ML20244D896

Summary of 890518 Meeting W/Util Re Performance of Licensing Activities.Meetings Should Be Scheduled to Seek Means for Eliminating Weaknesses Identified by NRC

ML20244D896
Person / Time
Site:	Grand Gulf
Issue date:	06/12/1989
From:	Kintner L Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8906200043
Download: ML20244D896 (16)

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. [y GCtG UNITED STATES I

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n-NUCLEAR REGULATORY COMMISSION

.,T $ ,E WASHINGTON, D. C. 20555 i

%....+/ June 12, 1989 IDocket No. 50-416 FACILITY: GRAND GULF NUCLEAR STATION, UNIT 1

. LICENSEE: SYSTEMENERGYRESOURCES,INC.(SERI)

SUMMARY

OF MAY 18, 1989 MEETING WITH SERI REGARDING PERFORMANCE OF LICENSING ACTIVITIES The NRC project management staff met with SERI management to discuss the policy and implementation of licensing activities. In addition, the staff was briefed on' corrective actions for the GGNS-1 recirculation pump shaft vibration recently experienced during startup from a refueling outage. Enclosure 1 is a list of attendees. Enclosure 2 is a handout prepared by the NRC staff providing comments and examples of licensing activities for discussion in the meeting.

Enclosure 3 is a handout prepared by SERI regarding GGNS-1 organization policies, programs and practices addressing safety issues.

While restarting from the third refueling outage, excessive vibration was measured on recirculation pump "B" at 90% power. Single loop operation was considered, but it was decided to bring the plant to a cold shutdown to inspect and repair the pump. Inspection of the pump and motor prior to disassembly indicated that the motor to pump coupling was good and the motor vibration was within normal range. Samples of reactor coolant were analyzed, and no unusual metallic particles were found. It was decided to replace the pump shaft and impeller on pump "B" with similar components from the Unit 2 reactor. If, as suspected, the "B" shaft was found to be cracked, the shaft and impeller on recirculation pump "A" would also be replaced. Shaft failure was expected to be the cause of the vibrations, because a similar failure had occurred on a foreign BWR 6 reactor at about the same service time. The NRC staff commented that the licensee had acted promptly and in a safe manner to correct the vibration problem before a more serious separation of the impeller from the shaft had occurred. Licensee indicated that a one month outage was )

planned to change components in both pumps. Complete shaft failure could have resulted in a longer outage, estimated at 8 months. In response to staff questions, the licensee stated that the noise detected by the loose parts monitor j in the "B" loop in the spring of 1988 was normal vibration in the "B" loop i discharge valve and was not related to the pump vibration. i The SERI Vice President - Nuclear Operations described the organization and planning for refueling outages and performance of the three outages experienced.

Improved planning and communications in the third outage resulted in improved performance. A peak of about 2000 people were used in the outage, with the Operations Manager serving as daytime overall manager of outage activities and the Maintenance Manager serving as nighttime manager. An outage manual was prepared, and a one-day seminar was given to outage employees. Prior to restart the operators took a refresher course on the simulator to better prepare for startup.

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3 l W The SERI management and technical support organization is shown in Enclosure 1, Page 3. The Vice President of Nuclear Operations is on site, and the Director - Nuclear Licensing and his staff are planning to move to the site for better communication with operations and engineering personnel. The Site Director position will probably be eliminated.

For normal operations, the unit organization (Enclosure 2 Page 4) has been changed to include 37 systems engineers, each of which specializes in certain l systems. The system engineers prepare design change packages and relieve the maintenance superintendent of much of the detailed work. The system engineers report to the Manager - Performance and System Engineering (P&SE). The safety l analyses of most non-conformances experienced in operation are the responsibility of the Manager - P&SE and his system engineers. More complex safety analyses for design non-conformances are the responsibility of Director Nuclear Plant 1 Engineering and his staff. Safety analyses involving Chapter 6 or 15 of the Final Safety Analysis Report may be sent to System Services, Inc. of Middle South Utilities, the parent company of SERI. The Independent Safety Engineering Group may also investigate safety questions.

One change being considered in the unit organization is to have one superintendent for Radiation Control and one for Chemistry in place of the present Chemistry /

Radiation Control Superintendent. This change will require a Technical Specifica-tion change.

The licensee commented on some of the weaknesses observed by the staff in the performance of licensing activities in the past year (Enclosure 2). Regarding changes required in submittals, the licensee stated that of 23 requests for amendments since January 1988, only 10 required additional information. The staff said most of the requests were for relatively minor changes but for major amendments involving safety questions such as the alternate decay heat removal system (ADHRS), the initial submittal provided inadequate TS conditions for its operation and repeated telephone calls and meetings did not result in an acceptable amendment. Rather, ADHRS use was restricted to the third refueling outage until acceptable TS could be proposed. This licensing action is an example of activities which arouse staff's concern that the licensee's goal is to meet the letter of the regulatory requirements but not the spirit.

Regarding the need for TS changes governing shutdown cooling requirements during refueling outages the licensee stated it has asked the BWR Owners' Group to consider such changes.

The staff commented that amendm: 1ts needed for safety requirements, for example Technical Specifications requiring secondary containment for handling loads over  ;

spent fuel, were not given the same priority and resources as amendments needed I to reduce outage time. Although the need for this amendment was identified by the licensee in 1988, the amendment request was not submitted until 6 weeks before it would be needed in the outage; and the initial submittal was inadequate.

l' ,

y Y i Another weakness mentioned by. staff was that corrective. actions' for repetitive safety problems are not completed. For example,'since plant startup in 1984, there have been many unnecessary isolations of the'six isolation valves in the reactor water cleanup system (RWCU). Proposed corrective actions to increase

' delay time in the differential flow isolation signal or to install a bypass for..

the signal while pumps are being started have not been taken. The corrective action taken (bypassing all signals for RWCU isolation while starting pumps) was not analyzed to determine whether it has an unreviewed safety question and .{

so a notice'of violation was issued. By not taking effective corrective action, 1

.the licensee continued.the unnecessary isolations and the associated LERs. The {

latest LER indicates a corrective action of participating in a generic effort with the BWR Owners' Group to address RWCU con'cerns. The licensee indicates that the isolations are an operational concern because water purity may degrade while f the system is isolated, but isolation is not a safety concern. The staff ques-tions whether unnecessary isolations of the valves would significantly. reduce their reliability to perform their dual safety function of' reactor coolant.

system isolation and containment isolation.

Another weakness mentioned by the staff is the use of Technical Specification  :

interpretations which are known to be contrary to staff interpretations. For example, allowed outage times (A0T) for engineered safety features (ESF) room coolers are taken te be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> consistent with the standby service room water system A0T ratner than the one hour A0T consistent with the engineered safety features equipment A0T, for which tha coolers are a support system. Another example of the use of incorrect interpretation is not reporting non-valid ciesel generator tests as required by TS. The staff's interpretation of these two examples was provided to the licensee in a January 25, 1989 meeting summary.

At the conclusion of the meeting it was agreed by licensee and staff that meetings should be scheduled to seek means for eliminatir.g the above weaknesses identified by the staff.

Original Signed By:

Lester L. Kintner, Senior Project Manager Project Directorate 11-1 Division of Reactor Projects -I/II Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ encl:

See next page 1 l

i PM.P 71 1 D -1 LKintner:sw , sam 6//t/89 6/p89

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r N Mr. W. T. Cottle )

System Energy Resources, Inc. GrandGulfNuclearStation(GGNS)

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

and Support System Energy Resources, Inc. '

System Energy Resources, Inc. P. O. Box 756 P.'0. 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 Department 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 39201 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 McMillen, Director Services, Inc. Division of Solid Waste Management 639 Loyola Avenue, 3rd Floor Mississippi Department of Natural New Orleans, Louisiana 70113 Resources P. O. 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. B. Hogg, Project Manager Jackson, Mississippi 39205 Bechtel Power Corporation P. O. Eox 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 Regulatory Commission Route 2, Box 399 101 Marietta Street Port Gibson, Mississippi 39150 Suite 2900 Atlanta, Georgia 30323 l

6-Enclosure 1 ATTENDEES' NRC - SERI MEETING May 18, 1989.

'NAME AFFILIATION' r

L. Kintner NRC, Project Manager, GGNS' E. Adensam NRC, Director, PDII-1 G. Latiat NRC, Asst. Director, RII Projects S.'Varga NRC, Director, Div. Reactor Projects I/II D. Verrelli NRC, Region II, Chief, Reactor Projects Branch No. 1 G. Cesare SERI, Director, Nuclear Licensing-M. Wright SERI, Manager, Plant Support, GGNS-1 F. W. Titus SERI, Director, Nuclear Plant Engineering W. T. Cottle, SERI, VP - Nulcear Operations W. A, Russell SERI, Operations Assistant, GGNS-1 W. E. Edge SERI, Manager, Licensing Support M.~ L. Crawford SERI, Manager, Nuclear Licensing

• W. Hodges NRC, Chief, Reactor Systems Branch

• J. Carter NRC, Events Assessnent Branch

• T. Colburn NRC, Project Manager, Perry

• R. Lipinski NRC, Mechanical Engineering Branch

• PART TIME

,. Enclosure 2 NRC - SERI MEETING MAY 4, 1989 NRC Staff Comments Regarding Licensing Activities o -Applications-for license amendments required substantial changes (Alternate decay heat removal system (ADHRS), TS 3.0.4 exceptions.

TS for control rod accumulator instruments)-

o Applications submitted too late to allow normal processing by NRC (sale and leaseback arrangements TS for load handling restrictions) o Responses to NRC Bulletions and Generic Letters inadequate (GL 88-11

" Radiation Embrittlement of RPV;" " Bulletin 88-10 Non-Confoming Molded Case. Circuit Breakers").

o Safety Analyses required by 10 CFR 50.59 not performed or inadequate for equipment and procedure changes-(Drain of RCIC steam supply line, bypassing all isolation instrumentadon for RWCU, addition of ADHRS, handling fuel in containment without primary continment (PLS-86-136), deletion of automatic trip of SGTS fans (PLS-86-123), addition of_ containment-hatchway crane (NPE-86-279)).

o Interpretation 'of TS- contrary to NRC staff's interpretation (Allowed outage times for ESF coolers, reporting requirements for diesel generator test failures, operability of an instrument channel if its actuated device is inoperable, ECCS injection LCO during refueling outages, RHR Shutdown cooling LCO during refueling outages) o Incorrect determination of non-valid diesel generator tests per Regulatory Guide 1.108 i

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AGENDA SERI-NRC MANAGEMENT MEETING '

l}, May 18, 1989 l

I. INTRODUCTION / PURPOSE LLK

'l II. SERI PRESENTATION A. RF03 Performance Review WTC B. SERI Organization WTC C. System Consolidation ,

WTC D. Policies, Programs and Practices Addressing WTC Safety Issues at GGNS E. Evaluation of Licensing Activities JGC o Applications for license amendments required substantial changes

~

o Applications submitted too late to allow normal processing by NRC o . Responses to NRC Bulletins and Generic Letters inadequate o Safety Analyses required by 10CFR50.59 not performed or inadequate for equipment and procedure changes o Interpretation of TS contrary to NRC staff's interpretation o Incorrect determination of nonvalid diesel generator tests per Regulatory Guide 1.108 1

III. NRC PERSPECTIVE ON SERI PERFORMANCE NRR/RII IV. DISCUSSION ALL V. CONCLUSION J14 MISC 89050302 - 1 g/

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. SYSTEM CONSOLIDATION--

J 0 . PURPOSE IS TO CONSOLIDATE MSU NUCLEAR' OPERATIONS MANAGEMENT.IN ONE COMPANY.

O APal.AND LP&L SUBMITTED OPERATING LICENSE AMENDMENTS TO L NRC.IN JULY 1988.

-0 NRC ISSUED PRELIMINARY SAFETY EVALUATION IN NOVEMBER

1988.

0 . PURSUING POSITIVE' REGULATORY ACTION WITH: ARKANSAS AND LOUISIANA PUBLIC SERVICE COMMISSIONS.

O THROUGH PROJECT OLIVE BRANCH' MSU IS SEEKING TO RESOLVE ALL REGULATORY AND-LEGAL ISSUES SURROUNDING.GGNS..

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POLICIES, PROGRAMS AND PRACTICES-ADDRESSING SAFETY ISSUES AT GGNS 0 CORPORATE MISSION'#1 l

ACHIEVE THE HIGHEST STANDARDS OF OPERATING PERFORMANCE'AND SAFETY IN THE U.S. NUCLEAR INDUSTRY

- PROVIDE EMPLOYEES A PROFESSIONAL, SAFE WORK ENVIRONMENT 0 CORPORATE OBJECTIVES DEVELOP AN. EMPLOYEE-TEAM DEDICATED TO PROMOTING SAFE OPERATION-ACHIEVE PERSONNEL RADIATION DOSE AND INDUSTRIAL SAFETY STATISTICS THAT ARE AMONG THE BEST-ACHIEVE AN APPROPRIATE IMAGE OF EXCELLENCE IN SAFETY AMONG SERI'S KEY PUBLICS O' RESPONSIBILITY BELONGS TO ALL' EMPLOYEES PRESIDENT HAS ULTIMATE RESPONSIBILITY FOR SAFE AND RELIABLE OPERATION VPNO DESIGNATED AS SENIOR NUCLEAR EXECUTIVE

- GGNS GENERAL MANAGER ASSURES SAFE, RELIABLE, AND EFFICIENT OPERATION OF THE. PLANT WITHIN THE CONSTRAINTS OF APPLICABLE REGULATORY REQUIREMENTS AND OPERATING LICENSES.

O SENIOR NUCLEAR EXECUTIVE ON-CALL TO MAKE HIGH LEVEL DECISIONS REGARDING PLANT SAFETY 0 INDEPENDENT SAFETY ENGINEERING GROUP TO ENSURE WE LEARN FROM OUR OWN AND OTHER PLANTS EXPERIENCES 0 SAFETY REVIEW COMMITTEES AND PLANT SAFETY REVIEW COMMITTEE ADVISE THF VICE PRESIDENT, NUCLEAR OPERATIONS AND GGNS GENERAL MANAGER ON MATTERS RELATED TO NUCLEAR SAFETY I

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~ DETERMINES SAFETY SIGNIFICANCE OF MATERIAL NONCONFORMANCES AND DEFICIENCIES-0' ' QUALITY PROGRAMS INSPECT MATERIALS-AND AUDITS PLANT ACTIVITIES 0 DEFICENCY IDENTIFICATION PROCESS AND OPERABILITY' DETERMINATION' x

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EVALUATION OF l.ICENSING ACTIVITIES

t. l 0 APPLICATIONS FOR LICENSE AMENDMENTS 0- APPLICATIONS SUBMITTED TOO LATE TO ALLOW NORMAL  :

PROCESSING BY NRC 0 RESPONSES To NRC BULLETINS AND GENERIC LETTERS' O SAFETY-ANALYSES REQUIRED BY 10CFR50.59 O INTERPRETATION.0F TECHNICAL SPECIFICATIONS 0 DETERMINATION OF NONVALID DIESEL GENERATOR TESTS PER.'

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