ML20083M851
| ML20083M851 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/11/1984 |
| From: | Guibert J ABB IMPELL CORP. (FORMERLY IMPELL CORP.) |
| To: | |
| Shared Package | |
| ML20083M842 | List: |
| References | |
| 01-0200-1296, 01-0200-1296-R00, 1-200-1296, 1-200-1296-R, NUDOCS 8404180368 | |
| Download: ML20083M851 (113) | |
Text
{{#Wiki_filter:* o o i l 1 THIRD PARTY REVIEW 0F THE GRAND GULF NUCLEAR STATION TECHNICAL SPECIFICATION REVIEW PROGRM l i Prepared for ! Mr. J. B. Richard Senior Vice President - Nuclear Mississippi Power & Light Company Prepared by Impell Third Party Review Team Mr. John C. Guibert. Project Manager In.pell Corporation 350 Lennon Lane Walnut Creek, California 94598 I I Impell Report No. 01-0200-1296 Revision 0 April 11. 1984 i 8404180368 840416 PDR ADOCK 05000416 P PDR , I J
I t 4 l TABLE OF CONTENTS i f 4 .
' P,, age,
1.0 Purpose and Scope
1 1 2.0 Independence of Impe11 Project Team 2 3.0 Qualifications of Impe11 Project Team 4 4.0 Specific Work Activities 7 5.0 General Programmatic Observations 15 6.0 Programatic Recomendations 17 1 7.0 Specific Observations 18 8.0 Conclusions 25 Appendix A - Resisnes of Impell Project Team Appendix B - General Guidelines for GGNS TSRP Process Reviews i . i Appendix C - Impell Notification Procedtre 1 l 4 Appendix 0 - Impell Notification Sheets 1 1 1 e ]
,t 1.0 PURPOSE AND SCOPE Impell Corporation was requested by Senior MP&L Management to conduct a Third Party Review of the Grand Gulf Nuclear Station (GGNS) Technical Specification Review Program (TSRP). The need for the GGNS TSRP was identified by the Nuclear Regulatory Comission (NRC) in a letter from D. G. Eisenhut to J. 8.
I Richard dated February 24, 1984. In response to that letter, Mississippi Power & Light Company (MP&L) organized a comprehensive review of the GGNS i Technical Specifications to address the identified IRC concerns. As an additional confirming measure, MP&L concluded that an independent third party review would be appropriate. Impell Corporation was contracted for this purpose and commenced work on the Third Party review on March 16, 1984. The i GGNS TSRP had already been initiated and a significant amount of work had i already been accomplished. The Impell charter was to provide MP&L Senior Management with an independent assessment of the effectiveness of the GGNS TSRP, including both the review l process and the results. In assessing the adequacy of the results, Impell utilized two principal criteria: accuracy and completeness. In conducting these reviews and assessments Impell prepared a plan which l , included: i Procedural review I Process reviews Process observations Personnel interviews TSRP documentation reviews As-built docunentation reviews, and an Independent review of selected design features In excess of 700 man-hours of Impell professional staff time were applied to this project. i
! $4 2.0 INDEPENDENCE OF INELL PROJECT TEAM i 1 To ensure the independence and credibility of the Third Party Review the l Impell Project Team reported directly to the W&L Senior Vice-President - Nuclear. In addition, the following measures were taken by &&L and Impell to , ensure independence and objectivity: : l
- Impell independently determined, defined, and implemented the work f
1 activities necessary to accomplish its charter.
- Impell team members had complete access to the personnel, records, and meetings of MP&L and other involved organizations.
Staffing needs for the Impell team were completely at the discretion of the Impell Project Manager. All Impell team members were interviewed to ensure that they had no f previous GGNS involvement. Although Impell Corporation has performed several tasks for W&L and currently have several personnel working in the MP&L Corporate and site locations, the l Third Party Review team members had no previous project involvement with GGNS. I At the time that the Impell third party review conenenced, it was recognized l that the GGNS TSRP was in progress and that it would likely continue to be in progress while the third party review was being conducted. Accordingly, in
.the interest of ensuring the effectiveness of the GGNS TSRP, Impell recommended that any progransnatic concerns identified during its review should be reported on a real-time basis to W&L senior management. This concept was agreed to in advance. The programmatic reconnendations developed by Impell are documented in Section 6.0 of this report.
Specific technical findings related to Impell's review of the results of the. GGNS TSRP were not reported to W&L until the TSRP technical review process hadbeencompleted[definedasfollowingfinaldispositionbytheReview, f i.
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Prioritization, and Direction Group (RPD)]. This approach was taken to ensure the integrity of the independent assessment of TSRP results. These findings were supplied to N&L, in accordance with a procedure developed specifically for that purpose (Appendix C), to ensure that they were evaluated and resolved. ; v . 1 , f
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3.0 IMPELL PROJECT TEAM QUALIFICATIONS i Based upon the diverse nature of this effort, Impell assembled a team of nuclear industry experts whose expertise and experience covered the full range I' of nuclear power plant design, engineering, construction, operations, and regulation with particular emphasis on previous experience with BWR li Technology, Licensing and Operations. The individuals were selected from several of Impell's Regional Offices and represented an average of more than [j 12 can-years of nuclear experience. Impell's Project Manager for this effort was Mr. John C. Guibert who is the company's Manager of Nuclear Safety and Licensing. Resumes for the members of the Impell Project Team are provided in Appendix A to this Report. The Imp.111 Third Party Review project organization chart is provided as Table i 1. A sunnary listing of the qualifications of each team member is provided in Table 2. l 4 s - i s e W n 3 '1 4
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l i l Table 1 Impe11 Project Organization < , a f" i Senior Vice-President ! Nuclear l 6 1 ' ' J. 8. Richard r Impell Project Manager J. C. Guibert .k Impell Staff D. Timins .I!
'i J. Skolds E. H.'Verdery . ,
G. Weber J. Ogawa A. Miller R. Machon , y
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Tchia 2 , l l-Summary Listing of Project Team Qualifications YEARS INDEPPEDEFT
, DESIGN NUCLEAR-INDUSTRY OPERATIONS LICENSING RECULATION TESTINC DESIGN CONSTRUCTION EXPERIENCE NAME REVIEW /QA X X 14 D. F. Brosnan X -
X X 9 P. Cortland X -X X 17
'J. C..Cuibert X X Y 13 R. D. Nachon X X 13 A. D. Mille, X X X 10 J. A. Ogawa X X X X 12 J. L. Skolds X ,
X X X X X 15 D. C. Timmons X X X X 17 E. H. Verdery X I X 9 C. Weber Total Experience 129 4.0 SPECIFIC WORK ACTIVITIES .I The following is an a summary of the major Impell work activities performed during the Third Party review effort: i 4.1 TSRP Procedure and Process Reviews
- a i At the onset of the Third Party Review project, an assessment of MP&L's i governing procedure (TS-1, Rev.1) for the TSRP was conducted. This
! included interviews with all key participants responsible for l' implementing the program, real-time process observations through attendance at working meetings, and documentation reviews. i+ Based upon this procedural assessment, Impell concluded that the governing procedure was adequate and that it was being effectively
- i implemented by participating organizations. A few potential programmatic l weaknesses were identified and were communicated to W&L senior -
,.I- management on a real-time basis. These recommendations are described in Section 6.0 of this report. ' In addition to the above-mentioned procedural assessment, the-third party review effort included more-detailed evaluations of the individual elements of the TSRP implementation process. Appendiz, 8 provides the
, general guidelines utilized by the third-party review team in performing these reviews.
- Specific reviews were conducted to evaluate the activities ano
- results of the three principal groups conducting the first-level i
i reviews (i.e., the ADMIN group which was responsible for TS Sections
- 1.0, 5.0, and 6.0; the RETS group responsible for all TS related to radioactive effluents and radiological environmental monitoring; and
. the NSSS/ BOP group which was responsible for Section 2.0 and most of Sections 3.0 and 4.0 of the TS). i
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- Reviews were conducted of the documented results of the three groups
! providing principal input to the NSSS/B0P group (i.e., Bechtel Power Corporation, GE on-site at GGNS, and GE at San Jose). These reviews included: TSRP package reviews, interviews, and a visit to GE's San Jose office.
i - A review was conducted of the activities and results of the Review, Prioritization, and Direction (RPD) group which was responsible for the final review of TSRP packages, disposition of program results, and prioritization of activities (i.e., TS changes) resulting from the TSRP. The review included documentation reviews, process observation, and interviews. I 1 The observations and conclusions resulting from these process reviews are I sumarized in Section 5.0 of this report. Additional back-up information l
; I ! exists in Impell's project file for the Third Party Review project, and is available upon request.
Ii 4.2 Impell Independent Review of Selected Design Features { At the onset of the Third Party Review project, it was recognized that [ the TSRP was particularly well-constructed to ensure the accuracy of the I GGNS Technical Specifications and to ensure that the level of detail of
, the GGNS Technical Specificaions was/would be* commensurate with current
, industry /NRC practice. It was also recognized that the TSRP was constructed in sucn a manner as to provide reasonable assurance that the l GGNS Technical Specifications were/would be complete (note: in this context "ccmplete" refers to inclusion, at an appropriate level of I detail, of Technical Specifications related .to design features, and associated parameters, which are unique to GGNS). To provide an
]! additional level of confidence in its assessment of.the " completeness" of .- {
the GGNS Technical' Specifications,'Impell performed an independent assessment of a representative sample of unique / plant-specific GGNS l; design features to verify that they were/would be appropriately reflected in the GGNS Technical Specifications.. l.
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l j Impell conducted an independent technical review of eleven design ,! features that were either unique to the GGNS/8WR-6 design or which were judged to be potentially prone to Technical Specification omissions due
! to their complexity. A listing of these selected feattres is provided as i Table 3. This assessment included a review of 17 TSRP packages.
The process through which this review was conducted is described below:
- The GGNS FSAR, SER and the existing GGNS TS were reviewed to obtain a preliminary overview of the TS coverage of parameters associated with i the selected design features.
- Based upon this preliminary overview and the personal knowledge and familiarity of the reviewers with the most significant aspects of the selected design features, several aspects of each design feature were selected for detailed investigation.
l I - The detailed investigations included reviews of design docunents, vendor manuals, industry standards, regulatory guidance docunents, and pre-operational and surveillance test procedures. When appropriate, discussions were held with MP&L and 8echtel personnel to i obtain additional information on specific design details.
- The reviewers extracted requirements, commitments, and design basis data from these docunents and compared them to the current GGNS Technical Specifications and the results of the TSRP.
- The reviewers checked both for proper inclusion of requirements and for consistency of details between documents.
- The term "would be" is used to reflect the fact that the TSRP did identify necessary changes to the existing GGSN TS.
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5*. ' ! As indicated above, the review of the parameters associated with each
; design feature was not all-inclusive. The review approach focused on a substantive investigation of a number of specific attributes within each '
of the selected design features. Impell believes that this approach and scope of review were sufficient to allow reasonable conclusions to be reached relative to the completeness of the GGNS TS and the effectiveness of the TSRP in addressing the issue of completeness. Recognizing that this review would not be all-inclusive in scope, prict to initiating this f review Impell reconnended to if&L that it would be prudent to confirm further the GGNS TS coverage of GGNS unique features (see Section 6.0). This recommendation was accepted by MP&L and such a confirmatory program has been initiated. The observations and conclusions of this review are presented in Section 7.1 of this report.' Additional back-up information exists in Impell's project files for the Third Party Review project and is available upon request. [ 4.3 As-Built - Rev tew The Third Party Review included several activities related to an assessment of the extent to which the TSRP adequately addressed the l
- I as-built condition of the plant. These activities included
- an assessment of the adequacy of the as-built " design input" (i.e., the drawings) used in the TSRP, an assessment of the extent to which this
" design input" was actually utilized by the Lead Review Organizations, an assessment'of the extent to which field verifications were performed by the Lead Review Organizations, and an independent assessment of.the accuracy of. selected parameters in the GGNS TS through procurement specification checks / field verifications.
These activities were carried out through personnel interviews, documentation reviews, and field verifications. The observations and l- conclusions resulting from this review are summarized in Section- 7.4. Additional back~-up information exists in.Impell's project file for the Third Party Review project and is available upon request.
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l . 4.4 Documentation Reviews (TSRP Packages) I l s As part of the Third Party Review project, Impell reviewed approximately
' 115 of the Technical Specification packages that were developed during the GGNS TSRP. The majority of these packages related to Sections 3.0 and 4.0 of the GGNS Technical Specifications; however, all packages related to Sections 1.0 and 5.0 were reviewed and a representative sample of packages from Section 2.0 and 6.0 were also reviewed.
These reviews were conducted for a variety of purposes, including:
- Assessment of the completeness of the documentation for each package.
- Assessment of the extent to which the design basis documents were utilized in the package reviews / development (i.e., the depth of the review).
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- Assessment of the extent to which operations personnel contributed to the package development / internal review.
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- Assessment of the extent to which-the BWR Standard Technical i Specifications may have been inappropriately utilized in the review I process.
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- Assessment of the technical adequacy of the packages and their associated conclusions /reconsnendations.
The observations and conclusions of this review are presented in Sections
! 5.0, 7.3, and 7.5 of this report. Additional back-up information' exists in Impell's project file for the Third Party Review project and is available upon request.
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i_ ** 4.5 Personnel Qualifications Assessments The Third Party Review project included several activities designed to assess the qual'ifications of personnel participating in the TSRP. These included personnel interviews, process observations, and resume reviews. The scope of this review included essentially all personnel participating
! in the TSRP. For personnel on-site at GGNS, personnel interviews were the principal source of information for this assessment and were augmented by process observations and resume reviews. For personnel off-site, resume reviews were generally utilized as the principal source of information and were often augmented by personnel interviews. In this regard, the qualification of GE personnel who performed their work.
off-site in San Jose were assessed during a visit to GE's San Jose offices. Qualifications were assessed on the basis of the specific TSRP responsibilities assigned to each participating individual and the extent { to which additional checks and balances existed (e.g., reviewer, checker, supervisory review). The obser'vations and conclusions of this review are summarized in Section 5.0 of this report. Additional back-up information exists in Impell's project file for the Third Party Review project and is available on request. 4.6 ff&L Quality Assurance Review The Third Party Review included an assessment of the extent to which the MP&L Quality Assurance Program was applied to the TSRP and of the affectiveness of the QA participation. This review included personnel interviews, process observations, and documentation reviews. l, I u 1
t The observations and conclusions of this review are presented in Sections l 5.0 and 7.6 of this report. Additional backup information exists in
.Impell's project files for the Third Party Review project and is available upon request.
4.7 W&L TSRP Prioritization Process Review Specific reviews were conducted to assess:
- The adequacy of the prioritization criteria utilized in the TSRP
- The uniformity and consistency of the application of the prioritization criteria The adequacy of the deliberative process through which priorities were assigned
> - The adequacy of the results of the prioritization process l These reviews consisted of personnel interviews, process observation, I
documentation reviews, and independent assessments. The Third Party Review included (but was not limited to) a review of all Problem Sheets 'I which were categorized by W&L as being Priority Category 1 or 2. The observations and conclusions resulting from this review are presented in Section 7.2 of this report. Additional back-up information exists in 3 Impell's project file for the Third Party Review project, and is available upon request. I i 1 1 1 i
- Table 3 I
Impell Third Party Review Independent Review of Selected GGNS Design Features i
; List of Features Reviewed i
I Rationale Feattre Drywell Purge System Unique to BWR-6/ Mark III Design Hydrogen Ignition System Unique to BWR-6/ Mark III Design Control Rods (Rod Control and Unique to BWR-6 Design Information System) Horizontal Fuel Transfer Unique to GGNS Design System (for BWRs) I i Crane Travel - Spent Fuel Unique to BWR-6/ Mark III and and Upper Containment Specific GGtS Design Fuel Storage Pools Details Centainment Spray Iodine Removal Credit Not Common to SWR-5s Standby Gas Treatment System Influenced by Mark III Containment and Specific GGNS Design Details Containment and Drywell Influenced by Mark III Containment and Hydrogen Recombiner System Specific GGNS Design Details Secondary Containment Integrity Not Unique, But Influenced by Specific-GGNS Design Details Fire Suppression System Strongly Influenced by Specific i GGNS Design Details D. C. Sotrces Influenced by Specific GGNS Design Details i l i
t i i 5.0 GENERAL PROGRAMMATIC OBSERVATIONS i . 1 Personnel Qualifications were connensurate with specific areas of assigned responsibility. A few isolated exceptions were identified, however adequate checks and balances existed to preclude this from having
! a discernible impact on the effectiveness of the TSRP.
1 Participation and influence of plant personnel, including licensed operations personnel, was appropriate and effective. This was particularly the case at the two critical points in the TSRP process: the NSSS/80P group reviews and the RPD group reviews. 4 - MP&L Quality Assurance was actively involved and performed thorough reviews. (See section 7.6 for additional information). Depth of review by LR0s was generally very good; docunented linkage back to FSAR supporting docunents and other relevant design docunents exists. / Level of docunentation was generally very good. 1 The thresnold for identification of " problem sheets" was low; the process was thorough. Potential over-reliance on Standard Technical Specifications; minor, if any, impact on quality of the program and its results. (See Section 7.3 l for additional information). Several discrepancies of minor, if any, safety-significance were identified. The TSRP process was through, but not perfect. Resource dedication reflected management commitment to a thorough, quality job. Strong MP&L management involvement and attention was evident. i Prograsnatic enhancement activities were implemented as work progressed. [, i
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- Cooperation and openness of all participants reflected their confidence l I in the effectiveness of the TSRP. !
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I 6.0 PROGRAMMATIC RECOMMENDATIONS AND RESPONSE As the Third Party Review progressed, a number of potential concerns related
' to the effectiveness of the GGNS TSRP were identified by Impell and were J
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promptly comunicated to MP&L's Senior Vice-President - Nuclear, along with ! specific recomendations. In all cases, MP&L accepted these recomendations and initiated appropriate actions. These recommendations were:
- MP&L Quality Assurance should perform audits of the work process for work < performed off-site by LR0s (i.e., 8echtel Power Corporation at Gaithersburg and General Electric at San Jose).
(Recomendation accepted: audits have been conducted)
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- MP&L should consider performing a discrete review of GGNS/8WR-6 Mark III unique design feattres to further confirm the results of the TSRP.
(Recomendation accepted: program has been initiated) MP&L Management should reinforce its comitment to a quality job, even at the expense of the TSRP schedule. (This recomendation was presented at the time that it became apparent that the RPO group was overloaded with work.) i (Recomendation accepted: original RPD sch'edule slipped a week)
- MP&L should ensure that there is -appropriate feedback from RPD to LR0s on disposition of their input, with sufficient opportunity for feedback.
~(Recomendation accepted and implemented)
- MP&L Plant Management should review Priority Two Technical Specification Problem Sheets and determine where Administrative Controls will be necessary or appropriate during the interim period while Technical Specification changes are being processed.
(Recomendation accepted and being implemented) t . , i 7.0 SPECIFIC OBSERVATIONS I 7.1 Independent Assessment of Selected GGNS Design Features As a result of this review, several minor discrepancies were identified. None of these were classified as Findings.* Only one of these items (identified as 0-4 in Table 4) is related to the potential need for the addition of a Technical Specification requirement for a unique GGNS/8WR-6 design featore. This item is judged to be of minor safety significance. Based on this review, including the nature of the discrepancies identified, Impell did not identify any programmatic concerns related to the completeness of the GGNS T.S. Based on this assessment, Impell has determined that: The GGNS/8WR-6 unique design features reviewed by Impell have been addressed in the GGNS Technical Specifications. The level of detail in the GGNS Technical Specification is influenced by the STS; this is to be expected. It would be prudent to perform an expanded review of the GGNS/BWR-6
- MK III unique design features to further confirm the results of the ,
TSRP. 7.2 TSRP Problem Sheet Prioritization Process Based upon its review of the TSRP prioritization process, Impell has determined that:
- The p.-ioritization criteria were appropriate; however, it should be noted that there is a wide range of safety-significance within the subcategories of category 2.
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- Definitions are provided in Table 4
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- The prioritization ' criteria were applied in a uniform and consistent r manner.
- The prioritization criteria were applied in a conservative manner.
Based on Impell's independent assessment, no Priority Category 2 items were identified that should have been categorized as Category i' l. In Impell's judgement, several of the Priority Category 1 items could have been categorized as Category 2 and a nunber of the Category 2 items could have been assigned lower sub-category designations. The personnel participating in the prioritization process were well-qualified. The extent of evaluation / deliberation which went into the [ prioritization process was very good. l 1 .1 1 Partially as a result of this review, Impell provided a programatic l recomendation to MP&L regarding the interim use of Administrative l Controls for certain Priority Category 2 items. (See Section 6.0). j 7.3 Potential Over-Reliance on the STS. J
- Based upon its review, of TSRP docunentation packages and personnel i interviews Impell has determined that:
No evidence was found that the STS were used as the only basis for
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), deleting an existing GGNS Technical Specification. I.
- Only one instance was found in which the STS may have been the sole basis for rejecting a proposed addition to the GGNS Technical f
Specification (this item is still under consideration).
- The LR0 reviews included a check for consistency with the STS, but
'- were not limited to such a check. i - 19-e- --
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- The level of detail of individual Technical Specifications within the 6
l GGNS Technical Specifications is influenced by the STS. This is to be expected, in that the STS represent current NRC guidance and industry practice with respect to Technical Specification level of , detail.
- The GGNS Technical Specifications include requirements which exceed the level of detail in the STS.
i 7.4 As-Built Review Based upon its review, Impell has determined that:
- The as-built data provided to the LR0s was up-to-date and was appropriately controlled.
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- The LR0s utilized the as-built data and supporting lower-tier documents in their reviews.
The TSRP documentation packages provide evidence that the as-built data and field verifications identified a number of inconsistencies between the GGNS T.S. and the as-built plant. j 1 Impell's limited procurement specification checks / field verifications
!l support the fact that the as-built data was used in the TSRP.
r 7.5 - TSRP Doctanentation Packages As indicated-in Section 5.0 of this report, Impell's third party review-( of approximately ll5 TSRP documentation packages resulted in the determination that:
- The level of documentation in the TSRP was-generally very good. ;
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The depth of the review by the LR0s was generally very good.
- Docunented linkage back to the FSAR, FSAR supporting docunented, and other relevant design docunents exists.
Participation and influence of plant personnel, including licensed operations personnel, was appropriate and effective. (Potential over-reliance on the BWR STS is discussed in Section 7.3)' i Based upon these TSRP docunentation package reviews, Impell identified several minor discrepancies. These are presented in Table 4 and can be summarized as follows: r t 0 Preliminary Findings 8 Preliminary Observations 5 Preliminary Deviations These discrepancies were identified to MP&L in accordance with the Impell Notification Procedure (Appendix C). Copies of the Impell Notification Sheets for each of these discrepancies are provided in Appendix D. MP&L's response to the above-mentioned preliminary observations and l deviations are docunented on the Notification Sheets in Appendix D. Based upon Impell's evaluation of MP&L's responses, the final , categorization of these items is as follows: 0 Findings 5 Valid Observations 5 Valid Deviations *
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- One preliminary observation was downgraded to a valid deviation. Two preliminary observations were deleted and one preliminary deviation was deleted.
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- It should be noted that, pending the outcome of the additional MP&L review of several of the items classified as Valid Observations, several of these items could be reclassified either as Valid Deviations or deleted from the classification system.
l In all cases, Impell has determined that MP&L's planned path for resolving these items is satisfactory. All of these items are judged to be of l minor, if any, safety significance. i 7.6 MP&L Quality Assurance Review o i Based upon its review, Impell has determined that: The MP&L QA review of the TSRP was substantive. Approximately 23.5% 1 I of the TSRP docunentation packages were reviewed by QA. In addition, MP&L QA conducted audits of the two organizations that performed work l j off-site (i.e., Bechtel Power Corporation in Gaithersburg and General Electric in San Jose). The MP&L QA review was proceduralized. An audit plan and audit checklists were developed and utilized. The MP&L QA review was thorough. It was conducted using a "zero-defect" philosophy. A number of undiscovered inconsistencies between the GGNS TS and related documents were discovered by QA. Although technical review of these inconsistencies concluded that they represented minor, if any, sir 'icance, the thoroughness of the
- QA audits and the contribution of the QA effort to the assurance of l TSRP effectiveness was evident.
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Table 4 Listing of Preliminary Observations and Deviations Technical Impell Specification Problem Item No. Section Title Description Observationsi 0-1 3/4.1.3.3 Control Rod Scram FSAR Requires i! Accumulator Level Accumulators
! Check 0-2 3/4.6.6.3 Secondary Minor TS Containment discrepancy (CFM Integrity vs SCFM air flow mits) l 0-3 3/4.6.6.3 Secondary Air flow Containment distribution Integrity test not included 0-4 3/4.6.7.2 Hydrogen Ignition No surveillance System test for seal box and ; hood spray shield 0-5 3/4.6.7.3 Drywell Purge Minor TS discrepancy (CFM vs.
SCFM air floe units)
! 0-6 3/4.8.2.1 DC Power Sources TS does not comply I with Reg. Guide 1.32
, 0-7 3/4.8. 2.1 DC Power Sources Performance test within first two years of service not included in TS 0-8 3/4.8.2.1 DC Power Sources Conflict -in annual capacity tests
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l Table 4 (Continued)
,. Listing of Preliminary Observations and Deviations Technical Impell Specification Problem Item No. Section Title _D_escription Observationsl D-1 3/4.1.3 Control Rod FSAR discrepancy Operability in fuel assembly weignt i
D-2 3/4.6.3.2 Containment Spray Apparent FSAR error in assumption of
; containment spray i flow rate D-3 3/4.6.6.3 Secondary FSAR references Containment diff. Reg. Guide Integrity 1.52 revision than TS D-4 3/4.6.6.3 Secondary SGTS Long-Term Containment flow discrepancy Integrity between FSAR and TS D-5' 3/4.6.6.3 Secondary FSAR/SER Containment discrepancy on Integrity time for SGTS to ! reach proper flow rate t
i Notes: 1- The following classification definitions were used by Impell in this i review: Finding - The need for a Technical Specification change has been determ ned by Impell to meet the criteria of MP&L's priority category 1A, 8, or C and was not identified at the completion of the GGNS TSRP technical review [ defined as following disposition by the Review, Prioritization, and Direction Group (RPD)]. Observation - Same as definition for a finding except that it meets the criteria of MP&L's priority category 2, A - I. Deviation - Actual or potential need for an FSAR revision which was not identified at the completion of RPD review.
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8.0 CONCLUSION
S Asstsning that the TSRP is carried out to fruition as presently constructed, Impell concludes:
- That the TSRP process and results provide adequate assurance that the GGNS Technical Specification, as revised to reflect the results of this program, accurately reflect the GGNS design analyses and tne as-built 3 pl ant. While the possibility remains that undiscovered discrepancies may 3
still exist, it is unlikely that such discrepancies would be of stbstantial safety significance.
- That the TSRP process and results provide adequate assurance that the GGNS Technical Specifications, as revised to reflect the results of this program, appropriately reflect the unique design features of GGNS. Impell believes that it would be prudent to confirm further the Technical i Specification coverage of GGNS unique features: MP&L has initiated such a confirmatory program.
- That the TSRP process and results provide adequate assurance that the GGNS '
Technical Specification, as revised to reflect the results of this program, meet or exceed current NRC/ Industry Standard for the level of l-detail to be included in Technical Specifications.
- That the GGNS Technical Specifications, as revised to reflect the results of this program, will be adequate to ensure safe operation of the plant.
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4 APPENDIX A l Resumes of Impell Third Party Review Project Team D. F. Brosnan l P. Cortland J. C. Guibert - Project Manager R. D. Machon l A. D. Miller t J.A. Ogawa J. L. Skolds D. C. Timmins E. H. Verdery G. A. Weber i
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DAfilEL F. BRO 5!;AN l l i EDUCATION B.S., Electrical Engineering, University of Notre Dame, 1964 M.S., Electrical Engineering, University of Southern California, 1971 Professional Certificate in Engineering Management, l University of California, Los Angeles, 1974 4 PROFESSIONAL Mr. Brosnan has over nineteen years of experience.in EXPERIENCE the design, licensing and project management of large commercial power generating facilities. The majority of his design experience has dealt with the electrical design and retrofit of power plants including high voltage switchracks, auxiliary power systems and emergency power supplies. He has experience in the design and installation of transformers, switchgear, motor control centers, bus and cable. He has prepared equipment layouts, electrical one line and schematic wiring diagrams, relay protection schemes, conduit and cable schedules, procurement specifications, cost estimates and systems descriptions. ) He has developed and modified computer programs for i i transmission systems, auxiliary power systems and ' l construction schedules. Transmission system studies include losses, compensation and grid stability
!' analysis. Auxiliary power system studies include -
short circuit analysis and load flow studies for normal load, large motor starting, low grid voltage r and emergency generator loading conditions. In ' addition, he has developed 3nd applied critical path method scheduling and cost control programs for design, procurement and construction-erection of
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power plants including electrical systems. Mr. Brosnan has been involved in electrical and seismic testing of equipment. He has prepared a-comprehensive equipment qualification program for , plant electrical equipment. This program included equipment qualification plans, implementing . procedures, review of vendor qualification plans and > preparation of licensing submittals. The plans and procedures included documentation requirements, files
; DANIEL F. EROSNAN
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' and interfaces. He also has been responsible for the PROFESSIONAL EXPERIENCE review and updating of instrument and control drawings and licensing documents for a major (Continued) equipment supplier.
Mr. Brosnan has extensive experience in both federal
-i and state. licensing processes for power plants. '
l While working for a major utility in their project i office, Mr. Brosnan was responsible for the preparation of-the project feasibility study report l and the Environmental Impact Report. As chairman of l the Project Engineering Committee he directed project engineering, scheduling, budgeting and cost control 3 for a proposed four unit power plant. He has been a .
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chairman and member of numerous joint utility / industry groups to develop industry positions on critical > ' power plant issues. He has prepared licensing testimony for federal, state and local hearings. . He is nationally recognized'in electrical standards development by his participation in the IEEE Power Engineering Society's Nuclear Power Engineering Committee.- For three years Mr. Brosnan was manager of our Systems Engineering Division. He was. responsible for systems analysis, plant performance and plant engineering. His responsibility included management of electrical and' instrumentation and controls
! engineers in analysis,_ design and engineering.
As manager of the Project Management Division for one year, he was responsible for the overall management, administration-and control services for over $25 millionofengineeringdesign,analysisandfield construction liason services. Project Management services include planning and scheduling,
'{ interdisciplinary coordination, estimating,' cost and- '
status reporting, vendor evaluations and licensing I testimony. ; 4
- l He is presently manager of.the Management Services Division with responsibilities for plant operations and maintenance support, emergency preparedness, training and information management systems.
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- OANIEL F. 60.0ShAN
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4 PROFESSIONAL Tau Beta Pi, National Engineering Honor Society AFFILIATIONS Eta Kappa Nu, National Electrical Engineering Honor Society Institute of Electrical and Electronics Engineers Institute of Electrical and Electronic Engineers, Nuclear Power Engineering Committee 4 REGISTRATIONS Electrical Engineer, State of California, AND LICENSES - Registration No. E-7161 Nuclear Engineer, State of California, Registration No. NU-1549 PUBLICATIONS AND "Effect of the February 9,1971, San Fernando PRESENTATIONS Earthquake on Power System Equipment," invited paper, presented at the American Power Conference, April, 1972
" Professional Societies and Nuclear Safety," _ invited panel member at Joint ANS, ASCE, ASME, IEEE Meeting, March, 1972
" Relative Spent Fuel Storage Hazard," D. F. Brosnan, J. F. Strahl, and E. N. Cramer, presented at American Nuclear Society, Winter Meeting, 1977 l
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Pt.UL CORTLAND EDUCATION B.S., Vachanical Engineering, New York University Graduate Studi.es in Welding Engineering, Ohio State University , MBA, Xavier University PROFESSIONAL Mr. Cortland has over 20 years of experience in EXPERIENCE nuclear, fossil and industrial operations, procurement, maintenance and welding. This experience includes supervision of maintenance and l construction engineers and crafts during plant ! outages. He has been actively involved in inspection and procedure development for nuclear construction and maintenance and has trained utility operators and engineers.
; An ongoing responsibility is the preparation and monitoring of procurement and materials specifications for imported materials. This work involves knowledge of import restrictions and coordination of the supply of parts for installation at a nuclear power plant.
- A recent responsibility was to perform a third party review of repair work in order to determine the
' causes and evaluate the hours charged. This review was prepared under the work product doctrine for future use.
Mr. Cortland has had broad involvement in nuclear power plants and has developed and performed the site ' coordination for maintenance. programs and procedures. He has prepared responses to corrective actions, non-conformance reports and quality audits. Paul has~ developed training programs and performed the actual training. He has been an inspector on nuclear plant construction and has supervised crafts in nuclear plant construction and maintenance. f Working as a Site Facilities Coordinator required the managing, planning and scheduling of the support services and materials prior *.o and during an
!' extended nuclear plant outage. This included interfacing with plant operations and construction personnel in order to effectively schedule plant manpower support during the outage.
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I - PAUL'CORTLAND ,
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-i PROFESSIONAL As.the Warehouse Supervisor at an operating nuhlear i EXPERIENCE plant he managed 23 staff and craft personnel and .L (Continued) wrote purchasing requisitions, selected vendors and-reviewed purchasing documents for. nuclear quality requirements. . Operating the warehouse involved-scheduling support, writing warehouse procedures and ,.
i integrating materials management into the overal.1 , outage schedule. As a Lead Senior Engineer, Mr. Cortland provides . engineering assistance and project field. supervision t and coordination for Impell clients. In this capacity he is responsible for developing and . -
. - tmplementing administrative and technical procedures. .
as well as planning and schedul', site activities. ,' 1 i Mr. Cortland has extensive experience in welding. He . has been responsible for developing technology, s ~. writing procedures, training people,-and field ,, brazing, and heat . , f applications treating. He for haswelding,lly directed 14 engineers j persota and controlled the selection of procedures for-welders and fitters engaged in manufacturing nuclear and fossil equipment for public utilities. This- work N involved replacement analysis and capital plann'ing. I PROFESSIONAL American Welding Society 't - y' AFFILIATIONS m ji American Electroplating Society "E ;{
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- REGISTRATIONS Professional Engineer, State of Ohio t' \ s AND LICENSES .
Professional Engineer, State of Iowa
- - y l$ Certified Welding Inspector, ' American Welding Society L i
i s COMMITTEES - American Welding Society. D1.1 Structural Welding Committee
. PATENTS U.S. Patent-3,542,995 Electron Beam Welding 9, ,g f 3 i.
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g , %;. JOHN C. GUI8ERT [, , , / 4 . i '1 - i \' 1 . t
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~ 8.S., Nuclear Science,1967, US Naval Academy,
[00 CATION , Annapolls, Maryland
, I M.S., Nuclear Engineering, 1968, Catholic University, Washington, D.C. ;
i* ' ' 1: , , Graduate Studies in Business Administration, 1980-81, George Washington University, Washington, D.C. e-i ! l Mr. Guibert is Impell's Manager of Nuclear Safety ! PROFESSIONAL and Licensing. In this capacity, he is responsible EXPERIENCE , for directing and participating in activities j
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associated with providing personal consulting and
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programatic services related to nuclear power plant l 4 licensing and safety assessment. 1
,' Prior to assuming his current position, Mr. Guibert was Manager of the Systems Engineering Division in
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' Impell's Western Region. In that capacity, he was '
responsible for the management and technical direction of activities associated with providing o
'. engineering services in the areas of systems analysis, systems design, computer systems applications, thermal-hydraulic analysis, plant performance, and probabilistic risk assessment.
l Mr. Guibert's experience prior to joining Impell . ' includes six years with the Nuclear Regulatory
' Commission and seven years as an officer in the U.S.
Navy Nuclear Power Program. During his career with the IRC, Mr. Guibert obtained
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r extensive experience and_ knowledge of nuclear i
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regulatory and licensing practices and policies while i 7 . serving in a variety of positions of increasing
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( ' responsibility. His assignments included: Project Manager in the Division of Operating Reactors, Office o? Nuclear Reactor Regulation; Technical Assistant to 1 , the Assistant Director for Operational Technology, i a. .., Division of Operating Reactors Office of Nuclear u '
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-i , - JOHN C. GUIBERT Page Two t
[. ! fI PROFESSIONAL to Conmissioner Richard T. Kennedy; Assistant EXPERIENCE Director for Radiological Health and Safeguards (Continued) Standards, Office of Standards Development; Deputy-Director, Division of Health, Siting and Waste, Management, Office of Nuclear Regulatory Research.
! As a Project Manager in the NRC's Division of ,
Operating Reactors, Mr. Guibert was responsible for coordination of all phases of review of licensing
! actions affecting several SWR nuclear power plants;-
t technical review of safety-related licensing actions; i: and preparation of safety evaluations. In addition, he served as the NRC's Program Manager for the .I' l generic reevaluation of the BWR Mark I Containment i System. As Technical Assistant in the Division of Operating Reactors, Mr. Guibert was responsible for technical coordination of activities related to
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operating nuclear power plants; development of policies, programs, procedures, and technical positions related to the regulation of operating' N nuclear power plants; review of reactor. operating ' experience; and preparation of technical reports on generic safety issues. In addition, he served'as the Division of Operating Reactor's representative in,the development-and implementation of the Office of " i Nuclear Reactor Regulation's Generic Technicald Safety Issues Program. ; i , As Technical Assistant to Connissioner Kennedy, Mr. - I Guibert was responsible for providing expert - technical and policy advice in connection with the' formulation, implementation, and evaldation'of NRC , policies, plans, and programs. In this' capacity, he' ~; developed reconnendations for establishing or s , modifying EC policies and programs and for the , resolution of controversial aspects of NRC staff .
! y policy and program proposals. As Assist' ant Director) y ,
for Radiological Health and Safeguards, Mr. Guibert planned and directed the E C's program for the development of regulations, regulatory guides,- criteria,'and standards for radiological health and safeguards matters. In this capacity, he provideo1 technical and managerial direction ph
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_i., . i* JOHN C. GUI8ERT Page Three I j PROFESSIONAL to the Radiological Health Standards Branch, the EXPERIENCE Occupational Health Standards Branch, and the (Continued) Safeguards Standards Branch. In addition, Mr. Guibert served as the Chairman of the NRC's Task Force for the comprehensive revision of 10 CFR Part i 20 and as the NRC's representative on the U.S. Radiation Policy Council's Working Group. As Deputy Director of the Division of Health, Siting, and Waste Management, Mr. Guibert was responsible for the formulation, implementation, and evaluation of the NRC's program for research and standards development i in the areas of radiological health, nuclear facility i siting, and radioactive waste management. 3 During his naval career, Mr. Guibert qualified as e Engineering Officer of the Watch on two pressurized water reactor plants and was certified as Engineer
' Officer of Naval Nuclear Propulsion Plants. He served as an Engineering Department Division Officer and as Radiation Protection Officer on an operational nuclear powered submarine,'as a member of Submarine Flotilla Six's Operational Readiness Evaluation Team,
~ and as a Department Director at a major naval submarine training center. PROFESSIONAL Atomic Energy Comission Fellowship in Nuclear AFFILIATIONS Engineering - 1968. t arf ican Nuclear Society
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. ; ., RICHARD D. MACHON l RESUME OF QUALIFICATIONS Richard D. Machon - 7 Wheelri ht Way - Smithtown, New York 11787
SUMMARY
OF QUALIFICATIONS: Registered Professional Engineer, Licensed Nuclear Test Supervisor, Graduate Mechanical Engineer, Director of Outage Management, Nuclear Operations Manager, Assistant Station Manager, Plant Support Group Leader, Senior Operations Engineer, Systems Engineer, Start-up and Test Engineer. l EDUCATION
! TECHNICAL MANAGEMENT Northeastern University Kepner-Tregoe Decision Analysis Boston Edison Company 1978 Boston, Massachusetts Mechanical Engineering (BS)
Shif t Test Engineer Program Skills for Utility Management General Dynamics Electric Council of New England 1979 Electric Boat Division Public Utilities Executive Program
; Groton, Connecticut University of Michigan 1983 i Qualified S5W 1972 S2W 1973 Various AMA Courses: 1978-1982 Westinghouse Plant Zero Based Budgeting Information Project Management Seminar 1976 Strategic Planning Matrix Management Combustion Engineering Management Simulator Stress Management Program 1977 General Physics BWR Management Simulator Program 1978 GE BWR Simulator l Morris, Illinois
! RLqualification Program 1979 EXPERIENCE:
Impe11 Corporation Operations Services Manager _ 225 Broad Hollow Rd. Accountable for establishing and providing the Melville, New York following services for Operating Nuclear Power Plants: maintenance & surveillance programs, spare parts, outage support, operating procedures &
' manuals, security, training, startup.and test, operational QA/QC, emergency preparedness, construction management and decommissioning.
RICHARD D. MACH 0N
; EXPERIENCE: (Cont'd) 1 B:ston Edison Company Director of Outage Management Pilgrim, Nuclear Power Station Reporting to the Senior Vice President Nuclear s
,lMRFDF1; Rocky Hil14oad i' and/ accountable for scoping scheduled outages Plymouth, MA 02360 such that funding, scheduling, procurement and design can be accomplished to support approved i 52ptember 1982 - October 1983 tasks prior to commencing the outage. When the Unit l was removed from service, accountable for performing the Outage on time within budget consistent with l' corporate policy and regulatory requirements.
l In addition, during unscheduled outages, accountable for ensuring that the reason the Unit was removed
' from service is critical path unless pre-empted by other tasks of a more critical nature, and the impact on the operational budget is minimized and documented.
1 Testified before the Department of Public Utilities on Performance Issues regarding outages. Aug.1980-Sept.1982 Nuclear Operations Manager leporting to the Vice President-Nuclear and accountable for the overall safe, reliable, and economic operation of Pilgrim Nuclear Power Station in accordance with Corporate policies and Regulatory requirements and responsible for providing the - 1 management controls to assure that Corporate ] policies and Regulatory requirements, as they i F pertained to the operation of Pilgrim Nuclear Power j Station, are satisfied. . Also, a member of the Nuclear Safety Review and l Audit Committee and the Emergency Director to j
, coordinate and implement the Radiation Emergency , Plan. /-
4 Aug.1979-Aug.1980 Assistant Station Manager - Nuclear Operations Department Responsible for providing the technical and
, administrative guidance necessary to assure 5
conformance with the Technical Specifications, Station Procedures, Regulatory Requirements and dependable operations of the Station. Acted as the Plant Manager during his absence and was Chaiman of the Plant Operations Review Comittee. Also I responsible as Project Manager for the Mark I Program during the 1980 Refueling Outage. {
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RICHARD D. MACH 0N [ EXPERIENCE: (Cont'd) Oct.1977-Aug.1979 Plant Support Group Leader - Nuclear Operations Department Responsible for providing the technical and 4 administrative direction to the engineers assigned to perfons the following functions in support of an operating BWR, NRC Licensing, Reliability Programs, Inservice Inspection Program, Radiation Protection program and to provide the operational review of a proposed PWR. Additional areas of supervision
- .; included the development and implementation of design changes required to improve plant perfonnance and independent operational review of design changes from outside the department. i I
l l Fcb.1977-Oct.1977 Senior 0)erations Ennineer Respons131e for providing the Operational and Maintenance review of a proposed PWR. Specific
.' areas included: Main Control Board Layout, PAID Review System requirements, Logic reviews, component Selection, equipment layout, general operating philosophy and system interaction review.
Yankee Atomic Electric Company System Engineer ' i 20 Turnpike Road
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Responsible for providing the engineering and Westboro, MA 01581 Licensing expertise required for the proper design, operational perfonnance, and maintenance of Fsb.1974-Feb.1977 nuclear power plant systems. Included in the above are preparation and/or review and approval of flow diagrams specifications, system descriptions, i perfcnnance test procedures, bidders' lists and I proposals. Additional areas included Main Control Board Layout and system interaction review. General Dynamics Qualified' Nuclear Test Supervisor-(S.T.E.) Electric Boat Division Responsible, as the on-scene representative of Electric Boat management, for the safe and orderly Eastern Point Road conduct of all phases of Reactor Plant testing during Groton, CT both new construction and overhaul of submarines. Nov.1971-Feb.1974 Shipbuilding Division Test Engineer East Howard Street Respons1D111 ties included surveillance of Quinch, MA installation procedures used in conjunction with hydraulic, pneumatic, and electro-mechanical systems and demonstration of these systems to the
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June 1970-Nov.1971 contractor, both Government and commercial. I! . 4 8 a
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I *- ALAN D, MILLER i EDUCATION 8.S., Chemical Engineering, Iowa State University Ph.D., Chemical Engineering, Universtiy of Wisconsin
! PROFESSIONAL Dr. Miller is Section Manager of Chemistry and Health ' EXPERIENCE Physics. He has extensive expertise implementing, organizing, and managing research and development I projects. His broad experience at operating nuclear power plants encompasses water chemistry, radioactive waste processing, analytical instrumentation r
packages, radiation monitoring, and hardware and i software packages for data acquisition / reduction systems. Dr. Miller was responsible for organizing the Chemistry, Radiochemistry, and Radwaste Program Area for the Nuclear Safety Analysis Center following the accident at Three Mile Island, and coordinating these activities with the Electric Power Research Institute, the Atomic Industrial Forum, and the Edison Electric Institute. Specific work included hydrogen flammability and detonability studies, f radiation source terms, radio-iodine transport, reactor containment structural capabilities, population radiation exposure, post-accident sampling', and radiation monitor response.
, As a Project Manager for the Electric Power Research Institute, Dr. Miller worked in the Chemistry and Radiation Control Program. He managed work in advanced radwaste treatment systems, decontamination, iodine spiking, Soiling Water Reactor offgas systems, and water chemistry.
Dr. Miller has spent a considerable amount of time in ( the field at nuclear power plants. supervising and conducting projects. These include continuous automated measurement of dissolved oxygen, specific conductance, and pH in high-purity water, water 1 sampling systems, ion exchange resin performance and l degradation, high-resolution gama spectroscopy in lI reactor containments, and nuclear fuel crud deposit
! sampling. He has also completed the General Electric Soiling Water Reactor Chemistry training course for i L1 the training of plant site chemists. l lf a
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' ALAN D. MILLER Page Two i
i I , l PROFESSIONAL American Nuclear Society l AFFILIATIONS American Association for the Advancement of Science Edison Electric Institute Health Physics Comittee, l former EPRI representative i ASME Radwaste System Comittee PUBLICATIONS AND Miller, A.D., "NSAC Workshop on Post-Accident PRESENTATIONS Sampling," ANS, San Francisco, November 1981 Kamil, H., M.C. Chen, G. Kost, and A.D. Miller,
" Investigation of the Behavior of TMI-2 Containment Structure for Hydrogen Burn Accidents," Sixth International Conference on Structural Mechanics in Reactor Technology, Paris, August 1981.
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- Miller, A.D., M. Kolar, G. Lahti, C. Pelletier, and F. Rahn, "New Directions in Radiation Protection and 3'
Shielding," ANS, Bal Harbor, Florida, June 1981. Miller, A.D., " Brunswick-2 Water Chemistry," EPRI i NP-1795, April 1981. Miller, A.D., "Short-Term Lessons Learned: Radiation i Protection Recommendations - The NSAC Perspective," ANS, Washington, November 1980. l Miller, A.D., "Three Mile Island, - Accident Aftermath," ASCE. Iowa City, Iowa, September 1980. Miller A.D., Radiation Source Terms and Shielding at 1 TMI-2," ANS, Las Vegas, June 1980. Miller, A.D., "Three Mile Island - What Happened," American Society of Civil Engineers, Ames, Iowa, October 1979. ( Remark, J.F., and A.D. Miller, " Review of Plant - Decontamination Methods," ANS, Sun Valley, September 1979. m-.- .%- , v r.
' ALAN D. MILLER Page Thren l
PUBLICATIONS AND Shaw, R.A., M.D. Naughton, and A.D. Miller, PRESENTATIONS " Radiation Exposure, Radiation Control, and (Continued) Decontamination," 'ANS, Sun Valley, September 1979. Shaw, R.A., A.D. Miller, and M.D. Naughton, " Exposure i and Radiation: U.S. Experience," IAEA/0 ECD-NEA,
' International Symposium on Occupational Radiation Exposure in Nuclear Fuel Cycle Facilities, Los Angeles, June 1979.
Miller, A.D., " Water Chemistry Characterization of a Boiling Water Reactor," Nucl. Tech., 37,, 111 (1978). Pdller, A.D., "Electrogenerative Chloro- and Bromo-fluorination of Olefins from Aqueous Media; the Electrogenerative Cell as a Chemical Reactor," J. ~~~ Appl. Chem. Biotechnol., j!7,,176 (1977). Indig, M.E., J.E. Weber, and A.D. Miller, "Honitoring Corrosion and 0xidation Potentials in a Boiling Water Reactor," Corros'on/77, San Francisco, March 1977. Miller, A.D., E.L. Burley, D.T. Snyder, and K.A. Selby, " Water Chemistry Characterizations of a ' Boiling Water Reactor," ANS, New York, June 1977. Miller, A.D., and S.L. Langer, "Electrogenerative j Bromination " J. Electrochem. Soc., 120 (12), 1965 (1973).
! Miller, A.D., "Electrogenerative Halogenation," PhD Thesis, University of Wisconsin, 1973.
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' i *. JEFFREY A. 0GAWA i i-i i EDUCATION 8.S. (with honors), Mechanical Engineering, University of California, Davis, California l l l PROFESSIONAL Currently, Mr. Ogawa is a Supervising Engineer. EXPERIENCE He has over ten years experience in the design, licensing, maintenance, and testing of commercial nuclear power plants. Prior to joining Impell, he participated in the design, licensing, and startup of Nuclear Steam Supply Systems (NSSS) and Balance of Plant (80P) [ Systems with Bechtel Power Corporation. As a design ' engineer, Mr. Ogawa has prepared piping and instrumentation diagrams, logic diagrams, system i descriptions, equipment specifications, and design
' calculations for BWR and PWR plants. He has also served as a licensing engineer for a Pressurized i Water Reactor, responding to NRC, ACRS, and ASLB l questions, reviewing and submitting SAR amendments, and reviewing accident analyses. Mr. Ogawa spent approximately one year working in the client's offices providing engineering support on 80P and nuclear systems for an operating BWR, as well as I on-site engineering support during three refueling outages.
While with the Washington Public Power Supply System, Mr. Ogawa was the Lead Nuclear / Mechanical Engineer on l i the WNP-2 project engineering staff. His responsibilities included overseeing A/E design work, resolving startup problems, responding to licensing questions for Emergency Core Cooling Systems (ECCS) and NSSS, and interfacing with General Electric. Other responsibilities included project interface on ASME Code (Sections III and XI) problems and on i generic issues, such as anticipated transients without scram, Browns Ferry 3, and issues related to Three Mile Island (NUREG 0737). While with Burns and Roe, Inc. (BRI), Mr. Ogawa was the Nuclear / Mechanical Group Supervisor on WNP-2. tie organized, coordinated, and implemented major assignments including containment-isolation provisions and safe shutdown requirements per i i Appendix R. He assumed responsibility for l F-
JEFFREY A. 0GAWA Page Two a PROFESSIONAL interpreting and evaluating design, licensing and EXPERIENCE startup issues. While supervising up to seven i (Continued) engineers, he coordinated and reviewed FSAR question responses, established licensing positions, prepared i engineering criteria, prepared botn conceptual and l detailed designs to implement design changes, and responded to startup problem reports and Nonconformance Reports. He also acted as the technical interface between BRI and General Electric l and participted in the engineering transition from B&R to the Supply System. PROFESSIONAL American Society of Mechanical Engineers AFFILIATIONS REGISTRATIONS Mechanical Engineer, State of' Washington, AND LICENSES Registration No. 19774 d Mechanical Engineer, State of California, Registration No. M-17511 4 e t e l
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JOHN L. SK0LDS EDUCATION B.S. , Applied Science United States Naval Academy Master of Business Administration (MBA), University I of South Carolina
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EXPERIENCE Mr. Skolds has over ten (10) years of comprehensive
, operational and regulatory compliance experience within the domestic nuclear power industry.
With Impell, he has worked in a number of different areas. He has spent a significant amount of time assisting clients in the areas of Technical Specification evaluation and audit, fire protection,
.. Regulatory Guide 1.97 activities and environmental j
qualification of equipment. He has also participated in the development of a client's emergency planning exercise. Prior to joining Impe11 Corporation, Mr. Skolds was employed by the U.S. Nuclear Regulatory Commission 3 for six (6) years. For four (4) years he served as
'; Senior Resident Inspector at a nuclear power -
generating station. Mr. Skolds planned, supervised, and conducted operational inspections to ascertain I whether the licensee complied with the provisions of a its license and NRC rules and regulations. He performed in-depth evaluations of incidents and
'T abnormal conditions at the plant to determine the a safety significance of various events and the appropriateness of the licensee's response. He was
. kept informed of the results of inspections performed
, t by specialists in the areas of radiological safety, environmental protection, fire protection, physical security and various engineering disciplines and made determinations as to which areas needed additional
- inspection effort. Mr. Skolds represented the NRC to the licensee, state and local officials and the news
't media concerning all matters that were within the responsibility of the NRC Regional Office. He conducted extensive inspections in the areas of preoperational testing, low power physics testing and power ascension testing. He was extensively involved in the generation of the facility's Technical
i JOHN L. SK0LDS Page Two i Specifications. He conducted numerous inspections of t EXPERIENCE , t , (Continued) administrative, operating and emergency procedures of this plant as well as the extensive review of the licensee's ISI Pump and Yalve Program prior to the issuance of the operating license. Mr. Skolds was
' directly involved in closing various open items restricting both the low power operating license as well as the full power license of this plant and was
- involved in the resolution of TMI Action Plan Items '
prior to its licensing. , As a USNRC Region II Reactor Inspector, Mr. Skolds conducted reactor inspections at various operational
; nuclear power plants in the Southeast and completed Nuclear Regulatory Connission training (both classroom and simulator) in Boiling Water Reactors
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and Pressurized Water Reactors. He additionally performed inspections in the areas of operations, - maintenance, training, and quality assurance at those , j, same nuclear power generating facilities. Prior to joining the USNRC, Mr. Skolds spent six (6) 1 years with the U.S. Navy. For two (2) years, Mr. j Skolds served as officer in charge of an operating crew at the Navy's S7G prototype facility. At that
- time, he conducted startup, preoperational, low power
> 4 physics and power range testing on a new concept in
' reactor design and was responsible for the. training, operations and maintenance performed by its operating crew. Mr. Skolds was qualified as a Chief Engineer i while assigned to this facility.
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. DOUGLAS C. TIMINS l-il EDUCATION 8.S., Physics,1968, Texas Technological University, Lubbock, Texas Graduate Studies in Business Administration, 1973-1975, Golden Gate University, San Francisco, ,
California Graduate Studies in Material Science, 1979, Joint Center for Graduate Study, Richland, Washington
- PROFESSIONAL Mr. Timins is Impell's Area Coordinator in Richland, EXPERIENCE Washington. In this capacity he is responsible for In 1
managing local Impe11 work and employees. addition he provides personal consulting services for a wide range of technical and licensing issues.
- related to nuclear power plants.
'* Sefore joining Impell, Mr. Timins' experience included seven years with the Supply System, three years with Bechtel Power Corporation, four years as
'q an officer in the U.S. Navy Nuclear Power Program and one year with Shell Oil Company.
j l, During his career with the Supply System, Mr. Timins t served in several staff, management and lead l positions. As Technical Specialist to the WNP-2
- Program Director, he provided counsel on project 4
i critical issues and functioned primarily in a problem
; solving mode. In this position he was the prime i
technical interface between the NRC, Inspection and
- Enforcement Branch, and the Project. His management
!!' responsibilities included engineering direction and resolution of construction and quality related problems. Significant issues managed by Mr. Timins were: construction quality' problems of the j sacrificial shield wall, evaluation and subsequent establishment and implementation of improved l
construction and quality programs following an NRC l ' Stop Work Order for WNP-2, resolution of NRC concerns
~~ related to I & E Bulletins 79-02 and 79-14, resolution of NRC concerns on electrical separation, and development of the Independent Design Review i'- Program for WNP-2. His various assignments included: Technical Specialist; Assistant Manager, Engineering; Contractor Engineering Director; Program l
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- DOUGLAS C. TIMMINS Page Two i
PROFESSIONAL Manager; Engineering Supervisor and Lead Engineer. ,~ EXPERIENCE His technical responsibilities included: welding,
' corrosion, mechanical equipment, ASME Code and (Continued) various standards, NSSS and balance-of-plant systems, radioactive waste processing systems, and Inservice Inspection.
Prior to the Supply System, Mr. Timmins worked for Bechtel Power Corporation as a Group Leader and
. Senior Engineer. His responsibilities included:
managing radiation shielding, radiological and
- environmental analyses (including control room
' habitability and dose pathways), and performing design for radwaste processing and chemistry control and sampling systems. During his naval career, Mr. Timmins qualified as Engineering Officer of the Watch and served as an i Engineering Department Division Officer. As a 5 Division Officer he was responsible for the reactor and secondary plant mechanical equipment, the propulsion equipment, and chemistry and radiological i
'j controls. His time in service was primarily associated with an extensive ship ov'erhaul. The overhaul allowed Mr. Timmins to become intimate with
! ; equipment and system testing, maintenance and repair 4 activities, and work under radiological conditions. At Shell Oil Company Mr. Timmins was a 1 petrophysicist. His responsibilities included assessment of oil and gas deposits for secondary i recovery and making recommendations related to subsequent economic decisions.
,i PROFESSIONAL Sigma Pi Sigma - Honorary Physics Society 4
i AFFILIATIONS ASME Radwaste Systems Consnittee (past member)
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1 EDWARD H. VERDERY t EDUCATION B.S. , U.S. Naval Academy,1967 Naval Nuclear Power Training 2 Law School - Completed 3 yrs. of 4 yr. Program l
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1 EXPERIENCE Mr. Verdery is a nuclear engineer with extensive
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experience in the operation, management and regulation of nuclear power plants. Currently, Mr. i Verdery is the Manager of the Operations and Technical Services Division in Impe11's Southeast Regional Office. He is responsible for production i work associated with this 60-man division. Reporting to him are six Section Managers responsible for a wide array of management, operations, licensing and
.i training services.
ly Prior to this assignment, Mr. Verdery was a Project lj Director for the Southeast Region. In that capacity, 1 he was responsible for several project managers and all of the work performed by Impe11 Corporation for l ; selected clients. Since joining Impe11 he has been l4 involved in the development of new capabilities and i clients to expand the Company's service areas. In j ' addition, he has been actively involved with the ANS ! l and AIF and has developed a broad perspective of 1 industry needs and direction. Mr. Verdery was recently involved in a key assignment
)
' for Louisiana Power and Light Co. at their Waterford
- 3 site. He served as a senior technical advisor to the Senior Vice President of Nuclear Operations. He
} was instrumental in evaluating several key technical areas and organizations to improve project
' effectiveness. The areas evaluated included project management and startup, design change control procedures, computer development, planning and scheduling and QA/QC effectiveness.
As an Operating Reactors Project Manager, he has managed the NRC licensing review of numerous 4 technical issues affecting individual utilities as well as several generic issues affecting entire
-classes of plants. He was instrumental in the
_~ _ .. _ . __ _ . __ EDWARD H. VERDERY Page Two i - j" EXPERIENCE implementation of 10CFR Part 50, Appendix I, ALARA, (Continued) on all operating reactors as the NRC's Generic Project Manager. Other licensing issues of importance included Core Reloads, ECCS, Fire Protection, BWR Mark I Containment Program, Power
'. Grid Instability, Feedwater Flow Induced Water Hammer and BWR LPRM Flow Vibration Cracking. His exposure included the highest levels of the NRC and the
- nuclear industry.
Following his assignment in reactor licensing, Mr. Verdery was assigned as a principal inspector and
! section chief in the Reactor Operations and Nuclear
- - Support Branch of the Office of Inspection and Enforcement, Region II. In that capacity, he managed ,
the NRC inspection program at several Southeastern ;
, utilities. He played an important role in the NRC response to Three Mile Island and was instrumental in ,, the implementation of Post TMI requirements at ij Crystal River and Oconee.
Prior to his NRC experiences, Mr. Verdery spent eight. years as an officer in the nuclear submarine force j . and served as Chief Engineer of the USS Francis Scott i Key and Training Officer at the SIC prototype, J - Windsor, Connecticut. In those positions, Mr. Verdery was intimately involved in the day to day j operation and management of pressurized water reactors. During his military career, Mr. Verdery was qualified as senior watch officer on four different nuclear' reactor facilities. Additionally, he has been J responsible for the training and qualification of several hundred power plant operators.
. \
COMMITTEES NRC Task Force on Review of Licensee Reporting Requirements NRC Task Force on Review of Strategic Nuclear
, Material at Research Reactors American Nuclear Society l
4 i _ , - . - - - - _ . _ _ _ , , - , . _,_ -._ . _ , , , _ _ _ , ,_,,,,,__,7_, _ . . , . , . , , , _ . _ . , , , , , , _ , ,
E . GARY A. WEBER EDUCATION B.S., Electrical Engineering, cum laude,1975, University of Michigan B.A., Physics,1974, Kalamazoo College i PROFESSIONAL. Mr. Weber is a Manager of Special Projects with i - EXPERIENCE extensive experience in nuclear plant operation, start-up, and analysis.
?
Mr. Weber's operating experience was gained as a plant engineer at a 2-unit, 4-loop PWR, where he gained working knowledge of plant staff organization and responsibilities. Mr. Weber's job required frequent interface with the plant's Technical, Operations, Maintenance, and QA Departments, and
- ~ '
working knowledge of department operating and 1 administrative procedures.
- Mr. Weber is experienced in the supervision of technicians and maintenance personnel in plant design
,4I change implementation, electrical and mechanical i i '
equipment maintenance,' and in coordinating personnel
+ in the set-up and performance of surveillance tests. l a He was responsible for test development and f administration, compliance with required Codes and l l ; standards, and test documentation. Mr. Weber is ,
also familiar with NRC reporting requirements (LERs, l
!, non-conformance reports, test reports, etc.) and ,
plant Technical Specifications. 4 As a plant engineer, Mr. Weber was responsible for performance and vibration testing and analysis, plant j thermal performance monitoring, and troubleshooting j of process control and logic system problems. Mr. Weber was responsible for the development of FORTRAN programs on the plant's process computer to
- g compute a daily index of plant thermal performance.
- [*
He has led investigations of plant transient events ' and has been successful in improving plant protective system reliability. l
- GARY A. WEBER Page Two l PROFESSIONAL As a start-up engineer, Mr. Weber has had field start-up and preoperational testing responsibilities EXPERIENCE (Continued) at a large nuclear generating facility. Included in this experience was the start-up and testing of a plant's emergency diesel generators, emergency electrical power system, emergency core cooling system, auxiliary feedwater system, and both nuclear and non-nuclear HVAC systems. Mr. Weber has directed major testing efforts, including several primary ' - containment local and integrated leak rate tests, a i full-scale ASME heat rate test, Tavg optimization ' tests, and main turbine-generator trip and transient tests. Involvement in-these tests has included preparation of the test procedures, the design, installation and start-up of microprocessor-based precision measurement and data acquisition systems, data evaluation, and reporting. One very unique test that Mr. Weber conducted involved the initial roll of a 1200MWe steam turbine generator. during the startup of the second PWR unit at a two-unit plant. In addition to conducting this test, Mr. Weber designed the steam flow control and test instrumentation i system that controlled the diversion ')f steam from " the Main Steam System associated with the operating i first unit to the turbine of the second unit.
4 Mr. Weber is familiar with and has applied many - different analytical techniques to power plant electrical, I&C, and process systems. His work
} has included safety sequence analysis, system steady-state and transient analysis, instrument power failure mode and affects analysis, statistical error g
analysis, equipment qualification studies, radiation. , 4 shielding studies, and plant thermal performance I analysis. He has also had project engineering l responsibilities for a major research effort to ) l determine the response of power plant generation and auxiliary systems to grid electrical disturbances. Mr. Weber has prepared licensing submittals and interfaced directly with regulatory agencies on the behalf of Impell clients.-
GARY A. WE8ER Page Three PROFESSIONAL Most recently, Mr. Weber has played a principal
~
EXPERIENCE role in Impell Corporation's development of Safety (Continued) Parameter Display system and Plant Safety Status Monitoring concepts and technology for implementing NUREG 0690 and Emergency Response Facility requirements. l Mr. Weber's experience also includes field engineering during the construction phase of a large power plant, wnere he performed electrical integrity tests on cable insulation, terminations, small motors, t low-voltage circuit breakers, and motor control ! centers. He also has had experience with protective relaying calculations and auxiliary electrical system load flow computer analysis. REGISTRATIONS Professional Engineer, State of Michigan Registration AND LICENSES No. 27689
.i 7 PROFESSIONAL Member, Institute of Electrical and Electronics AFFILIATIONS Engineers }
ia I a e t I L j
f, . t APPENDIX 8
, GENERAL GUIDELINES FOR GGNS TSRP PROCESS REVIEWS A. SCOPE OF EFFORT What was the scope of the review effort, as expressed by the personnel - participating in the review?
What were the " inputs" or " source docunents" used in the review? Were l they appropriate, adequate?
- Are both of the above commensurate with the MP&L procedure governing this ~
review effort (TS-1)?
- To what extent was tnis an "outside-in" review as opposed to an 7
1 "inside-out" review?
'T j 8. PERSONNEL QUALIFICATIONS Were the personnel performing the review qualified commensurate with the task they were assigned?
~
- Was the collective experience of the participants sufficient to accomplish the job? (i.e., did they have to request help in selected areas & if, so,
.i did they get help?)
Brief sunnary of qualifications /sunmary. C. CONDUCT OF WORK Were the procedures, checklists adequate to ensure that the review would result in a high level of confidence that the GGNS TS are accurate
consistent with applicable regulatory guidance, complete? j -4
- Wh'at was tne depth of the review?
- Did the review consider the as-built condition of the plant? Was there documented evidence of this?
What checks and balances (e.g., reviewer / checker) were applied to the 4 review? v
- - Was operational input reflected in the review?
9 D. RESULTS
- Is documentation of the rationale for the conclusions provided? If not, can they be readily ascertained through discussions?
i Were problems identified? How were they dispositioned? Were proposed 1 resolutions adequate (technically) (viz NRC format / content)? ' j Were there differing views between the LR0 and RPD on the f dispositioning of comments / recommendations? If so, were they appropriately resolved? I i >
- Are there any open items?
I I E.
SUMMARY
- What is your level of confidence that the GGNS TS, as modified by the changes proposed by this review, are:
i
- a. Accurate / correct viz the as-built plant I
- b. Consistent with NRC guidance for format and content
~
- c. Complete
- I l
l
+ - - - . -
..----.o, - , . _ . . . ,,,.--% y * .- -v
APPENDIX C
- Impell Notification Procedure b
9 .h 7 4 e f 6 e i 4 9
IMPELL NOTIFICATION PROCEDURE l l (MP&L GGNS Technical Specification Review Program) 1.0 PURPOSE The purpose of this procedure is to identify the means by which IMPELL will inform MP&L of a specific potential finding, observation or deviation by the IMPELL Corporation Third-Party Review Team.
2.0 BACKGROUND
i.. The basic function of the Third-Party Review effort is to provide MP&L management with an independent assessment of the effectiveness of
', the GGNS TSRP. As such, the IMPELL findings, observations and deviations will deal with potential errors or omissions in the TSRP specific review process. Since the TSRP is an ongoing process, it is in the interest of all parties that potential specific concerns be communicated as soon as possible without compromising the independence of the Third-Party Review. Programmatic concerns will be handled o a ' real time basis through communication by the UdPELL Project Manager to MP&L's Senior Vice-President Nuclear. This notification procedure is
]j intended to formalize how IMPELL will interact with the GGNS TSRP and allow them to address potential findings, observations, and deviations as identified by the IMPELL project team. Potential findings,
,j observations, and deviations will be handled as preliminary until the GGNS TSRP has had the opportunity to answer. Final determination will be made following those answers.
A 3.0 DEFINITIONS
~
For purposes of this procedure the following definitions are givenr
! 3.1 Finding - The need for a Technical Specification change has 4 been determined by IMPELL to meet the criteria of MP&L's priority category 1A, B, or C and was not identified at the i completion of the GGNS TSRP technical review [ defined as j following disposition by the Review Prioritization and Direction Group (RPD)].
3.2.1 Observation - Same as definition for a finding except that it meets the criteria of MP&L's priority category 2. A - 1. 3.2.2 Deviation - Actual or potential need for an FSAR revision which was not identified at the completion of RPD review. L48cdal
~ .
4.0 DETAILS
' Each member of the IMPELL Third Party Review Team must 4.1
; ensure that any information reviewed which could potentially result in a finding, observation, or deviation is reported F to the IMPELL Project Manager (J. C. Guibert) or his Deputy
. (E. H. Verdery) for evaluation and transmittal to the MP&L GGNS TSRP Project Manager and Senior Vice President of Nuclear Operations.
4.2 This action is particularly critical to provide MP&L with real time information on potentini problems resulting from the IMPELL Third Party Review effort. This will not af fect whether our subsequent evaluations consider the item reported to be significant or even accurate. 4.3 Each team member will execute the enclosed notification sheet and will submit it to the IMPELL Project Manager or his Deputy within 4 hours of the identification of a potential finding, observation or deviation. 4.4 IMPELL Project Manager will discuss the identified item with other team members and determined whether the MP&L <j technical review has been completed (closed by RPD). All items will be designated preliminary until MP&L GGNS TSRP h88 re8Ponded. Specific problems should not be reported to T MP&L until after RPD review is complete unless early g notification was approved by the IMPELL Project Manager, j 4.5 All items reported to MP&L will be specifically identified a in IMPELL's report and evaluated as to why the GGNS TS Review Program should have identified them. I 4.6 The IMPELL Program Manager shall notify the MP&L Project Manager (C. Tyrone) and Senior Vice President of Nuclear Operations (J. Richard) as soon as possible the day the item i is identified. I L48com2
IMPELL NOTIFICATION SHEET Item Number Preliminary j[ Final
- V Identified by Date Tech Spec Reference I"
FSAR Reference Problem Title
- 1. Problem Description (Tech Spec, FSAR, SER, Other):
- 2. Classification - Finding, Observation or Deviation:
.k
- 3. State of MP&L Review and Evaluation of MP&L Program's Ability to have found the Problem:
?
4
- a j
i t 4. Initial Disposition: i I I 5. Notification to MP&L:.
^
Time Date Who Notified
.I
- 6. MP&L GGNS TSRP Response: -i
., 7. Final Disposition by IMPELL:
i, 4 ) cc: Mr. C. Tyrone, Project Manager . Mr. J. Richard, Senior Vice President Nuclear Operations
- 4 L48com3 4
APPENDIX D Impell Notification Sheets ' ';,g - and Supporting Documents I T e 1 n A o 1
'? "
>d e
ie
nm+ T _. s g ,s
- s x ,
s s-s
\ *- <
4
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OBSERVATION 0-1 N,- b- '% w% l e 9 4 k s 1 m
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i s-i 6 , . s "4 I a
-N'.sw s s,
- 45
. % 's "- ____.______.______r'11
L l x:. . . - - l
'1 s IMPELL NOTIFICATION SHEET
)'
- -Itumdihber ' D ~1 qr) Preliminary Final Y-3-8Y Identified by . -[tmin\lU Q Date
% Tech Spec Reference SN.l.3.3
- rsAR neference L\.lo.3.\ . l. 5' [ o, 4.6- 3N Problem Title Ac#u.matic level check.
- 1. 'Jroblem Description heh Sph, FSAR, SER, Other):
95AR _J.ces cuuatudcdor e
'185k'\co. S on 3/4.l.5.3 does nc4. *
, ;2R Classification - Finding, Observation or Deviation:
db5erWLh.co beho.Movi[
- 3. State of NFLL Review and Evaluation of MP&L Program's Ability to
} g ,
have found the Problem:
,1 ;
1 f.C.c m pkG, N p a.c. . CLM prcenss LOCLL5d. ho.ve idenM?ied %w, 95AR., tehu.0 compk.k-
- 4. I it his th: b M's. M l
- 5. Notification to MPst:
Date Yk8Y ':no 50ttf ted 0 . Ty'i Co<J R _ _ y, a ir.e 1700 i,,,
- 6. MP&L CONS TSRP Pasponse:
$.tvK4 .,selstro 24$ Are pottet' odDwereq Atty r/cs /As sosrM /destede Jtasrd foot
- 7."$. 449"t42 WedMW CMek of /Metrett eiennen9 Coersat. too.no A dmucet as r<aas'.cJet/tAyrot,t 4/ //fiftJ44 $worcoso A sso A ss /f Ator. L 4 9 %
/4.Wef.
4Atu$s. YUf/f/f AM Ctr$ttrea rr.cf Alytty/<stt44ef YM2 //eslute Eastys:// 420 73's testet Jtalsyng,
- 7. Tiral Disposition hf IMPELL: , , . - . , - , , , ,
AC.to w a $dh 6 42/,*r foMt FJ M . A%2. Udf A.!A'!!!d /AoAl'M 3MfE7* 6 82/ 70 VAUD ptVd1M<V *Vor 66MedfMD ; <<[Soutr/oas .rdmcaroseY.
' # Y cc: Mr. C. Tyrone , ?roject Manal;er Mr. J. 7ie.hard. Senicr Vice President Tuc1zar Cperaticns g- T4 SsAR is W errer, o. davinkn der'vc+
' t ?cd:-3 i.
an cbservor ica-
t41 Tech. Spec.. 3N. I. 3. 3 Suajeck : Con 4cet hd .Sc.ca.m Ominu.\oAors ' h odbie P ery Generd Eledsc. l h bop Sh.4u.s- % (1 acom hek po d a y_) l loewneds consdemd 'in TSRP: I A3.A7467 i k2 3 9 1A7%7AA,Rel.4 (Cil-4cio) 3 BW R (, STS - 767 E673BA s kv.13 ~%2.E412.BA iRev.1; MctL desgn -5pec 1 1 reseo.)ed b3 Tige.\\ . 3
~T_)cco.menb ] F5AR 5ER,C,EK l3700 3
i 3 Discu.sden: j Trob\ow sheds 314 and 36\ hctcl been ger. era _kd . R?D u.n.s reepl' ins 1ssu.e.s dus.40 insu_4?iiisnt
} 'mfpenakn avo_b_ble. to ju.s410 resoluMx o-4 3
5g.0 e.cmmeA GE skded J. heir c2mmen was cci@vM ba cadew ccsascoMm ok h GG ds n bads. d A ,wthsc c? Pa..ts wue wg:na , no g c.c..s.sade.-
. zm Concerns [7 cob \ ems :
[, F5AR ) p. 9.6,-3h ab:ks u.wdes So.cve.'t b.ne.e Tes4s,
%A level e well as pressure skcuJJ be edi{ied Sor %e ommulabc. This su.rvehllo.nce b was aof in % GdN5 Tech.Sgc. 'm4'ne pek@-
The Rew had no4 been picKee u.p u.nder cornmen+s or pmb\em sheeb and h ESAR. msed was compWe. 6duing poda.og b6, no ocid%wal kms t.oe ce. 'iden6 Qed. I h veat ac 4 c h w h ei pe<aka : yes X no - e 9 9 . G O h
. . ~
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't 4
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. OBSERVATION 0-2 ,A 1
1
'T a
4 E
=
1
.1 8
l IMPELL NOTIFICATION SHEET Preliminary Item Number 0 - 2. td_f Final Identified by . kimrm AS QS Date N-3-8d [ Tech Spec Reference O N.b.b.3 t i, c FSAR Reference b .1. 3 O_nd b .6.3
- Problem Title kkf* hot.d LLO gpghtda.ygg Spec,FSAR,SER)Och ffDC LN.
- 1. Problem Description Cirde.d dcw_me.nh u.u "c b."u.sh. be b.sU.ng o.o.c.u. car.w , skcuM ua "schn!' . (*)
# 2. Classificatio# - Finding, Observation or Deviation:
Obswvako(.ramu) f
- 3. State of MP&L Review and Evaluation of MP&L Program's Ability to '
have found the Probles: I Lc.om.ptede. pada.g4. M P2.L o wo.re. o4 rdm'tlM* si-\u.a%n Evdu.a. kcl a.s no c.kangt es0.cd.ced . l.. Initial Disposition: 1
@s COA
- 5. Notification to MP&L:
I Time / 700 Date hk k'ho Notified -
- 6. MP&L GG:;S TSRP Respense:
- CF'M ts A//dW// Art JUL W/1 At@tWMoa.r*. Ato Mrroa AQWACD .
~ 7. Final Disposition by IMPELL:
l
.?NVAt./O edsftt/477dAT ,*
ffsecurionJdJf4cronj.. pff b%J 4)i/sv h cc: Mr. C. Tyrene, Froject L nager ( Mr. J. Richard. Sanic: ** ice Fre3;:' ant Nuclear Operations
~
MT.i \ C. .tO h M.,f'.M d k . Ud$,Ogd Q ndkM I. *. 3 f ? 23' e4m e sch% hu.t. Us #;d\ not cc$ rec.% E ,
[ OBSERVATION 0-3 7 .1 f f 4
- e b
e I 4 l I
z l
. l 1
IMPELL NOTIFICATION SHEET Item Number O-3 9dj Preliminary N Final ! Identified by . (imMtOS Date 1[-3-8N Tech Spec Reference . [4. b .
.; FSAR Reference (,3.2.3 a nd [o. 6. 3 Aic Stee dhMbuMco +e5t Problem Title nnt include _d
- 1. Problem Description ech Spec FSAR, SER, Other):
9.6.(..s.6. \ Aces no+ oamss po_ra.gra.plv
~
C s'. b e 4 6tddeisa h.w 2. s
- 2. Classification - Fin ng, Observation or Deviation:
Obserebn
- 3. State of MP&L Review and Evaluation of MP&L Program's Ability to 1 have four* the Problem:
1Y\ con \.plG3toya4- - ND N E N LO & S \d &t'Y \ \ i bg K n L G A.
- 4. Initial Disposition:
M'
. 5. Notification to >2&L:
Time U " Date 'ino Notified - 3
- 6. MP&L GGSS TSRP Response:
/Audra.$4 ear d ezz. k n becoa utsorrea so *4 base.r.c wts trcm dNo
.?cuisria w 3. - #4 c. mm.wso swras i.s ro p e r ise.,rs a sra r a s trcou w J6as ts, sy rnka metspra.) ra yn Astr.wr .rgers se 7:ye A.6., .
A!'Et4 2. 4%tVs: Atr-nwremet rces ar .suwestt4 ace rstr.
- 7. Final Disposition by IMPELL:
fAUD 0AffitMM41 kJN/CN M'Os'# M #'*/ " Ar4443rortyp gj 4 VAus Dzu/Anoasj Erletter/da SW NWA'V= cc: Mr. C. .yrene Proj ect Ya .sger f Y" W Mr. J. Richard, Senior.Vice President N'2 clear Cperations Lt. Sed =3
l
., . Ic-7 1
Tec.h. 5pec.. 3/4 6 6 3 6ubled : 64ondb 3 Gas Treeswed 5ysh
' Ras.pensbie Org: Bedde) 2 h% 5%.b.s : '~de.d
~
~
. Docu. meas consdemd 'in T5RP:
%4s-g-63a.o Re.13 CcJes. 3.9.3 Rev.c b 3.9 9 'fev. /
\\02. A b4 2 A Re 1 C3ulde 1.52. ,'Rev.2.
[ T) \\0 2. 6 1 *0 S 9&ysd"s#J'S goi.c _qs _ q./-/-o
~
G(= K 135o3 %4r- E-/2s 7-f s nev.G 90 ys-n-6 sa.o.-Gs-/4-8 96yS- E-I257 o.2. Rev.lp
,{
3ccumenTs revtetoed 'oS I g e.\h ,; Tc.xp 1.T4 S PT 41. '1 06-op -1.T4 8- 8.- 000 9- thJ 2 I 95AR 5ER 1
- .! h o , d cd c 1 3
. C,v a d e. l. 5 '2 i b . i. omd. '2-AM bT 14510 -WI 6' i 31scu.sscn.
j TiY.'b\em. s.we_ds l CO33 06.2, .9G.O. .and gn !vy 6..gn Og ine.xE#d. Ex4 ens.'we_ i c _'s i t h t.;c n c e vi c u ] v. a 5 2 cenas24.d 1 V-5AR- cle.nge re.se_dW . j C c . f i,...a.4 g .,c p c. 3 ,_,_g y 3 ,.,,g g , g ,,; g , q .y ,, ..,i, t.3 ,
, % s, % s 3 1. .
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. 2 'iCOO u.5 NU b $ co n58t".i d d.- t Tc exW'n c.kn and asPA and chrom hs\s.
\
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u -a e oss-5~ O merns irode>*5 : .
. < Ai< &w 61*Mion bst os a.c.1.s2,pra. c.s..b 3 is nok 'me.\ohA in %e Tech. Spg.c..( Aes L us t0-tci1f, App.3A s4aAas ccag6p 3
- 4 p[7curgea.pk8).90AR.1 40 %C,. \,Sa h1 nd %.a. hsR ( p.6-3.t) uda s 3
- G r 'in S u.gp\e m an+ 1. T3 rediIng ta.o ac. b iot om p in progro pk fo.(.1. 3. Vo_rious decu_ments u.s.c*c4m" M u.s4s. Lbas skeu.td ha_. sc.Sm b k correck and prcide.
~ /y3f o_ce.au.ca4. e. baufme. bc 4es&ng. V5AR po.raya.pk.
~
; L .a.3. t. @ p . L,. 2-so) skcu.!d ha.ve ta.o su_cnds, noi
\o\ s.uends. 93N2 sbhs in 6.53 %at \eng 4envi
/hveu&\ouo h 2.30o c4rn. Te.ck %ut.and preo9 aad G-)
acuwaen m et peraka: yes X- no ___.
~
p ta e m. 6 e4 e
- an - a nu.a 2
1300. O
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.l OBSERVATION 0-4 3 ,1 I .
1
?
A 9 a 4
+,
n..- l IMPELL NOTIFICATICN SHEET , l Ites Number 0-4 9 01 Preliminary X Final e . Identified by ) , I (YW rht MS Date //- 8 Tech Spec Reference 3k. [a. 7. 2 TSAR Reference bA Problem TitleNd%enI.QnWLCA atw 5\na %m4e.t_.4S.15MtA ton a a ' J
- 1. Problem Description ch S FSAR, SIR, other):
' Recommend induding su rve'diox.e Sor he, integrI42 o( We seo.t box and Hood spq shield.(% per \8 mordhf
- 2. Classification - Finding. Observation or Deviacion:
i Observa#1on
]
4
- 3. State of MP&L Review and Evaluation of MP&L Trogram's Ability to have found the Probles:
A d\OAOkrec.OyMwendah. h6 6.N % 6.. i is probo.bl3 su.yect +c opiden. i . 4. Initial Disposition: W
. & - Ls/ ,y .
1.1 5. Kotification to MP&L:
.ime / D Data E Who Notified-
- 6. MP&L GGNS TSRP Respense:
$twenuccc x.ist AfpfAurz Jed /dewliM /2 TS- ) Mf+L ""
Uccx FM /deuttwas sacM A Arguewwr se 7;s. sp erwst
- f f^ e rs ars r4 Wyb4/w Z,pwirpe* .fysrses,
- 7. Final Dispositica by-!MPELL:
., f/gssp lfhfggy,47? pay MctASJig4f/d/ ffdDMJ NM *M # Es.cosa rics /ArW JATM W 'W- f ft Astr.c . j cc: Mr. C. Tyrone, Project Manager /a/gy Mr. J. Richard. Senior Vice President Nuclear Operations 1 1 L48cdm3
s t e42. Tech. Spec. 3/G.'l. 2.
~
Suget* :_ R3drogen 1.gnWien Sus 4em 3 heenible ery Bec.k4. eA L'% Whs : Tleck (Incom.pek pa.q) f Docurneds consdered 'in T5R.P: f l
%95- E- its % shh.% , h.3 % da.c 40 ower 1 47 , W .3 sTs , a.ssaume. PW l a
4 98 b I 3 wih 'sce. con-lens i
't E- 1702.P i hv.2.
f! 3ceumeds relieu)ed b3 h .pe.\h , Treop i.EL1.5T&i. (ncooF) , %qs'- E- G 02.9 g 1.ed.1 l 1 06- EL- 1EL1-Q- 0002. ,Ree.g.o (2 41 operable)
- c ,
f O(o-OP- 1Ebi.- diseMon R-oco wWh i, he,s.O (> 000 F) Nac.R.in Lenn'is l [ T-SARs5ER 3
} Dismsm: f j Troblem. Sheeds 069 and \2 8 had been gemraded. , , Vio 1). No.c.Klg pormed deM. ds on: emegeq pouJe# . Su.ppig, mumkp +ransfprmer (120/11v), cu.cren4 dca.u] ~
4esh Etc dage. 4e near presmig quipment high heat o.reas anA cesuWan+ eppment problems (standing bus eM 9 000, g\ow p\g oround a resish.nce rnou.n+, { and use o4 sea \ed box /hocded spra.3 sh' sera.Qor cenWment sprau, ard pool suaali prokc4 ion. Alo4e: Mo cliscu.ssion in Tr5 A2. cin correspondence w da-
s wo
&.~
Comms[7 cob \em: A4ec es~ssen on sssh operoEon ena rene oS open isso.es, believe 14 wou.(d be pruden+ to ! periodica.tt3 surveil 4he. in%ri e4 4he s d box
,. and hood seg sMeld, Recommend o_ survell\ax,e.
ok least orce. per 18 mon %s on o g\ow ploog%
~
bass. Believe 4h'ts rec.cmmenda_bn 'is corn. men-suraAe. ult %. a. nuu.ber o4 ower -k survei\ta.nces I, in %.e. G/AMS Te.c.h. Spec 5. Loss o4 integrih cou.td i a.%:k ojew p(og per(ocnua_nc.e.
'_b.pell McM9e c_4cw $kaak generahd: yes N No
.!ii I ~ 5 9 e b e l l
m- -w-- - - . - - - - - - - - . _ . _ _ _ ,_ _ _ _ __ _ _ _ _ _ _ _ _ _ _ ____ e O O s a 'T n
?
OBSERVATION 0-5
- a i
I
,A 'T 3
lb e e 4 >e 6 O l I l i
\
1 IMPELL NOTIFICATION SHEET l Item Number O-f Preliminary [ ~ Final Identified by Date 8k Tech Spec Reference ,d 7 3 FSAR Reference N4 Problem Title W W b / M n* /*! $fr*fpf..CCC**f
- 1. Problem Description (Tech Spec, FSAR, SER, h: g[ #
r e. s m s,- s a - , s a o c c m a n n gopps,a.r fooo % as Jcte g be / dito uses Cf4 vs JC h
/4 fecA Sanc.
- 2. Classification - Finding, servatiojorDeviation: d866Frd-T/4v i -
}A 3. State of MP&L Review and Evaluation of MP&L Program's Ability to have found the Problem:
~f /gfe. e. beu W p / be r[ hhtes~$'444#U l , Q & /j f 'e d f k 4 Y / S S O C -
4
.. 4. Initial Disposition:
- . JuzyM CawM r
- 5. Notification to MP&L:
Time / 7dd Date (( Who Notified . /f'NC
.f
- 6. MP&L GGNS TSRP Response:
ry/.,r /.r.tae. lDbeM .Sbee r* e/9 , .vNtu/ Alae 497 sr/s7.c, MAoarte.1 Le
- 7. Final Disposition by IMPELL:
Doddo g?histsJr/s/ $4ssa on /Jsat Mm'6 444A0f f4fd
**'M*- g y,/,,,/,y cc: Mr. C. Tyrone, Project Manager Mr. J. Richard, Senior Vice President Nuclear Operations L48cdm3
. . \ e42.
E Tec,L. Spec. 3/4.4.7,3 r Su.bjed : .Org' P9
' ram =n6W Ory OvcLM
& CW L% 5%.%.s : Mss /soe Doed consdered 'm TSRP: l#5'/h2-[rs/L [s rr ml & g4 cgh, 2
T i 3ow.menb rese.Wed b3 Lpe.th Fs/H1.[5s/L/rr.5
] & (2M M,/k a-4 c dcaQ k ,b-
, Gy hA ,ph W 3{iv,x4
%~
a 60 %pe Ma [ _ g i w ~ &kon w% Fr*w MM < k i u % tose & " h i
~
[
+. g. 7 3. 6 . / m M 7*W
\a e ,_L (.o p u d dr d N wwb m . 4t ~
%.d % ioco k e &
llfo ok A k Ltd f M r f mm cv]
^'"49 003 .
% w to l186 y Na g oG1 N c. w f ^ = w c A &
D t u - m e% tavoek~ q '.
% 2 0 g.J _ mf,a n A w 4 g GuAld ed . f. % c~- h i- i &3 I
9 6 m 4 9 4 'T I ,a T e d 4 9 1 b 9
.e e
X. 4 f 4
; . O :
1 bM. erns hCONe.xAS : * * '
.% g n a 4 w M~
- T IODG S -
Q fp 06 -o r- I bl -9 '003 E '
, ^
gn o p__c. k Nut C W "
~
hiEc,,he~, 9 O e e _ f G 1 1 I A i LO t M J
- o e
~ -
s l
- 1 l
w O ge-n e OBSERVATION 0-6
'9 t
a 1 1 1
.I h .A i
t& 4
t IMPELL NOTIFICATION SHEET Item Number 0 - ' M Preliminary N Final 4 i Identified by . IMfit l\$ Date i Tech Spec Reference b b.)s k l . '! FSAR Reference b.3. k
^
Problem Title Q.ht,hk O O dWJL. C.OY\ LCI
, 1. Problem Des ription h Spec F SER, Other): . Ap pm c.ogLa.u., +o R6.1.3 L hu.~t, pa.ra. 0.t.c. ,
conMch u.ath C445 Tec.h.Sptc. 4 8.2.t.e.
- 2. Classification - Finding. Observation or Deviation:
i Observakn
}I 3. State of MP&L Review and Evaluation of MP&L Program's Ability to have found the Problem:
1No keh MfYadt301.L ' MN O
~
'\de. asst 'teld.. Ah d teLO W M G h b '
, 4. Initial Disposition:
gM d0 lW I .
.! 5. Notification to MP&L:
. Time /7 C# Date 4# Y Who Nocified M
- 6. MP&L GCNS TSRP Response:
fppsex fjear et .345' NAt beca Menrra A adhes NO w s AJ **// As 0 - 7 ** 4 6 - 8 . Cui,ru. rig 7kt.wina/opy ad /tashy e dhau O*prpuriy awand.c. l
- 7. Final Disposition by IMPELL: i L&up dhserams . Akraenon p.ra .r.oramray.
fA*'*'4 N*M=~'A*w.) - q,,3 cc: Mr. C. Tyrone, Project Manager Mr. J. Richard, Senior Vice President Nuclear Operations L48cdm3
142. Tec.k. 5p. 3/4 8. 2.. I e i+
. .. .. Su.16ed: B. C. Sctute_s - Opera-ing Tiv h 2-
~ ~
'Pa d n d W O r y G E h h. M - 3 14. 3 Why So.4u.s Re2 (LccS% ele poda.TL P
1)oeu.m,eds consdaad 'in TSRP: EsAR ssR, BWR4 sT5 g 3 GE VPF E22.-501
. %tt s- e- 102.3, b. Ito i OG- EL- lL51- R-o oc l
- } 'Docu.menb resewed b3 Impelb FsARgieR,I.EEE SM. '450-icrl2.and 1980, j
%.C,u.tde 132 3bv.2 3 T.eg Q.Ude l.17A Aprit 19mnd hi 3
' % H5'- M- \\oS A ,%L \
I T- l'2.59 sh4.1 b.T 3 3
. 1 E- 12.v1-ot ired.ll t
huo m: [ 7cate., d4 135,143,227 oA 2.88 haci xen $snam.4ed. ] LRO con 4acAed veAr on 75 2.2.7. BFC lincorporded as-bdtit load &c Ts tar.
.Docu.mented pktbsce% bg spc .
G4us rs = sTs -> c,ces Ts is og.
. ac,as Ts is we consenabewn s rs 7 GCnM5 TS is OK.
ConQsemed opereMon,'snk.cloets ad alarms on oa.MerS ! room. venWQi Ga.ns. Merb shee+ 1o. id d ed.
la. 33.s.2.1 Concern- A7 bul.tc u.p ckawg cka,rge. l heen3. c6cm ey.hausk -(c.n a.la. cms-
\oa % w nof runni
. no mobc -Q\ow high.'i.e.,hperab.),ie., bou nd ImpeAi reviewer t.uas eva.lu_o_Mg need G.<- Te_ck. Spc.. wvitba recui<e.meds on boAe.g room. edaust -Ga.ns, ,')ca.rren+1 3
, wo+ ockitesseci 'm STs e.e cac,Ms Tech. Spec..
7 A(Aer ev'a.lu.a4. ig s$s-e.m. operanon , % hk i h4 %e. bo.% avd b W hu ose
,i bulu.p % pr'im3 co.Ce qs6s W m-
! re.v teualg 1ocFR50.%, h condt.t.6ew w Mk M Te.ck. Dji"c5. a.re c.c.cr e.c;F l 4
o.~J %L ocid W , w l (a.m. survel1lo.nce need ; not be. 'tw4talecl. B.PC reviewer c4 C4M6 Tech. Spc. LA.B.a.l.4 ed not u.nlerda.nd 0r%s.6c raded , ba4. ec a,d c.cnQtsoA %. a.nnu.a.1 u.3as bks4 a. %ca A i eense. va-hsw_ in.h suruit\\a.no sckedale. !
i
. wz
--4 o - (o I
i Concerns /7 cob 6#s .) i MR Ekdes cou.PL d* fo 7%.c,ade i32. ih2. in App.'6A. The Pe-g.6a ?citMcn. C.\ c. 64cAes:"The. bab$ serse.e 4ed deschW_d in I.EEE 54d. Liso-R75 Shod be. perbm.ed 'in oM%on 4o4ha baMar$ perhrmetw.e. k discho.%e 4esh " G,4 a3 Tec(,5p,_e. 9. 8.2,l .e 6+a.les : )
" Owe e per 60 u.on% in4erva.1,%13 per@rmaue.dischage ~
kd mo.t) be perSemed in l'teu. e4 %e. bo_% seritce
. 4est." Aweoxs 40 k a. conflic4. -
(~%g.6uides i.a2. a.nd \.m re4er b 2.see 644. 450-A72 IEEG 5td.450-\M2. a.rcl 1976 54cdsu.nder Capam4g / Tesh 5ckedu.le. ,Terhrma.nce .(&) d 1,eu amu suei pera yes3 uo e 1l ! M A 9 ec4rwuwa 4es4 09 bo.h 3 ca.paug . . . sk.cu.0 be de uitEm %e b4 be gears o4 se.rsce. I ! Th'ts 4esMs no4 addressed 'm h GdMS Te.ch.
,1 4*-C- J The STS M GMs 76, g, sve an 'interM l 3.g e con @ch be4toeen tt.8.a. i. e a.nd 4.8.a.t..G. IE pa baMergeg;paitj'is 4 90% o s ma.n.da.ch.rer's robg 3 c nnd 4es4s care. rec.uired.(. 4 8.a.t.Q . l Thts con-QUcks t5t% 2 80%) cr. Aescc 's n t\ B.9.\ l unek, anouas 5 yea.r 'm4ervals behu.taen.1 80 -
k 90% baffeee capadihi.(su-p.acd 4esh kor' /
i
.g 3l4. 8.L1 The a. ppa. red c.on.Qk.+. i ohu.of. not sIg ni9aud) 4, Skou.Ad hA. cle.ox.e2 y.
)
$m IGEG W. 42r0- M71aed RfC lAaS so.me Loor&s 3 asstxn.e.d 1.EEG 54d, 46D-lHT had e me woeds. 0.ou.ld no4 loc _cde. coF-tg o 4 LMf
'4 versow cd %e C-6, MS si te. .
'T 1
u
'?
I
, I ma 4
4 e
- -- --.rv .- w. w e -
t t' t-i {' OBSERVATION 0-7
.1 't 1
4 k i1
. 9
)
)
, .t e
s
t IMPELL NOTIFICATION SHErr
. Ites Number 90 Preliminary Final Identified by . W\ id $ Date k-b~ b Tech Spec Refarance M. b .)
rSa R.ference B. 3. 2. Problem Title b.6uide[T.EEE S+dd co osgJtconkl'tY,
- 1. Problem Description hea Spec. FSAR SER, Other):
'~
Apfears cogruar_ % R.c,. t.s2w 1.1'2A(1.Ese s # tent)uaw restud h per4r.mu.aAes-\ ultWM
- 2. Classification - Finding, observation or Deviation:
2 Observe &on 7 3. State of MP&L Review and Evaluation of NP&L Program's Ability to j have found the Problem: -- n Lewplek Ap. Douhh i% wou.ld kwe kb6h \ 6d . h$ Q fe \ eld L.A.DS ccm R.,h.
- 4. Initial Disposition:
I~ 4./ M N i l I 5. Notification to MP&L: Time /W Date b Who Notified t 4
- 6. MP&L GGNS TSRP Response:
fAl//eq.fdeer= d.N.C A41 bWa) Altsire'd to Abm twJ sim, Ar astu-Af e-4 4<!b o-3. dwa.rusy twwwsseusy saio uswe dereew ofM/441'At)4 CfWAlpdn6AJ.
- 7. Final Disposition by IMP"L: .
//sti.sa 88/fd./ Arm) . /ffwtNo.) fd7W $477f/W7J' A,V*
O lN N f Y##' *
'l/f,hy g
~~ '
ec: Mr. C. Tyrene. Proj ect Manager Mr. J. Richard, Senior Vice President Nuclear Operations (+)h4 4wo gears o4 serdce. con.@ds wi+L GsNs Teck. s pu., A.8.2. \ 3 1.e.) not 'mchuled.
' lef t Tear.sp.3N82\
sua;ea : D.c. Sources - opera 4nS q heeneste ery G E ' BechAe\ D'14.3 % . a 2. l' h% sau.s : LJ (hcesp,eAe Aagd \- 1)oeu.m.eds consdexed 'in TSRP: resAR,ssa, BW% sTS , GE VPF E22.-501
; %45- E - 1013, b. llo
; OG- EL- lL5'\- R-O 00 l
}
~Dec.u.me.nb rese.t.oed b3 h pe.lh FsALseR,1 GEE SM 4sD-It2.and 1980,
,} %.Ciulde 132 3h2 3 h Qd.tde l.119, Aprit 19mnd bl
% H5'- M- \\o6 A ;te.4.1
.: ) T- n.59 $M.t h45 3 3
'I E- 12.v7-ot i Rev. l1 liwasm:
i
. 7coge.u,3keA3 135,143,221 a.nd 2.88 had Jeen $eara.4ed.
LRO contac.kd vend.or on. P5 2.2.7. BFC 'incorpocoAed as-bdd4 load ?or ?s tar.
~1)ocu_menkd pkbek bg EPc.
GG us Ts = STs -> c,c,as Ts b og.
. GC,M5 TS s5 uce conseNa.%svc %a.n STS 'r GC,M5 Ts b OK.
ConQcued eyeca.Nton,'takc\oeVs ad alarms on bak\e.r3 roo ven%\aben (aes. Mec+o shee* ic. iaded.
~. -
g 3A.s.2.) Concern- A 7 6Alc u.9 djin 3 ckage. l
... Meerg recu. ey.haust -{a.n a.larms-
\ous -%w
' e. not ru.nn.t t.
no $\otn mo%c hi 'gh. 34em. pero 3u.kie., bou.nd , T wpe.ti reviewer was eva.hA$ need b- Te.c.k. spc.. .sa.<veillo_wu_. recuiremanh
; on bone.$ reom edumst Cans ,)ca.nen+1 3 ,
I ywt ociatessec) 'm. STs e< Gc,Ms Teck. Spec..
'I AG4er ev'a.lu.d3 e$s-e.m. - operxAon , % M I +ko4. %e bo.4e$ a4 %e.~ W b.s are bd.9 % pr'i % 3 s (e.g qs 6 s W re- ! revtewig loc.FR50,%, %e. ccmdtu'tw >j- tus Mk % Ted. Spots, are c.seec;r
- o. d h ocid'bl Go surveilla.nce need not be. 'ov_.bdecl.
B.PC reviewer 04 GAM 5 Tech. Spc. 4 B.a.t.4 did not u.u.lersta.nd crA6a was (or a. dqiE raded b a 4. e r a.d c.orSud h o.rn.u.a.l. ks4 cu cense va_%sw in h survei\\o.na_. sch.eckde, .
l M , , , 2.af2 l r + 0 - (o
, Comms /Treb\eeV N fT5dk skes comp \\*"E Io 7% .c,ade i321h.7 in
. App.3A. The %.C,uide 7mt6m c.\.c 64cks:"The. .
)
ba.43 serse.a 4est deserth.d in nee s+a. 4so-s is shod be pe.rM 'in oM$on 4e4ba bcder$ perhrma.WE dis %e 4es+. " C,c,45 Tec.L. 5pu. 4. 8.2.,l .e 6+ ales : 1 " Owc.e per 60 m.cnw interva,1,Ws per(ecmo.ue.dischage , 4e:d mat) be verSemed in lieu. e4 h be.% sectisce~ kst." Avoeoxs 4e he a. conflic4. - (h.C,uides t.32. a.cd \N154 rebvr +o I.EEE 64d. 450-19K, l! IEEG Srd,450-\9T2. a,nd Icifo $4a4.e.u.nder Co. pact 4g f Tes4 Schedu le. 3 TerSrnta.wce .(&) T y e tt Mo#@.ch skaet geterah_a: yesl no ill
- M A7 erbrm u a M 04 bo k3 ca.Q . . . Lu.g l j! >
be d e. Wt h g e. 6 4 g ,5,,7s ,g w g 3 This 4esh'ts no4 oMre.ssect 'sn. %L C@S Tech. ,
- ?
fThe 6TS oA Cz,Ms J l
, Tech 5p. have o.n in4ern2 g.g 4 cone \'tch bekeen 4.8.a.t.e W 4.8.a.t. 6. IE h !
- bo.4\e3ea.pusg
- ss 4 90% o& mau4o.ekrer's j rabg 3 a.nnuA 4e54s c.re. re.c.uimd.(. 4,8.a \.Q . l This con-9\'icks u.st% 23Ohcttheitctin4B9; y
5 year 'm4erVals bedtoee.nr wi 8 u.)Nch., a.\ lou 3s
.k c10% battera capac.ih.fsu.vj %1 MsN 46[ _1 n
4 --q. 4 -- - < -
+ t 3l4. 8,Li O
Skeald b.a. cleos.ed up, T'
. he 'IGEG S4. ys o- M72a.d MiO buts so.me WortLS 3 assan.ed LEEG 5+d. 4st-Imr ha.d }
ems word s , C.ou Q u4 (ogh co c4 377 4 versow o9t %e C,G,MS site .
.A I
r. O 6 l 4 6. e
.t ,y y -w- .
m.
I T e o e T. I o e 4 9 OBSERVATION 0-8 .A T i a c> 't A I a 'e k i e
*P 8
4 Le .e
t IMPELL NOTIFICATION SHEET
. Ices Number 0-8 d Freliminary i Final Identified by . TL th v% W\ S Date k-M8 Tech Spec Reference 3/4.B.a 1 . FSAR Reference h.3.1 - Problem Title Id.6 M t_, bd Ih .3y\ 64 LW k M4 In 4
- 1. Problem Description hh 5 FSAR, SER, Other):
Apprexh conflicKrecpres ch%%ebeen
- 9.84.\.e and 4.e.2.1.C. JAnnu.o1 ksh be capaci% N
- 2. Classification - Finding, Observation or Deviation:
Obss<vdon
.1 t 3. State of M?&L Review and Evaluation of MF&L Program's Ability to
{ have fcund the Problem: hCOyW. k Eb Odk COO # t
.i i ha. ,wicewe e AM J men 4.InitialDgspositon: . J e/ y-y-ry hps4/M M ! 5. Notification to MP&L:
Time /7N Date Who Notified
- 6. MP&L GGNS TSRP Response:
)@ogtex cl%ee r d.h(.C ).4J hs) MMM 'JD Abbn.tr 7*M m, At* ' ' * * '
.. .*s o-i ~ s-v. cumy Aniksyy no A.;m 4.r.,ao
. niyunzy .awom., .
- 7. Final Dispcsition by !MPELL:
ShL/O 8/JdNAy?en.! a kJgcugo.J'k!W S M W M)'* 1 cc:
/k vas h N dtb M s l k d &
Mr. C. Tyrone. Project Manager l Mr. J. Richard, Senior Vice President Nuclear; Operations M owe isin con t,xit % g e.rt/r 'tys k r & \
'8*#"'
48thS hoc qac%'tc - t T 30B?o A is.a.i.. W y 4 . B A J e. c e s p.e c.s' v el q',
. . .- . . .. . . - = . .
t
. 1 42.
Tea. 5 pac.. 3N.B.2\ _._. Sulgeek :. . b. C. Sources - Operadn3
~
'Raipensble Ory GE ,i BechM Div 3 ~ D'iv h 2.
hwg_ saks. LJ (LcespeAe Ay-) I' 1
~
Deemne,4s consdaad 'in TSRP: EsAR,sER, BWR4 STs 3 GE VPF E22.-501
%4 s- e-l o2.3, b. llo OG- EL- itst- R-o oo (
} Domb reitewed bS 19 eth )
, FsARsseR,'I.EEE SM 450-IdG2 ancl 1980, l
%.C,u.ideta23h 2 3 h.Qtade 1.17A April l9T1and ht
)n % H5- M- \\o6 A ,ht. \ 3 l U 1 T- its9 sM. \ %5-3
'I 3
] huom:E- 12V1-ot iRev.l\ l
. 7cogem .se iss,N3,227 a.us 188 hac1 oeen Senem4ect.
'1 l
. LRO contac.W ve. dor on 75 21 l.
BPc 'incorpoco.W as-bde load for vs tw. { 1)ocu.enW .pklosoeb bg SPc.
. c,4 us rs = sts -7 c,c,us Ts is o_K. l
. ac,us Ts is ere conse"abe wa.n s ts 7 C,C,uS Ts is OK.
Con %cm.ed opera.4 ton in4er\cets ax.l alarms 'on s room venh%w bs; %ch sheeA lc. iaMaA=1. ac.hr3
t 1 . . la. 3;;tt.s.2.1 Concern- ( 6lc.u p duiing ckage.. i l' - _ hee <3 coca ey.haask (a.n a6ms-
\ous % us
? no &w i.e. no s mobc hihk. 4em.t ru.nn.peradu.p bou.nd ,ie., l T mpe.\\ reviewer was evolu_a:43 need 4- Te_ck. Spc.. .surveubv_. reculemeds o n boa e.v3 reovw. s y. 6 d S a.ns, ,)c a.r m n4 g ii ne+ o a tessecl 'm STs er sc,us Teck. spec.. AGer evalu.aM3 s$s-e.m. opera Aon %M 3 I
'n a4. h e. bo. % a d h W b 3 ose i
bc.t.u.p h pdg,Sodek. gtpems W re-I revie. wig 10cFR50 543, '06 ccmduItew lj w M k % Te.ck. Spots a.re. c.o<rehr o J %c oc:ldb~d b survel1lc.nce need , >$ no+ be. b.hulecl.
~
B.PC revieu3er 04 GGM5 Tech. Spc. 4.B. A.1,4 i did not u.nderata.nd ora 6a tuas foy- o. %a.;iE raded l ta4. er a.d cenQ.ac.d h conse, vak% in.h surve&na a.nnu.a.( 4es4 1 sckeckde.
q' 2. . u.
,- + o - co r /
Caneentsl 9 coble m W
.D j; (T5h5~sMes compkvee 40 h C'"tae 132. $eo.1 in j App.3A. The %.C,tade 7%t6m c.\.c e4c4es:"The_
I
- babg se< Ace 4esh descitw.d in T.eee 5+d. tiso-s is i ectdA be per%ed 'in addkn bh baeer$ pechtwa.vce (
1 .
. di%e 4ed." C,cius Teck. 5p. 4.8.2,l.e s+ ales: )
" Once per 60 nwn4h in4erva.i c4tds per(ecmau.e.discha.ge
- ~ hak mat) be perherwed in Uteu. e4 %. bo.%. serisce ;
hst." boeors 4e ho_ a. mnflic4. - I fg.6 des \.32. a.nd \XLM re9sr b I.EEE $4d. 45D-19td 7 IEEG Md. 450-\t2. a.n:-l 1936 $4cdeAnder Co.pwig i ""7 ! 'I Tes* 66edule Ter4rnta.nce .(3) 3 "I h e,ll blo % ecMcw SW generale.d: yes Y no i -
]1M A ver4 cum. 4ed os bc.% c_a.paug... sLou.g be made. t.dt4Gn %e bsA be gears o % sa_ race .
Th'is 4 eses no4 addressed 'in. %. G@s Te_ch.
- l ._
6p. j [. m [ The 6TS o J 6C,N5 Tec.h, 5pu.. have an in4erna.\ \
~7ge con 9'tch be.ht.oeen ' 4. 8. a . i . e a.nd 4. 8.a. t .
bo_4\ergeg.pasgis < 90% 0 h YWan.u.ko.Qb. rems ch3 3 a.nntud Aes4s a.re. rec.uired.(. 4.8.a.1,0 Ts3 c_onSucts u;t% 2 3ON erAertc. in 4Bg;g, 8 : t.uhtek, ahos 5 ye.ar 'm4ervah be* weens 80 % tr.
\
bsOr
\
q 0% ha.+feee ca P AS4d6u-P. ga.) /
.. _. ~ - -
1; 3/4. 8.3.d The a.ppded con.Qkk i albgk nd sIgnibnh sbald h.a. cleam.ed up.
. Su_e. IGEG SM. ysD- 1972amd IMO kS so.me Loeds 3 assavwa.d LEEG 54d. 4fD-1977 had 41rv4 woeds. O.ou.id no4 lom4e. coy ch LT7f 1 versow edt % e C,G,MS site .
7 i
'T
'} e t ed e - , , -
O 4 i9 S 'At a T 9
. DEVIATION 1 1
T 1 is 9 I, O i k ,b
. e l
IMPELL NOTIFICATION SHEET Item Number DEV-1 % Preliminary X
,. Final i Identified by . iwi ins Date 4-2-8'l Tech Spec Reference SN. /. 3 FSAR Reference , Q.hkg k.3-k , M k.Nof10 ,
Problem Title brCor'm u.P.1 a.SSerttbf4 />.)61 [f
- 1. Problem Description (Tech Spec. FSAR SER, Other):
VSAR To.b\e 13-1 sloks uxdgM is (ooo b. Vdehh4 'is E I,% tbs. b.et buedle s Goo ibs.
- 2. Classification - Finding Observation or Deviation:
C l(L Cv\ l
't 3. State of MP&L Review and Evaluation of MP&L Program's Ability to j have found the Problem:
MW 'P S
; iden@@ed %s mmer devioAlon.C'0 pC.S$$ L.OCLLY
- 4. Initial Dispositica:
I
~
g .4 / M N
- 5. Notification to MP&L:
, Tir.e /70 6 Date Ykk_ W o NotHied O.7ptoq,
- 3 l 6. MP&L GGNS TSRP Respense
No 4Wx. dye Ja./dee.ar %S. Ada f.f42 ey ec: Mr. C. Tyrone, Project Manager Mr. J. Richard, Se: tier Vice President Nucicar Operations L'.?c h3 4
!Ck1
~Fec.k. 6pec.. 3/4.(,.3.2 M je.ck: C.cnko.Inme.nk 6prg 1
~
h L? u S h\e O cQ' % Ec k l Anog sus- L a (1.nco m pek p Ka y ) loca.uteds consdared 'in -T5RP:
%45- K- \ o8s A , he. 9.9.B BWRL STS
. %45- M- 1085 B ha. 30 B 3
!l
%AEt\95EA %.1 3 i h. meas resewed bS hpe.th '
- ., VSAR i sER, I
%95- s-iss.o (Ts.sec..) s ecag Engr.6. noge 'i 9,45- M- \085 6 3
- b. GOB I
.. 31scu.ssen:
,i 'Ab\e.a s! ads ot2, ta a.nd ast had b.mqtneed.co.
STS sAo.kd do smcKs.jo'trJ esk 6 qsk.m. thPC OdVad againk u.ith 4ec.hnical csoScns. RPD
~
[ oesc ccds APG cce.cmmendaMon basecl on
'ined ux4e. 'ysVeaMcn 4r deleLn in %e.'m
.s eptme .
~
Coneeens f ?cobler.1s : '< VSAR Ah but. 3ro =@ px4E M 16 gem of l 90phA. (bQrm b3 chc cbeu.merfs.) 35'ox it,= 56cegpm . db. e.prg locKne o.ndg d 5 ass.u.es a spq Mou3 roAe o9 5Gsoggen The. S\ota
, ks4 Sor h s6sogpu_. is Ao. h RRR R% to 4k.e.
6'AP Pdon pod.( RwR pomps have. 742 %Prw@ 24ps'td.) 5b@ - 5600 4 l9, ancl RBR. y>u m-P5 h*VE " '
^
5600 ad. uoAe. &\ea ; hence, beGeve. &secepc.nc3 i s no+ 4 sogi fco.nhbut need 4e ree.cnJde V5AR and 4 6 3 2-
,heen Mc4%.ch hd generaka: yes % - no ]I l I XCd(Adkng kh4 %S A po.c.K% e,gno addg(tend $ke.M,s t w e r e i d e.n 4 % e. L 4
1 1
.l
6 t DEVIATION 3
'T
.1 t 4 i 8 e T m
.O to e
3 1
s i IMPELL NOTIFICA. TION SHEET Item Number D Sd- 3 Preliminary N
, Final Identified by . kkmMOD Date N-~3-b Tech Spec Reference 3N.6.6.3 ,, FSAR Reference b.2.3 d#\ch b a ba5 Problem Title . b v d6 (ed . CO Ad 0 M.0.-
v -
- 1. Problem Description f eh Spec. FSAR, S Other):
V5AR., App.3 A re9exences Rq.Cw.ide. l.s7. ih. l (or 3 c.capbmu.. SER.eci Te.c.h 5;w.s. re,$erence. b.2.,
- 2. Classification - Finding, Observation er Deviation:
6\ll(A., On
- 3. State of MP&L Review and Evaluation of MP&L Program's Ability to
'{ have found the Problem: }, LcontpieAe. padhcy . MPLL QA curo_re.. tli '
- 4. Initial Disposition:
b' I 5. Notification to MP&L: Ti:e DM Date S 8f 'sao Nottfied (, T%@AIG. i
- 6. MP&L GGNS TSRP Response:
f/odten afdeer t 82% A*2 Ned Nb r!*d 70 At / L y# $4/ss.
.. Ho isba 9 f.ca.1 i at< d.6,
- 7. Firal Disposition by IMPELL:
&, pevim . Auaume Are Dms.amy.
cc: Mr. C. Tyr:ne, Project Manager Mr. J. Richard, Senior Vice ? resident Nucicar Cperations
/"b#~ yf
!.t S ed= 3 l
l
)
b
'M
'e, 4
DEVIATION 4 i
}
s h l ie i } } . . . . _ . . _ . _ ..
}
. i , j IMPELL NOTIFICATION SHEET l
Item Number DIEi-N g Preliminary N f i Final Identified by . mVWL AS Date N-3 ~b Tech Spec Reference 3h b.b.3 FSAR Reference b.2.3 0.(\C$ b ,$.3 Problem Title 6bT$ bOnct-de.c% h\old i SER Other): s
- 1. FrSAR Problem Description sb.4e.s in bS.3( ech Spfs,everd pl,ar.e.5)4ha.4 long-le. 5 2300 c4rn. Te.ch.Ser_c.. prec p and wrve.illetnce. procEd'. tee 1
'mtp\g \eng-he rn \cd is 4 MOO 0c.4wt(e.'n00),buf not 2?00 'l 2. Classification - Finding, Observation or Deviation:
G.b' b.L OYT 1
, 3. State of MP&L Review and Evaluation of MP&L Program's Ability to .
'j have found the Preblem: LCT4hf33
'1.ric.c ntph).t. potL.W . cuhk Ik t.ocu.Id bcs hc.ed
- be.en ue.n&%eA , rrs AR. reotM ,ts c oen Pl m--
- t. . Initial Disposition:
& 4af Oh 4
I- 5. Netification to MP&L: Time /700 Date Y 8[ ';ho
. Norified b [ y g d W K.
i
- 6. >?&L GGNS TSRP Response:
XS. Meda anled ts Stenaste A Mea dnest & 7. f44/E ufo /,a.fe
. Mead f/ewoEJ/y de bAe'./, buf no/ys/ ,ox.oussd & Nel /ttdi.u .
- 7. Firal Disposition by I! GELL:
Et/du.D Bl*%d'flod , A.lfD OU~ fMeV/ cal
/ **/b f$c. k Am) dY h5 l
- cc: ':r. C. Tyrene, Freject 'Snsser /
Gf"N & ' vi /sy di Mr. J. Richard, Sanier Vice ? resident Nucicar Operatier.s
'.i$cdc3
b 5 ( ie 9 O 9 DEVIATION 5 P
'T t
e s 3 I e i S e I w
b .
~1 IMPELL NOTIFICATION SHEET
. Item Number .)KL/-I Preliminary l Final Identified by . MYn Ab Data hM8h Tech Spec Reference b.b.3 FSAR Reference b .1. 3 d.Ad b .6.3 Problem Title 7ty'M T~d 6 A C L 6. W O f~
- 1. Problem Description (Tech Spec SER, Other):
95AR po_rcA.pp.L. 6.a.3.\ .\.c. (.p. 6.2-50) sitould 54a.4 e_ l'LO u.conds.
- 2. Classification - Finding. Observation or Deviation:
GAfl(1 CY\
- 3. State of MP&L Review and Evaluation of MP&L Program's Ability to have fcund the Probles:
1r\@* cb %QO%i O U- W'O U- W
] hu.n MenM9{ted
- 4. Initial Disposition:
1 S-SA2. re. vie.u) iS (cSPO ' C* ) Q.- fd ?%_4NW I l 5. Notification to 12&L: Ti=e /700 Date / 'J/ '4to Notified [. 7Vgo4E 1
- 6. MP&L CGNS TSRP Response:
/AdetoM dbeer d 822 N4t W 4JLtTre<> >$m f.es*/</e /neeumey . . /u FJ.42.
- 7. Final Dispositten by I:TELL:
fi k./D Sgw.4774, $1Jd4uYM fA TN S47"M##Tv/f* t cc: Mr. C. Tyrc: e. Project Mans 3er
- !r. J. Richard. Se .ict Vice Pre-idant Nuclear C;erations
*~ h ~'- 3 sus %t_ p.icA s yc; n % 1 <_c, @ A c 9 c n & .*
6 s u.b&w s. .g-a s: .s. &nodum 4,""E -
a
,- I cE2.
g
~Teck. .Syea.. 3I4G*b*3 Mieck : biondb 3 Gas Trec2med 5ys4em
} hpcasMa Ory Bec(dej
% %sc 5%.bs - ' Red
~Docu.meds consdaad 'in T5RP:
%45-n-63a.o Re.13 h ics,3.9.3 h v.c.b 3.9 M b l
\\otA L42A T) Regdc.% CvUde I.52.,Rev.2.
\\o2. 6 teo. 4
^
~j 94y#-
% E-/257-ts nev.9g, y_.3og,o _q3_q,f G E K I35'o 3 96W-E-/257 01 geup m 94ys-n ss2 a 'Decu. mees re.o.-os-/4-gvietoed L ye.u'. 'o3
' Pre.cp 1.~t489T41.
1 O(o-oP -1.TH B- R- 000 9 ib El 3 rsARg5ER e hpdadei3 Sade C 1.s'2 , b.i.o.nd '2. AM5I Nsto-m s' 31sc.u.sscn: ,j 'Petb\em. skee3s 003 o(a, sc.a. 3,y gii A,..d Wn 3 op e rded. & J,engge,(c c, ggt 4;g,;cn , gu c,n,g
.. cena.c+:d 1 V-sis.s. c.ko.nge resalkd .
Cf\c.w.A 7,..<;p ch.,,.,.th v.,.yp,_,4
,5 s .c y.c.,.;..d,,;.s, Moto 5i n ..ss gia,
$\D .%.CZ~ \C G) 'S % C DD Q.h. hN ( O 'W V '!Y ' Y b ethbob and mea and chuzo.1 Ms.
i J
, ~ . ~
ta n us,~ o-D y w w w-r Concernsf 7 cob \ents:
. r Air Ew ds*sboka ksb4 R.s. i.s2,pra. c.s.b 3
's t not 'me.\ukA in %e Tech. Sp_c..( AusI. us to-tqq.(,
j To.c%ro-A B) V3AR- 1 A pp. 3 A) shoAe.s contpho. g A (40 %.C,. \,Sa ho.1 v.64 b.2. s 3 hsR ( p.6 '5.() m.o.de
@or 'tn Su.p.p\ ament i_y te.o131ng m.o 4tc. 4e ioi u c.
,2 in po.rogro.A 6.s'.1. 3. Va.rico.s dccu.menh u.3 t.
- c.4rn"
- g1 g/ u.n'sh. LbGs sh.cu[d bo scf m t -\-o \qL correck o.nd prcftdt N a.cawule. bas.d'me, br- 4esMnoy V 5 A R p c.r q a.pJ o
; L.a.s. t.((p. L.2-so) skcuad ho.ve tRo sucnds, noi iO\ '9s.cnds 93A1 -SkfLk6.5 't n 6.T.'3 4hok \cng 3,e.nn
[.
/ f \ow h 2.3.00 c.4m. Te.ek. 54u.e. and m.p and G-))
i
/L_pe.u Mc+%.c&cw %.eet ge.necoie_d : yes X_ no_.__
/-
, i l (%) 6A.I.C','N\\(V. .' CL pc_Cdu_@ \0U5t] \Cn U# 1' M be is c soco c4m (e e,co) kk na l "i asco. 4 4 .
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