ML20195H143

Requests Addl Info Re 880819 & 1109 Requests for Changes to Tech Specs 3.0 & 4.0,per Generic Ltr 87-09

ML20195H143
Person / Time
Site:	Grand Gulf
Issue date:	11/25/1988
From:	Kintner L Office of Nuclear Reactor Regulation
To:	Cottle W SYSTEM ENERGY RESOURCES, INC.
References
GL-87-09, GL-87-9, TAC-69814, NUDOCS 8811300240
Download: ML20195H143 (4)

Text

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DISTRIBUTION j

i Mw NRC PDR I

l November 25, 1988 Local PDR PD21 r/f  !

S. Varga (14E4) '

G. Lainas Docket No. 50 416 E. Adensam P. Anderson t L. Kintner  !

Mr. W. T. Cottle OGC  !

1 Vice President, Nuclear Operations E. Jordan (MNBB3302) i System Energy Resources, Inc. 8. Grimes (9A2) l Post Office Box 23054 W. Hodges (8E23)  !

Jackson, Mississippi 39205 F. Rosa (8020) l C. McCracken (8H7)

Dear Mr. Cottle:

ACRS (10) l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION . GRAND GULF NUCLEAR i' l STATION (GGNS), UNIT 1(TACNO.69814)

By letters dated August 19, 1988 and November 9, 1988, System Energy -

re Resources, Inc.fTS)pursuant quested tochanges GenerictoLetter the GGNS, Unit 1 Technical

Specifications 87-09 regarding TS Sections 3.0 and 4.0. The NRC staff is reviewing these submittals and finde  ;

that additional infonnation is needed to complete our review. The request for l j additional information is enclosed.  ;

! In order to support our review schedule, you are reSuested to respond to the i i enclosed request by December 16, 1988. This request was discussed with your  ;

j representatives in a meeting on November 16, 1988. j

! The reporting and/or recordkeeping requirements of this letter affects fewer  ;

! than ten respondents; therefore OMB clearance is not required under P. L. ,

j 96-511. e 1

i Sincerely, j l l j Lester L.'Kint er Senior Project Manager '

j Project Directorate Il-1 j Division of Reactor Projects I/II  ;

, Office of Nuclear Reactor Regulation t i

Enclosure:

) Request for Additional l j Information i cc w/erclosure:

1 See next page ,

, GGNS LTP. TAC 60814 d *See previous concurrence i

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]DATF:11/ /88 OFFICIAL PECORD COPY l

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POR ADOCK 05000416 i P_ ____ _____ __ PDC- _ _ _ _ _ _ _ _ _  ;

DISTRIBUTION Docket File  ;

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NRC PDR Local PDR  !

' PD21 r/f i S. Varga (14E4)

G. Lainas .

Docket No. 50 416 E. Adensam  !

P. Anderson  !

L. Kintner i Mr. W. T. Cottle OGC +

, Vice President. Nuclear Operations E. Jordan MNBB3302) i System Energy Resources, Inc. B. Grimes 9A2) i Post Office Box 23054 W. Hodges 8E23  !

Jackson, Mississippi 39205 F. Rosa (8020))  ;

C. McCr en(8H7)  !

Dear Mr. Cottle:

ACRS (1 c, i STATION (GGNS), UNIT 1 (TAC NO. 69814) l t

By letters dat;,d August 19, 1988 and Noverber 9,1988 System Energy [

l Resources re l Specifications Inc.(TS) quested pursuantchanges to Generic to the GGNS, Letter 87-09,Unit 1 Technical regarding TS - Sections 3.0 and 4.0. The NRC staff is reviewing these submittals and finds that additional information is needed to complete our review. The request for l

additional information is enclosed. ,

In order to support our review schedule, you are requested to respond to the f i enclosed request by December 16, 1988. This request was discussed with your

j representatives in a meeting on November 16, 1988. L I

The reporting and/or recordkeeping requirements of this letter affects fewer l than ten responoents; therefore, OMB clearance is not required under P. L. I i 96-511. I i

• l Sincerely,  !

I i i

l  !

l i tester L. Kintner, Senior Project Manager i Project Directorate 11-1  :

Division of Reactor Projects 1/II l lI Office of Nuclear Reactor Regulation i

Enclosure:

i Request for Additional  !

l Information

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cc w/ enclosure: l See next page f+,fj.k  ?

GGNS LTR TAC 69814 d C11

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DATE :11/ /88, :11/2.Y88 :11/G'88 :11/ /88 :11/$/88  :  :

OFFICIAL RECORD COPY

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. ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION_

CHANGES TO TECHNICAL SPECIFICATIONS PURSUANT TO GENERIC LETTER 87-09 GRAND GULF NUCLEAR STATION. UNIT 1 (GGHS-1)

The following information is needed for the staff's review of the August 19  ;

and November 9, 1988 submittals requesting changes to the GGNS-1 Technical Specifications (TS). This request was discussed in a meeting with the licensee <

on November 16, 1988.

1. Identify the TS and the associated Action Statements which presently include the statement "The provisinns of Specification 3.0.4 are not applicable" and which are proposed to be left unchanged when the proposed TS 3.0.4 is made effective. For these TS, justify the retention of this  :

statement in light of the revised TS 3.0.4 which defines the Action ,

Statement requirements for which entry into an Operational Condition shall -

not be made and the Action Statement requirements for which entry may be made. For example TS 3.3.1, "Reactor Protection System Instrumentation,"

c Action Statement "a" requires that one trip system be placed in the  ;

tripped condition whenever the nunter of operable channels is less than the minimum specified in Table 3.3.1-1. This action presently has an exception to TS 3.0.4 which states that "The provisions of Specification  ;

3.0.4 are not applicable." It is not clear why the November 9,1988 -

submittal proposes to retain this exception to TS 3.0.4 A footnote to  !

Action Statement "a" provides for alternative actions as given in Table  :

3.3.1-1 if placing the channel in a tripped condition would cause the trip function to occur. However, the exception is not intended to apply to the  ;

footnote. As an illustration, Functional Unit 1 in Table 3.3.1-1 is appli-  !

cable to Operational Conditions 2, 3, 4 and 5. Entry into Operational .

Condition 2 has an associated Action Statement which requires the reactor to be in HOT SHUTOOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Applying the exception to the  :

footnote would allow a transition from Condition 3 to 2 (change to a higher mode) followed by a shutdown shortly thereafter. This situation is not presently intended and is not intended by Generic Letter 87-09.

Another similar example where it is not clear why the exception to TS 3.0.4 should be retained is TS 3.3.2 (Isolation Action Instrurentation)

Action Statement "b".

r

2. By submittal dated August 12, 1988, the licensee proposed changes to i Specification 3.1.3.3, "Control Rod Scram Accumulators" by adding Action Statements "c" and "<t". Action Statements "c" and "d" previde alternate methods of determining the operability of the scram accumul tors in the ,

event the alarm for the scram accumulator pressure sensors and leak detectors is inoperable. The single alarm is a part of the rod control and information system (RCIS), and its failure could result in an indeter-minata number of degraded scram accumulators. To ensure that operable accur.ulators are available shortly prior to and during startup when the ettention of operations personnel should not be unnecesharily divert 2d, the staff requires either (a) the addition of a footnote in this TS to the effect that the alternate surveillance actions required by proposed Action Statements "c" and "d" be completed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period preceding startup initiation, or (b) justification be provided for not including the footnote described in (a) above.

6

• ' 9 t t

2

3. The Action Statement for TS 3.8.4.2, "Motor Operated Valves Thermal Overload Protection," states that if the thermal overload protection for the valves listed in Table 3.8.4.2-1 cannot be bypassed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, then declare the affected valve ir. operable and apply the appropriate Action Staterrent for the affected system. Evaluate the safety signifi-cance of Operational Condition changes as permitted under the revised TS 3.0.4 for inoperability of selected valves that are representative of the group of valves listed in Table 3.8.4.2-1. Also, list the valves that are associated with each group.

4 Technical Specific 4 tion 3.4.4, "Chemistry," was not changed by licensee's submittal dated November 9,1988. The proposed change to Technical Specification 3.0.4 would allow new flexibility by permitting entry into Operational Condition 3, (HOT SFUTCOWN) with chloride concentrations exceeding 0.5 ppm provided that an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the reactor coolant system is performed. This is not in agreement with the "BWR Normal Water Chemistry Guidelines," 1986 Revision, EPRI NP-4946-SR, dated October 1987, which the licersee has made a committment to follow.

These Guidelinet recommend that chloride concentrations be equal to or less than 0.1 ppm, prior to startup. Provide a footnote for TS 3.4.4 to maintain the present requirements when the proposed TS 3.0.4 is made effective or justify the edded flexibility.

5. The staff's Octcber S,1988 letter requested, among other things, "a description of adminstrative controls on maintenance, startup operatiun and refueling activities to demonstrate that plant startup and refueling activities will usually be conducted when all required equipment is operable." The licensee's Movember 9,1988 response stated that "work is prioritized to ensure that equipmant important to plant safety is returned to operation in a timely fashion." This is an inadequate response.

Provide assurance that the maintenance of equipment required by TS Limiting Conditions 'or Operation will receive the same priority after the proposed TS changes are made effective, even though the proposed TS do not require that equipment to be operable for startup. In addition, provide a description of adminstrative controls on outage activities in light of the additienal flexibility ouring refueling outages provided by the proposed changes.