ML20029A798

Application for Amend to License NPF-29,incorporating Developments Into Commitment for Reg Guide 1.97 Flux Monitoring & Permitting Implementation for Final Resolution of Appeal W/O Addl Change to OL

ML20029A798
Person / Time
Site:	Grand Gulf
Issue date:	02/27/1991
From:	Cottle W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029A799	List: ML20029A798 ML20029A800
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GNRO-91-00031, GNRO-91-31, NUDOCS 9103040273
Download: ML20029A798 (10)

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- Entergy g;;gaua= 'a*-

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ici tha 37 M ir W. T. Cottle .

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t.M i t *N gx' s. o February 27, 1991-U.S. Nuclear Regulatory Commission Mail: Station Pl-137

' Washington, D.C. 20555 Attention: Document Control Desk

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SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416-License No. NPF-29 Modification of Regulatory Guide 1.97 Commitment for Flux Monitoring; Propesed Amci.dment to Operating License Condition 2.C(36) PCOL-91/01, Revision 0 GNRO-91/00031 Gentlemen:

The issue of Ragulatory Guide (RG) 1.97 neutron flux monitoring has been under discussion between the BWR Owners' Group (BWROG) including Entergy Operations and the NRC Staff for several years. The BWROG had provided alternate require ',rsts on flux monitoring capability for RG 1.97 in Licensing Topical Leport NED0-31558, which was endorsed by Entergy Operations for Grand Gulf Nuclear Station (GGNS) on April 28, 1988 ,

(AECH-88/0083). The helC Staff rejected the BWROG positions by a Safety Evaluation Report on' January 29,f 1990, and the.GGNS positions by letter - '

on February 2, 1990 (MAEC-90/0025)._

On August. 16, 1990,- the BWROG' filed an _ appeal- of the NRC Staf f's position on NEDO-31558i In a September 13, 1990, letter to the BWROG Chairman, Dr ' Thomas E. Murley of the NRC indicated that his decision on the appeal would be made within two months and-also stated that licensees could defer plant-specitic actions until his decision was reached. As of- this-date, the NRC has not yet reached a.docision on the appool.-

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4 February 27, 1991 GNRO-91/00031 page 2 of 4 As discussed in our series of quarterly stat us reports. Entergy Operations has worked in good faith to moot eur commitment of upgrading existing CGN."1 flux monitoring capability by ss art-up from the fif th refueling outage (RF05). In order to ensure trat t.ho highly customtzod equipment involved is ordered, fabricated, and c'olivnrod in time for RF05 Installation, a purchase agreement is nooded with the equipment supplier by approximately March 1, 1991. We anticipato largo pnnaltins for cancellation once an agrooment has been oxocuted; therefore, Entergy Operations would face significont financial risk wit.hout t.ho NRC decision on the BWROG appeal. As discussed in our quarterly status report dated February 6, 1991 (GNRO-91/00006), Entergy Operat lons will not ontor into such a purchaso agrooment. for this reason until af ter the appeal decision is reached. Wo bolicyo this approach t.o be consistent with Dr. Hurley's statomont- regarding the deferral of plant-specific actions in the Sepcomber 13, 1990, NRC lottor to the BWR00 Chairman.

Based on discussion with the NRC project tianager which ir.dicated that the NRC decision on the appeal will not be made until after March 1, 1991, Entorgy Operations is by this letter submitting a proposed chango to the GGNS Oporating I.iconso. This chango will incorporato the dovolopments dJacussed abovo int.o our commitmont for RG 1.97 flux monitoring, and allow for the GGNS implomontation of the final resolution of the 'BWR00 appeal without additional chango to the operating license.

In accordance wit.h the provisions of 10CFR50.4 the original of the requestod amendment is attached. The at t ached OLCR-NI.-91/01 providos the techn.ica1 justifIcaLlon and dlacusston to support the roquestod amendmen t.. This request for amendment has hoon reviewed and accepted by the CGNS Plant Safety Review Committoo and the Snfoty Review Commit ten.

. Based on the guidol-1nos prosont'in 10CFR50.92, Entergy Operations has concluded that this proposnd amondment involvos ne significant hazards.

If you have any questions or dentro additiona! Information, ulcaso adviso.

Yours truly, 1.

/ c.a=> ?~~' %m WTC/IIEK/ams a attachment:

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~ ' February:27, 1991 GNRO-91/00031 Pago 3 of 4 cc ~ Mr. D. C. Illntz (w/a)

Mr. J. Mathis- (w/a)

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

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

Mr.11. L. Thomas (w/o)

Mr. Stcy:crt D. Ebneter (,:/n)

Regional Administrator U.S. Nuclear Regulatory Comminston Region 11 101 Marietta:St., N.W., Suite 2900 Atlanta, Georgin 303.13 Mr. L. I.. Kintnnr, Project Hannger (w/a)

Of fico of Nucionr Reactor Regulation U.S..Nucionr Roguintory Commisnlon

. Mail Stop 11D21 Washington, D.C.- 20555 L-l l-l :'

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. BEFORE Tile UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCRET NO. 50-416 IN Tile MATTER OF MISSISSIPPI POWER & LIGitT COMPANY and SYSTEM ENERGY RESOURCES, INC, and SOUTit MISSISSIPPI ELECTRIC POWER ASSO'IATION J

and ENTERGY OPERATIONS, INC.

AFFIRMATION I, W. T. Cottle, being duly r, worn, state that I am Vice President, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entargy Operations, Inc. , -System Energy Resources, Inc. , and South Mississippi Electric Power Association I am authorized by Entergy Opervtlons, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Operations GGNS of Entergy Operations, Inc. ; and thec the statements made and the matters set forth theroin are true and correct to the best of my knowledge, informatian and belief, rJP Idlecc:--

W. T. Cottle STATE OF MISSISSIPPI l COUNTY OF CLAIBORNE l SUBSCRIBED AND SWORN To before me in and for the County i and State above named, this _ M , a Notary day ofPublic,M eunwu , 1991.

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J G1k .M ton CL M NotaryQ11,c]

My commission expires:

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Attachment to GNRO-91/00031

.0LCR - NL-91/01 Modification of Regulatory Guide 1.97 Commitment for Flux Monitoring

1. SUBJECT Facility Operating License No. NPF-29; Operating License Condition 2.C(36) - Emergency Response Facilities; Attachment 1, Item (c)(4).

II. biSCUSSION The specific requirements necessary for BWRs to meet Regulatory Guide (RG) 1.97 for neutron flux monitoring have been discussed for some time betwocn the NRC Staf f and various licensees. Entergy Operations has been involved in many of these discussions, both as an individual licensee and as a member of the BWR Owners' Group (BWROG). The BWROG's positions were formalized and submitted to the NRC Staf f in Licensing Topical Report NEDO-31558 dated April 1, 1988 (Reference 1). Entergy Operations followed with the submittal of a Grand Gulf Nuclear Station (GGNS) plant-specific design evaluation for NEDO-31558 (Reference 2). The NRC Staff rejected both those submittals in January and February 1990 (References 3 and 4).

Af ter some discussion with the NRC Staf f (References and 6), the BWROG flied an appeal of the Staff's position on NEDO-31558 on August 16, 1990 (Reference 7). The decision on this appeal is still pending (Reference 8) and is not now expected to be made until after March 1, 1991. Final resolution of the appeal will determine the BWR requirements necessary for compliance with RG 1.97 for flux monitoring.

As discussed in the latest .;GNS quarterly status report on flux x monitoring (Reference 9), antergy Operations is faced with the need to enter into a purchasc agreement by approximately March 1, 1991, tu order to have the highly customized excore neutron flux monitoring system (NFMS) equipment available for installation-in the fif th refueling outage (RF05) por our. existing commitment.

There is a significant financial risk involved in entering into such an agrooment without the NRC decision on the BWRCG appeal.

Therefore, Enterpy Operations has not done so. We feel this is consistent with tne September 13, 1990, letter-by Dr. Thomas E.

l 'Murley of the NRC (Reference 8), which stated that licensees could defer _ plant-specific actions until an appeal decision was reached.

The current operating license condition specifies that GGNS will l implement the requirements of RG 1.97 for flux monitoring prior to start-up from RF05, and GGNS has previously cc.nmitted to accomplish this by the installation of a new excore NFMS (References 10 & 11).

The proposed change will continue to commit GGNS to impicmenting p the requirements of RG 1.97 for flux monitoring, and will allow ,

flexibility for GGNS and the NRC Sta ff as noted below:

1. The GGNS implementation schedule will be removed from the l Operating License to allow for a resnint. lor of the pending BWROG appen1, and G9102141/SNLICFLR - 6 l-1

Attachment to GNRO-91/00031

2. The specific GGNS implementation actions and associated shedules to meet RG 1.97 for r.ux monitoring requirements will be removed from the Operating ulcense to al'1ow for the implementation of RG 1.97 r quirements consistent with the final resolution of the P.ROG appeal (which might be different from the existin;; GGNS c immitment of a new excore NFMS). The GGNS implementation act,ons and schedules would be submitted to the NRC Staff for reyfew and approvel within 90 days after the final resolution of t he BWROG appeal, e

Ill. JUSTIFICATION As discussed above, the specific requirements necessary to meet RG 1.97 for flux monitoring for BWRs have not been conclusively determined. The BWROG and Entergy Operations feel that the positions in NEDO-31558 and the related GGNS evaluation are adequate, while the NRC Staf f has not previously agreed with these positions. The final resolution of the BWROG appeal will establish these necessary requirements for RG 1.97 flux monitoring for '1WRs including GGNS.

Therefore, the GGNS implementation of an excore NFMS as currently committed may result in the expenditure of considerable resources on an offort which could subsequently prove to be unnecessary.

Entergy Operations feels that thia may pot ntfally result in an overall negative impact on GGNS by reducing the resourcen available for other activities which might have a more positive benefit on plant operaticas.

Tne proposed enange will continue to require GGNS to impicment necessary RG 1.97 flux monitoring requirements, but only after these requireaents are established by the final resolution of the BWROG appeal. The proposed change also provides for NRC review and approval of GGNS actions and schedules for the implementation, which will ensure that the NaC Staf f agrees that these actions are in accordance with the final BWROG appeal resolution before their implement stion.

IV. SIGN'FICANT HAZARDS CONSIDERATIONS The proposed at r.dment would modify the GGNS Operating License Condition 2.C(36) Attachment 1, Item (c)(4) to ellow for the final resolution of the BWR00 appeal of the PRC Stoff's position on NEDO-31558 (and the final deterMnation of notessary BWR requirements for RG 1.97 flux monitoring) before the impleme'tation of +.hese requirements at GGNS. The proposed amendment includes a requirement for the submittal of future GGNS actions and schedules for RG 1.97 flux monitoring implementation to the NRC Staff for review and approval.

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Attachment to GNRO-91/00031 In accordance with the requirements of 10CFR50.92, the following discussion is provided in support of the determination that no significant hazards are created or increased by the changes proposed in this amendment request.

1. No significant increase in the probability or the consuquences of an accident previously evaluated results from this proposed change bacause:

A change in the existing GGNS commitment to install an excore NFMS before start-up from RF05 does not involve a significant increase in the probab111ty of an accident previously evaluated since the previously proposed excore NFMS would not af fect reactor operation and is no' an initiator for any provicusly evaluated accidents. The previously proposed excore NFMS would provide post-accident indication of reactor power and would not have provided any signals to actuate engineered safety systems or to trip tne reactor. Furthermore, reactor trip signals from the currently installed neatron r.ouitoring system to the reactor protection system would not have been changed by the addition of the proposed excore NFMS.

The change in the existing GGNS commitment to install an excore NFMS before start-up from RF05 would not cause the consequences of an accident previously analyzed to increase signif:cantly since:

a. The NRC Staff has recognized (References 3 an' 6) that an upgraded or new flux monitoring system would e of value primarily for currently undefined accidents which are outside the design basis,

b. The existing SRM/IRM system is expected to function during at least the initial phase of an accident (including a LOCA) to indicate subcritical reactor power. Long term post-LOCA monitoring is available through the APE:1 channels where operator action is required at the APRM downscale alarm. In addition, other measures and indications can provide the operator with reactor power information as discesand below:

1. Tht present control rod position indication system provides the reactor operator with information that all rods are inserted.

11. Qualified instrumentation such as reactor pressure, suppression pool temperature, and safety relief valve (SRV) actuation provide the reactor operator with post-accident information for assessment of reactor power.

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Attachment to GNRO-91/00031

c. _Under a potential event'as. considered in the NRC Safety-Evaluation Report on NEDO-31558 (Reference 3), the GGNS symptom based Emergency Procedures (EPs) provide appropriato conservative actions if reactor power cannot be directly measured in a post-accident condition. The EPs contain action steps which mitigato the symptomatic effects cf design basis events (such as LOCA) and beyond design basis events (such as ATWS) along with potential degraded core events.-

Therefore, the probability or the _ consequences of an accident

. proviously etaluated will not be significantly increased by this change from the existing commitment to install an excore NFMS before start-up f rom RF05. GGNS Implementation of RG 1.97 flux monitoring under the proposed change would be required as determined necessary by the final resolution of the issue, as reviewou and approved by the NRC Staff.

2. This proposnd change will not create the possibility of a new or dif ferent kind of accident than any prot a ws' e evaluated becauso:

The excore NFMS previously c.. smit $nd to would 'arovide supplemental post-accidenc monitorfnc capabil4ty only, by-providing additional operattt informat!?a in order to perform possible mitigativo actions during undefined, beyond-design-

, basis events. Its installation would not proclude or prevent any action. As such, the proposed chango (which would allow GGNS implementation of RG 1.97 flux monitoring af ter the final determination of necessary BWR RG 1.97 flux monitoring requirements) will not create the possibility of a new or dif ferent_ kit.d of accident. During the evaluation period to determine the conclusive RG 1.97 flux monitoring requirements and any period nocessary for implementation, the existing SRM/IRH neutron monitoring system will remain unchanged from the configuration that was previously evaluated in the FSAR.

Therefore, the possibliity of a now or dif ferent kind of accident than any previously evaluated would not be changed by the proposed change from the existing commitment to install an excorn NHS prior to start-up f rom' RF05. _ GGNS impicmentation of RG 1.97 flux monitoring under the proposed change would be required as determined necessary by the final resolution of the issue, as rovicwed and approved by-the NRC Staff.

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4 Attachment to GNRO-91/00031

3. This proposed change does not involve a significant reduction in the margin of safety because: ,

The current GGNS margin of safety is established by the existing SRM/1RM neutron monitoring system and the shutdown l- margin of the control rod system. The design, function, and operation of the existing GGNS 1RM/SRM neutron monitoring syatem wJil remain the same as that described in the UFSAR. No additional reactor protection tri; functions would be performed '

by the excore NFMS previously comnitted to for RF05 Installation. EP actions are conservative with respect to the use of the existing neutron monitoring system for verification that the teactor is shutdown. Given that the excore NFMS-previously committed to has not been determined to provide necessary information to operators for any defined _ accident scenario (References 1, 2, 3, 5, 6, and 7), GGNS operation with current procedures and the existing neutron monitoring system maintains the existing margin of safety.

Therefore, the margin of safety is net significantly reduced by the_ proposed change from the existing commitment to install an -

excore NFMS prior- to start-up f rom RF05. GGNS Implementation of RG 1.97 flux monitoring under the proposed change would be required as determined necessary by the final resolution of the issue, as reviewed and approved by the NRC Staff.

V. REFERENCES

1. BWROG/GE NEDO-31558 dated April 1, 1988; "BWR Owners' Group Topical Report Position on NRC RG 1.97 Rov. 3 Requ!romonts-for Post- Accident Neutron Monitoring System"

-2. AECM-88/0083 dated April 28, 1088 GGNS Plant Specific Design Evaluation for NED0- 1558

3. NRC letter dated January 29, 1993 (MAEC-90/0025); issuing the NRC-Safety Evaluation Report on C#ROG NEDO-31558

- 4. NRC letter: dated. February 2,1990; regarding Denial of Entergy -

Operations OL Amendment Request of December 20, 1989

5. BWR Owners' Group Letter (BWROG-9025/MFN-008-90) dated '

February 21, 1990 entitled " Position on NRC Regulatory Guide 1.97 Rev. 3 Requirements for Post-Accident Neutron Monitoring System"

6. NRC letter = dated May 21, 1990 to the BWROG entitled, " Position on the Regulatory Guide 1.97 Rev. 3 Requirements for Post Accident Neutron Monitoring System"

7. BWR Owners' Group letter (see BWROG-90107) dated Augur,t 16, 1990 entitled " Appeal of Staf f Position on Upg raded Noutron Flux Monitoring Systems" 09102141/SNLICFLR - 10

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P Att achment- to GNRO-91/00031 8 ~. NRC let ter dated September 13, 1990 to the BWROG Chairman;-

regarding.the BWROG Appeal of the Staff's Position on Post-Accident Neutron Flux Monitoring Systems

9. GNRO-91/00006 dated February 6, 1991; Quarterly Status Report for RG 1.97 Neutron Monitoring System for the Period Ending December 31, 1990 .

10. AECM 90/0116 dated June 22, 1990; Modification of RG 1.97 Compliance Schedule for Neutron Monitoring; Proposed Amendment to the Operating License Condition 2.C(36) PC01.-90/01, Revision 7

11. NkC Intter dated November 7,1990 (HAEC-90/0281); lasuing Amendment No. 72 to Facility Operating bicense No. NPF-29-(As corrected by NRC _ letter dated November 14, 1990, HAEC-90/0284).

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