IA-84-665, Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted

Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted

ML20134P278
Person / Time
Site:	Grand Gulf
Issue date:	07/26/1984
From:	NRC COMMISSION (OCM)
To:
Shared Package
ML20134P234	List: IA-84-665, Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted ML20134P231 ML20134P278
References
FOIA-84-665, REF-10CFR9.7 NUDOCS 8509060224
Download: ML20134P278 (11)

Text

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2Ne'N 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ,

4 DISCUSSION OF INVESTIGATIONS AND

{ POSSIBLE ENFORCEMENT ACTIONS 5

6 l l CLOSED MEETING - EXEMPTIONS 5 & 7 7 ,

8 l

! Room 1130 g 1717 H Street, N.W.

Washington, D.C.

10 Thursday, July 26, 1984 11 i

, 12 The Commission met, pursuant to recess, at 1:37 p.m.

13 COMMISSIONERS PRESENT: ,

14 NUNZIO PALLADINO, Chairman of the Commission  :

THOMAS ROBERTS, Commissioner 15 JAMES ASSELSTINE, Commissioner I FREDERICK BERNTHAL, Commissioner 16 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:

17 S. CHILK~

l 18 R. BURCH Q

, B. HAYES

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19  ! W. DIRCKS J. O'REILLY -

20 D. DeYOUNG '

R. LEVI 21 G. MESSENGER I 22 AUDIENCE SPEAKERS: - -

E. CASE i:

H. THOMPSON d 24 E. GOODWIN 1 25 8509060224 850820 -

PDR FOIA BELL 84-665 PDR  !

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CHAIRMAN PALLADINO: We will get OIA up here.

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23 I should note the staff has lef t,'and we h6ve I lt

!- l l 24 George Messenger from OAI to talk about the inquiry conducted ' ,

25 in connection with the 2.206 petition regarding Grand Gulf. ,

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. FREE STATE REPORTING INC. 'I

h 45 George, can you proceed?

2 MR. ME SSENGEF. : Fi rs t of all, what we cre doing, v.

3 ( have bef ore us -- and I am prepared f or more detail if you i

4 i so desire at this meeting.

5 f CHAIRMAN PALLADINO: Can you highlight them?

6 i MR. MESSENGER: Yes. A petition dated April 10, i

i 7 1 1984, submitted pursuant to 10 CFR 2.206 by Jacksonians United

! i g

I for Livable Energy Policies -- acronym JULEP -- three ,

g , matters of possible OIA interest were raised as follows:

30 a. "possible improprieties and illegal acts by  ;

i 33 NRC inspectors and investigators;' l l

b. "the handling by OIA of the improprieties l

13 which have been previously identified;" and

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34 "the effectiveness of NRC. Region II in 15 fulfilling the mandated responsibility to enforce the 16  ! regulations of the NRC which exist to ensure protection of t

37 l public health and safety. "

18 Thus far, interviews were conducted to determine l l

39

' whether JULEP had specific allegations of misconduct which g would demonstrate the matte.rs raised in their petition g presented above.

Field work into the two allegations thus identified has been completed and a report on the results of that 23 g effort is in preparation.

o Now T 'm prepared , if you would like, at this FREE STATE REPORTING INC.

c. . . .. m . _ : . . . n. _ , . .m

46

meeting tc co inte detail whc wt Interciewed end thc results

; thss far.

3 CHAI RKMs' P ALLADINO : k'cll, I think we would bc 4 interested in knowing your general finding on each of these i

5  ; points, whether there were specific allegations that supported 6  : them. If you found that these allegations were well i

7  ; substantiated.

1 I

8 i MR. MESSENGER: Okay.

I g CHAIRMAN PALLADINO: Whether anybody in your l0 opinion did something wrong.

33 l MR. MESSENGER: Okay. Ken Lawrence, a JULEP 12 member, was interviewed and he alleged that he and another 13 JULEP member were barred from a meeting at the plant site 34 l because the NRC was discussing a draf t inspection report l .

15 !w ith the licensee.

l 16

! Cynthia Stuart, author of the JULEP petition, 37 l alleged that NRC staff had improperly handled the issue 33 l of technical specifications for Grand Gulf containment.

39 They had approved specifications for a MARK-II containment ,

g which Grand Gulf does not have.

21 j Stuart had no other allegations to demonstrate 22 l the broad negative comments about NRC' presented in her 23

' 2.206 petition and specifically agreed she was probably in

,, error in her reference to.OIA.

G 25 OIA has not investigated anything at Grand Gulf FREE STATE REPORTING INC.

i pric to this petit:c..

l 2r The results that we found- '

1 1 31 It was found that the licensee draft inspection I 4 reports were under discussion and that Lawrence was barred 5 on the basis of protecting licensee proprietary information.

6 CHAIRMAN PALLADINO: Was it an NRC inspection I

7 Ireport or licensee?

8 MR. MESSENGER: Licensee.

9 CHAIRMAN PALLADINO: Licensee inspection report to that would have been discussed. j 11 MR. MESSENGER: Because no draft inspection report  !

l 12 was being discussed, this allegation was unfounded.

33 , The staff has already responded to the Commission 14 on the MARK-II containment issue in March of this year. More ,

15 recently, an enforcement action for submission of material  ;

t 16 false statement in connection with this issue has been l

1 17 suggested, and we note from our references, .it was the-I is Eisenhut memo of July 17, 1984.

ig CHAIRMAl; PALLADINO: Is thdre an investigation ,

20 going n on that?  !

21 COMMISSIONER ASSELSTINE: I think just what was  ;

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22 described to us.

23 MR. MESSENGER: Yes, I think that was --

24 MR. GOODWIN: They are determining whether they l( 25 are going to find it's a material false statement. The i

FREE STATE REPORTING INC.

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Eisenhut meme was a suggestac.- that thc; makc that I

2 determination.

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'I 3 COMMISSIONER ASSELSTINE: Yes. Tnat's what Dick l

4 DeYoung is going to report to us on on Tuesday, yes.

5 CHAIRMAN PALLADINO: Yes.

6 MR. MESSENGER: What we have found there, that this 7 issue has been adequately aired by the staff and consequently I

e there appears to be no remaining issue requiring further 9 investigative activity by OIA into this matter. .

I 1o We were presented with the interviews that we i

11 conducted, the paperwork on this. And it looks like it's I

12 Pretty well aired before the -- in the agency and before ,

i 13 the Commission.

L 14 CHAIRMAN PALLADINO: Okay, any questions or 1

comments? I 15 16 Let me ask OGC, how do we respond to a 2.206 l 17 petititn of this nature when OIA is involved, rather than  !

18 the staff? Does OGC respond, or --

i, 19 MR. LEVI: I think the easiest way to do it would ,

t 20 , be .just to have OIA respond and to tell them that raises l 21 matters more proper for investigation by OIA, and they have i 1 22 looked at them, and accordingly it has not been treated as j 23 a formal 2.206 petition. ,

24 Because it is labeled a 2.206 petition does not 1 25 necessarily make it a 2.206 petition.

1 FREE STATE REPORTING INC.

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1 CH AIRMAN PALLADINC : All right. So, a c; rect 2 response f rom OI A is the appropriate vehicle?

3 MR. LEVI: I would think so, yes.

I 4 j CHAIRMAN PALLADINO: You agree, as f ar as you know?

5 MR. MESSENGER: That's an unknown" to me . What 6 I intend to do is provide the report to the Commission. So, 7 in ef fect what we would be talking about is the disposition s of that report. , ,

g CHAIRMAN PALLADINO: It somehow intuitively feels ,

10 like an OGC action to me. The reason I bring it up is so  ;

33 it doesn't fall in the cracks. Ordinarily, it would be a 12 Denton matter and he would pick it up and carry it forward. l 13 This is a little more unusual, at least in my 34 experience.

15 MR. MESSENGER: Any of our reports, it always  !

16 comes up and the Comr.ission gets a vote on releasability in j i

37 conjunction with OCG. And that is what apparently we are .

I 18 talking Macut here.

39 COMMISSIONER ASSELSTINE: Yes.

George, when are you going to have the report done?

20 CEAIRMAN PALLADINO: What's that?  ;

21 COMMISSIONER ASSELSTINE: I was wondering when 22 23 George was going to have the report done.

MR. MESSENGER: My target is the end of next.

24 ,

week, before i go on leave. I'll be going on a week's leave.

25 FREE STATE REPORTING INC. -

50 So, that's the target. Tney are writing it right now.

2 COMMISSIONER SERNTHAL: Well, let's see, I assume 3

that you are -- were you asking that to find out the i

4

[ possible coincidence with the vote, or --

5 '

COMMISSIONER ASSELSTINE : Well, I was mostly 6

interested in when he was going to have the written report 7

done in terms of, yes, how much time would drag on beyond 8

, the beginning of next week, yes.

9 l' COMMISSIONER BERSTHAL: I see.

to  ;

I MR. MESSENGER: The interviews are all written 11 right n ow .

12 COMMISSIONER ASSELSTINE: Yes, all the field work 13 is done.

t l .

14 MR. MESSENGER: Yes. '

15 CHAIRMAN PALLADINO: But you raise the question,

[ t 16 should it be done before we take the vote? It would be i

17 inice.

18 COMMISSIONER ASSELSTINE: It would be nice. But I 19  ! gather it 's impossible.

f 20 '

l MR. MESSENGER: Yes, I think that 's -- with our l

21 own internal process because once it is written, it gets an 22 AD review, it gets an accuracy check, and then it comes to me.

23

{ COMMISSIONER ASSELSTINE: Yes.

24 MR. MESSENGER: That in itself would -- it takes a e

i 25 few days.  :

i FREE STATE REPORTING INC.

I 52 i , COMMISSIONER ASSELETINE: You have talked to the l -

2  ! PeoPl e that provided the 2.206 petition. Did they indicatt li 3 ' anybody else that they thought you ought to talk to in terms 4 of following up on it?

5 MR. MESSENGER: No, that was it. These two 6 people, that's what we've gotten.

i 7 COMMISSIONER ASSELSTINE: And you followed up on i

8 the two items, specific information that they provided to 9 you. You have resolved them in the way that you have j i

10 described.  ;

I I

33 MR. MESSENGER: Yes. . .

I 12 CEAIRMAN PALLADINO: Can I come back to my j 13 question. Is OGC going to follow through and make sure i

34 this is responded to -- l t

MR. LEVI: Certainly.

15 f l

A  : -- appropriately. I'll leave .

16 37 whatever " appropriate" --

18 MR. LEVI: When OIA submits the report, OGC will 39 see that it is taken care of. -

CHAIRMAN PALLADINO: All richt.

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Anything more that 20 .

we should discuss on this matter? Any more that we should 21  !

i discuss on investigations and rela 6ed topics, regarding Particularly Grand Gulf?

23 COMMISSIONER ASSELSTINE: No.

(- CHAIRMAN PALLADINO- Is it appropriate to adjourn 25 FREE STATE REPORTING INC.

_=_. .. . _ _ . . _ _. _ . . . . . . _ _ _ . _ _ ..

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, . ., i I the re-c ing?

l 2 CO.'II11SSIONER ASSELSTINE : yes, 3

CHAIRMAN PALLADINO: Okay. Thank you. We'll I 4 fstandadjourned.

.- 5 (Whereupon, at 2:45 p.m., the meeting of the

! 6 Comission was adjourned. )

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FREE STATE REPORTING INC.

1 NUCLE;.E RE 3'. JiTOR'. CO.' .' . ; E E I ON This 2s t o c e r t i f ;, : .5: the at:Lched proceedings

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2 3 before the Nuclecr Regula tory Commissior. ir. the matter of:

4 ; Discussion of Investigation and Possible i

Enf orcement Action 5 l

! Date of Proceedina: July 26, 1984 6 '

l Place of Proceeding: k'a sh ington , D.C., i 7 j jwereheldashereinappearsandthat this is the original 8 l l transcript thereof for the file of the Commission. -

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10 Reporter. M.E. Hansen 11 12 13 i

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25 FREE STATE REPORTING INC.

i  ! Court Rhino e Depositions .

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DISTRIBUTION:

July 17, 19S4 Docket No. 50-416 LB #4 r/f EAdensam MDuncan MEMORANDUM FOR: Jane A. Axelrad Director DHouston Enforcement Staff LKintner Office of Inspection & Enforcement DEisenhut/RPurple FROM: Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation

SUBJECT:

GRAND GULF - MATERIAL FALSE STATEMENT On March 13, 1984, Representative E. Markey wrote to the Comission requesting responses to certain questions. One question (Enclosure 1) asked the Commission's view as to the errors in Grand Gulf TS and surveillance procedures constituting material false statements.

On Decer.ber 15, 1980, the licensee submitted a markup of the Standard Technical Specifications for General Electric Boiling Water Reactors (NUREG-0123) which he stated reflected plant specific design factors. Additional submittals and changes were transmitted in letters dated June 26, and December 31, 1981, January 12, February 25, March 23, April 5, 6, 7 and 30, May 26, June 1, 9 (2 letters) and 10, 1982. Copies of the transmittal letters are included as Enclosure 2.

On June 16, 1982, NRC issued a low power (51) license to MP&L for Grand Gulf Unit I with appended TS.

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Contact:

L. Kintner, NRR X27038 8407240427 CF e40737 ADOCK 05000416  !

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Jane A. Axelrad -

Ur181cul signed y, s Darrell c, risenhut Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation

Enclosures:

1. Question 10(a)

2. Copies of transmittal letters cc: J. Lieberman

-T. Novak H. Denton ,

F. Miraglia l

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ENCLOSURE 1 i

QUESTION 10 (A)THECOMMISSION'SREGULATIONSATlbCFR50.100' STATE THAT A LICENSE MAY BE REVOKED OR SUSPENDED "FOR ANY MATERIAL FALSE STATEMENT IN THE APPLICA- '

TION FOR A LICENSE -OR IN THE SUPPLEMENTAL OR OTHER i STATEMENT OF FACT REQUIRED OF THE APPLICANT", OR,

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BECAUSE OF " CONDITIONS REVEALED...THAT WOULD WARRANT THE COMMISSION TO REFUSE TO GRANT A LICENSE ON AN ORIGINAL APPLICATION..." DOES THE COMMISSION CONSIDER THA THE ERRONEOUS TECHNICAL SPECIFICATIONS AND SURVEILLANC5 PROCEDURES SUBMITTED BY MP&L FOR GRAND' GULF CONSTITUTE EITHER A MATERIAL FALSE STATEMENT OR A FALSE STATEMENT OF FACT?

k RESPONSE _.

A DETERMINATION HAS NOT BEEN MADE AS'TO WHETHER OR NOT THE

ERRONEOU5 TS SUBMITTAL CON.STITUTES A MATERIAL FALSE STATEMENT.

THIS MATTER IS UNDER CONSIDERATION.

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4 MARKEY/&DQ -

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vz, ENCLOSURE 2 COPIES OF TRANSMITTAL LETTERS O

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em Pov l MISSISSIPPI POWER & LIGHT COMPANY l Helping Build Mossessippo P. O. B O X 16 4 0. J AC K S ON. MIS SIS SIP PI 39205 Dece=ber 15, 1980 innua eaccuenc>, cuaame=r .;

U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C. 20555 Attention: Mr. Harold R. Denton, Director

.  ?

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 File 0260/0277/15180 Submittal of Technical Specifications AECM-80/291 Enclosed is the initial submittal of the Technical Specifications for Unit 1 of the Grand Gulf Nuclear Station. This submittal consists of a markup of NUREG-0123, Standard Technical Specifications for General Electric Boiling Water Reactors, to reflect plant specific design factors.

In accordance with the discussion between our Mr. John D. Richardson and Mr. Bob Bottimore of the NRC on November 12, 1980, one copy of the Grand Gulf markup of NUREG-0123 is enclosed. Also, in accordance with the referenced November 12, 1980, conversation and other previous conversations with Mr. Bottimore, the Grand Gulf submittal has been developed on the basis of Revision 2 (August, 1979) of NUREG-0123.

l We would request that we be advised as soon as possible of your schedule for review of this submittal. Please advise us of any additional clarification which may be requited or of any followup meetings or discussions that you may determine to be appropriate.

Yours truly, h l >

L. F. Dale ,

Nuclear Project Manager l l

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f)OI A'6Y5)0 - Member Middle South Utilities System .

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/ MICSISSIPPI POWER O LIGHT COMPANY U.S. Nuclear Regulatory Commission AECM-80/291 Office of Nuclear Reactor Regulation Pageq cc: Mr. N. L. Stampley (w/o)

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

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

Mr. T. B. Conner (w/o)

Mr. Victor Stello, Jr., Director (w/o)

Division of Inspection & Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4

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Arts: Mr. narola s. Denton. Dirutor ,

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SUBJICT: Grand hit Euc.e Unit 1

• Docket No. 50 h16

,ile 0260/0277/15180 Submittal of Technical Scecifit.at!ons

• AECW81/213 Enclosed is the second submittal of the Standard Technical Scecifi- L cations for Unit 1 of the Grand Oulf Nuclear Station.

Grand *ulf Unit 1 Technical 3pecifications were originally submitted via AECS 80/291 (December 15. 1980) and subsequently revised by your Mr. Bottimore. This submittal is a markup copy of Mr. Bottimore's revision.

Changes have been indicated by margin bars, wh*.ch will aid you in l- your review. If you identify subsequent changes. if any, in this manner, future reviews will be acre exped.ent. We request that you advise us as soca as possible of your intended review schedule and your need for additional cAarification.

Your y.

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. ,. oce Manager of Nuclear Service.

'sdK/810(/JCR:aa g Attsebeen*. 3 cc Mr. 3. L. 5taspiey /

Mr. R. B. McGehee p,,, I, I.'.

Mr. f. 3. Canner N 4 Mr. G. 3. Tay.or }C (, fd4 Mr. 'li: tor Stel'o. Jr.. Director office of ..aspection 6 Enforcement U.. Nuclear RegMatory Commission Wa4nington. D.c. 20555 Member Middle South Utilities System tJL1 f)-. sy s.i .,- _i n M,, ,/

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. 6 MISSISSIPPI POWER & LIGHT COMPANY llelping Build Alississippi P. O. BOX 1840, J ACKSON MISSISSIPPI 39205 December 31, 1981 RECEwgn -

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U. S. Nuclear Regulatory Coc: mission ~

Office of Nuclear Reactor Regulation ] d4N4. Jgg " . _/

Washington. D. C. 20555 9 #acar % i

• WamIr I8C j Attention: Mr. Harold R. Denton. Director q '

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SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 File 0260/0653/5011/15160 Proposed Technical Specification for Containment Leakrate AECM-81/510 Dur letter to you. AECM-81/213. dated June 26, 1981, transmitted our proposed changes to the Grand Gulf Standard Technical Specifications (STS).

In that transmittal (subsection 3.6.1.2), containment leakage was limited to 0.4371 by weight of containment air for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period at a test pressure of 11.5 psig.

The most recent " Proof and Review" version of this section (dated November 20, 1981). provided to MP&L for concurrence by R. Bottimore of your office, reduced this allowed leakage value. In subsequent telephone conversations held December 22 and 23.1981 between J. Read of Accident Evaluation Branch and members of the staf f s of MP&L and Bechtel Pover, information was provided justifying the original value proposed in our letter of June 26. 1981, referenced above. A sum =ary of the calculational basis for the 0.437% leakage criteria, as discussed with Mr. Read, is provided as Attachment 1 to this letter.

As detailed in Attachment 1. the MP&L proposed leakrate criteria includes the tc:a1 leakage f rom the main steam isolation valves (MSIV). This is appropriate because the integrated leak rate test at Crand Culf is conduct.ed with the dryvell and containment volumes communicating and with the reactor vessel vented to the dryvell atmosphere. In this configuration test pressure vill be applied to the MSIV's.

The proposed leakrate limit of 0.437% was used in the analysis of offsite and control room personnel radiation exposure. As stated in FSAR subsection 15.6.5. the analysis results indicated that calculated doscs are within the guidelines of 10 CFR 100 and Cencral Design Criteria 19. and Appendix A to 10 CFR 50.

ten the %si:: of the referenced conversations, it is our understanding that Accident Evaluation Branch vill recommend a technical specification change based on the following MP&L commitments. We assume this vill result in l

a revised " Proof and Review" version of STS subsection 3.6.1.2.

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1. Containment leakage rate shall be limited to an overall integrated leakage rate of less than or equal to 0.437% by weight of the combined containment and dryvell air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the prescribed test pressure.

2. With regard to leakage past the main steam isolation valves, the combined leakage from all main steam lines (four) shall not exceed 100 SCF per hour.

3. Appropriate surveillance testing of each main steam isolation valve vill be conducted at intervals no greater than 18 months.

If additional information or clarification is required, please advise this office.

Yours tru1.y.

Yklfg --

L. F. Dale Manager of Nuclear Services JGC/JDR:ph l Attachment 1: Contain=ent Leakrate Criteria ec: Mr. H. L. Sta=pley (w/o)

< Mr. R. B. McGehee (w/o)

Mr. T. B. Conner (w/o)

Mr. G. B. Taylor (w/o) t Mr. Richard C. DeYoung. Director (w/o)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555

~

Attechsent I e

" AECM-81/510 Containment Leakrate Criteria Presented below is a summary of the method used to calculate an allowed leakage criteria for the containment's overall integrated leak rate test.

Information used in calculations: (See FSAR Table 6.2-1)

Net free volumes, cu.ft., Dryvell 270.128 Containment 1.400,236 Total 1,670,364 Design containment leakage .35% (See Note 1)

(volume percent, containment only) f MSIV leakage criteria SCF per hour 100 l l

(total allowed for four main steam lines)

1. Leakage in SCFH associated with containment design value (.35 volume %).

.35 x 10-2 0

x 1. 0232 x 10 = 204.20 SCFil

2. Total containment leakage allowed including main steam lines.

6 7 100 + 204.20 = 304.20 SCFH

3. Overall leakage criteria, based on total volume of containment and dryvell. 1 j 304.20 x 24 x 100 = 0.437%

6 1 1.670364 x 10 (In this calculation weight and volume percentages are equivalent.)

l J

4

• Note la As discussed with J. Read of Accident Evaluation Branch in a telephone cenversation held December 23, 1981, with C. Cesare of f

j Mississippi Fover & Light, an error was noted in FSAR Table 6.2-1.

This table incorrectly states that the design leakage of .35% is 1 based on the combined volume of the dryvell and containment. This f value is based on the containment volume only. FSAR Table 6.2-1 vill be revised in the next available amendment

• to correct this error.

1 . .

i MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. BOX 1840 J ACKSON MISSISSIPPI 39205 January 12. 1982 %IW f mucas aa racoucto.raraatwei.:

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I U. S. Nuclear Regulatory Cossaission 6 office of Nuclear Reactor Regulation .j All 13 'i93D"' .-C M

Washington. D. C. 20555 g,...,....,...

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Attention: Mr. liarold R. Denton, Director ,

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- . ;; p-Dest Mr. Denton: ,

SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 File 0260/15180 Revisions to CCSS Draft Radiological j Ef fluent Technical Specifications  !

AECM-82/19 l l

Recent conversations between representatives of Mississippi Power & l.ight Company and the Nuclear Regulatory Cossatssion have revealed the need for revintra selected pages in the Grand Culf Nuclear Station Radiological Effluent Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM). Accordingly. the revised pages are enclosed for your review and

" t insertion.

Please contact us if you have any eguestions.

A Yours truly.

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1.. P. Dale Manager of Nuclear Services

,' l.RMI!DR:rg ec: Mr. N. t.. $tsoplev (w/o) g Mr. R. 5. McGehee (w/o) g Mr. T. 5. Conner tw/o) s Mr. d. B. Taylor iv/o)

Mr. Richard C. DeYoung. Director (w/o) 00 I office of Inspectton & Enforcement 3 1.'. S. Nuclear Regulatory Cosisission Washington. D. C. 20555 4

I l Mr. J. P. O'Reillv. Regional Administrator (w/o) office of Inspection & Enforcement U. S. Nuclear Regulatory Cosusteston Region 11 l

101 Marietta St.. N.W.. Suite 3100 . _.

2 112 I O.

Atlanta. Georgia 30303 PDR ADOCK 03000416 PDR i

A Memtrer Middle South Utilities System n

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March 23,1982 9 S

wuapa ncouctos opAarus=v q ' M..m ,

U. S. Nuclear Regulatory Cosedssion -

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office of Nuclear Reactor Regulation C c t;/,'y~ N2 A ;

Washington, D.C. 20555 %g T*

Attention: Mr. Harold R. Denton. Director 2; > 9

SUBJECT:

Grand Culf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 File No. 0260/L-334.0/L-350.0 Additional Response to Concerns of Licensee Qualification Branch AECM-82/49 In this letter Mississippi Power & Light Co. (MP&L) operator of Crand Culf Nuclear Station on behalf of Middle South Energy. Inc. and South Mississippi Electric Power Association, is submitting responses to specific concerns expressed by the Licencee Qualifications Branch as well as changes made in the FSAR necessitated by recent organizational changes at MP&L.

As Grand Gulf Nuclear Station (CCNS) Unit No. I approaches the operational phase. Mississippi Power & Light Company (MP&L). operator of CGNS on behalf of Middle South Energy. Inc. and South Mississippi Electric Powcr Association has made certain organizational changes to insure a smooth transition for operation of Unit 1, resumption of construction of Unit 2 and the most expeditious use of the Grand Culf staff.

Attachment A to this letter presents a brief description of the details to be found in Attachments 1 through 13.

Should you have any questions, please advise.

Y urs truly.

/

L. T. Dale Manager of Nuclear Services hD<Ol PJR/JDR:ph Attachments g /

cc: See next page l

---a = aa ' '- 8203 23 h PP-Bh'KDOCKODOOog Member Middle South Utilities System .

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AECH-82/49 I

MISSISSIPPI POWER & UGHT COMPANY cct Mr. N. L. Staspley (w/a)

Mr. R. B. McGehee (w/a)  !

Mr. T. B. Conner (w/a)

~

Mr. C. B. Taylor (w/a) /

Mr. Richard C. DeYoung. Director (w/a)

Office of Inspection & Enforcement U. S. huclear Regulatory Commission ,

Washington, D. C. 20555 l

i l

1

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a MISSISSIPPI POWER & LIGHT COMPANY Helping Build Afississippi P. O. B O X 18 4 0. J AC K S ON. MIS SIS SIP PI 3 9 2 0 5 April 5, 1982 9l q

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Attention: Mr. Harold R. Denton, Director [ ,[ 8

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Dear Mr. Denton:

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SUBJECT:

Grand Gulf Nuclear Station l Units 1 and 2 Docket Nos. 50-416 and 50-417 File 0260/15180/L-860.0 '

Technical Specifications AECM-82/115 The purpose of this letter is to formally transmit Mississippi Power & Light Company's position on proposed changes to the Standard Technical Specifications that have previously been discussed informally with the Licensing Guidance Branch. Additional proposed changes to the Standard Technical Specifications regarding the Corputate Safety Review Committee (Technical Specification 6.5.2) were provided in AECM-82/49, dated March 23, 1982.

These proposed changes are included as an attachment to this letter and include the current " Proof and Review" page with proposed changes identified; and, additional justification if required.

Please advise if additional information is required.

Yours ruly, L. F. Dale Manager of Nuclear Services WK/Slul/JDR:Im Attachment cc: Mr. N. L. Stampley (w/a) Mr. G. B. Taylor (w/a)

Mr. R. B. McGehee (w/a) Mr. T. B. Conner (w/a) f Mr. Richard C. DeYoung, Director (w/a) l Office of Inspection & Enforcement 2 001 Vg U.S. Nuclear Regulatory Cosnission Washington, D.C. 20555 j l Mr. J. P. O'Reilly, Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Region !!

101 Marietta St., N.W, Suite 3100

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9994694#60 920405 Q a 30303

{M ADDCM OM00 h* iber Middle South Utilities System

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. Attscheent I to AECM-82/115 Grand Gulf Unit 1 Technical Specification Pages 3/4 1-3 & 1-4, dated December 18, 1981 l 1) Specification 3.1.3.1, Action a: As written, this does not allow l credit for a fully inserted control rod.

2) Specification 3.1.3.1, Action b.1: As written, this does not allow credit for a fully inserted control rod nor is the option for restcring the inoperable control rod to operable allowed.

3) Specification 3.1.3.1, Action b.1.b): If : red is able to be tripped (i.e., can be scramed), but not able to be moved, it is not practical to do this test. The footnote

• would also be deleted.

4) Specification 3.1.3.1, Action b.1: This is redundant to 3.1.3.1.b.2. Add the words "within one hour" and delete 3.1.3.1.b.2 and Footnote **.

5) Specification 4.1.3.1.2.b: This is added to lend consistency with the above changes. -

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j MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. B O X 18 4 0. J A C K S O N. MIS SIS SIP PI 3 9 2 0 5

, , February 25, 1982 g C  %

U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation E HECE(VRO '.'.l Division of Licensing Washington, D. C.

1. 01 rgg 20555

{.

• g i Attention: Mr. Darrel C. Eisenhut. Director p

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Dear Hr. Eisenhut:

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SUBJECT:

Grand Culf Nuclear Station Units 1 and 2

? Docket Nos. 50-416 and 50-417 4

File 0260/16360 4 Control of Heavy Loads y AECM-82/17

+

l e

This letter is being sent to you to supply certain corrections to the Heavy Load Report submitted to your of fice 'vith AECM-81/427 dated g November 23, 1981. In that report our plant specific definition of a heavy y load was changed from 750 pounds to 1140 pounds or from the weight of a

/ channeled fuel asseebly to the weight of a channeled fuel assembly plus its associated handling tool as defined in NUREC-0612.

{ The change was made in Footnote 1 of Table 4 on page 18 and in the g

proposed Technical Specifications for the fuel storage fuel pools. 3/4.9.7

[ and Jib crane, 3/4.3.13. However 1140 pounds is greater than the rated  :

capacity of the Jib crane. (Is ton), therefore since the limitation to 1140 pounds is meaningless, the latter technical specification is being deleted.

Reference to the proposed Jib crane Technical Specification is also being deleted on page 10.

g Two more references to the heavy load definition have been changed. On f the attached replacement to page 12 the words "and its associated handling tool" are added to Footnote (1) and on the attached replacement to page 15 in the New Fuel Bridge Crane paragraph 750 has been changed to 1140 in line six.

e' Attached are the required replacee?nt pages. Instructions for revision of the Grand Gulf six months Heavy Loads report are as follows:

?

^

Remove Replace With i

Page 10 Page 10-Rev. 1 Page 12 Page 12-Rev. 1 Page 15 Page 15-Rev. 1 Page 18 Page 18-Rev. 1 Technical Specifications g 3/4.9.7 3.4.9.7 Rev. 1 3/4.9.13 (2 pages) delete I\

N 820225 ,

Member Middle South Utilities System J DR ADOCK 05000416 --

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AECH-82/17  !

MISS!sstPPI POWER & LIGHT COMPANY Page 2 I If you have any questions please advise.

Yours truly.

L F. Dale p' Manager of Nuclear Services '

PJR/JDR:ph Attachments cc: Mr. N. L. Stampley Mr. R. B. McGehee ,

Hr. T. B. Conner Mr. C. B. Taylor Mr. Richard C. DeYoung. Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Com.ission Washington, D. C. 20555 I

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Missossippi P. O. B O X 184 0. J A C K S O N. MIS SIS SIP PI 3 9 2 0 5 April 6, 1982 y' A o u n eacu;ctins. toe u ew e' .

.' . 'b U.S. Nuclear Regulatory Commission .' .I-

, Of fice of Nuclear Reactor Regulation -

3 ggg e- 79 Washington, D.C.

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20555 i f

Attention: Mr. Harold R. Denton, Director A.,h\str#'~".7/8'h

Dear Mr. Denton:

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SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 3 Docket Nos. 50-416 and 50-417 ;l '

f File 0260/15180/L-860.0

) Technical Specifications i:

Reference:

AECM-82/Il5, dated c April 5, 1982 f AECM-82/136 f The purpose of this letter is to transmit a corrigendtun to the

[ previously transmitted reference. This page is attached.

Please advise if additional information is required.

Yours t uly, p 1,1l- -

L. F. Dale Manager of Nuclear Services

)

} WX/Silll/JDR:Im p Attartunent cc: Mr. N. L. Stampley (w/a) t h.

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

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

Mr. T . II . Conner (w/a)

F.

Mr. Richard C. DeYoung, Director (w/a)

Of f sie of Inspect son & Enforcement

{ U.S. Nuclear Regulatory Con.nission gDgol 3

f Washington, D.C. 20555 j V I I i

} Mr. J. P. O'Reilly, Regional Administrator (w/a) l l Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Region 11

. 101 H.irict ta St . , N.W. , Suite 1100 I Atlanta, Georgia 30303 i'

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I PDR ADOCK 05000416 PDR P- u.me.r uieei. South utinti . Sv. tom j f A

en,y r,a 1,908 C itLtidtmL*'s i Ivtya

:-l ADMINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written proce'dures shall be established, implemented and maintained covering the activities referenced below: '

a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978. ,

b. Refueling operations.

c. Surveillance and test activities of safety related equ.ipment.

d. Security Plan implementation.'

e. Emergency Plan implementation. ,

f. Fire Protection Program implementation.

g. PROCESS CONTROL PROGRAM implementation.

h. OFFSITE DOSE CALCULATION MANUAL implementation.

. ' Quality Assurance Program for effluent and environmental monitoring, RM'w of using the guidance in Regulatory Guide 4.15, February 197 W GEach procedure of 6.8.1 above, and changes thereto, shall b 6.8.2 e neyo~sl y of gd eyed .

4ry the PSRC and :;p==d by the Plant Manager prior to implementation and shall be reviewed periodically as set forth in administrative procedures.

6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:

a. The ihtent of the original procedure is not altered,

b. The change is approved by two members of the unit management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected,

c. The change is documented, reviewed by the PSRC and approved by'the Plant Manager within 14 days of implementation.

6.8.4 The following programs shall be established, implemented, and maintained:

a. Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the:

1. RCICsystemoutsidecontainmentcontainingsteamorwater[,

exceptthedrainlinetothemaincondenser[.

2. RHR system outside containment containing steam or water, except the line to the LRW system and headers that are isolated by manual valves.

3. HPCS system.

4. LPCS system.

5. Hydrogen analyzers of the combustible gas control system.

N 820406 PDR ADOCK 05000416 PDR

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GRAND GULF-UNIT 1 6-13

MISSISSIPPI POWER & LIGHT COMPANY

] Helping Build Afississippi P. O. B O X 16 4 0. J A C K S O N MIS SIS SIP PI 3 9 2 0 5 BGMhhmMB April 7, 1982 NUCLEAR PROCUCTION DEPARTMCedT U. S. Nuclear Regulatory Cocnission ,- @ ]< ,h

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w Of fice of Nuclear Reactor Regulation .,

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,Y Attention

Mr. Harold R. Denton, Director

Dear Mr. Denton:

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SUBJECT:

Grand Culf Nuclear Stati Units 1 and 2 ' 'h , ,U 5'

I Docket Nos. 50-416 and 50-41 -. J,ry \

File: 0260/15180 Plant Staff Working Hours AECH-82/132 In regard to the " Publication of Policy Regarding Nucicar Power Plant Staf f Working llours" contained in Volume 47. Number 33 of the Federal Register dated February 18.1982, page 7352 Mississippi Power & Light (MP&L) is '

changing its earlier commitment by incorporating the changes in the above I publication into the Crand Culf Technical Specifications (page 6-2 attached).

These same changes are being incorporated into the appropriate operating procedures for Crand Culf and will be submitted in a forthcoming FSAR amendment.

Yours truly.

L. F. Dale Manager of Nuclear Services RMS/SHH/JDR:rg Attachment rc: Mr. N. l.. Stampley (w/a)

Mr. R. R. McGebec (w/a)

Mr. T. R. Conner (w/s)

Mr. C. h. Taylor (w/a)

Mr. kirbard C. DeYoung. Director (w/a) 01itre of Inspectton & hnforcement l'. 5. Nuclear Regulat ory Compilaston Washington, D. C. 205 % of Mr. .l. P. O'keilly. Regional Administratur (w/a)

Office of Inspection and Enforcement fj (f.S. Nuclear I:rgulatory Commission Begion !!

101 Harlet t a St . , N.W. , Suite 11(*

Atlanta. Georgia 10101 ww"" S20407 i.mn.r u.eoi. souin utiiiti.. sv.t.m Epit 40W03000416 { P-

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UNIT STAFF (Co..tinued) . .- .

f. Ad.ainistrative procedures shall be developed and E p~1enented to limit the working hours of unit staff who perform safety related functions; e.g. , senior reactor cperators, reactor cperators, health physicists, a'uxiliary operators, ard by : ainteaance rarser...cl.

He:;uate shif t cever+ e shall t,e .atntai.4d it'<ut r:cti e taavy use of cvertir.e. f::.e.er, in the eve .t t'at unferestan ;r:ble .s rueire sustar.tial ; : _-ts cf :.ut' a to te used, t'e f:'it irg G.:icelines s hail be f cl h-ed: - .

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2. An individual shoeld r.ct be per..itted tc -crk :re t'En 15 h:srs

• in any 2*-h;cr' period, r.cr r:re than 14 heers in any OE-h'our pricd, ror :,re than 72 b:grs in a .y se.en :'ay ;eriod, all exchding shif t ter .e.ar tir.e.

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3. A break of at least eight h urs should be allo ed between -ork periods, including shif t turr.cver tir:.e.

. 4 'he .s e cf : . t'-( !':c'd t e c. .5 ; J e d :r s t'.:.si!ui t a c no; f:,r ;.* t . irs t.sff :. a *.c ft.

Ar.y deviation fr;. the atc

/ Plant Superintt-te .tI or 'ce .isguidelines deputy, ors'.allhigher t.elesels aut'.:rized t,y theent, of anage i i n a c c c rd a nc e s i t r. e s *. +: '. i t '.e d rt.c e d.:re s a d wi t h d: c . -e *. s t i er. o f i the tasis fcr grs-ti g *e deviat # :n. Cc.trols shall te it.:1 dic in I

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$1 ant Su;.erintendentsuch t?.atcrinch'vidual his designee ciertir.e to assure shallthatte revie.ed r:r.tniv excessive hou.s have not been assigr.ed. Reutine deviation frc. the above quicelines is net #6t'.crized.

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• UNIT STAFF (Continued)

f. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e.g., senior reactor operators, react,r operators, health physicists, auxiliary operators, and key maintenance personnel.

Adequate shif t coverage shall be maint,ined a without routine heavy use of overtime. llovever, in the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines shall be followed:  !

1. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time.

2. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period, all excluding shift turnover time.

3. A break of at least eight hours should be allowed between work periods, including shift turnover time.

4. The use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized by the ,

Plant Superintendent or his deputy, or higher levels of management, ,

in accordance with established procedures and with documentation of j the basis for granting the deviation. Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Plant Superintendent or his designee to assure that excessive hours have not been assigned. Routine deviation from the above guidelines is not authorized, i

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i CRAND CULF - UNIT I 6-2 Dlorgl MARKED UP COPY ATTAQlf.D - RETYPED FOR 1.F41 BILL 1T

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Afiasissippl P. O. B O X 184 0. J AC K S O N .AIS SIS SIP 9,

$7 April 30, 1982 s

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88UCLEAA PaooVCT)oM DEPAATMENT Q . /.

U. S. Nuclear Regulatory Commission ((

Office of Nuclear Reactor Regulation $ 'I , ,.S, bg! o

y }O Washington, D. C. 20555 .s R Attention: Mr. Harold R. Denton, Director O ' '

G #

.s N' eMi

Dear Mr. Denton:

c

SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 '

File: 0272/M001.0 FSAR and Technical Specification Changes Pertaining to RPS Circuit Response Times AECH-82/142 This transmittal is provided to inform the NRC of proposed changes to the CCNS FSAR and Technical Specifications as a result of actual delay response time measurements performed on the Turbine Stop and Control Valve Closure circuits and the RPV Water 1.evel Transmitter circuits. t During response time testing several of the main turbine stop and control valves circuits failed to meet the 70 msec. total maximum response time j specified in the CCNS Technical Specifications (Table 3.3.1-2). During '

similar testing, the RPV vater level transmitters circuits failed to meet the Technical Specification total response times of 300 msec.

As a result of the higher measured total response times, the CCNS Techni-cal Specification limits require revision in order that the limiting conditions for operation can be established for these circuits. The specification for total response time for the turbine stop and control valves (presently 60 and 70 maec., respectively) has been increased to 100 usec. for both circuit..

The RPV vater level transmitter total response time has been increased from 300 mace, to 1.05 seconds. These changes have been provided to Mr. Bottimore of the NRC and have been incorporated into the proof and review copy of the CCNS Technical Specifications. The revised proof and review copy of Table 3.3.1-2 is provided in Attachment 1.

The primary effect to be experienced from the longer response times will be on the transient analyses performed for Crand Gulf, due to the additional delay time prior to initiation of reactor scram.

The most limiting transient for Grand Gulf, which is the 1.oss of Feedwater Heating (Manual Flow Control), is controlled by the high flux initiated scram and is, therefore, unef fected by either response time ebenge being proposed.

8th s l

J 2 : ; 5 c e s s - } P, P -

b Member Middle South Utilities System

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AECH-82/142

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MI?.4ISOIPPI POWER O LIGHT COMPANY The limiting transients which are effected by a turbine control and stop valve scram trip signal are the Generator Load Rejection without Bypass.

Generator Load Rejection with Bypass, and the Turbine Trip without Bypass.

Each of these transients, which are pressurization transients, were reanalyzed using the CDYN Code to determine their effect on reduction in the minimum critical power ratios (MCPR). The Feedvater Controller Failure at Maximum Demand is the limiting transient effected by a longer RPV water level transmitter response time. Likewise, a reanalysis of this transient was performed with the longer total response time of 1.05 seconds. In each case, no significant change in CPR's was observed, and the MCPR's as reported in FSAR Table 15.0-1 (Amendment 55. April 1982) are accurate.

Therefore. for the CCNS transient analyses, it has been determined that no ef fect on the ability to safely operate the plant will be experienced from a change in these response times.

In order to avoid potential misinterpretation between the FSAR and the Technical Specifications. FSAR Table 7.2-5 is being deleted as it presently exists and the total response times, used as transient analysis input parame-ters, will be included in the response to NRC Question 211.134. The proposed FSAR revisions are provided in Attachment 2. The incorporation of these proposed revisions into the FSAR will be made pending the receipt of further guidance from the NRC in regard to post-operating license FSAR amendments.

Please advise if any additional information is required.

Yourn truly.

l k =

L. F. Dale Manager of Nuclear Services SAB/JCC/JDR:rg Attachments cc: Mr. N. L. Stamploy (w/a)

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

Mr. T. B. Conner (w/a)

Mr. C. B. Taylor (w/a)

Mr. Richard C. DcYoung. Director (w/a)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Wanhington D. C. 20555 Mr. J. P. O'Reilly Regional Administrator (w/a)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region 11 101 Marietta St.. N.W., Suite 3100 Atlanta. Georgia 30303

- {

.- *, 50 4 I' MISSISSIPPI POWER & LIGHT COMPANY Helping Build Afissinippi P. O. B OX 164 0. J AC K S ON. MIS SIS SIP PI 3 9 2 0 5 May 26, 1982 peUCLEAA PRODUCTiots (XPAATMDd?

Mr. Walter P. Haass, Chief Quality Assurance Branch Division of Engineering Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

SUBJECT:

Grand Culf Nuclear Station File 0272/0490/0491/15020 CCNS Tech Specs. 6.5.2.8 l AECM-32/225 As a result of recent telephone discussion between your Mr. J. Gilray, Mr. Benedict of Licensee Qualification Branch and MP&L's Mr. W. Edge and I.

MP&L is submitting the following interpretation of the Grand Gulf Technical Specification Section 6.5.2.8.

1 Technical Specification 6.5.2.8 begins: " Audits of unit activities j shall be performed under the cognizance of the SRC. These audits shall encompass: ..." . MP&L interprets these words as follows:

i "The SRC shall review the results of audits (or summaries

' thereof) of nuclear activities conducted in accordance with the MP&L Operational Quality Assurance Manual. Audits shall be conducted and results (summaries) shall be reviewed in the areas of: ... "

It is MP&L's understanding that the NRC does not choose to allow MP&L or other licensees to modify the Standard Technical Specification wording in 6.5.2.8, but does allow for the above type of interpretation.

Unless notified to the contrary, MP&L intends to implement the stated interpretation (as we have stated) tamediately. Further MP&L intends to submit a change in Revision 3 to the MP&L QA Topical Report (MPL-TOP-1 A) to state this interpretation and seek " formal" NRC acceptance.

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Member Middle South Utilities System

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AECH-82/225 Page 2 of 2 Please note this letter in draf t form was transmitted to your Messrs.

Gilray and Benedict. They concurred with this wording prior to this formal submittal. We appreciate the cooperation and assistance provided by you and members of your staff in this matter.

Yours truly, I

i T. E. Reave s , Jr.

Manager of Quality Assurance WEE:d1 cc: Mr. R. B. McGehee Mr. T. 8. Conner Mr. N. L. Staapley Mr. A. G. Wagner Mr. J. Gilray Mr. B. Benedict OQAM Ray. 3 File 0QAM Holders Manual File File l

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MISSISSIPPI POWER & LIGHT COMPANY b ]

Helping Build Afississippi D. O. B OX 164 0. J ACK S O N MIS SIS SIP PI 3 9 2 0 5 June 1, 1982 NUCLE AR Peo0UCTioN DEPARTMENT U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: Mr. Harold R. Denton, Director

Dear Mr. Denton:

L

SUBJECT:

Grand Gulf Nuclear Station

[ Units 1 and 2 r Docket Nos. 50-416 and 50-417

! File 0260/15180/L-860.0 Technical Specifications AECM-82/244 The purpose of this letter is to formally transmit proposed changes to Grand Gulf Nuclear Station Unit 1 Technical Specifications.

These proposed changes are included as an attachment to this letter in the form of current " Proof and Review" pages with the proposed changes identified.

Please advise if additional information is required.

Yours truly, L. F. Dale Manager of Nuclear Services WK/SHH/JDR:Im Attachments j

cc: Mr. N. L. Stampley (w/o)

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

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

Mr. T. B. Conner (w/o)

Mr. Richard C. DeYoung, Director (w/a)

Office of Inspection & Enforcement '

U.S. Nuclear Regulatory Commission Vashington, D.C. 20555 /

L Hr. J. P. O'Reilly, Regional Administrator (w/a)

Office of Inspection & Enforcement /

U.S. Nuclear Regulatory Commission # /

Region II 101 Marietta St., N.W., Suite 3100 Atlanta, Georgia 30303 AE3LI O 6 h- Member Middle South Utilities System A PDR

MISSISSIPPI POWER & LIGHT COMPANY

] Helping Build Afississippi EdhhikklMdB P. O. B OX 164 0. J AC K S O N. MIS SIS SIP PI 3 9 2 0 5 June 9, 1982 WM PROOUCTON O(PMTWENT U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: Mr. !!arold R. Denton, Director '

SUBJECT:

Grand Gulf Nuclear Station Units I and 2 Docket Nos. 50-416 and 50-417 File 0260/15180/L-860.0 Technical Specifications AECM-82/255 The purpose of this letter is to formally transmit proposed changes to Grand Gulf Nuclear Station Unit 1 Technical Specifications.

These proposed changes are included.as an attachment to this letter in the form of current " Proof and Review" pages with the proposed changes identified.

Please advise if additional information is required.  !

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Yours truly,

• L. F. Dale Manager of Nuclear Services WK/SIDl/JDR:la Attachments cc: Mr. N. L. Stampley (w/o)

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

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

Mr. T. B. Conner (w/o)

Mr. Richard C. DeYoung, Director (w/a) DC Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. J. P. O'Reilly, Regional Administrator (w/a)

Office of Inspection & Enforcement U.S. Nuclear Regulatory Connission Region !!

101 Marietta St., N.W., Suite 310 L , , _ j l Atlanta, Georgia 30303 p3g ADOCR'05000416 AE3L1 A PDR Member Middle South Utilities System

l P MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. B OX 1840. J AC K S ON. MIS SIS SIP PI 3 9 2 0 5 June 9. 1982 eu:tsAn maouenom ocumatwt U. S. Nuclear Regulatory Commission i Office of Nuclear Reactor Regulation Washington, D. C. 20555 Attention: Mr. Harold R. Denton, Director.

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 File 0260/0651/15180/1.-860.0 Phased Preoperational and Startup Testing Plan

Reference:

AECM-82/55 AECM-82/247 The referenced letter (attached) transmitted a description of Mississippi Power & Light Company's revised phased preoperational and startup testing program and the necessary Technical Specification vaivers for Phase I operations which consist of low power testing and non-nuclear heatup.

The purpose of this letter is to transmit further Techaical 3pecification vaivers that are required for Phase I operations only. Due to the fact that there vill be no significant decay heat or buildup of fission product inventory in the core during Phase I and that the reactor vill be maintained suberitical with an adequate margin of negative reactivity during non-nuclear heatup, these waivers vill create no hazard to the public health or safety.

Please advise if additional information is required.

I Yours truly.

.. F. Dale Manager of Nuclear Services JPM:1g Attachment cc: (See Next Page)

N N 820610 L pp' PDR ADDCK 05000416 A POR sember Middle South Utilities System

AECH-82/247

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. MISSISSIPPI POWER O L12HT COMPANY cc: Mr. N. L. Staapley Mr. R. B. McGehee Mr. T. B. Conner Mr. C. B. Taylor Mr. Richard C. DeYoung. Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington D. C. 20555 Mr. J. F. O'Reilly. Regional Administrator Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Region 11 101 Marietta St.. N.V., Suite 3100 Atlanta. Georgia 30303 -

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i Attachment to AECH-82/247 Technical Specifications Vaivers Required for Phase 1 Operations I. Testing / Plant Conditions during Phase I A. Fuel Loading B. Shutdown Margin Demonstrations C. Low Power Physics Testing i D. Non-Nuclear Heatup II. Technical Specification Exceptions / Clarifications A. For the non-nuclear heatup during Phase I testing, we request exemption from the Technical Specification requirements to have Primary Containment (Dryvell & Containment) operable, and all associated Technical Specifications.

B. Special test exception 3/4 10.3 - Shutdown Margin Demonstration.

We interpret this to allow shutdown margin demonstrations while applying Tech. Specs, required under Condition 5 (refueling). Thus we will perfore shutdown margin checks under the restrictions i imposed under condition 5.

C. It la our interpretation that testing requirements are also waived for any specifications for which an exception is taken.

D. 3.11.3 Solid Radvaste System The handling portion of solid radwaste shall be operable, however.

l a waiver is requested from the requirement to have the recainder of the solid radweste system operable until Phase 11.

E. 3.11.1.3 Liquid Radweste

! A waiver is requested to this specification. Any radioactive vaste

! which must be contained will be contained in suitable containers.

F. Special test exception 3/410.1 - Lower Power Physics Testing When operating under the provisions of this exception. we request  !

that the requirements for Operational condition 5 be applied for l technical specifications compliance. ,

i C. Table 1.2. Operational Condition  !

During non-nuclear hestup only that footnote *** be waivered to allow that the reactor mode switch may be placed in the Refuel l position while performing single rod scram time and friction testing provided that the one-rod-out interlock is operable.

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H. Additional waivers required while in Operational Condition 5

1. Table 3.3.2 Primary Containment Isolation Part 1 of the i

table and associated spec require isolation instrumentation.

A waiver is requested since that Primary Containment is not required, thus the instrumentation also should not be required.

2. 3.9.11.2 3.4.9.2 RHR Operability / Operating 3.9.11.1 A waiver is requested for these specifications since there is no decay heat which would require residual heat removal. The system will be operational, however, we do not necessarily wish to have the pumps operating.

3. 3.9.12 Horizontal Transfer Tube A waiver is requested for this specification since no irradiated fuel will be hand'!ed and all fuel movement will be done under dry conditions.

4 3.11.2.5 Mo* mal Ventilation Exhaust Treatment During Phase 1 with no itssion product inventory, the projectd cumulative dosis should not exceed .3MR during any 31 i day period, thus the normal ventilation exhaust treatment systems nee 1 not be operable.

5. 3.3.7.12 Gaseous Effluent Monitoring A waiver is requested for part 4 of this specification since

there will be no pottntial for radioactive gaseous effluents in i the turbine building during Phase 1 testing.

I. 3.5.2 ECCS -- Shutdown A waiver is requested to the requirement for the required

. subsystem / systems listed in this specification to be operable.

The fact that fuel in the core during Phase I is unirradiated means 1 that the ECCS safety function is not needed to protect pubite health and safety.

l MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. BOX 1840. J ACKSON. MISSISSIPPI 39205 June 10, 1982 eocum eaooucnom ountwo U.S. Nuclear Regulatory Comission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: Mr. Harold R. Denton, Director

SUBJECT:

Grand Gulf Nuclear Station

' Units 1 and 2 Docket Hos. 50-416 and 50-417 File 0272/M-632.0/M-222.0 Transmittal of Proposed Technical Specification Change.

Post-LOCA Vacuum Relief and Drywell Purge Vacuum Breaker Dosition Indication AECH-82/186 This letter transmits a proposed revision to the GGNS Technical Specifications pertaining to the drpell post-LOCA vacuum breakers and supporting justification. Associated # th this issue are certain in-strumentation changes for the check valves in the post-LOCA vacuum relief and drywell purge systems.

Both the post-LOCA vacuum relief and the drywell purge systems consist of a motor cperated butterfly type isolation valve in series with the vacuum breaker check valve (s) which provides drywell vacuum relief.

Both the vacuum breakers and isolation valves were provided with position indication. (See GGNS FSAR Figure 6.2-81).

During onsite testing of the vacuum breakers (check valves F001A.B. F002A,8, and F004A B in FSAR Figure 6.2-81) to assure actuation on 1.0 psid pressure, several factors caused sufficient resistance to prevent the proper opening and closing of the valves. The valves were reworked and modified to operate within their design requirements, however, the lever arms when contacting the position switches did not allow the valves to fully close. Therefore, the position switches and lever arms were subsequently removed from the check valves.

The motor operated isolation valves which are in series with the check valves, operate by the same 1.0 psid pressure and are provided with position indication. Based on this, Mississippi Power & Light (MP&L) contends that position indication on the check valve vacuum breakers is not required.

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AECM-82/186 9'

l MI551551PPI POWER & LIGHT COMPANY l

A proposed revision to Section 3/4.6.5, "Drywell Post-LOCA Vacuum Breakers " of the GGNS Technical Specifications is attached.

The Limiting Condition for Operation and Surveillance Requirements $

are revised to indicate the use of position indication on the isolation valves instead of the vacuum breakers. The Technical Specifications on the Drywell Purge System are presently correct and no revision is required.

In addition, two other corrections are provided in Technical Specification Section 4.6.5, which indicate a revision to the surveillance requirements based on the GGNS post-LOCA vacuum breaker design.

Subsection 6.2.5.5 of the GGNS FSAR was revised in Amendment 55 to show position indication only on the isolation valves in the post-LOCA and drywell purge systems. FSAR Figure 6.2-81 will be revised in a future amendment to delete position indication on the check valves discussed above.

Notwithstanding the above, HP&L intends to provide position indication with qualified non-contact type switches on the vacuum breakers as an operator aid. Switches for this application, qualified to NUREG-0588, are currently not available but are expected to be provided during the first regularly scheduled refueling outage.

This modification is being proposed as an operator convenience and is not considered a licensing requirement.

Please advise if any additional information is required. I Yours truly, L. F. Dale Manager of Nuclear Services SAB/JGC/JDR:Im Attachment l

cc: Mr. N. L. Stampicy (w/a)

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

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

Mr. T. B. Conner (w/a) l Mr. Richard C. DeYoung, Director (w/a) l Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. J. P. O'Reilly, Regional Administrator (w/a)

Office of Inspection & Enforcement U.S. Nuclear Regulatory Comission Region !!

101 Marietta St., N.W., Suite 3100 Atlanta, Georgia 30303 1

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\uc ear in"ormation and Resource Service 1345 Comet.M Awu N?. 4m Fe i.e ,;;r E : 20:n (202' 23i '552 August 6, 1984 James M. Felton, Director Division of Rules and Records Office of Adminstration OF INg U.S. Nuclear Regulatory Commission ET REQucsr Washington, D.C. 20555 hb & -S4.g(~44$

FREEDOM OF INFORMATION ACT REODEST

Dear Mr. Felton:

b W f -/o f Gt Pursuant to the Freedom of Information Act, 5 U.S.C. 522, as amended, the Nuclear Information and Resource Service re-quests the following documents regarding the Grand Gulf nuclear plant. Please consider " documents" to include reports, studies, test results, correspondence, memoranda, meeting notes, meeting minutes, working papers, graphs, charts, diagrams, notes and summaries of conversations and interviews, computer records, and any other forms of written communication, including internal NRC Staff memoranda. The documents are specifically requested from, but not limited to, the Office of Inspection and Enforcement (I&E); Office of the Executive Legal Director (OELD); and Office of Nuclear Reactor Regulation (NRR).

Pursuant to this request, please provide all documents tre-pared or utilized by, in the possession of, or routed through the NRC related to:

1. The receipt, analysis (legal and technical) and denial of one or more "Show Cause" petitions filed by Cynthia Stewart on behalf of Jacksonians for Livable Energy Policies (JULEP) requesting action on the Grand Gulf plant.

In our opinion, it is appropriate in this case for you to waive copying and search charges, pursuant to 5 U.S.C.

552 (a) (4) (A) "because furnishing the information can be considered as primarily benefiting the general public." The Nuclear Information and Resource Service is a non-profit or ganization serving local organizations concerned about r

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2-nuclear power and providing information to the general public. Information required by 10 CFR 9.14a was provided by letter dated August 3, 1984.

Sincerely, 6

Nina Bell Assistant Director cc: File 1

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\ucear n"ormation and Resource Service 13:6 Cc w JR '

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Dt as X ' ~5E August 6, 1984 James M. Felton, Director Division of Rules and Records Office of Adminstration U.S. Nuclear Regulatory Commission OF INmpg4 #2V ACT REQucsr Washington, D.C. 20555 D - P c.,f-4 4 S FREEDOM OF INFORMATION ACT REOUEST b 'd' f-/o f y

Dear Mr. Felton:

Pursuant to the Freedom of Information Act, 5 U.S.C. 522, as amended, the Nuclear Information and Resource Service re-quests the following documents regarding the Grand Gulf nuclear plant. Please consider " documents" to include reports, studies, test results, correspondence, memoranda, meeting notes, meeting minutes, working papers, graphs, charts, diagrams, notes and summaries of conversations and interviews, computer records, and any other forms of written communication, including internal NRC Staff memoranda. The documents are specifically requested from, but not limited to, the Office of Inspection and Enforcement (I&E); Office of the Executive Legal Director (OELD); and Office of Nuclear Reactor Regulation (NRR) .

Pursuant to this request, please provide all documents pre-pared or utilized by, in the possession of, or routed through the NRC related to:

1. The receipt, analysis (legal and technical) and denial of one or more "Show Cause" petitions filed by Cynthia Stewart on behalf of Jacksonians for Livable Energy Policies (JULEP) requesting action on the Grand Gulf plant.

i In our opinion, it is appropriate in this case for you to waive copying and search charges, pursuant to 5 U.S.C.

552 (a) (4) ( A) "because furnishing the information can be considered as primarily benefiting the general public." The Nuclear Information and Resource Service is a non-profit organization serving local organizations concerned about ,

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i, nuclear power and providing information to the general public. Information required by 10 CFR 9.14a was provided by letter dated August 3, 1984.

i sincerely,

)

Mr2 I Nina Bell i Assistant Director cc: File r

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