AECM-85-0218, Application for Amend to License NPF-29,revising Tech Specs to Reflect Deferral of Installation of Automatic Depressurization Sys Air Receiver Pressure Indication in Control Room to Second Refueling Outage.Fee Paid

Application for Amend to License NPF-29,revising Tech Specs to Reflect Deferral of Installation of Automatic Depressurization Sys Air Receiver Pressure Indication in Control Room to Second Refueling Outage.Fee Paid

ML20133K965
Person / Time
Site:	Grand Gulf
Issue date:	10/11/1985
From:	Kingsley O MISSISSIPPI POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20133K968	List: AECM-85-0218, Application for Amend to License NPF-29,revising Tech Specs to Reflect Deferral of Installation of Automatic Depressurization Sys Air Receiver Pressure Indication in Control Room to Second Refueling Outage.Fee Paid ML20133K970
References
AECM-85-0218, AECM-85-218, NUDOCS 8510220365
Download: ML20133K965 (6)

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi EIBMIMIME P. O. 6 3 X 16 4 0. J A C K S O N. MISSISSIPPI 39215-1040 October 11, 1985 O D. KING $ LEY. JR.

YtCE Pe EllDENT - NUCLE AR OPE RATIO 865 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 License No NPF-29 File: 0260/0840/L-860.0 Proposed Amendment to the Operating License (PCOL-85/12)

AECM-85/0218 On July 29, 1985, a meeting was held between members of the NRC staff and Mississippi Power & Light (MP&L). One of the subjects of discussion was the deferral of selected items which are' currently required for completion during the first refueling outage. One of these items is installation of Automatic Depressurization System (ADS) air receiver pressure indication in the control room as currently required by License Condition 2.C.(33.g).

In accordance with the provisions of 10 CFR 50.59 and 10 CFR 50.90, MP&L requests an amendment to License NPF-29, for Grand Gulf Nuclear Station (GGNS) Unit I to defer the installation of ADS air receiver pressure indication in the control room from the first to the second refueling outage. Since the outage is scheduled to commence in late Spring of 1986, an NRC response is requested by February, 1986 to allow time for planning and scheduling work.

MP&L is aggressively pursuing the implementation of required first refueling outage items. A seven week outage is currently in progress during which forty-five design change packages are scheduled for implementation. Many items required to be implemented during the first refueling outage will be completed during this fall outage. Despite this effort, fifty-seven work items will remain for implementation during the first refueling outage. This remaining large scope of work has necessitated an assessment of candidates for deferral in order to prevent significantly extending the completion time for the outage.

MP&L's justification for the ADS pressure indication deferral request is based on the increased complexity that this job will add to planning the outage and the affect of this work on other outage work.

The majority of work for installation of ADS air receiver pressure indication must be performed in the upper drywell. Since there is a significant n access to this area amount of work already scheduled in the drywell area 8510220365 851011 3

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AECM-85/0218 Page 2 will be limited during the outage, MP&L believes it is prudent to limit the scope of work in the area. Also, this item is viewed as a system enhancement because of the adequacy of current administrative controls and testing performed on the system.

In accordance with the provisions of 10 CFR 50.30, three (3) signed originals and forty (40) copies of the requested amendment are enclosed. The attachment provides the complete technical justification and discussion to support the requested amendment. This amendment has been reviewed and accepted by the Plant Safety Review Committee (PSRC) and the Safety Review Committee (SRC).

Based on the guidelines presented in 10 CFR 50.92, it.is the opinion of MP&L that this proposed amendment involves no significant hazards considerations.

Based on the guidance provided in 10 CFR 170.21, we have determined that the application fee is $150. A remittance of $150 is attached to this letter.

Yours Ir ly,

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ODK:rg Attachments: GGNS PCOL-85/12 cc:

Mr. J. B. Richard (w/a)

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

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

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

Mr. R. C. Butcher (w/a)

Mr. James M. Taylor, Director (w/a)

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

20555 Dr. J. Nelson Grace, 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 l

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F BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 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, O. D. Kingsley, Jr., being duly sworn, stated that I am Vice President, Nuclear Operations of Mississippi Power & Light Company; that on behalf 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 Operations of Mississippi Power & Light Company; and that the statements made and the matters set forth therein are true and correct to the est of my knowledge, information and belief.

O. D(' Kingsley t.

STATE OF MISSISSIPPI

's-COUNTY OF HINDS SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State above named, this % day of

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1985.

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[I Notary Public My commission expires:

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(OLCR NLS-85/03)

SUBJECT:

Facility Operating License No. NPF-29, page 13 License Condition 2.C.(33.g)

DISCUSSION:

It is proposed that the subject license condition be amended to allow deferral of the installation of automatic depressurization system (ADS) air receiver pressure indication in the control room until the second refueling outage. An NRC response is requested by February, 1986 in order to allow

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time for planning and scheduling of work.

JUSTIFICATION: Current estimates of the scope of Grand Gulf's first refueling 3'

outage (57 work items) have necessitated an assessment of candidates for deferral. The subject license condition g

requires installation of instrumentation to measure ADS air 3,

system pressure for display in the control room prior to 3.'

startup from the first refueling outage. MP&L's justification p

for deferral is based on the complexity of the job, the affects

'g of the work on other outage work, the fact that it is a systtm d

enhancement, and the adequacy of current administrative y

controls and testing performed on the system.

Grand Gulf's first refueling outage is estimated to extend for

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approximately 13 weeks and will involve the implementation of several large, complex design changes. The critical path is controlled by design change implementation activities. The y

current schedule permits few delays without extending the

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completion time for the outage. The bulk of the physical work

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for installation of ADS pressure indication is to be performed in the upper drywell. Work in this area is difficult due to space limitations. This job will add increased complexity to the outage due to the significant amount of other work already scheduled in the drywell area including MSRV replacement, g

inspection of the ADS accumulator tanks, inspection and testing y'~

of snubbers, and inservice inspection work on the reactor pressure vessel.

In addition, work in this area can only be performed for a limited time during the outage (an estimated 4 s

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weeks of the currently scheduled 13 week outage) due to fuel movement and ADS testing activities.

This makes it prudent that the scope of work be limited in this area in order to insure timely completion of scheduled activities without effecting the schedule.

W MP&L has installed a mechanical pressure gauge on the discharge of the instrument air booster compressor to the ADS air receivers. This gauge is checked once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Operational Conditions 1, 2, and 3 with the reactor steam dome pressure greater than 135 psig. The pressure is recorded on the daily operating log per Grand Gulf procedure y

06-OP-1000-D-0001. The acceptance criteria for this check requires Technical Specification Action Item 3.5.1.e.2 be

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g entered when the pressure is less than or equal to 150 psig.

Also, although there are currently no alarms associated with the ADS accumulator system, there is an alarm on the discharge of the instrument air booster compressor which will warn the control room operator of problems which could lead to a loss of pressure in the ADS accumulators.

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j The aforementioned pressure gauge is calibrated under the preventive maintenance program on a nominal eighteen month frequency to ensure its accuracy.

In addition, an integrated j.

leak test is performed on the ADS air system as described in MP&L letter dated October 24, 1983 (AECM-83/0672). Performance of this leak test verifies system integrity.

In conclusion, MP&L requests that the NRC approve this proposed operating license change. The current administrative controls and required testing for the system are adequate for detecting leakage. In addition, system components can be expected to be relatively leak free since this will only be the second cycle of operation.

MP&L plans to fulfill the other requirements of this license condition prior to startup from first refueling including l

performance of sampling to establish instrument air quality,

~i and establishing surveillance procedures and Technical Specifications for the system. These actions will provide further assurance of the ADS air system integrity. The installation of pressure indication is a system enhancement and l

deferral will not degrade the current capabilities of the system.

l SIGNIFICANT HAZARDS CONSIDERATION:

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The proposed change to the operating license does not involve i

1) a significant increase in the probability or consequences of a previously evaluated accident because the current 2

administrative controls and testing for the system will j

be extended through a second cycle of operation, or f

2) create the possibility of a new or different kind of j

accident from any previously evaluated accident because l

MP&L will continue to administrative 1y control and test the system, nor I

3) does it involve a significant reduction in a margin of safety because the current capabilities of the system will not be degraded.

Therefore, the proposed change does not involve a significant hazards consideration.

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