AECM-85-0081, Responds to NRC Re Violations Noted in Insp Rept 50-416/85-02.Corrective Actions:Updated FSAR Will Be Submitted by 851201 & Policy to Conduct Periodic Licensing Status Meetings W/Nrc Instituted

Responds to NRC Re Violations Noted in Insp Rept 50-416/85-02.Corrective Actions:Updated FSAR Will Be Submitted by 851201 & Policy to Conduct Periodic Licensing Status Meetings W/Nrc Instituted

ML20117N607
Person / Time
Site:	Grand Gulf
Issue date:	03/25/1985
From:	Dale L MISSISSIPPI POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20117N540	List: AECM-85-0081, Responds to NRC Re Violations Noted in Insp Rept 50-416/85-02.Corrective Actions:Updated FSAR Will Be Submitted by 851201 & Policy to Conduct Periodic Licensing Status Meetings W/Nrc Instituted AECM-85-0095, Responds to NRC Re Violations Noted in Insp Rept 50-416/85-02.Corrective Actions:Person Performing Independent Verification Will Function in Series & Not in Parallel W/Installation Activity
References
AECM-85-0081, AECM-85-81, TAC-56595, NUDOCS 8505170595
Download: ML20117N607 (3)

Text

F

, 1 xy . ..

s MISSISSIPPI POWER & LIGHT COMPANY

)) Helping Build Mississippi EulkhiMdidd5 P. O. B OX 16 4 0. J A C K S O N. MIS SIS SIP PI 39215-1640 l Ma M % 2585ntI : g g NUCLEAR LICEN$tNG & 5AFETY DEPARTMENT U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 .

1 Attention: Dr. J. Nelson Grace, Regional Administrator

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 File: 15521/15524 Report No. 50-416/85-02, dated February 19, 1985 (MAEC-85/0054)

AECM-85/0081 This is in response to your letter dated February 19, 1985, which contains a Notice of Violation for violations 50-416/85-02-01 and 50-416/85-02-03. The response to violation 50-416/85-02-01 was transmitted to you on March 21, 1985.

Our response to violation 50-416/85-02-03 is attached. As discussed in our letter of March 21, 1985, the due date for this response was extended to March 25, 1985, by Mr. Virgil Brownlee of your office.

MP&L is requesting that your office reconsider and withdraw violation 50-416/85-02-03 for the reasons discussed in the attached response.

Additionally, we ask the opportunity to meet with you in order to discuss our position on this issue. Should you have any questions, please contact my office.

Yours truly, L. F. Dale Director

! RLS/SHH:rw Attachment ec: Mr. J. B. Richard (w/a)

Mr. O. D. Kingsley, Jr. (w/a)

Mr. R. B. McGehee (w/a)

. Mr. N. S. Reynolds (w/a)

Mr. G. B. Taylor (w/o)

Mr. James M. Taylor, Director (w/o)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission 51hh5050429050g6 Washington, D. C. 20555 o J0P14AECM85032101 - 1 L

I ,

F 44 /

Attrchm:nt to AECM-85/0081 Page 1 Response to Violation 50-416/85-02-03 Notice of Violation 10 CFR 50.71(e)(3)(i) requires each licensee periodically update the Final Safety Analysis Report (FSAR) within 24 months of either July 22, 1980, or the date of issuance of the operating license, whichever is later. The licensee's Unit 1 operating license was issued on June 16, 1982.

Contrary to the above, as of January 15, 1985, the licensee had not updated the FSAR per 10 CFR 50.71.

I. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Mississippi Power & Light Company (MP&L) admits to the specifics of the alleged violation, in that MP&L did not meet the strict interpretation of 10 CFR 50.71(e)(3)(1). Although MP&L admits to the specifics of the alleged violation, it believes that the uniqueness of the extenuating circumstances as discussed in paragraph II below should form a basis for reconsideration and withdrawal of this violation by NRC Region II.

II. REASONS FOR THE VIOLATION On February 6, 1984, via letter number AECM-84/0026, MP&L requested an exemption to certain requirements contained in 10 CFR 50.71. During various discussions with the NRC Licensing Project Manager MP&L was led to believe that relief, in some form, probably would be granted. The latest such conversation was held on May 30, 1984. However, the NRC, via letter dated June 26, 1984, denied the requested schedule and requested MP&L provide a modified exemption request. MP&L was first advised of this decision on June 20, 1984, by the NRC Licensing Project Manager (telephone conversation). This date was four days after the 24 month deadline established by 10 CFR 50.71 and the decision was contrary to the information that MP&L had received until that time.

In preparing the revised request, MP&L held several telephone conversations with the NRC Licensing Project Manager from June through December 1984. The revised exemption request was submitted via MP&L letter number AECM-84/0352 dated December 31, 1984. The NRC granted an exemption until December 1, 1985, via letter dated February 26, 1985.

While MP&L's original exemption request was denied, it was MP&L's understanding that an extension would be granted following the submittal of a clarlfied exemption request. (Reference conversation with the NRC Licensing Project Manager on June 20, 1984.) Furthermore, the NRC letter denying the original request clearly implied that a delay of up to 12 months was acceptable to the NRC. Consequently, MP&L believed at the time that in view of the record of correspondence and discussions, and good faith efforts to obtain relief, MP&L was not in noncompliance with 10 CFR 50.71.

J0P13ATTC85030701 - 1

r e;k, ' '

Attach:2nt to AECM-85/0081 Page 2

-III. CORRECTIVE STEPS WHICH HAVE BEEN'TAKEN AND THE RESULTS-ACHIEVED As noted in II above, by letter dated February 26, 1985, the NRC has granted the relief sought by MP&L. MP&L will submit the Updated FSAR by December 1, 1985.

~

IV. CORRECTIVE STEPS'WHICH WILL BE TAKEN' TO AVOID FURTHER VIOLATIONS

'MP&L considers the circumstances surrounding and leading to this violation to be unique. . While there are no specific additional corrective steps considered necessary as a result of.this violation, MP&L has instituted a policy to conduct periodic licensing status meetings with.the NRC to enhance-communications between our staffs.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED With the granting of the requested extension in the NRC letter-dated February 26, 1985 MP&L is currently in compliance with 10 CFR 50.71(e).

i i ~

s e

J0P13ATTC85030701 - 2