ML20246M020
| ML20246M020 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/16/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246M018 | List: |
| References | |
| NUDOCS 8903270016 | |
| Download: ML20246M020 (9) | |
Text
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'o UNITED STATES
-II NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20556
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 58 TO FACILITY OPERATING LICENSE NO. NPF-29 SYSTEM ENERGY RESOURCES, INC., ET AL.
GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416
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1.0 INTRODUCTION
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By. letter dated January 26, 1989, as supplemented February 20, March 3, and March 6, 1989, System Energy Resources, Inc. (the licensee), requested an amendment.to Facility Operating License No. NPF-29 for the Grand Gulf Nuclear Station, Unit 1.
The proposed amendment would provide one time exceptions to Section 3.0.4 in the Technical Specifications (TS) for use only during the third refueling outage (RF03). The exce)tions would allow entry into certain operational conditions (OC) wit 1out meeting the Limiting Conditions for Operation (LCO), provided the requirements of associated action statements are met.
The submittals dated February 20, March 3 and March 6,1989, provided supplemental infomation in response to staff concerns raised during the review process. These submittais, which provide a narrowing of the scope of the original exception request and an expanded safety analysPpor justifying the exceptions, did not alter the action noticed or affect the initial determination published in the Federal Register on February 8,1989.
Section 3.0.4 in the Technical Specifications states:
Entry into an OPERATIONAL CONDITION or other specified condition shall not be made unless the conditions-in the Limiting Conditions for Operation are met without reliance on provisions contained in the ACTION requirements.
This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.
Exceptions to these requirements are stated in the individual Specifications.
The proposed changes to the TS, as identified in the February 20, 1989 submittal, would provide exceptions to Specification 3.0.4 to be used only during the third refueling outage in the following areas:
1.
The first proposed change would add a sentence to Action a and revise the ** footnote to TS 3.4.9.2 (RHR - Cold Shutdown) to state that the provisions of Specification 3.0.4 are not applicable N
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' for entry into OC 4 from 5 and that the change is applicable until-startup from RF03. The present Action c is being deleted since the-applicability expired at the end of the previous refueling outage.
-2.
The second proposed change would add a statement to Action a of TS 3.5.2 (ECCS - Shutdown) to state that the provisions of Specifi-cation 3.0.4 are not applicable for entry into DC 5 from 5* and.
revise the i footnote to state that the change is applicable until startup from RF03.
3.
The third proposed change would add a statement to Action e of TS 3.5.3 (Suppression Pool) to state that the provisions of Specification 3.0.4 are not applicable for entry into DC 5 from 4 or 5* and a **
footnote to state that the change is applicable until startup from RF03.
4.
The fourth proposed change.would add a statement to Actions b and c of TS 3.6.4 (Containment and Drywell Isolation Valves) to state that the provisions of Specification 3.0.4 are not applicable for-. entry into condition i for a maximum of 10 inoperable containment and drywell isolation valves and a ** footnote to. state that the change:
.is applicable until startup from RF03.
In addition, a statement is added to the
- footnote to state that OPERATIONAL CONDITION changesi are not allowed while isolation valves are open under administrative controls of the
- footnote.
5.
The fifth proposed change would add a statement to Actions b and c of TS 3.6.6.2 (Secondary Containment Automatic Isolation Dampers / Valves) to state that the provisions of Specification 3.0.4 are not applicable for entry into condition
- for a maximum of 10 inoperable dampers / valves and a i footnote to state that the change is applicable until startup from RF03.
6.
The sixth proposed change would add a statement to Actions b, e and d of TS 3.7.1.1 (Standby Service Water System) to state that the provisions of Specification 3.0.4 are not applicable. The change to Action b will only be applicable for entry into OC 4 from 5.
The change to Action c will only be applicable for lowering reactor cavity water level. The change to Action d will only be applicable for lowering reactor cavity water level in OC 5.
Alsc, the #
footnote is revised to state that the changes are applicable until startup from RF03.
7.
The seventh proposed change would add a statement to Action a of TS 3.7.1.3 (Ultimate Heat Sink) to state that the provisions of Specification 3.0.4 are not applicable for entry into OC 4, 5 and
- and a ** footnote to state that the change is applicable until startup from RF03.
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The eighth proposed change will add a statement to Action b.1 of TS 3.7.2 (Control Room Emergency Filtration System) to state that the provisions of Specification 3.0.4 are not applicable for entry into OC 4 from 5 and a # footnote to state that the change is applicable until startup from RF03.
9.
The ninth proposed change will add a new Action c to TS 3.9.11.2 (RHR and Coolant Recirculation - Low Water) to state that the provisions of Specification 3.0.4 are not applicable for entry into OC 5 from 4 or lowering reactor cavity water level and revise the
- footnote to state that the change is applicable until startup from RF03.
2.0 EVALUATION We have reviewed the licensee's proposals for the one time exceptions to TS 3.0.4 for certain TS to be effective only during RF03.
The proposals included a description and justification of the requested TS changes, a description of the outage activities that result in the request for the exceptions and a safety analysis. The analysis reviewed the safety implications of entering Operational Conditions (0C) when the plant is being operated in Action Statement (AS) requirements, thus, not fully meeting the requirements in the LCO.
The changes in OC in which exceptions to TS 3.0.4 were requested are listed below by major activity in which the exceptions are needed:
Activity Which Changes Operational Conditions Exception Requested Detensioning bolts in reactor TS 3.9.11.2, AS a pressure vessel (RPV) head and removing head with one inoperable RHR loop Drain water from reactor cavity TS 3.5.2, AS a to RPV flange with one inoperable TS 3.7.1.1, AS c&d ECCS subsystem and one inoperable TS 3.7.1.3, AS a RHR loop TS 3.9.11.2, AS aab Drain water from reactor cavity TS 3.7.1.1, AS cad to RPV flange with one inoperable TS 3.7.1.3, AS a RHR loop TS 3.9.11.2, AS a&b Retensioning bolts in RPV with TS 3.4.9.2, AS a one inoperable RHR loop TS 3.7.1.1, AS b In addition to the above listed activities, which change operational condi-tions, there are four other activities for which exceptions to TS 3.0.4 were requested because they will be performed during several 0C. These four activities ar.d the exceptions requested are listed below:
.tr.
. Activities Exception Requested-Alternate Decay Heat Removal TS 3.5.3, AS c System (ADHRS) installation and operation Containment and drywell TS 3.6.4, AS b and c isolation valves maintenance, inspection and testing Secondary containment isolation TS 3.6.6.2, AS b and c dampers and valves maintenance, inspection and testing Control room emergency filtration TS 3.7.2, AS b.1 system maintenance and surveillance The acceptability of these proposed exceptions to TS 3.0.4 are evaluated below.
2.1 Detension bolts in RPV head with one inoperable RHR loop This activity results in going from OC 4 to OC 5 with a low reactor cavity water level. TS 3.9.11.2 LC0 requires two operable shutdown cooling mode loops of the RHR system.
At this time, RHR shutdown cooling loop A will be operable and running.
RHR shutdown cooling loop B will be inoperable due to feedwater B local i
leak rate testing, which prevents use of the normal return path through l
the feedwater sparger. Action a allows an alternate method capable rf decay heat removal to be used provided the method is demonstrated before use. The licensee proposes to use RHR shutdown cooling loop B with the return path through the LPCI B discharge line as the alternate method.
The.LPCI B line discharges into the space between the fuel assemblies near J
the top of the core.
This alternate method provides an acceptable level of safety because the only difference between the proposed alternate and-an operable shutdown cooling loop is that the discharge will be into the space between fuel assemblies rather than to the feedwater sparger. TS 3.9.11.2, AS a, requires that the decay heat removal capability of the alternate method be-demonstrated before use.
This action is required so that any differences in reactor coolant flow within the reactor vessel for the different return path of the alternate method will be determined by test to be acceptable prior to use.
Accordingly, the proposed change to TS 3.9.11.2, AS a, is acceptable for this activity.
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2.2 Drain water from reactor cavity with one inoperable ECCS subsystem
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and one inoperable RHR loop This activity. results in _ going from a high water level in the reactor cavity to a low water level (to the reactor pressure vessel flange) during OC 5.
TS 3.5.2 LCO requires at least two ECCS subsystems to be operable in OC 5 except that no ECCS subsystems are required to be operable for a high water level.
TS 3.9.11.2 LCO requires two operable shutdown cooling mode loops of the RHR system. TS 3.7.1.1 LC0 requires operable' standby service water (SSW)' subsystems associated with the RHR loop required-to be operable by TS 3.9.11.2.
TS 3.7.1.3 LCO requires an operable cooling tower basin associated with the subsystems required to be operable by TS 3.7.1.1.
At the start of this cavity draining, the low pressure core spray (LPCS) and low pressure coolant injection (LPCI) subsystem A will be operable.
As the water level is lowered, the LPCI A will become inoperable because the jockey pump for LPCI A must be isolated because of the operation of a new system, the ADHRS. We are reviewing the acceptability of the ADHRS separately.
By letter dated March 3,1989, the licensee comitted to determine actions necessary to prevent adverse effects of the ADHRS on LPCI operability for future outages and provide results to the NRC by October 7,1989. Action a allows one of the required subsystems to be inoperable provided all operations that have a potential for draining the reactor are suspended.
Lowering the reactor cavity water level is not an operation with the potential to drain the reactor vessel because the cavity drains are external to the reactor vessel at about the reactor vessel flange elevation. The cavity water level cannot be lowered below the reactor vessel flange when it is drained in this manner.
During our review we noted that the TS 3.5.2 LCO lists three ECCS subsystems thataremanuallyinitiated(LPCIA,LPCIBandLPCIC)andtwosubsystems (LPCS and HPCS) that are automatically initiated when the reactor pressure vessel water level is low. We were concerned that if two manually initiated subsystems were required to be operable.--the core may be uncovered in an inadvertent drain event. In response to this concern, the licensee, by letter dated March 6, 1989 (AECM-89/0052), committed to implement adminis-trative controls in the form of a Technical Specification Position Statement (TSPS) to require that at least one of the two ECCS required operable by, TS 3.5.2 be capable of automatic initiation and injection to the reactor vessel.
The TSPS will be in effect for the short term including RF03.
A modification to the TS will be considered by the licensee and evaluated following RF03.
The licensee has comitted to submit the evaluation and necessary TS changes to the NRC by September 22, 1989.
Thus, we conclude that draining the' water from the reactor cavity with an inoperable ECCS subsystem is. acceptable for RF03 because the remaining operable subsystem, the LPCS, will be automatically actuated upon low reactor vessel water level. Accordingly, the requested exception to TS 3.0.4 for TS 3.5.2, AS a, is acceptable.
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'a' w. 2.2 Drain water from reactor cavity with one inoperable ECCS subsystem and one inoperable RNR loop This activity results in going from a high water level in the reactor cavity to a low water level (to the reactor pressure vessel flange) during OC 5.
TS 3.5.2.LC0 requires at least two ECCS subsystems to be operable L
in OC 5 except that no ECCS subsystems are required to be operable for a high water level. TS 3.9.11.2 LC0 requires two operable shutdown cooling mode loops of the RHR system. TS 3.7.1.1 LC0 requires operable ~ standby service water (SSW) subsystems associated with the RHR loop required to be operable by TS 3.9.11.2.
TS 3.7.1.3 LCO requires an operable cooling tower basin associated with the subsystems required to be operable by TS 3.7.1.1.
At the start of this cavity draining, the low pressure core spray (LPCS) and low pressure coolant injection (LPCI) subsystem A will be operable.
As the water level is lowered, the LPCI A will become inoperable because the jockey pump for LPCI A must be isolated because of the operation of a new system, the ADHRS. We are reviewing the acceptability of the ADHRS l
separately. By letter dated March 3,1989, the licensee connitted to determine actions necessary to prevent adverse effects of the ADHRS on l
LPCI operability.for future outages and provide results to the NRC by October 7,1989. Action a allows. one of the required subsystems to be..
inoperable provided all operations that have a potential for draining the reactor are suspended. Lowering the. reactor cavity water level is not an operation with the potential to drain the reactor vessel, because the cavity drains are external to the reactor vessel at about the reactor vessel flange elevation. The cavity water level cannot be lowered below the reactor vessel flange when it is drained in this manner.
During our review we noted that the TS 3.5.2 LCO lists three ECCS subsystems-thataremanuallyinitiated(LPCIA,LPCIBandLPCIC)andtwosubsystems (LPCS and HPCS) that are automatically initiated when the reactor pressure vessel water level is low. We were concerned that if two manually initiated subsystems were required to be operable, the core may be uncovered in an inadvertent drain event. In response to this concern, the licensee, by letterdatedMarch6,1989(AECM-89/0052), connitted to implement adminis-trative controls in the form of a Technical Specification Position Statement (TSPS) to require that at least one of the two ECCS required operable by.
TS 3.5.2 be capable of automatic initiation and injection to the reactor vessel. -The TSPS will be in effect for the short tenn including RF03.
A modification to the TS will be considered by the licensee and evaluated following RF03. The licensee has committed to submit the evaluation and necessary TS changes to the NRC by September 22, 1989.
Thus, we conclude that draining the water from the reactor cavity with an inoperable ECCS subsystem is acceptable for RF03 because the remaining operable subsystem, the LPCS, will be automatically actuated upon low reactor vessel water level. Accordingly, the requested exception to TS 3.0.4 for TS 3.5.2, AS a, is acceptable.
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' The licensee also requested TS 3.0.4 exceptions for TS 3.9.11.2, AS a and b; TS 3.7.1.3, AS a; and TS 3.7.1.1, AS c and d, because during the drain down, only RHR shutdown cooling loop A will be operable.
TS 3.9.11.2 LC0 requires two operable RHR shutdown cooling loops. RHR l
loop B will be inoperable due to maintenance on the loop.
The ADHRS
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is proposed as the alternate method for removing decay heat.. The ADHRS is powered by offsite power only. However, its use, as proposed here, is acceptable because it would replace RHR shutdown cooling loop B, which would also be powered by offsite power, because the Division II diesel generator would be undergoing maintenance.
We conclude that draining water from the reactor cavity with an inoperable RHR shutdown cooling loop is~ acceptable because the ADHRS is equivalent to the inoperable RHR B loop it would replace in that both would be powered by offsite power. Accordingly, the proposed changes to.TS 3.9.11.2, AS a and b, TS 3.7.1.3, AS a, and TS 3.7.1.1, AS c and d, are acceptable for this activity.
2.3 Drain water from reactor cavity with one inoperable RHR loop This activity is similar to that described in Section 2.2, except in this: drain down there will be two ECCS subsystems operable so that an exception to TS 3.5.2 is not requested..The licensee requested TS 3.0.4 exceptions for TS 3.9.11.2, AS a and b; TS 3.7.1.3, AS a; and TS 3.7.1.1, AS c and d, because during the drain down only RHR shutdown cooling loop A will be operable. The TS 3.9.11.2 LCO requires two operable RHR shutdown cooling loops.
RHR loop 8 and the associated SSW subsystem and the associated ultimate heat sink (VHS) basin will be inoperable because basin water level will be less than that required in the TS 3.7.1.3 LCO. This basin water level is normally required so that a 30-day water supply will be available following an accident. The basin water level will be lowered for cleaning and maintenance of the basin. The licensee proposed to use RHR loop B with a reduced water level in the basin as the alternate method capable of decay heat removal required by TS 3.9.11.2, AS a.
By letter dated March 3, 1989, the licensee provided a suunary of procedures and a safety analysis to demonstrate that water level in the basin would be kept to a level adequate to meet SSW pump net pump suction head requirements and that an adequate water supply to the basin would be available. We conclude that this alternate method for decay heat removal is acceptable because (1) the only difference between the proposed alternate method and the operable RHR loop B is the lower water level in the UHS basin and (2) procedures will be in place to assure adequate NPSH and an adequate water supply to the UHS basin for the plant conditions.
Accordingly, the proposed changes to TS 3.9.11.2, AS a and b; TS 3.7.1.3, AS a; and TS 3.7.1.1, AS c and d, are acceptable for this activity.
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. 2.'4 -Retensioning bolts in the RPV head with one inoperable RHR loop This activity results in going from OC 5 to DC 4 with a low reactor cavity water level. TS 3.4.9.2 LCO requires two operable RHR loops.
RHR loop A will be operable and the TS 3.7.1.1 LCO requires associated SSW subsystems to be operable. RHR loop B and the associated SSW sub-system will be inoperable due to a low water level in the UHS basin.
RHR B loop will be the alternate means for shutdown cooling required by AS a.
As discussed in Section 2.3 of this safety evaluation, this alternate means is acceptable because procedures will be in place to assure adequate NPSH for the SSW pump and an adequate water supply to the VHS basin.
Accordingly, the proposed changes to TS 3.4.9.2, AS a, and TS 3.7.1.1, AS b are acceptable for this activity.
2.5 Alternate decay heat removal system (ADHRS) installation and operation The installation of the new ADHR$ and its use during RF03 would result in one division of the suppression sool water level instrumentation being inoperable. This is due to tie requirement for RHR C jockey pump to be out-of-service when the ADHRS is installed and operated.
This pump keeps the reference leg filled for one division of suppres-sion pool water level instrumentation. The licensee has requested a one-time TS 3.0.4 exception for TS 3.5.3, AS c, for use during RF03.
By letter dated March 3, 1989, the licensee committed to evaluate l
actions necessary to prevent this adverse interaction of ADHRS opera-tion on the suppression pool level instrumentation, j
When one division of the suppression pool level instrumentation is inoperable TS 3.5.3 requires the level be verified at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
For this one time, use of ADHRS visual inspecticn of the actual pool water level will be performed once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Other planned activities during this interval of the outage do not affect suppression pool inventory. We conclude that the alternate means of determining suppression pool level for this activity is acceptable.
Accordingly, the proposed change to TS 3.5.3, AS c, is acceptable.
2.6 Containment and drywell isolation valves maintenance The licensee has requested an exception to TS 3.0.4 for TS 3.6.4, AS b and c, for the purpose of maintenance, testing and inspection of containment and drywell isolation valves.
During this interval of the outage, the plant will be in OC 5.
Other activities during these intervals will include core alterations, handling irradiated fuel, I
and work on the reactor pressure vessel bottom drain line. The number L
of valves allowed to be inoperable at any one time would be limited to 10 valves. The requirements of AS b and c would be met to maintain L
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> isolation of each penetration during this activity.
In addition, changes-in plant operational conditions would not be allowed during the time isolation valves are reopened under administrative controls as allowed by the present
- footnote in TS 3.6.4.
Therefore, we conclude that the proposed changes to TS 3.6.4, AS b and c, and footnote
- are acceptable because these action statements, as modified, would maintain containment and drywell integrity during the time the valves are being worked on and tested.
2.7 Secondary containment isolation dampers and valves maintenance i
The licensee has requested an exception for TS 3.6.6.2, AS b and c, J
for the purpose of maintenance of secondary containment isolation dampers and valves. The requirements of AS b and c would be met to maintain secondary containment integrity. The number of isolation dampers and valves allowed to be inoperable at any one time would b(
limited to 10.
I We conclude that the proposed changes to TS 3.6.6.2, AS b and c,
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are acceptable because these' action statements as modified would maintain secondary containment while the valves and dampers are worked on and tested.
2.8 Control room emergency filtration system maintenance and testing Maintenance on the control room emergency filtration system will result in the inoperability of both subsystems, because maintenance is planned on l
the isolation valves in the connon fresh air inlet and the common purge j
line. AS a.1 requires an inoperable subsystem to be placed in the "I
isolation mode of operation. Since both subsystems will be inoperable, the licensee would place both subsystems in the isolation mode and one of the systems in operation.
Plant procedures require cessation of any painting in the vicinity of the system inlet duct to preclude clogging of the charcoal and decreasing the iodine removal efficiency of the filters.
The licensee has requested a TS 3.0.4 exception for TS 3.7.2 AS a.1, during this maintenance activity. We conclude that the requested TS exceptions are acceptable because the filtration system will be capable of j
performing its safety function in the event of an accident during this activity.
2.9 Sunnary The proposed exceptions to TS 3.0.4 are acceptable, as requested, during RF03 because the compensatory measures described in this safety evalua-tion are acceptable alternatives to meeting the LCO requirements.
The new ADHRS to be installed and used during RF03 causes some adverse interactions with other systems required to be operable during cold j
shutdown and refueling. The licensee has committed to detennine actions i
necessary to prevent these adverse interactions for the long term.
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3.0 ENVIRONMENTAL CONSIDERATION
This amendment changes a requirement with respect to the installation or use of a facility component-located within the restricted area as defined in 10 CFR Part 20.
The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the' types, of any effluents that may be released off site; and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion. set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
4.0 CONCLUSION
The Commission made a proposed determination that this amendment involves no significant hazards consideration, which was published in the Federal Register (54 FR 6199).on February 8,1989, and consulted with the state of Mississippi.
No public comments or requests for hearing were received, and the State of Mississippi did not have any connents..
The staff has concluded, based'on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the p(ublic will not be endangered by operation in the proposed manner, and2) such a regulations and the-issuance of this amendment will not be inimical to the common defense and the security, or to the health and safety of the public.
Principal Contributors:
M. McCoy, Reactor Systems Branch L. Kintner, Project Directorate II-1 Dated: March 16,'1989 l
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