AECM-87-0081, Application for Amend to License NPF-29,requesting Deletion of OL Condition 2.C (20) Re Standby Svc Water Sys.Fee Paid

Application for Amend to License NPF-29,requesting Deletion of OL Condition 2.C (20) Re Standby Svc Water Sys.Fee Paid

ML20206E029
Person / Time
Site:	Grand Gulf
Issue date:	04/08/1987
From:	Kingsley O SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206E032	List: AECM-87-0081, Application for Amend to License NPF-29,requesting Deletion of OL Condition 2.C (20) Re Standby Svc Water Sys.Fee Paid ML20206E066
References
AECM-87-0081, AECM-87-81, TAC-65156, NUDOCS 8704130493
Download: ML20206E029 (6)

Text

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gsg April 8, 1987 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk Gentlemen:

2

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Proposed Amendment to the Operating g-License (PCOL-87/02)

Deletion of OLC 2.C.(20) on SSW AECM-87/0081 System Energy Resources Inc. (SERI) is requesting by this submittal, an amendment to License NPF-29, for Grand Gulf Nuclear Station Unit 1. This amendment requests deletion of Operating License Condition (0LC) 2.C.(20) concerning the Standby Service Water System (SSW). The provisions of OLC 2.C.(20) requiring modifications to SSW loops A and B have been completed and required design flows have been achieved to all essential SSW system components. The deletion of this license condition is based on a mutual decision by both the NRC and SERI.

In accordance with the provisions of 10 CFR 50.30 and 50.4, the signed original of the requested amendment is enclosed and the appropriate copies will be distributed. The attachment provides the complete technical justification and discussion to support the requested amendment. This amendment has been reviewed and accepted by the Plant Safety Review Committee (PSRC) and the Safety Review Committee (SRC).

Based cn the guidelines presented in 10 CFR 50.92, it is the opinion of System Energy Resources, Inc. that this proposed amendment involves no significant hazards considerations.

In accordance with the requirements of 10 CFR 170.21, we have determined that the application fee is $150. A remittance of $150 is attached to this letter.

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AECM-87/0081

- Page 2 cc: Mr. T. H. Cloninger (w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr.~ H. L. Thomas (w/o)

Mr. R. C. Butcher (w/a)

Dr. J. Nelson Grace, Regional Administrator (w/a)

U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 f

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_ ._ ~ . _ _ . _ . _ _ _ _ _ _ _ _ _ , _ _ - . . _ . _ _ . _ . . . ._ .._. ._

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE N0. NPF-29 00CKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION

! AFFIRMATION I, 0. D. Kingsley, Jr. , being duly sworn, stated that I am Vice President, Nuclear Operatior.s of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by System Energy Resources, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, l'uclear Operations of System Energy Resources, Inc.; and that the statements made and the matters set fort therein are true and correct to the best of my kno.vledge, information an ief.

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O. Of Kings , r STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN T0 bef ye me, a Notary Public, in and for the County and State above named, this 4-dayof($94lst. , 1987.

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,)r Notary Public My commission expires:

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Attachment to AECM-87/0081 OLR NLS-87/01 Deletion of License Condition 2.C.(20) on SSW SubvECT: Operating License Condition 2.C.(20) on the Standby Service Water System; page 8 of the GGNS Operating License.

DISCUSSION: OLC 2.C.(20) restricts placement of irradiated fuel in the GGNS Unit 1 spent fuel storage pool prior to completion of modifications to either Loop A or Loop B of the Standby Service Water (SSW) system and verification that the design flow can be achieved to all essential SSW system components in the modified loop. Certain provisions for a core off-loading prior to completion of system modifications are provided in OLC 2.C.(20).

OLC 2.C.(20) also requires that the spent fuel pool cooler in an unmodified loop be isolated from the loop by locked closed valves or the loop shall be declared inoperable. The position of these valves were required to be verified every 31 days until the design flowrate for the SSW loop was demonstrated.

In a letter (AECM-86/0234) to the NRC dated July 25, 1986, a commitment was made to submit a proposed license amendment deleting License Condition 2.C.(20) within 3 months after restart following the first refueling outage at GGNS. This submittal requests deletion of License Condition 2.C.(20) on the Standby Service Water System. A reference to NRC correspondence documenting successful completion of the provisions of OLC 2.C.(20) is provided herein.

JUSTIFICATION: Both SSW Loop A and Loop B required modifications in order to comply with the provision of OLC 2.C.(20). Modifications included installation of larger SSW pump motors and impellers, piping modifications and pipe cleaning and flushing.

In the fall of 1985, a larger SSW pump motor and impeller were installed in SSW Loop B in order to increase system flow rates.

In the fall of 1986, during the first refueling outage a larger pump motor and impeller were installed in SSW Loop A.

As documented in LER 86-029-05 dated March 19, 1987 (AECM-87/0060) during an RF01 system flow check conducted with the SSW in the post-LOCA configuration, it was revealed that flowrates to certain components were below post accident design values due to flow impediments. These flow impediments were caused by the fouling of small diameter branch piping due to microbiological induced corrosion and sedimentation from Plant Service Water (PSW) interface connections . Flows were improved to the components by hydrolazing and flushing the PSW/SSW piping to reduce the amount of blockage. Permanent flush and drain connections were installed in the piping to facilitate more routine future cleaning operations. When flushing /hydrolazing was complete some components still had flowrates below nominal design values; however, engineering determined that the flowrates met or exceeded the minimum acceptable flowrates needed to achieve the design intent of the components. This newly established minimum acceptable value became that component's minimum design flowrate.

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Attachment to

• - AECM-87/0081' Prior to startup from RF01, flowrates to the SSW supplied components were remeasured and found to be acceptable. Thus the-license condition was satisfied prior to startup from the first refueling outage.

NRC Inspection Report 86-39 dated January 16, 1987 documents satisfactory completion of the provisions of License Condition-2.C.(20).

SIGNIFICANT HAZARDS CONSIDERATION:

The proposed change to the GGNS Unit 1 Operating License would delete License Condition 2.C.(20) on the.SSW System. The operating license was conditioned originally to' prevent the storage of irradiated fuel in the Unit I spent fuel pool until the required modifications to'the SSW system have been completed and proper cooling flow verified.(

Reference:

NRC SER on GGNS, NUREG-0831, Supplement 2, June 1982). The overall intent of this condition was to establish appropriate regulatory requirements restricting the use of the Unit 1 spent fuel pool until certain corrective measures were taken.

The required design changes to the SSW system _have been implemented and appropriate minimum design cooling water flow rates to essential SSW system components have been established and verified. The provisions of the license condition have been satisfied, and the restrictions contained in the condition are no longer applicable.

Since the condition is no longer applicable and since its presence in the operating license may lead to a misinterpretation or misapplication of requirements, this change to the operating license proposes the deletion of License Condition 2.C(20). Because the subject license condition has been satisfied and is now no longer applicable, this proposed change is considered administrative in nature.

The proposed change does not involve a significant hazards consideration because operation of Grand Gulf Unit 1 in accordance with this change would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated. Design changes to the SSW system have been completed and minimum design flows to all essential SSW components have been verified. Therefore, since the SSW system is performing its safety function and since proper controls of the system are in place through the technical specifications and related procedures, there is no increase in the probability or consequences of an accident previously evaluated.

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Attachment to

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.(2) create the possibility of a new or different kind of accident from any accident previously evaluated. The modifications to SSW Loops A and B were made to return

. system flowrates to minimum design requirements or better. These modifications do not create the possibility of a new or different kind of accident from any accident previously evaluated because no additional failure modes have been introduced.

(3) result in a significant reduction in the margin of safety. The margin of safety has been increased with the return to minimum design flows for all essential SSW components. The subject license condition has been satisfied with the establishment and verification of proper SSW cooling water flow to essential components, including the spent fuel pool coolers (previously valved out of service). The license condition is no longer applicable. Its presence in the license may contribute to misinterpretation or misapplication of requirements.

Proper controls regarding the system are in place by way of the plant's technical specifications. For these reasons deletion of the license condition is appropriate and represents no reduction in the margin of safety.

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