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MONTHYEARAECM-82-492, Requests That License Condition 2.C.(44)(i)(a) Be Revised to Require Submittal Re Automatic Depressurization Sys Logic Mods by 821215.Previous Submittal Date of 821029 Erroneously Requested Due to Revised BWR Owners Group Schedule1982-10-21021 October 1982 Requests That License Condition 2.C.(44)(i)(a) Be Revised to Require Submittal Re Automatic Depressurization Sys Logic Mods by 821215.Previous Submittal Date of 821029 Erroneously Requested Due to Revised BWR Owners Group Schedule Project stage: Other AECM-82-603, Comments on BWROG-8260, NUREG-0737,Item II.K.3.18,Mod of Automatic Depressurization Sys Logic. Option 4,providing Bypass Timer Delay,Will Assure Adequate Core Cooling During Worst Case Conditions1982-12-14014 December 1982 Comments on BWROG-8260, NUREG-0737,Item II.K.3.18,Mod of Automatic Depressurization Sys Logic. Option 4,providing Bypass Timer Delay,Will Assure Adequate Core Cooling During Worst Case Conditions Project stage: Other AECM-84-0252, Special Rept 83-067/3:on 830819,during Scheduled Surveillance on Four Pipe Mounted Triaxial Peak Recording Accelerographs Used for Seismic Monitoring,Instruments Damaged Due to over-ranging.Design Changes Under Way1984-05-0404 May 1984 Special Rept 83-067/3:on 830819,during Scheduled Surveillance on Four Pipe Mounted Triaxial Peak Recording Accelerographs Used for Seismic Monitoring,Instruments Damaged Due to over-ranging.Design Changes Under Way Project stage: Other AECM-84-0307, Submits Commitment to Evaluate Design of Certain Seismic Monitoring Instruments to Determine Location,Range & Type of Instrument Prior to Restart Following First Refueling Outage.Proposed Tech Spec Changes Will Be Submitted1984-05-31031 May 1984 Submits Commitment to Evaluate Design of Certain Seismic Monitoring Instruments to Determine Location,Range & Type of Instrument Prior to Restart Following First Refueling Outage.Proposed Tech Spec Changes Will Be Submitted Project stage: Other AECM-85-0014, Forwards Addl Info,Requested in ,Re Concerns Involving Transfer of Control to Remote Shutdown Panel Resulting in Change in Operating Status of Load That May Be Detrimental to Safe Shutdown1985-01-17017 January 1985 Forwards Addl Info,Requested in ,Re Concerns Involving Transfer of Control to Remote Shutdown Panel Resulting in Change in Operating Status of Load That May Be Detrimental to Safe Shutdown Project stage: Other ML20133P1711985-08-12012 August 1985 Proposed Tech Specs,Reflecting Design Changes & Editorial Clarification Re Leak Rate Testing of RHR to Head Spray Isolation Valve & ECCS Actuation Instrumentation Project stage: Other AECM-85-0228, Application for Amend to License NPF-29,changing Tech Specs to Reflect Design Changes & Editorial Clarifications.Fee Paid1985-08-12012 August 1985 Application for Amend to License NPF-29,changing Tech Specs to Reflect Design Changes & Editorial Clarifications.Fee Paid Project stage: Request ML20133A7611985-09-25025 September 1985 Proposed Changes to Tech Specs 6.3.1 & 6.4.1,providing Justification for Exemption from Requirements for Senior Reactor Operator Qualifications Project stage: Request AECM-85-0304, Application for Amend to License NPF-29,supplementing 850812,23 & 30 Submittals,To Provide Justification for Exemption from Tech Spec 6.3.1 & 6.4.1 Requirements for Senior Reactor Operator Qualifications1985-09-25025 September 1985 Application for Amend to License NPF-29,supplementing 850812,23 & 30 Submittals,To Provide Justification for Exemption from Tech Spec 6.3.1 & 6.4.1 Requirements for Senior Reactor Operator Qualifications Project stage: Supplement AECM-85-0306, Responds to Request for Addl Info Re 850812 Application for Amend to License NPF-29.Prompt Resolution of Questions & Approval of Previously Submitted Tech Specs Needed for Outage Scheduled to Start on 8510121985-10-0505 October 1985 Responds to Request for Addl Info Re 850812 Application for Amend to License NPF-29.Prompt Resolution of Questions & Approval of Previously Submitted Tech Specs Needed for Outage Scheduled to Start on 851012 Project stage: Request AECM-85-0341, Forwards Addl Info Re ECCS Performance Analysis Which Supports Increase in Peak Cladding Temp of 51 F Compared to Current FSAR Analysis,Per Request.Fsar Changes Will Be Made If Design Change Implemented1985-10-22022 October 1985 Forwards Addl Info Re ECCS Performance Analysis Which Supports Increase in Peak Cladding Temp of 51 F Compared to Current FSAR Analysis,Per Request.Fsar Changes Will Be Made If Design Change Implemented Project stage: Other ML20137Q8971985-11-22022 November 1985 Safety Evaluation Re Low Pressure ECCS Sys Pressure Permissive Interlocks.Exceeding ASME Code Allowable Design Pressure for Interlocks Unacceptable Project stage: Approval ML20137Q8901985-11-22022 November 1985 Forwards Safety Evaluation Re 850812 Request for Amend to License NPF-29,adding Pressure Permissive Interlocks to Control Circuits for Low Pressure ECCS Injection Valves,Item 13 of 850812 Request Should Be Revised Project stage: Approval AECM-86-0006, Forwards Technical Justification for Proposal to Delete Peak Recording Accelerographs Currently Installed on Reactor Piping Locations,Per Section 16.3.1 of Sser 6 (NUREG-0831).Response by 860228 Requested.Fee Paid1986-01-10010 January 1986 Forwards Technical Justification for Proposal to Delete Peak Recording Accelerographs Currently Installed on Reactor Piping Locations,Per Section 16.3.1 of Sser 6 (NUREG-0831).Response by 860228 Requested.Fee Paid Project stage: Other AECM-86-0082, Supplemental Application for Amend to License NPF-29, Modifying 851114 Proposed Change Re License Condition 2.C.(28) & Revising Tech Specs Concerning Design Changes to Be Implemented During First Refueling Outage.Fee Paid1986-03-21021 March 1986 Supplemental Application for Amend to License NPF-29, Modifying 851114 Proposed Change Re License Condition 2.C.(28) & Revising Tech Specs Concerning Design Changes to Be Implemented During First Refueling Outage.Fee Paid Project stage: Supplement ML20154R5461986-03-21021 March 1986 Proposed Tech Specs Revising License Condition 2.C.(28) Re Requirement for Corporate Mgt Officials on Nuclear Operations Staff & Modifying Tables 3.3.7.2-1 & 4.3.7.2-1 to Reflect Design Change Project stage: Other ML20155D8101986-04-0808 April 1986 Summary of 860401 Meeting W/Utils Re Resolution of Issue of Interlocks for ECCS Injection Valves Which Also Function as Pressure Isolation Valves.Viewgraphs & List of Attendees Encl Project stage: Meeting ML20205S2151986-05-27027 May 1986 Safety Evaluation Supporting Util 860110 Proposal to Remove Four Peak Recording Accelerographs Mounted on Reactor Piping Project stage: Approval ML20205S2021986-05-27027 May 1986 Forwards Safety Evaluation Supporting Util 860110 Proposal to Remove Four Peak Recording Accelerographs Installed on Reactor Piping Due to Inoperability Caused by Operating Transients & Adequacy of Other Seismic Instrumentation Project stage: Approval AECM-86-0163, Provides Addl Info to 860321 Proposed Change PCOL-86/04 to License NPF-29 Re Mods to Automatic Depressurization Sys Per BWR Owners Group Evaluation of NUREG-0737,Item II.K.3.18. Info Clarifies Changes Made to Sys Initiation Circuitry1986-05-30030 May 1986 Provides Addl Info to 860321 Proposed Change PCOL-86/04 to License NPF-29 Re Mods to Automatic Depressurization Sys Per BWR Owners Group Evaluation of NUREG-0737,Item II.K.3.18. Info Clarifies Changes Made to Sys Initiation Circuitry Project stage: Request AECM-86-0111, Forwards Supplemental Info Re Design Change to Add Interlocks to ECCS Injection Valves,Per NRC 860403 Telcon. Approval of 850812 Proposed Amend to Tech Specs Also Requested1986-05-30030 May 1986 Forwards Supplemental Info Re Design Change to Add Interlocks to ECCS Injection Valves,Per NRC 860403 Telcon. Approval of 850812 Proposed Amend to Tech Specs Also Requested Project stage: Supplement AECM-86-0221, Application for Amend to License NPF-29,changing Tech Spec Seismic Monitoring Instrumentation Tables to Delete four- Peak Recording Accelerographs on Reactor Piping & Make Measurement Values Consistent.Fee Paid1986-07-15015 July 1986 Application for Amend to License NPF-29,changing Tech Spec Seismic Monitoring Instrumentation Tables to Delete four- Peak Recording Accelerographs on Reactor Piping & Make Measurement Values Consistent.Fee Paid Project stage: Request AECM-86-0208, Forwards Addl Info Re Emergency Containment Venting in Response to Item 1.1 of 860527 Request.Encl Rev 1 to ...Emergency Procedures Upgrade Program Procedures Generation Package Addresses Remaining Request1986-07-15015 July 1986 Forwards Addl Info Re Emergency Containment Venting in Response to Item 1.1 of 860527 Request.Encl Rev 1 to ...Emergency Procedures Upgrade Program Procedures Generation Package Addresses Remaining Request Project stage: Request ML20207E7261986-07-15015 July 1986 Proposed Changes to Tech Spec Seismic Monitoring Instrumentation Tables 3.3.7.2-1 & 4.3.7.2-1 to Delete four- Peak Recording Accelerographs on Reactor Piping & Make Measurement Values Consistent Project stage: Request ML20209D1521986-08-28028 August 1986 Notice of Consideration of Issuance of Amend to License NPF-29 & Proposed NSHC Determination & Opportunity for Hearing Re Addition of Specs to Table 3.3.3-1, ECCS Actuation Instrumentation Project stage: Other ML20210L7951986-08-28028 August 1986 Notice of Consideration of Issuance of Amend to License NPF-29 & Proposed Nhsc Determination & Opportunity for Hearing Re 850812,0925,1005 & 22 Requests for Revs to Listed Tech Spec Tables on ECCS Actuation Instrumentation Project stage: Other ML20209D1361986-09-0202 September 1986 Requests Notice of Consideration of Issuance of Amend to License NPF-29 & Proposed NSHC Determination & Opportunity for Hearing Re Addition of Specs to Table 3.3.3-1, ECCS Actuation Instrumentation Be Expeditiously Published in Fr Project stage: Other ML20215E4051986-10-0606 October 1986 Amend 20 to License NPF-29,revising Tech Specs to Reflect Installation of Pressure Interlocks for Injection Valves in Low Pressure ECCS & Mod to Automatic Depressurization Sys Actuation Logic Project stage: Other ML20215E4131986-10-0606 October 1986 Safety Evaluation Supporting Amend 20 to License NPF-29 Project stage: Approval AECM-86-0329, Submits List of Affected Tech Spec Pages,Effective Dates & Associated Amend Numbers,In Response to NRC 860827 & 1006 Requests1986-10-14014 October 1986 Submits List of Affected Tech Spec Pages,Effective Dates & Associated Amend Numbers,In Response to NRC 860827 & 1006 Requests Project stage: Other AECM-86-0332, Advises of Effective Dates for Amends 6 & 8 to License NPF-29 for Listed Tech Specs,In Response to 851021 & 860827 Requests1986-10-17017 October 1986 Advises of Effective Dates for Amends 6 & 8 to License NPF-29 for Listed Tech Specs,In Response to 851021 & 860827 Requests Project stage: Other 1986-01-10
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Enclosure 4
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO DELETION OF PEAK RECORDING ACCELEROGRAPHS MISSISSIPPI POWER AND LIGHT COMPANY GRAND GULF NUCLEAR STATION UNIT NO. 1 DOCKET NO. 50-416
- 1. 0 INTRODUCTION In accordance with the guidance provided in Regulatory Guide 1.12, Revision 1, a total of three triaxial peak recording accelerographs (PRAs) should be provided at one location on each of the following:
i (1) A selected location on the reactor equipment; 4
(2) A selected location on the reactor piping; I
(3) A selected location on Seismic Category I equipment or piping outside of the containment structure.
In Grand Gulf Nuclear Station (GGNS), Unit 1, four out of 11 PRAs pro-vided are installed on the reactor piping, namely, one each on reactor recirculation piping, main steam piping, the low pressure core spray line, and the high pressure core spray line.
As reported by the licensee in its letter AECM-84/0252, dated May 4, 1984, these four instruments were found non-functional in July, 1983, during surveillance.
The licensee's commitments to review this matter were documented in its letter AECM-84/0307, dated May 31, 1984.
This included a commitment to implement appropriate design changes prior to restart following the first refueling outage, as well as a commitment to submit a proposed i
Technical Specification change on a schedule consistent with the implementation of these modifications.
The NRC staff review of this issue was subsequently documented in Supplement No. 6 to the SER (Section l
16.3.1).
It was concluded that no change to the Technical Specification l
would be required because the instruments were not used to actuate engineered safety features and post seismic damage could be evaluated, j
if necessary, using conservative antlyses based on the measurements of other seismic instruments which were operable.
t l
In its follow-up letter AECM-86/0006, dated January 10, 1986, the licensee described its proposed deletion of the above four PRAs, in fulfillment of the commitments made in letter AECM-84/0307.
The staff's up-to-date evaluation of this issue is provided in the following.
l 8606120091 860527 l
PDR ADOCK 05000416 j
p PM l
f i 2. 0 EVALUATION There are currently 11 PRAs provided in the GGNS-1 design.
One is located on a reactor vessel support, four on reactor piping systems as stated previously, one on the containment dome, one on the control building foundation, one in the control room, one on the standby diesel generator, one on the auxiliary building foundation, and one in standby service water pump house B.
While seven of the PRAs functioned satisfactorily, the four units mounted on the reactor piping were subject to repeated failures.
All four were found non-functional in July, 1983, during surveillance.
Two of these were again found non-functional during surveillance in January,1985.
The probable cause of malfunction of the PRAs which are mounted on the reactor piping is believed to be the following.
A PRA is a passive device capable of recording peak acceleration during a transient event.
The reactor piping is subjected to various transients during startup and normal plant operation. During these transients, the peak acceleration recorded by instruments mounted on the piping can be very high, and can exceed the range of the PRAs (0.01 to 2g) so as to render them inoperable.
The licensee, therefore, in its letter of January 10, 1986, proposed to remove the PRAs mounted on the reactor piping.
The licensee's justification for such a proposed action is as follows.
(1) The vendor (Kinematrics) has confirmed that a passive device (PRA) is not suitable for installation on a system which is subjected to frequent transients.
(2) The peak acceleration response due to a seismic event can not be separated from the response due to the system transients.
In many cases the predicted peak seismic response is less than that due to the system transients.
(3) A meaningful and conclusive evaluation of the piping response due to a seismic event cannot be performed by relying on a peak l
acceleration value at a single location on the piping system.
(4) Currently there are five Triaxial Time History Accelerographs (SMAs) installed in the plant.
One SMA is installed on the containment foundation, one on the drywell wall, one in the standby service water pump house, and one on the standby gas treatment system filter drain.
The fifth SMA is installed on the free field.
These recorders will provide reliable acceleration time history, which can be converted to seismic response spectra.
These can easily be compared with the respective GGNS design seismic spectra for post-seismic damage evaluation.
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. (5) A sixth SMA will be installed on a reactor piping support for the high pressure core spray system by restart from the first refueling outage [0perating License Condition 2.C.(7)].
This SMA will provide an acceleration time history at the support location, which can better serve to confirm the post-seismic evaluation for this plant component than the PRA which is currently located on the corresponding piping system.
(6) The are seven PRAs mounted at various locations inside and outside the containment which will provide reliable and meaningful information for post-seismic damage evaluation.
3.0 CONCLUSION
The staff has reviewed the above licensee's justification and concluded that the four PRAs which are mounted on the reactor piping do not serve any meaningful purpose for post-seismic damage evaluation and, therefore, can be deleted.
The staff also concludes that with the sixth SMA which will be installed and the already available devices in GGNS-1, there are sufficient seismic instruments which will provide required information for post-seismic damage evaluation.
Therefore, we conclude that the intent of Regulatory Guide 1.12, Revision 1, and Standard Review Plan Section 3.7.4 (NUREG-0800) has been met.
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