AECM-83-0622, Forwards Rept Describing Generic Problems Discovered During Surveillance Program Review Effort & Corrective Actions Implemented to Correct Surveillance Deficiencies,Per IE Insp Rept 50-416/82-67

Forwards Rept Describing Generic Problems Discovered During Surveillance Program Review Effort & Corrective Actions Implemented to Correct Surveillance Deficiencies,Per IE Insp Rept 50-416/82-67

ML20086T834
Person / Time
Site:	Grand Gulf
Issue date:	12/01/1983
From:	Dale L MISSISSIPPI POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
AECM-83-0622, AECM-83-622, NUDOCS 8403070057
Download: ML20086T834 (29)

Text

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. B O X 16 4 0, J A C K Sp,N , M I S S I S S I P P I 3 9 2 0 5 e .it. .O December 1, 1983 NUCLEAR PRODUwflON DEPARTMENT U. S. Nuclear Regulatory Commission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30303 Actention: Mr. J. P. O'Reilly, Regional Administratcr

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-13 File 0260/L-835.0 GGNS Unit 1 Surveillance Review Program Results AECM-83/0622 Nuclear Regulatory Commission (NRC) Inspection Report No. 50-416/82-67 dated December 10, 1982, transmitted several violations that identified numerous GGNS Surveillance Program deficiencies. Mississippi Power & Light (MP&L) responded to the NRC violations in a letter (AECM-83/436) dated January 21, 1983. In this response, MP&L committed to establish a Surveillance Review Program to rewrite as necessary all surveillance procedures to ensure technical adequacy and compliance to Technical Specifications.

MP&L has implemented numerous corrective actions to ensure that all surveillance procedures are technically adequate and in compliance with the Technical Specifications and a program has been established to effectively incorporate, control, and implement regulatory reauirements.

The attached report describes the generic problems discovered during the review effort and the corrective actions implemented to correct surveillance deficiencies.

Yours truly, E $ NN L. F. Dale Manager of Nuclear Services EBS/SHH: sap Attachment cc: (See Next Page) 8403070057 831201 PDR ADOCK 05000416 G PDR g\ I

/ \ T Member Middle South LJtilities System

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AECM-83/0622 MISSISSIPPI POWER O Ll2HT COMPANY #E*

cc: Mr. J. B. Richard (w/a)

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

Mr. T. B. Conner (w/o)

Mr. G. B. Taylor (w/o)

Mr. Richard C.'DaYoung, Director (w/a)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. ~20555 Document Control Desk (w/a)

U. S. Nuclear Regulatory Commissinn 4 Washf.ngton, D. C. 20555 i

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Table of Contents Summary i

Section 1 - Generic Problems A. Non-Incorporation of Technical Specification Items B. Procedural Non-Compliance with Technical Specification Definitions i C. Non-Incorporation of Amended Technical Specifications D. Non-Conservatism I

E. Mis-Scheduling of Required Surveillances F. Inadequate Document Cross-Reference

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G. Head Correction Problems H. Technical Specification Non-Conformity to As-Built Conditions i

I. Technical Specification Inconsistency J. Technical Specification Editorial or Nomenclature Errors K. Proposed Technical Specification Changes Section 2 - Corrective Actions i

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a SIMMARY '

This report is a final summary of all problems encountered in the GGNS Sutveillance Program.

Inadequate surveillance procedures were a result of inadequate programmatic controls ever surveillance activities. The surveillance program deficiencies were a result of (1) inadequate technical review, (2) inadequate independent quality revinz, and/or #3) failure to review the final approved Technical Specifications against procedures which had been developed from earlier draft Technical Specifications.

Section 1 documents'the problems discovered in the surveillance program review effort and the probable consequences of each generic problem. An estimate of the number of procedures associated with each generic problem is provided in t'.e associated discussion of each problem.

Section 2 describes the corrective actions used to ensure that all surveillance procedures are technically adequate and in compliance with the Technical Specifications and the program established to effectively.

incorporate, control, and implement regulatory requirements.

All surveillance procedures have been reviewed for adequacy. All procedures identified as inadequate which are needed for Operational Conditions 2, 3, and 4 have been rewritten, reviewed, and approved, and, as necessary, associated surveillances have been reperformed for the applicable operational requirements. Additional procedures that have been identified as inadequate which are needed for Operational Condition 1 are expected to be rewritten, reviewed, and approved by mid-January. Certain procedures which are needed in the long-term, such as procedures needed for refueling, will be rewritten at a later date.

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, . l SECTION 1 ll i

Generic Problems A. Non-Incorporation of Technical Specification Items The following specific problems were found by the Surveillance Review Team involving surveillance procedures that did not adequately incorporate all Technical Specification requirements:

1. Procedures did not exist to perform the surveillances required by Technical Specifications. Thirty-eight procedures were affected.

2. Procedures did not test all the equipment required. Eighty procedures were affected.

3. The motor operated valve thermal overload protection functional test requirements of Technical Specification 4.8.2.1 and Technical Specification 4.8.4.2.3 were incorrectly or inadequately covered by procedures. Twenty-nine procedures were affected.

4. Procedures did not test every valve, br+aker, or snubber required by the Technical Specifications. Thirty-fcur procedures were affected.

5. One procedure was changed prior to an ODCM revision, which would permit the change.

The probable consequences of non-incorporation of Technical Specification items are:

1. The inability to satisfy Technical Specification operability requirements, resulting in entry into an LCO action statement.

2. Uncertainty of the actual operational status of equipment not tested.

3. Operation of equipment not in compliance with Technical Specifications.

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SECTION 1  !

B. Procedural Non-Compliance with Technical Specification Definitions The following specific problems were found by the Surveillance Review Team involving procedural non-compliance with Technical Specification Definitions:

1. Procedures did not check every alarm required by Technical Specification Definitions 1.4 and 1.6. Fifty-four surveillance procedures were affected.

2. Procedures did not specify the acceptance criteria for channel checks. Forty surveillance procedures were affected.

3. Calibration procedures did not adequately include a functional test as required by Technical Specification Definition 1.4. Fifty surveillance procedures were affected.

4. Channel calibration procedures did not check the entire parameter sensing loop (pressure transmitter and trip unit) as required by Technical Specification Definition 1.4. Twenty-eight surveillance procedures were affected.

5. The Logic System Functional Test did not take into account the required " series of sequential, overlapping or total system steps" so that the entire logic system could be considered tested per Technical Specification Definition 1.22. Forty-seven surveillance procedures were affected.

6. Some equipment response times were not covered by procedures. This invalidated the required " series of sequential, overlapping or total steps" concept so that the entire system response time, as defined in Technical Specifications 1.12, 1.13, 1.19, and 1.34, was inaccurate. Ten surveillance procedures were affected.

The probable consequences caused by non-compliance with Technical Specification Definitions are:

1. The inability to satisfy Technical Specification operability requirements, resulting in entry into an LCO action statement.

2. Uncertainty of the actual operational status of equipment not tested.

3. Operation of equipment not-in compliance with Technical Specifications.

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SECTION 1 C. Non-Incorporation of Amended Technical Specifications Administrative Procedure 01-S-06-12, Revision 5, "GGNS Surveillance Program", had no effective program to ensure that surveillance procedures were revised to comply with amended Technical Specifications. The probable consequences of an ineffective update program would have been the performance of surveillances that were not in compliance with the GGNS Technical Specifications.

D. Non-Conservatism Procedure acceptance criterias were less conservative than Technical Specifications required. For example, some instrument setpoints used tolerances not within the limits of Technical Specifications or erroneously listed incorrect units. Twenty-three procedures were affected.

The probable consequences of this problem would have been the operation of equipment not in compliance with Technical Specifications.

E. Mis-Scheduling of Required Surveillances The following specific mis-scheduling problems involving required surveillances were discovered by the Surveillance Review Team:

1. Procedures incorrectly stated the surveillance frequency requirements. Seventy procedures were affected.

2. Procedures incorrectly stated and/or did not include the operational conditions for which the surveillance was applicable. Eighty-one procedures were affected.

3. Time response procedures incorrectly stated the required test frequency of individual channels or subsections. Thirty-five procedures were affected.

The probable consequences of mis-scheduling required surveillances are:

1. Surveillance requirements not satisfied before the late date. This would require entry into an LCO action statement.

2. Surveillance procedures not being performed during the applicable operational conditions. This would require entry into an LCO action statement.

3. Surveillances being performed at a grer.ter rate than the Technical Specification requires. This wculd not violate Technical Specifications but could create a manpower shortage for performing other required surveillances.

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SECTION 1 1

F. Inadequate Document Cross-Reference l The following specific problems involving inadequate document cross-l references were discovered by the Surveillance Review Team:

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1. Proceaures specifying " normal" valve position were not in accordance with the Technical Specifications, FSAR, or the System Operating Instructions. Thirteen procedures were affected.

2. Steps were not provided in surveillance procedures to return safety

! related valves and switches to their "nornal" or "as found" f positions upon completion of a test when their positions were changed as a result of a survsillance. Sixteen procedures were affected.

3. Procedures referenced a System Operating Instruction or Integrated Operating Instruction to perform a surveillance or sequence of steps, however, the SOI or IOI did not actually perform the surveillance or sequence of steps to the desired end result.

Fourteen procedures were affected.

The probable consequences of this problem would have been:

1. Surveillance requirements not being performed, resulting in the entry into an LCO action statement.

2. Equipment not returned to the " normal" operational configuration at surveillance completion.

G. Head Correction Factors The calibration procedures of pressure transmitters were found to be inaccurate due to miscalculation of the transmitter head factor. The miscalculation was the result of using head height of the transmitters' designed location, but not the specific as-built transmitter location.

All procedures which calibrate pressure transmitters were reviewed and corrected, as necessary, for this problem. The operation of pressure, flow, and level detection devices and their associated trips or alarms outside the allowed tolerances established by Techofezl Specifications is a probable consequence of the inaccurate head correccion problem.

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l SECTIOM 1 11 . Technical Specification Non-Conformity to As-Built Conditions Changes were made to the Technical Specifications to account for as-built plant conditions. The as-built conditions conform to the systems described and analyzed in the FSAR and approved by the NRC in its operating license review. The changes were necessary to correct inadvertent errors in the Tecnnical Specifications when the license was issued rather than to change any physical features of the plant.

The procedures satisfying Technical Specification surveillance requirements have been reviewed by the Surveillance Review Team for compliance with the changes. The procedures have been revised as necessary. The probable consequences of not revising the procedures would have been non-compliance with Technical Specification surveillance requirements.

Table 1 references the amended Technical Specification number, the document containing the Technical Specification change technical evaluation, the number of surveillance procedures affected, and summary of the Technical Specification change.

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SECTION 1 l

e Table 1 .

' Technical, Surveillance

- . Specification AECM Number Procedures Number (Item Number) Affected Summary of the Technical Specification' Change

' Table 2.2.1-1 l83-0314 7 More conservative setpoints per NSSS specifications.

(1)

' Table 32.2.1-1; 83-0356 4 Revised setpoint values more conservative than current values.

.Tcble13.3.4.2-2 (4)

.Tgblef3.3.2-1. 83-0180 1 Addition of valves to listing.

(29)-

Tchle 3.3.2-2: 83-0370 8 Reflects actual conditions rather than nominal conditions.

'(4) >

fTcble 3.3.2-2 83-0338 2 Revision of setpoints per NSSS specification, within bounds of Table:3.3.3-3 . (2&3) previous analysis. ,

-3.3.2-3 83-0180. 1 MSIV isolation not a function of this instrumentation.

(16) ,

, Table 3.3.3-2 0356 2 Revised values more conservative than previous analysis.

-(1)

Tcble 3.3.3 33-0370 11' Revised timer delay to incorporate tolerance, still within bounds of

(5) analysis.

'Tcble 3.3.7.1-1 & 83-0207 1 Provides surveillance for additional radiation monitor installed

' Table 4.3.7.1-1 (11) over approved fuel storage area.  !

Tcble 3.3.7.3-1 & 83-0180 2 Direct Temperature at 162 ft. level not monitored, Differential Tcble-4.3.7.3-1 (30)- Temperature with lower elevation is provided as required parameter.

83-0180 Automatic isolation not a function of noble gas monitor, isolation Tible 3.3.7.12-1 & 2 Tsble 4.3.7.12-l' (19)- provided by ventilation exhaust monitor.

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SECTION 1 Technical- . Surveillance -

Specification AECM Number Procedures Number (Item Number) Affected Summary of the Technical Specification Change 3/4.6.1.3' 83-0314 1 Change reflects that pressure instrumentation is provided for each 3/4.6.2.3 (10) air lock door inflatable seal rather thsn the air lock door seal system air tanks (flasks) .

Tcble 3.7.4-2' 83-0314 2 Added snubbers to surveillance table.

(14)

Tcble 3.7.6.5-1 83-0254 3 Provides proper notation for hose station locations.

(6)

Tcble 3.7.8-1. 83-0207 .1 Lower terperature Ifmits agree with actual qualification temperature-(4) as required by NRC evaluation.

Table 3.8.4.1-1 83-0180 2 Revised the Trip Setpoint for the 6.9 KV circuit breakers to reflect

-(14) the Iceked rotor current rise due to residual voltage. Provides equivalent protection of equipment.

-T1ble 3.8.4.2-l' 83-0180 3 Added valves to surveillance table.

(23)

- 3' . 9 .1 83-0180 1 Deleted fuel grapple and SRM count rate interlocks.

(26) 3.9.1 83-0207 1 No lever arm on vacuum breaker, testing to be conducted by another (6) suitable means.

4.1.3.1.4 83-0370 1 Deletes an individual test that cannot be run separately; test still (10) retained as part of another test.

Table 4.3.3.1-1 83-0314 5 Solid State digital systems allow only testing of overall delay, (5) not individual inputs.

-4.6.1.4 83-0338 1 Original values from purchase specification, revised values from (8) functional test.

4.6.4.4 83-0180 1 Explosive valves not included in TIP system; not required for Mark

-(7) III containment.

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SECTION 1 ~!

Technical- Surveillance Specification AECM Number Procedures Summary of the Technical Specification Change Number- (Item Number) Affected

'4.6.'6.3.D.2 83-0338 1 Reflects a more conservative pressure drop for filter bank.

(9)-

4'.6.6.3.D.3. 83-0314- 1 Change adds " manual initiation" to the list of SGTS actuation ,

.(11) signals and allows verification of test signals by LOGIC SYSTEM

, FUNCTIONAL TEST.

-4.6.7.1 83-0207 1 Deleted since specified system has no piping penetrations through (12) containment: not applicable to GGNS.

4.7.21 83-0207' -2 Deleted since GGNS design is single path system and has no bypass (5) valves. .

.4'.7.2'.D.2- 83-0314- 1 Change adds " manual 'nitiation" to the list of CR emergency (13) filtration system actuation' signals and allows verification of test ,

signals by LOGIC SYSTEM FUNCTIONAL TEST.

4.8.1.1.1 83-0138 3 .Deletec surveillance requirement on a non-existing feature

(12) (automatic transfer to another offsite source).

l4.8.1.1.2 83-0207- 10 Revised to reflect faster Diesel Generator start time; agrees with (9) NRC evaluation.

L4.8 1.1.21.16; :83-0180 3 The word " engine" replaced the. word " generator" such that' item f (22) reads " engine bearing temperature high (11 and 12 only). Item j was appended-to reflect applicability to D/G 13 only. ,

Table 4.8.2.1-1 s 83-0180 '2 'Different battery type, new limits reflect manufacturer's  ;

(15) specifications.

4.8.3.1.1 & 83-180! 1 Voltage instrumentation not present on MCCs/ panels; sufficient 14.8.3.2.1 z(12) . voltage instrumentation present on busses on LCs.

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(25)

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l SECTION 1 Technical Serveillance Specification AECM Number Procedures

! Number (Item Numbcr) Affected Summary of the Technical Specification Change

.3.6.4, 4.6.1.1 83-0449 58 Nomenclature corrections, addition of valves to surveillance tables, Tchles 3.3.2-1, 3.3.2-2 (1) reduction in closure times to agree with accident analysis, 3.3.2-3, 3.6.4-1, and adjustment of closure times to agree with AMSE Section XI testing, 3.6.6.2-1, and 4.3.2.1-1; realignment of valve groups according to 1 solation actuation.

end B3/4.6.4, B3/4.6.6 83-0492 (1) 4.4.7, 83-0492 1 Revised to allow MSIV and any other valves that can be tested in Table 3.6.4-1 (2) other than COLD SHUTDOWN or REFUELING to be tested with the plant hot but before reaching 600 psig.

.Tcble 3.3.3-1, 83-0422 3 Redefines " operability" range for HPCS until first refueling outage 4.3.3.1-1 (15) due to water level instrumentation inaccuracies at low pressure.

Table 3.6.4.1 83-0356 2 Incorporates design change to prevent automatic tripping of RHR (18) jockey pumps; needed to prevent potential damage from waterhammer.

4.4.2.1.2.b, 83-0338 3 Provisions of Technical Specification 4.0.4 suspended to allow plant 4.4.2.2.1.b (7) to attain operating conditions necessary of ADS trip system Table 3.3.3-1 curveillance testing (one time Technical Specification exception).

4.1.3.1.'4.a 83-0422 1 Provisions of Technical Specification 4.0.4 suspended to allow plant (13) to attain operating conditions necessary for scram discharge volume surveillance testing (one time Technical Specification exception).

Tcble'3.3.2-1 83-0356 12 Redefinition of instrumentation system configuration.

Tcble 3.3.3-1 (16).

Table 3.3.7.1-1 83-0356 0 Increases the number of minfrum operable channels.

(10) 3.4.2.1 83-0314 2 Change revises the drift allowance for the relief valve function of (8) the safety / relief valves to coincide with the design specification of these valves.

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SECTION 1 Technical Surveillance Specification AECM Number Procedures Number (Item Number) Affected Summary of the Technical Specification Change 3.4.2.2 83-0314 2 Change revises the drift allowance for the relief valve function of (9) the safety / relief valves to coincide with the design specification of these valves.

3.7.6.2 83-0422 3 Additional spray / sprinkler system for surveillance.

4.7.6.2 (8) 83-0422 Can verify positio  ; release levers but not valves. Redefinition 3.7.6.4 4 f 4.7.6.3 (3) of actuation and system operability surveillance.

4.7.6.4 83-0370 Addition of circuit breakers for surveillance; revision of Table 3.8.4.1-1 2 (7) nomenclature.

4.1.3.2.B 83-0356 1 Allows entry into operational mode to test after maintenance or (9) modificatione.

4.3.7.5-1 83-0422 1 Increases surveillance frequency for hydrogen analyzers.

(12) 4.5.1.3 83-0370 5 Reflects test line pressure requirements to conform to ASME (8) Section XI.

4.6.6.1.B.2 83-0370 1 Increase in pressure requirement.

(11) 4.6.6.3 83-0449 (Re- 1 Exempts phase balance testing criteria, heater cont.inuity assured by 4.7.2 (3) submittal other elements of testing.

B3/4.6.6 of 83-0422 B3/4.7.2 Item 14, 83-0356 Item 2) i 4.6.6.3.D.3 83-0314 3 Redefinition of functional testing, actual component performance (11) test on same schedule H28sp29

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. Technical -Surveillance Specification AECM Number Procedures Number (Item' Number)- Affected Summary of the Technical Specification Change 4.8.1.1.2 83-0338 3 System load shedding revised to agree with FSAR.

-(13) 4.8.1.1.2 83-0422 3 Reflects rated load of diesel generators.

(10)

- 4. 8.1' .12.D . 2 ' 83-0422 3 Revision due to nomenclature; largest load agrees with component (2) table in FSAR.

4.7.2.D.2' 83-0314 3 Redefinition of functional testing; actual component performance test (13) on same schedule.

Table 3.3.3-1. 83-0422 0 Changes make the Technical Specifications consistent with plant Table 4.3.3.1-1 (15) design. Further, they clarify that the required functions of the Base' Figure.3/4.3-1 HPCS initiation instrun;entation do not always include injection and that false indications of reactor water level due to instrumentation design and calibration requirements do not affect the safe operation of the plant. Changes to tables applicable until restart following the first refueling outage. Change to base figure is a permanent

change.

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SECTION 1 I

1. Technical Specification Inconsistency I Several modifications were made to Technical Specifications to maintain internal consistency within the Technical Specifications. None of the changes involved a significant relaxation of the criteria used to o establish safety limits or the bases for limiting safety system settings I or limiting conditions for operation.

These administrative changes affected several surveillance procedures that the Surveillance Review Team revised as necessary to reflect the amended Technical Specification.

The consequence of not revising Technical Specifications and procedures would be the potential misinterpretation of surveillance requirements.

T ' '. 2 references the amended Technical Specifications, the document co.c.:_1ning the technical evaluation of the change and the number of procedures affected.

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SECTION 1 ,

Table 2 Technical Specification AECM Surveillance .

Section Number Procedures Affected 3.2.2 83-0338 1 Table 3.3.2-2 83-0180 2 Table 3.3.6.2 & 83-G180 1 Section 4.1.4.2 3.7.1.3, 4.7.1.3 83-0314 2 3.8.1.1 83-0356 .2 Table 4.3.3.1-1 83-0370 9 Table 4.3.3.1-1 83-0180 6 Table 4.3.6.1-1 83-0180 2 Table 4.3.6.1-1 83-0180 4 Table 4.3.7.12-1 83-0207 3 4.5.3.1, 4.6.3.1 83-0370 4 4.7.7.2 83-0422 (Resubmittal of 83-0314 Item 15) 3 4.8.4.3 83-0422 1 Table 4.3.7.5-1 83-0422 2 3.1.3.1 83-0422 0 Ta~ ole 3.3.4.2-1 83-0207 4 H26sp11 L j

SECTION 1 J. Technical Specification Editorial dr Nomenclature Errors Several modifications were made to. Technical Specifications which were administrative in nature and were necessary to correct editorial and nomenclature ectors. None of these changes involved a significant relaxation of the criteria used to establish sefety licits or the bases for limiting safety system settings or limiting conditions for operation.

The consequences of not revising Technical Specifications would have been the possible misinterpretation of Technical Specification requirements.

Table 3 references the amended Technical Specification and the document containing the technical evaluation of the change.

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. l SECTION 1 Table 3 Technical Specificatien AECM Section Number AECM Item Number Table 3.3.2-1 83-0180 6 i 4.4.6.1.3 83-0207 3 4.8.1.1.2.d 9 83-0207 13 I

6.5.2.8 83-0207 22 3.7.5 83-0254 1 Table 3.3.2-1 83-0314 3 Table 3.3.3-3 83-0314 4 Table 3.3.7.1-1 83-0314 6 Table 4.3.7.12-2 83-0314 7

! Table 3.3.7.1-1 83-0338 5

, 4.6.7.3 83-0338 10 ,

i 3.11.1.1 83-0338 15 i

3.11.1.2 83-0338 15 3.11.2.2 83-0338 15 i

3.11.2.3 83-0338 15 3.7.10; 4'.7.10 83-0370 2 and 3

83-0565 3 Table 3.6.4-1 83-0183 1

( Table 3.6.4-1 83-0180 2 I

Table 3.3.3-2 83-0180 -5 j

< Table 3.6.4-1 83-0180 9 3.1.3.2.B' 83-0180 10

,i Table 4.3.7.11-1 :83-0180 111

- Table 1.1 83-0180 1 71

, Table 3.6.6.2-1 83-0180' 18:

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SECTION 1 I l

i Technical Specification AECM Section Number AECM Item Number Table 3.3.7.1-1 83-0180 21 Table 3.3.7.5-1 83-0180 24 Table 3.3.2-1 83-0180 27 I

Table 3.3.2-2 83-0180 27 Table 3.3.2-3 83-0180 27 4

Table 4.3.2.1-1 83-0180 27 Table 3.3.7.2-1 83-0180 32 Table 4.3.7.2-1 83-0180 32 3.11.1.3 83-0180 34 6.9.1.12.K 83-0207 i Table 4.3.1.1-1 83-0207 2 rable 3.3.3-2 83-0207 7 Table 3.3.2-3 83 0207 10 5

Table 4.3.7.11.1 83-0207 17 3.5.1 83-0207' 10 4.7.4 83-0207 21 4.7.5.3 83-0254 2 3.3.2; 3.6.6.1; 3.6.6.2; 83-0314 2 3.6.6.3;-3.7.1.1.3; 3.7.2; 3.8.1.2; 3.8.2.2; 3.8.3.2; Table 3,3.2-1; 3.3.7.1-1; 4.3.2.1-1; 4.3.7.1 '

' Table 3.3.7.9-1 83-0411 1 2

and i 83-0565. 1

-Table 4.3.1.1-1 83-0422 1 Table 3.7.6.6-1 83-0422 '4 j 3.3.7.9;. Table 3.7.8 83-0422 5 6.9.1.5; 6.9.1.12 83-0565 17 6.5.2.2. ,83-422' 9-H28sp14

SECTION 1 K. Proposed Technical Specification Changes

. Due to the large number of Technical Specification changes required, the changes were prioritized, based upon the operational mode requirements l necessary to achieve criticality, power ascension, and commercial

, operation. Some proposed changes have been received as Technical Specification Amendments 7, 8, 9, 10, and 11 while others are undergoing NRC review or being prepared by MP&L for NRC submittal. Table 4 provides a list of Technical Specifications yet-to-be amended and the document containing the technical evaluation of the change.

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SECTION 1 Table 4 J

Proposed changes to Technical Specifications Technical AECM Number

! Specification (Item Number) Summary

, 3.3.2-1.2.E 83-0356 Resolves Technical Specification j 4.3.2.1-1.2.E ( 8) conflict to perform required Condenser l

Vacuum Surveillance.

4 Table 3.3.7.9-1 83-G253 Deletion of some smoke detectors.

( 8) 3.4.2.1 83-0373 Ref12 cts a design change to SRV

( 1) low-low set logic.

Table 3.6.4-1 83-0356 To support implementation of a design (18) change package needed to correct a design deficiency.

Table 3.6.4-1 83-0449 Makes basis for maximum valve

( 2) isolation times consistent; conply (Partial sub- with ASME Section XI requirements.

mittal of 83-0373,

Item 4) 3.7.6.4 83-0254 Revision to conform with as-built CGNS 4.7.6.4 ( 5) design.

4.7.6.3.1 4.7.6.3.2.B.1 3.9.2.C 83-0207 Redefinition of applicability 4 (19) requirements.

I 4.3.7.5-1 83-0356 Alternate method for calibration of (13) containment /drywell area radiation

monitors.

4.3.7.5-1~ 83-0356 Increases calibration frequency.

i (14) 4.5.1.C.2.B 83-0356 Maintain consistency between Technical (11)- Specifications and system design specifications.

4.5.1.C.A.2.A 83-0356 ' Correction to LCPI A & B low pressure

-(15) .setpoints to reflect plant. design.

4.7.6.1.1.E.1 83-0254 Deletion of requirement'not applicable

( 3). .to CGNS design.

4.7.6.1.3.A. 83-0254 Provide consistency between GGNS

-( 4) . Technical Specifications and Standard j Technical Specifications of NUREG-0123.

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SECTION 1 Technical AECM Number Specification (ltem Number) Summary 4.8.1.1.2.A.5 83-0356 Modification of requirements to better 4.8.1.1.2.D.9 ( 5) represent actual plant design and to comply with the it. tent of Regulatory Guide 1.108.

4.8.1.1.2.D.2 83-0?07 Maintain consistency with the largest (15) single load that can be applied to ESF busses during planned testing of the diesel-generators.

6.5.2 83-0180 Change the Advisor to Vice-President Nuclear Operations from a non-voting member to a voting member of the SPC.

6.5.2.10 83-0180 Maintain consistency with Operational Quality Assurance Manual regarding audits of SRC written reports.

4.8.2.1.D.2.B 83-0356 Revision of Division 2 125 Volt D.C.

( 6) battery load profile to reflect as-built plant conditions and a planned change in the Division 2 inverter.

4.3.4.2.3 L3-0356 Corrects the specification and bases B 3/4.3-3 ( 7) to accurately reflect the breaker are suppression requirement. The basis change clarifies the definition of the EOC-RPT system response time.

3.7.6.2 83-0338 Addition of spray / sprinkler system 4.7.6.2.C (11) surveillance requirements; deletion of visual inspecions of pre-action sprinklers.

4.4.2.1.2.B 83-0338 Allows entry into Operational j 4.4.2.2.1.B ( 7) Condition 2 without performing the l Table 3.3.3-1 valve opening part of the LOGlC SYSTEM FUNCTIONAL TEST.

4.8.4.3.B 83-0314 Revision of setpoint tolerances to I (16) agree with equipment design specifications.

4.9.6 83-0314 To incorporate additional plant (17) features not covered by Technical Spectrications.

6.5.2.2 83-0338 Reflect change in MP&L corporate (14) structure.

3.3.1 83-0565 Conformance of Technical (18) Specifications with the Standard Technical Specifications.

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SECTION 1 Technical AECM Number Specification (Item Number) Summary 3.1.3.2 83-0565 Redefinition of Technical (32) Specification applicability requirements.

Table 3.3.3-2 83-0565 Revision of setpoints per NSSS (24) specifications, within bounds of previous analysis.

Table 3.3.2-3 83-0565 Pipe break detection circuitry (10) modification for compliance with generic letter 83-02.

3.3.3 83-0565 Utilization of the most limiting LPCI

( 6) response time to maintain consistency with FSAR.

3.3.3.2 83-0565 Revision of reference evaluation of 3.3.5-2 (21) suppression pool level instrumentation to maintain consistency with plant design.

3.3.6-1 83-0565 Redefinition of operational condition 4.3.6-1 (13) applicability requirement.

3/4.3.7.1 83-0565 Inclusion of data inadvertently Table 3.3.7.1-1 ( 5) omitted by the NRC in Amendment 7.

3.4.1.4 83-0565 Redefinition of requirement

( 4) applicability.

3.6.2.5 83-0565 Reflects incorporation of one of the B3/4.6-3 (22) Humphrey concerns into plant design.

3.7.1.1 83-0565 Revised to reference all applicable 4.7.1.1 ( 9) operational conditions.

Table 3.7.6.5-1 83-0565 Addition of fire hose stations to (23) list.

Table 3.7.8-1 83-0565 Change of temperature limits and (33) changes to conform to Standard Tec,hnical Specifications.

Table 4.3.3.1-1 83-0565 Addition of surveillance requirement (28) inadvertently omitted from Technical Specifications.

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SECTION 1 Technical AECM Number Specification (Item Number) Summary ,

4.3.7.6.C 83-0565 Change SRM minimum count rate Table 3.3.6-2 ( 1) setpoints to prevent replacement of-neutron source; within bounds of G.E.

1 Rod Drop Analysis re-analysis.

Table 4.3.7.12-1 83-0565 Deletes surveillance requirements of (19) non-existent alarms or trip functions of certain f3ow rate monitors.

Figure 6.2.2-1 83-0565 Change to Unit Organization Chart for (55) more effective utilization of 1 personnel resources.

6.5.1.2 83-0565 Expansion of PSRC membership.

(20)

Table 3.3.8-1 Uaassigned Note (d) does not apply to as-built.

(Not yet submitted) i Table 3.3.8-1 Unassigned Minimum operable channels listed are (Not yet too few.

submitted)

Table 3.3.5-1 83-0642 Minimum operable channel should be

( 1) four for low-low level.

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,9ECTION 1 Proposed Technical Specifications changes to correct editorial and nomenclature errors.

i AECM Uumber Technical Specification (Item Number)

, Table 3.3.1-1 83/0565 (27) 3.3.2 83/0565 Table 3.3.2-2 (16) 3.3.3 83/0565 Table 3.3.3-1 (7)

Table 3.3.7.1-1 83/0565

Table 4.3.7.1-1 (2) (Resubmittal of AECM-Table 3.3.7.12-1 83/0370, Item 6)

, Table 3.4.3.2-1 83/0565 Table 3.4.3.2-2 (8)

E3/4.6.1.7 83/0565 i

(14) 4.5.3.1 83/0565 3.6.3.1 (15) .

B3/4.6.3 1

! 3/4.6.7 83/0565 '

(12)

Table 3.7.4-2 83/0565 (31) i 3.8.1.2 83/0565 (11) ,

Table 3.8.4.2 83/0565~

(25) 4.8.1.1.2.D.9 83/0565 (26)-

5.1.3 83/0565

Figure 5.1.1-1 (29)

. Figure 5.1.3-1 .

! 6.10.2 83/0565 (30)

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SECTION 1 i

AECM Number i Technical Specification (Item Number)

Table 3.7.6.6-1 83/0422 (Resubmittal of 4 (4) AECM-83/0254, Item 7) j 4.8.4.2.1.A 83/0356 (12) 4.3.4.2.3 83/0356 (Not a Technical

l. B3/4.3.3 (7) Specification Change - one time i exemption to the operating license)

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SECTION 2 Corrective Action The following describes the corrective actions used to ensure that all Technical Specifications and Surveillance Procedures are technically adequate; and the program established to effectively incorporate, control and implement regulatory requirements:

1. A Surveillance Review Team, headed by the Technical Engineering Supervisor, was established to review / rewrite all existing and new surveillance procedures to ensure technical adequacy and compliar.ce to GGNS Technical Specifications and 10CFR50 - Appendix J. A preliminary review of compliance with ASME Section XI regulations, which are not required until commercial operation, was conducted.

2. A standard criteria checklist was developed to serve as a review guideline and method of review documentation.

3. A surveillance punchlist was established and maintained to identify and track discrepancies internally within the Surveillance Team. This included all procedural problems, needed Technical Specification changes, and programmatic problems encountered by the Surveillance Review Team.

4. The Integrated Operating Instructica and Operating Logn were reviewed by the Surveillance Review Team to ensure that the surveillance requirements associated with operational mode changes are adequately incorporated.

5. Revision 6 of 01-S-06-12. "GCNS Surveillance Program Administrative Procedure" was written to ensure prompt incorporation of Technical Specification changes into applicable surveillcnce procedures.

6. Revision 0, 09-S-05-7, "GGNS Technical Specifications / Surveillance Program Master Cross-Index" was developed and issued to aid plant personnel in the use of Technical Specifications and Surveillance Procedures.

7. A cross-reference index of surveillance procedure requirements to operational mode requirements was developed to aid plant personnel in the use of Technical Specifications and Surveillance Procedures.

8. The computerized surveillance scheduling program was reviewed by the Surveillance Review Team to ensure procedures are scheduled in accordance with Technical Specification requirements. This presently is an effective program, however, the Review Team is looKing at other methods ,

to further enhance the program. l l

9. Section Level Procedure Philosophy Statements and Technical Specification l Position Statements are being prepared as necessary to document the clarificatien of specific procedures and technical specification requirements as an gid to plant personnel.

10 To satisfy the requirements of the Logic System Functional Tests per Technical Specification Definition 1.22, the following overall test philosophy was developed by the Surveillance Review Team:

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, 'o i SECTIOH 2 Instrument calibration prccedures are used to accomplish testing from the sensor to a convenient overlap point in the logic. A functional test then overlaps with the calibration procedure and verifies the logie and the required action of the actuated device. l

11. Instead of retesting equipment tested in another procedure tc obtain an equipment response time from which a system response time could be calculated, the following approach was developed to satisfy system response time testing per Technical Specification Definitions 1.12, 1.13, 1.19, and 1.34:

4 Systen Response Time Test procedures were revised to reference the procedure and step to which equipment response times were tested.

This data is collated to produce a series of sequential, overlapping or total steps such that the entire system response time is measured.

12. Applicable Plant Quality Deficiency Reports, Material Ncn-Conformance Reports and Quality Assurance Corrective Action Requests concerning the Surveillance Program were reviewed and corrective actions were coordinated witn MP&L QA and Plant Quality.

13. The " Grand Gulf Nuclear Station Operations Enhancement Program", was established to improve the short and long-term safety, reliability, and operating effectiveness of the Grand Gulf Nuclear Station. More specific goals include:

Improve management controls necessary for safe and reliable j operations.

Increase the proficiency and quality of licensed personnel.

Emphasize procedure awareness and regulatory concern.

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l Establish efforts to improve the utilization / effectiveness of management and licensed operating personnel.

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