi 39209Director, touclear LicensingSystem Energy Resources, Inc. Alton B. Cobb, M.D.P. O. Box 469 State health OfficerPort Gibson, Mississippi 39150 State Boarc of Health

P. O. Box 1700fir. C. B. Hogg, Project lianager Jackson, Mississippi 39205Bechtel Pa er Corporation-P. O. Box 2166 PresidentHouston, Texas 77252-2166 Claiborne County Board of Supervisors

Port Gibson, Mississippi 39150; Mr. H. O. Christensen| Senior Resident Inspector Regional Administrator, Region II

U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory ComissionRoute 2, Box 399 101 Marietta StreetPort Gibson, Mississippi 39150 Suite 2900

Atisr.ta. Georgia 30323t

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#DISTRIBUTION FOR MEETING SUMMARY DATED:~ November 15,1989

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Facility: Grand Gulfh .;

Decket"'Pite=~ '

NRC PDRLocal PDRT. Murley 12-G-18.. .

J. Sniezek 12-G-18'- -

E. Adensam= 14-B-20t .P. Anderson 14-B-20 '

L. Kintner 14-B-20- :

OGC 15-B-18 '

.E.' Jordan MNBB-3302-ACRS-(10)' P-315-B. Borchardt 17-G-21

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ENCLOSURE 1

Attendees September 19, 1989 Meeting,

NAME AFFILIATION i

George Zinke SERI-LicensingD. L. Pace SERI-NPE ,

Steve Bennett SERI-NLJohn Fowler SERI-NLYosi Balas LicensingM. L. Crawford SERI-NLF. W. Titus SERI-NPEJ. G. Cesare SERI-NLH. O. Christensen NRC Senior Resident InspectorL. L. Kintner NRC Senior Project Manager

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'NRC-SERI LICENSING ACTION STATUS MEETING i

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September 19, 1989- jy:

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{ -I.aINTRODUCTION 1

11. PLANT ACTIVITIES

A'. Status ~.

', B. Recent Events / Issues

III. SPECIAL TOPICS OF-INTEREST

j; A. ADHRS'

JB. .. Individual Plant Evaluation (GL 88-20) :

C. M0 VATS (GL89-10)-'

D. Light Loads

E. Tech Spec Improvement Program'

IV.: KEY-LICENSING ACTIONS :

A. NRC Action '

B. SERI-Action

~V. OBSERVATIONS.REGARDING LICENSEE PERFORMANCE'

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KEY LICENSING ACTIONS'

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I. NRC ACTION - TECH SPECS

A. - RPS

B. Test, Vent and Drain Valves,t

C. SERI Organization /PSRC/SRC Composition

D. . Combine STA/SR0

E. -GL 87-09, TS 3.0.4 and 4.0.3

F. Standby Liquid Control, Boron Concentration

G. Control Rod Testing

H. Consolidated Operating Company

II. NRC ACTION - OTHER

A. Fire Protection Program,

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B. Containment Purge Programi

C. Pressure - Temperature Curve for R.G. 1.99

D.. Pipe Support Issues fIII. SERI ACTION - TECH SPECS

A Light Loads

B. Shutdown Cooling (ADHRS)

C. Cycle Specific Variables

'D. Relocation of RETS

E. Containment Purge (Pending NRC)

F. Fire Protection Program (Pending NRC)

G. Fire Protection - Addition of Smoke Detectors

H. Pressure - Temperature Cu;ve (Pending NRC)

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KEY LICENSING ACTIONS(Continued)

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IV. SERI ACTION - OTHER !

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'A. Inservice Testing Program Extension 10/3

(GL 89-04)

B. Boraflex Gap - RAI 10/15 '

C .- Individual Plant Evaluation (GL 88-20) 10/31

D .' R.G.1.97 Neutron Monitoring System Report 10/31

E. Surface Vehicle Bombs (GL 89-07) 11/8'

F. Motor Operated Valves - M0 VATS (GL 89-10) 12/2209

G. ASME Section III Procurement (GL 59-M) TBD,

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y. ENCLOSURE 3'

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GENERIC IEITER 89-09.

ASME SECTION III 03@CNDff REPIACEMElGS| Q (GGNS inplementation) |L- y

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kFor a consistent inplementation of the NRC positions contained in GenericIstter 89-09 (GL), the following clarifications are provided. 1

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In addition to replacement wupcrMits, the GL may also be applied to lop e., cwyonent parts (i.e. , disks, bonnets. . . ) .

o When an item is procurred from a non-N-Certificate holder, an Authorized !Nuclear Inspector will be assigned to the supplier's facility when the item

fj is manufactured with pr=c- that require witnessing by an ANI. Whenff 3- items are manufactured with processes that do not require witnessing by an :

ANI, the site ANII,s review of all associated documentation will satisfy- !

the requirements of ASME Section III.

o he FSAR will be revised to reflect the inplementation of GL 89-09. AS analternative to listing the GL 89-09 replacements in the FSAR, the ASMESection XI Repair / Replacement Summary Report (NIS-2) will drment the use

.NO of the GL. Eis method of atterting ccupliance with the GL contains acertification statement frce the owner. Additionally, it bares a statement .

from the ANII. For class 1 and 2 replacements this information is providedto the NRC in the ASME Section XI Sumary Report within 90 days ofccupleting each refuel outage.

o % e NRC position says that the licensee must first establish that an '

" equivalent" Section III stanped replacement is not available. GGNSunderstands this to have different meanings for ccrponents verses parts.

V 2e term " equivalent" regartling ccmponents inplies that an alternativeI c-5 component can be obtained from an ASME N-Type certificate Holder that

will fulfill the same safety function without physical design changesto the facility. Also, to qualify as equivalent, the replacementccuponents operating parameters should imitate the original ocuponentsto the extent that a new system or safety analysis is not required.

W e term " equivalent" for parts is more difficult for the owner toc5 define. Most ccmponents are designed by the ccmponent manufacturcr.

- h e owner provides a design specification to the manufacturer that|- gives information for the components design. We owner, in all cases,i may not be able to determine if a part made by another manufacturer

possesses the same form, fit ard function abilities. With the recentconcerns regarding counterfeit parts, it is believed prudent to obtainreplacement parts from the original manufacturer (when available)rather than trying to match parts frca an alternative manufacturer.When parts cannot be obtained frcn the original manufacturer, thereplacement part will be obtained from an N-type certificate holder,when available.

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