ML20196B597
| ML20196B597 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/05/1988 |
| From: | Kintner L Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GL-87-09, GL-87-9, TAC-69184, NUDOCS 8812060313 | |
| Download: ML20196B597 (17) | |
Text
r
^
l i
D;cember 5, 1988 DISTRIBUTION See next page Docket No. 50-416 LICENSEE: System Energy Resources, Inc.
FACILITY: Grand Gulf Nuclear Station, Unit 1
SUBJECT:
SUMMARY
OF NOVEMBER 16, 1988 FEETING REGARDING TECHNICAL SPECIFICATION (TSI CHANGES PURSUANT TO GENERIC LETTER 87-09 (TAC NO 69184)
The licensee met with NRR staff to brief reviewers on its reouest for Technical Specification changes per Generic Letter (GL) 87-09.
The request was submitted August 19, 1988 and resubmitted November 9, 1988 to provide additional infor-mation requested by the staff. Enclosure 1 is a list of attendees.
Enclosure 2 is a handout prepared by the licensee.
The licensee provided an overview of its interest and activities regarding implementation of GL 87-09 (Enclosure 2, Pages 2-4).
The licensee also described the method used to evaluate the effects of the proposed TS 3.0.4 on 1
individual TS (Enclosure 2, Pages S-8).
Pages 6 and 7 uescribe the classes of TS considered.
One group consists of Action statements that have an exception to the present TS 3.0.4 and deletion of the exception with the proposed TS 3.0.4 will not change the TS (Attachment 3 of the submittall. A second group consists of Action statements that have an exception to the present TS 3.0.4 and deletion of the exception with the proposed TS 3.0.4 would change the TS (this group was not identified in the submittal).
For this group the exception won M not be deleted. A third group consists of Action statements that have no exception to the present TS 3.0.4 and for which the proposed TS 3.0.4 would provide added flexibility in that operational conditions (mode) changes would be permitted whereas they are presently prohibited. The November 9, 1988 submittal providcs a safety evaluation for each of the TS in the third group.
The licensee found that for some TS, the additional flexibility in the Action statement did not provide a level of safety at least equivalent to that of the limiting condition for operation (LCO) and, therefore, an exception to the proposed TS 3.0.4 was requested for these TS.
The staff commented that one of the TS in the second group. TS 3.3.1, Action a (Enclosure 3) for which the licensee proposed no change appeared to provide greater flexibility than intended by GL 87-09.
If the exception to TS 3.0.4 applies only to Action a, as interpreted by the staff, the TS belongs to the first group and the exception should be deleted because no change to the TS would occur. However, if the exception applies to the footnote to Action a, as interpreted by the licensee, it applies to all the Actions in Table 3.3.1-1, some of which require shutdown. At the staff's request, the lfcensee agreed to consider the staff's interpretation of this TS and deletion of the exception to the proposed TS 3.0.4 In addition, the licenlee will identify and justify other TS that it considers to fall within the second group.
h20jDOCK05000416 O
0313 estros C
p PDC I
o
-2 The staff commented that the response to its request for "a description of I
administrative controls on maintenance, startup operation, and refueling I
activities" (Page 101 of the November 9 submittal) was insufficient. The l'
licensee agreed to expand on its response.
The staff cominented that the evaluation of TS 3.8.4.2 Action statement was inadequate because the Action statement referred to other "Action statements for the affected systems" in Table 3.8.4.2-1, and no evaluation was given of the effect of mode changes with inopercble valves on the safety function of these affected systems. The licensee agreed to evaluate the effect on affected l
systems identified in Table 3.8.4.2-1 and provide an evaluation of the effect l
on typical systems.
The staff commented that the present TS on water chemistry (TS 3.4.4 Action c, item 2) already provides ample operational flexibility and that the additional l
flexibility appeared to degrade the intended level of safety in the LCO.
The l
licensee agreed to consider an exception to the proposed TS 3.0.4 to preclude l
startup until the LCO is met.
Regarding TS 3.1.3.3 Actions c and d, the licensee agreed to consider a footnote restricting startup operations when the alarm for the control rod accumulators l
The action required is to drain each of the 193 accumulators I
within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and read the local pressure each 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The staff commented that such monitoring appeared to be a substantial detraction for the operators l
to cope with during startup.
The staff said that a letter requesting information discussed in the reeting, as well as other information requests from the continuing review, would be issued by November 30, 1988. A response will be requested by December 16, 1988.
I Based on this schedule the target date of March 1,1988 for issuance of the j
amendment appears reasonable.
The licensee commented that should substantial slippage due to unforeseen technisal problems arise it may request a change in those TS which impact the refueling outage, leaving the other changes for later resolution.
The staff said that this sounded 1%e a feasible contingency plan.
I
/_5/
LesterL.Nintner,SeniorProjectManager Project Directorate !!-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation Enclosures As stated cc w/encls:
See next page (GGN TG SUM 69184)
PM WD21:0RPR RPR LLK< ntner:jfw A
nsam 11@/88 1p /88 i
System Energy Resources, Inc.
Grand Gulf Nuclear Station (GGNS) t CC' Mr. T. H. Cloninger Mr. C. R. Hutchinson Vice President. Nuclear Engineering GGNS General Manager and Support System Energy Resources, Inc.
System Energy Resources, Inc.
Post Office Box 756 P. O. Box 23054 Port Gibson, Mississippi 39150 Jackson, Mississippi 39205 Robert B. McGehee, Esquire The Honorable William J. Guste. Jr.
Wise, Carter, Child Steen and Attorney General Caraway Departnent of Justice P. O. Box 651 State of Louisiana Jackson, Mississippi 39205 Baton Rouge, Louisiana 70804 Nicholas S. Reynolds, Esquire Office of the Governor Bishop. Liberman, Cook, Purcell State of Mississippi and Reynolds Jackson, Mississippi 39701 1400 L Street, N.W.
Washington, D.C.
20005-3502 Attorney General Gartin Building Mr. Ralph T. Lally Jackson, Mississippi 39205 Manager of Quality Assurance Middle South Utilities System Mr. Jack McMillan, Director Services, Inc.
Division of Solid Waste Management 639 Loyola Avenue, 3rd Floor Mississippi Department of Natural New Orleans, Louisiana 70113 Resources Post Office Box 10385 Mr. John G. Cesare Jackson, Mississippi 39209 Director, Nuclear Licensing System Energy Resources, Inc.
Alton B. Cobb, M.D.
P. O. Box 23054 State Health Officer Jackson, Mississippi 39205 State Board of Health P.O. Box 1700 Mr. C. R. Hogg, Project Manager Jackson, Mississippt 39205 Bechtel Power Corporation P. O. Box 2166 President Houston, Texas 77252-2166 Claiborne County Board of Supervisors Port Gibson, Mississippi 39150 Mr. H. O. Christensen Senior Resident Inspector Regional Administrator, Region II U.S. Nuclear Regulatory Commission U. S. Nuclear Regulat;ry Commission Route 2. Box 399 101 Marietta Street Port Gibson, Mississippi 39150 Suite 2900 Atlanta, Georgia 30323 l
l I
ENCLOSURE 1 i
i ATTENDEES NRC - SERI MEETING NOVEMBER 16, 1988 000E Offl!!$1195 L. L. Kintner NRC, Project Manager D. M. Verrelli NRC, Acting Project Director
- f. J. Wit.'
NRC/ DEST /ECEB A. L. Toalston NRC/NRR/ DEST /SELN M. A. McCoy DEST /SRXB l
R. J. Giardina NRC/NRR/DOEA/0TSB i
B. S. Marcus NRC/ DEST /SICB i
J. J. Stefano NRC/DSRP/PD 31 J. G. Cesare SERI, Licensing Director J. Fowler SERI, Licensing K. Fortenberry SERI, Licensing L. Robertson SERI, Licensing D. Hoffman SERI,(Consultant) l i
i r
f t
i i
i
ENCLOSURE 2 PAGE - 1
(_
AGENDA SERI - NRC MEETING REGARDING APPLICATION OF GENERIC LETTER 87-09 NOVEMBER 16, 1988 I
INTRODUCTION II BACKGROUND t
III SERI METHODOLOGY IV TABLE OF CONTENTS FOR SERI SUBMITTAL
[
V DISCUSSION l
VI CONCLUSIONS j
PAGE - 3 I INTRODUCTION o
SERI considers Generic Letter 87-09 to be an improvement.
o The upcoming refueling outage (March 1989) and future outages incorporate the Generic Letter 87-09 concept into their logic.
o Several plants have already received amendments in accordanca with Generic Letter 87-09.
susquehanna 04/04/88 McGuire 06/21/88 Catawba 07/12/88 Beaver Valley 08/09/88 St. Lucie 07/19/88 Hope Creek 09/28/88 Limerick 11/07/88 South Texas Project (Low Power License)
(. _-
i PAGF, - 3 l
II BACKCROUND l
June 1987 SERI requested 3.0.4 exception for 5
specifications to provide needed flexibility during refueling outages.
June 1987 Generic Letter 87-09 issued.
October 1987 SERI revised 3.0.4 exception request to a one-time exception request for RF02 only.
SERI agreed to re-submit in accordance with Generic Lotter 87-09.
l l
December 1987 One-time exceptions to 3.0.4 approved for RF02.
May 1988 STR.*;
prepared an amendment request in accordance with Generic Letter 87-09.
Submittal was modeled after a previously approved submittal from Susquehanna.
June 1988 Discussions held with NRC concerning planned submittals, including the Generic Letter 87-09 submittal.
SERI is directed to include consideration of each affected Technical Specification.
FAGE - 4 August 1988 SERI revised and submitted Generic Letter 87-09 amendment request to include consideration of each affected Technical Specification.
Each affected specification was considered and was discussed in categories.
j August 1988 NRC issued additional internal guidance on Generic Letter 87-09:
all technical specification changes require a technical safety basis.
the effect of the proposed change on maintenance priorities should be assessed.
September 1988 NRC advised that categorization war not appropriate and an individual evaluation 1
should be provided for each specification.
NRC also asked that the submittal address 1
maintenance priorities.
1 Noventer 1988 SERI resubmitted revised amendment request.
l.
1 4
+
PAGE - 5 III SERI METHODOLog A.
Generic Letter 87-09 Encouraged Technical specification changes to resolve three problemnt 1.
Unnecessary restrictions on mode change caused by 3.0.4.
2.
Unnecessary shutdown caused by 4.0.3 when surveillances are inadvertently exceeded.
I 3.
Conflicts between 4.0.3 and 4.0.4 when complying with shutdown action requirements.
I i
PAGE - 6 B.
Change to Specification 3.0.4 o
current 3.0.4 Ensures that a
higher mode of operation is not entered when equipment is inoperable or when parameters exceed their specified limits.
o current 3.0.4 exceptions Stated in individual specifications.
o Revised 3.0.4
- For Action requirements permitting continued operation for an unlimited period of time, mode changes are permitted in accordance with these Action Requirements.
Some specifications already have 3.0.4 exceptions and meet the criteria for exception under the revised 3.0.4 (Attachment 3).
Some specifications already have 3.0.4 exceptions but do not meet the criteria for exception under the revised 3.0.4.
(It is not the Staff's intent that the ravision of Specification 3.0.4 should result in more restrictive requirements for individual specifications.
No change is being requested.)
PAGE - 7 Some specifications do not currently have 3.0.4 exceptions but do meet the criteria for exception under the revised 3.0.4.
t o (flexibility is being requested) o (flexibility not being requested) r L
l d
I e
I O
l L
i t
I l
?
r I
f l
I l
PAGE - 8 C.
Safety Analysis were deve.'.oped for each action for which the revised T.S. 3.0.4 provided additional flexibility.
1.
The safety function or functions involved in each affected Specification was evaluated.
2.
The effect of the revised T.S.
3.0.4 on each affected specification was evaluated.
3.
The effect of the revised T.S.
3.0.4 on the safety functions of each affected Specification was evaluated.
4.
The acceptability of each affected specification was demonstrated by:
a.
Showing that compliance with the relevant Action requirement achieve a
level of safety greater than or equal to the Limiting conditions for Operation.
b.
Identifying any additional restrictions or administrative controls needed to demonstrate the acceptability of the proposed change.
COVER PAGE for NL 88/01, Implementation of Generic Letter 87-09 Revision 1 l
page #
Subject 2
Discussion 2
Justification 4
No Significant Ha:ards Consideration 10 l : Technical Specifications for which 16 l
the pretosed change to 3.0.4 will provide new flexibility : Technical Specifications for which 20 SERI is not currently reauesting the new flexibility provided by the preposed change to 3.0.4 : Technical Specifications for which 21 l
the currently stated exception to 3.0.4 is being deleted because the new 3.0.4 provides ecuivalent provisions : Evaluation of Action reautrements 23 for Tecnnical Specifications with new flexibility l : Description of maintenance priorities 98 and control at Grand Gulf Technical Specification Mark-Ups 102 l
l l
l J14MISCSE102501 - 1
ENCLOSURE 3 3/4.3 INSTRUMENTATION 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION LIMITING CON 0! TION FOR OPERATION 3.3.1 As a minimum, the reactor protection system instrumentation channels shown in Table 3.3.1-1 shall be OPERABLE with the REACTOR PROTECTION SYSTEM RESPONSE TIME as shown in Table 3.3.1-2.
APPLICABILITY: As shown in Tal e 3.3.1-1.
ACTION:
a.
With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement for one trip system, place the inoperable channel and/or that trip system in the tripped condition
- within one hour.,
The provisions of Specification 3.0.4 are not applicable.
b.
With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement for both trip systems, place at least one trip system ** in the tripped condition within one hour and take the ACTION requirud by Table 3.3.1-1.
SURVEILLANCE REQUIREMEt!TS 4.3.1.1 Each reactor protection system instrumentation chatinel shall be demonstrated OPERABLE by the pei forniance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.1.1-1.
4.3.1.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed at least once per 18 monthi
- 4. 3.1. 3 The REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip functional unit shown in Table 3.3.1-2 shall be demonstrated to be within its limit at least once per 18 months.
Each test shall include at least one chan-nel per trip system such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specif 9 reactor trip system.
"An inoperable channel need not be placed in the tripped condition where this would cause the Trip Function to occur.
In these cases, the inoperable channel shall be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the ACTION required by Table 3.3.1-1 for that Trip Function shall be taken. '
- The trip system need not be placed in the tripped condition if this would cause the Trip Function to occur. When a trip system can be placed in the tripped condition without causing the Trip Function to occur, place the trip system with the most inoperable channels in the tripped condition; if both systems have the same number of inoperable channels, place either trip system in the tripped condition.
GRAND GULF-UNIT 1 3/4 3-1
TABLE 3.3.1-1 cs REAC7OR PSGTECTION SYSTEM INSTRUIENTATION g
APPLICABLE MINIfRM OPERATIONAL DPERABLE CHAfeIELS FUNCTIONAL UNIT COISITIONS PER TRIP SYSTEM (a)
ACTION 1.
a.
Neutron Flus - High 2
3 1
3, 4 3
2 5(b) 3 3
b.
Inoperative 2
3 1
3, 4 3
2 5
3 3
2.
Average Power Range Monitor IC):
a.
Neutron Flux - Nigh, Setdown 2
3 1
3 3
2 5(b) 3 3
w4 b.
Flow Biased Simulated Thereal Power - High 1
3 4
c.
Neutron Flux - High 1
3 4
d.
Inoperative 1, 2 3
1 3
3 2
5 3
3 3.
Reactor Vessel Steam Dome Id)
Pressure - High 1, 2 2
1 4.
Reactor Vessel Water Level - Low, Level 3 1, 2 2
1 5.
Reactor Vessel Water Level-High,
{
g)
Level 8 1
2 4
6.
Main Steam Line Isolation Valve -
I ')
4 4
I
)
Closure Id)
I 7.
Main Steam Line Radiat.fon - High 1, 2 2
5' III l
8.
Drywell Pressure - High 1, 2 2
1 l
I l
u.
- L
, TABLE 3.3.1-1 (Continued)
REACTOR PROTECTION SYSTEM INSTRUMENTATION E
m APPLICA8LE MINIfRM E
OPERATIONAL OPERABLE CHANNELS J
FUNCTIONAL UNIT CONDITIONS PER TRIP SYSTEM (a)
ACTION
~
9.
Scram Discharge Volume Wter Level - High If 2
1 g
5 2
3 10.
Turt.ine Stop Valve - Closure 1(h) 4 6
11.
Turbine Control Valve Fast Closure, Valve Trip System Oil Pressure - Low 1(h) 2 6
w 12.
Reactor PhkW Switch Shutdown 1
Position 1, 2 2
1 w
3, 4 2
7 1
5 2
3
- 13. Manual Scram 1, 2 2
1 3, 4 2
8 5
2 9
I O
I INSTROMENTATION h
TABLE 3.3.1-1 (Continued)
REACTOR PROTECTION SYSTEM INSTRUMENTATION i
ACTION ACTION 1 Be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
ACTION 2 Verify all insertable control rods to be inserted in the core and i
lock the reactor mode switch in the SHUTDOWN position within ene hour.
ACTION 3 Suspend all operations involving CORE ALTERATIONS *, and insert all insertable control rods within one hour.
Be in at least STARTUP within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
ACTION 4 Be in STARTUP with the main steam line isolation valves closed ACTION 5 within G hours or in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Initiate a reduction in THERMAL POWER within 15 minutes and ACTION 6 reduce turbine first stage pressure to less than the automatic bypass setpoint within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Verify all insertable control rods to be inserted within ACTION 7 one hour.
Lock the reactor mode switch in the SHUTDOWN position within ACTION 8 one hour.
Suspend all operations involving CORE ALTERATIONS *, and ACTION 9 insert all insertable control rods ar.d lock the reactor mode switch in the SHUTDOWN position within one hour.
"Except movement of IRM, SRM or special movable detectors, or replacement of LPRM strings provided SRM instrumentation is OPERABLE per Specification 3.9.2.
GRAND GULF-UNIT 1 3/4 3-4
ElEIElE91!90.E98.0EEJJU9,}yby381,961Ep; December 5, 1988 Facility: Grand Gulf Nuclear Station, Unit 1 Docket ' File * >
NRC PDR Local POR PDil-1 Reading E. Adensam P. Andersoi1 L. Kintner OGC E. Jordan (NNBB 3302)
- 8. Grimes (9A2)
F. Witt s8H7)
J. Stefano (13H15)
R. Giardina 11f23)
A. Toalston 8020)
D. Verrelli.9egion !!)
ACRS (10)
R. Dorchardt (17019) cc:
Licensee / Applicant Service List