ML20059N497

Safety Evaluation Accepting Util Response to Generic Ltr 88-01,w/listed Exceptions

ML20059N497
Person / Time
Site:	Grand Gulf
Issue date:	10/01/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059N494	List: ML20059N493 ML20059N497 ML20059N510
References
GL-88-01, GL-88-1, NUDOCS 9010160119
Download: ML20059N497 (3)

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UNITED STATES NUCLEAR REGULATORY COMMISSION j

t,, . ;f wAssiwoTow. o. c. rosss i g / ENCLOSURE 1 L' *...*

f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION  ;

REGARDING RESPONSE TO GENERIC LETTER 88-01 i i

ENTERGY OPERATIONS. INC.

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

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1.0 INTRODUCTION

5 Thelicensee(SystemEnergyResourcesInc.beforeJune'6,1990,andEntergy l Operations, Inc. on or af ter June 6,1990), submitted its initial response to l NRCGenericLetter(GL)88-01,"NRCPositiononIGSCCin8WRAusteniticStainless  ;

Steel Piping," for Grand Gulf Nuclear Station, Unit 1 (GGNS Unit 1) by letter  !'

dated August 8,1988, and additional information by letters dated July 24, 1989 and April 23, 1990. GL 88-01. requested the licensees and construction  :

permItholderstoresolvetheIGSCCissueforBWRpipingmadeof-austenitic .j stainless steel that is 4 inches or larger in nominal diameter and contains .

reactor coolant at a temperature above 200 degrees Fahrenheit during power  ;

operation regardless of Code classification. The licensee was requested to  !

address the following' i

1. The current plans regarding pipe replacement and/or other measures taken

.l to mitigate IGSCC and provide assurance of continued long-term integrity i and reliability. ~

2. TheInserviceInspection(ISI)Programtobeimplementedatthenext-refueling outage for austenitic stainless steel piping covered under the scope of this letter that conforms to the staff positions on inspection  !

schedules, methods and personnel, and sample expansion included in i GL 88-01. i L  :

3. AchangeinTechnicalS>ecifications(TS)toincludeastatement.inthe  !

, TS section 4.0.5 that tie ISI Program for piping covered by the scope of-  !

GL 88-01 will be in conformance with staff positions on schedule, methods i l-and personnel, and sample expansion included in GL 88-01 (See model BWR .  !

StandardTechnicalSpecificationenclosedinGL88-01). It is recognized  ;

that the Inservice Inspection and Testing sections may be removed from ,

the TS upon implementation of the Technical Specifications Improvement  !

Programs. In this case, this requirement would remain with the 151 ,

section when it is included in n alternative document.

4. The confirmation of your plans to ensure that the TS related to leakage  !

detection will be in conformance with the staff positions on leak  ;

detection included in GL 88-01.

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l s' 5. The plans to notify the NRC in accordance with 10 CFR 50.55a(g) of any

) flaws identified that do not meet IWB-3500 criteria of Section XI of the j Code for continued operation without evaluation, or a change found in the

condition of the welds previously known to be cracked and your evaluation I of the flaws for continued operation and/or your repair plans. '

4 2.0 DISCUS $10N I

The licensee's response to GL 88-01 has been reviewed by the staff with the assistance of its contractor, Viking S The attached Technical Evaluation Report (ystems International (VSI).TER) provides VSI's licensee's response to GL 88-01. The staff has reviewed the TER and concurs i with the evaluations, conclusions, and recommendations contained in the TER i exceptforrecommendation(3)ofSection4. The staff will review the  !

j expression for fatigue crack growth used in the evaluation of actual flaws '

when (2)andthey(5) of the TER have been completed.are submitted By letter dated April 23, to the 1990, NRC for review a the licensee provided an acceptable inspection schedule for Category D weld No. XN9-13.

The staff finds the following items to be unacceptable: 1

1. The licensee's position not to amend the Technical Specifications (TS) to includeaninserviceinspection(ISI)statementasrequiredinGL88-01.

2. The licensee's position not to amend the TS to include a requirement of limiting the increase in unidentified leakage to 2 gpm over a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less as required by GL 88-01.

3. The licensee's position not to accept operability of monitoring instruments requirements outlined in GL 88-01. l I

For a detailed discussion of these items see sections 2.0 and 3.0 of the TER attached to the Safety Evaluation.

O The staff has reevaluated the frequency of leakage monitoring. After discussions with several BWR operators, the staff concluded that monitoring every four hours creates an unnecessary administrative hardship on the plant operators. Thus, reactor coolant system leakage measurements may be taken every eight hours instead of every four hours as. required in GL 88-01.

The licensee took exception to Regulatory Guide.l.45, " Reactor Coolant Pressure Boundary Leakage Detection Systems " Position 7 which states that indicators andalarmsforeachleakagedetectIonsystemshouldbeprovidedinthemain ,

control room. The licensee stated that the drywell equipment drain sump level monitoring system does not have direct level indication in the control room.

However, the drywell equipment drain sump level indicator and recorder are located in the auxiliary building for determining identified leakage as a subsystem of the leakage detection system. The recorder is monitored for level 4 and flow every four hours per Technical Specification surveillance requirements. I l

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Furthermore,thelicensee'ssurveillanceprocedure(06-0P-1000-D-0001) provides the operator with the formula for calculating the total flow. The staff has reviewed this deviation from Regulatory Guide 1.45 and concludes it is acceptable.

3.0 CONCLUSION

Based on the review of the licensee's response to NRC Generic Letter 88-01, the staff concludes that the response is acceptable with the exceptions as identified in Section 2.0 above. The licensee should submit TS changes to resolve items 1 2 and 3 in Section 2.0. The staff also concludes that the proposedIGSCCInsp,ectionandmitigationprogramwillprovidereasonable assurance of maintaining the long-term structural integrity of austenitic -

stainless steel piping in the Grand Gulf Nuclear Station, Unit 1.

Dated: October 1, 1990 Principal Contributors: T. McLellan W. Koo 9

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