ML20138R898

Conformance to Generic Ltr 83-28,Items 3.1.3 & 3.2.3,Grand Gulf Units 1 & 2, Technical Evaluation Rept

ML20138R898
Person / Time
Site:	Grand Gulf
Issue date:	10/31/1985
From:	Vanderbeek R EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20138Q704	List: ML20138Q702 ML20138Q705 ML20138R898
References
CON-FIN-D-6001, CON-FIN-D-6002 GL-83-28, NUDOCS 8511190218
Download: ML20138R898 (8)

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J CONFORPANCE TO GENERIC LETTER 83-28 ITEMS 3.1.3 AND 3.2.3 '

GRAND GULF UNITS 1 AND 2 1 R. VanderBeek .

R. Haroldsen 4

4 gn.c.9a7 Published October 1985 EG&G Idaho, Inc. i Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission

'dashington, D.C. 20555 i Under DOE Contract No. DE-AC07-761D01570

• FIN Nos. 06001 and 06002 1

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t ABSTRACT s

This EG&G Idaho, Inc. report provides a review of the submittals for Grand Gulf Nuclear Station for conformance to Generic Letter 23-28, items 3.1.3 and 3.2.3.

FOREWORD This report is supplied as part of the program for evaluating licensee / applicant conformance to Generic Letter 83-28 " Required Actions based on Generic Implications of Salem ATWS Events." This work is conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of System Integration by EG&G Idaho, Inc., NRC Licensing Support Section.

The U.S. Nuclear Regulatory Commission funded the work under the authorization, B&R 20-19-19-11-3, FIN hos. D6001 and 06002.

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Docket Number TAC Numbers Grand Gulf Unit 1 50-416 53004, 53842 Grand Gulf Unit 2 50-417 -- --

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CONTENTS ABSTRACT .............................................................. 11 i a FOREWORD .............................................................. 11

1. INTRODUCTION ..................................................... 1

2. REVIEW REQUIREMENTS .............................................. 2

3. REVIEW RESULTS FOR GRAND GULF UNITS 1 AND 2 ...................... 3 3.1 Evaluation ................................................. 3 3.2 Conclusion ................................................. 3

4. REFERENCES ....................................................... 4 I

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CONFORMANCE TO GENERIC LETTER 83-28 ITEMS 3.1.3 AND 3.2.3 GRAND GULF UNITS 1 AND 2 4

1. INTRODUCTION I

On July 8, 1983, Generic Letter No. 83-28 was issued by -

D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor.

Regulation, to all licensees of operating reactors, applicants for operating licenses, and holders of construction permits. This letter included required actions based on generic implications of the Salem ATWS events. These requirements have been published in Volume 2 of NUREG-1000

" Generic Implications of ATWS Events at the Salem Nuclear Power Plant".2 This report documents the EG&G Idaho, Inc. review of the submittals from Grand Gulf Units I and 2 for conformance to items 3.1.3 and 3.2.3 of Generic Letter 83-28. The submittals and other documents utilized in this evaluation are referenced in section 4 of this report. .

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2. REVIEW REQUIREMENTS Item 3.1.3 (Post-Naintenance Testing of Reactor Trip . System Components) requires licensees and applicants to identify, if applicable,  ;

any post-maintenance test requirements for the Reactor Trip System (RTS) in existing technical specifications which can be demonstrated to degrade .

rather than enhance safety. Item 3.2.3 extends this same requirement to include all other safety-related components. Any proposed technical specification changes resulting from this action shall receive a I

pre-implementation review by NRC.

i The relevant submittals from the Grand Gulf Units 1 and 2 were reviewed to determine compliance with items 3.1.3 and 3.2.3 of the Generic Letter. First, the submittals from this plant were reviewed to determine that these two items were specifically addressed. Second, the submittals were checked to determine if there were any post-maintenance test items 1 specified by the technical specifications that were suspected to degrade rather than enhance safety. Last, the submittals were reviewed for evidence of special conditions cr other significant information relating to the two items of concern.

l The BWR Owners Group is presently addressing Generic Letter 83-28 item ,

3 4.5.3 which is expectea to result in proposed changes to the technical I

specification requirements for surveillance testing frequency and out-of-service intervals for surveillance testing and post-maintenance l testing. The primary concern of item 4.5.3 is the surveillance testing intervals. Items 3.1.3 and 3.2.3 are specifically directed at post-maintenance test requirements. These concerns are essentially independent. However, the evaluations of these concerns are coordinated so that any correlation between these concerns will be adequately considered.

Since no specific proposal to change the technical specifications have been proposej, there is no identifiable need at this time for correlating the I reviews. of item 4.5.3 with this review.

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. 3. REVIEW RESULTS FOR GRAND GULF UNITS 1 AND 2 3.1 Evaluation Mississippi Power and Light Company (MP&L), the licensee for Grand Gulf Nuclear Station Units I and 2, provided responses to items 3.1.3 and 3.2.3 of Generic Letter 83-28 on November 4, 1983.3 Within the responses the licensee stated that a review of all technical specifications will be conducted to ad_ dress item 3.1.3 and a response to item 3.2.3 will be provided on September 27, 1985. On December 14, 1984,4 the licensee provided an additional response for item 3.1.3, stating that MP&L had recently completed a detailed comprehensive technical specification review program which identified inconsistencies in technical specifications and verified technical accuracy and completeness of the specifications. MP&L believes that this review program represented a comprehensive review of the Grand Gulf Technical Specifications.

A supplementary response to item 3.1.3 was provided by the licensee on January 16, 1985.5 Within that response, the licen,see's evalaation for item 3.1.3 is that, following a review of the technical specifications, no post-maintenance test requirements were identified for the reactor trip system ccTponents which tended to degrade rather than enhance plant safety. A subsequent submittal on September 30, 1985 6 included a similar response for item 3.2.3. In this submittal MP&L stated that they had reviewed the Grand Gulf Technical Specifications and were unable to identify any post-maintenance test raquirements which degrade safety.

3.2 Conclusion Based on the licensee's statement that they have reviewed their I

technical specification requirements for the RTS and safety-related components to identify any post-maintenance testing which could be demonstrated to degrade rather than enhance safety and found none that degraded safety, we find the licensee's responses for items 3.1.3 and 3.2.3 acceptable. The licensee's commitment to continue the review of incoming

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1 vendor information and engineering recomprendations for information that 4

l could identify instances of potential degradation of safety caused by .

post-maintenance testing requirements provides additional assurance that the technical specifications will continue to provide a basis for safe plant operation and is acceptable. ,

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4. REFERENCES

1. fiRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits, "kequired Actions Based on Generic Implications of Salem ATWS Events 3 (Generic Letter 83-28)", July 8, 1983.

, 2. Generic Implications of ATWS Events at the Salem Nuclear Power Plant, NUREG-1000. Volume I, Apr11 1983; Volume Z, July 195J.

3. Mississippi Power & Light Company letter to NRC, J. P. McGaughy Jr. to D. G. Eisenhut, Director, Office of Nuclear Reactor Regulation, NRC,

" Grand Gulf Nuclear Station Units 1 and 2. Docket hos. 50-416 and 50-417, License No. NPF-13, file: 0025/0272/L-860.0, Response to Generic Letter 83-28, AECM-83/0723." November 4,1983.

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4. Mississippi Power & Light Company letter to NRC, L. F. Dale to H. R. Denton, Director, Office of Nuclear Reactor Regula+1on, NRC,

" Grand Gulf Nuclear Station Units 1 and 2, Docktt Nos. 50-416 and 50-417, License No. NPF-29, File: 0025/L-860.0, Response to Generic Letter 83-28. Item 3.1, AECM-84/0533." December 14, 1984.

5. Missis:1ppi Power & Light Company letter to NRC, L. F. Dale to H. R. Denton, Director, Office of Nuclear Reactor Regulation, hRC,

" Grand Gulf Nuclear Station Units 1 and 2. Docket Nos. 50-416 and 50-417, License No. NPF-29, File: 0025/L-860.0, Supplementary Respunse to Generic Letter 83-28, Item 3.1.3, AECM-85/0004." .

January 16, 1985.

6. Mississippi Power and Light Company letter to NRC, L. F. Dale to H. R. Denton, Director, Office of Nuclear Reactor Regulation, NRC,

" Grand Gulf f4uclear Station Unit 1, Docket No. 50-416 Response to Generic Letter 83-28 Item 3.2, September 30, 1985.

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