ML20067C273
| ML20067C273 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/06/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 GNRO-91-00006, GNRO-91-6, NUDOCS 9102120009 | |
| Download: ML20067C273 (7) | |
Text
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T Entergy Operations
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W. T. Cottle February 6, 1991 U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C.
20555 Attention:
Document Control Desk
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50 416 License No. NPF-29 Quarterly Status Report for RG 1.97 Neutron Monitoring System for the Period Ending December 31, 1990 GNRO-91,00006 Gentlemen:
As discussed in AECM-89/0013 dated February 6, 1989. Entergy Operations requested a change in commitment related to Regulatory Culde (RG) 1.97 for the implementation of an excore Neutron Monitoring System in lieu of an incore type system.
The NRC approved the Entergy Operations request as discussed in a letter dated July 21, 1989 (MAEC-89/0228), and requessed Entergy Operations to continue submitting quarterly status reports for NRC review.
In response to this request, Attachment 1 provides the RG 1.97 Neutron Monitoring System Quarterly Status Report for the period ending
-December 31, 1990.
This report includes major actions completed to date for the OGNS excore system and those major actions necessary to complete implocentation of the system. provides the estimated m(.astone schedule of these activities.
As discussed below, these efforts may be affected by the ongoing NRC review of the BWR Owners' Group (BWROG) appeal related to RG 1.97 and neutron monitoring requirements.
On August 16, 1990, the BWROG filed an appeal of the NRC Staf f's position on BWROG Topical Report NED0-31558.
This report had provided alternate requirements on neutron monitoring for RG 1.97, and was previously endorsed by Entergy Operations.
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-specific actions until his decision was reached.
As of this date, the NRC has not yet reached a decision on the appeal.
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G9101071/SNLICFLR - 1 9102120009 910206 PDR ADOCK 05000416 PDR
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8 4
s February 6,-1991 GNRO-91/00006 Page 2 of 4 As discussed in this series of quarterly status reports, Entergy Operations has worked in good fait h to moot our current Operating Licenso condition of upgrading existing neutron monitoring capability by the end of the fifth refueling outage (RF05).
At this point, our current commitment schedule can be met only if Entergy Operations enters into a purchase agreement with the supplier by approximately March 1, 1991.
This date is necessary to ensuro the equipment is ordered, fabricated, and delivered in time for RF05 installation.
The equipment involved is highly customized and we anticipate large penalties for cancellation once a purchase agreement has been executed.
Therefore, we cannot proceed to ontor into such an agrooment without significant financial risk until the NRC decision on the BWROG appeal is made.
We bellove this approach to be consistent with Dr. Murley's romark regarding the deferral of plant-specific actions in the September 13, 1990, NRC letter to the BWR00 Chairman.
Due to the above, Entergy Operations requests notification of the NRC decision on the BWROG appeal prior to March 1, 1991.
If such notification cannot be made by this dato, we will submit an Operating Licenso amo:dment request to adjust our commitment schedulo past RF05 or establish a now commitment for neutron monitoring capability consistent with the final resolution of the BWROG appeal.
Should the NRC accept the BWROG appeal (and consequently NEDO-31558 positions) prior to March 1,1991, Entergy Operations anticipates submitting an amendmert request to be consistent with the appeal results.
in accordance with Operating License Condition 2.C(36), Entergy Operations is continuing to pursun Implomontion of an excore Neutron Monitoring System for RO 1.97 as discussed above and in the Attachments, plonso adviso if you require any additional information on this matter.
Yours truly,
<-4.::s y
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WTC/IIEK/ tkm attachments: 1.
RG 1.97 Neutron Monitoring System Quarterly Status Report 2.
Estimated Milestone Schedule for Installation of Excore Neutron Monitoring System for RG 1.97 cc:
(Sco Next page) 09101071/SNLICFLR - 2
m.
February 6, 1991 GNRO-91/00006 Pago 3 of 4 cc:
Mr. D. O. Illntz (w/a)
Mr. J. Mathis (w/a)
Mr. R. B. McGohoo (w/a)
Mr. N. S. Reynolds (w/a)
Mr.11. L. Thesas (w/o)
Mr. Stewart _D. Ebneter (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marlotta St., N.W., Suito 2900 Atlanta, Georgia 30323 Mr.
L.- L. Kintner, Project Manager (w/a)
Offico of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Hall Stop 11D21 Washington, D.C.
20555 Mr. G. J. Beck, Chairman (w/a)
BWR Owners' Group Philadelphia Electr.tc Company 955-65 Chesterbrook Doulevard Wayne, Pennsylvania 19087-5691 G9101071/SNLICFLR - 3
~ to GNRO-91/00006-REGULATORY GUIDE 1.97 NEUTRON' MONITORING SYSTEM
.?
QUARTERLY STATUS REPORT (PERIOD ENDING DECEMBER 31,1990) 1.
GENERAL IMPLEMENTATION SCHEDULE STATUS The current GGNS design approach involves the installation of two instrument channels with one detector for each channel. The detectors will be. located within holes bored in the shield wall to provide the greatest sensitivity for neutron detection.
Under full power or hot operating conditions upon shutdown, Entergy Operations anticipates a sensitivity of up to 1 E-6% power.
Entergy Operations is currently progressing on. schedule :for the implementation of.an excore Neutron Monitoring System for_ Regulatory Guide (RG) 1E. - Overall progress was limited this reporting period due to the GGNS fourth refueling outage.(RF04); however, this does not impact
.the schedule for system installation by the end of RF05.
- During RF04, walkdowns for the Neutron Monitoring System sensor locations were completed.
Several other activities were also completed since the previous-status report, see Items 1, 5, and 6 below.
II. MAJOR ACTIVITY STATUS The following provides a. discussion of the status for-the major activities necessary to complete implementation of the system:
' 1. -
Perform' detailed engineering and design for the excore system.
o in progress.
Some specific actions-for this major activity are:
=The Excore Neutron Monitoring System Design Criteria has been completed and is currently i_n review.
The Excore System Purchase Specification has.been completed and issued for Entergy Operations use.
The preliminary review of Gamma Metrics environmental qualification documentation for applicability to -GGNS has L
been completed.
Detailed determination and evaluation of available se'nsor locations was completed based upon.information obtained by walkdowns during RF04.
L
- The Design Changt Package will be completed and-issued.
i See scheduling note on page 2 of this Attachment.
G9101071/SNLICFLR - 5
Attachment I to GNRO-91/00006 2.
Perform an evaluation of GGNS specific excore :Sutron Monitoring System range compliance, o Complete, as summarized below:
Entergy Operations has reviewed the locational considerations for installing the GGNS excore Neutron Monitoring System to attempt to meet the range of 1 E-6% to 100% power given in RG 1.97.
In order to attempt to meet a range of 1 E-6% to 100% power, Entergy Operations has determined that holes must be bored in the shield wall and the detectors mounted within these holes.
3.
Obtain NRC review of the BWROG alternate neutron monitoring position report NEDO 31558, stating that upgraded neutron monitoring is unnecessary.
A similar position was taken by GGNS in a plant-specific analysis and endorsement of NED0-31558 via AECM-88/0083 dated April 28, 1988.
o Complete; af ter review, the NRC Staf f rejected the positions in report NED0-31558 and the GGNS suttmittal AECM-88/0083,
- 4 Following item 3 above, Entergy Operations submitted PCOL-90/01 (Revision 2 transmitted via AECM-90/0118 dated June 22, 1990) to change the commitment for installation of the RG 1.97 Neutron Monitoring System to the end of RF05.
o Complete.
5.
Obtain NRC review and approval of PCOL-90/01, o Complete, see OL Amendment 72 (MAEC-90/0281).
6.
Develop and issue purchase specification for the excore system
-hardware, o Complete, see Item 1 above.
(A vendor quote has also been requested.)
7.
Issue a vendor purchase order *; vendor-fabrication of equipment, o Future action.
- The BWROG has appealed the Staff's nosition on NEDO-31558.
The NRC review of this appeal is now in progress and is being followed by GGNS.
Due to the ongoing review of this appeal, there is a potential schedule conflict.
To meet the existing schedule, GGNS must complete a vendor purchase order by approximately March 1, 1991.
If the NRC decision on the BWROG is not made by this date, GGNS will face financial risk by proceeding with an agreement (see the cover letter for additional information).
G9101071/SNLICFLR - 6
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Attachaent 1 to GNRO-91/00006 8.
Develop and issue a design change packago for GGNS installation of the excore system.
i o -In progress (see items 1 and 2 above).
9.
Receive excore system hardware onsite for installation, o future action.
10.
Install the excore system, o Future action, d
4 09101071/SNLICFLR - 7
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