ML20087H507

Tech Spec Review Program Description

ML20087H507
Person / Time
Site:	Grand Gulf
Issue date:	03/31/1984
From:	MISSISSIPPI POWER & LIGHT CO.
To:
Shared Package
ML20087H496	List: AECM-84-0183, Forwards Description of Tech Spec Review Program,Per 840224 Request.Program Estimated to End on 840406.Formal Response Expected by 840409 ML20087H507
References
PROC-840331, NUDOCS 8403210062
Download: ML20087H507 (20)

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J, GRAND GULF NUCLEAR. STATION TECHNICAL' SPECIFICATION REVIEW PROGRAM i

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MISSISSIPPI. POWER & LIGHT COMPANY

' MARCH, 1984

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S' GRAND GULF. NUCLEAR STATION TECHNICAL SPECIFICATION REVIEW PROGRAM

. A.

Introduction i

B.'

Objectivesand'ReviewConcept.

C.

Management' Control Requirements' D.

. Organization:an'd Review Execution E.

. Review Scope and. Criteria

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F.

Review and Closure Process G.

MP&L/NRC Interface-

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Schedule I.

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Introduction-x y

The NRC letter-to Mississippi Power & Light Company (MP&L), dated

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February 24, 1984,. requested a review of the Grand Gulf Nuclear

-Station-(GGNS) Technical' Specifications be provided within 10 days e

of' receipt of that letter..Pased on various discussions held with

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~ your staff the week of February 26, 1984, and as_a result of our meeting with the Commissioners on February 29, 1984, MP&L has undertaken a detailed review of theLstation technical specifications and associated documentation.

The" Technical Specification Review Program was described to the NRC

Staff in a meeting held March 9, 1984. The information provided here as'a program description represents formal documentation of that program,-confirming MP&L's connitments in this matter. Where possible, clarifications and additional detail have been included 2

to address ~certain questions raised by the NRC Staff.

The.MP&L approach to'NRC concerns regarding the plant's technical specifications is to conduct a thorough review of the specifications.according to established criteria. All previously known, apparent technical specification discrepancies and the results of the Review Prog' ram will be properly categorized and dispositioned according to approved procedures. The overall goal is to assure accurate and adequate specifications.

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It should be noted that the NRC letter to MP&L, referenced above,

-also requested MP&L to verify the consistency of the as-built plant configuration with the Final Safety Analysis Report (FSAR) and supporting documents. The primary focus of the Review Program is to verify the accuracy of the technical specifications.

Nevertheless, the FSAR, as it relates _to'the technical specifications,'will also be reviewed. The resulting discrepancies will en documented and dispositioned according to the program's procedures.

B.

Og ectives and Review Concept The primary objectives of the Review Program are as follows-1.

To verify consistency of the plant's technical specifications with the as-built plant configuration, the FSAR, and the NRC Staff's Safety Evaluation Report (SER) on GGNS (NUREG-0831).

2.

To' identify, submit, and support issuance of necessary changes

.to the technical specifications in a timely manner.

1 F

3.

Lastly,-to provide the necessary assurance that the GGNS technical specifications are accurate and adequate.

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?At the. core of-the review effort is the goal to establish assurance H,-

7that'the technical: specifications are consistent ~with (1) the e as-built plant configuration and (2) the current FSAR and SER as

amended through Supplement No. 4.

To accomplish this, the review (criterit will.be used to' evaluateL the specifications against as-built. documentation; where appropriate, field walk-downs will be conducted.

LThis-review concept uses.the current technical specifications

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(through Operating License ~ Amendment No.-12) as-the basis for

, review and compares that basis against the above noted documents.

-To provide. assurance that technical specification related

. commitments-contained inlvarious licensing documents are considered

'in the review,=a computerized commitment. tracking system will be 3:

L utilized. >Use of.this system is discussed further in Section.E.

~Inadditiontothereviewofthe-technicalspecificationsagainst

.the above described documents, a comparison of the GGNS Technical Speciiications to the BWR-6 Standard Technical Specifications (STS)

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will be performed. This comparison will> assure consistency with the STS, except-for those areas.where the' Grand Gulf Technical Specifications deviate, but are considered appropriate due to plant unique' design features. : This review will be conducted primarily by General-Electric and Bechtel Power Corporation. These companies were selected _to-perform this review because of their direct involvement in the plant's design and construction.

1 Additional detail on:the review scope,. method, and criteria is

. presented ~in Sections E and F.

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C.

Management Control Requirements 1Several measures have been incorporated into the Review Program to

_ ensure a quality result. Some of the more significant wanagement controls ore as follows:

1.

'All' key Review Program positions-will be filled by MP&L' employees.

'2.

The Review Program Project Manager reports directly to the l

Senior'Vice President --Nuclear.

3.

The Revie6 Program activities.will be conducted and controlled in accordance with a definitive, approved procedure.

4.

The review of each technical specification section and disposition of discrepancies identified will be thoroughly documented.

5.

The Review Program is fully auditable, and Quality Assurance will' conduct audits of the Program's implementation and effectiveness.

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g; :Significant management' attention has been focused on this very critical activity. All resources necessary to implement and

execute this program will.be made available.

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To provide an independent assessment of the program's effectiveness, MP&L management has retained Impell Corporation to-r view the: program, inspect. work activities in progress, and provide a-report on the' adequacy of Lae program.

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-D.

Organization and Review Execution

!1.

Project Management

'The Review Program's; organization is'shown in Figure D-1.

Reporting directly.to the Senior Vice: President - Nuclear is the Project Manager.

In this capacity the Project Manager is direct.ly responsible for the program's implementation and effective execution. By reporting to the highest level of

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. management in the Company's nuclear organization, the Project Manager exercises the authority of senior management in

' acquiring >the necessary resources to accomplish the program's objectives and to coordinate the activities of the major resources within the nuclear organization; namely, Nuclear Plant Engineering -(NPE), Nuclear Services, the Plant Staff, and.the Plant and-Corporate-Safety Review Committees. This alignmentfalso provides optimum communication with the

-Company's senior. management in regard to the program's progress-and results.

Also reporting to the Senior Vice President - Nuclear, working

.with the Project Manager, is an executive. level Steering y-Committee. This committee. consists of the managers of all major' nuclear organizations within MP&L, the Advisor to the

'Vice-President - Nuclear, and senior management representatives of General' Electric Company (GE).and Bechtel Power Corporation (BPC). MP&L's Vice President - Nuclear is chairman of this committee'and is responsible for assisting in program development, project oversight, and resolution of -

'programatic problems, as necessary.

The Project Manager is' also assisted by an Assistant Project Manager, a Scheduler,'a Quality Engineer, and a Records Control Manager. These staff positions function primarily to

-relieve the Project Manager of some of-the program's

. administrative burden and also to provide project quality

. control support.

3 2.

Review Organizations At the core of the program's organization are four principal groups..Three groups conduct detailed reviews of specific areas, and the fourth group evaluates the detailed review results, assigns priorities, and coordinates appropriate corrective actions.

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P review organization is; configured to use the technical

' Consistent with the-program's~ review concept (Section B), the m w l' specifications asfthe; base' document =toLwhich other licensir.g-J r

. andLdesign' documents"will be compared.' This concept will b'

s insure a thorough review of.the current' technical

.J specifications.

.~In' keeping with' tl is ' approach, the technical 4

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. specifications have been divided into three major _ areas.

. These'three areas,are defined'as:

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TeAhEicd1 specifications'primarilyassociat'dwith e

. equipment or' systems provided by the-Nuclear Steam System c Supplier- (NSSS),cr by the Balance.of Plant (BOP)

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~ Radiologicalzeffluent technical specifications, and-3.

Technical specifirations related_to administrative. areas

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'or controls.

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A' lead review. organization is asoigned=to each of the above listed areas. Each review organization is supervised by an MP&L.' manager. All of these managers are-located at the plant-site.

. 2.1 NSSS/ BOP Review Group The NSSS/ BOP Review Group is the most complex entity in the project organization due to this group's interface with the

'NSSS and BOP reviewing organizations. This group is

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- supervised by the NSSS/ BOP Manager, who is an MP&L employee.

Reporting to the NSSS/ BOP Manager are the NSSS Manager and the

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- BOP Manager, both of whom are MP&L employees. These two

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managers coordinate the activities of the NSSS review organization and the BOP review organization. These three managers'are' located on site.

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'Also reporting to'the NSSS/B0P Manager is an Onsite Review

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-Team (ORT). This team,is' composed, as a~ minimum, of the

_ following:

(a) A GE c. BPC engineer.

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<(b). An MP&L NPE' engineer.

f (c) An MP&L-Senior Reactor Operator.

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The initial review for the NSSS/B0P Review Group will be condu'cted by GE and BPC as the lead review organizations

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(LRO), each according to a defined Division of Resp _onsibility, (DOR) for the technical specifications. This review will in e

part be_ conducted at the LRO's home office, with some field

- verification conducted at-the plant site. The total number of s

personnel involved in the NSSS/ BOP review, including all managers, is approximately 115_ personnel, the majority.of whom are knowledgeable ~ engineers.

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The result of the lead organization's review is a technical specification review package.

(Criteria and scope of review is discussed in Section E.) This package is reviewed by the respective NSSS or B0P Manager and forwarded to the NSSS/ BOP Group Manager who then assigns the package to the Onsite Review Team (ORT) to concur with the findings and recommended actions.

In areas where GE and BPC scopes interface, the ORT is specifically tasked to resolve any conflicts as appropriate., Items not immediately resolvable are escalated directly and without delay to the attention of the Project Manager. With ORT concurrence on the technical specification package, the NSSS/B0P Manager reviews and forwards the package to the Review, Prioritization and Direction Group (RPD) for further processing. As noted earlier, the RPD group will evaluate the. review results and assign an appropriate priority

'to any potential technical specification change identified.

The.RPD group would then refer the item to the appropriate section in the Nuclear Production Department for resolution.

In suaimary, prior to the RPD group receiving a given specification's package, the specification will have been reviewed by a responsible engineer in the GE or BPC organization,.the NSSS or B0P Manager, the ORT, and the NSSS/ BOP Manager. A knowledgeable MP&L engineer will be in permanent residence at each of the subject home offices, monitoring progress and assisting in resolution activities, as necessary. This position will be filled continuously for at least the initial month of review and, thereafter, on an "an-needed" basis.

2.2 RETS and Administrative Review Groups The Radiological Effluent Technical Specification (RETS)

Review Group and Administrative Review Group have a j.

substantially smaller scope than that of the NSSS/ BOP Review Group. Both groups a're supervised by MP&L employees, specifically selected for their background and experience in their respective areas. The RETS review effort is directed by

-Z' the MP&L Manager of Radiological and Environmental Services.

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'The Administrative Review Group is directed by a knowledgeable m

_' engineer from the MP&L Quality Assurance organization.

Both

. groups, upon generation of a specification review package,

.b forward their findings to the RPD Group for further processing.

(See Section F for discussion of the role of the RPD Group.)

-2.3.

Review,'Prioritization and Direction Group

.The RPD Manager is the Plant Staff Technical Superintendent.

N-This group consists of representatives from Nuclear Plant Engineering (NPE), Plant Staff, Nuclear Safety & Compliance x'

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(Nuclear. Services), and selected consulting engineers. The A

role of this group is discussed in more detail in Section F.

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Review Scope and Criteria i

1.

Review'Scopo u

1.1 Specific Objectives in Technical Specification Sections

As discussed.'in Section B, the review objectives are to review the technica1' specifications and verify

. consistency with principal design and licensing Ldocumentation. The Review Program's. objectives relative to the specific sections of the technical specifications are discussed below:

1 1(a) Safety Limits, Verified to be complete and in.

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accordance with-the. plant's design analyses.

(b) ' Limiting Conditions for Operation (LCO) - Determined to accurately reflect the necessary functional

capability or performance level of equipment

' required-for. safe operation, based on design

, analyses.

(c) Action Statements.- Verified to be consistent with design analyses.

(d) ' Surveillance Requirements - Test' types and

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,frequences reviewed to ensure that they adequately address design requirements and

. allow conservative operation during testing.

~(f) Bases Verified to be correct and in accordance with design analyses.

(g) Design Features - Verified to be accurately described.

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(h) Administrative Controls - Verified to be consistent with relevant licensing commitments.

4 Each lead review organization,. based on the tie'chnical specification division of responsibility (DOR), will approach their respective specifications with the objectives as discussed above.

In many cases, an assigned specification may-impact the iajority of the' above listed objectives. Some overlap of review is

. expected and'is considered to enhance the quality of review.

1.2 Lead Review Organization, Primary Scope of Review The. lead review organizations have the following primary scope of review:

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GE/BPC 'These organizations, reporting to their respective MP&L NSSS or BOP Managers, are responsible for the bulk of the review effort.

Their review scope < consists primarily of technical specifications Sections 2.0 and 3/4.1.through 10, as definedtin the approved DOR. Their review will also

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~ cover all Definitions, Bases or Design Features

' associated with an assigned specification.

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lRETS Review Group - This group,'as the title implies, will review primarily. technical specifications Sections 3/4.11 and 3/4'.12,. effluent and L

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-radiological manitoring, respectively. Other appropriate' areas will be assigned by the DOR. The L

RETS group will also be responsible for associated

-Definitions, Bases and Design Features, as applicable.

' Administrative Review Group - The scope of this. group's-review consists of those sections not already

specifically' covered, namely:

'J Section 1.0 - Definitions

,Section 5.0 - Design Features

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. Section 6.0 - Administrative Controls 1.3 Licensing Documentation Basis For the purposes of this review, the following revision or amendment status represents the basis for all reviews.

f Operating License - Amendment 12 (2/21/84)

.. Final Safety Analysis Report - Amendment 57 (11/83)

Final Environmental Report * - Amendment 8 (12/81)

Safety Evaluation Report (NUREG-0831) -'As revised

.and supplemented through Supplement No. 4 (5/83) i* Applicable to RETS' review only.

1.4 ' Review Concept-As. discussed in Sections.A and B, the approach of this review utilizes the technical specifications as the central document which is compared with other documentation and information. Under this approach, the--

. technical specifications are compared to the FSAR, SER, FER (RETS review only), and the as-built plant configuration. The review against the as-built plant-includes, where'necessary, a field walkdown by knowledgeable engineers. The processing of review

'results is discussed in Section F.

In-addition'to the review' efforts described above, all

-e outstanding items.previously identified in several MP&I.

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and NRC sponsored reviews will be placed on a master

'punchlist:and processed through the RPD Group. This effort will provide a re-evaluation of these items in a

. documented and consistent manner based on standard criteria. As with all items delivered to the RPD Group,

= an assessment of priority-will be made and appropriste corrective action directed and tracked.

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.As a matter of completeness, steps will be taken to

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-identify and properly resolve open commitments in the FSAR and other licensing documents that relate to the technical spec; fications. To accomplish this task the

.already existing Licensing Commitment Tracking System g

-(LCTS), will be utilized. The LCTS was implemented.by MP&L in 1983. The LCTS data base was~ generated from a licensing review of 'the FSAR, SEI; and supplements, operating license, and all formal correspondence between

-MP&L_and NRC. The system is maintained by the MP&L Nuclear Services. Organization-in accordance with approved administrative procedures.

Apparent'or possible changes to the technical specil'ications generated from this review activity will

. be added to a master punchlist'of possible technical specification changes and provided to the RPD Group for further processing;(see Section F).

2.:

Prioritization Criteria Once.an item identified by a review group is determined by the RPD Group to warrant a change to the technical specifications, it is the responsibility of the RPD Group to assign an appropriate priority to'the, item...The priority structure consists of three tiers, generally in the order of the evaluated safety, significance. These are described as follows:

Priority 1:

Problems requiring resolution-in the short term including items which would necessitate a plant shutdown or prohibit startup. Technical specifications not conservative with' respect to the FSAR or SER are. included in this priority.

All items included here require, as a minimum,

'NRC concurrence-to proceed above 5%. power.

lg Priority 2:

Problems / enhancements requiring resolution.

All items included here are considered to have minimum or no safety significance where

- operations above 5% power is clearly justified from a "significant safety hazard consideration" aspect.. Items in this priority 1

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are, therefore, considered to be required, if at all, on a long term schedule.

Priority'3:

' Items classified in this priority are genera 11r problem areas that were identified by an

. organization outside of MP&L in which case the organization suggests, requests, or requires a change to the technical specifications. The item's-presence in this group reflects a determination by MP&L that a change to the technical specifications is not justified and, AD10

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.therefore, not recommended by MP&L. Such items are. assigned a priority _ classification primarily for documentation purposes. Priority 3 items may be generic in' nature, but in any

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case, have. insufficient safety significance to warrant.a higher priority.

The specific priority definitions with which the RPD Group is making this determination are presented in Table E-1.

F.

Review and Closure Process 1.

Overall Process and Procedural Controls An overall presentation of the review and closure process is

.provided.in Figure F-1.

This figure, in block diagram format, begins with the initial review by the primary review groups as

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identified in Figure D-1, and presents the process through the ultimate closure of the review packages.

In some cases, closure includes the MP&L receipt, review, and acceptance of NRC granted changes to the technical specifications.

This overall process is implemented principally by an administrative procedure, especially developed for the Review Program. Existing administrative procedures will be used to the maximum extent practical where the Review Program interfaces with ongoing Nuclear Production Department activities. Control of FSAR changes and the processing of proposed changes to the' operating license are examples of such instances.

2.

Technical Specification Review and Review of Previously

' Identified Items The group review activities are discussed in Section D.

In general, the specifications have been divided into three

. general areas and a~ review' group assigned to each area.

Specifications are assigned to each group according to an approved division of responsibility. The results of the group review consists of a documentation package on each assigned specification'with any potential problems identified. This package, is then forwarded to the RPD Group for further

. processing. -The RPD Group will review the package, regardless of' the absence or-presence of discrepancies identified by the primary review group.

f To take proper advantage of other reviews currently in progress or completed since.MP&L's Surveillance Procedure Task Force effort, all known outstanding items have been entered on the master punchlist for review and processing. These items originated from reviews by MP&L and NRC and.will be subjected to the same criteria that is applied to any item identified in

'the current Review Program.

Items determined to involve a

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, potential technical specification change will be assigned an 1.

,. appropriate priority by the RPD Group and processed along with those items identified in the Review Program.

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Review,.Prioritization, and Direction Group Activities The primary functions of the RPD Group.are toi (1) evaluate

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. findings forwarded to it, (2). assign-priority to potential 4

, changes to the sp'ecifications,'(3) direct nece'ssary corrective

-action, and (4) concur with findings or' adequacy of completed or proposed. corrective actions.

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Upon evaluation of a documentation package'(or item identified from outside source), the RPD Group has the follov ng general options.to-select:

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' Concur that no discrepancies exist which require additional actions; recommend closure to Project Manager.

'(2) Find that a potential. specification change is warranted, L

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-_ assign priority, and transmit. package to Nuclear Safety &

Compliance for development of justification and significant hazards consideration'(SHC) evaluation.

(3) ' Determine that' additional engineering or. licensing o

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. support is required. This' assistance is provided by s

normal organizations within MP&L's. Nuclear Production

. Depa rtment'.

EExamples of-such assistance are additional safety or

, engineering analyses,- FSAR-changes, procedure revisions,.

etc. All such actions are documented and tracked to closure.

Overall, all resolution of problems / concerns are reviewed.by the.RPD Group. Even the case where a technical specification change.is requested and eventually granted by the NRC, the

. operating license amendment is reviewed by the RPD Group to ensure that the original concern was properly addressed. This

. activity is required for closure of the specification's review 4

package, It should be noted that it is not MP&L's intention to maintain

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' 7 the Review Program's project team activated during operations above 5% power. For this reason, specification changes assigned a long-term priority will.be processed by normal s

means, utilizing currently. existing procedures for changes to

.the' technical specifications. ' Adequate. closure documentation

'will be established in all cases.

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4.

Processing of Potential Technical Specification Changes

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Once a potential specification change is identified, the development of a~" Proposed Change to the Operating License" lAD12 m,

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~(PCOL) package is initiated. The initial. step here is to generate proper." marked up" pages of. the affected current

' technical specification (s) and to develop adequate justification for the proposed change.. Justification development includes an evaluation of the Significant' Hazard Consideration (SHC), in accordance with 10CFR 50.92. Except

- for the development of preliminary working 'information, for use in'. initial discussions with the NRC, this! process of PCOL package development is addressed entirely in existing

< administrative procedures.

As shown'in Figure F-1, with the development of the proposed change's' ^ justification, MP&L will request an informal discus'sion and tentative agreement, ifcpossible, with'NRC

-Staff representatives'on the proposed change. This step is

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primarily to agree on the significance of the item, the assignment' of proper priority, and adequacy of justification.

If MP&L and the NRC concur that the change requires processing prior to exceeding 5% power, then the PCOL will be processed and formally submitted.without delay. The PCOL review pre, cess includes formal safety committee review (Plant and Corporate).

If the subject change is agreed upon to have a longer term pricrity, it will be processed in a timely manner, according to an NRC/MP&L mutually agreeable schedule.

5.

Closure-As discussed in Sections F.1 and F.3 above, closure documentation packages are developed for all specification sections. The package will-include _a record of corrective actions directed and accepted by:the RPD Group. For corrective actions incomplete at 'the time of package closure, a record of the tracking mechanism accepeted by the RPD Group will be included. All closure packages will be reviewed by

the Project Manager.

G.

MP&L/NRC Interface LAs" discussed with the NRC Staff in the meeting held March 9, 1984, 5MP&L has taken immediate steps to provide optimum support of the

NRC Staff review associated with this program. For the duration of the Review Program, MP&L will staff a local Bethesda, Maryland office with two full-time MP&L employees from the Nuclear Services 2 Department. This staff, representing MP&L's safety and licensing organizations, will be supported,.as necessary, by engineering and operations' personnel to respond to NRC questions and concerns.

MP&L proposes daily; working meetings with the NRC Project Manager

<and principal staff reviewers to support expeditious problem tresolution and to maintain effective communications on the status of MP&L'and NRC efforts. These meetings should also provide a

. convenient means for bringing high priority items to the NRC's immediate attention. Weekly meetings are proposed to provide

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. proper.NRC/MP&L' communications at a management level and also to

' 4 efficiently utilire' specific expertise, as required, to resolve J ~

- problematic items.

.As indicated in Figure.F-1, MP&L intends to-provide the NRC preliminary information regarding potential. specification changes.

.This is theJresponsibility of MP&L's Bethesda office. By this

- means -it.is MP&L's objective to involve the NRC, as soon as

.possible, in the decision making process,-as it relates to the

-evaluation'of safety significance and priority assignment.

-MP&L will provide, as a management tool, the master punchlist of

potential specification changes on an informal; basis and on a

. frequency acceptable to the NRC Project ~ Manager. Other

~information., such as anticipated section review schedules, will be provided to-the NRC, as requested, to support their review.

H.

Schedule-W The Review Program essentially began the week ended March 2, 1984,-

with the finalization of review scope and criteria, commencement of the lead organization review, and the prioritization of items tuown to date. The program ~has been estimated to lequire a total of five weeks. At the end~of this period, all high priority items will have.been discussed with the NRC and the. majority of these will have been formally' submitted as proposed-technical specification-changes. By.that time the NRC and MP&L will have also discussed

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all other possible specification changes identified in the review (or previously known) and will have agreed that a longer term submittal' schedule ~is appropriate. Figure H-1 presents the

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program's schedule, including principal milestones.

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MP&L will~ respond.to the NRC letter on this matter (Eisenhut to t'

Richard, dated February 24,-1984) no later than the conclusion of the program's fifth week, i.e., April 9, 1984.

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' Summary

.The program described here is considered to be a thorough, quality,

and. safety conscious review, fully responsive to recent.NRC

. concerns surrounding the Grand Gulf technical specifications.

' Substantial resources have been dedicated to support this program l

and accomplish its goals.

'To realize the program objectives,.MP&L requests the cooperation.

and' support of-the NRC. Staff. The program and project organization have been developed.with the-goal of achieving agreement between MP&L and the NRC at= critical points in the' effort. The program

plan and overview were presented.to the NRC Staff on March 9,1984.

-Initial efforts to agree on priority assignments began the week of

March 12,L1984. Steps such as these and, in general, a close working relationship and dedication of resources are required to

ensure a timely and efficient execution of the program.

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Overall, providing the dedication and efficient use of resources and effective communication'between the NRC and MP&L, this Review f

Program will meet _ schedule objectives and yield the necessary assurance that the Grand Gulf;technica1' specifications are adequate

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and accurate, that is, consistent with the plant's design basis and

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sufficie'nt to support safe operation.

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9 TABLE E-1 TECH SPEC PROBLEM SHEET PRIORITY DEFINITIONS 1.

Problems Needing Resolution - Short Term A.

Safety Significant Items which would require plant shutdown, prohibit plant startup, or require other plant actions to reestablish safe operating conditions.

• B.

Existing Tech Spec is non-conservative with respect to FSAR or supporting documents (e.g., approved design specs, SER, etc.).

MP&L requires NRC concurrence and resolution prior to next criticality.

• C.

Existing Tech Spec is non-conservative with respect to FSAR or supporting documents (e.g., approved design specs, SER, etc.).

MP&L requires NRC concurrence and resolution prior to exceeding 5% Thermal Power.

2.

Pro'oieas/ Enhancements Needing Resolution - Long Term A.

Existing condition could result in unnecessary challenges to eufety systems or plant transients or is required to enhance plant safety.

B.

Errors or confusing items in Technical Specifications which will not result in non-conservative operation with a reasonable dependence on administrative controls / plant knowledge /cperational practices; Licensing commitments which require a Tech Spec change; items determined by MP&L to be important.

C.

Could restrict power level or mode changes.

D.

Typographical Errors and Enhancements / Concerns which do not fall into a higher priority.

E.

Problems with, or enhancements to Tech Spec sections other than 3/4 (e.g., Administrative Controls, Bases, etc.).

F.

Over-conservative Tech Specs for which changes are cost-j ustified.

• The factors used to distinguish priorities IB and IC are operational mode requirements (generally Mode 2 requirements are associated with priority IB and Mode I with priority IC), fission product inventory considerations (generally priority IB do not involve dealing with high fission product inventories while

. priority IC which is associated with higher power levela may involve dealing with high fission product inventories), and relative safety significance of systems.

2

7 -

TABLE E-1 (Continued)

G.

Design. Changes which require Tech-Spec changes.

.H.

Pending design / analysis (e.g., Maximum Extended Operating

~ Domain, Exxon Fuel, Single Recire Loop Operation, etc.).

I.

Others.

3.

Tech Spec change not justified.

A.'

Item is-generic an'd not included in'STS.

B.

Others.

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,t, FIGURE F-1: Rsviiw cnd Closure Procssa p----.----___.______-__q l

I NSSS/ BOP RETS ADMINISTRATIVE I

g GROUP-GROUP GROUP REVIEW REVIEW REVIEW l

1 l

u 1r o

I _ PERFORM SECTION REVIEWS

___.____1 L

DISCREPANCIES l

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l

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NOT NEEDED TECH SPEC CHANGE NEEDED q

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l FOR RESOLUTION l JUSTIFICATION 1

1 0

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• Proposed Change to the Operating License

M O WEEK I

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BECHTEL PRIORITY l - NEEDED PRIOR TO EXCEEDING 5% POWER.

l PRIORITY 2 - NEEDED BUT NOT PRIOR TO EXCEEDING 5% POWER.

l PRIORITY 3 - POSSIBLv NEEDED FOR CLARITY.

OTHER WEEK 1 - COMPLETE REVIEW AND PRIORITIZATION OF ALL EXISTING KNOWN ITEMS.

RECEIVE RESULTS OF NRC REVIEWS.

WEEK 2 - COMPLETE REVIEW AND PRIORITIZATION OF NRC ITEMS.

WEEK 3 - REVIEW COMPLETE FOR NSSS SCOPE.

WEEK 4 - REVIEW AND RESOLUTIONS COMPLETE FOR B0P SCOPE.

WEEK 5 - RESOLUTION COMPLETE FOR NSSS SCOPE.

ALL PRIORITY l ITEMS IDENTIFIED AND DISCUSSED WITH NRC.

PRIORITY 2 AND 3 ITEMS AGREED UPON WITH NRC.

FIGURE H-1: Review Program Schedule

,