ML20216J889
| ML20216J889 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/04/1999 |
| From: | Roberts J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-99-00075, NUDOCS 9910060272 | |
| Download: ML20216J889 (10) | |
Text
N Ent:rgy oper:tions, Inc.
- Ent
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Port Gibson, MS 39150 j
Tel 601437 6470
]
Jerry C. Roberts l
r Safety Assurance October 4,1999?
' U.S. Nuclear Regulatory Commission AMN:' Document Control Desk-Ashington, D.C.
20555-
SUBJECT:
Grand Gulf Nuclear Station Unit 1 -
Docket No. 50-416
, License No. NPF-29 Fuel Handling Accident Operational Conditions Proposed Amendment to the Operating License, LDC 1999-051
Reference:
- 1) GNRO-99/00049, Fuel Handling Accident Operational Conditions, dated June 23,1999
- 2) GNRO-99/00063, Information Supporting the Review of Accident Operational Conditions, dated August 6,1999
- 3). GNRO-99/00070, FHA Operational Conditions, dated September 8,1999 GNRO-99/00075 Gentlemen:
Reference i submitted a proposed amendment to the Grand Gulf Nuclear Station (GGNS)
Operating License to relax cedain Technical Specification requirements during shutdown conditions. In recent phone calls, the NRC has requested additional information regarding the
' GGNS commitment to the draft NUMARC 93-01 changes as discussed in the original request.
The stated commitment was that GGNS would adopt selected provisions of NUMARC 93-01, L Section 11.2.6, dealing with " Safety Assessment for Removal of Equipment from Service during
' Shutdown Conditions." Details of existing procedural guidance and planned administrative
. controls s're provided in the attachment to this letter.
The requested changes are impodant to GGNS. They potentially represent a net saving of one day of the overall duration of the upcoming RF10 outage. On this basis, GGNS respectfully requests your review and approval of these changes by October 20,1999. This date will permit 4
us to implement the changes and realize the full benefit during the refueling outage.
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GNRO-99/00075 Page 2 of 3 The proposed Technical Specification changes in Reference 1 revise those specifications associated with selected systems and equipment that no longer need be credited following a design basis fuel handling accident. The changes affect operability requirements during conditions where irradiated fuel is handled in the primary or secondary containment and during core alterations. These changes are based on the revised analysis of the fuel handling accident for GGNS. References 2 and 3 provided some follow-up technical infonnation to support the NRC review of the application.
The shutdown safety controls will be in effect pending revision to NUMARC 93-01, Section 11.2.6, " Safety Assessment for Removal of Equipment from Service during Shutdown Conditions." As discussed further in Reference 1, the draft NUMARC 93-01 concepts will be utilized at GGNS for controlling the removal from service of systems, structures and
. components that are currently required by Technical Specifications during core alteration / fuel handling periods.. Should you have any questions regarding this information or the original request, you may contact Jerry Burford at (601) 437-2714.
Yours truly,
/FGB attachment 1: GGNS Administrative Controls, to address draft NUMARC 93-01 Changes -
attachment 2: Oath and Affirmation cc:
(See Next Page)
1 4
GNRO-99/00075 Page 3 et 3 j
cc:
- Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator -
U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. S. P. Sekerak, NRR/DLPM/PD IV-l (W/2)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 04-D3 11555 Rockville Pike Rockville, MD 20852-2378 1
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- GNRO-99/00075 o
bec:
File (LCTS/RPTS)(w/a) i Fiie (Hard Copy)(w/a)
File (Central)(w/a)( 10 )'
ccmail:
Mr. W. B. Abraham Mr. M. G. Hurley Mr. G. R. Ashley (ANO - LIC)
Mr. C. R. Hutchinson (ANO - VP)
Mr. W. J. Beck (RB - LIC)
Mr. D. E. James (ANO - LIC)*
Mr. S. J. Bethay (ECH - LIC)
Mr. R. S. Johnson
- Mr. J. G. Booth Mr. M. L. Jones *
- - Mr. C. A. Bottemiller Mr. C. W. Lambert Mr. P. W. Brewer Mr. M. J. Larson 1
Mr. F. G. Burford Ms. J. M. Manzella (W3 - QP)*
Mr. W. C. Cade Mr. J. R. McGaha (ECH)*
Mr. R. W. Carrol Mr. T. O. McIntyre*
- Mr. D. G. Cupstid Mr. R. V. Moomaw
- ' Mr. J. P. Czaika Mr. S. D. Reeves *
- Mr. L. F. Daughtery*
Mr. J. C. Roberts *
Mr. C. D. Stafford -
Mr. W. A. Eaton*
Mr. R. L. Thomas (ECH)*
Mr. C. W. Elisaesser Mr. T. H. Thurmon Mr. J. L. Ensley (ESl)
Mr. J. D. Vandergrift (ANO - LIC) i M. E. C. Ewing (W3 - LIC)*
Mr. J. E. Venable Mr. R. A. Wilson -
)
i
=. to:
GNRO-99/00075 GGNS Administrative Controls To address draft NUMARC 93-01 Changes A proposed draft of changes to NUMARC 93-01, Revision 2, Section 11.2.6 includes the following excerpt:
Maintenance activities involving the need for open containment should include evaluation of the capability to achieve containment closure in sufficient time to prevent potential fission product release. This time is dependent on a number of factors, j
including the decay heat level and the amount of RCS inventory available.
In addition to the guidance in NUMARC 91-06, forplants which obtain amendments to Technical Specification requirements on primary or secondary containment operability
' and ventilation system operability during fuelhandling or core alterations, the following guidelines should be included in the assessment of systems removed from service:
During fuel handling / core alterations, ventilation system and radiation monitor availability (as defined in NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. Following shutdown, radioactivity in the fuel decays away fairly rapidly. The basis of the Technical Specification operability amendment is the reduction in doses due to such decay.
The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay, and to ensure releases from the plant are monitored.
To ensure that any potential radiation releases from a rapidly evolving event, 1
e such as a fuel handling accident, would be routed to appropriate systems for 1
treatment and monitoring, a single normal or contingency method to promptly close pnmary or secondary containment penetrations should be developed Such prompt methods need not completely block the penetration or be capable of resisting pressure. The purpose is to reduce containment inleakage to enable ventilation systems to be able to draw the release in the proper direction such
~ that it can be treated and monitored.
The Technical Specification changes proposed by GGNS in letter GNRO-99/00049 would relax the operability requirements during shutdown conditions for both primary and secondary containment, as well as the Standby Gas Treatment System. In light of the guidance above and in keeping with the commitment made in the PCOL, GGNS offers the following information
. regarding the administrative controls to be employed.
- in the analysis of the Fuel Handling Accident, GGNS determined that coerability of these systems was required only for the first eight days after shutdown. Beyond this point, while these systems are no longer required to be operable, GGNS still intends to ensure that any radioactive releases due to a fuel handling accident are kept as low as reasonably achievable.
. While a primary and secondary containment are no longer required to be OPERABLE, GGNS l
- intends to track openings, establish contingency plans to provide for closure of extemal
_ openings through the secondary containment, and maintain at least one train of SGTS available
' to provide for a forced air filtered release path. GGNS has not proposed the relaxation of the
[...
~ to:
GNRO-99/00075
. Control Room Fresh' Air System filters; these will still be controlled in accordance with the Technical Specifications during fuel handling operations and core alterations.
i Procedure 01-S-06-2, " Conduct of Operations," includes section 6.7, " Control of Outage Operations," which provides guidance and controls during outage situations. It currently
- includes three subsections that provide special guidance regarding primary and secondary j
containment during shutdown. Section 6.7.25 provides for evacuating containment and for closing up any containment isolation valves being worked. Sections 6.7.26 and 6.7.27 provide special tracking controls for identifying valves in both the primary and secondary containment ~
areas. Copies of the procedure pages are attached.
1 In addition to the Conduct of Operations procedure, GGNS also maintains administrative -
controls in the Shutdown Operations Protection Plan (SOPP). This document outlines management's shutdown safety philosophy that is based on defense-in-depth principles. It currently references NUMARC 91-06, " Guidelines for Industry Actions to Assess Shutdown Management," and provides guidance addressing the five key shutdown safety functions, including containment. Copies of Section V.F are attached describing containment guidance.
GGNS will update the SOPP prior to RF10 to incorporate the following items:
1)
Incorporate reference to NUMARC 93-01 providing additional guidance for conducting i
the assessment of the removal of equipment during outage conditions.
2)'
Add a statement: During fuel handling / core alterations, the ability to filter and monitor any releases should be assessed. In particuirr, SGTS and its associated radiation
- monitors should be available (but are not required to be OPERABLE).
3)
Add a statement: The ability to expeditiously establish secondary containment during fuel handling / core alterations should be maintained. A contingency methN to immediately close any external openings in the secondary containment (inciuding the roll-up door, if in use) should be developed.
4),
Add a contingency action: Secondary Containment - The Operations Shift -
Superintendent ~will notify the Maintenance Department to take the necessary actions to
' close all external openings in the secondary containment.
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GNRO-99/00075 Titlos conduct of Oparations No.:
01-S-06-2 Ravicion:
107 Pogs:
33 6.7.17 Maintenance section personnel are responsible for activities that involve core alterations from below the reactor vessel.
Operations section personnel are responsible for all other activities that involve core alterations.
6.7.18 The Senior Reactor Operator may suspend and recommence refueling activities based on Refueling Floor conditions (e.g., environment, coincident activities, equipment malfunctions, personnel conduct, etc.) as necessary.
6.7.19 The Refuel Floor Supervisor has the authority to stop any activities deemed in violation of plant procedures or unsafe to personnel or plant equipment.
6.7.20 Health Physics personnel may recommend that refueling activities be suspended based on radiological conditions.
6.7.21 Special cperational conditions during refueling (e.g., handling irradiated fuel in primary or secondary containment, core alterations, control rod withdrawal) may be. assigned a predetermined duration as specified by the Operations 1
Superintendent.
i Entry into a special operational condition will be controlled a.
under IOI 03-1-01-5, Refueling.
b.
Special operational condition activities may be no.1-
' continuous or may be suspended, but as long as Tech Spec Compliance is maintained (for example, surveillance s
requirements are kept current), the plant may be considered to have remained in the special operational conditions, and activities may be subsequently recommenced without having to meet the entry requirements for that special operational
~
condition again.
c.
For instance, if while in a special operational condition an LCO is not met and its corresponding action statement ~
requires suspension of activities pertaining to the special operational condition, those activities may be recommenced upon clearing the LCO without having to again meet the entry requirements for the special operational condition.
6.7.22 Health Physics will monitor the movement of fuel assemblies from initial fuel movement throughout the completion of fuel movement activities. A Senior Health Physicist must be present on the Refuel Floor whenever. fuel movement and associated refueling activities are in progress.
6.7.23 Communications must be maintained between the Drywell Control Point HP and the Refueling Floor HP.
6.7.24 The Refueling Floor Supervisor must be an additional holder on any tagout which, by being hung or cleared, can create an operation wtth a potential for draining the reactor vessel as defined in the TRM.
6.7.25-If at any time events 'are in progress that lead the Shif t Superintendent to believe that any spent fuel assembly may become uncovered, he shall pass the word over the plant PA System to evacuate the containment and for Maintenance personnel working on L
isolation valves to install valve covers and notify Security to l
activate their contingency plan to close the containment.
I l
l Ja\\ADM_SRVS\\ TECH _ PUB \\ REVISION \\1\\15062. DOC
4EERment i to:
GNRO-99/00075 Titla:
C:nduct of Opar0tions No.:
01-S-06-2 R2Vicion:
107 Page:
34 6.7.26 During Core Alterations or operation with a potential for draining the reactor vessel, work involving a major breach of a containment penetration greater than 4" in diameter must have one of the following contingencies:
a.
The opposite containment isolation valve will be tagged closed.
b.
In those cases where it is not possible to isolate the j
penetration with a closed isolation valve, the WO work instructions shall contain directions to require temporary covers to be installed when work is not in progress and when directed to do so in accordance with Step 6.7.25.
j A major breach is the complete remcval of a valve or its internals creating a major hole through the containment wall. Removal of packing or other similar small items is not considered a major breach.
Attachment III lists all containment penetrations greater than 4" in diameter.
6.7.27 In addition to the secondary containment isolation valves listed in Tech Specs, the following systems have been identified as potential problems while maintaining secondary containment boundaries during outage periods.
Whenever any of the listed systems are opened to the Drywell, Containment or Auxiliary Building atmosphere and not isolated by Red Tag, the valves listed next to each system will be tagged closed with the tag sheet held by the shift Superintendent. A note will be placed on the clearance sheet indicating they are tagged to maintain secondary containment and which jobs required them to be tagged.
RCIC: E51-F025 or E51-F026, E51-F250, E51-F253 HPCS:
E22-F001, E22-F220, E22-F209 Feedwater B21-F065A(B)
Main Steam Lines: B21-F098A(B,C,D) and B21-F020 SSW-A P41-F001A, P41-F005A, P41-F183A, P41-F184A, P41-F023A, P41-F018A, SSW-B:
P41-F001B, P41-F005B, P41-F183B, P41-F184B, P41-F018B, P41-F023B P64-FA10A and P64-FA10B should remain closed unless needed for response to a fire.
6.7.28 Before each outage, Operations Management will convey to shift supervision guidance for monitoring the adequacy of spent fuel pool cooling based on the conditions present and on related system status (e.g., additional or more frequent monitoring would be appropriate when the whole core is offloaded or when inadvertent changes in plant status or electrical perturbations occur).
Ja\\ADM_SRVS\\ TECH _ PUB \\ REVISION \\1\\15062. DOC
- to:
GNRO-99/00075 V.
- f. '
Containment Closure 1.-
Guidelines a)
Operations will maintain a list of all breaches to Primary and Secondary Containment b)
The Mechanical Supervisors are assigned responsibility for the closure of the 166' containment equipment hatch, the 119' airlock and the 208' airlock should action be initiated by the Shift Superintendent or Cutage Director.
c)
Primary containment is assumed to NOT be available during Modes 4 and 5 and therefore increased awareness is required during OPDRV's (Operations with Potential to Drain the Reactor Vessel), Core Alts and handling irradiated fuel.
)
i
Attahcment 2 to:
GNRO-99/00075 BEFORE THE
)
UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29
}
DOCKET NO. 50-416 IN THE MATTER OF ENTERGY MISSISSIPPI, INC.
I and SYSTEM ENERGY RESOURCES, INC.
and i
SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.
AFFIRMATION 1, J. C. Roberts, being duly sworn, state that I am Director, Nuclear Safety Assurance, GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc.
to sign and file with the Nuclear Regulatory Commission, this application; that I signed this application as Director, Nuclear Safety Assurance GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information and belief.
J. C. Roberts
- STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State above named, this 9" day of &M/m,1999.
A k
Notary Public l
My commission expires.
l Ut3SES!TPi STATIW!OF A0 TOY NJUO l
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