ML20077P132
| ML20077P132 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/12/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-91-00143, GNRO-91-143, NUDOCS 9108150277 | |
| Download: ML20077P132 (4) | |
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W. T. Cottle August 12, 1991 U.S. Nucleat Regulatory Commission Mail Station PI-137 Washington, D.C.
20555 At t ent.J on :
Document Control Desk
Subject:
Grand Gul f Nuclea r St at.f on Unit 1 Docket No. 50-416 1,1 cense No. N PF-29 Safety System Functional Assessments (SSFAt 1 GNRO-91/00143 Gentlemen:
The Grand Gulf Nuclear Station (GGNS) recently complet ed its third Safety System Functional Assessment (SSFA).
The purpose of an SSFA is to perform an independent and unbiased assessment of selected safety systems to determine if they have been installed, tested, operated, maintained, and managed in accordance wit.h the original design ba-is and applicable regulat ions, standards, and comm i tments.
Assessment act iv i ties are conduct ed under the auspices of the Quality Programs (QP) organizet ten nad an approved procedure.
'Ihn SSFA concept was introduced in August 1988 as a self-assessment program des igond t o examine <a fet y-reintnd syst ems and support systems to det ermine if generic or progrnmmatic deficiencies oxist. that would inhibit t he syst em f rom ful.ctioning as dnsigned.
The SSFA team is composed o highly qualified and experienced GGNS and contract. personnel whose fonetion is t o assess syst em act ivitins in essentlal1y four areas:
design, operations, t.es t i ng, and maintonnnce.
By cnnducting detailod system assnssments, conclusions can be reached on the overall plant design process, operations, and managnmont controls.
Plant documents nasociated with the system and interfacing systems atn reviewed including, design and modification packages, procedures, survn!llances, QP audits, tests, work orders, regulatory documents, c.ommitments, training records, etc.
Thiq allows the SSFA team to become familiar with dif ferent nct ivit ies perforrand on a system in order to determine the overall offectiveness of existing plant programs. A system
" walk-down" is also performnd to veri fy t hat the as-built configuration complies with applicable design docummt s.
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When a weakness'is detected, the team identifies the issue, determines its extent, states'any known requ'rement, i.e.,
regulatory. FSAR, etc.,
discusses the technical aspects, and provides a qualitative comment as to the safety significance.
Deficiencies or-deviations noted during these assessments are promptly identified and processed in accord 9nce mith the
= applicable corrective action program, and in a manner consistent with the safety significance of_the issue.
This information is later compiled, by discipline, and included in a final report that summarizes the assessment scope, schedule of activities, significant findings, observations, strengths, and_ weaknesses.
The final SSFA report is issued to GGNS senior management and a copy provided to the NRC Senior Resident Inspector. The assessment results are discussed with the Senior Resident Inspector who has, in the past, issued Inspector Followup ltems to identify, document, and track the remaining SSFA open items until they are closed.
The first SSFA was conducted August 1-26,.1988 to assess the functionality and operationni readiness of the Standby hiquid Control-System (SLCS). 'The assessment team utilized NRC Safety System Functional Inspection-(SSFI) techniques to assess the system's as-built condition.
Although several concerns worn-raised by the team, they were relatively minor 'in nature or were resolved through the provision of additional-information.
They included areas, such as, design and modification calculation adequacy and retrievability, modification traintig, and
-procedural controls. The team co.icluded that the SLCS was generally well maintained,_ tested, and operated in a manner to assure the system would function as designad upon operator initiation.
A-second SSFA was-performed January _8-26, 1990 on the Fuel Pool Cooling and Cleanup (FPCCU) system. The scope of the u.4essment. included the interface to safety-related systems that support the FPCCH, such as thn pump room ventilation system, leakage detection system, and electrical power to subecmponents.
Of all thn concerns raised during this assessment, one proved to be signi ficant.
It involved the failure to meet a technical speci fication requirement to stroke test a redundant
' Division II solenoid valvo associated with a secondary containment isolation valve. This issum was documented on an Incident Report and subsequently-reported to the NRC via the hicensee Evant-Report (LER) process.
This incident prompted an investigation and review of other test procedures that assured all dual solenoid air cperated valves had been properly tested in accordance with the requirements of the technical specifications. Other concerns of Inss significance were identified and resolved.
The FPCCU was observed and verified _ to be capable of meet ing Its intended safety functions, as-designed.
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August-12. 1991 GNRO-91/00143 Page 3 of 5 Members of the BWR-6 Owners Group sponnot ed, in unison, the four SSFAs scheduled to be completed in 1991. The group's objective is to conduct an SSFA on the same safety-related system at each HWR-6 plant. The informat ion geithered will be shared among the Owners Group members to determine any generic benefits.
It was agreed that Grand Gulf would begin the assesse.cnt cycle for the BWR-6 group.
This assessment,
'ha third for GGNS, was conducted April 22 through May 24, 1991 on
.tigh Pressure Core Spray (IIPCS) and the Division 111 Emergency Diesel t,enerator (EDG) system.
Interfacing systems, such as the EDG cooling system, condensate storage tank, funi oil storage, Division III hattery rooms, etc. were also assessed. General observations were made during this assessment that required minor changes to procedures, FSAR, design calculations packages, etc.
The llPCS system and the Division III EDG were found to be adequately designed and maintained in a manner sufficient to meet its required functions.
We believe that performance of SSFAs has enhanced current programs, along with providing the Quality Programs organization with increased technical knowledge and experience in conducting in-depth, performance-based techniques; thus, improving their overall assessment abilities.
Consequently, we intend to continue our cooperative effort with thn BWR-6 utilities as well-as sharing results with the NRC Senior Resident Inspector on future SSFAs.
We would he happy to discuss our SSFA experiences with you, or provide you with any addit.ional informatian you may be interested in regarding this ;aat ter.
Yours truly, c <O r C w W3C/JSlams cc:
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Mr. D. C. Illntz Mr. J. I.. Mathis Mr. k. D. - Mcticheo j
Mr. N. S. Reynolds-Mr. 11. I..
Thomas
-l Mr.. F. W. -TJ tits Mr. Stewart D. Ebneter Regional Administrator U.S.-Nuclear Regulatory Commission Region'11 l
101 M1rintt.a St., N.W., Suite 2900 Atlanto, Georgia 30323 Mr.= I.. L. K1ntner, Project Manager Office of Nucionr Reactor Regulation U.S. Nuclear ~Rogulatory Commission
-Hall Stop 11D21 Washington, D.C.
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