ML20092B464
| ML20092B464 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/18/1984 |
| From: | Mcgaughy J MISSISSIPPI POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20092B467 | List: |
| References | |
| AECM-84-0336, AECM-84-336, NUDOCS 8406200225 | |
| Download: ML20092B464 (14) | |
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P MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. B OX 1640, J ACK S O N, MIS SISSIP PI 3 9 205 June 18, 1984
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U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: Mr. Harold R. Denton, Director
Dear Mr. Denton:
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-13 File 0260/0840/L-860.0 Proposed Amendment to the Operating License (PCOL-84/11A)
AECM-84/0336 Mississippi Power & Light Company (MP&L) completed its review of the Grand Gulf Nuclear Station Technical Specifications in accordance with the Technical Specification Review Program (TSRP) submitted to the NRC on March 18, 1984 (AECM-84/0183). The results of the TSRP were submitted to the NRC on April 9, 1984 (AECM-84/0217) and on April 19, 1984 (AECM-84/0229). Findings of the TSRP, which require changes to the Grand Gulf Technical Specifications, were identified on Technical Specification Problem Sheets (TSPS). A number of revised Problem Sheets were submitted to the NRC on May 1, 1984 (AECM-84/0251) and on May 8, 1984 (AECM-84/0286). Eleven additional problem sheets summarizing items identified by the NRC were included in the May 1, 1984 letter. Since submittal of the final TSRP results, MP&L and the NRC staff have met numerous times to discuss the TSRP findings, and the justification for, and safety significance of any proposed changes to the Grand Gulf Technical Specifications identified during the TSRP.
On April 18, 1984, the NRC issued an Order Restricting Conditions for Operation of Grand Gulf Unit No. 1, in which twenty-two changes were made to the Grand Gulf Technical Specifications. These twenty-two changes were those identified by MP&L in its TSRP as being necessary to support testart and full power operations for Unit No. 1. With the implementation of these changes to the Grand Gulf Technical Specifications, MP&L was authorized to restart and operate Unit No. I under its operating license up to five percent power.
On May 24, 1984 MP&L submitted a proposed amendment to the Grand Gulf Nuclear Station Technical Specifications. This amendment included a revised organization and modified terminology in the administrative section of the technical specifications. This amendment also resolved two technical specification problem sheets as noted in a letter from MP&L to the NRC dated May 25, 1984 (AECM-84/0303). Further proposed changes associated with the TSRP were submitted on June 17, 1984 (AECM-84/0330). l tsB1 8406200225 840618 ember Middle South Utilities System PDR ADOCK 05000416 P PDR M 40
AECM-84/0336 MICOIKIIPPI POWER & LI2HT COMPANY Page 2 As a follow-up to the TSRP and the NRC Order of April 18, 1984, MP&L was notified by letter dated May 9, 1984 from Mr. T. M. Novak of the methods to be used in resolving the findings of the TSRP. In accordance with that letter and with 10CFR 50.59 and 10CFR 50.90, MP&L requests that the proposed changes to the Grand Gulf Technical Specifications, set forth in the attachments to this letter be incorporated into the full power amendment to License No. NPF-13. All of these proposed changes to the Grand Gulf Technical Specifications have been reviewed and evaluated by both MP&L and the NRC staff as part of and in conjunction with MP&L's TSRP. The proposed changes in the attachment to this letter are a portion of the changes necessary to
-render the Grand Gulf Nuclear Station Technical Specifications consistent in all material respects with the as-built plant, the SER, and the FSAR and supportin/, documents.
The description of, f.echnical justification for, and safety evaluation of the proposed changes to the Grand Gulf Technical
' Specifications are inclr.ded in the attachment to this letter which contains all of-the prcposed technical specification changes within the purview of the Chemical Engineering Branch, Division of Engineering of the Office of Nuclear Reactor Regulation.
The proposed changes to the Grand Gulf Technical Specifications have been divided into four categories as described below. This-categorization was made to assist the NRC staff in expediting its review of the proposed changes to the Grand Gulf Technical Specifications:
TECHNICAL SPECIFICATION CHANGE CATEGORIES o TYPOGRAPHICAL ERRORS, EDITORIAL CHANGES, CLARIFICATIONS:
Changes which correct obvious typographical errors, implement editorial changes such as correction of' spelling errors, punctuation errors and grammatical errors or merely provide clarification of, without changing, the basic meaning and intent of the technical specification being changed.
o TECHNICAL SPECIFICATION /AS-BUILT PLANT CONSISTENCY: Changes which are proposed to render the technical specifications consistent with the as-built plant. In all such cases, the as-built plant is consisteat with the safety analyses and the licensing basis.
o ENHANCEMENTS THAT ARE CONSISTENT WITH THE SAFETY ANALYSES:
-Changes which are consistent with the safety analyses and the licensing basis and which provide clarification, render areas consistent with the philosophy and intent of the technical specifications, or provide additional plant operational margin.
o REGULATORY REQUIREMENTS / REQUESTS / RECOMMENDATIONS: Changes or.
enhancements to render the technical specifications consistent.
-with recent changes in NRC policy and the Code of Federal Regulations as well as to implement changes or enhancerents recently requested or recommended by the NRC.
.tsB2
AECM-84/0336 MIZISSIPPI POWER & LIGHT COMPANY Page 3 The enclosed changes to the Grand Gulf Technical Specifications have been reviewed and approved by the Plant Safety Review Committee and the Safety Review Committee. All of the proposed changes have been determined to be conservative with respect to the Grand Gulf safety analyses and, based on the guidelines set forth in 10CFR 50.92, involve no significant hazards considerations.
In accordance with provisions of 10 CFR 50.30, three (3) signed originals and forty (40) copies c f the proposed changes to the Grand Gulf Technical Specifications, as described in the attachment, are hereby formally provided for your review and approval. These proposed changes include an additional portion of the changes to the Grand Gulf Technical Specifications identified by the TSRP and determined by the NRC staff to require resolution prior to issuance of'the full power amendment to License No. NPF-13.
Based upon MP&L's evaluation of the proposed changes and upon discussions with members of your staff, MP&L has concluded that there should be no additional fee for the proposed technical specification changes.
Yours truly, f~n, i f)?
JPM:Im Attachments cc: Mr. J. B. Richard (w/o)
Mr. R. B. McGehee (w/o)
Mr. N. S. Reynolds (w/o)
Mr. G. B. Taylor (w/o)
Mr. Richard C. DeYoung, Director (w/a)
Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. 'J. P. O'Reilly, Regional Administrator (w/a)
U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Dr. Alton B. Cobb (w/a)
State Health Officer State Board of Health Box 1700 Jackson, Mississippi 39205 tsB3
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- BEFORE THE UNITED STATES REGULATORY COMMISSION LICENSE NO. NFL *3 DOCKET No. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and MIDDLE SOUTH ENERGY, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, J. P. McGaughy, Jr., being duly sworn, stated that I am Vice President
- Nuclear Support of Mississippi Power &. Light Company; that on b'ehalf of Mississippi Power & Light Company, Middle South Energy, Inc., and South Mississippi Electric Power Association I am authorized by Mississippi Power &
Light Company 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 - Nuclear Support of Mississippi Power'& Light Company; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information and belief.
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- s. 'P. Il=C.m McGaugfiy',VJr.
STATE OF MISSISSIPPI /
COUNTY OF HINDS SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State above named, this //1 day of Xfr C , 1984. -,
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ATTACHMENT TO AECM-84/0336 (6/18/84)
PROPOSED CHANGES TO THE GRAND GULF NUCLEAR STATION -
TECHNICAL SPECIFICATIONS i
NRC TECHNICAL REVIEW BRANCH: CHEMICAL ENGINEERING T
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Attechm:nt / Chemical Enginscring AECM-84/0336 (6/18/84)
Page 2 ,
o Listing of Item Numbers by Technical Specification Probl,em Sheet (TSPS) Number TSPS No. Item Nos.*
055 A.02 070 D.01 071 D.01 ,
072 D.02 073 B.01 102 B.01 203 B.02 223 D.03 244 B.03 245 B.04 277 C.01 299 B.05, A.01 304 B.01 338 B.06 351 B.01 Y
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- Item number format: A.02 Item number within category Category designator TS5:rg2
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- Attacharnt / Chtmical Enginsering AECM-84/0336 (6/18/84)
Page 3
- s A. TYPOCRAPhTCAL ERRORS, EDITORIAL CHANGES, AND CLARIFICATIONS These proposed changes correct obvious typographical errors, implement editorial changes such as correction of spelling errors, punctuation errors, and grammatical errors or provide clarification of the basic neaning or intent of the subject technical specifications.
MP&L has determined that the proposed changes do not; o involve a significant increase in the probability or consequences of an accident previously evaluated; or o Create the possibility of a new or different kind of accident from any accident previously evaluated; or o Involve a significant reduction in a margin of safety.
' Therefore, the proposed changes do not involve a significant hazards consideration.
A description of these changes including necessary justification for the changes is provided below:
TYPOGRAPHICAL ERRORS A typographical error is being corrected by this submittal as listed below. Correction of this typographical error is purely an administrative change. (See attached revised technical specification page for exact change propcaed.)
TSPS No. TS Page No.
- 1. 299 3/4 7-33 4
EDITORIAL CHANGES a praposed editorial change to the technical specification is discussed below: 1
- 2. (TSPS 055), Reactor Coolant System Surveillance Requirement.
Technical Specification 3/4.4.4 The proposed change is to delete the phrase "for up to 31 days" from ?
.. Surveillance Requirement 4.4.4.c. As presently worded the f
TS57rg3
Attach 2snt / Chimical Engineering AECM-84/0336 (6/18/84)
Page 4 Surveillance Requirement could be interpreted to imply that the in-line conductivity measurement is required only for the first 31 days of the period in which the continuous recordin.g conductivity monitor is inoperable. Deletion of this phrase will clarify the intent of the surveillance requirement, that is, to measure the in-line conductivity for any period of time that the continuous recorder is INOPERABLE. This change is purely administrative in order to clarify the requirement.
(Page 3/4 4-12)
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AttachmInt / Chemical Engintering AECM-84/0336 (6/18/84)
Page 5 o
B. TECHNICAL SPECIFICATION /AS-BUILT PLANT CONSISTENCY The following changes are proposed to render the technical specifications :
consistent with the as-built plant. In' all such cases, the as-built plant is consistent with the safety analyses and the licensing basis.
In that these proposed changes are inherently consistent with the safety j analyses and the licensing basis, it is concluded that the proposed changes do not; o Involve a significant increase in the probability or consequences of a an accident previously evaluated; or f o Create the possibility of a new or different kind of accident from any I accident previously evaluated; or ,
o Involve a significant reduction in a margin of safety. .
Therefore, the proposed changes do not involve a significant hazards consideration. ,
A description of these changes including justification for the changes is ;
provided below:
- 1. (TSPS 073, 102, 304, 351), Fire Detection Instrumentation, Technical Specification 3/4.3.7.9, Table 3.3.7.9-1, and Bases 3/4.3.7.9 The following Technical Specification changes are proposed:
- a. Revision of Table 3.3.7.9-1 format to list the fire detection instrumentation by zones and areas within each zone,
- b. Identification of instrumentation by type as Function A (early warning and notification only) and Function B (actuation of '
fire suppression systems and early warning and notification).
- c. Clarification of the associated ACTION statements for Function A and Fanction B inoperable instrument (s).
- d. Revision of Bases 3/4.3.7.9 to address Function A and Function '
f B instrumentation.
- e. Incorporation of additional detectors, zones and areas into ;
Table 3.3.7.9-1.
Some of the proposed changes included herein supercede changes previously submitted as Item 1 of letter AECM-83/0565, dated September 9,1983 and withdrawn by letter AECM-84/0303 dated May 25, 1984. - ,
TS57rg5
Attachment / Chrmical Engineering AECM-84/0336 (6/18/84)
Page 6 l a
The proposed changes to clarify the location, type and function of !
instrumentation and the changes to the ACTION statements and Bases are enhancements to reflect as-built conditions.
Zones, are.as and associated instrumentation are added to include i those areas that contain either safety-related equipment / cables l protected by fire detection instrumentation or nonsafety-related j equipment / cables protected by fire detection instrumentation whose malfunction could affect fire detection instrumentation in areas l i
containing safety-related equipment / cables. Instrumentation was also added by design changes to increase fire detection capability. l These changes are enhancements to safety in that they increase the l amount of fire protection equipment included in the specification, provide clarification and are consistent with the as-built plant. t (Pages 3/4 3-76 through 3/4 3-80 and B 3/4 3-5) 4 2. (TSPS 203), Spray and/or Sprinkler Systems, Technical Specification ,
i 3.7.6.2 This proposed change correctly identifies the sprinkler system for the control building elevation 93 feet (Item 3) as NSP64D140. l j
This proposed change clarifies that this sprinkler system is shared '
between Units 1 and 2 and is a purely administrative change made to reflect as-built conditions and design intent. (Page 3/4 7-31) ;
- 3. (TSPS 244), Halon Systems, Technical Specification 3/4.7.6.4 l
The proposed change to Technical Specification Surveillance Require- !
ment 4.7.6.4.a will delete the hazard area selector valves F497G and F497H from the requirement to verify valve position. All valves in the Halon flow paths are totally enclosed, nitrogen pressure or explosive pin actuated valves that cannot be manually 7 manipulated or visually verified to be in the correct position. In addition, operation of any of the valves would actuate the system, which is contrary to the intent of the subject surveillance require- ,
ment. All other valves in the Halon flow path except valves F497G r
and F497H can be indirectly verified to be in their correct posi- l tion by measurement of halon tank pressure since a failed or :
leaking valve would bleed off the affected tank. The proposed change will not adversely impact plant safety because it is consis- -
tent with the intent of the surveillance requirement and will make the surveillance requirement consistent with the as-built plant. .
t (Page~3/4 7-35)
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- 4. (TSPS 245), Spray and/or Sprinkler Systems, Technical Specification '
3/4.7.6.2 f
A revision to the subject technical specification is proposed which will add a footnote and appropriate references to indicate that the l h
. TS57rg6 ;
7, Attach 2snt / Chemical Engineering AECM-84/0336 (6/18/84)
Page 7 j aceas listed for the auxiliary building, control building, and !
fire pump house are protected by wet pipe sprinkler systems. The l diesel generator building is sh,own to be protected by pre-action sprinkler systems. The proposed changes are purely administrative !
modifications to reflect the as-built plant design and do not .
affect the' technical content of the technical specifications.
(Page 3/4 7-31) ,
- 5. (TSPS 299) CO 2 Storage Tank Level Technical Specification 3/4.7.6.3 t The proposed change increases the minimum CO, storage tank level t requirement in Surveillance Requirement 4.7.6.3.2.a. from 50% to 60%. The design requirement for the CO2 storage tank is to provide sufficient capacity for double-shot coverage for the largest room covered in addition to one main generator purge. The proposed storage tank level consistent with the change as-built makes plant. theTh CO,is proposed change is an enhancement to plant safety since it applies stricter requirements than the existing technical specification. (Page 3/4 7-34) 1
- 6. (TSPS 338) Fire Hose Stations, Technical Specification Table ,
3.7.6.5-1 This proposed change adds two fire hose stations located in the control building to the list of fire hose stations which may be -
relied upon to confine and extinguish fires occurring in a portion of the facility where safety related equipment is located. The proposed change is appropriate because safety related cables pass through the areas covered by these hose stations. These two fire hose stations are installed in the plant and this change is pro-posed to reflect as-built plant design and useage. This change is an enhancement to plant safety in that it increases the amount of fire protection equipment included in the technical specification. -
(Page 3/4 7-38) l i
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- Attach =cnt / Chanical Engineering AECM-84/0336 (6/18/84)
Page 8 4
C. ENHANCEMENTS THAT ARE CONSISTENT WITH THE SAFETY ANALYSES The following proposed change is an enhancement which is consistent with the safety analyses and the licensing b~ asis and which provides clarifica-tion, renders areas consistent with the philosophy and intent of the technical specifications, or provides additional plant operational margin.
Since this proposed change is included in the current licensing bases and is bounded by existing safety analyses, the proposed change dees not:
o Involve a significant increase in the probability or consecuences of an accident previously evaluated; or o Create the possibility of a new or different kind of accident from any accident previously evaluated; or o Involve a significant reduction in a margin of rafety.
Therefore, the proposed change does not involve a significant hazards consideration.
A description of this change including justification for the change is provided below:
- 1. (TSPS 277) Fire Rated Assemblies, Technical Specification 3/4.7.7 This proposed change to Surveillance Requirement 4.7.7.1.c requires that sample selection of penetration seals be such that each penetra- The tion seal is inspected at least once during each 15-year period.
present specification requires at least 10% of each type of sealed penetration to be inspected at least once per 18 months but does not require each penetration to be inspected at least once per 15 years.
This change is an enhancement to plant safety in that it constitutes a more stringent surveillance requirement than is presently in the technical specifications. (Page 3/4 7-41) 4 TSS7tg8
Attachmtnt / Chtmical Enginsering AECM-84/0336 (6/18/84)
Page 9 1
L D. REGULATORY REQUIREMENTS / REQUESTS / RECOMMENDATIONS ,
l The following changes are proposed to render the technical specifications consistent with recent changes in NRC p'olicy and the Code of Federal Regulations, as well as to implement changes or enhancements recently !
requested or recemmended by NRC reviewers.
These proposed changes are required to render the technical specifications consistent with recent NRC guidance, and it has been concluded based on a review of each item that the proposed changes do not:
I o Involve a significant increase in the probability or consequences of an accident previously evaluated; or o Create the possibility of a new or different kind of accident from any ;
accident previously evaluated; or ,
o Involve a significant reduction in a margin of safety. >
f Therefore, the proposed changes do not involve a significant hazards consideration. .
A description of these changes including justification for the changes is ,
provided below:
- 1. (TSPS 070 and 071) Deletion of Special Reporting Requirements for Fire Protection, Technical Specifications 3/4.7.6 and 3/4.7.7 The proposed revision to delete all references to special reporting requirements for inoperable components of fire suppression systems is in response to NRC Division of Engineering recommendations as found in
. memorandum from Victor Benaroya to Cecil 0. Thomas, " Grand Gulf Nuclear Station Unit 1 - Technical Specifications," dated November 7, !
1983. The deletion of the special reporting requirements does not I constitute a relaxation of conditions required for safe operation in .
that the subject technical specifications retain all necessary !
entrective actions to ensure that the plant is operated safely. The revision therefore does not adversely impact plant safety and makes the subject technical specifications more easily understood. (Pages !
3/4 7-28, 31, 33, 35, 36, 39, 41, and B3/4 7-3)
- 2. (TSPS 072) Spray and/or Sprinkler Systems Technical Specification !
3/4.7.6.2 and Bases 3/4.7.6 This proposed change revises Surveillance Requirement 4.7.6.2.c and Bases 3/4.7.6 to include visual inspection to ensure that spray areas and patterns are not obstructed by temporary structures or objects. This change is an enhancement to plant safety in that it constitutes an additional control not presently included in the ;
technical specifications. In addition, this proposed change is consistent with proof and review comments provided to MP&L by the l NRC Staff. (Page 3/4 7-32 and B3/4 7-3) ,
i TSS7rg9
Attachmtnt / Chzaical Engineering AECM-84/0336 (6/18/811 Page 10
- 3. (TSPS 223) Fire Suppression System Surveillance Requirements.
Technical Specification 3/4.7.6.1 This proposed change provides sn additional surveillance require-ment for the fire suppression water system. Surveillance Require-ment 4.7.6.1.1.e was added to ensure that a system flush is performed at least once per 12 months. This addition was recom-mended by the Chemical Engineering Branch of the NRC, following their comparison of the GGNS Technical Specifications to the GE i Standard Technical Specifications. This proposed change does not !
adversely affect plant safety since ic provides a more stringent '
surveillance requirement. (Page 3/4 7-29) i i
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