Text

Forwards Tech Spec Problem Sheet,Item 818 Re FSAR Sections on Secondary Containment Isolation
	ML20084K826
Person / Time
Site:	Grand Gulf
Issue date:	04/10/1984
From:	; MISSISSIPPI POWER & LIGHT CO.
To:	Adensam E; Office of Nuclear Reactor Regulation
References
	NUDOCS 8405140206
	Download: ML20084K826 (101)
	v • d • e

... <.

I DOC. DATE: April 10, 1984 DOCKET #:

50-416 FACILITY: Grand Gulf Nucicar Station, Unit 1 AUTHOR AFFILIATION: Mississippi Power & Light Co.

RECIP. NAME:

E. Adensam RECIPIENT AFFILIATION:

Licensing Branch 4, Office of Nuclear Reactor Regulation

SUBJECT:

Technical Specification Problem Sheets j

/

8405140206 040410 PDR ADOCK 05000416 P

PDR

~~

- - -==-m

. a u..,

n-TECHNICAL SPEC 1FICATION PROBLEM SHEET Item Number:

818 Priority:

3B

/

Identified By Date Responsible Supervisor Tech Spec

Reference:

N/A; FSAR Section 6.2.3.2 Tech Spec Page: N/A; FSAR 6.2-50 through 53a Probles

Title:

FSAR/ Secondary Containment Isolation 1.

Problem Description (Tech Spec, FSAR, SER, GE Design, Other):

FSAR Section 6.2.3.2 needs to be revised to indicate that blind flanges and rupture discs are also used to isolate secondary containment.

2.

Safety Significance:

Not applicable.

3.

Anticipated Resolution:

Evaluate FSAR Section 6.2.3.2 with respect to the need for indicating that f

blind flanges and rupture discs are also used to isolate secondary containment t

and, if nec,essary, include appropriate changes in the naxt annual FSAR update per 10 CFR 50.71(e)(4).

4.

NRC Response to Item (NRR/IE):

/

NRC Notified:

Individual Notified Date Time 5.

Disposition:

Items Closed (How)

/

Date Time cct J. E. Cross R. F. Rogers Rev. 23, 4/10/84 Pisd301

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CONSISTENT / INCONSISTENT - SECTION 3/4 Pega 8 cf 8 TECHNICAL-OTHER AREAS

~

SPECIFICATION FSAR SER STS AS-BUILT OF TECH SPECS OTHER PROPOSED ACTION 98 II I

3/4.11.2.7 C

C 1

N/A I

I 98 3/4.11.3 C

C 1

N/A N/A N/A, -

98 3/4.11.4 C

C 1

N/A' C

C 98 3/4.12.1

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1 N/A C

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' 98 104 3/4.12.1-1,2 C

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C 1

90 3/4.12.3 C

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- C Process Control 02

Program-(PCP) 1 C

N/A N/A N/A C

Offsite Dose

+-

Calculation Manual (ODCM)

C C

C N/A C

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Rev. 4, 4/13/84 X1sd16

4 48

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O IT LA 0

CI 2

3 4

5 6

7 8

9 3

AC 1

2 4

1 1

IF 1

1 1

2 3

1 1

1 2

NI 2

2 2

3 d

9 s..

6 7

8 8

8 9

9 9

9 HC 5

5 5

1 CE 5

EP 1

6 6

X.

TS

(

i

i1j 4

8

/

3 1

3

/

4 f

o 4

3 a

v g

e c

R P

NO I

TCA DE SO PO R

P REH A

A A

I

/

T

/

'I I

N N

I O

N N

N S

0 C

SE 6

AP ES N R O AH I

C T

RE E

H A

A A

A C ET S TF

/

OO N

C C

N C

C C

N N

N 1

N N

N TNET T

S L

I I

S U

O A

A A

A N

B C

S

/

N A

N N

I

/TNE A

4 T

S

/

2 S

T I

S C

C C

N C

C C

C 1

C SN O

R A

A A

A C

E

/ /

/

/ /

/

/ /

/

S C

N N

N C

C N

N C

N N

C C

C N

N C

N RA A

A A

A S

/ /

/

/ /

/

F C

N N

N C

C N

N C

N N

C C

C N

N C

N N

O IT LA AC 0

1 2

3 1

1 1

1 CI 5

6 7

8 9

1 1

2 1

IF 3

2 NI 1

1 1

0 0

0 1

2 2

3 3

4 5

d HC CE 9

9 9

9 s-1 1

1 1

1 EP TS 6

6 6

6 X

l'

FOOTNOTES - SECTION 2 Page 1 of 1 NOTE TSPS i PRIORITY SAFETY SIGNIFICANCE COMMENTS 1

319 2E

.No.

The reactor vessel was manufactured using

. Tech Spec Bases references wrong code the proper code as identified in the FSAR.

date for Rx vessel. Change 1974 code to 1971 Edition thru winter 1972 Addendum.

2 151 3B No.

Tech Spec is correct per GE Spec data Change FSAR and SER from 112.5% to 118%

i sheet 22A3738AE Rev. 4 Sheet 18 for APRM. trip.. Tech Spec is correct.

l 3

189 2H No.

The requirements exist in the particular Tech Spec Bases need to be revised to Tech Spec. Revising the Bases will be include this trip, with final setpoint to informational only.

be determined by Startup Test Program.

(Final setpoint for turbine first stage.

scram bypass.)

4 015 IB Yes.

A potential exists for being.

Drywell pressure trip units / transmitters nonconservative when ambient pressure drops read out in psig units whereas the below 14.7 psig.

transmitters are.actually absolute pressure transmitters. Variations in barometric pressure need to be considered in setpoints.

i 2

i 4

1 f

i l

l 1

Rev. 4, 4/13/84 W2sd1

FOOTNOTES - SECTION 3/4 Pcg2 1 of 21 i

NOTE TSPS I PRIORITY SAFETY SIGNIFICANCE COMMENTS l

1 152 2E No.

The Tech Spec is more conservative; this FSAR to be revised to.28% delta k/k increases the delta k/k required by the FSAR.

shutdown margin. Tech Spec is more conservative. FSAR now states.25% delta I

k/k shutdown margin.

2 241 2D No.

Referencing the Action Statement in the (1) Action Statement.for immovable action requirement would be an enhancement to control rod should be referenced in make the use of the Tech Spec easier. The GGNS action section of Tech Spec rather requirement on inop. rod separation is more than just in the surveillance conservative than STS. The use of 3.0.3'for SDV section.

inoperability in overly conservative.

(2) Also 3.1.3.b.l.a requires inoperable withdrawn rods be separated from other inop. rods by two cells.

It is only necessary to separate them from other inop. withdrawn rods per STS.

(3) No specific action statements l

addressing SDV inoperability requires the use of 3.0.3 which is overly j

restrictive. Specific action statements should be developed.

i 3

014 2B No.

Tech Spec as written requires sensor check The Surveillance in Tech Specs is being and functional test.

performed as stated, however, both the l

Tech Spec & STS indicate the desire for a 1

sensor check via a functional test which I

does not include the sensor.

1 4

805 3B No.

The Tech Spec is more conservative than FSAR needs to be corrected for sodium h

the FSAR requirement.

pentaborate required volume. Tech Spec shows 4,587 gallons; FSAR shows 4,170 j

gallons. Correct FSAR 9.3.5.3 1

surveillance test requirements with a I

loop inop. to match Tech Specs.

i 5

313 2B No.

This is only a clarification and indicates Tech Spec 4.1.5.d.4 changes " Heaters" to that there is only one heater per plant design.

" normal heater".

SLC tank has only one heater for maintaining temperature.

l 6

300 3A No.

The present MAPLHGR is correct. The FSAR Change FSAR MAPLHGR Limit at 20,000 MWD /T is different due to the method of calculation.

to read 12.6 kw/ft (Table 6.3-6).

i i

Rev. 4, 4/13/84 W2sd2

._~

FOOTNOTES - SECTION 3/4 Paga 2 of 21 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 7

800 3B No.

The Tech Spec scram setpoint is more Change FSAR APRM scrampoint. Tech Spec conservative than that shown in the FSAR.

3.2.2 vs FSAR Table 7.6-6.

I 8

806 3B No.

The specific Grand Gulf analysis for the MCPR limit of 1.18 in Tech Spec is fuel load error yields delta MCPR of 0.1; adding correct. Change SER Section 15.4.3.

a MCPR safety limit of 1.06 would give an Fuel load error analysis is not limiting.

4 operating MCPR limit of 1.16.

The Tech Spec value of 1.18 is more conservative.

9 253 2C No.

In Modes 3 and 4, SRM's provde the neutron IRM MOC should be 3 instead of 2 in Modes 1

]

monitoring function. Although IRM's fulfill a 3 & 4 when shutdown margin has not been safety function in these modes for SDM checks, established. Grand Gulf has an the GGNS SDM checks will not be performed until established shutdown margin, the first refueling outage.

i 10 318 3B No.

The intent of the STS is met by GGNS Tech STS requires 2 channels operable for mode Spec as written. Apparent inconsistency is due switch, Tech Spec has 1.

Depends on MP&L J

to differences in definitions of channels and-definition of trip system / function.

trip systems.

1 11 314 2B No.

IRM's provide adequate protection in Adds Mode 4 to APRM setdown scram Mode 4.

requirements. GE considers this to be a non-safety issue.

a 12 112 2A No.

GGNS Tech Spec as it exists now is more Adds clarification. Deletes first part l

conservative than STS which is the basis for of

note, does not change the meaning of l

the proposed change.

the notes. Deletes first part of "with a design providing only one channel per

]

trip system".

This will allow GG hetter l

operating margin, i.e., will not j

necessarily have to place a trip system j

in trip as Tech Spec now requires.

13 212 2D No.

CGNS Tech Spec is more conservative than STS allows for placing channel in trip STS which is the basis for the proposed changes.

vs. entire trip system. Tech Spec is now more restrictive.

l I

i Rev. 4, 4/13/84 W2sd3

FOOTNOTES - SECTION 3/4 Pcga 3 of 21:

NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 14 315 2B No.

It has not been ascertained that the new These setpoint discrepancies need to be values are pertinent to CGNS design.

resolved for RCIC/RHR steam flow isolation, MSIV low VAC isolation.

i RCIC/RHR is max allowed value. Setpoints.

?

are presently being reviewed by CE and I

Bechtel.

1 15 015 IB Yes. Under abnormal or worst case conditions "Drywell setpoint barometric pressure 016 IB a potential exists for being nonconservative.

change issue."

Includes TSPS 15, 16, 33.~

See note 4 section 2.

033 IB l

16 211 2B No.

This is for clarification 6nly and does not "Downscale" signal (s) should be "Inop" effect the acutal system operation.

signal (s).

1 17 238 2D No.

The intent of the footnote is clear and Correct typo from 3.6.5.2-1 to 3.6.6.2-1.

administrative controls can be effected to

'5 eliminate confusion.

l 18 005 IB Yes. The absence of MOC would allow operation Revise Tech Specs to include MOC for RWCU with the isolation feature inoperable.

isolation for SLC initiation.

l 19 013 3A No.

The missing signal is associated with a The MSL high rad inoperable missing from j

trip function which is not necessary to initiate the table.

actions to mitigate the consequences of an accident.

20 037 1C No.

Rosemont trip units are being calibrated Change Riley temp switch cal freq. &

monthly. Calibration information (drift) on Rosemont trip unit cal freq. per vendor l

the Riley temp.

Switches do not indicate need recommendations.

for more frequent calibrations, j

21 110 2B No.

Change will be for clarification only. No Adds a clarification footnote to state logic or instrumentation changes will be that the 3-7 see time delay is already j

included in the 13-second response time required.

for RCIC isolation logic on Table

'1 3.3.2-2.

22 111 2D No.

The current Tech Spec setpoints result in Radiation isolation trip setpoint an isolation at a more conservative value than changes. Reference AECM-83/0565 (PCOL-83/20) i necessary.

Rev. 4, 4/13/84 4

W2sd4

FOOTNOTES - SECTION 3/4 Pags 4 of 21 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 23 201 2B No.

The present design is correct, the removal Table 3.3.2-1 change is to delete note of the note is an editorial modification.

(f) for secondary containment manual isolation valve groups. Mechanical vacuum pumps do not trip on manual d

I isolation initiation.

24 308 IB Yes.

The time required to detect a 25 gpa Table 3.3.2-2.

Changes to valve steamleak would be extended.

isolation actuation instrumentation setpoints and allowable values for i

l temperatures. Present values do not agree with design calculations.

25 076 IB Yes. Using the present values in the Tech Spec This is inconsistency in ECCS response could allow operation outside the bounds of the times between FSAR & Tech Spec.

accident analysis.

LPCS/LPCI to be 40 sec.

l 26 316 2B No.

It has not been ascertained that the new GEwantstochangethehi$rhwellECCS l

numbers are supported by accurate calculations initiation setpoint & allowable value to and cnalysia, and therefore are warranted.

1.73 psig and 1.93 psig respectively.

Deleted.

I 27 28 802 3B No.

Accident analysis assumes that the EOC-RPT Change FSAR to state 40% of rated thermal feature is inoperative at power levels below power for RPT-EOC function; now states 40%. The reference to 30% power in FSAR 30% power.

7.6.1.8.1 is incorrect.

29 147 3B No.

Second-level voltage sensors and time SER 8.4.4.1.d requires maximum and delays have been incorporated into the Tech minimum'11mits for second-level voltage Specs per plant design.

sensors and time delay devices. Table 3.3.3-2.

30 114 2B No.

The maximum level is based on pool swell Table 3.3.3-2.

Setpoint change to considerations. The increase will provide suppression pool level-high HPCS and RCIC consistency with design, isolation due to instrument reference elevation revision.

I 31 022 2A No.

However, the current design would trip a ATWS recire pump trip. Tech Spec has recire pump by following the present action wrong option from STS.

statements.

Rev. 4, 4/13/84 I

W2sd5

~. -

FOOTNOTES - SECTION 3/4.

Paga 5 of 21-NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 32 199 3B No.

SDV bypass switch rod blocks do not Revise Rod Blocks to be consistent with provide a safety function;for control-rod block STS;for Scram Discharge Volume bypass instrumentation.

switch & mode switch if necessary.

4 33 011 2B No.

The GCNS design does not include an auto This change deletes note that says 1RM bypass of the detector not-full-in interlock detector. full in interlock is bypassed on 3

in Range 1.

Range 1.

Grand Gulf does not bypass until run mode.

34 803 3B No.

This will allow the FSAR to more clearly Tech Spec Table 3.3.7.1-1 and FSAR Table reflect the Tech Specs.

11.5-1 do not match.

(Rad Mont. Inst).

Consider explanatory note as addition to FSAR.

35 198 1C Yes.

In order to ensure operability, 2 Correct Min operable channels for Rad' channels / trip systems may be required to meet Monitoring.

single. failure criteria.

4 36 120 2B No.

2 channels are required operable in Modes Some minor inconsistencies exist between I and 2 in 3.3.7.1.

The only time that 3.3.7.12 Tech Spec 3.3.7.1 & 3.3.7.12 but are offgas system in operation would be required purely administrative in nature.

would be af ter sufficient power history to Reference Problem Sheet 185 and Note 101 provide enough decay heat to maintain air for establishing consistency for mode ejector operations.

applicability.

37 038 1C No.

Currently the monitors are calibrated Revise Tech Spec per vendor i

annually. Change will ensure they continue recommendations. Cal freq of carbon bed to be calibrated annually.

vault monitors 18 to 12 months.

38 119 2B No.

Since the dryer storage area ARM is Add to sin operable channels "1" to make required to be operable in.3.3.7.1-1, then at the Tech Spec complete. There is only least one is assumed to be required.

one channel.

39 807 3B No.

The FSAR changes are to effect consistency FSAR Change to show proper Surveillance l

between the various FSAR sections. A proposed intervals (Sections 11.5.2.3.1; l

change to Tech Spec 4.3.7.1-1 was requested in 11.5.2.3.2; 12.3.4.2.7).

AECM-84/0216.

1 i

Rev. 4, 4/13/84 W2sd6

FOOTNOTES - SFCTION 3/4 P&gs 6 cf 21 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 40 202 3B No.

Tech Spec is more conservative than Table 3.3.7.5-1.

Proposed change required by plant design.

increases the number of required channels of suppression pool temperature monitoring from 6 (1/ sector) to 12 (2/ sector).

41 327 3B No.

Calibration requirements of Tech Spec are Change FSAR requirements for CTMT/DRWL sufficient.

area rad monitor inst to be sent to vendor for calibration each refueling outage.

42 328 3B No.

The requirement is to have 2 monitors in Revise Tech Spec to require two each the containment.

In a Mark III, one monitor in CTMT/DRWL area rad monitors operable,' to j

the drywell and one in the primary containment agree with STS.

(outside drywell) meets the requirement.

43 329 IC Yes.

Rod monitors may not be operable in a Revise' Tech Spec to require post accident i

mode in which they are potentially needed.

rad monitors to be operable in conditions 1, 2, and 3-to agree with STS.

44 330 2B No.

Daily channel checks can be implemented Table 4.3.7.5-1.

Proposed change adds and controlled administrative 1y.

daily checks to accident monitoring instrumentation.

Reference:

FSAR 11.5.2.3.1.

t Deleted.

45 i

46 216 3B No.

Need for Tech Spec changes has not been Resolve operability of post accident identified. Item is.for tracking performance monitoring instrumentation per of additional review.

NUREG-0737.

i 47 251 2F No.

The.7 cps has been previously approved by The.7 cps was approved by Amendment 12 Amendment 12.

Tech Spec 4.9.2.c needs to be and issued by NRC is now inconsistent i

changed to provide consistency.

with the FSAR.

48 009 2D No.

Tech Spec 3.3.7.6 requires operability of Should be 4 SRMs operable vs 3 for modes SRM's for monitoring purposes only. Tech Spec 2*,

3, and 4.

i 3.3.6 which address the trip functions of the l

SRM's requires 4 operable SRM's in Modes 2 and 5.

Whether 3 or 4 SRMs are available for l

monitoring in Modes 3 and 4 is of no safety l

l concern.

Rev. 4, 4/13/84 l

W2sd7

FOOTNOTES - SECTION 3/4 Pggs 7 of 21' NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 49 010 2B No.

Operability of all 5 TIPS can be Plant has 5 TIPS vs. 3 as stated in Tech maintained administrative 1y.

Spec. Change Tech Spec to say 5.

50 050 2B No.

Change needed for clarification only.

The deletion of the requirement to normalize TIPS prior to using for monitoring should be a clarifying issue.

51 285 1C No.

Calibration of detectors more frequently Change chlorine detector calibration than required by Tech Specs can be controlled frequency, administrative 1y.

52 073 2B No.

The insuracne requirements are more Table 3.3.7.9-1.

Update Table of fire 102 2B restrictive than the Tech Spec and are detection instrumentation and zones in 304 2D controlled administrative 1y.

both Tech Spec and FSAR.

53 262 1C No.

However, the SBGT exhaust (release point)

Add SGTS exhaust radiation monitor to should be monitored any time the SBGT system' Table 3.3.7.12-1.

has the capability to release to the environment.

54 284 2B No.

Existing Tech Spec requirement is Revise Tech Spec frequency for channel consistent with NUREG-0473. Revision 3, Draft 7.

check and channel functional test.

55 054 IB Yes. With the present MOC, the redundancy of MOC for containment spray.

CTMT spray is below a level appropriate for single failure design.

56 257 2B No.

The inconsistency is conservative.

The Action Statement b of Tech Spec 3/4.4.2 is inconsistent with 3.6.3.1 Action Statement b but is more conservative in that it requires mode switch to shutdown immediately at a pool temp of 105"F with a stuck open valve where the FSAR and Tech Spec 3.6.3.1 allow the temp to go to 110*F.

l 57 331 2B No.

This setpoint change is on an interlock Table 3.4.3.2-2.

Setpoint change for i

l that would be used in the steam condensing mode valve interface leakage. E12-F052 to l

of RHR operation. This is presently not allowed E51-F064. NOTE: This alarm does not at GGNS.

provide interface leakage indication.

l Action' Statement times for MSIV's.

58 264 2B Rev. 4, 4/13/84 W2sd8

~

1 l

FOOTNOTES - SECTION 3/4 Pcg2 8 cf 21 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS i

59 001 IB Yes. Tech Spec as written would allow operation ADS 7 vs 8 valves.

with an operable equipment configuration which was not considered in accident analysis.

60 317 2E No.

Since the Tech Spec is correct, any error Change Bases for HPCS discharge pressure in the Bases has no effect on safety.

and flow. B3/4 5-1.

Tech Spec is correct as written.

61 309 2A No.

System relief would provide protection.

LPCS and LPCI high pressure alarm 310 2A setpoint revisions. Present setpoints too close to system relief valve settings.

62 332 3B No.

The minimum drawdown level is greater than Condensate storage tank minimum level 170,000 gallons required.

change. Stated volume is correct.

63 126 2D No.

This change is administrative in nature, Editorial change to minimum suppression the LCO is still 12'8".

pool level 12'5" vs required 12'8".

64 144 2B No.

Change would be for clarification only.

Clarification to type B testing Testing the proper penetration after it has requirements after a penetration has been been broken can be controlled administrative 1y.

broken.

65 235 2B No.

Requirement can be controlled Clarification corrects Tech Specs to administrative 1y.

agree with Appendix J requirements.

66 292 IB Yes.

Based on current leak testing acceptance Air lock minimum pressure change from 293 IB criteria, this change is needed to ensure greater than or equal to 60 psig to adequate seal pressure for 30 days with no greater than or equal to 90 psig.

Revise makeup air supply.

Tech Spec.

67 229 2B No.

Strictly clarification, only the inboard 4.6.1.4.a.2 and c.1 revise for system has heaters.

clarification. MSIV LCS heater only on inboard system, not on outboard as implied by STS.

68 166 3B No.

The existing design of the feedwater Add requirement tc. functionally test FW system has been determined not to be credible leakage control system.

drywell bypass leakage path.

Rev. 4, 4/13/84 W2sd9

FOOTNOTES - SECTION 3/4 Pzga 9 of 21 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS

~

69 801 3B No.

Tech Spec values are correct for accident Evaluate equipment qualification program analysis.

to confirm CTMT to Auxiliary Building Diff. Press. Range. Revise FSAR and NUREG-0588 response.

70 260 3B No.

Previous Mark III analysis determined that CTMT avg. air temp. 80*F vs 90*F.

CTMT average air temperature can be 95'F without Correct FSAR.

compromising the analyzed accident CTMT pressure and temperature limits.

71 167 2B No.

Drywell integrity will be maintained if Resolve differences between LCO 3.6.2.1

,one drywell airlock door is operable. Change and 3.6.2.3.b for drywell integrity, would be for clarification.

Clarification.

72 172 2B No.

Change would be for clarification only.

A//~E~is not leakage. Clarification, i

Drywell bypass leakage requirements would not change.

i 73 168 2B No.

Required actions are clear as Tech Spec Specification 3.6.3.1 is unclear with is presently written.

respect to what actions are required in Mode 3.

I 74 234 3A No.

Tech Spec and plant design are consistent FSAR revisions to agree with Tech Spec.

and correct.

Tables for Sup. Pool Volume and instrumentation. Editorial for clarification of suppression pool level instrumentation.

Deleted.

75 76 169 2D No.

Containment spray sparger was successfully Add containment spray sparger to tested during preoperational test.

Surveillance Requirements.

77 12 2D No.

The need for the more conservative STS Action times vary and STS requires 8-hour requirement has not been confirmed and thus far restoration for 1 loop inop of l

1s not supported.

suppression pool cooling Tech Spec has 7 days.

i 1

Rev. 4, 4/13/84 W2nd10

FOOTNOTES - SECTION 3/4 Paga 10 of 21 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS i

78 312 25 No.

This is controlled administrative 1y.

STS Surveillance Requirement to verify refueling gates in stored position is not in Tech Specs. Verification if covered by Admin. Proc.

l 79 83 2B No.

Administrative controls and application of Suppression pool makeup instrumentation.

[

the definition of operability verify that-

+

required associated instrumentation is operable to declare suppression pool makeup operable.

80 20 2B No.

There is significant margin between the Change leak test requirements from hydro primary containment measured leakage rate and to air.

the allowable leakage rate as specified in Appendix J to 10 CFR 50.

.I 81 021 1C No.

Snubbers can be added to the surveillance Add one RCIC snubber and non-Q snubbers 139 1C schedule and controlled administrative 1y.

to snubber table.

82 72 2D No.

This can be controlled administrative 1y.

Add surveillance requirement to verify i

fire system spray nozze1 pattern is unobstructed.

4 Deleted.

83 I

84 203 2D No.

Change is editorial only and would not M1P64D140 should be NSP64D140.

l change the location, function or maintenance l

of the system.

j 85 131 2G No.

Surveillance of all hose stations can be Table 3.7.6.5-1 requires update for hose controlled administratively, stations for completeness.

4 1

1 86 277 2B No.

The requirement is implicit and is Requirement to sample fire rated currently being met administratively, assemblies such that each is inspected once per 15 years is not in the Tech Spec. Covered by GGNS Surveillance Procedures.

]

87 132 2B No.

Would be an administrative change. The Delete Equip.;not operating column for j

intent of the Tech Spec will not be altered with clarification'.

or without the change.

Rev. 4, 4/13/84 W2sd11

FOOTNOTES - SECTION 3/4 Paga 11 of 21 i.

NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS

~

88 804 3B No.

The FSAR sections referenced on the problem. This is an inconsistency with the FSAR sheet are not inconsistent but rather address only, not the.SER. later evaluation different capacities.. An FSAR change is not determined Tech Spec and as-built to be required.

correct and revision.of FSAR is needed.

Diesel day tank volume needs to be corrected.

l 89 808

.38 No.

The design, Tech Spec and FSAR are SER does not properly describe Diesel correct.

Generator trips under emergency conditions.

4 90 333 2B No.

The sequencing of post-LOCA loads is Proposed change is to add a surveillance verified by Tech Spec 4.8.1.1.2.d.7.a)2) albeit requirement to verify load sequencing of with a concurrent LOP signal. However to offsite power per STS.

l require verification of sequencing under 4.8.1.1.2.d.12 would be checking the same logic i

and handware tested under 4.8.1.1.2.d.7.a)2).

This would be redundant and not add to safety.

i 91 335 2B No.

The additional requirements are currently Clarification of which revision of

]

being performed under administrative controls, Regulatory Guide 1.137 applies. Proposed although there is no requirement to do so in change to include diesel fuel oil testing I

Tech Spec.

requirements. Check for water.

I Deleted.

92 93 810 3B No.

This is a software change only to update FSAR revision required to describe the FSAR to the Tech Specs and trip setpoints as-built trip setpoints per DCP 82/3173.

as modified by DCP-82/3173.

FSAR Q&R 040.5.c needs to agree with Tech Spec 4.8.4.1.

i 94 809 3B No.

FSAR section 7.1.2.6.22 indicates that the FSAR and SER should be changed to Crand Gulf design complies with Regulatory Guide properly describe MOV thermal overload q*

1.106.

This is correct.

bypass circuitry.

4 Deleted.

92 l

93 810 3B No.

This is a software change only to update FSAR revision required to describe

]

the FSAR to the Tech Specs and trip setpoints as-built trip setpoints per DCP 82/3173.

as modified by DCP-82/3173.

FSAR Q&R 040.5.c needs to agree with Tech Spec 4.8.4.1.

1 Rev. 4, 4/13/84 i

W2sdl2 J

~

I I

FOOTNOTES - SECTION 3/4 Pega 12 of 21 4

NOTE TSPS I PRIORITY SAFETY SIGNIFICANCE COMMENTS 1

94 809 3B No.

FSAR section 7.1.2.6.22 indicates that the FSAR and SER should be changed to Grand Gulf design complies with Regulatory Guide properly describe MOV thermal overload 1.106.

This is correct.

bypass circuitry.

95 251 2F No.

The.7 cop has been previously approved by Table 3.3.6-2 Item 3.d and Tech Spec Amendment 12.

Tech Spec 4.9.2.c needs to be Surveillance 4.3.7.6.c and Tech Spec changed to provide consistency.

Sury. 4.9.2.0 are inconsistent.

96 275 2B No.

Water level of 22' 6 3/4" is adequate to Tech Spec to be revised to comply with satisfy the design basis and would have no as-built water level of 22' 6-3/4 vs.

i significant effect on plant safety.

23'.

1 Deleted.

i 97 98 249 2D No.

Changes are enhancements.

Certain wording enhancements should be implemented upon issuance of NUREG-0473, j

Draf t,7, Revision 3, STS (RETS),

i l

99 249 2D No.

The most conservative reporting Reporting requirement is inconsistent, requirement can be met until consistency is with Technical Specification 6.9.1.12.k.

affected.

(

100 193 2D No.

The inconsistency requires H m nitoring Applicability for 3/4.11.2.6 is 2

to be operable at all times _which is overly inconsistent with Technical Specification conse rvative.

Table 3.3.7.12-1(2).

101 185 2B No.

Applying operability requirements of the Applicability for 3/4.11.2.7 is various specifications affecting offgas inconsistent with Technical Specification pretreatment monitor assures the monitor is Table 3.3.7.12-1(6a).

l operable whenever the air ejectors would be in i

service. The inconsistency causes the Tech Specs to be overly conservative.

102 249 2D No.

The use of a vendor, with proper FSAR does not address GGNS use of a administrative controls, is not significiant to vendor to perform solidification /

]

safety, dewatering of radwaste.

Deleted.

103

)

i i.

Rev. 4, 4/13/84 W2sd13

FOOTNOTES - SECTION 3/4 Peg 2 13 of 21 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 104 249 2D No.

Any additional sample points to meet Present requirement for air samples Reg. Guide 4.8 requirements can be controlled locations in X/Q locations is administrative 1y.

inconsistent with Reg Guide 4.8 which requires air samples to be located in areas with the highest X/Q.

105 158 2D No.

The intent of the GGNS Tech Spec is the GGNS Tech Spec states that "T is always same as that of the STS.

less than 1".

STS states "T is applied only when T is less than ". The T is used in the APRM flow biased scram formula.

106 103 IB Yes.

Present requirement could allow, in the MOC for MSIVs on hi flow is acceptable as worst case, six channels to be inoperable and written, MOC for drain valves from the not require entry into Action Statement.

mainsteam lines MOC needs to be revised.

107 322 2E No.

Inaccuracies in the bases do not alter the Change to ADS Bases page 3/4 5-2.

Change accuracy of the LCO or the ability to the the Bases with respect to LPCS/LPCI subject equipment to perform in accordance with injection pressure into the vessel.

accident analysis.

Change to state that the reactor pressure is reduces by ADS substantially below the pressure at which LPCI/LPCS inject into the vessel 108 321 2B No.

Tech Spec is more conservative than STS Section 3.6.3.1 of GGNS Tech Spec differs by omission of this allowance.

from STS in that STS now has 1 additional action statement with respect to 95*F which places a limit on time and power above 95'F.

109 320 2E No.

The plant design and LCO requirements are Page 3/4 6-4 of the Bases has an based on Bechtel drywell and containment incorrect number of 1089 for blow down analysis which cites 1060 psig reactor pressure, pressure. Should be 1060 psig which reflects 105% heat balance.

110 323 2B No.

Revoval of shorting links can be Tech Specs 3.9.2 and 3.10.3.

The RPCS is I

controlled administrative 1y from SDM not an alternate to the shorting links demonstrations, being removed when performing shutdown margin demonstrations in Mode 5.

The shorting links were removed for the first shutdown margin demonstration.

Rev. 4, 4/13/84 W2sd14

FOOTNOTES - SECTION 3/4-Prg2 14 cf 21 i

NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE

' COMMENTS 111 148 3A No.

Due to the extremely low probability of SER requires Turbine stop/ control valve turbine missile hazards which could affect plant bi-weekly testing.

safety and due to the ability to control turbine testing administrative 1y, inclusive of such a Tech Spec is not necessary.

4 112 234 3A No.

Tech Spec and plant design are consistent Suppression Pool Level instrumentation and correct.

does not clearly reflect FSAR. Need 4

clarification of which instrument 1

channels meet each Tech Spec.

j 113 075 2B No.

Current setpoint is overly restrictive in LPCI B & C Pump discharge pressure High 1

j that the setpoint is only allowed to vary in Allowable Value. Allowable value changed one direction from its nominal value.

for item A.2.f but not for item B.2.e.

=

Change needed for B.2.e.

i 114 213 1C Yes.

The Tech Spec indicates testing of the Minimum operable channels for manual i

wrong function.

actuation of each ADS trip system in Tech Spec Table 3.3.3-1 now reads 1/ valve -

2 should be 2/ system.

l l

115 116 2B No.

Plant procedures incorporate monthly LPCS Pump Discharge Pressure High; trip i

calibration.

unit calibration frequency changed to monthly.

116 078 IB Yes. The RCIC initiation could be defeated if RCIC minimum operable channels - RCIC the Tech Spec were misinterpreted.

Level 2 Trip changed from 2 to 4 minimum operable channels.

117 039 2G No.

These instruments are used "after the Seismic Monitoring - some monitors could l

fact" to determine the amount of pipe movement experience larger transients from plant after seismic events. They have no active operation than from seismic events.

I role in initiating protective actions or mitigating accident conditions.

118 045 2B

'No. Approved techniques are being used to ODCM Setpoints - some setpoints in Table i

determine the setpoints. This item does not 3.3.7.12-1 not calculated in accordance affect safe plant operation.

with ODCM.

l

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Rev. 4, 4/13/84 j

W2sd15

FOOTNOTES - SECTION 3/4 Pagi 15 of 21 4

f NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 119 291 3B No.

Per GE analysis, Tech Spec is adequate.

Maximum MSIV Isolation Times - Allowable The apparent inconsistency is due to times differ in FSAR and Tech Spec.

insufficient detail in the FSAR to relate the instrument response times to the analysis.

120 024 2B No.

The current requirement could be Jet Pump Operability - Surveillance misinterpreted to preclude entry into requires J.P. proven operable prior to operational Conditions 1 or 2.

This is an exceeding 25% power. Add 4.0.4 operational concern.

exemption.

121 028 2B No.

Although the table does not.specifically RCS Interface Table 3.4.3.2-1 does not address each valve, the surveillance address each specific valve.

procedures do.

122 243 3B No.

A change to the ISI pump and valve program MSIV stroke time definition: Tech Spec will be made to reflect the proper testing (ASME Code), GE Design Spec. & FSAR are consistent. Method of testing under methodology.

d section XI is inconsistent with the definition.

123 057 2B No.

Testing frequency will be performed in 4.0.2 exemption in Tech Spec is accordance with Appendix J.

inconsistent with Appendix J.

3 l

124 294 2B No.

Testing frequency will be performed in Containment Leakage Rates - inconsistent i

)

accordance with Appendix J.

The procedures with Appendix J requirement for LLRT; require summing the leakage, does not require all penetration leakage to be summed.

125 019 2B No.

Ensuring the more conservative method is Drywell Purge Flowrate Definition - Tech used (SCFM or CFM) is controlled Spec definition is in CFM, should be SCFM administrative 1y.

(i.e. temperature dependent).

f 126 062 2E No.

Unless further evaluation indicates that Moisture Control in Charcoal Bed Heaters the humidistatically controlled heaters running

- 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months " cumulative" operation is not 4

l for 10 cumulative hours will not maintain an sufficient to control moisture; Bases j

acceptable moisture level, no change is needed.

incorrect.

j 127 245 2B No.

This is only editorial in nature and Spec requires test of dry pipe headers.

246 2B provides clarification.

i Rev. 4, 4/13/84 W2nd16 i

t FOOTNOTES - SECTION 3/4 Pcgs 16 of 21 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 128 100 3B No.

This change would increase the qualified ESF Electrical Room Maximum Temperature -

life of certain equipment to 40 years.

Bechtel generated 0588 FSAR change from 104*F to 90*F.

129 136 2D No.

Change is to correct typographical errors Valve # Typos on Table 3.8.4.2-1.

only, and is purely administrative.

130 137 2B No.

Change is a clarification of intent only.

Channel Functional Test of MOV Thermal Overload. Change Tech Spec to allow test of bypass circuitry once/92 days; Test of entire channel once/18 months. Presently requires LOCA initiation once/92 days.

131 191 2D No.

NUREG-0473, Rev. 3, Draft 7, specifies only Dose Rate in ODCM - Tech Spec requires 1-131 and 1-133 and agrees with the ODCM.

calculation using all radiciodines, ODCM only requires 2.

132 299 28 No.

The level can be administrative 1y CO storage tank level - 50% level 2

controlled to have enough CO to provide 2 specified in Tech Spec is not sufficient 2

discharge and purging of the main generator.

for " double shot" coverage of the largest room.

133 303 2B No.

Change is for clarification and can be HPCS action statement 33.b indicates 2 controlled administrative 1y.

trip systems; only 1 trip system of 4 cannels should be indicated.

134 308 IB Yes.

Present sepoints may be too high to Temperature setpointe for Room Hi-Temp affect system isolation soon enough, and Delta Temp - Bechtel calculations and Tech Spec setpoints are in disagreement.

135 271 2B No.

The weight of the Halon bottles can be Halon Storege Requirements - 95% weight 244 2B increased administrative 1y to provide the of present Halon bottles may not provide 247 2B required 5% concentration.

a 5% concentration 10 minutes after discharge and other design features.

CGNS Tech Spec requires tests which are not possible for PGCC Halon.

136 176 2B No.

The intent of the current Action Statement Crane operation above containment is to preclude a load drop onto spent fuel, pool-action statement should include This can be controlled adminstrative1y.

suspension of crane operation as is done for the spent fuel pool.

Rev. 4, 4/13/84 W2sd17

FOOTNOTES.- SECTION 3/4 PKg2 17 of 21 a

NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 137 226 3A No.

The EPA's are not part of the plant RPS Electric Power Monitoring Spec:

transient response equipment and, therefore, Should the Tech Spec include time delays?

have no effect on the safety analyses.

138 035 2C No.

No fuel handling activities are anticipated Refueling platform specs rewritten to be in the near future and thus it is not of in accordance with GGNS design, immediate concern. Proposed changes can be controlled administrative 1y.

139 190 2D No.

GGNS Tech Spec uses most conservative Drinking Water - Tech Spec requires limit.

analysis if drinking water is taken from Mississippi River within 3 miles from plant discharge. Can reduce allowed

]!

limit if greater than 3 miles.

't r

140 138 2D No.

Change is for clarification only.

Radioactive Gaseous Waste Sampling - Two 1

Requirements can be effected administrative 1y.

additional sampling points proposed:

Radwaste Bldg. vent exhaust and fuel

]

handling area vent exhaust.

f 141 185 2B No.

" Hot Standby" is not a defined condition Tech Spec directs operation to go to " Hot 4

in BWR's.

Actions concerning " Hot Standby" can Standby" - should be " hot shutdown and be controlled administrative 1y.

then to cold shutdown." Add 4.0.4 exception to 4.11.2.7.2 such that sampling is not required until main condenser air ejector is in service.

l 142 334 2D No.

This provides clarification to make the Revise Tech Spec 3.1.4.2 (Rod Pattern wordage consistent with the specific GGNS Control System) so that it is more design..

compatible with system design and provides better implementation of RPCS.

i 143 004 2E No.

The SMPU mode switch is required to be There is no mode switch interlock which "off" during refueling. In addition, other prevents opening the make-up dump valves actions that would deviate:from admin controls as Bases implies.

i l

would also have to occur to open the valves.

144 017 2D No.

If the fan is running it is already Need to clarify requirement to start the performing its required safety function.

SSW cooling tower fan from control room when fan is already running.

i Rev. 4, 4/13/84 W2sd18 u

7 FOOTNOTES - SECTION 3/4 Pag 2 18 of 21 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 145 023 28 No.

Administrative controls can be effected to SRV/LO-LO cet Tech Spec does not clarify and control equipment requirements.

recognize two trip systems of instrumentation.

146 032 2B No.

Appropriate controls can provide assurance Generic problems with RCS leakage Tech' that the intent of the specification is Spec:

inconsistencies and errors.

fulfilled even though the specification is confusing.

147 077 2B No.

All equipment controlled from the RSP was NRC recommends additional Surveillance s

tested during the pre-op phase. Specific Requirements on the remote shutdown testing will be performed during the power panel. FSAR commits to periodic testing.

ascention program that will demonstrate RSP operability.

148 094 2D No.

The present pump ISI surveillance Add Surveillance Requirement to HPCS requirements ensure pump operability. The Service Water Tech Spec per STS.

system automatic valves are checked operable during the monthly diesel test.

149 173 2D No.

Change would be:for clarification only.

LCO misleading in references to equipment Equipment required for operability can be such as ECCS pump room seal coolers.

controlled administrative 1y.

150 338 2B No.

Surveillance of all hose stations can be Add Hose Stations 53C and 54A.

controlled administratively.

151 812 3B No.

The timer is in the plant and Tech Spec.

INEL item 3B.

MSL Tunnel Temp Timer is

)

816 3B Its exclusion from the FSAR has no impact.

not in FSAR. FSAR values for MSL FSAR setpoints being incorrect do not af fect Flow-High setpoint and range are wrong.

the accuracy and consistency between the plant design and Tech Spec.

152 233 IB No.

Total developed head presently specified HPCS, LPCS, LPCI pressure / flow values are by the Tech Spec may make OPERABILITY different in Tech Spec, FSAR, AND SER determination questionable.

(I&E Inspection Item). All values are correct, however, the Tech Spec values do not bound pump performance to ensure design requirements.

(Portions of this item are being tracked under Note 159.

Problem Sheet 344.)

Rev. 4, 4/13/84 W2sd19

FOOTNOTES - SECTION 3/4 Pags 19 of 21-NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 153 820 3B No.

Incorrect FSAR numbers do not affect the RCIC Instrument settings in FSAR Table accuracy and consistency between plant design 7.4-1 differ from Tech Spec setpoints, and Tech Spec.

154 819 3B No.

This involves correcting a nomenclature FSAR 3.7-17 reference to triaxial problem only.

response spectrum recorders is incorrect.

Should be spectrum analyzer.

155 818 3B No.

Administrative controls have been affected Revise FSAR 6.2.3.2 to indicate that to ensure blind flanges and rupture discs are blind flanges and rupture discs are also included as part of secondary containment used to isolate secondary containment.

I isolation.

156 817 3B No.

Change to FSAR would be an editorial Revise FSAR 6.2.3.2 to indicate that SGTS 4

addition which would have no effect on the has capability to overcome the additional system capability.

inleakage from a single 4 inch penetration or failure of all non-Q lines 2 inch and under.

i l

157 827 3B No.

The as-built level setpoint provides the Revise FSAR 9.5.1.2.1 to correct the fire j

required water volume in the storage tanks, water storage tank low level makeup water supply setpoint.

158 306 IB Yes.

If the specified closing times;for the Add several drywell, valves to Tech Spec RWCU valves are not within analytical limits, Table.

Investigate analytical stroke i

this may result in a release following an RWCU time discrepancies.

pipe break in excess of previously analyzed 1

releases.

159 344 IB No.

Total developed head presently specified by The present specified TDH may not Tech Spec may make OPERABILITY determination ensure GE design injection requirements.

questionable.

160 345 2B No.

The high reactor water level turbine trip Incorrect Allowable Valve:for reactor is an equipment protection function and not does vessel water level turbine trip.

4 not affect the safety analysis.

i 161 349 2D No.

Tech Spec may not be adequate to ensure The scope of the action statement should isolation of the fuel handling area ventilation be increased to require secondary containment when the fuel handling area

systems, l

radiation monitor is inoperable.

Rev. 4, 4/13/84 W2sd20

\\

FOOTNOTES - SECTION 3/4 Pagt 20 of 21 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 162 350 2B No.

The present ACTION Statement could require The present ACTION statement would unnecessary plant shutdown.

require plant shutdown if inaccesible isolation valves in the drywell were INOPERABLE.

l 163 357 2B No.

Failure of the by-pass circuitry could-There is presently no requirement to defeat the EOC-RPT logic, calibrate / functionally test the EOC-RPT bypass instrumentation.

164 357 2B No.

The Tech Spec ACTION statement is The present ACTION statement implies that I

inconsistent with the system design. There there are two trip systems'for the HPCS is, however, no safety consideration.

initiation. The GGNS design has only one trip system.

1 165 365 2D No.

The performance test performed in lieu of FSAR commits to R.G. 1.32, Rev. 2.

This the service test is adequate to demonstrate the Reg. Guide, however, requires a service OPERABILITY of the batteries.

test of the ESF batteries in addition to the performance test.

This requirement l

is not in the GGNS Tech Spec.

166 821 3B No.

The surveillance as performed is in FSAR implies that CRD accumulator level compliance with the BWR-6 design, is checked weekly. GGNS Tech Specs require pressure verification only.

167 822 3B No.

The GGNS procedures adequately cover the Tech Specs do not include all testing intent of Reg. Guide 1.52, Rev. 2.

required by Reg. Guide 1.52, Rev. 2.

168 823 3B No.

The subject valves are included in Tech FSAR Table 7.6-12 does not list all Spec Table 3.6.6.2-1.

secondary containment isolation valves.

169 824 3B No.

The subject valves are included in Tech FSAR Table 7.2-44 does not list all Spec Table 3.6.4-1.

primary contianment isolation valves.

170 825 3B No.

Tech Spec Table 3.3.2-1 correctly indicates FSAR section 5.4.6 does not currently l

that concurrent signals are required for value reflect that valve group 9 requires group 9.

concurrent drywell high pressure and RCIC steam supply pressure - low signal to isolate.

(

i Rev. 4, 4/13/84 W2sd21

'~

~.

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~ __. ;

F00TNorES' SEbTION.3/4 Paga 21 of 21 NOTE TSPS #

PRIORITY

_. SAFETY l'qyIFLChMCE COMMENTS 171 826 3B No.

There is no safety impact that results SER Section 9.1.3 states that the-spare-from this discrepancy. Plant procedures fuel pool cooling pump' will-be tested currently require surveillance on both pumps.

periodically according to the Tech Specs.

Tech Spec 3.7.9; requires the temperature of the The GGNS Tech Specs contain no such:'

spent fuel pool be'stintained below 125'F.

provisions..

172 828 3B No..

There is no plant safety impact as a result FSAR Section 7.4.1.1.3.'2 indicates that<

.ct this discrepancy. Tech Spec 3.3.5 correctly the RCIC system is actuated on a reactor 1ists'the RCIC initiation setpoints..

low-water level. The CGNS Tech Spec J

indicates initiation on Low-Lcv, Level 2.

I 173' 829 3B No.

The GGNS Tech Specs are consistent G1th The GGNS Tech Spec differs"from'the FSAR' current requirements and commitments, regarding reactor water chemistry action s

statements and surveillances.

s 174 830 3B Nc.

There is no plant safety' impact as a result FSdR Sect' ion 5.3 3.6.b indicates the of this discrepancy.- Tech Spec 3.4.1.4

. coolant temperature difference between s accurately lists (he 100*F differential limit.

dose and bottom head drain is no greater than 145'F.

Tech Spec 3.4.1.4 indicates 100*F.

a i

s i

I l

I 1

l i

4 l

Rev. 4, 4/13/84 W2sd22

FOOTNOTES - SECTION 5.0 Pcgi 1 cf 1 i.

NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 1

1 225 2D No.

The same information that is on the 111egible figures.

illegible figures can be obtained from other 4

administrative 1y controlled rources.

2 105 2E No.

Unrestricted area boundary is not Correction of terminology for effluent appropriate for gaseous and liquid effleunts.

release boundary vs. unrestricted area.

This is only a difference in terminology, boundary.

3 252 3B No.

A special evaluation has shown that the The figures for containment and drywell Tech Spec values are consistent with plant net free air volume in the FSAk are not i

j design.

the same as those in the Tech Spec.

Within the FSAR the numbers are not consistent among Tables 1.3-4, 6.2-1, 6.5-6.

4 281 2E No.

The value listed in Tech Specs is a Best available information shows average nominal value, fuel enrichment (of initial core loading) to be 1.71933% U-235; 1.70% is the maximum value allowed in GGNS Tech Spec.

1.70% ic design nominal value; allowable telerance is ii.5% of nominal.

I Deleted.

5 j

6 258 3B No.

The spent fuel pool is restricted from The spent fuel pool can be partially j

normal use for spent fuel until SSW pump drained if the valves (G41-F032 F033) capacity is increased.

are opened while the spent fuel pool gate is removed. The valves are neither 1

locked nor do they have electrical

(

j interlocks to prevent inadvertent l

l operation.

7 259 2B No.

Tech Spec is correct. An FSAR change is GGNS Tech Spec Table 5.7.1-1, Vendor required. What appeared to be inconsistencies Documents, and FSAR Table 3.9-1 do not l

was due to use of different terminology in the correlate. The transients / cycles are different documents, defined differently in the documents.

l i

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i Rev. 4, 4/13/84 W2sd23 4 - _,

FOOTNOTES - SECTION 6.0 Paga 1 of 3 t

NOTE TSPS f PRIORITY-SAFETY SIGNIFICANCE COMMENTS I

104 2E No.

The title correction does not change the Correct title Shift Superintendent to responsibility or authority of any of the plant Shift Supervisor.

perspr.nel as described in the FSAR.

2 095 2E No.

These.are only administ'rative and do not Correct Organization Chart in Tech Specs

~

101 2E affect ths;ssfety of operating the plant. No and FSAR.

decrease in staff competancy or the number of SRO's required.

~

3 340 21 No.

In response to thacrequirement of Revise the following to requite an.efght 9

NUREG-0737, FSAR Section 18.1.3 states 8 hr.

hour break as opposed,to a twelve hour This provides consistency within the FSAR.

break.

o Amendment 49, FSAR, Section 13.1 o SER Supplement 2,'Section 13.1.2 4

052 2E No.

The title of the individual holding the Cerrect Plant Superintendent to Plant t

l position of senior onsite management Manager.

representative is not safety significant.

4 l

5 063 2E No.

This is an administrative probles that Clarify ISEG qualification requirements.

does not effect plant safety.

S 339 l'

h.

The term "Non-Licensed Operator" in FSAR Chap. 18 identifies "Non-Licensed cv sistent with the title " Auxiliary Operator" Operators" the GGNS-TS identifies 1

" Auxiliary Operators". The

< 4 th respect to shif t crew ccuposition.

qualifications for these titles are quite

~

~~

different.

i I

0QAM'Rev. 3 Section 1.3.10 does not add 7

811 3B

.No.

The OQAM can be controlled all PSRC requirements as imposed by the

~ administratively.

GGNS Tech Spec.

{

~'

4 8

106 2E No.

The addition of members to the PSRC is not Adds two additional members to PSRC.

safety significant.

p 9

064 2E

- No.

The qualifications and the length of time Time frame that an alternate can be used an alternate serves can be controlled and the qualification of alternates are edministratively.

not addressed.

Rev. 4, 4/13/84 W2sd24 d

~

-FOOTNOTES - SECTION 6.0 Pag 2 2 of.3 NOTE TSPS f ^ PRIORITY SAFETY SIGNIFICANCE COMMENTS 10 296 2E No. 'Any changes would be to clarify.the PSRC responsibilities in the GGNS Tech

. responsibilities of the PSRC. The intended Spec disagree with GE-STS requirements.

functions of the Tech Specs are being conducted by the PSRC.

11 093 2E No.

This ensures reporting requirements are Incorporate 10CFR50.72 and 10CFR50.73 fulfilled and does not affect safety.

reporting requirements into GGNS Tech Spec.

12 814 3B No.

The requirement can be controlled SER requirements for SRC composition are administrative 1y.

in conflict with the GGNS Tech Spec.

13 813 3B No.

The requirements for the Manager of' Requirement for MQA are less restrictive Quality Assurance position have no impact on in the OQAM than in the GGNS Tech Spec.

the safety of operation of the plant.

MQA is required by GCNS Tech Spec to be a member of the SRC.

14 065 2E No.

The qualifications and the length of time Time frame that an alternate can be used an alternate serves can be controlled and the qualification of alternates are administrative 1y.

not addressed.

15 290 2E No.

This is a typographical error only and Paragraph 6.5.2.4 of GGNS Tech Spec does not effect plant safety.

incorrectly references paragraph 6.5.2.3.

The correct reference should be paragraph 6.5.2.2.

16 096 2E No.

Requirement for SRC review of reports of FSAR requires semi-annual review of ALARA audits of the ALARA Program can be controlled appraisals by SRC.

administratively.

17 295 2E No.

The proposed change in composition of the Revise CGNS Tech Spec paragraph 6.5.2.8.h SRC would ensure that the appropriate people are to include qualified licensee QA available to conduct the audit. Any changes personnel as being responsible for 24 made would be for clarification, month audit of Fire Protection.

I Deleted.

18 19 270 2E No.

The program described in 6.8.3 meets the Verify GGNS Tech Spec, include NUREG-0737 intent of NUREG-0737. Specific details within requirement.

the program can be controlled administratively.

Rev. 4, 4/13/84 W2sd25

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

- ~.

FOOTNOTES - SECTION 6.0 Paga 3 ef 3 NOTE TSPS # -PRIORITY' SAFETY-SIGNIFICANCE COMMENTS 20 146 2E No.

The requirement can be controlled SER requires Tech Spec to control work in the control room ceiling in other than administrative 1y.

cold shutdown.

21 341 3B No.

The current Tech Specs requirement ensure GGNS Tech Specs do not require each an adeauate procedure review.

procedure be reviewed by the Plant Manager and PSRC.

i 22 027 2E No.

This is-a' typographical error and has no Correct the reference to the snubber Tech safety significance. The correct reference is Spec section.

easily found.'

l 23 088 2D No.

This does.not effect plant safety, only Clarification needed to determine " Major 1

j reporting requirements.

Changes". Add footnote to provide alternative means for reporting changes in liquid, gaseous, and solid waste i

treatment syntems.

24 249 2D No.

Any changes would be enhancement items and Certain enhancements should be do not effect safety.

implemented upon issuance of NUREG 0473 Draft 7. Revision 3 STS (RETS).

I i

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Rev. 4, 4/13/34

. 2sd26_,._ _ _, _ _ _ _. _ _

W

g?

J FOOTNOTES - SECTION 2 FSAR INCONSISTENCIES Page 1 of 1 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 1

319 2E-No.

The reactor vessel was manufactured using Tech Spec Bases references wrong code the proper code as identified in the FSAR.

date for Rx vessel. Change 1974 code to.

1971 Edition thru' winter 1972 Addendus.

2 151 3B No.

Tech Spec is correct per GE Spec data Change FSAR and SER from 112.5% to 118%

sheet 22A3739AE Rev. 4, Sheet 11.

for APRM trip. Tech Spec is correct.

1 l

4 i

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Rev. 4, 4/13/84 Wisd1

FOOTNOTES - SECTION 3/4 FSAR INCONSISTENCIES Paga 1 of 6 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS i

1 152 2E No.

The Tech Spec is more conservative; this FSAR to be revised to.28% delta k/k increases the delta k/k required by the FSAR.

shutdown margin. Tech Spec is more conservative. FSAR now states.25% detta k/k shutdown margin.

4 4

805 3B No.

The Tech Spec is more conservative than FSAR needs to be corrected for sodium 1

the FSAR requirement.

pentaborate required volume. Tech Spec shows 4,587 gallons; FSAR shows 4,170 gallons. Correct FSAR 9.3.5.3 surveillance test requirements with a loop inop to match Tech Spec.

5 313 2B No.

This is only a clarification and indicates Tech Spec 4.1.5.d.4 changes " Heaters" to l

that there is only one heater per plant design.

" normal heater".

SLC tank has only one heater:for maintaining temperature.

1 i

j 6

300 3A No.

The present MAPLHCR is correct. The FSAR Change FSAR MAPLHGR Limit at 20,000 MWD /T 4

is different due to the method of calculation, to read 12.6 kw/ft (Table 6.3-6).

i i

l 7

800 3B No.

The Tech Spec scram setpoint is more Change FSAR APRH scrampoint. Tech Spec i

conservative than that shown in the FSAR.

3.2.2 vs FSAR Table 7.6-6.

j 8

806 3B No.

The specific Grand Gulf analysis for the MCPR limit of 1.18 in Tech Spec is fuel load error yields delta MCPR of 0.1; adding correct. Change SER Section 15.4.3.

a MCPR safety limit of 1.06 would give an Fuel load error analysis is not limiting.

operating MCPR limit of 1.16.

The Tech Spec value of 1.18 is more conservative.

I 23 201 2B No.

The present design is correct, the removal Table 3.3.2-1 change is to delete note of the note is an editorial modification.

(f) for secondary containment manual isolation valve groups. Mechanical vacuum pumps do not trip on manual isolation initiation.

25 076 IB Yes. Using the present values in the Tech Spec This inconsistency is in ECCS response could allow operation outside the bounds of the times between FSAR & Tech Spec. LPCS/

LPCI to be 40 sec.

accident analysis.

Rev. 4, 4/13/84 Wisd2

FOOTNOTES - SECTION 3/4 FSAR INCONSISTENCIES Prg2 2 of 6 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 28 802 3B No.

Accident analysis assumes that the EOC-RPT Change FSAR to state 40% of rated thermal feature is inoperative at power levels below power for RPT-EOC function; now states 40%. The reference to 30% power in FSAR 30% power.

7.6.1.8.1 is incorrect.

34 803 3B No.

This will allow the FSAR to more clearly Tech Spec Table 3.3.7.1-1 end FSAR Table reflect the Tech Specs.

11.5-1 do not match.

(Rad Mont. Inst).

Consider explanatory note as addition to FSAR.

39 807 3B No.

The FSAR changes are to effect consistency FSAR Change to show proper Surveillance between the various FSAR sections. A proposed intervals (Sections 11.5.2.3.1; change to Tech Spec 4.3.7.1-1 was requested in 11.5.2.3.2; 12.3.4.2.7).

l AECM-84/0216.

40 202 3B No.

Tech Spec is more conservative than Table 3.3.7.5-1.

Proposed change increases the number of required channels i

required by plant design.

of suppression pool temperature monitoring from 6 (1/ sector) to 12 (2 / t.* c tor).

l 41 327 3B No.

Calibration requirements of Tech Spec are Change YSAR requirements for CTNT/DRWL area rad monitor inst to be sent to sufficient.

vendor for calibration each refueling outage.

43 329 1C Yes. Rod monitors may not be operable in a Revise Tech Spec to require post accident mode in which they are potentially needed.

rad monitors to be operable in Conditions 1, 2, and 3 to agree with STS.

44 330 2B No.

Daily channel checks can be implemented Table 4.3.7.5-1.

Proposed change adds and controlled administrative 1y.

daily checks to accident monitoring instrumentation.

Reference:

FSAR 11.5.2.3.1.

47 251 2F No.

The.7 cps has been previously approved by The.7 cps was approved by Amendment 12 Amendment 12.

Tech Spec 4.9.2.c needs to be and issued by NRC is now inconsistent with the FSAR.

changed to provide consistency.

49 010 2B No.

Operability of all 5 TIPS can be maintained Plant has 5 TIPS vs. 3 as stated in Tech administrative 1y.

Spec. Change Tech Spec to 5.

Rev. 4, 4/13/84 Wisd3

FOOTNOTES - SECTION 3/4 FSAR INCONSISTENCIES Pags 3 of 6 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 52 073 2B No.

The insurance requirements are more Table 3.3.7.9-1.

Update Table of fire 102 2B restrictive than the Tech Spec and are detection instrumentation and zones in 304 2D controlled administratively.

both Tech Spec and FSAR.

56 257 2B No.

The inconsistency is conservative.

The Action Statement b of Tech _ Spec 3/4.4.2 is inconsistent with 3.6.3.1 Action Statement b but is more conservative in that it requires mode switches to shutdown immediately at a i

pool temp of 105*F with a stuck open valve where the FSAR and Tech Spec 3.6.3.1 allow the temp to go to 110*F.

4

{

59 001 IB Yes. Tech Spec as written would allow operation ADS 7 vs. 8 valves.

j with an operable equipment configuration which was not considered in accident analysis.

67 229 2B No.

Strictly clarification, only the inboard 4.6.1.4.a.2 and c.1 revise for clarification. MSIV LCS heater only on system has heaters, inboard system, not on outboard as j

implied by STS.

)

69 801 3B No.

Tech Spec values are correct for accident Evaluate equipment qualification program to confirm CTMT to Auxiliary Building analysis.

Diff. Press. Range. Revise FSAR and NUREG-0588 response.

70 260 3B No.

Previous Mark III analysis determined that CTMT avg. air temp. 80*F vs. 90*F.

CTMT average air temperature can be 95'F without Correct"FSAR.

j compromising the analyzed accident CTMT pressure i

and temperature limits.

~~

72 172 2B No.

Change would be.for clarification only.

A/[~k is not leakage. Clarification.

i Drywell bypass leakage requirements would not i

change.

74 234 3A No.

Tech Spec and plant design are consistent FSAR revisions to agree with Tech Spec.

Tables for Sup. Pool Volume and and correct.

j instrumentation. Editorial for clarification of suppression pool level instrumentation.

Rev. 4, 4/13/84 l

Wisd4

FOOTNOTES - SECTION 3/4 FSAR INCONSISTENCIES P&g2 4 of 6 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 85 131 2G No.

Surveillance of.all hose stations can be Table 3.7.6.5-1 requires update for hose controlled administrative 1y.

stations for completeness.

88 804 3B No.

The FSAR sections referenced on the problem This is an inconsistency with the FSAR sheet are not inconsistent but rather address only, not the SER. Later evaluation

}

different capacities. An FSAR change is not determined. Tech Spec and as-built to be correct and revision of FSAR is needed.

i required.

i Diesel day tank volume needs to be corrected.

4 91 335 2B No.

The additional requirements are currently Clarification of which revision of being performed under administrative controls, Regulatory Guide 1.137 applies. Proposed although there is no requirement to do so in change to include diesel fuel oil testing i

Tech Spec.

requirements. Check for water.

93 810 3B No.

This is a software change only to update FSAR revision required to describe the FSAR to the Tech Specs and trip setpoints as as-built trip setpoints per DCP 82/3173.

modified by DCP 82/3173.

FSAR Q&R 040.5.c needs to agree with Tech q

Spec 4.8.4.1.

i i

f 94 809 3B No.

FSAR section 7.1.2.6.22 indicates that the FSAR and SER should be changed to Grand Gulf design complies with Regulatory Guide properly describe MOV thermal overload 1

1.106.

This is correct, bypass circuitry, i

102 249 2D No.

The use of a vendor, with proper FSAR does not address GGNS use of a administrative controls, is not significant to vendor to perform solidification /

i dewatering of radwaste.

i safety.

L l

107 322 2E No.

Inaccuracies in the bases do not alter the Change to ADS Bases page 3/4 5-2.

Change accuracy of the LCO or the ability to the the Bases with respect to LPCS/LPCI i

{

subject equipment to perform in accordance with injection pressure into the vessel.

accident analysis.

Change to state that the reactor pressure

]

is reduced by ADS substantially below the r

4 pressure at which LPCI/LPCS inject into the vessel.

i 1

i Rev. 4, 4/13/84 Wisd5

~.

FOOTNOTES - SECTION 3/4 FSAR INCONSISTENCIES Pcg2 5 of 6 NOTE TSPS i PRIORITY SAFETY SIGNIFICANCE COMMENTS 109 320 2E No.

The plant design and LCO requirements are Page 3/4 6-4 of the Bases has an based on Bechtel drywell and containment incorrect number of 1089 for blow down analysis which cites 1060 psig reactor pressure, pressure. Should be 1060 psig which reflects 105% heat balance.

119 251 3B No.

Per GE analysis, Tech Spec is adequate.

Maximum MSIV isolation Times - Allowable The apparent inconsistency is due to times differ in FSAR and Tech Spec.

insufficient detail in the FSAR to relate the instrument response times to the analysis.

125 019 2B No.

Ensuring the more conservative method is Drywell Purge Flowrate Definition - Tech used (SCFM or CFM) is controlled Spec definition is in CFM, should be SCFM administratively.

(i.e., temperteure dependent).

151 812 3B No.

The timer is in the plant and Tech Spec.

INEL item 3B.

MSL Tunnel Temp Timer is 816 3B Its exclusion from the FSAR has no impact.

not in FSAR. FSAR values for MSL Flow-FSAR setpoints being incorrect do not affect High setpoint and range are wrong.

the accuracy and consistency between the plant design and Tech Spec.

153 820 3B No.

Incorrect FSAR numbers do not affect the RCIC Instrument settings in FSAR Table accuracy and consistency between plant design 7.4-1 differ from Tech Spec setpoints.

and Tech Spec.

154 819 3B No.

This involves correcting a nomenclature FSAR 3.7-17 reference to triaxial problem only.

response spectrum recorders is incorrect.

Should be spectrum analyzer.

155 818 3B No.

Administrative controls have been affected Revise FSAR 6.2.3.2 to indicate that to ensure blind flanges and rupture discs are blind flanges and rupture discs are also included as part of secondary containment used to isolate secondary containment, isolation.

156 817 3B No.

Change to FSAR would be an editorial Revise FSAR 6.2.3.2 to indicate that SGTS addition which would have no effect on the has capability to overcome the additional system capability, inleakage:from a single 4 inch penetration or failure of all non-Q lines 2 inch and under.

157 827 3B No.

The as-built level setpoint provides the Revise FSAR 9.5.1.2.1 to correct the fire required water volume in the storage tanks, water storage tank low level makeup water supply setpoint.

Rev. 4, 4/13/84 Wisd6

POOTNOTES'- SECTION 3/4 FSAR INCONSISTENCIES Pt.:g2 6 'ef. 6 -

NOTE TSPS #

PRIORITT SAFETY SIGNIFICANCE COMMENTS 158 306 IB Yes.

If the specified closing times for the Add several D/W valves to Tech Spec RWCU valves are not within analytical limits, table. Investigate analytical stroke this may result in a' release:following an RWCU time discrepancies.

pipe break in excess of previously analyzed j

releases.

172 828 3B No.

There is no plant safety impact as a result FSAR Section 7.4.1.1.3.2 indicates that j

of this discrepancy. Tech Spec 3.3.5 correctly the RCIC system is actuated on a reactor.

i lists the RCIC initiation setpoints.

Iow-water level. The GGNS Tech Spec, I

indicates initiation on Low-Low, Level 2.

l 173 829 3B No.

The GCNS Tech Specs are consistent with The GCNS Tech Spec differs from the j

-current requirements and commitments.

FSAR regarding reactor water chemistry Action Statements and Surveillances.

174 830 3B No.

There is no plant safety impact as a FSAR Section 5.3.3.6.b indicates the result of this discrepancy. Tech Spec 3.4.1.4 coolant temperature difference between j'

accurately lists the 100*F differential limit.

done and bottom head drain is no greater than 145'F. Tech Spec 3.4.1 indicates 100*F.

Rev. 4, 4/13/84 Wisd7

- -. - ~.

FOOTNOTES - SECTION 5.0 FSAR INCONSISTENCIES Pagt 1 of 1-e NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 1

225 2D No.

The same information that is on the Illegible figures.

illegible figures can be obtained from other administrative 1y controlled sources.

2 105 2E No.

Unrestricted area boundary is not Correction of terminology for effluent appropriate for gaseous and liquid effluents, release boundary vs. unrestricted area.

This is only a difference in terminology.

boundary.

i 3

252 3B No.

A special evaluation has shown that the The figures for containment and drywell.

Tech Spec values are consistent with plant net free air volume in the FSAR are not the same as those in the Tech Spec.

l design.

Within the FSAR the numbers are not consistent among Tables 1.3-4, 6.2-1, 6.5-6.

6 258 3B No.

The spent fuel pool is restricted from The spent fuel pool-can be partially normal use for spent fuel until SSW pump drained if the valves (G41-F032, F033) capacity is increased.

are opened while the spent fuel pool gate is removed. The valves are neither f

locked nor do they have electrical interlocka to prevent inadvertent j

i operation, i

l 7

259 2B No.

Tech Spec is correct. An FSAR change is GGNS Tech Spec Table 5.7.1-1, Vendor required. What appeared to be inconsistencies Documents, and FSAR Table 3.9-1 do not i

j was due to use of different terminology in the correlate. The transients / cycles are different documents.

defined differently in the documents.

i j

I l

i i

1 Rev. 4, 4/13/84 Wisd8

FOOTNOTES - SECTION 6.0 FSAR INCONSISTENCIES Paga 1 of 1 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 13 813 3B No.

The requirements for the Manager of Requirement for HQA are less restrictive Quality Assurance position have no impact on in the OQAM than in the GGNS Tech Spec.

the safety of operation of the plant.

MQA is required by GGNS Tech Spec to be a

~

member of the SRC.

16 096 2E No.

Requirement for SRC review of reports of FSAR requires semi-annual review of ALARA audits of the ALARA Program can be controlled appraisals by SRC.

administratively.

19 270 2E No.

The program described in 6.8.3 meets the Verify GGNS Tech Spec, include NUREG-0737-intent of NUREG-0737. Specific details within requirement.

the program can be controlled administratively.

Rev. 4, 4/13/84 Wisd9

FOOTNOTES - SECTION 2 SER INCONSISTENCIES Pcgi 1 cf'l s

NOTE TSPS f PRIORIT".

SAFETY SIGNIFICANCE C0tMENTS 1

319 2E No.

The reactor vessel was manufactured using Tech Spec Bases references wrong code the proper code as identified in the FSAR.

date for Rx vessel. Change 1974 code to 1971 Edition thru vinter 1972 Addendum.

2 151 3B No.

Tech Spec is correct per GE spec data Change FSAR and SER from 112.5% to 118%

sheet 22A3739AE Rev. 4, Sheet 11.

for APRM trip. Tech Spec is correct.

Rev. 4, 4/13/84 Wisd18

._.A w w-.e_-

7 4

,m 4

-s 4

a---

e a

a--

.u.-

4.-

u...

m I

\\

700TNOTES - SECTION 3/4 SER INCONSISTENCIES Pcg2 I cf I s.

I NOTE TSPS #

FRIORITT SAFETT SIGNIFICANCE C000fENTS l

8 806 3B No.

The specific GGNS analysis for the error MCFR limit of 1.18 in Tech Spec is j.

yields delta MCFR of 0.1; adding a MCFR safety correct. Change SER Section 15.4.3.

limit of 1.06 would give an operating MCFR limit Fuel load error analysis is not limiting.

j of 1.16.

The tech spec value of 1.18 is more

{

conservative.

I j

23 201 28 No.

The design is correct, the removal of the Table 3.3.2-1 change is to delete note a

note is an editorial modification.

(f) for secondary containment manual j

isolation valve groups. Mechanical j

vacuum pumps do not trip on manual

]

isolation initiation.

I 29 147 3B No.

Second-level voltage sensors and time SER 8.4.4.1.d requires maximum and delays have been incorporated into the Tech minimum limits for second-level voltage Specs per plant design.

sensors'and time delay devices. Table 3.3.3-2.

1 i

89 808 3B No.

The design. Tech Spec and FSAR are correct. SER does not properly describe Diesel l

Generator trips under emergency conditions.

l4 i

94 809 3B No.

FSAR Section 7.1.2.6.22 indicates that FSAR and SER should be changed to

- the GGHS design complies with R.C. 1.106. This properly describe MOV thermal overload is correct.

bypass circuitry.

I 111 148 3A No.

Due to the extremely low probability of SER requires Turbine stop/ control valve turbine missile hazards which could affect plant by-weekly testing.

j safety and due to the ability to control turbine i

testing administratively, inclusive of such a Tech Spec is not necessary.

4 i

1 171 826 3B No.

There is no safety impact that results from SER Section 9.1.3 states that the spare j

this discrepancy. Plant procedures currently fuel pool cooling pump will be tested j

require surveillance on 1oth pumps. Tech Spec periodically accordingly to the Tech 3.7.9 requires the temperature of the spent fuel Specs. The GGNS Tech Spec contain no pool be maintained below 125'F.

such provisions.

j!

l 1

1 i

i Rev. 4, 4/13/84 l

i Wisd19

FOOTNOTES - SECTION 6.0 SER INCONSISTENCIES F ge 1 ef 1 NOTE TSFS i PRIORITT SAFETT SIGNIFICANCE ColetENTS 2

095 2E No.

These are only administrative and do Correct Organization Chart in Tech Specs 101 2E not affect the safety of operating the plant.

and FSAR.

No decrease in staff competancy or the number of SRO's required.

3 340 21 No.

In response to the requirement of Revise to require an eight hour break as NUREG-0737, FSAR Section 18.1.3 states 8 hr.

opposed to a twelve hour break.

This provides consistency within the FSAR.

12 814 3B No.

The titles were changed and were reflected SER requirements for SRC composition are in a Tech Spec revisions.

in conflict with the GGNS Tech Spec.

20 146 2E No.

The requirement can be controlled SER requires Tech Spec to control work in administratively, the control room ceiling in other than cold shutdown.

Rev. 4, 4/13/84 Wisd20

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EXPANDED MATRIX CONSISTENT /INCONSISTENi - SECTION 3/4 Peg? 2 cf 9' OTHER AREAS TECHNICAL.

SPECIFICATION FSAR SER STS AS-BUILT OF TECH SPECS-OTHER PROPOSED ACTION (323, 324)

(106,325) 15 - Submit PCOL I

I 18 - PCOL 84/02 119 16,23 (325) 20 - PCOL 83/20

151, 24,106.162 19,20 7

24 - Submit PCOL 10 23 12,13 134,18,22 17 21 3/4.3.2 7

7 7

106 - PCOL 84/05-(326) 15,26 (328, (326, 30.113

329, 15 - Submit PCOL (26) 327) 114.133 330) 25 - PCOL 83/20 9

l 113,115 I'

I 1

N/A 114 - PCOL 84/03 3/4.3.3 I

3/4.3.4.1 C

C C

I N/A N/A (I

3/4.3.4.2 I

C C

I N/A N/A

153, 7

30.116 C(22,322)

N/A

'116 - PCOL 83/23 3/4.3.5 C

C 1

N/A (

N/A

(

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3/4.3.6 C

C I

I (53) 16, 5 35 - PCOL 84/03

9 8.168 36(37) 37 3/4.3.7.1 1

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I 3/4.3.7.3 C

C C

C N/A N/A l47 3/4.3.7.4 C

C C

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40,41 40,42 7

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48 C( U C( 8) 7 N/A 3/4.3.7.6 I

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EXPANDED MATRIK CONSISTENT /INUJW MTENT - SECTION 5.0 Pcg? I of 1

~ 01ilER AREAS TECHNICAL FSAR SER STS AS-BUII.T OF TECH SPECS :

OTHER PROPCSED ACTION SPECIFICATI0t1-I '2 l

C(400) C N A( }~

5.1.1 C

C I

5.1.2 C

C C

N/A N/A I'

5.1.3 C

C N/A C

N/A I*

3 C(401).yfg(3)

N/A N/A 5.2.1 1

C

'C N/A' N/A 5.2.2 C

C

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5.2.3 1

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'N/A N/A_

cN/A y

0

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C 1

N/A N/A 5.3.1 5.3.2 C

C C

C N/A N/A 5.4.1-C' C

C C

N/A

___ N/A C(403) C(403)

N/A N/A

^

5. 4'. 2 C(403) C w

5.5 4

C(400) c N/A N/A C

C 5.5.1

~

C I

C(405) C 'O'} C '05)

N/A N/A C(403) 5.6.1.b 5.6.1.2 6

5.6.2 C

-C

-C 1

N/A N/A 5.6.3 C

C C

C N/A N/A C( }

C( }

N/A N/A I

C 5.7,1 Rev. 1, 4/12/84

' X3cdm7

48

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1 2

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6 7

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1 1

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6 X

FOOTNOTES - FOR DELETED MATRIX ITEMS Pgg2 I of 18 COMMENTS NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE Delete. Not an inconsistency - this 300 210 2G None.

remark is in reference to a future modification to add additional scram discharge volume float switchen.

Delete. This is not an inconsistency but 301 124 2G None.

MP&L's desire to increase.the allowed ties for performing shutdown margin demonstration. The GGNS Tech Spec is not inconsistent with the STS. The GGNS Tech Specs are more conservative.

Delete. This adds the word " withdrawn" 302 N/A N/A None.

to GGNS Tech Spec. STS already has.

Provides a greater degree of flexibility.

Delete. STS states "3.0.4 Not 303 N/A N/A None.

Applicable;" GGNS Tech Spec does not.

GGNS Tech Spec is more conservative than STS.

Delete. This is an inconsistency with 304 N/A N/A None.

STS but should remain in the GGNS Tech Spec. GGNS Tech Spec has a provision for 4.0.4 exemption after maintenance on CRDs.

If provisions for "3.0.4 Not applicable" are added to GGNS Tech Spec as in STS, then this note can be deleted.

Delete. GE is recommending that some of 305 108 2C None.

the action statements should actually be written into the LCO vs. the action statement. The plant can operate under this Tech Spec. This does not render the GGNS Tech Spec inconsistent with plant design, it only provides better operating margin.

Delete. TSPS #154 is in error - Tech 306 154 2D None.

Spec is OK as written.

Rev. O, 4/13/84 W6sd1

FOOTNOTES - FOR DELETED MATRIX ITEMS Pag 2 2 of 18 e;

NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 307 N/A N/A None.

Delete. STS has provision for "3.0.4 Not Applicable." Need to add to GGNS Tech Spec when possible. GGNS Tech Spec is now more conservative.

308 N/A N/A None.

Delete. Action is consistent with STS but does not adequately verify' scram header pressure.

It does demonstrate CRD i

pump operating but not at 1750 psig.

There are other sufficient methods available to measure header pressure, ff desired.

309 214 3B None.

Delete. Design was not intended for this type surveillance requirement. GE recommends deleting this surveillance.

GGNS Tech Spec and STS requires checking the check valves between the HCU and CRD pump. This does not correspond to GE requirements. GGNS Tech Specs are overly conservative.

Deleted. STS has provisions.for "3.0.4 310 N/A N/A None.

Not Applicoble." Need to add to GGNS Tech Specs when possible. GGNS Tech Spec is more conservative.

Delete. GGNS design has "an alternate 311 155 2D None.

rod position indicator." GGNS has 2 channels of RPI.

Delete. STS has provisions for "3.0.4 312 N/A N/A None.

Not Applicable." Need to add to STS when possible. GGNS Tech Spec is more conservative.

Delete.

STS now provides for rearming of 313 N/A N/A None.

CRD for testing. Need to add to GGNS Tech Specs when possible. GGNS Tech Spec is more conservative.

Rev. O, 4/13/84 W6sd2

FOOTNOTES - FOR DELETED MATRIX ITEMS Page.3 of 18 I

NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS l

314 051 2B None.

Delete. This is only a misspelled word "withdrawl" vs " withdrawal."

315 N/A N/A None.

Delete. This was identified by the GE FSAR/SER review and is totally inconsistent with the LSE review. LSE states 3/4.1.4.2 is adequate and meets design requirements.

316 156 2D None.

Delete. GE would like to add storage tank outlet valve to action statement.

However, GGNS Tech Spec is coraistent with STS, 317 157 2D None.

Delete. This is not an inconqistency.

Illegible; figures are not an inconsistency; however, they will be corrected.

i Delete. We do not see this as an J

318 N/A N/A None.

inconsistency but only as a GE recommendation. MP&L's interpretation l

and understanding of the Tech Spec is that the pumps are run one at a time for.

testing of SLC.

319 N/A N/A None.

Agree. Total peaking factor is in STS but not GGNS Tech Spec.

I Delete. STS allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . GGNS Tech 320 049 2B None.

Spec says 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , thus we are more conse rva t ive.

Delete. Provides more operational 321 049 2B None.

flexibility. STS allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months vs 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as in GGNS Tech Spec. We are more conservative.

4 Delete. The simulated thermal power time 322 N/A N/A None.

constant is given in Table 4.3.1.1-1, footnote (1).

Rev. O, 4/13/84 W6sd3

FOOTNOTES - FOR DELETED MATRIX ITEMS Pcg2 4 of 18 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 323 040 2F None.

Delete. GGNS Tech Specs are much more conservative, thus are not inconsistent i

with requirements.

i l

324 N/A N/A None.

Delete. Delete all response times from Table 3.3.2 except Mainsteam Line Isolation response time per FSAR. This does not appear from CEs interpretation to an inconsistency. The GCNS Tech Specs are more conservative.

Delete. The ** (indicating preliminary 325 204 2H None.

values to be verified during S/W testing)

I are missing.

326 206 2G None.

Delete. This is not an inconsistency for the plant as-built. CE listed this against the LPC1/LPCS interlocks to be installed in.first refuel outage.

i Delete. Only the min flow function is 327 N/A N/A None.

inconsistent with STS as the GGNS f

Tech Spec covers the power monitor portion under LSSS Tech Spec J

requirements. Change notes to say "GGNS j

Tech Spec and STS differ in that min flow trip functions for LPCI/LPCS have been included in STS."

I Delete. No specific item is identified.

328 074 2D None.

Delete. This is not an inconsistency 329 205 2H None.

until first refueling outage. The HPCS wide range level instrument nondensity compensation problem will be resolved prior to restart following the first refuel outage.

i Delete. ESF notation vs. ECCS is not an l

330 N/A N/A None.

inconsistency especially in the ECCS Spec.

Rev. O, 4/13/84 W6sd4

FOOTNOTES - FOR DELETED MATRIX ITEMS Pcga 5 of 18 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS Delete. This is not viewed as an 331 047 28 None.

inconsistency, but a word clarification I

within the same Tech Spec. The GGNS Tech Spec is consistent with all other references. Testing frequency EOC-RPT response time testing.

332 114 2B None.

Delete. This item changes the Allowable i

Value for Suppression Pool Level. The GGNS Tech Specs are conservative with i

respect to the desired' change and are consistent with STS, FSAR, etc.

1 Delete. The APRM Rod Block of 4% vs. the 333 237 2D None.

l 5% in Tech Spec is not an inconsistency.

When Grand Gulf implements ATWS during

'the refueling outage, this Tech Spec will t

be changed.

334 009 2D None.

Delete. Even though TSPS #009 lists the number of SRMs required OPERABLE as inconsistency among Tech Specs, the only spec which is wrong and should be changed is Tech Spec 3.3.7.6.

i 335 029 3B None.

Delete. This is not an inconsistency.

Plant Staff has identified a better way I

to perform neutron monitoring functional test without having to rely on Position j

Statement 12.

This is purely an implementation issue and has no bearing on the Tech Specs.

i 336 197 3A None.

Delete. Refueling Rod Blocks not included in Rod Block Inst. Spec but are included in Refueling Spec. GGNS Tech Spec is consistent with STS.

f Rev. O, 4/13/84 W6sd5

FOOTNOTES - FOR DELETED MATRIX ITEMS Page 6 cf 18 NOTE TSPS I PRIORITY SAFETY SIGNIFICANCE COMMENTS Delete. This TSPS item will make the 337 118 2D None.

maintenance of the SRM drives possible in Operational Condition 5.

(SRM detector not-full-in interlock rod block.)

Delete. The changes to the GGNS Tech 338 048 2H None.

Specs as a result of the MEOD analysis will be handled on a routine basis and is not an inconsistency.

Delete. This item is not an inconsistent 339 018 3B None.

with any known document, and only needs clarification from the NRC.

Delete. This item refers to APRM Low 340 237 2D None.

Power Rod Block and is not an inconsistency with as-built condition.

Delete. MP&L would like to resolve the l

341 123 2D None.

issue of the 100*F dif ferential temperature for starting a recire pump below 212*F but believes the Tech Specs l

as written are acceptable and that this is not an " inconsistency."

Delete. The Tech Specs as written 342 023 2B None.

require surveillance of actuation inst.

and given setpoints. As the Tech Specs are written any channel which fails puts the plant in a less than min. required channel condition. The Tech Specs could be written in a better format, but this does not represent an inconsistency.

Delete. This is not an inconsistency.

343 159 2D None.

TSPS #159 was written for possible enhancement only.

l Rev. O, 4/13/84 W6sd6

FOOTNOTES - FOR DELETED MATRIX ITEMS Pcg2 7 of 18 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS

^

344 221 2D None.

Delete. This is not an inconsistency.

It is written against TSPS #221 which proposes additional operational flexibility. The Tech Spec as written is more conservative than STS and exceeds the requirements of the STS.

I 345 N/A N/A None.

Delete. This is not an inconsistency.

This item describes a plant modification (Low Pressure ECCS Injection Valve Rx Low Pressure Interlock) which will not he installed until first refueling outage.

The Tech Spec is acceptable as written.

346 055 2D None.

Dele.e.

This is not an inconsistency.

TSPS #55, which was written for enhancement purposes only, proposes deletion of the phrase "for up to 31 days."

347 160 2E None.

Delete. This is not an inconsistency.

It is written against TSPS #160 which suggests changes to the Bases to more clearly define the curves presented in Figure 3.4.6.1-1.

348 N/A N/A None.

Delete. This is not an inconsistency.

Amendment 9 added operational enhancement to the existing wording in the STS survaillance requirement. The Tech Spec as written exceeds STS requirements. The FSAR will be revised through the normal i

procedures.

Delete. This is not an inconsistency.

j 349 161 2E None.

It was written against TSPS #161 which was discussed during the onsite GE-LSE review t

i and determined to be adequate as written.

Rev. O, 4/13/84 W6sd7

FOOTNOTES - FOR DELETED MATRIX ITEMS Pcg2 8 of 18 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 350 030 2D None.

Delete. This is not an inconsistency.

The HPCS line break detection surveillance as written exceeds the requirements of BWR/6-STS.

351 030 2D None.

Delete. This is not an inconsistency.

The item is written against the CE-FSAR/

SER review item for Tech Spec 3/4.5.1 actions "f" and "g".

This item is a proposal to change GCNS Tech Specs to be consistent with recent changes to the GE STS.

352 N/A N/A None.

Deleted.

353 056 3B None.

Delete. This is not an inconsistency.

It is written against TSPS #56 which has been determined to be unjustified since Surveillance Requirements already exists for the CST automatic transfer.

Delete. This is not an inconsistency.

354 162 2D None.

It is written against TSPS #162 which involves a clarification of an ACTION statement.

Delete. This is not an inconsistency.

355 N/A N/A None.

Tech Spec as written contains surveillances that are no longer required in the GE STS.

i Delete. This is not an inconsistency.

356 163 2D None.

It is written against TSPS #163 which involves a clarification of an ACTION statement.

Delete. This is not an inconsistency.

357 N/A N/A None.

The Tech Spec as written is more conservative than the BWR/6-STS.

GGNS Tech Spec contains additional Surveillance Requirements.

Rev. O, 4/13/84 W6sd8

FOOTNOTES - FOR DELETED MATRIX ITEMS Pcg2 9 of 18 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS 358 195 3A None.

Delete. This is not an inconsistency.

It is written against TSPS #195 which was written to cover the concern that the existing Surveillance Requirements may not be adequate. The onsite GE-LSE review determined that present Surveillance Requirements were adequate.

359 N/A N/A None.

Delete. Suppression pool temperature monitors are powered from RPS busses.

Proposed change is to supply power from class IE UPS.

Future design consideration DCP process will implement any changes required if a DCP is implemented.

360 N/A N/A None.

Delete. Section 3.6.3.1 of the GGNS Tech Specs differs from the GE-STS in that the STS now has an additional action statement which places a time and power limit on how long the suppression pool temperature may remain above 95'F.

361 012 2D None.

Delete. This is not an inconsistency.

It is written against TSPS #12 which involves a typographical error.

362 N/A N/A None.

Delete. STS Surveillance requires SGTS filter train and dampers to operate for each automatic and manual actuation signal. GGNS Tech Spec requires operation for at least one of the-actuation signals (approved by Amendment 9).

Delete. STS Surveillance requires t

363 N/A N/A None.

automatic value isolation for each isolation signal. GGNS Tech Spec requires automatic valve isolation for at least one isolation signal (approved by Amendment 9).

Rev. O, 4/13/84

- ~^'

FOOTNOTES - FOR DELETED MATRIX ITEMS Prga 10 of 18 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 1

364 006 2D None.

Delete. This is not an inconsistency.

Present snubber Tech Spec is more conservative than the recommended change-and is completely adequate.

i 365 N/A N/A None.

Delete. This is an inconsistency with the STS.

However, the GGNS design requires only one SRV Tail Pipe pressure switch position indicator per valve.

366 216 3B None.

Delete. This is not an inconsistency.

It is written against TSPS #216 which identified no specific problems or inconsistencies.

367 N/A N/A None.

Delete. GGNS Tech Spec does not require checking of diesel fire pump battery individual cell voltage or cell plate physical condition as required by STS.

Batteries are automotive type and do not 4

have provisions for these tests.

i 368 223 2B None.

Delete. GGNS Tech Spec does not require i

periodic flush of system piping as i

required by STS.

Flushing will be i

performed through periodic hose tests.

2 1

369 N/A N/A None.

Delete. STS requires that when fire pumps are tested for operability that they be run on recirculation flow. GGNS Tech Specs do not state pump flow condition for testing. Tech Spec meets intent.

Deleted.

370 Delete. Relaxation of diesel generator 371 142 2F None.

testing requirements. No changes 175 3B recommended until a relaxation is made to Reg. Guide 1.93.

Rev. 0, 4/13/84 W6sd10

FOOTNOTES - FOR DELETFD MATRIX ITEMS Pag 2 11 of 18 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 372 145 2F None.

Delete. Delete Tech Spec 4.8.1.1.2.d.6 (Simulated loss of diesel generator with offsite power not available) Surveillance Requirement in accordance with NRC letter 83-30.

This allows consistency between GDC 17, Reg. Guide 1.8, and Standard Review Plan. Present Tech. Spec is consistent with all review documents and change is an enhancement.

373 N/A N/A None.

Delete. Loads sequenced on the diesel generator during ECCS actuation are referred to as " shutdown loads." They should be referred to as " emergency loads" to distinguish them from loads sequenced during a loss of offsite power.

Unnecessary clarification.

Delete. Proposed change to define 374 141 2F None.

testing requirements for different types of diesels. Tech Spec does not define test frequency requirements for the two different type of diesel generators installed at GGNS. Future enhancement.

Delete. This is not an inconsistency.

375 17 2E None.

It was written against numerous TSPS 175 3B addressed as follows:

026 2D 145 2F (1) TSP 3 #43 - Was written for 134 2D clarification enhancement only. GE i

007 2F onsite engineering review determined 043 2D the item to be invalid.

4 (2) TSPS #7 - Tech Spec as written is more conservative than the recommended change, so is not inconsistent.

(3) TSPS #134 - Was written to correct a typographical error, t

Rev. O, 4/13/84 W6sdll

f FOOTNOTES - FOR DELETED MATRIX ITEMS Peg 2 12 of 18 NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE COMMENTS

~

375 (Continued)

(4) TSPS #145 - Tech Spec as written is more conservative than recommended change, so is not inconsistent.

(5) TSPS #26 - Was written to correct a typographical error.

(6) TSPS #175 - Tech Spec as written is more conservative than the recommended change, so is not inconsistent.

(7) TSPS #174 - Was written for clarification enhancement only.

376 176 2B None.

Delete. This is not an inconsistency.

It was written against TSPS #176 which involves an enhancement to ACTION statement a for Tech Spec 3.8.1.2.

377 060 28 None.

Delete. This is not an inconsistency.

It was written against TSPS #60 which was written for clarification enhancement only.

378 135 N/A None.

Delete. This is not an inconsistency.

It is written against TSPS #135, which was corrected by Amendment 12 to the GGNS Tech Specs.

Inconsistency no longer exists.

379 177 2D None.

Delete. This is not an inconsistency.

It is written against TSPS #177 which involves differences in the wording of ACTION Statements 3.8.2.1(c) and 3.8.2.2(c).

Delete. This is not an inconsistency.

380 N/A N/A None.

The item involves clarification of an ACTION statement to address additional inoperable equipment.

I Rev. O, 4/13/84 W6sd12

FOOTNOTES - FOR DELETED MATRIX ITEMS Pag 2 13 of 18 NOTE TSPS I PRIORITY SAFETY SIGNIFICANCE COMMENTS 381 143 2G None.

Delete. Add new load profile for hattery to Tech Spec and FSAR. Increasing the valves for the DC load profile will allow j

addition of future loads without requiring Tech Spec change enhancements.

382 N/A N/A None.

Delete.

3/4.8.2.1 ACTION item a of GCNS Tech Spec is different from ACTION item a in STS (chargers not included in GGNS Tech Spec) and ACTION items c in GGNS Tech Spec is not addressed in STS ACTION l

items. Change is for clarification intent is met.

383 N/A N/A None.

Delete.

FSAR revision to describe addition of UPS per DCP-82/5004. DCP covers FSAR change.

384 N/A N/A None.

Delete. Revise FSAR Q & R 040.5.c to agree with Tech Specs to properly describe the methods of periodic circuit breaker testing.

385 N/A N/A None.

Delete. GGNS Tech Spec and STS have different testing requirements for circuit breakers that protect circuits l

that penetrate the Containment. GGNS Tech Spec is plant specific, t

f 386 810 3B None.

Delete. Revise FSAR documents in accordance with DCP-82/3173.

(6.9 kv BKR l

trip setpoints) DCP program will revise.

j Delete. Add surveillance requirement to l

387 N/A N/A None.

perform channel calibration following l

maintenance of a motor starter. This is function of standard maintenance practices and does not belong in Tech Specs.

Rev. O, 4/13/84 I

W6sdl3

. ~

FOOTNOTES - FOR DELETED MATRIX ITEMS Pag 2 14 of 18 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 388 181 2F None.

Delete. This is not an inconsistency.

It is written against an existing TSPS

181 which was written for clarification only.

389 226 3A None.

Delete. This is not an inconsistency.

Request review to determine if RPS EPA spec was necessary and if so consider adding timer spec. Enhancement only.

Delete. This is not an inconsistency.

390 180 2A None.

Change to support a future DCP to change RPS undervoltage trip to prevent spurious trips. The existing numbers in GGNS Tech Specs are more conservative than the recommended change, therefore, considered consistent. Enhancement only.

Delete. This is not an inconsistency.

391 182 2D None.

Change terminology "all rods in" vs. "one rod out".

TSPS is for clarification only.

Delete.

Inconsistency with STS in that 392 N/A N/A None.

STS identifies two interlocks. However, the two interlocks listed in STS are not applicable to Grand Gulf.

Inconsistent but acceptable.

Delete. This is not an inconsistency.

393 N/A N/A None.

GE's request was for Bechtel to verify 1140 lb. value which was done.

Delete. This is not an inconsistency.

394 N/A N/A None.

Change LCO to prevent loading fuel in a cell with control rod withdrawn / removed.

GE's position is that a Tech Spec change is required because two plants in 1982 did not follow the Tech Spec as written.

This is an internal administrative l

problem at those two plants not a Tech I

Spec problem.

Bown @n_4/13/84

~.

FOOTNOTES - FOR DELETED MATRIX ITEMS Page 15 of 18 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 395 046 2F None.

Delete. This is not an inconsistency.

Plant availability enhancement concerning RHR mode during refueling asks;for consideration for an operational enhancement only.

396 184 2D None.

Delete. This is not an inconsistency.

Change terminology " Rod-Dut-Notch-Override" vs. " Continuous Withdrawal."

]'

" Rod-Out-Notch-Override" control refers to a description of the function, not the name of the push button that performs i

that function.

397 N/A N/A None.

Delete. Change Tech Spec 4.4.1.2 to allow test at equal flow vs. equal valve position. This was shown on wrong spec.

This is an enhancement under consideration.

398 N/A N/A None.

Delete. FSAR and FER give dilution l

factors for radwaste discharges which do not reflect present plant practices and design. Tech Spec is not changed. DCP program will correct FSAR through normal updates.

399 N/A N/A None.

Delete. This is not an inconsistency.

Eliminate reload fuel weight percent reference. The BWR/6-STS leaves this number blank and is a site specific number. The reload fuel presently onsite l

is consistent with the percentage reference in specification as written.

400 N/A N/A None.

Delete. The GE STS states that the Met.

Tower location is on Figure 5.1.1-1.

The I

j Met. Tower location is shown on Figure i

5.1.2-1 ef the CGNS Tech Spec, however, CGNS Tech Spec Figure 5.1.1-1, Note 4 states that this is the case. This is not an inconsistency.

Rev. O, 4/13/84 W6sdl5

,n-.

,, + - - -

--e, 4,-

-,3 y, - -

FOOTNOTES - FOR DELETED MATRIX ITEMS Pag? 16 of 18 i

NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 401 N/A N/A None.

Delete. The GGNS Tech Spec states a suppression pool depth of " Approx. 18-19 feet" while the GE STS states " Approx. 20 feet."

This is GGNS specific.

402 N/A N/A None.

Delete. Currently no mechanism is in place to ensure vessel design parameters.

Design, conrtruction, and N-stamp was accomplished per Section III requirements using listed parameters. After code stamping, vessel parameters are maintained by Section XI ISI requirements based on the operational values related to the design parameters.

Delete. The nominal T ave of 533*F 403 297 2B None.

presented in Tech Spec does not appear to agree with temperatures shown in FSAR Figure 5.1-1.

Problem is nomenclature clarification.

Delete. The allowance for uncertainties 404 N/A N/A None.

in Keff equivalent given in the GE STS is j

not in the GGNS Tech Spec. This is optional in STS and not required.

Delete. The GGNS Tech Spec addresses 405 N/A N/A None.

only the center-to-center spacing in the spent fuel storage racks; the FSAR, SER, and "As-Builts" also addresses the within-rack spacing. Values are comparable.

Delete.

Standard Technical Specification 406 N/A N/A None.

(GE-STS) require a directive issued by i

highest level of Corporate Management.

l GGNS Tech Specs requires a directive by the Senior Vice President. This is GCNS specific.

Rev. O, 4/13/84 W6sd16

FOUINOTES - FOR DELETED MATRIX ITDtS.

Pags 17 of 18-NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS i

407 N/A N/A None.

Delete. GGNS Tech Spec does not reflect the organizational arrangement for performing and monitoring QA activities as required by GE-STS.

Organization chart shows QA interfaces, which is

+

. sufficient.

i Delete. PSRC composition in the GGNS 408 N/A N/A None.

Tech Spec and the GE-STS are in conflict.

Both the GGNS Tech Spec and the GE-STS I

are in conflict with actual composition.

This is GGNS specific, i

l 409 N/A N/A None.

Delete. There is a direct implication that alternates be organizational 1y tied

(

to members of the PSRC.

It is the intent I

that alternates be qualified in the same j

manner as members. This is administered by plant procedures.

4 Delete. GE-STS states alternates to the 410 N/A N/A None.

PSRC are appointed by the PSRC Chairman.

f The GGNS Tech Specs requires appointment j

by the Plant Manager. This is GGNS specific.

d Delete. STS states reports will be sent 411 N/A N/A None.

to the Director, Office of Resource Management. GGNS Tech Spec does not contain this requirement. GGNS Tech Spec meets intent.

Delete. Revise Table 3.3.1-2 to add a 412 N/A N/A None.

footnote to describe initial starting point to be used for turbine stop valve closure response time testing. Tech Spec is adequate as written.

~

1 I

Rev. O, 4/13/84 l

W6sdl7

FOOTNOTES - FOR DELETED MATRIX ITEMS' P ga 18 of 18; NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS Delete. End-of-cycle recirc pump trip:

413 N/A N/A None.

Time from start of TSV closure or TCV fast closure to complete suppression of the circuit breaker are varies between i

the GE Specs and the GGNS Tech Specs. GE

~

Spec changed for GGNS plant specific.

1 Delete. GCNS Tech Spec requires 414 N/A N/A None.

individuel responsible for reviews must' meet or exceed section 4.4 of ANSI 18.1, 1976. This requirement would limit reviews to only a few plant personnel.

GGNS Tech Spec should reference ANSI -

18.1, 1976.in its entirety. This is correct.

t 4

i i

l i

I I

i Rev. O, 4/13/84

. W6sdl8

~~

-- ~ ~

~

~ ~

~ ~ '

}

i INCONSISTENCIES: FSAR vs. AS-BUI' T PLANT Page 1 of 2 1

J NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 52 073 2B Smoke detection is provided;for subject areas.

a. FSAR 9A.7.2.2.24 and 69 states that 102 2B Overall SER conclusions not impacted.

smoke detectors will be installed.

304 2D The as-built plant has these detectors installed. FSAR is not current.

Purely editorial. Renaming of zones does not

b. FSAR Figure 9A-22 does not correctly alter fire protection requirements or measures identify fire detection zones. The provided. Overall SER conclusions are not design documentation does identify the impacted.

zones correctly.

(Applies to diesel generator buildings.)

74 234 3A The FSAR discussion should be expanded to clarify The FSAR 6.2.7.5 does not clearly reflect reference to narrow range instrument. The the suppression pool level clarification of the high and low water level instrumentation, i.e., which instrument alarm input should not alter overall conclusions provides high and low level alarms, in the SER (7.5.2).

Narrow range instrumentation not described. Arrangement of sensors requires clarification.

l 85 131 2G Second column line is an editorial error. There FSAR Figure 9.5-4 incorrectly lists a can be only one location for a single hose second column line for a single hose station. Area is provided necessary fire station.

protection measures. No impact on SER overall conclusions.

94 809 3B (Evaluation of item under review.)

FSAR 7.1.2.c.22 does not fully describe methods used for providing thermal overload protection to MOV's.

5

\\

112 234 3A The FSAR discussion should be expanded to clarify FSAR 6.2.7.5 does not clearly reflect i

reference to narrow range instrument. The the suppression pool level clarification of the high and low water level instrumentation, i.e., which instrument l

alarm input should not alter overall conclusions provides high and low level alarms.

in the SER (7.5.2).

Narrow range instrumentation not described. Arrangement of sensors requires clarification.

4 Rev. 4, 4/13/84 W3sd1

~~-

\\

INCONSISTENCIFSt FSAR va. AS-BUILT PLANT Pcg2 2 of 2 j

NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS s

154 819 3B By MP&L/Bechtel evaluation, the key issue is that FSAR Table 3.7-17 incorrectly describes prompt readout of seismic information is provided certain seismic instrumentation. The in the control room. The current design, with as-built plant has response spectrum analyzers, meets this requirement. The SER analyzers not recorders, overall conclusions are not impacted.

155 818 3B Barriers such as these are consiaered acceptable FSAR does not indicate that. blind flanges based on MP&L/Bechtel evaluation of BTP CSB 6-3.

and rupture discs are used in secondary The omission of the discussion of the use of containment boundary (FSAR 6.2.3.2).

I blind flanges and rupture discs does not impact the overall SER conclusions (SER 6.2.2).

158 306 IB Categories "a" through "f" include discrepancies Numerous corrections and clarifications which are purely editorial, dealing with proposed to FSAR Table 6.2-44, information or changes to information which do

" Containment Isolation Valves." The not bear significantly on the overall acceptance items fall into the following categories:

of the plant's containment isolation provisions, a) Penetration sizes incorrect or not indicated in Table.

b) Divisional power supply incorrectly labeled.

c) Valves incorrectly labeled as inboard or outboard.

d) Direction of flow in line incorrect.

I e) Footnotes no longer referenced in Table should be deleted.

f) Valve position under certain circumstances not expressed consistently throughout Table (e.g.,

" Closed" vs. " fail closed").

(Justification for Category "g" changes under g) Isolation signals of some valves review) listed incorrectly.

Rev. 4, 4/13/84 W3sd2

FOOTNOTES - SECTION 2 AS-BUILT INCONSISTENCIES Ptg2 1 ef.1

,[

NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE' COMMENTS 1

319 2E No.

The reactor vessel was manufactured using Tech Spec Bases references wrong code the proper code as identified in the FSAR.

date for Rx vessel. Change 1974 code to 1971 Editicn thru winter 1982 Addendum.

4 015 IB Yes.

A potential exists for being Drywell pressure trip units / transmitters nonconservative when ambient pressure drops read out in psig units whereas the below 14.7 psig.

transmitters are actually absolute pressure transmitters. Variations in barometric pressure need to be considered in setpoints.

Rev. 4, 4/13/84 Wisd10

1 FOOTNOTES - SECTION 3/4 AS-BUILT INCONSISTENCIES Pag 2 1 of 6 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 5

313 2B No - This is only a clarification and indicates-Tech Spec 4.1.5.d.4 changes " Heaters" to that there is only I heater per plant design.

" normal heater."

SLC tank has only one heater.for maintaining temperature.

14 315 2B No.

It has not been ascertained that the new These setpoint discrepancies need to be values are pertinent to GGNS design.

resolved for RCIC/RHR steam flow isolation, MSIV low VAC isolation. RCIC/

i RHR is max allowed value. Setpoints are i

presently being reviewed by CE and Bechtel.

l 15 015 IB Yes.

Under abnormal or worst case conditions a "Drywell setpoint barometric pressure 016 IB potential exists for being nonconservative.

change issue."

Includes TSPS 15, 16, and 0331 IB 33.

See note 4 section 2.

16 211 2B No.

This is for clarification only and does "Downscale" signal (s) should be "Inap" not effect the actual system operation.

signal (s).

23 201 2B No - The design is correct, the removal of the Table 3.3.2-1 change is to delete note note is an editorial modification.

(f) for secondary containment manual j

isolation valve groups. Mechanical vacuum pumps do not. trip on manual isolation initiation.

j I

24 308 IB Yes - The time required to detect a 25 gpm Table 3.3.2-2.

Changes to valve 4

steamleak would be extended, isolation actuation instrumentation setpoints and allowable values for temperatures. Present values do not agree with design calculations.

i 26 316 2B No.

It has not been ascertained that the new GE wants to change the hi drywell ECCS numbers are supported by accurate calculations initiation setpoint & allowable value to and analysis, and therefore are warranted.

1.73 psig and 1.93 psig respectively.

4 j

30 114 2B No.

The maximum level is based on pool swell Table 3.3.3-2.

Setpoint change to j

considerations. The increase will provide suppression pool level-high HPCS and RCIC consistency with design.

isolation due to instrument reference elevation revisions.

1 Rev. 4, 4/13/84 Wisdll

p ff -

, ' _ ;C :

i i

[3 FOOTNOTES - SECTION 3/4 AS-BUILT INCONSISTENCIES

-'~ # rcg2 2 of 6

~

/,,

f NOTE TSPS #

PRIORITY

' S AFETY SIGNIFICANCE '

COMMENTS

~

-c 1

d

31 022 2A No. However. Ahe current-design would trip a ATWS recire pump trip. Tech Spec has 7

recire pump by following the present action wrong option ~from S!S.

statements.

33 01][ '

2B No. The CGNS design does not include an auto This change deletes note'that sa3s IRM-I bypass of the detector not-full-in interlock in detectur full-in intericck',is. bypassed'on',,

e Range 1.

-Range 1. ' Grand Calf does not b'y pace until run mode.

35 198 1C Yes. In order to ensure operability, 2 chahnels/ Corre.cc Min.. operable channels for Rad..

trip, system may be required to meet single Monitoring.

~

failure criteria.

/

40 202 3B No.

The Tech Spec is more conservative than Table 3.3.7.5-1.

Proposed change required by plant design.

increases the number of required channels of suppression pool temperature monitoring from 6 (1/ sector) to 12 (2/ sector).

49 010 2B No.

Operability of all 5 TIPS can be Plant has 5 TIPS vs. 3 as stated in Tech maintained administrative 1y.

Spec.

Change Tech Spec to say 5.

52 073 2B No.

The insurance protection requirements are Table 3.3.7.9-1.

Update Table of fire 102 2B more restrictive than Tech Spec and are detection instrumentation and zones in 304 2D controlled administrative 1y.

both Tech Spec and FSAR.

s 53 262 IC No.

However, the SBGT exhaust (release point)

Add SGTS exhaust radiation monitor to should be monitored any time the SBGT system has Table 3.3.7.12-1.

the capability to release to the environment.

55 054 1B Yes. With the present MOC, the redundancy of MOC for containment spray.

CTMT spray is below a level appropriate for single failure design.

l l

57 331 2B No.

This setpoint change is on an interlock Table 3.4.3.2-2.

Setpoint change;for that would be used in the steam condensing mode valve interface leakage. E12-F052 to of RHR operation. This is presently not allowed E51-F064. NOTE: This alarm does not at GGNS.

provide interface leakage indication.

4 Rev. 4, 4/13/84 Wisdl2

. FOMNOTES - SECTION 3/4 AS-BUILT INCONSISTENCIES Pega 3 of 6-NOTE-TSPS f

' PRIORITY SAFETY SIGNIFICANCE COMMENTS 59' 001 IB Yes. Tech Spec as written would allow ADS 7 vs 8 valvea.

l operation with an operable equipment configuration which was not considered in accident analysis.

61 309 2A No.

System relief would provide-protection.

LPCS and LPCI high pressure alara 310 2A setpoint revisions. Present setpoints too close to system relief valve settings.

62 332 3B No.

The minimum drawdown level is greater than Condensate storage tank minimum level 170,000 gallons required.

change. Stated volume is correct.

i 63 126 2D No.

This change is administrative in nature, Editorial change to minimum suppression the LCO is still 12'8".

pool level 12'5" vs required 12'8".

66 292 IB Yes.

Based on current leak testing acceptance Air lock minimum pressure change:from.

293 IB criteria, this change is needed to ensure greater than or equal to 60 psig to i

adequate seal pressure for 30 days with no greater than or equal to 90 psig. Revise makeup air supply.

Tech Spec.

i 1

j 67 229 2B No.

Strictly clarification, only the inboard 4.6.1.4.a.2 and col revise:for clarification. MSIV LCS heater only on system has heaters.

inboard system, not on outboard as implied by STS.

I l

74 234 3A No.

Tech Spec and plant design are FSAR revisions to agree with Tech Spec.

)

consistent and correct.

Tables for Sup. Pool Volume and instrumentation. Editorial for l

clarification of suppression pool level

('

instrumentation.

[t l

80 20 2B No.

There is significant margin between the Change leak test requirements from hydro primary containment measured leakage rate and to air.

i j

the allowable leakage rate as specified in Appendix J to 10 CFR 50.

81 021 1C No.

Snubbers can be added to the surveillance Add one RCIC snubber and non-Q snubbers 1

139 1C schedule and controlled administrative 1y.

to snubber table.

1 i

Rev. 4, 4/13/84 u

Wisd13

- A }<

g

~

FOOTNOTES - SECTION 3/4 AS-BUILT INCONSISTENCIES Pags 4 ofl6 NOTE TSPS f PulbRITY SAFETY SIGNIFIC!J'CE COMMENTS g

~

84 203

-2D No. _ yhange is ' editorial only and w'ould not N1P64014_0'should be:NSP64D140.

change the location, function or maintenanc9 s

of the system.

85 131-2G No.

Surveillance of all hose stations can be

~ Table 3.7.6.5-1 requires update for hose

~

controlled administrative 1y.

station's for completeness.

96 (

275 2B No. (Water level of 22' 6 -3/4'.* is adequate to Tech Spec to be resised to comply with s

\\

satisfytthe design basis and would have no as-built water level of'22' 6-3/4 vs 23'.

significant effect on plant safety, 1

3, 1

-y 106.. l G) 1B Yes.

Present requirement could allow, in the MOC for MSIVs on hi flow is acceptable as

-(

worst case, six channels to be inoperable and written, MOC for drain valves,from the

- 1 not require entry into Action Statenient.

mainsteam lines MOC needs to be revised.

g 113 075 5 2B v No.

Current setpoint is overly restrictive in LPCI B & C Pump discharge pressure High that the setpoint is only allowed to vary in Allowable Value. Allowable value changed

[,'

one direction from its nominal value.

for item A.2.f but not for. item B.2.e.

Change needed for B.2.e.

}

'11'4', 213 1C Yes.

The Tech Spec indicates testing of the Minimum operable channels for manual sctuation of each ADS trip system in Tech wrong tunction.

Spec Table 3.3.3-I now reads 1/ valve -

should be 2/syctera'.

l i

116

'078 IB

.Yes.

The RCIC initiation could be defeated if RCIC: minimum operable channels - RCIC i

the Tech Cpec were misinterpretid.

Level'2 Trip changed from 2 to 4 minimum I

operable channels.

121 028 2B No.

Although the tabic does not specifically RCS Interface Tabi'e 3.4.3.2-I does not address each valve, the surveillance addresa each specific valve.

procedures do.

~126 062 2E No.

Unless further evaluation indicates that Moisture Control in Charcoal Bed Heaters the humidistatienlly controlled heaters running

- 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months "cumuistive" operation is not for~10 cumulative hours will not maintain an sufficient to control moisture; Bases acceptable moisture level, no change is needed, incorrect.

l 127 245 2B No.

This is only editorial in nature and Tech Spec requires test of dry pipe headers.

246 2B provides clarification.

Rev. 4, 4/13/84 Wisd14

FOOTNOTES - SECTION 3/4 AS-BUILT INCONSISTENCIES Paga 5 of 6 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS i

128 100 3B_

No.

This change would increase the qualified ESF Electrical Room Maximum Temperature -

life of certain equipment to 40 years.

Bechtel generated 0588 FSAR change from 104*F to 90*F.

129 136 2D No.

Change is to correct typographical errors Valve i Typos on Table 3.8.4.2-1.

only and is purely administrative.

130 137 2B No.

Change is a clarification of intent only.

Channel Functional Test of MOV Thermal Overload. Change Tech Spec to allow test-of bypass circuitry once/92 days; test of entire channel once/IP months. Presently requires LOCA initict'.on once/92 days.

J 132 299 2B No.

The level can be administrative 1y CO storage tank level - 50% level 2

controlled to have 'enough CO to provide 2 specified in Tech Spec is not sufficient 2

discharges and purging of the main generator, for " double shot" coverage of the largest room.

1 133 303 2B No.

Change is for clarification and can be HPCS Action Statement 33.b indicates 2 controlled administrative 1y.

trip systems; only 1 trip system of 4 channels should be indicated.

l 134 308 1B Yes.

Present setpoints may be too high to Temperature setpoints for Room Hi-Temp

)

affect system isolation soon enough, and Delta Temp - Bechtel calculations and Tech Spec setpoints are in disagreement.

i j

135 271 2B No.

The weight of the Halon bottles can be Halon Storage Requirements - 95% weight j

244 2B increased administratively to provide the of present Halon bottles may not provide j

247 2B required 5% concentration.

a 5% concentration 10 minutes after discharge and other design features.

I GGNS Tech Spec requires tests which are not possible for PGCC Halon.

138 035 2C No.

No fuel handling activities are anticipated Refueling platform specs rewritten to be in the near future and thus it is not of in accordance with GGNS design, immediate concern. Proposed changes can be controlled administratively.

1 I

f a

Wisd15 Rev. 4, 4/13/84

.~

FOOTNOTES - SECTION 3/4 AS-BUILT INCONSISTENCIES P ga 6 of 6 NOTE TSPS #

PRIORITY SAFETY SIGNIFICANCE COMMENTS 140 138 2D -

No.

Change is for clarification only.

Radioactive Caseous Waste Sampling - Two Requirements can be effected administrative 1y.

additional sampling points proposed; j

Radweste Building vent exhaust and fuel' handling area vent exhaust.

143 004 2E No.

The SMPU mode switch is required to be There is no mode switch interlock which "off" during refueling. In addition, other _

prevents opening the make-up dump valves actions that would deviate:from admin controls as Bases implies, would also have to occur to open the valves.

i 145 023 2B No.

Administrative controls can be effected to SRV/LO-LO set Tech Spec does not 1

clarify and control equipment requirements, recognize two trip systems of l

instrumentation.

)-

149 173 2D No.

Change would be for clarification only.

LCO misleading in references to equipment Equipment required for operability can be such as ECCS pump room seal coolers.

controlled administrative 1y.

3 i.

150 338 2B No.

Surveillance of all hose stations can be Add Hose Stations 53C and 54A.

controlled administrative 1y.

158 306 IB Yes.

If the specified closing times for the Add several drywell valves to Tech Spec i

RWCU values are not within analytical limits.

Table. Investigate analytical stroke this may result in a release.following an RWCU time discrepancies.

pipe break in excess of previously analyzed releases.

i 1

l i

Rev. 4, 4/13/84 l

Wisdl6

FOOTNOTES - SECTION 5.0 AS-BUILT INCONSISTENCIES Page 1 of 1 COMMENTS NOTE TSPS f PRIORITY SAFETY SIGNIFICANCE 4

281 2E No.

The value listed in Tech Specs is a nominal Best available information shows average fuel enrichment (of initial core loading) value.

to be 1.71933% U-235; 1.70% is the maximum value allowed in GGNS Tech Spec.

1.70% is design nominal value; allowable tolerance is 1.5% of nominal.

6 258 3B No.

The spent fuel pool is restricted from The spent fuel pool can be partially normal use for spent fuel until SSW pump drained if the valves (G41-F032, F033) l capacity is increased.

are opened while the spent fuel pool gate is removed. The valves are neither locked nor do they have electrical interlocks to prevent inadvertent I

operation.

l l

i Rev. 4, 4/13/84

ML20084K826

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