ML20236J342

Summary of 871008 Meeting W/Util Re Licensee 870706 Application for Amend to License NPF-29,changing Tech Specs on Operational Condition 4, Cold Shutdown & Condition 5, Refueling. Attendance List Encl

ML20236J342
Person / Time
Site:	Grand Gulf
Issue date:	10/30/1987
From:	Kintner L Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8711060010
Download: ML20236J342 (7)

Text

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october 30, 1987 Docket No. 50-416 DISTRIBUTION R. Goel 4 Docket?EfTeT T. Dunning NRC & Local PDRs R. Emch LICENSEE: System Energy Resources, Inc. PD22 Reading S.~ Brown H. Berkow A. Wang FACILITY: Grand Gulf Nuclear Station, Unit 1 L. Kintner M. Hodges OGC-Bethesda E.' Jordan

SUBJECT:

SUFMARY OF OCTOBER 8, 1987 MEETING REGARDING PROPOSED B. Troskoski LICENSE AMENDMENT CONCERNING CHANGES TO TECHNICAL ACRS (10) l SPECIFICATIONS FOR REFUELING OUTAGES J. Kudrick R. Licciardo l' The purpose of the meeting was to discuss two items in the licensee's July 6, 1987 request to change the Technic 61 Specifications (TSs) applicable to Opera-tional Condition 4, " Cold Shut Down," and Operational Condition 5, " Refueling." i For one item, the licensee had requested exceptions to TS 3.0.4 to allow entry into Operational Condition 4 or 5 without meeting the Limiting Conditions for Operation (LCO), provided the requirements of certain Action Statements (AS) are met. For the other item, the licensee had requested deletion of operability requirements for primary containment isolation valves during core alterations and operations with a potential for draining the reactor vessel. A list of attendees is enclosed.

With respect to the first item, the staff said it was concerned that the grant-ing of these exceptions would allow inoprability of the RHR and ECCS systems and the use of unspecified alternate methods for removal of decay heat and recirculation of reactor coolant during extensive portions of refueling outages or forced cutages. The staff felt that the alternate methods do not provide a level of safety equivalent to safety-related systems, such as the RHR and ECCS systems. For example, alternate methods are not required to be powered by the emergency diesel generators and so would be subject to failure due to loss of offsite power. The intent of the present TSs is that the time spent in the AS allowing inoperability of the RHR or ECCS sy:,tems be limited to that for necessary repairs or testing of the systems and that entry into an operational condition during evolutions leading to plant startup should not be made until equipment required by the LC0 is operable.

The licensee described its need for the exceptions based on experience gained l during the first refueling cutage. The activities for the upcoming outage are /

scheduled so that at least one RHR is operab'e during niost of the cutage.

However, there is an interval of about one week when both RHR loops will be inoperable for repairs and leak-rate testing of cornon suction valves. One PHR loop is in operation during the first part of the outage until alternate systems can accommodate the decay heat load. With the present TSs, when refueling is completed and the water level above the reactor is lowered, two RHR loops are required by the LCO to be operable. However, the AS for the low water level condition allows alternate nethods of decay heat removal, similar to the AS for the high water level condition. With the present TSs, if outage activities required the inoperability of RHR systems at this time, the outage activities would have to be interrupted to make the PHR systems operable until the LCC for the low water level condition was demonstrated, and then the RHR systems would have to be made inoperable again as allowed by the AS until the 9711060010 a71030 PDR ADOCK 05000416 P PDR

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exceptions. The request for deletion of operability requirements for primary l l containment isolation valves would include only those valves which can be justi- l fied 'for scheduled outage activities and would include a description of admini- l strative procedures to obtain primary containment integrity within a short time,  :

if needed.  ;

i Original signed by tester L. Kintner, Project Manager Project Directorate II-2 l l Division of Reactor Projects-I/II

Enclosure:

As stated I cc: See next page l

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NUCLEAR REGULATORY COMMISSION WASHINGT ON, D. C. 20555

\Q,* October 30, 1987 Docket No. 50-416 LICENSEE: System Energy Resources, Inc.

FACILITY: Grand Gulf Nuclear Station, Unit 1

SUMMARY

OF OCTOBER 8, 1987 MEETING REGARDING PROPOSED LICENSE AMENDMENT CONCERNING CHANGES TO TECHNICAL SPECIFICATIONS FOR REFUELING OUTAGES The purpose of the meeting was to discuss two items in the licensee's July 6, 1987 request to change the Technical Specifications (TSs) applicable to Opera-c tional Conditicn 4, " Cold Shut Down," and Operational Condition 5, " Refueling." t for one iten, the licensee had requested exceptions to TS 3.0.4 to allow entry into Operational Condition 4 or 5 without meeting the Limiting Conditions for l Operation (LCO), provided the requirements of certain Action Statements (AS) are met. For the other item, the licensee had requested deletion of operability requirements for primary containment isolation valves during core alterations anc operations with a potential for draining the reactor vessel. A list of attendees is enclosed.

With respect to the first item, the staff said it was concerned that the grant-ing of these exceptions would allow inoperability of the RHR and ECCS systems and the use of unspecified alternate methods for removal of decay heat and recirculation of reactor coolant during extensive portions of refueling outages or forced outages. The staff felt that the alternate methods do not provide a level of safety equivalent to safety-related systems, such as the RHR and ECCS systems. For example, alternate methods are not required to be powered by the emergency diesel gererators and so would be subject to failure due to loss of offsite power. The intent of the present TSs is that the time spent in the AS-allowing inoperability of the RHR or ECCS systems be limited to that for necessary repairs or testing of the systems and that entry into an operational  !

condition during evolutions leading to plant startup should not be made until equipment required by the LC0 is operable.

The licensee described its need for the exceptions based on experience gained during the first refueling outage. The activities for the upcoming outage are scheduled so that at least one RHR is operable during most of the outage.

However, there is an interval of about one week when both RHR loops will be inoperable for repairs and leak-rate testing of common suction valves. One RHR loop is in operation during the first part of the outage until alternate systenis can acconrnodate the decay heat load. With the present TSs, when refueling is completed and the water level above the reactor is lowered, two RHR loops are required by the LCO to be operable. However, the As for the low water tevel condition allows alternate methods of decay heat removal, similar ,

to the AS for the high water level condition. With the present TSs, if outage activities required the inoperability of RHR systems at this time, the outage activities would have to be interrupted to make the RHR systems operable until the LC0 for the low water level condition was demonstrated, and then the RHR systems would have to be made inoperable again as allowed by the AS until the

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' necessary repair or testing activities concerning the RHR systems.were completed.

lhe granting of the exceptions would pennit uninterrupted completion of RHR l

repair activities while plant startup evolutions are in progress. Similarly, j in replacing the reactor head and tightening the bolts, the operational condi- I tion changes'from 5 to 4 The present TSs would require making the PHP system  ;

' operable to neet the LCO of Operational Condition a, whereas the AS of Opera- l tional Condition 4 is the. sanie as the AS of Operational Condition' 5.

]

The licensee said that its outage philosophy is to require conservatisnrin planning and executing outages. This philosophy will.be translated into adminfirative procedures by means of a FNS TS position statement. These procedures will require testing of alterute heat removal systems prior to 1

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o intentional removal of RHR or ECCS systems from operability. In addition, the l tin,e when the systems are inoperable will be minimized in outage planning.  !

J With respect to the second item in the July 6,1987 application, the' staff said j f t also had concerns' regarding deletion of the requirement for primary contain- i ment. valves to be operable for co're alterations and during operations with a potential for draining the reactor vessel. The staff's concern is that inade-quate consideration has been given to potential accidents during outages that, l although not considered to be design basis accidents, may indicate the need to )

. reinstate primary containment integrity. For example, many events during outages have resulted in partial draining of the reactor vessel oc temporary loss of shutdown cooling to the extent that low reactor vessel water level automatically isolated the reactor or boi'ing of reactor water has occurred.

For such incidents, automatic isolation of primary containment valves and the capability to reinstate primary containment integrity in a short time (e.g.,

1/P hour) should be retained ir. the TSs. )

The licensee stated that it is aware o' the reactor water drainage events and loss of shutdown cooling events as documented by the NPC and industry in the last few years. The licensee has a conservative philosophy which has been  ;

implemented in a TS position statement to identify operations with a potential for draining the reactor vessel water. Certain TSs require specified actions during these operations with a potential for draining the reactor. The licen-see stated that the limiting time for reinstating primary containment is replacing the primary containment equipment hatch which must be open during outage activities. The licensee said, however, that it is alert to the poten-tial need to replace the hatch in the shortest time possible and would be prepared to do so. For GGNS, secondary containment integrity is maintained during fuel handling in containment and since secondary containment encloses the prin,ary containment, including the equipnent hatch, primary containment is not required for fuel handling. The licensee stated that deletion of the '

operability requirements for certain primary containment isolation valves is desirable for local leak rate testing and resulting repairs, if necessary.

However, deletion of the TS operability requirements for most valves, as pro-posed, is not necessary.

After separate caucuses, the staff and the licensee agreed to a resubmitted of the proposed changes to the TSs. The request for exceptions to TS 3.0.4 would be for one-time exceptions during the second refueling outage and would include a description of administrative procedures to prevent unnecessary use of the

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- exceptions. The . request 'for deletion of. operability requirernents for pritaary containn:ent isolation valves would include ~ only those valves which can be justi-fied for scheduled outage activities and would include a description of admini-strative. procedures to obtain. priniary containtnent integrity wit nin a short tirre, if ~ needed.

W Lester L. Kintner, Project Manager

~ Project Directorate II-2 Division of Reactor Projects-I/II

Enclosure:

-As stated j

cc: _See next page i

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c " Octobar'30,,1987:

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- ,; ENCLOSURE ATTENDANCE-.

'SERI.- NRC: MEETING  !

0CTOBER 8, 1987 l

l NAME A_FFl_LIATION <

l S.. Lee Robertson SERI  ;

- Joe Hendry SERI- '

1 J. E. Cross SERI H Donald- R.' Hoffman SERI l Tom Dunning'- NRC/TSB i

Rich Emch NRC Stu Brown NRC .l Alan-Wang. NRC' Guy Cesare

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SERI 'j L. Kintner. NRC/PD22 i H. Berkow NRC/PD22 '

J.'Unda. NRC/PD22 I M. W. Hodges NRC/RSB 'l

. J. Kudrick NRC/PSB-  !

R. Licciardo' NRC/PSB R. Goel NRC/PSB 1

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3 Mr.! Oliver D. Kingsley, Jr.  ;

System Energy Pesources, Inc. Grand Gulf Nuclear Station (GGNS) l L , j l cc:

Mr.:Ted H. Cloninger Mr. C. R. Hutchinson i Vice President, Nuclear Engineering GGNS General Manager .

and Support- System Energy Resources, Inc. t L System Energy Resources, Inc. Pest Office Box 756 p Post Office Box 23054 Port Gibson, Mississippi 39150 Jackson, Mississippi 39205-l Robert B. McGehee, Esquire The Honorable William J. Guste, Jr. ~;

Wise, Carter, Child, Steen and Caraway

, Attorney General

.P.O. Box 651 Department of Justice Jackson, Mississippi 39205 State of Louisiana Baton Rouge, Louisiana 70804 1 Nicholas S. Reynolds, Esquire Bishop, Liberman, Cook, Purcell .]1 Office of the Governor '

and Reynolds State of Mississippi 1200 17th Street, N.W. Jackson, Mississippi 39201 Washington, D. C. 20036 d

L Attorney General L

Mr. Ralph T. Lally Gartin-Building Manager of Quality Assurance Jackson, Mississippi 39205-Middle South Utilities System Services, Inc.

P.O. Box 61000 Mr. Jack McMillan, Director l New Orleans, Louisiana 70161 Division of Solid Waste Management Mississippi Department of Natural

-Mr. John G. Cesare Resources  :

Director, Nuclear Licensing  !

System Energy Resources, Inc. Post Office ;x 10385 P.O. Box 23054 Jackson, Mh sissippi 39209

' Jackson, Mississippi 39205 Alton B. Cobb, M.D.

Mr. R. W. Jackson, Project Engineer State Health Officer Bechtel' Power Corporation State Board of Health 15740-Shady Grove Road P.O. Box 1700 Gaithersburg, Maryland 20877-1454 Jackson, Mississippi 39205 Mr. Ross C. Butcher President Senior Resident Inspector Claiborne County Board of Supervisors  !

U.S. Nuclear Regulatory Commission Port Gibson, Mississippi 39150 Route 2, Box 399 Port Gibson, Mississippi 39150 .

I Regional Administrator, Region II l U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., S'ulte 2900  ;

l Atlanta, Georgia 30323 Mr. James E. Cross  !

GGNS Site Director l System Energy Resources, Inc, j P.O. Box 756 Port Gibson, Mississippi 39150 l

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