IA-85-187, Partially Withheld Anonymous Allegation Re Proposed Enforcement Action - Grand Gulf Nuclear Station
| ML20212C040 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/15/1985 |
| From: | Bowers H, Mark Resner, Sicilia P NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | |
| Shared Package | |
| ML20212B780 | List: |
| References | |
| FOIA-85-187 NUDOCS 8703030693 | |
| Download: ML20212C040 (96) | |
Text
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R PORT OP I :: 0U IRY TITLE: ANONYMOUS ALLEGATION REGARDING PROPOSED ENFORCEMENT ACTION - GRAND Gl" P NUCLEAR STATION
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PREPARED BY: Mark E. Reanch . 4t i[ [,,,eUATE: / /5 75 Inventigator Offico of Innpo' tor and Auditor Potor Sicilia Jr.'
Auditor E
/'/f 7'[C Offico of Inspector and ,
Auditor ,4 .(g APPROVED BY:llollin nowers, Actin 9 D ATE: ,/.'ef'. d' y* V" Annintant Director for
- Invon*igationn Offico of Innpoctor and Auditor Sharon R. Connolly, Director C! MA' +
Offico of Inapoctor and Auditor OFFICE OF INSPECTOR D AUDITOR
' U.S. NUCLEAR REGULATORY COMMISSION informallon la lhlt record wt deleted la AOCord.ince wil'l it I frrt *)m of Inform Aci,tAemlions.IlA_}f,],k l f0!Ad 2 0., _
FHCCDOM OF INFOHMATION/PHIVACY ACT EXEMPTION ,..,.gg) gy) g33
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O,OaOnoma n OFFICIAL USE ONI.Y l l'Ott i UI A CUNN I NC U,U ~ I UI PUN '
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l EACKGROUND On November 16,1984, the Office of Inspector and toditor (0!A), received a ;
.erorandun ' rom hunzio J. Pa11adir.o. Chainnan, U.S. Nuclear Reculatory Commis- !
sien (NRC), dated November 15, 1984, which directed OIA to conduct an inouiry into an aronymou' handwritten 711enetion relatirg to staf' r" duct (Attachment 1). More specifically, atteched to that nemorandun was a j handwritten, unstered letter dated November 13, 1984, addressed to Chairman Palladino. The anonymous letter cited a proposed enforcement action by MRC, l
as described in SECY P4-419 (Preposed Enforcerent Action (EA-84-75) for Mississippi Power and 9egardino Technical Light Company),(Grard Specificatiors and elleged thatGulf) theFor Material pro;nser' civilFelse State penalty "...was carefully planned to cover up the disgraceful performance of NRR where the real blane lies." Furthermore, it was stated in the anonynous letter, "This is the most flagrant violation cf ehics in government that I have ever seen."
Subsecuent to a review and analysis of the pertirent information available to 4 01A, an inquiry into this matter bepen on Decerber 14,1984. I f0PMARY Jane A. Axelrad, Of rector, Enforcerent Staff, Office cf Inspection and Enforcercet (IE), when interviewed, said that en July 17, 1984, Darrell G. l Eisenhut. Director, Division of Licensing Office of Nuclear Reactor I
? Regulation (NRR), sent a memorardum to her recardf ro the Technical Specifica-
, tions (Tech Specs) for Grand Gulf Nuclear Station (GGh5) recorrending that a possible enforcerent action be pursued against Mississippi Power and Light (HPt.L) fnr Material False Statements in connection with errors in their Tech a Specs. Axelrad said that based on that nemorandun, she was fure that the prnposed enforcement ection against MP&L regardino Tech Specs was initieted by NRR. Axelred said that as a result of that me-orardun, she directed Paul R.
Parron, forrerly a Senior Enforcenent Specialist on her staff, to meet with Elinor G. Adensam, Chief Licensing Cranch #4. Division of Licensino. NRR, and collect information relating to the errors in the Tech Specs which NRR believed indicated that material false statements were made. NRR provided Aneirad with a list of ten itens they believed to indicate that material false statements were made. Axelrad said that she reviewed NRR's basis (the marked 4, up Tech Specs) for their findings concerning material false statements, and because tie Tech Specs were so narked up, she could not decipher if the errors in the Tech Specs were made by the applicant or by NRR staff. Based on l
, Axelrad's review and analysis of those Tech Specs, she gleaned four items I which became the basis for SECY 84 305 (Prelimirary Views on Proposed Civil eenalt Gulf))y Action
. Axelrad (EA 84-75) described for84-305 SECY Mississippi Power and as a preliminary SECYLight paper.Company (Grand
'n retrospect, Axelrad stated there was little time between when she received the July 17,1984, Eiserhut memorandun and a scheduled July 76,1984, Comis-slon meetina re In order to a'idress I hP.R's July 17, garding the operating license for GGNS.1984, recorrendation l Comission meeting on July 26, 1984, a fast turn around was required and that l l
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\ ;m 4r. why a prelimirery SECY paper was prepared. in addition to the tire con-st-aints, there was ne trail as te wFn in f RR dic whet with respect to licens. I ino reviews of GGNS Tech Specs. ' Axelrad said that because of that, it was '
oifficult to determine if hRR or the applicant had errored. Axelrad noted M that NRR initiated the enforcenent action.because they believed the applicant had rade naterial false statements, however, in her cpinion NRR helieved too any iterrs were natorial false statenents. '
3 avalrrd said that ir cerverta+ir es with RicFa* d C. PeYcurg, Director, IE, Fe tedicated that it is the licensee's responsibility to ensure the accuracy of :
the Tech Specs end, theref ore, PPAL sbruld be cited for the vich. tion and a civil peralty should be levied. Axelra'd said that DeYoung's decision to cite the applicant and levy a civil penalty was not based on any rule er raculaticn '
ty as much as it was based on his many years of experience with the Agency in NRR
and IE. Axelrad indicated that DeYoung telieves the Tech Specs are the ;
licensee's and, therefore, they are the responsible party' that should be fined the naximun amount of $500,000. DeYeuno is upset that-NRR staff appears to have also centributed to the errors in the GGNS Tech Specs and no one in NRR
- } is being held responsible for the errors. However, the fac+ that NRR contributed to the problem does not relieve the applicant of their restcosibility or r.eoate the civil penaltv.
I Axelrad stated that there is "no chance tha+ f:0R trinnered the civil penaltv t to take the respersibility off of NRR." Axelrad believes just the opposite'is true in that supporting the civil penalty "has put the spotlight on NRR and i
the nicroscore on NRR's licensing process."
4: ' Axelrad recalled a neeting that included Edsen G. Case, Deputy Director, NRR, DeYoung, James P. O'Reilly, P ional Administrator R ion 11 and herself .
wheroin Case ir.dicated tha xelrad sai se-ouent to that meeting, civ penalty of $500,000 was sent
!'- 'orward by her office, but was hel EDO) level for a period of the Executive Director for rations -
l, N Attachment .
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en interVi said that s-64 as a n that capacit as involved at.the inception of IE s oftert concerning i
d enforcement action against MPAl. for errors-in the GGkS Tech Specs, said that IE had learned from Region !! that there were discrepancies nt ~GGNS Tech Specs. in anticipation of a Commission meeting, relative to the licensing of GGNS, to be held in Aucust c 1984, and in consideration of the information learned from Region 11, DeYoung '
e and Axelrad wanted to be prepared for an uestions concerning possible enforcement natters at GGNS. Therefore, was directed by Axelrad to obtain from Region 11 and NRR inforna ion ut the discrepancies in the Tech Specs. Towards tha Division of 1.icensing. and Axelrad met with Eisenhut, Director,
.c m called that Eisenhut presented no ideas, pro i
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re cen, to ther at that time with respect te e nossible erforcer'd action in this natter. Eisenhut simply identified t.RR staff who had beer irvolved with the Tech Specs and acreed to make them availab!e for as'.istance to IE in this.
natter.
When poke
' 7p they indicated to rembers of the NRR staff irvolved with the T9ch Specs, that they wented the Enforcement Staff to ta a cau-tious approach to ny enforcement action, said that it ras opinion these irdivideels were nct st.re if tha epr?icant~was resennsih n # he errors in the Tech Specs or if NP.R was responsible. To newledge,
- $P ranagenent rever expressed an opinien about responsi lity fcr th erro s in the Tech Specs beino attributed to the licensee or the NRC staff, said that generally believes the approach by NPC in ratte of this rature -
has been itinately hold the licensee responsible, said that DeYoung initiated the proposed enforcerert action conc ning the crrors in the Tech Specs and r.aintained a prs ' e that the licensee is responsible for the accuracy of submittals to NRC.
said IE believed it was not uncommon to see discrepancies in the Tech Specs but nre of the si9nificant issues concerning GGNS was the degree or nu,mber of errors.
. During eview of this natter, it becare clear to
- paper thil erning th [h'atthe rrors in the Tech Specs was almost irrpossible to said that follow, by whom, han was unable, in mest instances, tn trace when, and to the rious Tech , Spec submittals were made. Farron noted
' that during his review, looked at Tech Spec submittals from 981 fo tard to tbc point in tire when was licensed. In doire se, it was, cbservation that certain Tech e were accura e in all of the subnittals, _
except the final submittal. said that had happened (Attachment 3).
could not detemine why this ,
Darrell G. Eiserhut, Directcr Divisien of Licensing, NRR, when interviewed, said that licensing review responsibilities for the Tech Specs was transferred f rom the Division of Safety Technolooy, NRR, to Division of Licensino in the i
1980 through 1982 tireframe. Prior to the transfer, the Licensing Guidance Brecch, Division of Safety Technology, was the review group primarily responsible for the Tech Spec reviews. After the transfer, the Safety Assessment Group, Divisinn cf Licensing, assumed the respnnsibility for the Tech Spec reviews. Eisenhut said that the Licensing Guidance Branch lacked-formality in the Tech Spec review process. Decisions were made based on telephone discussions and were followed up with buck slip memcranda. Eisenhut indicated that too often NRC cnd applicants' msnagers were not aware of .
decisions made due to the lack of formality in the process. Eisenhut said to strengthen the review process, it was transferred to Division of Licensing.
Eisenhut said that Donald S. Brinkman, Section leader, Technical Specifications Review Group, Division of Licensing, NRR, fomerly with the Licensino Guidance Branch, Division of Safety Technology, NRR, was the person within th inq Guidance Branch in charge of t Recent reviews.
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isenhut said that since the GGNS issue surfaced, E ard . a-
. has been named the group leader f,or the Technical Sepcifications
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r/{ when interviewed, said that in October 1981, he was pr Technical Specificatio e (petion Leader and at that tine were being prepared by 'of his. staff, GGNS Tech Soecs preparino the GGNS Tec had been
.bjCaFie pecs since early1980. Brinkman air' tha when he s wor supervisor, he did not CocCUCt a review er analysis Cf -
'peciessio to date because he considered said that d relied on Bottinore's perfomance in t s oratter, be a cor:petent did not conduct a thorough, in-depth review of inknan ' '
work through the oletion o be GG Tech Specs which were issu June 16,1982. Brinkran told by NR the Safety Evaluation Report to double check the Tech Specs against ,
{Evaluatire.ad Report were also idertified in the Terb Soecs.emure that all iters ide been working extensively on Boiling Water Rea'ctor (BWR) Tech Prinkman noted that pecs on expert during the BWRthe preceding Tech Specs. six or seven years and was recognized es the NRC r
n inknan seid that on Jaruarv 5,1982, MP&L was provided with a proof and review version of the Tech Specs for GGNS.
Brinkran said he did not recall proof and review version was transnitted tE MPAL, but suspects without cover personally letter.9 ave it to them infomally or trensmitted it informally
- fC practice in NRR Specs to the applicant. to formally Brinkman noted that at that time, it was not comon transrit the proof arc review version of the Tech n' t Brinkman believed that he conducted a cursory review roof and review version of the Tech Soecs and provided his comments to rade man knows in retrospect that there were a number of chances receive o the proof and review versien based on rnrrents from for GGNS, the we various technical review branches, the Resident I ector boien II staff, and the applicent, but those, naes unusual or unioue in number. The ments were reviewed by e not believed to have been resolved by nd nif t problent. with the Tec pecs Brinkman does 7 tot reca any or other NRC staff. oc brought to his attention by
~ changes the proof and review version were addressing.the pr timeframe and not events subsecuert to licensing on June 16, 1982 After Tech cs ceived the coments on the proof and review version of the
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$then prepared a final version of GGNS Tech Specs for Director, Division of Licensing, NRR, for Novak's use in issuiversio operating license.
The transmittal memorandum was prepared by .
! Investigator's Note:
he no longer functions in that capacity.Although Brinkman's title on rec;
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cencurred Branch, ardinsigned by Brinknar by ard Donald Skovholt, iber Chie', Licensino Guidance Frank Schroeder, then Assistant Director for Generic Projects, Division cf Safety Technolooy, NRP, before it we? fomarded to Novak.
Brinkran caid that it was the practice of Skovholt and Schroeder not to redaw the Tech Specs and he suspects they received the transmittal memo-reindun withcut the attacted Tech Specs. Brinknar noted that the Tecn Scecs were issued by NRC on Jure 16, 198?, as Appendix A to the ncerating literse .
for GGNS without any questions or crncerns expressed to the Standard Technical Specificctiers Secticn from NRC erff nr tha ecclicant's rta#f.
Brir:Frar, said that tha Standard Technical Srecifications Sectice vas responsible for preparing the Tech Specs and providing them to the Project -
Manacer at the time of licensino. As a matter of practice the licensinn Project Manager did not become involved in the preparation of the Tech Specs, but rather directed the Standard Technical Srecifications Section to prepare the Tech Specs. Subsecuent to the licensing of CGNS, the respersibility for.
the Tech Specs was transferred to the Project Fenager, and the Project Mananer
-typically assuned responsibility for the Tech Specs after the olant licensed. However, in the instance of GGNS, the Stardard Tectnical had been Specifiretions Section was dimcted by Eiser. hut, and possibly Denton, to essist the Project Manaccr in correctino the GC-PS Tech Specs.
to the Project Manager was provided durin This assis*ance
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% tinef rame. Brinkman noted that August 1983 through the July 1984 etired March 31, 1983.
Brinkman said that on December 13, 1983, then Comissioner Gilinsky wrote a renorandon in the Tech Specs tn theforED0 GGNS.inquiring about the numercus errors (approximately 2001 NRR ther prepared a response to Commissioner Gilinsky.
% Brinkman noted that a former NPC employee, crepared a draf t resfsonse mercrandum or the E00's signature. Ecwever, earlier drafts of this .
memorandun stated the responsibility for the errors in the GGNS Tech Specs I
were shared discarded by both and by Brickman the NRC staf and the applicant. The earlier draf ts were Cecil 0. Thomas, Chief S ndard because they had received them back fron of Licensing, with instruct.io,hs to make changes.ation and Special Projects B ,
Thomas told Brinkman that he h.. ,eA should tt incorporate the-changes which had been narked en the drafts to show 1
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the best of Brinkman's recollection, Brinkman recognized the l changes mar ed on the draf t menoranda tr he in the handwriting of Frank Miraglia, then Assistant Director for Safety Assessment, Division of Licensing, or believes Thomas may have told him the changes were desired by Miraglia. Along with the changing of the draft memoranda, Brinkman had wmereus discussions with Thomas regarding the sharina of responsibility by 4
MP&L and NRC, and in general, the procedures used by NRC for preparing Tech Specs. Brintran told Thomas that he believed the NRC staff had to share the responsibility for the errors in the Tech Specs and that the NRC staff is
, respcrsible for the accuracy of the Tech Specs issued by NRC in accordance with 10 CFR 50.36.
Brinkman said that he did not focus on the regulation per se, but emphasized to Thomas that NRC should ensure the accuracy of the Tech Specs because NRC issues them as an NRC document (the operating license).
Brinkman said that Thomas did not respond to him at that time. A couple of months subsequent to their discussions about the conte,nts of the draft - -
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. ororanda, Thems esnet' sad the belie' +n Prickran aed others that the apolici.nt bore the re'.pensibility and not NP.C.
1.'ith respect to disrosition of the response to Corrissioner Gilinsky'e Decenber 13. 1983, inquiry, Brinkman said that a draft nemorandum was provided to Comissierer Gilinsky by the Plarnirg and Prograr Analysis Staff, NRP, bef ore finalization of the memorardun. Brinkman said that Thomas told him that information. A couple " -
of days later Brinkman was told by Thnnas to
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' henas told Br rdnen that +.bese instruC'jons carie _ rcn 'ourth floor
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(meaning Denton's staff). Therefore, another memorandum was. prepared and '
forwarded after the detailed inforration had been edited. Brinknan said that three or four oays later he was told by Thomas nemorandum .
t which inclu he tailed _infomation that -
- 1 Brinkman said that Thomas to d him Edson . ase '> ~,
reouested that the tails be included in the remorandun.
Brinkman also recalled that Miraglia contacted him (Brinkman) ard told him to include words in the new memorandun to the e he responsibilities f for the GGNS Te e nr a" wero t
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Prinkman said that in March 1984, Congressman Markey wrote a letter to Chair-an Palladino raising the issue of naterial false stater.ents made by MP&L in conrection with the errors in the Tech Specs for GGNS. This letter apparently caused the NRC E Staff to review the GCN ch Spec problem.
Brinkman said Thonas and hi hen met with Cecil 0. -U if to reouest them to review the app cant's. original submittal e
of the marked up General Electric Standard Technical Specifications sible naterial false statenents centained therein. A few days later, 9C.- sked Brinkman and Thomas to find approximately six examples of itens in the original Tech Specs subnitted to NRC by MP&L which remained in error in the version of Tech Specs issued on June 16, 1982. The findings were provided to g _ siy in July 1984 in the form of handwritter evaluations of the examples found in the review. Brinkman noted that his feelirgs were, at that time, and sti.11 are, that althouch the GGNS applicant had more errors
' than other applicants, he does not believe that MP&L attempted to deceive the "RC. Brinkman believes that the errors were due to inexperience on the part of MP&L.
! Brinkman said there were discussion in a bu the July 1984 tineframe between Thomas, Adensam, Axelrad, and himself concerning why NRC wanted to pursue an material false n thi matter Brinkman's knowl
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- and send a message to the nuc ear industry *ra ieco necs must be ta e seriously.
Brinkman stated that he bel s some manacers i icensino l (Miraglia and Thomas) want These inanagers believe the licensee is ul tely responsible for Tech Specs and want to
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. cover themselves by pointing the finger at the licensee for the purpose of cetting the message to them that they are responsible for Tech Specs (Attachment 5).
Cecil 0. Thomas, Chief, Standardization and Special Projects Branch, Division of Licensing, NRR, when interviewed, said that in late 1982 he became indirectly involved with the GGNS Tech Specs because of his supervisory capacity with the Standardization and Special Projects Branch. In the later rart of 1983, Thcmas became more closely involved with the GGNS Tech Specs decause of the NRR responses to various inquiries from Congressman Markey and the Commission.
In general, Thomas said that NRR initially provided MP&L with the Standard Technical Specifications for a BWR V Mark II because the Standard Technical Specifications for the BWR VI Mark III had not been developed by NRR at that time. The primary difference between the Mark II and III .is the reactor containment design and the differences are contained in about 10 percent of the areas involved. Thomas said that the fact NRR provided MP&L with a Mark
- I . version of the Standard Technical Specifications as a guide for GGNS was not unusual. This procedure of providing an earlier version of the Standard Technical Specifications had been a standard practice used by NRR if the Standard Technical Specifications for a specific type of plant had not been developed. In retrospect, Thomas noted that GGNS made about 400 changes to the Mark II Standard Technical Specifications, but he believes these changes were all outside the 10 percent area in which there are differences between the Mark II and III Standard Technical Specifications.
Thomas said that NRR should have been more formal with MPAL in providing the modified Tech Specs to them. NRR informally provided tO Tech Specs to MP&L rather than by way of formi correspondence, which would have clearly notified PP&L they were provided with an earlier version that needed to be updated to their Mark III design. Thomas said the informality of the NRC process, and the inexperience with the Tech Specs on the part of MP&L both contributed to errors in the Tech Specs. However, the responsibility to submit accurate Tech Specs is totally the applicant's. Thomas said that NRR, in effect, assists the applicants by conducting a limited review of the Tech Specs submitted in accordance with 10 CFR 50.36. Furthermore, NRC's responsibility is to opull the final licensing package together and the Tech Specs are an integral part of that license package.
Thomas said that prior to the point in time when GGNS began receiving high visibility, he estimates that the overall review of Tech Specs by NRR was less than 50 percent. Additionally, there was ir. sufficient NRR staff to thoroughly review the Tech Specs. Thomas noted that NRR staff dedicated to the Tech Spec review process has recently been increased because of the GGNS problem.
With respect to their proposed enforcement action resulting from the Tech Spec problem at GGNS, Thomas said that its purpose is twofold. It will send a nessage to the NRC staff that Tech Specs are important, and secondly, it will send a message to the " industry" about the importance of Tech Specs.
Thomas recalled a meeting during the spring of 1984 between Axelrad, Brad
. Jones, Regional Attorney, Region II, Brinkman, an attorney frcm the Office of the Executive Legal Director (ELD), possibly another person and e
binself. At trat reatinc, TFomas wae. +cid tha' IE was pursuire the rcssibility cf oateriai false statenents mace by !! PAL concerning the GGilS Tech Specs. NRR was asked tc review all past Tech Spec submitta1 5 by MP,AL for possible naterial false staterents, and FLD was to review the MP&L correspon-dence, which transmitted these submittals to NRC, 'or the purpose of deternin-ino bcw the licersee repraserted the submittals. Thoras said that ha also recalis there was possibly a second meetinc for the purpose of. discussing possible enforcement action in this matter. Thomas noted that he did not receive any guidance ir input fror his sunervisors with respect to an NPF position on the proposed enforcement action. Thomas simply was requested to look fer examples of oossible ncterial false stateren+s.
Regarding a January 13, 1984, nenorandum for Cennissicrer Gilinsky fron William J. Dircks, Executive Director for Operations, concerning GGNS Teca Sners, Thnmas recalled that there were several draf ts written by Donald Hoffman and possibly Brinknan.
Thomas believes the first draf t was provided to Derton ("the fourth floor"' and subsecuently was provided to then Conmissioner Gilinsky as a preliminary response. However, Gilinsky returned the draf t because there was not enough detailed infornation contained in it.
The memorandun was then rewritten to include more details and was finalized on January 13, 1984 In retrospect, Thomas believes there may have bcon a shor.t menorandum from Denton to Gilinsky which transmitted the first draft. The transnittal memorandum probably contained an explenation to the effect that
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the draf t memorandum was only a preliminary response. Thoma recalled s ese changes were only race in an effort to be more respcnsive to Gilinity's inquiry. Thonas vacuely recalls a meeting between Edson Case, Frank Miraglia and himself wherein Case eindicated rrors. to them that NRR staff also had a responsibility for the Tech Spec Case alsn indicated to them that the memorandun should state that in j crder to be more on point in respondirg to Gilinsky. Thomas said there was no effort on the part of NRR te vindicate themselves by shifting the blame or i
responsibility in this ratter to the licensee.
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I M. Dean Houston, Licensing Project Manager, Licensing Branch 42, Divister of Licensing,Project Licensing NRR, when Managerinterviewed, said that in June 1981 he was the primary for the Perr Houston was asked by Albert Schwencer,y Nuclear Power Statien. At that time, then Chief, Licensing Branch #2, S
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Divisien of Licensing, NRR, to assis+ him 7n GGNS. Hcuston said. that his assisterce was required because the fomer Licensing Project Manager for GGNS was reassigned just prior to the due date for the Safety Evaluation Report.
Houston said that in Juiy 1981 Schwencer asked him to concentrate his efforts on processina the GGNS Safety Evaluatier Report because Schwencer "was trying to get .it out" in time for. the scheduled Advisory Comittee on Reactor Safeguards Subconmittee meetirg on GGNS scheduled for August 1981. Houston .
said that he raintained his involvement with the Safety Evaluation Report ""
crocessirs until approxinately August /Septenher 198!. At that time, Pouston reverted back to concentrating on his primary responsibility as the Perry
':uclear Power Station Licensire 'Prcject Manager. In February 1982, Houston was infonned that he would be the Licensing Project Manager for GGNS and the management of Perry Nuclear Power Station would be reassigned to another Licensing Project Manacer. Prior to this point in time, Houston had not officially been assigned as the GGNS Licensing Project Vanager.
Houston said that he did not have any knowledge of NRR or NRC staff positions regarding the responsibility for problems with the Tech Specs for GGNS or how they relate to a proposed enforcement action in this natter. However, Houston noted that in June or July 1984, NRR was asked by Axelrad to review all of the applicant's post-licensing, proposed Tech Spec amendrents to determine if any material false statements were nade. Housten said that NRR had some difficulty defining what constituted a material false statenent; however,'be was told by Adensam "to .iust write down any false statements found and let someone else decide how material they are and what enforcement action should-be taken." Housten said that the list of possible material false statements generated forred "little or ne basis for enforcement action." In this regard, the false statements dealt witF " simple things" and the element of rateriality and degree of falseness was "very marginal" ( Attachment 7).
-~.e
ATTACHMENTS Penorandum for Sharcr R. Connelly from Nunzie J. Palladino, dated November 15, 1982
- 2. Report of Interview - Jane A. Axelrad, January 10, 1985.
- 3. Report of Interview - 1anua ry 11, 1985. -
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4 Report of Interview - Darrell G. Eisenhut, December 31, 1984 5.
Report of Interview - Donald S. Brinkman, January 3,1985.
- 6. Report of Interview - Cecil 0. Thomas, January 9,19P' 5.
- 7. Report of Interview - M. Dean Housten, January 4,1985.
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U.s. NUCLEAR CEGULATORY COMMIS$1EN Ottice et inspector and Auditor o,,,...........
January 11, 1985 l
l Report of Interview I
Jane A. Axelrad, Director, Enforcement Staff, Office of Inspection and Enforcenent (IE), U.S. Nuclear Regulatory Cm-ission (NRC), was interviewed concerr.ing evers in the Technical Specifications (Tech Specs) for Grand Gulf Nuclear Station (GGNS) and the related proposed enforcement action. She provided the following infernation:
On July 17, 1984, Darrell Eisenhut, Diractor, Division of Licensino (DL),
Office of Nuclear Reactor Regulation (NRR), NRC, sent Axelrad a memo stating that a " situation" regardino GGNS Tech Specs was found that " appears to ccr.stitute grounds for a finding that a raterial false staterent (MFS) was '
made by the licensee," and recomending that the issue be pursued for pcssible enforcenent action (Exhibit 1).
Axelrad stated that, based on the July 17, 1984, NRR memo, she "was sure that NRR triggered the whole thinn -- the moverent for enforcement action acainst Grand Gulf -- and had it not been for NRR's initiation," she would not have.
initiated enforcement action against Grard Gulf cr her own. NRR was the stimulus."
Axelrac' explained that with the receipt of Eisenhuts July 17, 1984, memo,' she initiated were na action and looked irto the Grand Gulf situati f MFS ardiro the Grand Gulf Toch Sne She had
~7(
eet wi er NRR contact person, Elinor Chief. Licensing ranc nsan, (LPr4), DL, hRR, and collect information relatino to errors in the Tech Specs which NRR be'4eved tn indicate that MFS were nade.
NRR provided Axelrad with a list of " ten things" which they (NRR) helieved to indicate that MFS were made. These " things", howevar, were based on -
Grand Gulf's marked up Tech Specs.
Axei..u ieviewed NRR's basis (the marked up Tech Specs) and stated that they were so marked up that she (Axelrad) could not decipher if the errors in the Tech Specs were rade by the applicant.when they marked up the Tech Specs, or made by the NRR staff when they reviewed the marked up Tech Specs.
Based on her review and analysis, Axelrad ended up with "four" items. The Enforcenent Staff weeded out all the potential MFS areas contained in NRR's notes and boiled them down to just those areas that contained MFS based solely i on the applicant's notations. These "four things" became the basis for SECY '84-30S - Preliminary Views en Proposed Civil Penalty Action (EA 84-75) For-Mississippi Power and Light Company (Grand Gulf) (Exhibit 2).
j
,_,,,,,,,,,,,, January 10, 1985 ,, Bethesda, Md. i
,,,,, Ing 85-7
- {
,, Peter Sicili .Afark E. Ibsn IA January 11 1
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_ ______ ____._____ ._-_-___- - I
.In retrospect, t.yelrad stated there wae.
i Eiserhut mercrandum and a scheduled Julylittle 26, 1984tire between Comissier the .luly 17, 1984, racetina regardinc the opera;ing license for GGNS.
In order to address NRR's July 17, 1984, reconinerdation for enforcerent action at the scheduled .tuly 26; 1984 ,
i Comission meeting, a fast turn around was required and hence, a prelimicary SECY paper (SECY 84-305) was prepared. Compourdina the ocoblen, there was no
- trail"Specs."
Tech as te "whn in fiRR cid what with retpect to licensinq reviews of GGNS "It was difficult to detennine if NRR or the applicant had errored.". In additirn, she noted ' bat ~NRP ir.itiated the r*'orceront action Decause "they (NRR) were the ones who felt the applicant had made f4FS; however, in her opinion, NR9 be'ieved too rany items were raterial false statements." I I
Axelrad described ratariality as a' stardard and defined material staterent as 4
a statement " capable of influencina a reaserable agency reviawer." Pased on this definition, the. lack cf a paper trail in NRR and the fact that NRR's
) licensina process contributed to the proble , ,
kss
- n discussier uit her boss,
' Richard C. DeYouno. Director. E, however, Axelrad was told by DeYoung that it i is the licensee's recpersibility tn ensure the accuracy c' the Tech Specs and, therefore, MP&L should be cited for the violation ard a civil penalty should be levied. ,
3' .
i Axelrad stated that DeYoung's decision to cite the applicert and' levy a fine
, was not based er any rule or reculation as ruch as it was based en his r.any years IE. eFperience with the agercy and the work he had per' erred in both NRR and DeYoung feels the Tech Specs are the licensee's and, therefore, they are the responsible par +y and should be fined the raximum amcunt of $500,000 DeYouro is upset that !!PR staff (vis-a-vis licensing) ap; ears to have also cor;tributed held respnrsible to the errors for theinerrors.
the GGNS Tech Specs and no one in NRP. is being However, the fact that NpP contributed to the problen the civil penalty. does not relieve the applicant of their resporsibility or negate 15)
Axelrad to take the stated ,that there is responsibility off"no of chance NPR." that NRR triggered the. civil penalty
, In fact, she feels iust the opposite l
is true, in that supporting the civil penalty "has put the spotlight on NRR '
and the microscope on NRR's licensing process." .
Axelrad knows the views of Region II regarding the staff's reconvaendayon for enforcement action against GGNS. She said that she has-received James P.
gg 0'Reilly's (Administrator, Region II) views throQgh J. Michael Puckett, i
vecti iv Coordination Staff
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Investicator's Note: Enclosure 2 to Exhibit 2 contains the "four things," or i
es stated in SECY 84-305, "four specific examplee that appear to be material f alse statements by direct licensee actior." (en:)hasis added) .
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NUCLEAR REGULATORY COMMISSION k...../
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' WASHING TON, O. C. 20555 -
' July 17,1984
- E'40RAN00M FOR:
Jane A. Axelrad, Director Enforcement Staff
, Office of Inspection & Enforcement FROM:
Darrell G. Eisenhut, Director Division of' Licensing Office of Nuclear Reactor Regulation ..
SU3 JECT:
On March 13, 1984, GRAND GULF - MATERIAL FALSE STATEMENT i
responses to certain questions. Representative E. Markey wrot ccrstituting material false statements. Commission's asked the and -reached the following As determination.
a result of that request, we haveo addressed a se statement in the TS -
On December 15, 1980, the licensee submitted a Specifications for General Electric Boiling Watemarkup of the .
stated reflected plant specific design factors
.were transmitted in letters dated r Reactors June 26, (NUREG-0123) and December which 31 February 25, March 23 April 5, 6, 7 and 30 M 10, 1982. Additional submittal's and changes
, , 1981, January 12 On June 16, 1982 Copies ~of the transmittal letters are includeday 26, June 1,
. as Enclosure 2.
Unit I with appen,ded TS.NRC issued a. low power (5%) license to MP errors (see October 20,1982, COA).Those TS were subsequently or Grand Gulf found to trative nature. -
many L
Some of these errors were of an adm Others, however, were instances where the TS did plant.
plant specific design features described in the F and actually built in the
{ to be operable while the actual plant has, 8 valves. the FSAR analyses y and the7 SER required ads valves evaluation considered, and Because these TS were based on information provid d we rely to provide correct reflectioneof plant specifiby the licensee, because known theerrors of the NRCatwould the time, notit have appears issued c design theandlice features, that thinse with incorre s situation constitutes
Contact:
L. Kintner, Npg X27038
,- Exhibit 1
Jane A. Axelrad grounds for a finding that a material false statement was made by the licensee.
Therefore, we secomend that this issue be pursued for possible . enforcement action, s /
/ L1 v11b a re . G. Eis Fu t, Tire'ctor Division of Licensing Office of Nuclear Reactor Regulation Enclo'sures:
- 1. Question 10(a)
- 2. Copies of transmittal letters cc: J. Lieberman T. Novak H. Denton
- F. Miraglia e
4
E?1 CLOSURE 1
.UEST10N'-10 lA) THE COMMISSION'S REGULATIONS AT 10 CFR 50.10 STATE THAT A LICENSE MAY BE REVOKED OR SUSPENDED-
"FOR ANY MATERIAL FALSE-STATEMENT IN THE APPLICA
-TION FOR A LICENSE OR-IN THE SUPPLEMENTAL OR OTHER STATEMENT OF FACT REQUIRED OF THE APPLICANT", OR, BECAUSE OF " CONDITIONS REVEALED...THAT WOULD WARRANT THE COMMISSION TO REFUSE TO GRANT A LICENSE ON AN ORIGINAL APPLICATION..." DOES THE COMMISSION CONSIDER THA THE ERRONEOUS TECHNICAL <
SPECIFICATIONS AND SURVEILLANCE PROCEDURES SUBM BY MP&L FOR GRAND GULF CONSTITUTE EITHER A MA FALSE STATEMENT OR A FALSE STATEMENT OF FA,CT? ,
- ESPONSE A DETERMINATION HAS NOT BEEN MADE AS TO WHETHER OR NOT T EF40NEOUS TS SUBMITTAL CONSTITUTES A MATERI AL FALSE STAT Tu!S MATTER IS UNDER CONSIDERATION.
MARKEY/EDO -
MAY 10, 1984 j[
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, u U.S. NUCLEAR REGULATORY COMMisslON Office of insoector and Auditor 4
o................ January 12, 1985 Report of Interview 4c as intervieved concernir.g the probicrs associated with the' -
Technical Spec ications (Tech Specs) for Grand Gulf Nuclear Station (GGNS).
He provided the following infornation:
7 w, With respect to a reposed enforcement action concerning the errors in the GGNS Tech Specs,' recalled that was involved at the beginning of IE's effort in that reoard. IE had lea ed from Reoion II that there were some discrepancies in the GGNS Tech Specs. In articipation of a' Comission meetino relative to the licensing of GGNS to be held in August 1984, and in con-sideration of the information learned from Region II, Richard C. DeYoung, Director, IE, and Jane Axelrad, Director, Enforcement Staff, wanted to be orepared f a uestions concerning possible enforcement matters'at GGNS.
g '- Therefere, was directed by Axelrad te cbtain from Region !! and the Office of clear Reactor Regulation (NRP.) any.infomation about the discrepancies in the Tech Specs. Towards that end, he and Axelrad ret with Darrell G. Eisenhut, Director, Division of Licensing (DL), NRR. Eisenhut presented no ideas, pro or con, to them at that time with respect to a possible enforcement action in this natter. Eiserhut simply identified NRR staff who had been involved with the Tech Specs and agreed to trake them available for assistance to IE in this matter. ~
i
- /C M spoke with Ceil 0. Thomas, Chief, Stand?rdization and Special ' Projects Branch, hRR, Donald S. Brink Section Leader, Technical Specifications Review Group (TSRG), DL, and TSPG, concerning the Tech Spec discrepancies. Generally, t ese individua s wanted the .En'orcement S ff to take a cautious approach to any possible enforcement action. It was ,
opinion that these individuals were not sure if the applicant was resoonsible for the errors in the Tech Specs or if NRR was responsible. From conversations with NRR, he was certain they.had not conducted a. r 1 of the licensing process at that point in time to detemine how and why the Tech Spec licensing process failed. ,
l
,,,,,,,,.... January.11, 1985 .. Ibckville, Maryland ....=_Ing. 85-7 Mark E. Pc ter Sicilia ,' OIA ,,,, _ ,,,, January 11, 1985
- =m::::,=:;=.===:.==,===*" ~~
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TTo it r knowledce, NRR r.anagement never exprassed an opinion abcut responsibil-Petever, rrors ir the Tech Specs belnnaire to the licensee or NRC staff.
nature F crerally believes that the approach by NRC in natters of this een tc ultinately Feld the licensee resocesible. Clearly, DeYounc initiated the proposed enforcement action concerning the errors in the Tech Specs and naintained a posture that the licensee is rasnonsible for 'the accuracy of submittals to NRC.
IE believed it was not uncomon to see discrepancies in the Tech Scecs, but One n' the significant issues concernino GGNS tar the degree or nurber of errors.
% During% review of this ratter, it became clear tMthat the paper tr i concerning the errors in the Tech Specs was almost impossible to follow.
was unable, ir rest instar.ces, to trace when and by v.hcm channes to the YC various Tech Specs submittals were made. While conductino this review, it was W Mperceptien that the .Npr: Tech Spec staff believed they did not have enouch resources to do an adecuate job.
NRR managerent wanted licensees to follow the standard Tech Specs as closely as possible and this navr 't difficult for applicants / licensees to ge ges in the Tech Specs that deviated from the standard Tech Specs. It wa - 7C opinier that a more experienced cpplicant probably wculd have more v gorously
. attempted to get changes made to the Tech Spes despite the et that t changes nay not have adhered to tFe standard Tech Specs. oted tha lef t NRC befor@lould conduct a thorouch review of th events and ci -
7(
stances which ccTn ributed to the errors in the Tech Specs.
Q C % cted that during M rrview, ooked at Tech Specs submittals from 1981 forward to the point in time v.* hen 2NS was licensed. In doing scL. it was observation that certain Tech 5 ecs were accurate in all the subnittals, g-except in the final submittal. could not deternine why this had happened.
% Generally, M noted that inthemeetingsbetweenNRCandtheutilitythath attended, Mutility seemed to lack both rescurces and experience ir the Tech Spec area and appeared to be asking NRC staff for guidance and direction on what needed to be done.
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U.S. NUCLEAR REGULATORY CoMMIS$lON office of inspecter and Auditor o,i,..i,..........._ January 2. 1985 Report of Interview :
I i
Darrell G. Eisenhut, Director, Division of Licensing (DL), Office of Nuclear i
Reactor Regulation (NRR), U.S. Nuclear Regulatory Conunission (NRC), was interviewed cencerning NRR staff invnivement relttive to the Technical Specifications (Tech Specs) for Grand Gulf Nuclear Station (GGNS). Upon interview, he provided the following information:
Licensino Review Responsibilities for Tech Specs were transferred from the Division of Safety Technningy (DST), NRR, to the Division of Licensing (DL),
NRR, in the 1980-1982 tineframe. Prinr to the transfer, the Licensing Guidance for Tech Spee Branch (LGB), OST, NRR, was the, review group primarily responsible reviews.
NRR, assumed the responsibility for Tech Spec reviews.Af ter the trans 4
Th'e LGB lacked fomality in it Tarn Spec ieview process. Decisions were made based on telephere discussions and were fnllowed up with buck slip memoranda.
Too of ten NRC and applicants' managers were not aware of decisions made due to the lack was of formality transferred to OL, in the process. To strengthen the review process, it NRR.
Within LGB Donald S. Brinknan was the persor in charge of the Grand Gulf Tech Spec Reviews.
On or around 1980, he was transferred with the LCB function to i the Safety Assessment Grs..J Gulf Tech Spec Reviews. Group (SAG), DL, where he remained in charge of the Recently, be was moved into another tion t ranacenent res onsibilities. Eisenhut indicate 4
C.,
QC,Brinkman, were the original NRC staff members involved with the and and one other employee Gulf Tech Spec i Review pr ss. Of those fiv ople, only one is still employed by NRC -
7C Brinkman. ecently left NRC. Eisenhut suspects that the~v left RC because they b e Grand Gulf Tech Spec problen was "being laid in their laps." had primary responsibility for the i preparation and review of th time ago (approximately two years ago).GGNS Tec1 Specs and he retired from Since the Grand Gulf the group leader and
^ sue surfaced, Edward J. Butch'er, Jr., has been named phonetic), phonetic), and five former project managers have be.en reassigned to e Tec Spec Review Staff. ,,
7C
....... .. .. Deconber 31, 1984 Bethesda, Maryland 1
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, , , , ,_ Ing. 85-7
,,, Peter Sicil rMuk E. Re , OIA o,,, ,,,,,,,, _ January ' 2, 1985 n ,
Ev'r'doNe'N[
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, Attachment 4 , - -
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- Prior to the transfer of LGB from DST to OL, Roger .l. Mattson, Donald Skovholt, Robert Tedesco, and Stephen Hanauer were the DST managemert officiels ornanizationally recponsible for the LGB. In recalling the ' names er these rwnagement of ficials be noted that his memory was not perfectly clear in that regard.
With respect to any violttien of 10 CFR 50.36. Eiserhut ' eels he "can't say whether (or not) NRC violated the code." He stated the " process was so informal that its hard to tell, e.g., there were no <ign-of' sheets indiccting the responsible personrel at various levels of the organization."
Eisenhut still wants an independent, objective review regarding the Grand Gulf Tech Spec Review as part of the licensirg process to determinP exactly-what J went wrong and why, and how it contirued to go on for so long without being \
detected. NRR has performed many reviewe c' the process, but NRR's reviews 5 have not been detailed and "its herd to be objective."
Referring to a nenoranduri ' rom the Executive Director for Operations to Comissioner Gilinsky (Exhibit 1), he noted that the staff has informed the Ccmission tFat fiRR provided W-issippi Power and Light (MP&L) with a copy nf Standard Technical Spe s (STS) for a Mark 11 instead of a Mark III. b
%However, accordino to Encicsure 1 to Exhibit 1), this is misleading {
in that rd a General Electric official met with the apolica t '
and had , rovicea them %ith a modified version of the Mark 11 STS to be applied to the Mark III plant in developing the Tech Specs.
Referring to a memorandum from Frank Miraglia, Deputy Director, DL, NRR, to Thoras Novak, Assistant Director for Licensing OL (Exhibit ?), he noted that OL has reviewed MP&L's review precram descrit'ed in a March 18, 1984, submittal to NRC, and MPAl's inplementation cf the erroneous Tech Specs identified sirce the licerse was issued on June 16, 1981.
Eisenhut noted that the Idaho Natione.1 Engineering Laboratory (INEL) was contracted by NRC to review the Grand Gulf Tech Specs against the Firal Safety Analysis Report; however, "we were not very happy with the review they perforned." Dettils of the review and its results can be obtained from Miraglia.
Investigator's Note: On November 10, 1984, Brinkman was listed in the NRC profile as Chief Standard Tech Spec Section, Standardization and Special Projects Brarch, Safety Assessment Group, DL, F!RR.
.y
,r
APR 2 01934 MEHORANDUM FOR: Commissioner Gilinsky FROM: Willian J. Dircks Executive Dire: tor for Operations
SUBJECT:
CONVERSATION WITH .ONCERNING GRAND GULF TECHNI SP CATIONS Enclosed for your in at JW e record of an April 11, 1984 telephone conversation between formerly of the NRC, and Cecil 0. Thomas, Chi Standa z on & Special Projects Branch, Division of Licensing. naged the preparation of the Grand Gulf technical specific the NRC st!ff. .This infomation - 7C is being provided since it is relevant to our memoranda to you dated January 13 and February 2,1984 in which we discuss the development of the Grand Gulf technical specifications.
(Signes Wr.im J. Cit:ks William J. Dircks Executive Director for Operations
Enclosure:
As stated cc: Chairnan Palladino Commissioner Roberts Commissioner Asseltine Commissioner Bernthal SECY OPE OGC DISTRIBUTION:
Docket File '
NRC POR DCS '
SSPB Reading ..
H. Denton/E. Case W. Dircks -
M. Bridgers D. Eisenhut .
- f. Miraglia
- C Thomas (L '
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ENCLOSURE
- * " ' y'o, UNITED STATES i e NvCLEAR REGULATORY COMMISSIO. j a [hW ,, l I wash NoroN, o. c. 20sss
- 47C j / April 13,1984 ,
NOTE TO: Darrell G. Eisenhu' i
THRU: Frank J. Miragli [
FROM: Cecil 0. Thomas This is to inf a telephone conversation Jad on Wednesday.
April 11, with 7 As you know i 6 uhsequently retired from NRC and
' 7C prepared the Grand Gulf tech specs is presently consulting with utilities on tech spec matters.
called to advise me that we had erroneously inferred Cemissioner ilinsky that we had provided the Grand Gulf applicant with GE Mark II containrent plant STS to be used in the development specs. Wtated that in March with the1980 j_
of (thethetire Grand Gulfwe we said tech provided Ihe Grand Gulrapplicant Mark II ' /L STS) $ and f GE met with the Grand Gulf applicant in
,lackson, Mi sissippi; mo ified the Mark II STS to apply to Mark III plants, and provided the Grand Gulf applicant with the mark d u co be used in the development of the Grand Gulf tech specs. - 7C requested that we advise Commissioner Gilinsky of our error.
I advised that I didn't consider his marked up Mark II - 7C STS to be equivalent to Mark III STS and misled Commissioner Gilinsky. W, therefore, didn't maintained that we believe mi wee 4 Comissioner Gilinsky and stated that if we didn't so advise him _- .
7C would call Commissioner Gilinsky himsel'.
Although I didn't tell ' it is iroortant to noteonthat Grand Gulf licensee in oth its presentations and submittals the the ' 7 C subject agreed with our representation, i.e., that in March 1980, we provided them with Mark II STS to be used in the development of the ~
Grand Gulf tech specs.
Cecil 0. Thomas o .
cc: D. Brinkman
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- ~. .p * % e,'o f UNITED STATES jj^g,f,Ij,
- g /,. t NUCLEAR REGULATORY COMMISSION WASHING T3N,0. C. 20555 APli 11 TA(
R:ket fio. 50-416 l'EMORANDUM FOR: Thomas M. Novak, Assistant Director -
for Licensing Division of Licensing FROM: Frank J. Miraglia, Assistant Director for Safety Assessment Division of Licensing S'. 3 JECT:
ADEOUACY OF GRAND GULF TECHNICAL SPECIFICATION REVIEW PROGRAM AND ITS IMPLEMEllTATION Ir. rerpense to your memorandum to me of l' arch 30, 1984, reouesting a review
- -' the adequacy of MP&L's program to accomplish its intended obiectives, we have reviewed MP&L's program which was submitted as an attachment to t'.eir March 18, 1984 letter. We and Region II personnel also reviewed the implementation of this program during a site visit conducted on March 28-30, 1994 In our review, we identified certain deficiencies in the licensee's c-ogram and its implementation which we believe require correction. However, if these deficiencies are corrected as We understand the licensee is in the process of doing, we believe there is reasonable assurance that the licensee's prcgram as . implemented can accomplish its intended objectives. The details of our evaluation of 11P&L's program and its implementation are attached.
OJQ , IN Frank J. Mbagi a, sssistant D.irector for Safety Assessnent Division of Licensing Enc 1csure:
As stated -
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. weitt Exhibit 2
I ,
EVALUATION OF THE GRAND GULF NUCLEAR STATION TECHNICAL SPECIFICATION REVIEW PROGRM1 AND ITS IMPLEMENTATION Irtroductinn ,
As a result of concerns expressed regarding the accuracy of the Grand Gulf Technical Specifications (GGTS), the licensee undertook a detailed review of these technical specifications. The stated objectives of this review were to:
(l' verify the consistency of the GGTS with the as-built plant configuration, the FSAR and the staff's SER; (2) identify, submit, and support issuance of re:essary changes to the GGTS in a ticely manner; and (3) provide the necessary assurance that the GGTS are accurate and adequate. A description of the
'd:ensee's program for conducting its review was presented to the staff during a reeting on March 9,1984. The licensee followed up on that meeting by submit-ti .g a written description of its program as an attachnent to its letter of Pa ch 18,1984 The staff reviewed the licensee's program as described in that at achment. The staff also reviewed the licensee's implenentation of its pro-grm during a site visit on Parch 28-30, 1984 The site visit was performed by NRR and Region Il personnel.
A: eptance Criteria for Program To determine the adecuacy of MP&L's Technical Specification Review Program, we established the following acceptance criteria and reviewed the program against these criteria.
- 1. The progran should cover the entire scope of the GGTS and should consider the adequacy of that scope.
- 2. The program should recuire conparison of the GGTS with the various licensing documentation (FSAR, SER, etc.) and with the as-built plant.
- 3. The program should include appropriate management involvement and oversight by MP&L.
4 The program should require substantial licensee involverent in "all appropriate aspects of the procran.
. 5. The program should involve all appropriate parties including GE, Bechtel, and appropriate represertatives from MPAL.
- 6. The program should be under the licensee's Quality Assurance program.
Review and Evaluation of Program The licensee divided the GGTS into four portions. These four portions were:
(1) the technical specifications and associated bases within the NSSS (GE) scece, (?) the technicti scecifications and associated tases within the ritect engineer's (Bechtel) score, (3) the technical !Escifice. tic 9s and esscciated bases concerning rad'clericai e#fluen: arc r.v':crire (F.ETS), and
( ' the technical specifications concerning definitions, design features and
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adrinistrative controls. This division of the technical specifications and e.etr subsequent assignnent to appropriate review gregs ensured that all the technical specifications were reviewed by at least ce, and in some cases,
- e than ene review group. Therefore, we cenclude that the program covers cf the entire scope of the GGTS.
he program requires that the GGTS be used as a focal point for comparing them with the FSAR, SER, BWR/6-STS and the as-built plant. We find this comparison requirement desirable and acceptable in so far as it goes; however, we believe that there is an inherent deficiency in the ~ program in that by establishing Ps GGTS as the focal poirt of the review, the progra . presumes the GGTS to be sufficient in scope and in mcde applicability. We believe that in addition .to ec oaring the GGTS with the BWR/6-STS, the program sh:uld require consideration
' the GGTS to detemine if their scope and made applicability are adequate and if the GGTS contain unnecessary requirements. Our reasons for this concern are t at the BWR/6-STS were prepared in conjunction with the GGTS and their scope ar.c mode applicability have not been proven through use on other plants as have the other STS currently in use. Furthermore, the BWR/6-STS 5"te not been er.dorsed by the staff. Therefore, the BWR/6-STS are r.ot gonstdered to provide a sound basis for determining that the GGTS are adequate in scope or mode
- a .:lic:bility. We believe that the program should cor.tain elements requiring the reviewers to consider whether the GGTS contain the appropriate scope and riede applicability requirements. The requirements should be verified by
- paring the GGTS with the assumptions used in the Grand Gulf safety analyses.
' We also noted that while the program provides for a direct comparison of the G3?S with the as-built plant and with the FSAR, it does not provide for a direct corpar. son of the as-built plant to the FSAR. In view of the fact that a number of discrepancies between the FSAR and the as-built plant were detected during
- ther recent such comparisons (e.g. during the Region II inspection of February 21-24, 1984 ' ref. Inspection Report 84-06), we believe that such a ec, parison would have provided added assurance that the as-built plant is accurately described in the FSAR. However, a limited comparison of. the as-built
- lant to the FSAR will be possible through cross comparisons of the as-built plant to the GGTS and the FSAR to the GGTS. We believe this ifmited comparison is acceptable. If in this limited ccerparison, a large number of inconsistencies are detected and are determined to be significant froc a safety standpoint, a ro e thorough comparison should be required. .,
The licensee established a project-oriented organization reporting to the Senior Vice Pie'ident-Nuclear s to coordinate the review effort.. The Project P.anager, Technical Specifications Review is an MP&L eeployee who reports directly to the Senior Vice President-Nuclear. The Review, Prioritization and Direction (RPD) Panager, Administrative Manager, RETS Manager, and the NSSS/ BOP
ar.ager are all HP&L employees and they report directly to the Project Manager.
"e tene19de that the program provyes for appropriate VPAL ranagenent involve-r er ar.d oversight.-
. ,\
3 The RPD Manager is the Plant Staff Technical Superintendent. The RPD Group includes representatives from Nuclear Plant Engineering (NPE), Plant'St6ff and f:uclear Safety and Compliance. The primary functions of the RPD Group -
are to: (1) evaluate findings forwarded to it. (2) assign priority to' -
- otential changes to the technical specifications, (3) direct necessary corrective action, and (4) concur with findings or adequacy of completed- -
er proposed corrective actions. .
'he NSSS/ BOP Manager has an NSSS Manager and a BOP Manager, both of4hom are "P&L employees, reporting to him. Also reporting to the NSSS/B0P Manager is an Onsite Review Team whose minimum composition includes: (1) A GE or Bechtel engineer, (2) An MP&L NPE engineer, 'and (3) An MP&L Senior Reactor Operator.
The initial review of technical specifications within the NSSS/ BOP Review Group scope of respcnsibility will be conducted in the GE and Bechtel home offices, as appropriate, followed up by some field verification at the plant site.
The Administrative P.eview Group is directed by an engineer from the MP&L Tuality Assurance organizattor,.
The RETS Review Group Manager is the MP&L Manager of Radiological and Environmental Services.
Our review shows substantial licensee involvement in all appropriate aspects
~
- f the program which we consider preferable to delegation of such involvement to a consultant or other organizations. Our review elso shows that the progran requires the involvement of all the appropriate parties in this review effort.
The program provides for auditing its implementation and effectiveness by the MP&L Quality Assurance nrganization. A Quality Engineer is assigned to the -
program to provide quality control support to the Project Manager. Therefore, we conclude that the program includes cemnitments for adequate participation by the licensee's Quality Assurance organization.
~
Although it was not part of our acceptance criteria, the program includes the ese of an independent organization to assess the program's effectiveness. We '
telieve this review to be an exceptionally good idea and we comend the
, iicensee for including it in the program. The licensee selscted the Impe11 Corporation to perfom this independent audit. The Impell Corporation is to .,
review the program, inspect work activities in progress, and provide a report en the adequacy of the program to the Senior Vice President-Nuclear.
Another element of the progr:m which was not part of our acceptance criteria was a prioritization scheme developed by the licensee for all item.s which require technical specification changes. Priority 1 items would be those required
+o be changed prior to resuming critical operation of the plant. Priority 2
' tens are those for which technical specification changes are required but such changes are not reovircJ for safe operation of the plant. Pricr; 3
'ters are those dich do not require tectrical specification chenges. From a safety standpoint this prioritization scheme appears reasonable.
.o .
4
The licensee's prioritization scheme appears reasonable from a safety standpoint 5 that the licensee recorrends that all items identified as Priority I he
?; approved by the NRC and issued as license anendments prior to resuning critical c:eration of the plant. However, it should be roted that from a legal or policy standpoint, all items which have been identified as requiring technical specifi-cations changes may have to be approved by the NRC and issued as license amend-i" rents prior to resuming critical operation of t'.e plant.
2.olementationofProgram l'
The licensee initiated implementation of the Grand Gulf Technical Specificati'on Review Proaram on March 2,1984. The staff (NRP and Region II) conducted an c site inspection on fiarch 28-30, 1984 to review the licensee's implementation
, cf the program. During this inspection, we interviewed several nembers of the licensee's organization as well as several GE and Bechtel representatives and inspected several technical specification review packages. Our acceptance
- criteria were to determine if the program was being implemented in accordance with its provisions. The results of this inspection were presented to the
'icensee during an exit ir.terview with the licensee's representatives on March 30,1984. Region II will followup on the licensee's resolution of the
'* discrepancies noted during this inspection. These results are also discussed in our following evaluation. ,
. Review and Evaluation of Progran Implementation
~
The staff (NRR and Region II) conducted an onsite inspection on March 28-30, 1984 to review the licensee's implementation of its technical specification review program. We interviewed several nembers of the licensee's organization
- as well as several GE and Bechtel representatives and we examined several technical specification review packages during our onsite review. From our exanination of these packages, we determined that the licensee implemented the program as described in its submittal of March 18, 1984. However, our review aTso disclosed that the licensee (particularly 'n the Bechtel areas of review responsibility) was apparently using the draft BWR/6-STS as justifi~ cation for~
the acceptability of the GGTS. As discussed ab:ve, the draft BWR/6-STS have reither been endorsed for use by the staff nor are the BWR/6-STS considered as
" mature" as are the other STS currently in use. Therefore, while we believe that the RtG/6-STS can serve as a useful guide in evaluating the a'dequacy of '
tre GGTS, we believe that a determination regarding the acceptability of the GGTS based upon a comparison of them with the BWR/6-STS is inadequate. The licensee has stated that in its final closure of technical specification packages, the draft BWR/6-STS will not be used as sole justification for detemining the acceptability of the GGTS but that additional justificat. ions will be provided. Region II will followup to confim this commitment.
r s Othcugh we fouid indicatinns that some of the revievers considered the e fecuecy cf the scope and mode applictbility recuirementr in their reviews o' the GGTS. Our ensite review confirred that there was no syr.teratic icplementa-icr.
c' a plu for the reviewers to censider the adecuacy of either the scope or mode
--= -
- m. , ,
- .5:-
applicability requirements of .the GGTS. We believe this to be a deficiency in heth the program and in its implerentation. The licensee has made an informal co nitrent to correct this deficiency and Region II will followup nn the' licensee _'s cemi tment.-
- 1.'e. observed that potential technical specification problems could be identified dring reviews by various reviewers and determined to be insignificant by the
' RPD. - When such a' determination was made, item numbers were not assigned to the-e:hnical specification problem sheets and.therefore a potential exists for items- '
which were actually_ significant to not be~ identified and hence dropped from.
. -ther censideration. We believe that this is La deficiency in the program and -
that a tracking system for such .itens should be developed and implemented. The li:ensee has informally committed to implement-a tracking system for such items.
Eegion II will also followup on this conmitment- .
We noted that the Impell Corporation audit was in progress during our onsite ir:s pection. Impell _ had-selected and was in the process of reviewing _11 features
' of the Grand Gulf design to determine if these features were adequately covered -
ir. the GGTS. Impell concentrated its selection of features to be reviewed on-features unicue to the BWR/6 and/or hrk III containment designs, and to the Grand Gulf plant design. The staff received .a briefing on the Impell review on April 4,.1984 We conclude that the 11 features selected for review are a'n .
adequate sanple to determine if these unique features are covered in the GGTS.
Although the Impell review is not yet quite complete-(a final report is scheduled to be submitted to the licensee's Senior Vice President-Nuclear on April 13,1984), its preliminary conclusions were presented to the staff in the April 4,1984 briefing. Those conclusions are:
4
- 1. . The Technical Specification Review Program process and results provide adequate assurance that the GGTS, as revised to reflect the results of Impell's' review, accurately reflect the Grand Gulf Nuclear Station design analyses and the as-built plant. While the possibility remains that undiscovered technical specificatien ~ -
l discrepancies may still exist, it is unlikely that such discrepancies would be of substantial safety significance.
~
- 2. The Technical Specification Peview Program process and results provide adequate assurance that the GGTS, as revised to reflect ,
the results of Impell's review, appropriately reflect the unique design features of Grand Gulf Nuclear Station. Impell believes that it would be prudent to confirm further the technical specifi-l cation coverage of Grand Gulf Nuclear Station unique features and notes that the licensee has initiated such a confirmatory program.
l L
l~
?. The Technical Specification Review Program prccess and results provide adequate assurance that the GGTS, as revised to reflect t% ruults c' Ir;eli's review, reet er exceed current llRC/indestry standarcs for the level of detail to be included in technical specifications.
D
,,,__,_.,_y , , , _ _ . , . . . . _ , .
, . . . l 6-J A. The GGTS, as revised to reflect the results of Inpell's review, will be adequate to ensure safe operatien of the plant.
We have revfewed Impell's preliminary conclusions and we concur with their con-clusions subject to confirmation in their final report scheduled to be issued on April 13, 1984 --
Overall Conclusion The licensee has developed and inplemented a' program for reviewing the GGTS.
Ir. cur review of this program and its implenentation we noted four deficiencies which we identified to the licensee during our exit interview from the onsite irspection of March 28-30. 1984.- In addition, the Impell Corporation has made prelimina ty conclusions that if its recommendations for certain improvements in the program a.re made, the licensee's program is adequate to ensure the accuracy ar.d completeness of the GGTS. It is our understanding that the licensee has taken actions to correct these deficiencies. Region II will followup to verify that these deficiencies are corrected. It is our conclusion that if these four deficiencies are corrected in the manner that the licensee has informally described to us, there is reasonable assurance that the licensee's program as inplemented can accomplish its intended objectives.
An important measure of the adequacy of the program and its implementation is the discrepancies and proposed changes identified during the program's imple-mentation. Therefore, the results of the program's implementation require
, careful review. However, the review of those results are beyond the scope of
. this evaluation and will be cvaluated separately. .
e
- q e
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9
- . . _ _ - ... __c - - . ,,,-,r_x--_ -- __.,._..w.a , , , r w e_. ~ . w , p m _m U.s. NUCLEAR REGULATORY COMMisslON Off.ce of Inspector and Avd. tor o....s......... January 7, 1985 Report of Interview Donald S. Brinkman, Section Leader, Technical Srecifications Review Group, Divisien of Licensino (DL), Office of Nuclear Peactor Reculation (MPR), U.S.
Nuclear Regulatory Comission (NPC), was interviewed concerniro the Technical-Specifications (Tech Specs) for Grand Gulf Nuclear Station (GGNS). He pro-vided the following infornation:
In. February 1973 he becar workinc to vrvelop Standard Techr.iral Specifications (STS) for the four light water reactor vendors (Westin Engineering, Babcock and Wilcox and General Electric) ir. ghouse, ' Combustion existence at that
' time. From 1973 to 1979 he was primarily responsible for developing the STS and preparing the Tech Specs for Westinchouse and Combustion Engineering power reactors. From March-1979 to October 1981, he was assigned to the Three Mile Island (THI) Program Office. In October 1981, he was oromoted to Section Leader for the .STS Section (at that time approximately fcur professienal staff renbers) in the Licensing Guidance Brarch (LGB), which was at that time in the Division of Safety Technology (DST), NRR. Donald Skovholt was then Chief, LGB, and Dr. Stephen Hanauer was then Director, DST. Frank Schroeder was Assistant Director for Generic Pro.iects in DST at that tine. He noted that LGB then reported to Frank Scheneder, who in turn, reported to Hanauer. In approyinately Septenber/ October 1982, LGB was abolished and the STS Sectien was transferred urder the Standardization and Special Projects Branch (SSPB)
' in the Division of Safety Assessr.ent, DL. Concurrently with the transfer of the STS Section to SSPB, Cecil 0. Thonas was named Chief, SSP 8. At that tire, Frank Miraglia was Assistant Director for Safety Assessment, DL, and Darrell G. Eisenhut was Director, DL. During the suriner of 1984, Miraglia was i
oromoted to Deputy Director, DL, and Dennis M. Crutchfield was appointed Assistant Director for Safety Assessment (AD/SA) in DL. In October 1984 the STS Section was reorganized into the Technical Specifications Peview Group (TSRG) and expanded to approximately 10 professional staff members. .
Edward Butcher was appcinted as Group Leader reportino directly to '
Crutchfield.
Digressing to October 1981, when he wa ction Leader, the GGNS Tec pecs were being prepared by f his staff. - 7C 7C ad bee arino the GGNS ch Specs since ear 1980. When he Brinkman l upervisor, he did not conduqt, a ' review or '
T- analysis of competent pro ess ona arwork e ,ied3Lr o date sbecauseperfo he consideredLs to be a Brinkm matter]..
did not conduct a thoroul , isceptn ivlew of work through the completion of the GGNS ech Specs hich were sued by Again, he noted that as supervisor, he relied on p June 16, 982.
January 3, 1985 ,, Bethesda, Md. Inq. 85-7 * ""
,, Mark E. /PetersiciliFE,otA January 7, 1985
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. . .. . - u~ u =t r ww:. awaw.- wn:m 1. w . . v- m mg censpetence te rrnperly prepare the Tech specs. He told o double -
9 check the Tech Specs against the SFR to' ensure that all ter's ide tified in the SEP were also identified in the Tech Srecs. Furthermore, he noted that g,, had been workinc extensively on Boiline Pater Reactor (BWR) Tech pecs curing the preceediro six or seven years and was recognized as the NRC expert. en the BWR Tech Specs.
He said that. ' prepared a prncf and review version of the Tech Specs for GGHS. This versioT. was provided to the ARC staff and epplicant, ftississippi Power and Light (MP&L), on January 5,1982. Nonnally, one month is provided for en indeperdert review by NRC staff and the applicant. When the proof and review version of the Tech Specs was provided to the various technical review branches in the NRC staf# 'or review and commert, it was transritted to them by a memorandum fron Skovholt to all the technical review branches. He noted that orobably prepare:d that metrorendym and be '
(Briokran) concurred in be oreit was signed by Skovolt. Brinknan does not recall how the proof and review version was transmitted to MP&L, but suspects
~l C r personally oave it to than informally or transmitted it informally-without cover letter. He notec tFat at that time, it was not cortnor practice in NRR to formally transmit the proof and review version of the Tech Specs to the applicent. To the best of Brinkran's knowledge, the nemorandun s.iored by Skovholt that transmitted the pronf and review copy to the technical review branches was in existence in approxinately February 198a because the Januarv 5,198?, dat d above was cleaned fron that memorandum by leither'himself ori fomerly of SSPB, DL, NRR._ He dn9s nn+. now krow the whergbokof that ne rardum, but indicated that jmay kn6w where it is. Jperfc med a gcst licensing Tech Spec reTview of the SER and told Brinknaa thit there were SER Tech Spec itens that had not been l identified in the Tech Specs.
i The coments concerning the proof and review version were received from the various NRC technical review branches, the Resident inspector for GGHS, the o'
Reoinn 11 staff, and the plicant
- The coments were reviewed and believed 7C to have been resoived b Brinkman eoes.not rece.ll a ficant problems with the Tech ecs eing broucht to his attention by er other NRC staff. Prinkman believed that he conducted a cursor, review 6i the, proof and review version of the Tech Specs and also previded his coments to Brinkman knows in retrospect that there were a number of change's made by o the proof and review versinn based on comments received, however, e does t recall that the changes were unusual or ur.ique by number, and believes that the changes were typical of similar efforts with other licensees. He noted that his consnents concerning the changes to the proof and review version were addressing the pre-licensinq timeframe and not events
~
subsecuent to licensing on June 16, 1982, ~.mee-r..
.~ Md '
%Afte'r received the coments on the proo# end review version of the Tech .pecs, he then prepared e final version of GGNS Tech Specs for issuance.
The final version was transmitted to Thonte Novak, then Assistant Director for Licensing under Darrell Eisenhut, Director, OL, for Novak's use in issuing the GGNS operating license. The transmittal memorardum was prepared by o cor. curred in by himself (Brinkma'n) and Skovholt, then signed by Scb-oeder forwarded to Novak. The date of the transmittal memorandum is believed to -
have been a June 1982 date, however, he (Brinknan) has n una to locate that memorandum. He noted that, at that time, he asked if he had ~7C i
resolved all the corrents on proof dcesn't recall specificclly, d review version. Althouab he Brinkman would not have ccoc reply bad to have been affirmative or g to Novak. ed in the memorandur forwarding the Tech Specs It was the practice of Sknyhnit and Schroeder not to review the Tech Specs and he se.pects Skovbolt and Schroeder received the transnittal menorardun withcut the attached technical speci'ications.
He noted that the Tech Specs were then issued by HRC on June 16, 1982, as Appencix A to the crorating licensing fer MNS withcut any questiers or concerns expressed to the STS ' rom NRC staff or the applicant's staff.
He noted that the STS Section was responsible for preparing the Tech Specs and providino then to the Prciect Manar,er (PM) at the tire of licensing. As a matter of practice, the licensing PM did not heceme involved in the preparatien cf the Tech Specs, but the Tech Specs. He recalls that 11 rather directed the STS Sortion tc prepare Deer Houston became PM 'cr CGNS approxirately six predecessors were. months before licensing. He does not recall who Houston's Subsequent to licensing of GGNS, the rettensibility for the Tech Specs, in this instance, was transferred to the PM, and it is typically done in this manne~r.
Af ter issuance of the operating license for GGNS problems with the Tech Specs were identified by both Region II, NRC, and MP&L. At the tire they were identified, GGNS criticality. had been shut down for a period of time following initici Region 11 advised the licensee that the problems with the Tech Specs would have te be corrected before they could operate. This notification was made by a cerfirr.ation of action lettrr dated October 20,198?. He noted that subsequent to issuance of the operating licente, the PM wnuld normally be resporsible for processing of and changes reeded to the Tech Specs, however, in this instance, the STS Section was directed by DL management (Eisenhut) and Specs. the Director, hRR, to assist the PM in correctico the GGNS Tech possibly This assistance to the PM by +he STS Section was provided n August 1983 through the July 19M timef rame. He noted that on March 31,1983. - tired - [C i
1 On December 13,1983, then Comissioner Gilinsky wrote a remorandum to the -
Executive Director for Operations (EDO) incuiring about the numerous errors (approximately 200) in the Tech Specs for GGNS. NRR then prepared a response to that remorandun for the EDO. He noted that prepare a draf t -7L response memoranducifor the ED0's signature ( it I that earlier drafts of this memorandum state
[
oes not have the earlier drafts ne cop 4e and to his know ge, they have.been discarded bfprobab(v himsqlf o were discarded because he andi The earlier drafts r?(
Jhad received those.4p{%depproximately
- 3) back from Cecil 0. Thomas.hief,'3SPB, DL, with instructions to change them. When Thomas returned the earlier drafts to him (Brinkman), Thomas told him that he should incorcorate the indicated charces narked on the drafts to the best of his, recollection, Brinkman recocnized the changes on the draft memoranda to be in the handwriting of Frank Miraglia or believesy '
that Thomas may have told hin the changes were desired by Miraglia. The.
drafts were returned on different occasions rather,than at one tine and also
i
included other itens to he charged. Brinkman's interface with ranagerert r,r the chancing of the dra.fts was limited to Thomas. Brinkman noted 'that in 1 ceneralfonce Miraalia's cocrents have been incorporrted into a document, fhere are very few changes nade in the #irrl docurent issued by HRR. This was
- true-in Br this instance. Aleng with the. changing o' the d ft nenoranda, f.
- n had rerercus discussions with Thomas- regardine. ~g' reparing Tech pecs. Brinkn nd in general, the proce res used by NR or <
told Thomas that he believed the NRC s'eff had -
'o chare the responsibility for the errors ir the Tech Specs and that the NPC staff is 'respcosible for the accuracy of the Tech Specs issued by NRC in accordarre rith 10 CFR 50.36 He (Brinkman) dic nc* focus on the regulation per se, but emphasized to Thomas that the NRC should ensure the accuracy of the Tech Specs because we (hRC) issue ther, es ar NRC dt unert and because the; Tech Specs are part of the operating license. For whatever reason, Thomas did j
not respond to Brinkman at that time on that issue.
A couple of months subseouent te their discussions pertaining to the contents i of the draft cernranda and after issuance of the final nerorandur (Exhibit 2),
i Tuomas expressed the belief to Prinknar ano others .thet the applicant primari-ly bore the responsibil v and not NRC. Brinkman also noted that because he IBrinkman) acc s.
i he has 'K also expressed this belief tr rembers of the nuclear irdustry with om he has contact. This is not to say that he believes this concept is valid.
' With respect to the disposition of the response to Ccrrissioner Gilinsky, he noted that Exhibit 1, supra (draft remo) was provided to Comissioner Gilinsky i by the Plannino and Program Analysis Staff, NRP, before finalization of the memorandum. Prinkman was told that by Thomas. A by Thoras to Exhibit I
/
instructions came rom horas told him that those our oor rean rc Harold Denton's staff).
Therefore, Exhibit 2 was prepared and forwarded after the detailed infomation had been edited.
Approximately three or four days later, Brinkman was told by-Thomas that another memora hi it 3) had to ed. -
b)@
inkman also is be told y Mirag new memoran (Exhibit 3) word h t
sibilit licant for t problems with ** G.j <
.psharingof the In March 1984,'tongressman Markey wrote a letter to Chairman Palladino in which he raised the issue of naterial false statements nade by MP&L in con-nection wjth the er,romJa the Tech Specs for GGNS. This apparently awa--
precipitated the NRC Enforcer t St d f t view tha GGNS Tech Spec problem and the NPC Enforcement Staff to request ther to review the applicart's igiral iet with Cecil Thomas and Brinkman [C submittal of the marked up General Electric STS for any material falso rtatements centaired therein. A
'cw days later, Msked Brinknan and Thomas to find apcroximately six 7g axirples renainedof' itens in tTie original Tech Specs sobri+ted to NRC by MPAL which Ig error in-the version of the Tech Specs issued on June 16, 1082.
assisted ries. The'findires Brinktran were ir this providec to review in and the selection of six exam-July 1984 in the fon" of -
mndwritten evaluations of the six example. found in the review. Brinknan/ C oted that his frelings were at that tire, and still are, that although the GGNS applicant had more error,s than other rpplicants, he does not believe that vpst attennted to deceive the MpC.
inexperience on the the part of MPIL.He helieves the tte errors were due to There were also discussions (both telephone discussions and reetings) during this timef rame between Thomas, hirself (8rinkrar), Elinor G. Adensam. Chief, Licensing Branch #4, DL, NRR, Jane Axelrad. Director, Enforcenent Staff, and 7C.gencerning why NRC wanted to pursue a material false statement in this natter. To the cerbalized that best of his (Brinnran's) knowlecce the Enforcement Staff they wanted f 1 .
nd send a ressage to the nuclear industry that Tech Specs must be taken (b l'J i .-
seriously.
He noted in closing that during conversations with Miraglia regardino NRC staff responsibility versus applicant responsibility concerning Tech Specs, "iraglia has said, in relation 'c thet Tech Spec problem with GGNS.- that 10 CFR 50.36(a) requires the applicant to ensure the accuracy of Tech Specs because
- he regulation states, in part, the applicart shall include proposed Tech Ipecs in their application. Aaain, Prinkman errpFesized that because the NRC reviews ar.d issues the Tech Specs as en NRC docurent, NRC must sbare the responsibility for the accuracy of the Tech Specs. He said "previously (prior to 1973-741 NRC only put a stanp of approval on the licensee's Tech Specs.
Put then, we (NRC) decided we would prepare and issue Tech Specs--we took on a lotdodge to of responsibility with that decision and now it seems as if we're trying it." He believes sone DL manager a Uliraglit and Thomas) want to shif t the blame to the licensee. These manacers believe the licensee is
.1tinately responsible for Tech Specs and want to cover themselves by pointing the finger at the licensee for the purpose of getting the message to them that they are responsible for Tech Specs.
Investigator's Note: Although Brinknan's title is Section Leader, he no longer functions in that capacity.
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g' "'Cg 4 ,og UNITED STATES j y .g NUCLEAR REGULATORY COMMISSION
- , 1 WAsHINGTc N, D. C. 20555 l
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f f!,$)90 M$4 "E"0 rat;DUM FOR: Commissioner Gilinsky F:0M: William J. Dircks Executive Director for Operations s
S3 JECT: GRAND GULF TECHNICAL SPECIFICATIONS Y:ur r emorandum dated December 13, 1983 inquired about the nature of the Technical Specifications which were issued for Grand Gulf with the low power license on June 16, 1982. You also asked about the changes to the Technical S;:ecifications since the issuance of the license, the actions of the licensee
- i. regard to this issue and the extent of OIA and OI involvement.
Y u asked why the General Electric Standard Technical Specifications (GE-STS) for Mark 11 containment plants were used to develop the Technical Specifications for Grand Gulf which has a Mark III containment, and how we came to approve Technical Specifications for Grand Gulf which were grossly in error. At the
-ime preparation of the Grand Gulf Technical Specifications was initiated (early 1980), we knew that Grand Gulf had a Mark III containnent; hcwever, we had not yet prepared GE-STS for Mark III containment plants. Preparation of a GE-STS for Mark III containment plants occurred concurrently with the preparation
- the Grand Gulf Technical Specifications. Nere'cre, the Grand Gulf applicant wes provided with a copy of the GE-STS for flark II containment plants and was instructed to identify those Technical Specificatiors which were not applicable er which required modifications due to design differences. We took this apprcach since there are only a few differences between the Technical Specifications in the GE-STS for Mark II containment plants and these for Mark III containment
- f. ants. Furthermore, as noted in the Enclosure, use of the GE-STS for Mark Il containment plants to develop the Grand Gulf Technical Specifications did not result in any significant contribution to the number of changes required to correct the Grand Gulf Technical Specifications. The fact that the Grand Gulf Technical Specifications contained so many errors when issued was primarily the result of a poor review on the part of the applicant who failed to ensure the Technical Specifications were reflective of actual plant design. The Enclosure was prepared by the NRC staff to provide detailed information in response to your concerns. .
m You asked what has been done to determine whether the issuance of the Grand Gulf Technical Specifications with so many errors is an isolated instance. A review of all licenses issued subsequent to the initiation of the STS effort in 1974 shows that no changes to plant-specific Technical
. Specifications anywhere near this magnitude have occurred before or since the
. Grand Gulf license issuance.
s m#
Exhibit 1
$ 6. s .
^,,
. Commissioner Gilinsky , ,
~Ycu' asked what has been done to ensure that1 issuance of plant-specific-echnical Specifications wi*
- elieve-that this was'an is. many errqrs will not recur. As noted above, we L:he part of the applicant ? ed instance due-primarily to a poor = review on
- wever, become sensiti s " crefore, do not expect it'to recur. He have, circunstances surrounding this instance and i f in ' the future .we d ct a similar situation developing, we will take a:propriate' measures prevent such problens frcm rec.cring.
.v:u-asked-how nany changes -to the Grand Gulf . Technical Specifications and
. associated surveillances have been made or requested since.the~ Grand Gulf-license was' issued. Since the low pcwer license was issued.on June 16, 1982, se licensee has requested 205 changes to the Technical Specifications of
,.hich enied. 130 have been granted, 43 are under review to be issued and 32 have 'been
. Chronologically,11' of the changes were proposed prior to the
. surveillance procedure review required by the October 20,1982, Confirmation' of Action (C0A) Letter issued by Region II. The remaining'194 changes ~were
.review.
requested to incorporate changes identified during the surveillance procedure For comparison, Pennsylvania Power and Light with its first nuclear
- lant, Susquehanna Unit 1. (Mark 11 containment), requested 34 changes to its Technical Specifications in the same post-licensing time frame. Approximately
.490 Grand Gulf surveillance procedures were revised or written by the licensee-curing the period from October 1982 through September 1983 as a result of
- changes to the Grand Gulf Technical Specifications.
t.. The fell into proposed changes to Grand Gulf Technical Specifications generally four categories: (1) Editorial or Nomenclature Corrections, (2) Consistency within Technical Specifications, (3) Conformance to the As-Built Plant and (4) Changes to.the Bases Section. Categories (1) and (2). are purely administrative changes. Category (a) irvolves clarification
. statenents Specifications. for a better understanding of the reasons for the Technical In accordance with 10 CFR 50.36, Category (4) items are not considered as part of the Technical Specifications. An analysis of the i
considered breakdown: changes Category (1) - 36% to(62theitems)Technical Cate Specifications shows the Category (3) - 45% (78 items) and Category (4) -gory '(2)items).
4% (6 - 15% (26 items ,
Since" i
i- Categories (1), (2) and (4) are administrative in nature, we find that 55%
of the proposed changes are administrative and 45% are associated with some i
function of the as-built plant. It is important to note that none of the proposed changes have involved a finding, proposed or final, that a significant hazards consideration exists.
, , proposed changes are described in the Enclosure. The details of the nature of the j , . _ .,... . . .
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. Commissioner Gilinsky .
Ycu asked when the licensee first became aware of the flaws in the license conditions and what action was taken by the licensee after dis:overino these
-iaws. .Ycu also asked to. <. hat extent the pre-operational tests and the low rewer tests revealed the inappropriate license conditions. Tre Region II
'r.spections perforned shortly af ter the issuance .of the Grand Gulf license indicated that the procedures were not completely adeouate to implement the
~
-squirements of the Technical Specifications. The findings :# these nspections prompted Grand Gulf to do a meticulous review of their Technical I:ecifications and surveillance procedures.
This review revea'ed deficiencies in the Technical-Specifications and surveillance procedures. Grand Gulf
- oposed Technical Specif.ication changes and revised existire surveillance rocedures and wrote news ',urveillance procedures to' correct these deficiencies. -The details of the Region II inspections and changes-to the echnical Specifications and surveillance procedures are described in the Enclosure. The pre-operational tests and low power tests did not . reveal significant Technical Specification discrepancies. This is not unusual in nat 'the values used for acceptance tests prior to licensing are based on the test available parameter values contained in vendor manuals, design s:ecifications and calculations and the proposed Technical Spe:ifications.
You asked to what extent DIA and 01 are involved in looking into questions regarding the Grand Gulf Technical Specifications and surveillance procedures.
Neither 0IA nor 01 have been requested to review these matters.
William J. Dircks Executive Director for Operations
Enclosure:
As stated cc: Chairnan Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal SECY OPE
'0GC
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/ at Enclosure -
Tiscussicn of Initial Technica1' Specifications-Ne plant-specific Technical. Specifications are prepared basically by the
-Same method.for all plants. This method is described:in the foreword section-
. : cf the--Standard 1 Technical Specifications'(STS) for each light water reactor cendor (Attachment). , Copies of the. Ger.eral Electric STS (GE-S 5) were sent
- o - the -licensee in March 1980.- The licensee marked up the.GE-STS and returned S to~ the NRC staff tin June 1980. The licensee wasinot 'able ^t: provide all
, the requested information, i.e., plant-specific parameters, values,.
dmenclature, figures, gr.gphs, etc. , at that time because sore information -
was.stillLbeing developed ~and analyzed. The NRC staff reviewed'the licensee's.
- -oposed nark-up and prepared a draf t of the Grand Gulf Technical- s hecifications in August 1980. A copy of this' draft was-provided to.the
-licensee for review. Several NRC staff / licensee meetings were held over the ccurse of.the next 16 months to resolve noted differences between the NRC staff and the : licensee. During this period, the -licensee supplied the cutstanding information required to complete the Technical Specifications.
he Grand Gulf Technical Specifications were issued'for Proof and Review (final review by the staff and the licensee) on January 5,1982. The comments from this review were resolved and incorporated in the Technical-
- Specifications during the March-April 1982 time frame. The Grand Gulf
. Technical Specifications were issued as Appendix A to the Grand Gulf Unit 1 License on June 16, 1982. ,
In its preparation of plant-specific Technical Specifications, the NRC staff reviews the applicant's proposed Technical Specifications (marked up
- STS) against the criteria in the applicant's FSAR and the NRC staff's SER.
Hwever, it should be noted that the NRC staff depends signif':antly upon- the applicant to perform a thorough review of the draft Technical Specifications to ensure that the information provided is reflective of actual plant design and: configuration. Our experience shows that it is preferable to have this review performed by members of the applicant's plant operatfor.s staff to ensure that the draft Technical Specifications reflect the actual plant -
design and configuration. This was not the case with Grand Gulf.1The Technical Specifications were prepared by the NRC staff and a consultant acting as the contact for and on behalf of Grand Gulf. Although provided to the. reactor vendor and the Architect Engineer (AE) for their review and coment, the proposed Technical Specifications were not reviewed by the Grand Gulf plant operations staff during the initial development period up to and
' ' including the Proof and Review. Nevertheless, when the license was issued, the NRC staff, based on its work with the applicant's designated contact, '
believed that the Technical Specifications were reflective of plant design and were consistent with the operational requirements of Grand Gulf.
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.Ctanoes to Technical Specifications Since-Licensing "any of the nonenclature changes were p'ropcsed to achieve consistency -
w'th the way the operating staff had been trained. For example, numerous ri agraphs in the Technical Specifications. referred to the " Containment and A.;xiliary Building" in regard to containment barriers._ The licensee requested
- at this reference te changed to "Prfrary and Seconderj Containnent." Either way is acceptable to the staff and this nomenclature change was granted
- satisfy the licensee's preference.
Fellowing issuance of the., operating license for Grand Gulf, the staff ceveloped the GE-STS for Mark III containments. Draf t copies of this STS were a.ailable
' e. Mostin December 1982 and were nede available to the licensee at that of their proposed changes. in Categ:ry (2) were requested .to obtain tr.e latest position as stated in this version of the GE-STS.
Lch has been said about the use of GE-STS for Park II containments as a framework for Grand Gulf and the fact that installed systems were different c not installed. A review of the Category (3) items ir,dicates only nine items out of a total of 78 that were concerned with non-existent
. ecuipment or a misrepresented function associated with some equipment or s stem. Of these nine, one (Explosive Valves in TIP System) clearly was'a carry over from the Mark I and II concepts. Three items (Fuel Grapple Irterlock, Load Shedding and Sequencer Automatic Function and Low Condenser
acuum Bypass) were consistent with the Grand Gulf design as reflected i- the Grand Gulf FSAR. The Grand Gulf FSAR was in err:r with regard to the actual plant design. One (Lever Arm on Vacuum Breaker) was the direct result ca change that was specifically requested by the. licensee and approved in Ld:ense Amendment No. 4. Later, the licensee deternined that these lever aras c'd not, in fact, exist.
As a result, another Technical Specification change request had to be processed. One discrepancy was related to e te the Mark III containment plants (Fuel Tube Transfer Systea)quipment Thereunique are two c:-ions available, horizontal and vertical. Grand Gulf has a horizontal system but incorrectly selected some Technical Specifications appropriate for a vertical system. Two itens involved details of the as-built plant that are generally not available in the FSAR for staff review (Voltage Instrumentation on NCC Panels and Control Room Filtration Bypass). One item (Hydrogen Recombiner Penetrations) was accurately described in the FSAR but incorrectly addressed in the Technical Specifications and should have been detected by the licen'see and the NRC staff.
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' In addition 3to' the' discussion on~ as-built ' plant conditions, many of _the wr: posed changes to the,TechnicilfSpeci.fications :resulted from the licensee's use 'of canufacturer's specifications rather than the parameters of _ the -
C stalled; equipment'or resulted from the_'use of ina:;ropriate conservative
.1'.ues obtained from tests. _ For example, {the licensee specified that a surveillance test for an electrical ~ motor. rated at 2780. kw be performed at 2 ilkw when in' fact -the motor, as installed, woulc cnly draw 2180 kw at full-system rated flow. The licensee's performance lof and review of preoperational tests should have~ identified'this inconsistency. A cther change was in regard to containment isolation-valve ' closure ~ times. For _ example,' the licensee srecified a valve. closure _ time-of 28.4 seconds (initial determined test time)
-fcr a valve in a system th,at was required by accident analysis to close= in less than or equal to 40 seconds. The NRC staff had reconmended.that the-0:.nding time of less .than or equal' to.40 seconds be_ used_ by the licensee but this advice was not accepted. The example valve that closed in 28.4' se:onds in the initial' install.ed state would be expected to close in 32 to 34 se:onds later in life. After the license'was issued, the. licensee realized
.that the plant' operation could be limited by a minor but acceptable ~. increase ir ' closure time by the as issued Technical Specifications. ~The licensee requested and the NRC staff approved a relaxation to a longer and still acceptable closure time.;'o.Had the licensee prepared the original _ input to the Technical Specifications rr the basis of bounding closure times, numerous requests for changes to the Technical Specifications of this type could have been avoided.
Awareness of Licensee to Technical Specification Preblem .
~ The Grand Gulf Operating License, NPF-13, and the associated Technical 5:ecifications were issued on June 16, 1982. Actua' fuel load began on JL y 1, 1982. Initial criticality ist zero power wi:n an open vessel was-
'uccertaken. on August -18,1982. Following criticality on that day the plant -
was shutdown and entered a major maintenance outage to make modifications to the Drywell Cooling System. This system had shewn considerable deficiencies during the non-nuclear heatup tests. These: deficiencies would ha,e significantly reduced plant operational capability. Consequently, as a result of C0A Letter of October 20,'1982, the reactor was not' restarted until the deficiencies in Technical Specifications and surveillance procedures 'were identified and fully corrected.
- 4 c
. !$ortly after issuance of th'e license, Region !! inspections concentrated on
.9e adequacy of plant procedures .to demonstrate Technical Specification
- epliance. Findings revealed the procedures were not ecmpletely adequate to.
' plement the Technical Specifications. Special attention was devoted to the atequacy of surveillance procedures to assure irplerentation of.the Technical Soecifications. Region II did not originally consider the Technical I ecificaticos as a significant prcblem because of the large' review effort put
- crth by the. staff in establishing the Technical Specifications. As :tated a bove, there were numerous meetings between i:RR and the licensee, ser.e with F.egional participation. After review of the draft Technical Specifications, Tsgion II corrented in wr.i, ting on them in Noverber 1981. Important findings cocumented in our reports' during that period are suutarized in the following aragraphs.
- nspection Report 50-416/82-55 was issued to MP&L on July 30, 1982.
Tnis inspection covered the period of June 16 to July 16, 1982. The
- indings were presented to the Plant Manager in an exit interview on July 16,
- cluding four examples of plant procedures which did not adequately implement s;rveillances required by the Technical Specifications.
- nspection Report 50-416/82-62 issued to MP&L Seotember 3,1982 documents a
. eeting on July 26, 1982 at the MP&L corporate offices. The major topic of
-hat meeting was a discussion of the corporate Safety Review Comittee's role in the safe operation of Grand Gulf. Another tcpic addressed was "the number
' cf problems identified with procedures." This refers to the negative findings esulting from Report 82-55 described above. During the meeting, NRC representatives emphasized to MP&L the necessity of conducting a meticulous review of their procedures to ensure Technical Specification reouirements are
- .lly irpler.ented by procedure. MP&L stated that such a review would be done.
- spection Report 50-416/82-67 was issued to MP&L on December 20, 1982
.nich covered the period September 27 - October 8,1982. That report
'.cluded the results of a special team inspection cenducted by Region 11 to
.erify that changes to Technical Specifications are promptly incorporated
'nto procedures and properly implemented, that surveillance procedures are in place to implement all Technical Specification requirements, and that surveillance procedures are technically adequate. The general findings, as c'escribed below, were negative. This information was presented to MP&L durin,g an exit interview at the site on October 8,1982.
The general conclusions of the inspection were as follows:
Some Technical Specification surveillances or FSAR requirements were d- not incorporated into the appropriate plant procedures.
Technical Specification requirements were found to be misstated or incorrectly incorporated into surveillar.ce documents.
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Technical Specification. requirements were not being followed where 'a-Technical Specification ar.endme,nt .had been requested but _had not yet been approved by f:RR.
~ Technical Specificatien requirements existed that related to hardware
- not applicable to Grand Gulf but no amendment request had been submitted to delete the requirenent (one -ite _ cnly -- valves in TIP system).
Ar. . enforcement conference was. held ~on' 0ctober 14, 1982, in the Region II' c'# ice to further discuss ,these findings. The corrective actions addressed .
tre above findings and were documented in a C0A letter from Region II to MP&L issued.0ctober 20, 1983.
The C0A letter. stated that l P&L shall take the a:oropriate corrective actions prior to the achieverent of the next reactor criticality. During this four-month period from license issuance in' June to
- full . recognition of the Technical ' Specification deficiencies, the plant did nct operate, with the exception of the initial criticality on. August 18, 1982.
Also, the plant did not operate again until all known deficiencies were cc rected, i
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,- . Ners: 744 pur ApMa, 4 ynu aa.Cr rea:La i) wig v.. me mia. . w j Cc.nissio'nei.' Gilinsky .._3 1
e' ' LTeu asked when the licensee first became aware of the flaw's-in the license cerditions and what action was ta. ken by the' licensee after discovering these f'aws. You also asked to what extent the pre-operatier.al . tests and the low
- aer tests ' revealed the inappropriate license conditions.1 _The
- Region II i-spections; performed shortly after the issuance of the Grand Gulf, license
' indicated that~ the procedures were not completely.' adequate to implement the es:uirer.ents of'the Technical' Specifications. The_ fir. dings of'these
' ir.spections. prompted Grand Gulf to'do a meticulous review of'their Technical-S:scifications and Lsurveillance procedures. This review revealed deficiencies' in.the Technical Specifications and surveillance procedures. Grand Gulf p-eposed Technical Specif1 cation changes and revised existing surveillance '
a _ procedures .and wrote new,furveillance procedures to correct these
.es#iciencies.. The details of the Region II inspecticns'and changes to the.
-Te:hnical Specifications and surveillance procedures are described in:
t-e Enclosure. The. pre-operational tests,and low power tests did not reveal c significant Technical Specification discrepancies. This is not' unusual in.
that the ' values used for acceptance tests prior to licensing are based on the best available parameter values contained in vendor manuals.-design <.
s:ecifications and calculations and the proposed Technical Specifications.
~
-Y:u asked to what extent DIA and OI are involved in locking into questions.
regarding the Grand Gulf Technical Specifications and surveillance crocedures.
Neither.01A nor 01 have been requested to review these matters.
William J. Dircks Executive Director for Dperations
' E-cl os ure : -
As stated
. cc: Chairman Palladino Commissioner Roberts Commissioner Asselstine Comissioner Bernthal ,
SECY OPE OGC
, f. DISTRIBUTION:
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SECY(3)
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'W. J. Dircks J. Roe T. Rehm V. Stello R. DeYoung J. O'Reilly, R-II G. Cunningham OIA GI
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Ekhibit 2
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, . l- #p *ig'o,A UNITED STATES MUCLEAR REGULATORY COMMISSION 4.' I WASHIN;Tc N. D. C. 20$ 55
..... January 13, 1984 "Eu]RANDUM FOR: Comissioner Gilinsky P.:M: William J. Dircks . ._
Executive Director for Operations SU5 JECT: GRAND GU E TECHNICAL SPECIFICATIONS Ycur memorandum dated December 13, 1983 inquired about the Technicel Specifications which were issued for Grand Gulf with the low power license on June 16,1982.
he General Electric Standard Technical Specifications (GE-STS) for Mark II containment plants were used to develop the Technical Specifications for Grand Gulf'which has a Mark III containment. At the time preparation of the Grand Gulf Technical Specifications was initiated (early 1980), we knew that Grand Gulf had a Mark III containment; however, we had not yet prepared GE-STS for Mark III containment plants. Preparation of GE-STS for Mark III containment
.' - ;;1antsReurred concurrently with the preparation of the Grand Gulf Technical Specifications. The Grand Gulf applicant was provided with a copy of the GE-STS for Mark II containment plants and was instructed to identify'those Technical Specifications which were not applicable or which required n:difications due to design differences. We took this approach since there
' are only a few differences between the Technical Specifications in the GE-STS fer Mark II containment plants and those for Mark III containment plants. The use of the GE-STS for Mark II containment plants to develop the Grand Gulf .
Technical Specifications did not result in any significant contribution to the nut.ber of changes required to correct the Grand Gulf Technical Specifications.
The Region 11 inspections performed shortly after the issuance of the Grand Gulf license indicated that the plant procedures were not completely adequate to implement the requirements of the Technical Specifications. The findings of these inspections prompted Grand Gulf to do a meticulous review of their Technical Specifications and surveillance procedures.. This review revealpd deficiencies in the Technical Specifications and surveillance procedures.
The Grand Gulf applicant proposed Technical Specification changes and revised existing surveillance procedures and wrote new surveillance procedures to correct these deficiencies. The pre-operational tests and low power tests did not reveal significant Technical Specification discrepancies. This is not unusual in that the values used for acceptance tests prior to licensing are based on the best available parameter values contained in vendor manuals, design specifications and calculations and the proposed Technical Specifications.
1 I
Cc :-issioner Gilinsky - -'
Since the low power license was issued, the Grand Gulf licensee has requested 205 changes to the Technical Specifications. Apprcximately 55% of the recuested changes were administrative and approximately 45% were associated with some function of the as-built plant. Of these requested changes, 130 have been granted, 32 have been denied and 43 are under review. It is t :crtant to note that none of the proposed changes involved a finding, prcposed or final, that a significant hazards consiceration exists.
As discussed above, a number of factors contributed to the problems encountered with the Grand Gulf Technical Specifications. However, we
.telieve in retrospect that'the single most ir.portant factor was the failure t , the part of the Grand Gulf applicant to-ensure that the proposed Technical 5 ecifications were properly reviewed. Although we understand that copies of the proposed Technical Specifications were provided to General Electric and '
Bechtel for their review, the Grand Gulf applicant assigned primary responsibility for review of the proposed Technical Specifications to a consultant. This consultant had no experience in the operation of comerical SW:.s and only limited experience in the operation of other power reactors.
The proposed Technical Specifications were not reviewed by the Grand Gulf plant operations staff to ensure that they reflected the actual plant design.
We believe this was an isolated instance. Usually, utilities' plant c:erations staffs are intimately involved in the development of their plants' Technical Specifications. We have become sensitized to the importance of this aspect of the utilities' review of their propgsed Technical Specifications and if in the future we detect a similar situation developing, we will take appropriate measures to prevent its recurrence.
(Signed)Wil!!am J. Dircks William J. Dircks Executive Director for Operations cc: Chairman Palladino Comissioner Roberts Comissioner Asselstine -
Comissioner Be'rnthal SECY
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"I" F.ANDUli FOR: Conrnissioner Gilinsky- *
- DI * " o e 6M FECM: William J. Dircks-Executive Director for Operaticns SCEJECT: PREPARATION OF .TECHfMCAL SPECIFICATI0fiS As a followup to my January 13, 1984 nemorandum to.y:u on the Grand Gulf Technical Specifications and in response to your verbal request to Edson Case fer additional information regarding the procedu es used for preparation of techr.ical specifications in general and for additional information regarding the development of the Grand Gulf Technical . Specifications, the NRC staff has prepared .the enclosed information. Enclosure 1 describes the procedures t e
- RC staff has been usi,ng for preparing techr.ical specifications for new S
operating licenses. Enclosure 2 describes how these procedures were applied to G and Gulf and includes a discussion of the reaser.s for the many changes regired in the Grand Gulf Technical Specifications following issuance of its low power operating license.
EI EDM Wilfisc J. 0.:ks '
William J. Dircks '
Executive tire: tor for Operations' .
Enclosures:
- 1. Frocedures Used for Preparation of Technical Specifications
_for New Operating Licenses
. 2. Preparation of Grand Gulf Technical Specifications -
cc: Chaircan Palladino
- Commissioner Roberts -
Commissioner Assel stin'e Conrnissioner Bernthal .-
SECY OPE *
- OGC DISTRIBUTION: .
Docket File D. Brinkman .
NRC PDR '
F. Miraglia ,
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., ,I Exhibit 3
ENCLOSURE 1 e 4 PROCEDURES USED FOR PREPARATION OF TECHNICAL
_. SPECIFICATIONS FOR NEW OPERATING LICENSES Te: r.ical sp.ecifications for new operating licenses are prepared by the NRC wi- extensive input by the applicant. The NRC staff has prepared a ' set of -
Standard Technical Specifications (STS) for each of the four light water '
rea: tor vendors. These STS are the startir.g peint for preparing technical s;e:ifications for each new plant. The STS are revised periodically by the NR staff to reflect revised or new regulatory requirements and design changes.
The following procedures f0T preparing plant-specific technical specifications
. are described in the Foreword (see attachment) of each of the four STS documents.
A;;roximately one year before the plant's scheduled fuel load date, the applicant is provided a copy of the applicable STS and instructed to review the STS de: ment, to fill in the applicable plant-specific information, to identify
" ncn-applicable specifications or requirements, to identi'fy are'as where technical s;s:ifications are required but not included in the STS and to' return the marked-up document to the NRC staff for review. The marked-up document is then re.lewed by the NRC staff and compared with commitments made in the FSAR and with requirements established in the staff's SER. Draft technical specifications are then prepared and a copy of these draft technical specifications is provided te -he applicant for review.
Some plant-specific information will usually'still be lacking sin'ce it may not be available for various reasons, e.g., completion of construction, analyses, or preoperational testing. Therefore, several NRC staff / applicant meetings are normally held to resolve the differences and to cbtain the lacking information.
Following the review of the draft technical specifications and approximately three months prior to the scheduled fuel loading date, the NRC staff issues the Preef and Review Copy of the technical specifications. The Proof and Review copy is issued to the NRC staff review b, ranches and to the applicant for a final review prior to issuing the operating licer.se. The plant-specific technical specifications are essentially complete when the Proof and Review -
copy. is issued. The NRC staff and applicant are requested to identify any required changes. The typical time alloted for this review is four weeks. Any coarnents from this review are then resolved and the final technical specificationc are prepared for issuance with the operating license, e
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Duri ; preparation and review of plant-specific technical specificaticns,
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the 'iRC staff depends significantly upon the applicant to perfcrm.a thorough rev'es of the information submit'ted in,the marked-up STS document and that cor.:ained in the draft technical specifications and in the Proof and Review Cep;. to ensure that the information is reflective of actual' plant design, ccr.#iguration and nomerclature. Our experience shows that for reviews performec by the applicant, it is preferable to have this review performed by menbers of the spplicant's plant operations staff since they are usually the most familiar witn the plant's actual design and configuration. The information provided by the applicant to be included in the plant-specific technical specifications is reviewed by the NRC staff during its review of the draft technical specificatic s and the Proof and Review Copy but only on an audit basis and with little emphas's on inputs.that reflect plant-specific nomenclature, e.g., compenent or-system.
ti;*es.
The staff',s review and acceptance of the draft technical specifications are based more upon ensuring that the safety criteria described in the applicant'>
FSA . and in the staff's SER are maintained than upon ensuring that actual plant nc a ,clature is accurately reflected in the technical specifications. Ensuring that actual plant nomenclature is accurately reflected in the technical specification is a function left primarily to the applicant.. .
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. FOREWORD -
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' IM* LE.W.ENTATION -
The in three implementation phases. of the STS en an individual license application will procee
.- 'The major step,s within each phase are indicated below..
s - Phase I .
The applicant should;
- 1. Obtain copies of the STS from the LPM.
2.
Identifyorand design mark other those specifications not recuired because of plant
- factors. >
. Specifications within this category should
-
- be retained and discussion.
in position within the doew.ent package for later revied 3.
Identify those provided areas where specifications are required but are not in the STS.*
- 4. Provide the applicable val es of the paramete and variables identified by blanks 'or parentheses in the STS.
- 5.
- Provide the STS package. the figures', graphs and other information required to complete
- - +
Phase II- ,
. , 1. '
. The Commission staff willt review the ir'f'ernation provided in the marked
, ' up STS package resulting form the Phase I preparation.
h '*
2.
An applicant / staff meeting will be held to resolve noted ciff.erences -
of position and A.E.
and other related comments from the applicant *,' vendor <
Phase III 1.
The Commission will provide a P cof and Review edition of the technicai specification for final review by all parties based upon the resolution of comments and positions in Phase II.
2.
Final comments and corrections will be incorporated into the document as received. -
3.
The Appendix Technical "A" specifications will be issued by the Cormission .as .
of the Ope, rating License. .
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i GE-STS 11 I
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, , ENCLOSURE 2 PREPARATION OF GRAND GULF TECHNICAL SPECIFICATIONS Copies of the Standard Technica1' Specifications for Genera 1' Electric Boiling Water Reactors (GE-STS) for Mark II containment plants were provided to the Gra-i Gulf applicant in March 1980. Although we knew that Grand Gulf had a Mars. III containment, we provided them with the GE-STS for a Mark 11 contain--
ment since we had not yet prepared a GE-STS for Mark III containment plants and since there are only a few differences between the technical specifications in e GE-STS for Mark II containment plants and those for Mark III containment plar:s. ,
Furt.hermore, we instructed the Grand Gulf applicant to identify those technical specifications which were not toplicable or which required modifications due to design differences and to identify areas where technical specifications were required but not provided in the GE-STS. The applicant marked up the GE-STS and -eturned it to ,the NRC staff in June 1950. The applicant was not able to provide all the requested infomation, i.'e. , plant-specific parameters, values, nome clature, figures, graphs, etc.,. at that time because some infomation was sti being developed and analyzed. The NRC staff reviewed the applicant's pro : sed mark-up and prepared e 4 raft of the Grand Gulf Technical Specifications in f. gust 1980. A copy of this draf t was provided to the applicant for revie.e.
Several NRC staff / applicant meetings were held over the course of the next 16 mont's to resolve noted differences between the NRC staff and the applicant' .
During this period, the applicant supplied the outstanding infomation required' to c:mplete the Technical Specifications. Proof and Review Copies of the Grand Gulf Unit 1 Technical Specifications were issued on-January 5,1982. The corm ents from this review were resolved and incorporated in the Technical Speci-fica: ions during the March-April 1982 tine frame.c The Grand Gulf Technical Specificati.ons were issued as Appendix A to the Grand Gulf Unit 1 License on June 16, 1982..
As r:ted in Enclosure 1, we believe it is preferable to have the plant's operation staf' review the draft technical specificatiens during their development.
, Howe er, this was not the case with Grand Gulf. The technical specificatioris were prepared by the NRC staff and a consultan.t acting as the contact for and on behalf of Grand Gulf. Although provided to the reactor vendor and the Architect Engineer for their review and comment,.the proposed technical specifications were not reviewed by the Grand Gulf plant operations staff during the initial development period up to and including the Proof and Review. Never-theless, when the license was issued, the NRC staff, based on its work with the app}icant's desi'gnated contact . believed that the technical specifications were
. reflective of actual plant nomenclature and that the technical specifications were consistent with the operational requirements of Grand Gulf. ,
The Grand Gulf licensee has requested 205 chang'es to. the Technical Specifications since the low power license was issued on June 16, 1982. Of the 205 requested changes,130 have been granted, 43 are under review to be issued and 32 have been denied' For comparison, Pennsylvania Power and Light with its first nuclear plant, Susquehanna Unit 1 (Mark ,II containmcnt), requested 34 changes to its technical specifications in the same post-licensino time frame.
a
' The IGC staff has analyzed the 205 requested changes and has determined that the requested changes generally fell into four categories: (1) Edito~ rial or r:cmenclature Corrections-62 items'-(36%), (2) Consistency within Technical Specificatichs-26 items (15%), (3) Conformance to the As-Built Plant-78 items (45%), and (4) Changes to the Eases Section-6 items (4%). Categories (1)and (2) were purely administrative changes. Category (4) involved clarification .
state ents for a better understanding of the reasons for the Technical Specifications. In accordance with 10 CFR 50.35, Category (4) items are not considered as part of the Technical Specifications. Since Categories (1),
(2) and (4) are administrative in nature, we find that 55% of the proposed chances plant.
.as-b[ilt are administrative and 45% are associated with some function of the In accordInce with our procedures for pre specifications, the requested changes in Category (1), (2)parino technicaland{4) type that we primarily depend upon the applicant to detect while some of the items in Category (3) should have been detected by the NRC staff during our review.
A review of the Category (3) ites showed that only nine' of the 78 items were concerned with non-existent equipment or a misrepresented function associated with some equipment or. system. Most of these nine items should have been detected and corrected during the staff reviews. One item (Explosive Valves in TIp. System) clearly was a carry over from the Mark I and II concepts. Three items (Fuel Grapple Interlock, Load Shedding and Sequencer Automatic Function and Low Condenser Vacuum Bypass) were consistent with the Grand Gulf design as reflected in the Grand Gulf FSAR. However, the Grand Gulf FSAR kas in error
- with regard to the actual plant design. One (Lever Arr on Vacuum Breaker) was the direct result of a change that was specifically requested by the licensee and approved in License Amendment No. 4 Later, the licensee determined that these lever arms did not, in fact, exist. As a result, another technical specification change request had to be processed. One discrepancy was.related to ecuipment unique to the Mark III containment plants (Fuel Tube Transfer System). There are two options available, horizontal and vertical. Grand Gulf has a horizontal system but incorrectly selected some technical specifications appropriate for a vertical system. Two items involved details of the as-built plant that are generally not available in.the FSAR for staff review (Voltage .
Instrumentation on MCC Panels and Control Room Filtration Bypass). One item (Hydrogen Recombiner Penetrations) was accurately described in the FSAR but incorrectly addressed in the technical specifications and should have been detected by the NRC staff.
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U.S. NUCLEAR REGULATORY COMMIS$ ION t Of fice cf Inspector and Auditor
- o....m........_ January 10, 1985 Reenet of Interview 7
Cecil 0. Thomas, Chief, Standardization and Special Projects Branch (SSPB),
Division of Licensing (DLi, Of fica cf Nuclear Rearter Recdiation (NRR), l'.S. '
Nuclear Regulatory Comission (NRC), was interviewed concerning the_Terknical Speci'ications (Tech Specs) for Grand Gulf Nuclear Station (GGNS). He pro-vided the following i,fornation:
He has been empInyed in his current position since A gust 1982 His imediate supervisor is currently Assessnent, DL, NRR. Dennis M. Crutchfield, Assistant Director for Safety Fron Septenber 1981 to August 1982, Theras was assigned to the Clinch River Breeder Reactor Progran Office, NRC. '
in late 1982, the Standard Technical Specifications (STS) Section, Licensing Guidance Branch (LOR), DL, became part of S.cPB. At that point in time, be' becare indirectly involved with the GGNS Tech Specs because of his supervisory capecity with SSPB. He noted thet in the later part of 1083, he became more closely involved with the GGNS Tech Specs because of the NRR responses to various inquiries frc,m Congressman t'arkey and the Comission. ,'
In general, he noted the+ NRR initially provided Mississippi Fower and' Light (MPil) with the STS for a Boilier Pater Reactor (BWR) V Park !! because the ,
STS for the BWP VI Park lit hed not been developed by fiRR at that tire. The primary difference between the V Mark !! and VI Mark .I'l is the reactor 4 containrent design ard the differences are contained in about 10 percent nf the areas involved. The fact that NRR provided MP&L with a V Park II version, of the STS at a enide for GGNS was not urusual and, ir fact, this procedure of providino an earlier version of the STS had been a standard practice used by ,
NRR if the STS for a specific tyra of plant (in this case a Mark III) had not' been developed.
In retrospect, he noted that GGil5 had made 'about 400 Aanges to the Mark II STS, but he belie"es these changes were all .outside the 10 -
percent area in which there are differences between the Mark II and III STS, He also noted that NRR sbculd have been more forral when they provided the ,
modified Tech Specs to MP&L. flRR infonnally provided the Tech Specs to MPAL rather than by way of formal correspondence, which would have clearly put itP&L ,
on notice that the Tech Specs they were provided with were an earlder version
- that needed to be updated to their Mark III design. The infornality of the NRC process and the inexperience with Tech Specs on the part of PPAL both contributed to arrors in the Tech Specs. However, the responsibility to' submit accurate Tech Specs is totally the applicant's. NRR, in effect. -
assists the applicants by conducting a limited review of the Tech Specs submitted in accordance with 10 CFR 50.36. Furtherrore, Nr.C's responsibility is in pull the final licensing package together and the Tech Specs are en integral part of that license package.
,,,,, ,,,,.. January 9, 1985 ,
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OIA January 10, 1985 o . . . .. m. .
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Prior to the pow in time when 6GliS begar receivinc bigh visibility, he estirates that the cverall review of Tech Seers by NPP was less than 'ifty percent. Vithin each technical brrnch it was less than twenty five percent, ono as a practical matter, lass than f raccent in scee of the breech reviews,
'1 He suspected that sene of the NRR technical review branches who were sunposed h to review and ccrrent on thr. Tech Specs rever saw them. Additinrally, there was ir.tufficient NRP staff to thoroughly review the Technical Specs. He also p noted that NRR sta'f dedica+ed for the Tech Soec raview function het recently been ircreased because of the problers ref t ' ting fecn. GCNS. He estinates that NRR r.nw condurts a seventy five to one hundred percent review of Tech Specs it.bmitted by the applicants. It is his opininn that the Tech Spec review by i
the NRR staff should parallel the schedule for preparing end finalizirp the Safety Evaluation Report. Thie is because tFa currect practice of an ad hoc ;
review by HRR staff is difficult in consideration of the volurnnus nature of the Teeb Specs ard nany changes rada tn ther right up te the poin+ the license is issurr*. In the instance of GGNS, the 400 changes mado were greater than ten percent.
Concerning the proposed enforcement action for the problem with frNS Tech Specs. it was his perception that its purpose is twofold. It will send a nessage to the FCC staff that Tech Spe:s are important and secordly, it will send a message to the " industry" about the importance of Tech Specs.
In regard to the proposed erforcement action, he recalls a meetino during the spring cf 1984 between Jane Axelrad, Directer, Enforcement Staff, Office of i
irsrection and Enforcenert (IE), Brad Jones, Reaieral Attorney, Region it, i Donald Brinkman of his (Thomas' staff), and an attorney from the Office of the Executive Lecal Director (ELD), himself, and possibly another person. The meeting was held in ELD. He was told at that reeting that IE was rurtuing the j
possibility cf Paterial False Staterants (MFS) by MPt.l. concerning the GGNS
}
L ecn Specs. NPR staff was asked to review all rest Tech Spec submittals by
- MP81. for pnssible PFS and ELD was to review the f:Ptt correspondence which I trarsmitted those submittals to NRC for the purpose of determining how the licensee represerted the submittals. Ha recalls that NRR later reviewed the h
' submittels for errors, however, he is not certain the review package put tcgether by hRR was ever provided to IE. Pe also recalls that there was possibly a serrnd meeting for the purpcse of discussing possible enforcercot action. Pe did not receive any guidance or input from his supervisors with respect to an NRR position on the proposed enforcement action. He simply was reauested to look for examples of possible Material False Statements (MFS).
It has been his experience in NRR, that decisions regarding whether an item is an MFS are left to ELO.,
Regarding a January 13, 1984, memorandum for Comissioner Gilinsky from William J. Bircks concern GGN pecs, he recalled that there were several drafts written by ornerly of NRC, and possibly Doneld Brinir.an. He believes that t first draf t wrs provided to - 7C Harold Denten Director, NRP. ("the fourth floor") and subsequently was provided to then Comissioner Gilinsky as a preliminary response. However, Comissioner Gilinsky returned the memorandum because there was not encugh detailed infomation contained in it. The memorandum was then rewritten to include more details, and finalized on January 13, 1984 In retrospect, he believes there may have been a short remerandum from Denton to Comissioner Gilinsky which transmitted the first draft. That transmittal
rcrerandum prrbabl.y corti.ined an explaration +c +he ef fect that tha dref*
renorandum was only a preliminary response to Cilinsky.
O These changee erre only made ir. an effert to be more responsive tr Commissiorer Gilinsky's inquiry. He vaguely recalls a reeting between Edson G. Case, then Deputy Director, NPR, Frank Miraglia, and himself wherein Case indiceted to then tFat NRR stait also had a ereponsibility for the Tech Spec errors and the nenorandun should state that in order to be more on point in responding to Cilinsky. There was no effort on the part of NRR tr.
vindicato themselves by shifting the blame or responsibility in this natter to the licensee.
He recalls a lot of discussions within NRR concernino applicant responsibility versus NRR staff responsibility in the GGNS Tech Spec issue. Some of those discussions were between Frank Miraclia, Ocnald Brinknan, Darrell Eisenhut,
=rd himself. Eisenhut and Miraglia both firmly believed that the emphasic for the responsibility cf accurate Tech Specs it placed upon the applicarts and licensees. Thomas believes that Miraglia and Eisenhut have always had this belief. He (Theras) also believes that the applicant is responsible for assuring the accuracy of the Tech Specs. Concerning this issue, there did come a peint in tire (approxinctely May In84) when the Tech Specs received a great deal of attentien from Congress and the Commission. There was dis-cussion at that time between Miraglia, Thomas and Eisenhut that NRR did the best they could have done in tFe GGNS Tech Specs with tbc resources available to them and the licensee also had a responsibility in that regard. Collec-tively, they (NRR) were "not going down to the Cennission with their tail between their lers."
Af ter the GGNS Tech Specs became an issue, be was asked by Miraglia. with some guidance fron Eiserhut, to review the problens encountered with the Tech Specs and deternine what improvements could be made. There was also a review of this matter conducted by a task force' headed by James Sniezek, Deru+y Director, IE in the fall of ISP?. From the results of these efforts, Miraglia 5+.arted "a get well prooran for Tech Specs." With the new progran, the NRP staff dedicated to the Tech Spec area has been siorificantly increased and the management acccur.tability for Toch Spec development and preparation has been emphasized by making one manager responsible for the Tech Spec review proce.ss.
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r U.s. NUCLE AR CEGULATO?.Y COMMisslON Of fice of inspector and Aud, tor
]
o.. .. ............
January 7, 1985 l
~ Report of Interview
.~
. 1 M. Dean Houston, Licensing Project Manacer (LPM), Licensing Branch #2 (LB#2),
Division of Licensing (DL), Office of fluclear Reactor Regulation (NRR), U.S.
Nuclear Regulatory Commission (NRC), telephone 492-8933, upon interview provided the following information:
On June 5,1978, when the Final Safety Analysis Peport (FSAR) was docketed, and until 1980, Ton Houghton was assigned as the Pro.iect Manager (PM) for the Operating Licensing (OL) Review of the Grand Gulf Nuclear Station (GGNS).
From 19F0 until June 1981. Joe Matore was the PM assigned to the GGNS OL review.
In 1980, Houghton left NRC and joined the censultant firm formed by Donald Knuth, former NRC Office of Research employee. In June 1981, Matore was pror.oted to Technical Assistant to the Director, DL, NRR. In August or September 1981, Matere left NRC and went to werk with TERA, a consultant firm
'"which does a lot of work for Mississippi Power and Light (MP&L) and Bechtel."
MP&L _ owns GGNS and Bechtel is the architectural engineering finn ~and construction contractor that designed and built GGNS.
In June 1981, Houston, who was the primary LPM for the Perry Fuclear Power Station (PNPS), was asked by Al Schwencer, Chief, LB#2, DL, NRR, to assist him on Grand Gulf. Houston's assistance was reouired because Matore's reassign-ment in DL came about just prior to the due date for the Safety Evaluation Report (SER). Houston recalls Schwencer noted that there were many open issues that needed to be closed in order to finalize the SER; however, the
, period of time available for this task was very short.
In July 1981, Schwencer then asked Houston to concentrate his efforts on processing the GGNS SER because Schwencer "was trying to get it out in time for the scheduled Advisory Consnittee Reactor Safeguards (ACRS) Subcommittee meeting on GGNS scheduled for August 1981 and the full consnittee schedul'ed for September 1981."
Prior to June 1981 Houston had not been involved with GGNS, and the licensing reviews performed by NRR's technical reviewers against the FSAR had already been completed by Houghton and Matore. Therefore, he had nothing to do with the licensing management aspects of GGNS -- he was just processing the SER by assisting Schwencer in closing out the open issues. Houston noted that Schwencer, MP&L and Bechtel staffs, NRR staff technical reviewers, and himself spent much time in June, July, and August 1981 in meetings trying to resolve and close open SER issues.
. ... .... January 4, 1985 .,__Bethesda, Md. ,,,,, Ing. 85-7 Peter Sicilib.Aiark E. Re IA January 7, 1985
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Houston maietriped his involvement with the SEF processinn until abcut Aucust or Septenber prirery 1981. ataswhich responsibility time be the PNPS reverted back to corcentratino on his' l.Pfi.
In February GGNS art' 1982, houston was infomed that he would take over es the LPM for the ramperent of the PFPS would be assigned to another LPH. Prior to this time, Hourton had not been officially assigned as the GGNS LFM; therefore, an official trarsfer of Matore's GGNS files tn Houston had not t a h.e place. Furthermore ',ince Matore lef t the arrtcy in August er Senterttr 1981, ocither an of'icial-transfer ciscussion n' CCNS licensir9 probiere of his files, nor an exchange of views or a between Fam-c and Hour tv took place.
In retrnerect Housten stated:
1.
Prior to actinst thehis involverert FSAR with GGNS had been corpleted in June by other LPMs.19Pl. the licansino reviews 2.
Between July-Aucust 1981, bis role was to cet the GGNS SER published, but he raintained his primary respersibility as LPM for PNPS.
3.
Schwencer open issues.was the " Lead Mar" for resolvir.9 the pre-ACRS Subecmittee SER Schwencer "took the responsi together and resolving the open issues" - trying glity oftoputting the SERand
(;et resolution closino as nany open issues as he cculd.
4 During with, the last week in June 1981,' ^ ard into July 1981, Schwencer sat dcwn
~
, HRP, and discussed with Vas reking -- chance any of the Tech Spec changes *N
,@inute m bc%re the SER was finali:ed.that were being made righ 5.
Procedurely, Mas responsible for preparing the Tech Specs and -- Z coordinating the Tecb*5pec reviews perfomad by the Division of Engineeri
- addition, DE) and the Division of Systers Integration (DSI), FPR. In bni a as resprosible for ersurino that all applicant ech Spec changes were reviewed by DE and DSI. Furthernere ,
ealt airectly with the applicart and its contractors, and was yC t .
point of contact for Tech Specs.
6.
Treditionally, when Tech Specs were prepared by LGB, DST, hRR, the final version of the plant's Tech Specs were transferred from DST to DL via a memo from Don Skovholt, AD/ DST, to Robert Tedesco, AD/DL NRR. Hewever, "that never happened -- such a letter transmitting the GGNS Tech Specs from DST to DL was never sent because of the last minute changes being made to the Tech Specs right before the SER was issued."
7.
For the period between Matore's departure from NRC in June 1981 to Housten's assignment as LPM for GGNS in February 1982, there was not, in effect, an LPH managing the GGNS licensing process.
8.
The Tech Spec problems did not come to light until about July 1982 --
(one nonth after the license was issued) when Reofon II became a
~~_,..., , - . , . ._. .-
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m significant problems and then followed up in October 1982 with a confirmation action letter.
. As to why Houston, as the PM and manager of the GGNS licensing process, did -
not discover the Tech Spec problem, Houston acknowledged the fact that PMs and NPD staff technical' reviewers are secondarily responsible for Tech Spec reviews as stated in the Standard Review Plan (SRP). However, he said that despite -the procedures' and delegations 'of responsibility outlined in these -
documents, Specs. he doesn't know of any PMs who have been involved with the Tech -
i we shirked "In practice ~,'PMs never got involved with Tech Specs and, therefore, our duty."
He noted, however, that the GGNS FSAR licensing review was completed prior to his assignment as the LPM for GGNS, therefore, he could .
not speak to the LPNs involvement with Grand Gulf.
Regarding the appropriateness of the Standard Technical NRC provided to the ' applicant Houston stated that ifications (STS) in September ' 7C ,
1980, provided MP&L with a proposed draft of the B VI Mark III STS. ,
Hcwever, the proposed Mark III STS had not been through nor approved by the' Committee to Review Generic Requirements and,'therefore, they were not officially acceptable. Notwithstanding this fact, MP&L prepared and in Decemt,er 1980 submitted their proposed plant specific Tech Specs developed against the unofficial draf t BWR V Hark III STS provided by Bottimore.
- However, in 1981,Mprepared the draft " Proof and Review" Tech ' Specs based on the BWR V Mark III STS, which were officially approved by NRC, and which were submitted to DE and OSI, NRR, technical staff reviewers for review as part of the licensing process (Exhibit I at pages 7-9 and Exhibit 2).
~
Houston did not have any knowledge of NRR or NRC staff positions regarding responsibility for problems with the Tech Specs for GGNS or how they relate to proposed enforcement action in this matter. However, he noted that in ' June or
. July 1984, NRR was asked by Jane Axelrad, Director, Enforcement Staff, Office of Inspection and Enforcement (IE), to review all of the applicant's post licensing, proposed Tech Spec amendments to determine if any material false statements were made. Houston stated NRR had some trouble defining what constituted a material false statement; however, he was told by Elinor Adensam, Chief Li'c ensing Branch #4, DL, NRR, "to just write down any false statements found and let someone else decide how material they are and what j enforcement action should be taken."
As letter. instructed, a list of false statements was prepared and sent to IE via a Houston noted, however, that the false statements were "relatively tame" and collectively the list formed "little or not basis for enforcement action." In this regard, the false statements dealt with " simple things" and l-i the element of materiality an,d degree of falseness was "very marginal."
Houston recalls meetings that took place involving Axelrad, Tom Novak, Assistant Director, DL, and Adensam, regarding GGNS Tech Specs. He stated i
Novak is currently the " Super PM" and Adensam is the " Assistant Super PM" for Grand Gulf and he (Houston), while still assigned as the PM for GGNS, in practice, is just another person involved with the plant.
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Investigator's Note: As dio Matore, _ John Pichardson, forner GGNS Licensing Mananer, MP&L, lef t MP&L and went' to work with TERA. 0er Davis, a;former NRC FM for Babcock and Wilcox Plants, went with TERA et the San ~ Francisco Office.
Fouston recalls seeinc Davis at.a neeting in Jcly or August 1981 during. the period when he was assisting Schwencer in closing the cpen SER issues. MPAL used TERA (and in this case Don Davis) te rrview and resolve the lest round cf Tech Spec concerns as part of the July / August 1981 task of closing:the SER.
For exanple, he recalls . Davis usivo the Washington, D.C. TERA nf# ice while working on.the resolutien to Appendix J exerptier.s for the leak _ test feedrater check valves.
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~ ' . MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi C " -
P. O. B O X 16 4 0, J A C K S O N. MIS SIS SIP PI 3 9 205 July 23, 1984 i.:..:'c;l.'.i.....,.......
The Honorable Nunzio J. Palladino _ n Chairman U.S. Nuclear Regulatory Co= mission 1717 E Street, N.W.
- as
. hington, D.C. 20555
Dear Mr. Palladino:
SUBJECT:
Crand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 License No. NPF-13 File: 0260/L-860.0
' Co:: cents on Commission Responses to Question from Rep. E. J. Markey of March 13, 1984 AEOi-84/0375 s
on July 17, 1984 the Commission filed final responses to questions raised by Representative E. J. Markey in his letter to the Connission, dated March 13, 1984. These responses were obtained by Mississippi Power & Light Company (MP&L) on July 21, 1984. MP&L has reviewed these Commission responses and wishes to take this opportunity to provide clarifying remarks and additional information regarding the responses to Questions 1(B) and 1(F).
MP&L does not disagree with the factual content of the subject responses but considers that there exists additional information surrounding these cceplex circumstances and events. The purpose of this letter is to provide that information in hope that it will be useful to you and the other Cot:missioners in constructing a more balanced view of these complicated l
issues.
Specific clarifying information with respect to Question 1(B) and 1(F) is contained in Attachment 1 to this letter. Information on the chronology of the development of the CCNS Techcical Specifications which supplements and expands the information provided in our April 9, 1984 1stter is provided as Attachment 2 to this letter. That chronology indicates the significant effort expended in the development of the CCNS Technical Specifications and illuminates the co=plexity of the total issue. Additional background information on the development of the GCNS Technical Specifications is provided in Attachment 3.
Please advise me if you require clarification or additional information regarding these attachments.
i Tours truly Mo
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JBR:rg Attachments
- Exhibit 1
,. ec: See next page k
............n.
AECM-84/0375 Pag 2 2 MISSISSIPPI POWER & LIGHT COMPANY cc: . Commissioner James K. Asselstine (w/a)
Commissioner Frederick M. Bernthal (w/s)
Commissioner Thomas M. Roberts (w/a)
Commissioner Lando W. Zech (w/a)
Mr. William J. Dircks (w/a) . .;
Executive Director for Operations U. S. Nuclear Regulatory Commission Washington. D. C. 20555 Mr. Harold R. Denton. Director (w/a) '
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Co==ission Washington, D. C. 20555 Mr. Darrell C. Eisenhut, Director (w/a)
Division of Licensing.
Office of Nuclear Reactor' Regulation Washington, D. C. 20555 Mr. R. B. McGehee (w/o) ,
Mr. N. S. Reynolds (w/o)
Mr. G. B. Taylor (w/o) , .
Mr. Richard C. DeYoung. Director (w/a)
Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission
- Washington, D. C. 20555 Mr. J. P. O'Reilly. Regional Administrator (w/a)
U.S. Nuclear Regulatory Commission Region II ,
101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323
.<wret - * *eem.. -o ww
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AECM-84/0375 MIS 012SIPPI POWER & 5 lGHY COMPANY Peg 2.3 b:c: Mr. A. Zaccaria (w/o)
Mr. R. W.- Jackson (w/a)
Mr. R. D. Couse (w/o)
Mr. J. F. Hudson, Jr. (w/o)
Mr. T. H. Cloninger (w/a)
Mr. J. P. McCaughy (w/o)-
Mr. T. E. Reaves (w/o)
Mr. J. E. Cross (w/a)
Mr. Steve Feith (w/a)
Mr. A. R. Smith (w/o)
Mr. A.'G. Wagner (w/a)
Mr. C. C. Hayes (w/a) .
Mr. M. D. Houston (w/a)
Mr. M. D. Archdeacon (w/a)
Mr. W. E. Edge (w/2)
Mr. J. C. Roberts (w/o)
Mr. L. F. Daughtery (w/a)
Mr. L. F. Dale (w/a)
Mr.-J. C. Cesare (w/a)
Middle South Services Nuclear Activities (w/a)
File (LCTS) (w/2)
File (Plant) (w/a)
File (Project) (w/a) (j[/]
S "9
Attechzent 1 to AECM-84/0375 ADDITIONAL IhTORMATION RECARDING QUESTIONS IDENTIFIED IN REPRESENTATIVE E. J. MARKEY -
LETTER TO TNE NUCLEAR REGULATORY ' COMMISSION, i.
DATED MARCH 13, 1984 Question 1(B) .
MP&L Comments on Commission Response, dated July 17, 1984 The NRC indicates that two significant contributors to problems associated with the GCNS Technical Specifications were excessive informality of the-process employed by both HP&L and the NRC Staff and a lack of sufficient-review by the plant operations staff.
P7&L discussed both of these causes in a meeting with the NRC Staff on April 4,1984 and formally documented these two areas as causes in letter AECM-84/0217, dated April 9, 1984. To the extent that the plant operations
- staff should have been more involved in the latter stages of the development of the GGNS Technical Specifications, MP&L concurs with the NRC Staff assess-ment of these two factors as causes for the technical specification probleas'..
P76L also believes that there were additional, significant causes which were not discussed in the NRC response to this question. In psrticular: ,
- s. Lack of Standard Technical Specifications and the first-of-a-kind-nature of the plant;
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- b. Absence of application of Quality Assurance attention to the develop-
- - ment and review of technical specifications;
- c. Insufficient management attention;
- d. Insufficient review of technical specifications by not only the plant operating staff, but also by Bechtel and General Electric during the late stages of technical specification development; and E
- e. No final, complete review of technical specifications immediately af ter receipt of Attachment A to the GCNS operating license.
The entire issue of problems associated with the GCNS Technical Specifications is complex with numerous contributors as discussed above. In particular, the factetbat no BWR6 Standard Technical Specifications existed while the CGNS Technical Specifications were being developed is considered by MP&L to be a eajor contributor. For the initial three years of the five year span in which the CCNS Technical Specifications were being developed, substantial resources l vere expended by PT&L in an effort to develop a suitable BWR6 standard on 2
which to base plant specific technical specifications. This expenditure of resources was essentially inefficient and ineffective since ultimately the NRC required that submittals be based on a set of technical specifications for an earlier;model plant.
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Attachment 1 to AECH-84/0375 l l
Information on the chronology of the development of the CGNS Technical Specifications which supplements and expands the inforestion provided in our April 9, 1984 letter is provided as Attachment 2 to this letter. That chronology indicates the significant effort expended in the development of the GCNS Technical Specifications and illuminates the cocplexity of the total issue and the role of the informality, lack of a standard, ~imd inadequati MP&L canagement attention in the development process. Additional background information on the develop =ent of the CGNS Technical Specifications is provided in Attachment 3.
Regardless of the contributors leading to the problems identified MP&L -
considers that the applicant / licensee is ultimately responsible for the development and implementation process; MP&L acknowledges that responsibility.
Since the receipt of the Lev Power Operating License, management attention has steadily increased regarding the technical specifications.
This increased management attention has given rise to significant review ef forts expended to establish the accuracy and adequacy of the technical specifications and associated surveillance procedures. Detailed evaluations were conducted into the background and causes of the problems experienced.
NT&L considers all root causes to be- adequately addressed by various '
corrective actions taken to date and is further com=itted to providing the
, proper level .of management attention to maintain these documents accurate and adequate. ,
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Question 1(T)
MP&L Comments on Comission Response, dated July' 17, 1984 By way of the background, the Comission Response to Question 1(F) briefly discusses some key events.and activities at Crand Gulf Nuclear Station 1:=ediately following the receipt by MP&L of the Lov-Power Operating License en June 16, 1982. Additional information is provided here to elaborate on the sequence of events following initial criticality, the rationale for the proposed testing schedule, and the entry into the maintenance outage' following that testing.
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~ The low power test program was specifically constructed to aliov for ticely execution of required tests and to eliminate duplicative testing, wherever possible. Proper sequencing vas, therefore, essential to the ef ficient startup of CGNS - a prototype BWR6/ Mark III design. For the pur-poses of this discussion, the sequence of some key events during this period is presented as follows:
. (a) Initial fuel load; (b) Lov power physics testing (reactor pressure vessel head off, as is' characteristic of the BWR design);
(c) Installation of reactor pressure vessel head; *
.(d)- Non-nuclear heatup using recirculation system; (e) Conduct prototype reactor, internal component vibration monitoring testing; (f) With reactor near normal operating temperature and pressure, conduct single rod scram (friction) testing.
It should be noted that steps (e) and (f) above must have the reactor's fuel installed as a prerequisite. For this reason and because low power physics testing was to be conducted with the RPV head orf, this test sequence ,
dictated that non-nuclear heatup follow the plant's initial criticality. This test sequence is typical of an initial BWR startup.
Non-nuclear heatup commenced in mid-September,198 2. It was during the testing at or near operating conditions, following initial criticality and non-nuclear heatup, that it was discovered that the dryveS1 cooling capability.
for a number of reasons,.was,apparently insufficient. Only af ter an evaluation of this insufficiency and the prescriptio'tNef appropriate corrective actions did MP&L elect to commence a maintenance outage to support the resulting design changes. That maintenance outage comenced in late October,1982.
a In sue =ary, as clarification to the Comission Response to 1(F), the plant was shutdown following initial criticality testing; however, only af ter the conduct of later, appropriately scheduled testing and subsequent evaluation was a decision made to enter into a maintenance outage.
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AnAcmT 2 TO AECM . /0375 CmONOLOGY OF GRAto GULF NUCLEAR STATION TECENICAL SPECIFICATIONS !
1977 There were several early efforts to. develop GGNS Technical Specifications (Tech Specs) and to develop BWR6 Standard Technical Specifications (STS). MP&L-begon to develop GGNS " Standard' Technical Specifications based upon the existing standard which was for o M,ork I plant. A BWR6 Standard Technical Specifications Review Group was e.sicSlished to deterinine o licensing strategy and develop a set of BWR6/Mork 111 Stonderd Technical Specifications. This group consisted of: Mississippi Power & Light Company (MP&L), Cleveland .
Electric illuminating Congany, Culf States Utilities Company, Tennessee Volley Authority, Illinois Power Coh[ny,*Public SegigCompany of Oktohoma, Puget .
Sound Power & Light Company, Tiowan Power Company, and General Electric
/
(GE). The initial N(P&L ! 5ptesentoilye.[or'C ,
e roup was from the 4
corporate Project Monogernent st6ff! version of 14 BWR6 ST3 3 Basea c' 3 rimosed &:f t of the S The early efforts involvedUid'of:o DeceShefelP75cBV/f13/4 k i GE Standard Technical Specification foh5rM hyk',;$ht'[djft y g S developed by the Review Group was a re-t/ ped versichroTw6ncsedio;o marke%qof the Bob Bottimore of the NRC orldwastdiented mostly;t
, issues and developing a li k ch hM' ) rg{llfktEwg{N since oil Operations personnelfondatiestcof<thdtite>r aupervisora;oh egr fi sted on pfant staff were involvedhg{,LQrjeQo,1)fg,'iQhg}thjlg c the year. Stof f to Bechtel.
4.
In ectly 1978, the NRC was in the p ::ess of revising the GE STS. In April of 1978 they issued Revision I of the CE i
STS. This STS was tofer revised by the NRC in Sr.,m - > , October, Ne.em% , o,d epin in December cf l 19'70
' -Ser, these rev?sio s were not forrr.c!!y in ed l 2 i
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l 1978-With fuel food scheduled for 1980, MP&L realized that the Technical Specifico.
' tions must be developed os early os possible in order to support completion of surveillonce procedures, operator training, and Pre-Op Testing. Therefore, most of the activities for deveioping BWR6/12 ark lit Standord Technical Specifications and the Grand Gulf specific Technical Specifications become more Intense, in 1978 the following significant events took proce:
- l. The BWR6 STS Review Group evolved into 2 groups, one
.of which remained oriented toward the licensing issues and the second group which took over the responsibility for the. technical content of the Technical Specifications.
This second group was represented by most of the utilities' plant operofions staff in order to take odvantoge i . of the best operations experience avoitable to the BWR6 utilities. In addition, besides GE most utilities had on
. Architect-Engineer (A/E) represen,tative. MP&L was re-presented by a Plant Stoff Technical Support Section Engineer.- The Bechtel primary representative was the !
Mechonical Group Supervisor.
- 2. By September of 1978, MP&L working closely with the BWR6 STS Review Group, comp,leted a second draft of the Grand Gulf version of the BWR6 STS.
3.
Based on o proposed draft of the BWR6 STS prepored by Mp&L and the Review Group, MP&L, in iote 1978 begon intensive efforts to complete the Grand Gulf specific Technical Specifications with input from GE and Bechtel.
At this time the Technical Sur.*-' Ntion of Plant Stoff was assigned responsibility for developing Crond Gulf specific Stondord Technical Specifications. The Technical Support Section was responsible for insuring proper review
- by Operations, HP/ Chemistry, Stortup, Maintenance, PSRC, Engineering, Licensing, etc. Project Engineering was formally responsible for obtaining the CE ond Bechtel imut and reviews os requested by Technical Support.
- However, most communication went directly from Plant Stoff to Bechtel.
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- 4. In early 1978, the NRC was in the process of revising the GE STS. In April of 1978 they issued Revision I of the GE STS. This STS was later revised by the NRC in September, October, November, and again in December of 1978. However, these revisions were not formally issued e
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by the NRC. The new revised sections were informally sent to the oppropriote utilities for inclusion in the Technical Specifications.
S. LoSolle submitted their proposed Technical Specifications on October 29, 1978. Since the document submitted by:
LoSolle was so different from the stonderd, they did not follow NRC direction,s and submit c marked-up copy of the STS. Insteod, they had a new draft Technical Specifi '
cotions printed and submitted that copy. However, the
-NRC felt it- would be too difficult to review such a document and requested that LoSolle instead mark-up the stonderd, regardless of the difference between LoSolfe's proposed Technical Specifications and the standard. The NRC Intended to revise the standard ogoin based upon their review of LoSolle Technical Specification and to issue o new stonderd based on the BWRS product line.
1979 Significant activities continued through 1979 by both the Stonderd Technico!
Specifications Review Group ond.MP&L. MP&L was planning to complete its ,
second draft of the GGNS specific Technical Specifications with a final review ~
by the end of 1979, and then submit the GCNS Technical Specifications in early. -
1980.~ To meet this objective the following events took ploce:
- l. In January 1979, the NRC provided MP&L with a draft
" proof and review" copy of the STS which had been revised in September, October, November, and ogain in December of 1978. The NkC, offer making several odditional significont chonges, later issued this basic document as Revision 2 of CE STS in August 1979. This
- STS still did not incorporate BWRS product line features.
- 2. MP&L contacted the NRC, Dr. Bob Bottimore, to discuss the submittal of GCNS Technical Specifications. His direction was to use the latest moferial issued from his
" office and to mark up these Technical Specifications for submittol to the NRC. He Indicotd that the Technical Specifications should not be submitted any earlier than 6 months prior to fuel load and, based upon NRC estimates of the GGNS schedule, he felt a submittal in 1980 would be too soon.
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- 3. Becouse of the significant changes which had occurred in the Stondord Technical Specifications; Bechtel & CE were asked to supply odditional input ond review the draft GGNS Technical Specifications in time to supply another dro.'t of the CGNS Technical Specifications by July of-1979. Because of the. problems experienced of LoSolle, Bechtel ond_GE were directed for the first time to supply their input in the form of marked-up STS poges. It was in-this draft that MP&L changed the format from o com-pletely retyped Technical Specifications to o mark-up of the STS. The mark-up was based on the latest draft copy
. of the STS provided by the NRC in Janvory of 1979, which was effectivel did, however,reflect y still the a Mark ~l STS. The theSTS used had by MP&L changes which NRC proposed in September, October, November and December of 1978.
- 4. At the July 10, il meeting of BWR6 Technical Specifico-tions Review Group, M.P&L presented the following ;
schedule for the Technical Specifications:
- a. July 1979 -' resolve comments and complete new draft of GGNS Technical Specifications.
' b. October 1979 - using the Bechtel, GE, and Review Group comments and the new STS Revision 2, com- -
plete o second draft of GCNS Technical Specifico-tions.
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- c. January 1980 - revise the GCNS Technical Specifi-cotions os necessory due to changes in the STS and complete the submittol pockoges with justification for changes from the STS.
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- d. March 1980 - submit the final CGNS draft Technical Specifications to the NRC for review and opproval,
- e. October 1980 - NRC opproval of the Technical Specifications and fuel food.
i S. Bechtel input to the GGNS Tech Specs was supplied on i
July 9,1979 (MPB-79/0042). GE Input would not be provided until-September of 1979 and would be in the
- form of a revised STS submitted to the BWR6 STS Review Group.
- 6. Internally, MP&L went through of feest four rewrite and review cycles during this period in order to develop the draft Tech Specs by the end of the year. The efforts were all coordinated by the Plant Stoff Technical Support Section and involved extensive review by Operations, Maintenance, HP/ Chemistry, and Startup.
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- 7. At the July 10,. Il meeting of the BWR6 STS R2 view Croup the -following major generic BWR6 issues were identified os priority issues requiring resolution for the BWR6 STS:
- a. Section 3/4.6 - Containment Systems
- b. Section 3/4.4.5 - Specific Activity
- c. -.Section 3/4.8- Electrical .
- d. Section 3/4.1.3 - Control Rods
- e. . Section 3/4.4.I - Recirculation Systems
- f. : Section 3/4.1.1 - Shutdown Morgin
- g. Section 3/4.4.2 - Sofety Relief Volves .
- h. Section 3/4.3 - Instrumentation
- 1. Radiological E f fluent Technical Specifications
- 8. The BWR6 STS Review Group objective was to resolve these generic BWR6 issues with the NRC .before Dr.
Bottimore issued the GCNS " proof and review" copy for review. This way, only specifle GCNS Issues would have to be token up with the NRC during their review process.
The NRC was contacted and made aware of the fact that the group was preporing a position on these generic issues and would like to meet with the NRC to resolve them.
The NRC was receptive, but felt their priority was on BWR5 STS and review and opproval of the LaSalle Technicol Specifications. -
- 9. In June,1979, responsibility was assigned to o consultant (Ron Williams, from NSC/Ovodrex) working under the direction of the Operations and Mointenance Superinten-dent (Assistant Plant Monoger) to coordinate the final review ond.opproval of GGNS Technical Specifications and establish a plan for developing surveillance procedures and controlling the Tech Specs /surveillonce procedures such that changes to the Tech Specs would be reflected in the surveillonce procedures. The consultant was o previously degreed SRO Senior Operations Engineer from Commonwealth Edison Co. (Dresden 2,3) with many .
years of BWR operations experience.
- 10. In August of 1979, several key monogement positions and organizational changes occurred which had some impoet on the Technical Specifications and surveillance proce-dure effort. The Operations and Mointenance Superinten- -
dent was promoted to onother position in the Corporate office. The Operations Superintendent was promoted to the Monoger of Sofety and Licensing position in the Corporate office. At this time, it was felt that the basic draft Tech Specs had been developed by the Plant Stoff and most of the remaining octivity with the Technical Specifications would be between the NRC and MP&L S
Licensing along with support from Plant Stoff, GE ond Bechtel. Therefore, it was agreed by the Plont Monoger and the #,onoger of Sofety and Licensing that responsibi-lity for the Technical Specifications would shift to the Licensing Section. The Plant monoger felt that this was oppropriate, since the Monoger of Sofety and Licensing
. had been instrumental in the development of the
~ Technical Specifications, knew the'GGNS design well, and most of the future activities would involve licensing. In cddition, this would relieve his personnel and allow them to concentrofe on the surveillonce procedsres, it was egeed that the Monoger of Sofety and Licensing would
' ossure oppropriate review and opproval of Technical Specification changes by Plant Stoff. Primary responsibi-lity for the surveillonce procedure effort shifted from Operations and the Operations and Mointenance Superin-tendent to the Technical Support Section on plant stoff.
1980 As o result of delays in projected fuel load date for Grand Gulf Unit I, the proposed dote for' submittal of the GGNS Tech Specs was delayed until the end of ,
1980. As c result, the following activities took place: ,
- 1. A meeting of the BWR6 STS Review Group was held in Morch 1980, in order to review and resolve comments on significont changes to the STS proposed by GE. In addition, the group met with Dr. Bob Bottimore of the NRC to discuss plans for review of the proposed STS and otso the NRC review of the GGNS plant specific Tech Specs to be submitted later in the year. At the meeting, Dr. Bottimore said that his plans for the upcoming year were to issue the " proof and review" copy of the LoSolle Tech Specs in the summer, to issue o Revision 3 to GE STS for BWRS by the end of the year and to issue o droit copy of the BWR6 STS.
- 2. A droft copy of the upcoming STS Revision 3 (marked
" proof and review" March 1980) was provided to MP&L
. and other members of the BWR6 Standard Review Group.
Thspose _of Revision 3 was to incorporate BWR5 feotoree and therefore.hrthe-fg' 11 g Lnibse T of~the~
NRC's proposed upgr_ade. Dr. Bottimore indicated that he%reciated the input for the BWR6 STS since it was his intent to issue o draft STS copy opplicable to the BWR6 by the end of the year. However, because of his heavy work food he probobly would not have much of a
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s
chonce to incorporate the' Owners Group input. He indicated that the NRC version should resolve most of the BWR6 issues. He odvised GGNS to submit a marked-up version of the lotest STS provided from his office and that os he reviewed the Owners Group input and mode changes to the BWR6 STS droff copy he would provide those to
_ MP&L for incorporation into their Tech. Specs. It was at
. this point that several copies of the STS and GGNS Technical Specifications be'gon cireviating.-
- 3. A proposal was mode by the Owners to the NRC to rewrite the STS in order to make it more useable' by the operofions and maintenance personnel. Dr. Bottimore indicated that any ottempts to change the FordiTg in" tee 575Ewould be'u~noccebtable since this was a legal docu-ment the N _RC.thoThod been carefully reviewed and opproved by
- 4. By May 17,1960, MP&L had prepored another draft of the GGNS Technical Specifications based on Revision 2 of the STS. It otso reflected changes identified in the March 1980 STS " proof and ' review" copy and incorporated . ~
additional Input from CE ond Bechtel. The GE Input was specificolly tailored to GCNS for the first time.
S. In July of 1980, offer odditional internal review by MP&L, .
o_pr_opose!LdmfLof the GCNS Technical Specifications dole.d Moy.19.JP80 was issued to oli of the util_ities.In_the BWR6.S_TS_ Review Gr_qvpuGE, and Bechtel for a final _
review, in addition, this copy of the Technical Specifico-tions was issued to all Plant Stoff sections for o thorough final review ond comment prior to NRC submittal.
- 6. Bosed on a mid 1981 projected fuel food date, the NRC had requested submittol of the draft GGNS Technical Specifications by October 1980.
- 7. The LoSolle draft " proof and review" copy of the Tech Specs was issued by the NRC on August I,1980 this copy of the Tech Specs went through approximately 25 revi-stons from this period through January of 1982.
- 8. In September of 1980, Dr. Bob Bottimore informally sent to MP&L o copy of a proposed draft BWR6 GE STS dated August 25, 1980 for use in completing GGNS plant specific Tech Specs.
I 9. In November of 1980, Dr. Bottimore ogoin informally sent I
o new BWR6 GE STS which changed the STS he had sent l so MP&L in September.
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- 10. - As o result of these changes by the NRC, the submittol of
~ GCNS Tech Specs was delayed to December of 1980, in order to ossure that the lotest guidance from the NRC was incorporated prior to submiltol. On December 15 1980,' MP&L submitted the. proposed GGNS Tech Specs, and indicated that It was based primority on Revision 2 of
- the STS since_this was the only formal revision issued by
- . the NRC of that time. Actually, MP&L included the NRC Revision 3 features they ogreed with and omitted those that were unocceptoble, or proposed on olternative.
1 1.- In December 1980, the NRC issued Revision 3 (BWRS) to .
. NUREG-0123 GE STS which superceded Revision 2.
- 12. Throughout this period,- GE was working.with the NRC relatively independent of the Owners on BWR5 ond 6 STS.
Dr. Bottimore received the input from GE, changed the STS if it was occeptoble to the NRC and then informally sent changed pages to the owners.
- 13. Although earlier efforts had been initiated to develop the surveillance procedures, very little work had been com- .
pleted. Because of the relatively final status (as MP&L thought)of the GGNS Tech Specs and the impending 1981 fuel food date, o progrom was initiated by MP&L to complete the surveillance procedures. A consulfont *
(Quadrex) with approximately 20 engineers and procedure writers was contracted to complete the surveillance pro-cedures. The initial drafts of most of the surveillonce procedures were compteted in mid 1981.
! 1981 4
The primary objective of the Technical Specifications effort in 1981 was to complete negotiations with the NRC, resolve all Technical Specifications issues, and gain NRC opproval of the Grand Gulf Technical Specifications. As a result, the following major octivities occurred:
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- l. By the time Grand Gulf submitted their Technical Specifi-cations in December,1980, the BWR6 STS Review Group hod completed most of its activities and no longer func-
. tioned as on estoblished owners group.
- 2. Because of the potential for a significant number of changes during NRC review and the fact that the surveil-lance procedures were under development, odditional pro-8 i
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4 cedures were put in ploce for controlling the Technical Specifications. An M.P&L contract engineer in the Licen- ~ '
sing Section was assigned primary responsibility for con-trolling Technicol Specification changes. This individual performed two functions: 1) to odministratively trock ond control chenges and insure the proper review ond
, opprovols, and 2) to perform on initial technical licensing review. A similar position was established ,within the Plant Stoff Technical Support Section (Licensing Coordinator) to receive proposed changes from Licensing to ossure proper Plant Staff review ond opproval, and to receive opproved Plant Staff requests for changes and tronsmit them to Licensing. ;
- 3. During.1981, os a result of submittal of the Technical Specifications to the NRC, the MP&L Licensing Section controlled the Technical Specifications by use of a moster copy. The master copy was dated and o log was kept for oil proposed revisions to Technical Specifications. Any
' proposed changes re eived by the Plant Staff were re-viewed by the Licensing Section and submitted to the NRC. Any proposed changes received from GE, Bechtel, -
or the NRC were sent to the Plant Stoff for review. Any changes proposed by the NRC or " proof and review" pages received by the NRC were reviewed by Plant Stoff and Licensing ond, if opproved by MP&L, the changes were -
dated and incorporated into the moster copy. If the '
changes were not opproved, then alternative specifico-tions were proposed to the NRC.
- 4. The NRC did not really look of MP&L's submittal of their Technical Specifications submitted in December of 1980; they were octively involved in the review and opproval of the LoSolle Technical Specifications. In April 1981, offer i o review by Bechtel and on internal review by the Plant Stoff, the Radiological Effluent Technical Specifications were submitted to the NRC.
S. In May 1981, the NRC provided MP&L with their version j (o droit " proof ond review" copy) of the Grand Gulf plant i Technical Specifications which was primarily a version of the BWRS STS that hod been revised to reflect the issues which hod been oddressed on the LoSolle Plant. MP&L p told to mark-up the proposed Technical Specifications and submit them to the NRC by the second week of June, -.
j 1981. !
4 Based on on initial review of the NRC transmitted Tech-nical Specifications, it was obvious that they had not ;
incorporated much, if any, of the previous CE input for BWR6 STS or input from the MP&L proposed Technical 9
Specifications. . There were many additional items and changes which were obviously a result of the LoSolle Technical Specifications review effort by the NRC.
- 7. On June 26, 1981, offer o review of the NRC proposed Grand Gulf Technical Specifications by Bechtel, GE, MP&L Plant Stoff, and MP&L Licensing, the MP&L-approved second draft of the Crond Gulf Technical Spect-
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fications was submitted to the NRC. All the changes over the previous draft were indicated by margin bors and the NRC was requested to please use this type of identifi-cotion for subsequent proposed revisions (this was usually not done by the NRC).
- 8. On October 7 and 8,1981, the NRC held a meeting with MP&L ct the Crond Gulf Nuclear Station to discuss the proposed Technical Specifications with the MP&L Licens- ~
ing group and primarily the MP&L Plant Operations stoff.
The objectives of the meeting were to discuss MP&L's requested .Technice' Specifications changes and .to identify the issues which would require resolution, os well .
os those items which the NRC would not opprove. for the -
4 Crand Gulf Technical Specifications. In addition, the NRC wanted to ossess the Plant Stoff's involvement in the Tech Specs.
9., Consultant support for surveillonce procedures was reduced in the fall of 1981 to one o'perations and two maintenance (l&C) procedure writers to complete oddi-tional procedures and subsequent revisions to the dures (normally done by Temporary Change Notices)proce-
- 10. By the end of 1981, MP&L had requested odditional reviews by Bechtel ond GE in order to assure the occurocy of the Technical Specifications and to finotize the Techni-i col Specifications to the maximum extent possible. Most of the tables and setpoints were blank since this informo-tion was not available when the Technical Specifications were submitted. At this time, fuel fooding was scheduled for early to mid 1982.
1982 MP&L was scheduled to food feel in early to mid 1982 ond the objective of the Technical Specifications effort was to resolve NRC open items, complete oli the setpoint calculations, complete the tables and gain NRC opproval of the Grand l Gulf TechnicalSpecificotions.
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- 1. In early 1982, Bechtel and GE were requested to finotize the instrument setpoints and to comptete the tobies in the Technical Specifications. These changes, as they ~were received, were sometimes sent to the NRC by formal. !
. letter, but more usuolly sent informo!!y to Dr. Bottimore, who preferred it that way.
- 2. In Jonvorh 1982, the NRC informally fronsmitted MP&L's
" proof ond review" Technical Specifications for final review.
- 3. In early 1982, MP&L Licensing requested one final review .
of the Grand Gulf Tech'nical Specifications and indicated to the plant operating organization that the FSAR ond Technical Specifications would be finalized follo' wing this 4
review ond comment resolution in order to obtain a final copy that the NRC could print for issvonce in the operating license.
- 4. Because the final proof and review had to be " frozen" to ollow printing, the NRC was very reluctant to make any additional changes. For the most port, change requests
- were sent to the NRC and new NRC opproved pages were not sent boek to MP&L Indicating their disposition.
Therefore effectively MP&L did not know until receipt of the ope, rating licens,e if the many changes requested in .
the lost several months prior to receipt of the operating license on June 16,1982, were mode by the NRC.
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- 4. Just prior to the receipt of the operating license (within
- one week before OL issuonce), several changes requested by the plant staff os o result of their ongoing work at the site to close out all remaining items for fuel fooding were requested by MP&L and subsequently mode by the NRC.
- 5. Upon receiving the operating license, the plant staff was requested to review the Technical Specifications in order to ensure their occurocy and oppropriateness, since many of the changes requested in early 1982 and just prior to licensing may not have been incorporated by the NRC.
This review, however, was never formally conducted and discreponcles in the Technical Specifications and surveillance procedures were identified during fuel
, _ looding and low power physics testing as attempts were mode to use them.
m ATTACIDiDsT 3 TO AICM-84/0375 ADDITIONAL INFORMATION ON TECENICAL SPECIFICATION DEVEI.OPMDT.
I. OVERVIEW OF APPROACH 1, early 1977, when MP&L initiated efforts to develop CCNS Technical Specifi-
- cotions, the tosk oppeared to be formidoble. In the early days of the GGNS project, the operations experienced resources were limited, and the guidonee from the NRC was outdated and two BWR product lines removed. As a result, MP&L, in conjunction with other BWR6 owners, General Electric and Bechtel, determined that the best opprooch would be to pull together the best operations experience ovoilable to the BWR6 pfants. This effort would not only provide voivable Irput to a set of Stondord Technical Specifications, it would o!!ow on efficient use of utility resources to resolve all generic issues relative to the
. BWR6 Technical Specifications such that when individuol plants submitted their plant specific Technical Specificctions, only issues relevant to that plant would have to be dealt with for the NRC review. The early opprooch of the BWR6 STS -
Review Group was to develop a completely new retyped version of the STS.
However, as indicated previously, based on direction from the NRC In'1979, rather than develop o BWR6 specific STS, the Review Group was required to rnork up a previously issued version of BWR3/4 STS.
The BWR6 STS Review Group interfoced informo!!y with the NRC (Dr. Bob Bottimore) and during the initial efforts discussed their prons and objectives with the NRC. The NRC Indicated their receptiveness to receiving the input from the BWR6 STS Review Group. Once the Review Group had completed most of its l work toward developing a BWR6 STS, the Intent was to meet with the NRC as I necessory to resolve generic issues until a final BWR6 STS had been developed
.. and ogreed upon between the Review Croup and the NRC. .%
MP&L's opprooch to developing the GCNS specific Technical Specifications involved using the Review Group's basic BWR6 STS document and revising it as necessory for plant specific opplications. Since most of the operations expertise i existed on the Plant Operating Stoff, it .wos the responsibility of the Plant i
i e#
1
Operating Stoff to develop the Initial set of CCNS Technical Specifications until submittal of the document to the NRC. Following submittol of the Review Group's BWR6 Stondord Technical Specifications, MP&L Intended to submit its GGNS Technical Specifications, providing at least one year for NRC's review and resolution of issues since it was the leod BWR6. Following submittal of the GCNS Technical Specifications, it would be MP&L Licerning's responsib*ilitieslo l negotiote the issues with the NRC using the expertise of the orchitect/ engineer and NSSS vendor, os well as the operations expertise of the Plant Operating Staff
~
os necessary. An internal set of, Technical Specifications, controlled by the Licensing Section, would be used as the base d>cument for developing surveil-foxe procedures and training operofors. This wovfd prevent use of out of date revisions to the GCNS Technicot Specifications. .
This opprooch,' olthough logical, did not occount for the number of proposed Standard Technical Specifications issued by the NRC during the process. .With the number of Technical Specifications changing so rapidly during the critical sfoges of preparation for fuel food, it is not oppropriote to expect any system to
- odequately control and distribute the proper version of a specific Technical -
Specification of any one porticular time. In addition, because of a number of design changes to the plant in the late stages of construction resulting from
- Thrie Mile Island, other new regulatory issues, and design problems found during preoperational testing, much of the plant specific design information necessory to complete the Technico! Specifications, including setpoints, was not ovoilable until very late in the development process. It was not anticipated that this ,
information would be available until such a late dote. In order to control the review ond revision cycle and assure the odequate reviews and opprovols from the Plant Operating Stoff, Licensing assigned on Individuct on the Nuclear Safety Stoff responsibility for trocking and coordinating the review ond opproval for oli proposed Technical Specification changes from MP&L or the NRC. In oddition, o focal point for Plant Operating Staff Interfoce was established as the Licensing Coordinator in the Plant Technical Support Section. During this period of significont chonges to the Technical Specifications, much of the Interfoce with
~
! ine NRC was through Informo! chonnels.
2 l
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- 11. QUALIFICATIONS OF PREPARERS AND REVIEWERS -
l DAing the initial sfoges of development of the GGNS Technical Specifications and the BWR6 Review Group, the effort was predominantly handled by the MP&L Plant Operating Stoff. The Technical Superintendent was responsible for developing the GCNS, Technical Specifications. The Technical Superintendent was a degreed nuclear engineer who had been 6 reoctor operdtor In,the nuclear .
novy, with rnany years of novel operating experience. He assigned primary responsibility to two of his engineers, both of whom hod been involved in the GGNS project since' its early days. All three of these Individuals had been through the initial portions of the GGNS operator cold licensing training progrom which included certification as on SRO at the Dresden simulator. In addition, the Operations Superintendent and the initial Shift Supervisors were Intimately
! involved in the review of the proposed GGNS Technical Specifications. The Operations Superintendent had been previously qualified as on Engineering Officer of.the Watch and a Shift Supervisor at a ncvol prototype, and had otso had been through the operofor cold licensing training program which included certification as on SRO of the Dresden simufotor.
in early 1979, o BWR operations experienced consultant was contracted by Plant Stoff from Nuclear Services Corporation (Ron Williams). This consulfont had been on SRO licensed senior operating engineer at the Dresden 2/3 plants and hod many years of BWR operating experience. His Initial responsibilities involved working for the Operations Superintendent to review the Technical Specifications and to develop the Operations Section surveillonce procedures.
Shortly offer his initial efforts, he was assigned responsibility by the Operations and Maintenance Superintendent for Initiating the surveillance procedure deve-lopment efforts and developing a Technical Specification /surveillonce procedure cross reference matrix.
' .. As indicated previously, in tote 1979 contrel of the TechnicoLSpecifications was shifted to the Corporate Licensing Section. In 1980 when the Technicoi Specifications were changing very ropidly due to'chonges in the base STS
- documents, the Licensing Section contracted with a BWR experienced consulfont from EDS Nuclear who hod several years of BWR engineering experience with Georgio Power Company. His responsibilities included initial technical review of the proposed revisions to the Technical Specifications from either MP&L or the NRC, providing recommendations on the disposition of such changes, and
U obtaining the necessory reviews and opproval of the Plo'nt Operating Stoff, Bechtel and General Eleetrie. This consultont worked directfy for the Supervisor
. of Nuclear Sofety _who reviewed all of his recommendations and work efforts.
The Supervisor, Nuclear Sofety was a degreed nuclear engineer (MS Nucleor Engineering) with over il years of engineering and licensing experience in BWR l and PWR designs. The 5vpervisor, NucIeo~r Safety as weil os the Monoger, Sofety l c-d Licensing (over 8 years engineering, operations and licensing experience in PWR and BWR designs), who had previously been the Operations Superintendent on the Plant Operating Staff, were both Intimately involved in the development, review and opproval process.
In mid-1981, when the NRC directed M.P&L to resubmit a complete new set of Technical Specifications, another controcted engineer was esiigned responsibility for assisting in the coordination of the Technical Specifications revision effort.
From that point on, this consultant, who bod many years of predominontly PWR engineering experience (some BWR engineering experience), was ossigned responsibility to odministratively control the Technical Specifications in the Sofety and Licensing Section. In this role he interfoced with the Plant Stoff ,
Licensing Coordinator who otso octed in on administrative copocity to obtain the
- - necessary reviews and opprovals of the Plant Operating Staff of any changes requested by the NRC or MP&L.
In the lotter portions of the Technical Specifications development effort and during the lost two years prior to receipt of on operating license, several personnel with BWR operations experience were odded to the Plant Operating Stoff. The Assistant Plant Monoger, Nuclear Support Monoger, Operations 1
Superintendent, and several shift supervisors were previously SRO licensed and possessed several years of BWR operating experience. During this period of time it was the responsibility of the Licensing Coordinofor and the Plant Operating Staff to obtain their review and opproval of proposed Technicot Specificotton changes.
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Exhibit 2
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' .,' f "E":U.',DUM FOR: . Victor Stello, Jr.
Deputy Executive Director for Regional Operations and Generic Requirements Office of the Executive Director for Operations FROM: Harold R. Denton, Director Office 'of Nuclear Reactor Regulation 5;i'E;T:
-REVISION 4 TO GENERAL ELECTRIC STANDARD TECHNICAL SPECIFICATIONS (GE-STS)
In accordance with your expressed desire to. review changes to the Standard Technical Specifications and with my comitment to submit them to you and the Comittee for the Review of Generic Requirements, I am enclosing for your consideration Revision 4 to ths '. -STS (NUREG-0123) as Enclosure 1. .
For clarity and ease of use, the GE-STS has- been divided into three volumes.
Volume 1 is applicable to the BWR/4 product line, Volume 2 to the BWR/5 product line and Volume 3 to the BWR/6 Droduct line.
All of the significant changes in Revisionk to the GE-STS were reviewe'd and approved by the staff during the licensing reviews of Susquehanna-Unit 1 (BWR/4), LaSalle-Unit 1 (BWR/5) and Grand Gulf-Unit 1 (BWR/6). In addition,
-Prcof and Review copies of all three volumes of Revision 4 to the GE-STS were reviewed by the staff in September and October 1982.
Encicsure 2 is a summary of the significant changes between Revision 3 and Revision 4 of the GE-STS.
Enclosure 3 is a discussion of the impacts associated with the changes made in the GE-STS between Revision 3 and Revision 4.
Draf t copies of Revision 4 to the GE-STS have been provided to General Electric Company and the anticipated users (Fermi-Unit 2, Shoreham-Unit 1, Zimer-Unit 1 Washington Nuclear-Unit 2, and Clinton-Unit 1) for their review and comments. My staff has been orally informed by representatives from General Electric and these users that Revision 4 is useful, presents no problems, and that they are using it to prepare the technical specifications for these units.
We believe the information provided herein and the enclosves are responsive to ycur request and that a CRGR briefing on this matter is not necessary.
However, if after reviewing the enclosures you still would like to discuss this atter, we will schedule a CRGR briefing at the earliest practicable time. In that event, we would appreciate being informed in advance of areas you wish to explore further so we can arrange for the appropriate staff to be present.
....~n_.
Enclosure 1 to Exhibit 2
4 -
- Victor _ Stollo, Jr. -
?.
' We rsquest and reconnend 'your approval to. publish, distribute and use Ree sion 4 to the GE-STS. - Please. let c.e know if CRGR desires to review part or _all of the revisions.
Harold R. Denton, Director Office of Nuclear Reactor Regulation Enc 1csures:
. 1. GE-STS Revision 4; Volume 1-BWR/4,
clune
. 2-BUR /5, Volume 3-BWR/6 2.- .Significant Differences Between GE-STS Revision 3 and Revision 4
- 3. : Impacts Associated with GE-STS Revision 4
~ c'c ' w/e nc1 osures:
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Enclosure 2 31G'.liitA.; tIFFEFi!.'LS LETWEEN -
GENEDat EEECTD!C Po!L!ve, WATED oraCTOR STANDARD ,
- TECHNICAL SDECIF];ATIONS (NUREG-1023)
REVISION 3 AND REVISION 4 The following changes represent the significant changes which have been made.
since-the issuance of Revision 3 of NUREG-0123 in December 1980. In addition to the following' changes, there were a number of other minor changes made to ccen:t editorial errors, clarify technical specification intent, reorganize
, specifications .and provide consistency of technical specification content
.thr:.ghout the .GE Standard Technical Specification. These minor. changes are not considered to be _of significance, and, therefore, they are-not' included
--in the follo. ing listing. In addition, separate GE-STS have been developed for the BWR/4 and BWR/6. GE-STS Revision 3 represented only the BWR/5 prod-uct '.ine.
The technical specifications are not used as a vehicle to require plant modi-fications but rather are used to provide assurance that plant features that already exist and for which credit has been taken in the safety analysis are ma inJained operable. GE-STS Revision 4 includes surveillance requirements for periodically demonstrating the operability of these plants features.
These surveillance requirements do not require plant shutdowns solely for their performance. For those surveillance requirements that require the plant to be in a shut down condition, their required f requencies -are such that all of these tests can be performed during refueling outages. Con-se.p.-ntly, the traditional method ,of considering cost-benefit, i.e. , cost of equipment, installation, downtime and maintenance vs. safety benefit achieved by the equipment modification, is not applicable.
A. - Defini t. ions 1
End-of-Cycle Recirculation Pu: p Trip System Response Time Change: Revised definition to include commonly used alternate requirements for measuring E0C-RPT response time.
Justification: Include previously accepted alternate requireraents.
- 2. Fraction of Limiting Power Density, Fraction of Rated Thermal Power, Core Maximum Fraction of Limiting Power Density Change: Added definitions for comonly used alternate terms in APRM Setpoint specification. .
Justification: Include previously accepted alternate terms.
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E. .{y:tien3and4: L i?.i tir.- C:ndi tiert fer- O,' eratiqr._ ard Surveillance *
- q;ui rerents l.- 3/4.1 Reactivity Control Systems
.a. 3/4.1.3.1 Control Pod Operability, ~3/4.1.3.2 Control Rod Maximum Scram insertion Times, 3/4.1.3.4 Four Control Rod Group Scram Insertion- Times, 3/4.1.3.5 Control Rod Scram 5::u ul: tort. 3/4.1.3.5 Ccrtrol Rod 0-is e Crueling, and 3/4.1.3.7 Control Rod Position Indication Change: . Provisions of-Specification 3.0.4 were made not appli-cable to these specifications so that entry can be made into the applicable Operational Conditions when the conditions for the Limiting Condition for'0peration are. not cet because of an inoperable control rod (s), provided that no_ control rod is stuck or untriopable, that the applicable Action (s) is satisfied, and not more than a total of 8 control rods are inoperable.
Justification: Analyses of operation in the startup ' domain include the effect of inoperable control rods.
- 2. 3/4.2 Power Distribution Limits ,
- a. 3/4.2.2 APRM Setpoints _ f-Change: Revised requirements to include commonly used alternate terms and limits.
, Justification: Include previously accepted alternate terms and limits.
- b. 3/4.2.3 Minimum Critical Power Ratio
. Change: Added alternate Specifications for use of ODYN Option A and B.
Justification: Include previously accepted alternate methods.
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B. Sec tic 9 ;3;a,nd 4:
- Limitino Conditionc For Oreretien and Surveillance -
- 3ajp_r cynts (Conti,.ed)
- 3. 3/4- 3 ' Instrumentation
- a. 3/4.3.2 Isolation Actuation Instrumentation Channe:
Delet:d re?sirena t to me.2sure isolation instrumentation-response ti e wher. inrtr:mantatic- res rnse tine is not considered in tne safety analysis because of the assumed diesel generator starting and secuence loading delays.
Justification: The instrumentation-response time is a very small ~
f raction of the assumed aiesel generator delays and is not assumed in the s:fety analyses.
- b. 3/4.3.7.1 Radiation Monitoring instrumentation Change: Revised typical instrumentation requirements -per comments of Ef fluent Treatment Systems Branch.
Justification: Make consistent with ETSB requirenents.
- c. 3/4.3.7.5 Accident Monitorir.g Instrumentation F
Change: Added new requirements for operability and surveillance of containment gross radiation monitors and high range noble gas effluent monitors.
,Justi fication: NUREG-0737 itans 11.F.1.1 ano ll.F.1.2.
- c. 3/4.3.7.10 Fire Detection Ijrs_trucentation Change: Revised requirements to list total nancer of instruments,-
to cover inoperability of aJjacent instru ents, ann .o delete the requirement for a Special Report if requireo instr. mentation is inoperable for more than 14 days.
Justification: Better identify tne required instrumentatior, ano Action recommended by the Chemical Engineering Branch.
- e. 3/4.3.7.11 Loose-Part Detection System Change: Added Specification.
Justification: Regulatory Guide 1.133, " Loose-Part Cetection Program.for the Primary System of Light-Water-Cooled Reactors,"
l-lay 1981.
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- 3. 3/4.4 Reactor Coolant: System', _
' a .- 3/4.4.2.1 Safctv/ Relief Valves T
' C h a :.30:. ..odec~ Au tion s:stement' and Survcillar.ce Requircr.:;nts -
fe* :d-t/.?:1'cf vcli: ; c;ition indicati .e c :*aSility. = A<;ded
- Action. state icnt 'for stuck open relief 'v alve.- .
Justification: 'NUREG-0737 item II.D.3.
~~
w b. 3/4.4.2.2 Safety /Relie'f Valves Low-Low Set' Function ~ -
Change: . Added Specification.
Justification: ' Require operability of new jdesign function assumed in safety analysis.
- c. 3/4.9 ' Residual lleat Removal' - 3/4.4.9.1 ' Hot Shutdown and -
3/4.4.9.2 Cold Shutdown Change: Revised to require RHR system'to be in operation.
Permitted operability.of alternate methods of residual' heat
. removal'and coolant circulation.
Justification: Ensure representative reactor coolant temperature ia1ication and ' residual heat ;r. tval c:*oaDility.
- 1. Eaeraency Core Cooling Systems
- a. 3/4. 5.1 ECCS-Operating
~ Cn .%: i. :L ; 5arveillance.Requirerer.:3 ~ ;. r; .:. re t es t i s,: c:
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ADS acce.c.ulators backup compressed sas systc:.; ic.: pres:,urc
, alarm system.
Justification: Ensure availacility cf bacgup to operate ADS valves when required.
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4 B. 0; tion -3 and 4: Limitir.: Ccr.4itions For Opcraticr. and Surveill.r.:e
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1:1.:rements (Continucc)-
o '. 3/4.6 Containnent Systems
- a. 3/4.6;1.8 Oryyell and Suporession Cha :ber Purge System Change: Revised Specification to include purging purpose limit;ticns ard Lraillar.cs r:;;irec;nts f:r lock to tir.g valves with resilient caterial seals.
' Justi fication: Branch Technical Position CSB 6-4. The revised leakage integrity tests s.ith a maxit..am allcwable leakage rate for purge supply and exhaust isolation valves will provide early inoication of resilient n.aterial seal uegradation and will allow the opportunity for repair before gross leakage failure develops.
This revision was the result of numerous reports of unsatisfactory performance of the resilient seats for the isolation valves in
-containment purge and vent lines and was requested by Containment dystems Branch,
- b. 3/4.6.3.5 Primary Containment Isolation Yalves -
Change: Added Surveillance Requirement for traversing in-core probe (TIP) explosive isolation vaTves.
Justification: Ensure ope'rability of isolation valve explosive squibs.
- 7. 3p . 7 Plant Systems
-a. 3/4.7.5 Snubbers Change: Permits snutbers which are inaccessible during reactor operation- to have required visual inspection postponed until next shutdown greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Justification: Deletes requirement for reactor shutdown just to visually inspect inaccessible snubbers.
- b. 3/4.7.7 Fire Suppression Systems Change: Reviseo Action statements of all fire suppression systems to delete the requirement for a Special Report if required equipment is inoperable for more than 14 days.
Justification: The Chemical Engineering Branch recommenaed deletion because the Special Report is not necessary.
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- 7. 3/4_. 7 Plant Systems _ (Continued) l
.c. 3/d.7.8' Fire Dated Assemblics Change: l Revised Specification to ir.clude all fire tuted n ::r.bliet ir::cac of j;-t firc t:r-icr r e ;tre.i- :. Revised Action stater.ent to delete requirerent for a Special Report if-ineferable nore than .14 days. Pcvi:ec 5. .eillar.cc Rcquircnent to permit surveillance of sample of sealed penetrations rather
.than all caled pcnctrations.
Ju3tification: Consistency with IC CFF. E; Arper. dix R and recognize adequacy of' inspection of representative sample of sealed penetrations of same design. The Chemical Engineering Branch recommended deletion of the Special Report because_ it-is not necessary.
- d. 3/4.7.9 Area Temperature Monitoring Change: Identified Specification as optional and changed surveillance interval from 24 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
i-Justification: Specification is not applicable to all plants.
- Surveillance interval was changed to be consistent witn Action statement.
S. 3/4.8 Electrical Power Systems
- a. 3/4.8.1.1 A.C. Sources - Operating and 3/4.8.1.2 A.C. Sources - Shutdown Change: Increasea flexibility for methoc of ciesel generator starting when increased diesel generator starts are required per Table 4. 8.1.1. 2 -1. Revised diesel fuel oil test requirenents.
Justification: Revised diesel generator start methods and diesel fuel oil changes were recommended by Power Systems Branch.
- b. 3/4.8.2.1 D.C. Sources - Operating and 3/4.8.2.2 0.C. Sources - Shutdown Change: Revised Surveillance Requirements for station batteries and Action statement requirement for an inoperable battery charger.
Justification: Incorporated the require ents of IEEE Standard 450 anc revised Action statement required witn a Dattery charger in@erable per reco..nencations of Power Systems Branch.
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- r,ts ' ' :citir.i Ccaditions Fcr OL ration s-c [urveillance u"v.ccl
. 3/4.6. Electrical Power Sys'tems (Continued)
- c. 3/4. 9. d.? Drir3rv' Containment Penetration Conductor uver:.urrent .wrotective Devices
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r i vi r t u ' : tic e state ~i. tc re<1 fr: t'c affe:tec
{rEs -ind cc ponents to be ' declared inoperable when the.
- st:i";t :vt reurrent- pr::ectivc dcvice is ir:;erable, Reviseo Sur'veillance Requirement acceptance criteria for
. circuit Lrc:hcr tc!!ing.
- ,
- , J ~ ; s . c i ut. : Clc .'icoLion vi c;,a ro , i i i tj :, . 6ui. o f affectea systems and components. Surveillance Requirements for ovcrcurrent protective cevices revised per recommendation -
of Power Systems Branch.
- d. 3/4.8.4.3 Motor Operated Valves Thermal Overload Protection Change: Reviseo Specification ~ to include optional aspects of Regulatory Guide 1.106' " Thermal Overload Protection for Electric Motors on Motor Operateo Valves," Revision 1, March 1977. ,f Justi fication: Regula' tory Guide 1.106, Revision 1.
- e. 3/4.8.4.4 Reactor Protection System Electric Power Monitoring Change: Aoded Specification.
Justification: Provide for monitoring of power supply quality to RPS instrumentation.
- 9. 3/4.9 Refueling Operations
- a. 3/4.9.11 Residual Heat Removal and Coolant Circulation, 3/4.9.11.1 High Water Level and 3/4.9.11.2 Low Water Level Change: Revised Specification to require RHR system to be in operation. Permitted operability of alternate methods of residual heat removal and coolant circulation.
Justification: Ensure residual heat removal capability and representative reactor coolant temperature indication.
' . . . Bases for Sections 3.0 and 4.0:
The B:ses .:ere revised to De consistent '..itn the revisions 5.nion were made to their respective technical sp,ecifications.
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TH'CHAN6ES-i]:.Fl"'M-95ffVISION4
-'The-ci...:.;es have beer. cate'.arihv3 to portray the reason for.anc impact of tne : ct.ance, as t ollo-s:
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.c t efint inclusion'of re i..uniy i (f'
- - i cncnts.- No im;2ct is
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.-q as en aitc-native.
. . i .e. r.ts . are still applicehle t
' . - Charige L.4.b reflects ' changes in oesign instituted by the. industry.
i The re::1.=tery pcsit c" crpiisd is t'M 35.ne as for. Revision 3 but 4
the specification changes Lecause of the -design changes. The fr;;;t :cn:4:t:
set fur: tion surveilla~nce req;uirencnts and is estimated at 3504f :.*.;
man-hours per reactor -for 18 month . cycle.
~3 . Changes B. 3. b' g
B .4.c , 8. 7. b, B . 7.c , 8. 7. 0, B.8.c, B.8.d, and B .9.a
.s 1- t rearrangenents and clarifications of the specifications -
based on expericnce in their use. These changes do not make suustantive char.ges in requirements ant: no substantial impact is
' associated.
- 4. Ch:
1.; es B.1. a ,1. 3.a , 6. 3. d. B .3. e , B .!:'. a B .5.b , B .8. a and B .6.e rcflect the addition or nooification of technical specifications-recuirements for ,c'r fornance ch'aracteristics already reflected-in the F5'A and usea in safety analyses. Pequiring in the spc.:i fications Inat these , ceforr;a' cc "haracteristics be main-taine2 opera:le pmvides ircreased assurance of the validity c0 i
th; ::: sty .nal; sis.
Changa 1.2.e
- -:, ires tne Operabil :y ci tl.c loose-part cettctior, sys em. Ine ir ' t of perf orcu- a *n essociateo surveillanct er reactor pt- ' .
". .a 'ig e E . 5. a ^- ; i : s th : !_rveill:r:c of automatic depressurization systc, i ADS) valve accumulator low cressure alarm instrumentation ano the cycle. impact is estinateo at 3o0 uan-nours per reactor per 18 month
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6t q...or.-heu rs per; - root tor. per l J r~n tr. %y :. l e .
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a.. ry.r.ge B.6.e -reflects nw equirements to ensure - the operability of contair.r'ent purge valves, .especially those with resilient
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r.ents is 200 r.an-hours per reactor per 16 month cycle. .
-. . - ' b. Change t:.7.6 reflects a r$lai: tion in the rcquirener.ts for-
- visual. inspection of inaccessible str.6bers so that shutdown will not- be required specifically for; this surveillance,
- c. Change B.B.b incorpcrates the requir3nents of IEEE Standard 45D
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in the Surveillance ~ Requirements for oatteries and changes' the Action'to disa'lew continued operation with an inoperable charger un the basis that the battery is o;. oole. The it: pact-is
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