ML20205M641

Responds to Violations Noted in Insp Rept 50-416/86-01. Corrective Actions:Special Training Program Will Be Developed & Conducted for Personnel Performing FSAR Update Reviews to Provide More Definitive Guidance

ML20205M641
Person / Time
Site:	Grand Gulf
Issue date:	04/07/1986
From:	Kingsley O MISSISSIPPI POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
AECM-860083, NUDOCS 8604150335
Download: ML20205M641 (4)

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MISSISSIPPI POWER & LIGHT COMPANY

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Helping Build Mississippi EdMIMdidd5 P. O. BOX 1640, J ACK SON, MISSISSlPPI 39215-1640

'10 aB;"'"

April 7, 1986

o. D. KINGSLEY, JR.

VICE PREllDEasT NUCLEAR OPERATIONS Dr. J. Nelson Crace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W.,

Suite 2900 Atlanta, Georgia 30323

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Report No. 50-416/86-01 dated March 6, 1986 (MAEC-86/0056)

AECM-86/0083 Mississippi Power & Light Company hereby submits the response to Violation 50-416/86-01-01 regarding Failure to Update the FSAR.

Yours

uly, r

ODK:dem Attachment cc:

Mr. T. H. Cloninger (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 h

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J14AECM86032401 - 1 Member Middle South Utilities System

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Attrch;;nt to l

AECM-86/0083 i

NRC VIOLATION 50-416/86-01-01 l

NOTICE OF VIOLATION 10 CFR 50.71e requires that the updated Final Safety Analysis Report (FSAR) accurately present information and analyses submitted to the Commission and that the FSAR be up-to-date within a maximum of six months of the date of filing the revision.

Contrary to the above, information presented ::y the licensee to the Commission on April 26 and 28, 1985, and accepted by the Commission by a Safety Evaluation Report (SER) issued on April 29. 1985, was not reflected in the updated FSAR issued on December 1, 1985.

Consequently, the peak l

clad temperature for the loss of coolant accideat, presented in FSAR Table 6.3-3, is approximately 10*F less than predicted by the licensee's current analysis.

In addition, Tables 15.0-2 and 15.0-3 were not revised to show that the pump inertial time constant used in analysis was three seconds.

I I. ADMISSION OR DENIAL OF ALLEGED VIOLATION Mississippi Power Light Company (MP&L) aduita to the alleged violation.

This violation had no effect on the health and safety of the public.

II. REASONS FOR THE VIOLATION IF ADMITTED 1

l On April 28, 1985 MP&L submitted a letter (AECM-85/0138) to NRC l

documenting a slight deviation between the results of Startup Test No. 27 (Turbine Trip and Generator Load Rejection) and No. 30 (Recirculation Pump Trip) and the FSAR specified Level 1 acceptance criteria with regard to recirculation pump coast down performance.

General Electric and MP&L analyzed this deviation (documented in attachments to the letter) and concluded that the actual pump coast down performance has negligible impact on the plant's accident and transient analyses, as presented in FSAR Chapters 6 and 15.

The effect on calculated PCT was estimated by General Electric to be small (less than 10*F).

The addition of a 10*F delta to the current GGNS PCT of 2098'F results in a PCT well below the 10 CFR 50.46 acceptance criterion of 2200*F. MP&L, based on its review and i

the General Electric analyses, concluded that the slight test deviation from the specified acceptance criteria was acceptable and that the test I

results should be considered acceptable.

Further, in. Attachment 1 MP&L l

stated "It is also concluded that no modification to the FSAR acceptance criteria is necessary and that the test results should be accepted." At the end of the letter MP&L requested NRC's approval of this deviation.

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In the NRC's response to MP&L's request on April 29,1985 (MAEC-85/0141) the Staff stated:

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Attrch=nt to AECM-86/0083 "The licensee has concluded, and staff agrees, that the deviation is i

acceptable because neither ECCS analyses (FSAR Chapter 6) nor the transient response analyses (FSAR Chapter 15) are significantly impacted by the observed deviation from Level 1

acceptance criteria.

The licensee also concluded, and staff concurs, that no modification to the FSAR acceptance criteria is necessary and that the test results should be accepted."

One phase of MP&L's FSAR Update Program was the review of all letters sent to NRC from April 28, 1978, through June 1, 1985, the cut-off date of the initial FSAR update.

This was a necessary part of the FSAR Update Program to insure that analyses submitted to the NRC were identified and incorporated into the updated FSAR.

The review was conducted according to written instructions developed specifically for the FSAR Update Program.

The review of letter AECM-85/0138 was completed and documented on May 24, 1985.

The letter was incorrectly determined to have no potential FSAR impact.

MP&L has conducted interviews with the engineer who reviewed the letter and has concluded that the reviewer was misled by the information and

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overall conclusions given in the AECM letter; specifically the statements pertaining to negligible impact on accident and transient analyses, small effect on PCT (less than 10*F), and the conclusion that there was no need for modifications to the FSAR acceptance criteria.

III. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 1.

MP&L is including appropriate UFSAR changes to document the subject analyses in its next update scheduled to be filed on December 1, 1986, i

2.

MP&L has reviewed all startup test exceptions written against Level I failures to confirm that no further changes to the FSAR are j

l required to reflect correct plant operations or descriptions resulting from the startup test program.

I IV. CORRECTIVE STEPS TAKEN TO AVOID FUTURE VIOLATIONS 1.

MP&L plans to implement an improved FSAR impact review

.s as part of its procedure on development of correspondence to Hhc.

This process will require review and recognition of potential FSAR impact by the Licensing staff member responsible for the preparation of the NRC correspondence.

This will help ensure positive recognition of needed FSAR changes.

A management directive has placed this program in effect while a procedure is under development.

2.

MP&L will develop and conduct a special training program for personnel performing these reviews to provide more definitive guidance and enhanced capability to recognize potential FSAR impacts.

This training will also focus on FSAR content and format.

Special emphasis will be placed on analysis information submitted to the NRC as addressed in 10CFR50.71(c).

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Attcchmnt to AECM-86/0083 V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by December 1, 1986, upon submittal of the next update to the FSAR.

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