ML20126D392
Text
{{#Wiki_filter:, ,~
- 39 i
IMPELL THIRD PARTY REVIEW 0F t GGNS TECHNICAL SPECIFICATION REVIEW CROGRAM NRC STAFF PRESENTATION APRIL 4, 1984 l l JOHN C. GUIBERT--IMPELL PROJECT MANAGER l t f eg61,gs850205 BELLB4-459 PDR k
IMPELL THIRD PARTY PEVIEW NRC PRESENTATION APRIL 4, 1984 PURPOSE AND SCOPE INDEPENDENCE OF IMPELL PROJECT TEAM OUALIFICATIONS OF IMPELL PROJECT PERSONNEL SPECIFIC IMPELL WORK ACTIVITIES GENERAL PROGRAMMATIC OBSERVATIONS PROGRAMMATIC RECOMMENDATIONS SPECIFIC OBSERVATIONS (PRELIMINARY) STATUS OF ACTIVITIES PRELIMINARY CONCLUSIONS i l m
IMPELL THIRD PARTY REVIEW PURPOSE AND SCOPE CHARTER: TO PROVIDE MPal SENIOR MANAGEMENT AN INDEPENDENT ASSESSMENT OF THE EFFECTIVENESS OF THE GGNS TECHNICAL REVIEW PROGRAM, INCLUDING BOTH THE REVIEW PROCESS AND THE REVIEW RESULTS, METHODOLOGIES UTILIZED: PROCEDURAL REVIEWS PROCESS REVIEWS PROCESS OBSERVATIONS PERSONNEL INTERVIEWS TSRP DOCUMENTATION REVIEWS AS-BUILT DOCUMENTATION REVIEWS INDEPENDENT REVIEW 0F SELECTED DESIGN FEATURES SPECIFIC ACTIVITIES r2
.= IMPELL THIRD PAPTY REVIEW INDEPENDENCE OF IMPELL PROJECT TEAM .gvfd M TEAM INPEPENDENCE REPORTING DIRECTLY TO SENIOR VICE-PRESIDENT NUCLEAR INDEPENDENTLY DETERMINED, DEFINED, AND IMPLEMENTED THE WORK ACTIVITIES NECESSARY TO ACCOMPLISH CHARTER TOTAL AND FREE ACCESS TO THE PERSONNEL, RECORDS, AND MEETINGS OF MP8L AND OTHER PARTICIPATING ORGANIZATIONS INDEPENDENTLY DETERMINED IMPELL STAFFING NEEDS AND SELECTION OF IMPELL PROJECT PERSONNEL NO PRIOR GGNS PROJECT INVOLVEMENT THIRD PARTY PROVIDED RECOMMENDATIONS TO MP&L SENIOR 4 MANAGEMENT ON POTENTIAL PROGRAMMf7'" CONCERNS AS THEY WERE IDENTIFIED l
IMPELL THIRD PARTY REVIEW PERSONNEL QUALIFICAIT0NS be 10[ THE IMPELL PROJECT TEAM IS COMPRISED OF EXPERIENCED PEPSONNEL WITHACOMPOSITEEXPERIENCEBASEWHICHINCLJ1DESALLFACETSOF NUCLEAR POWER PLANT DESIGN, CONSTRUCTION, OERATIONS, AfD 4 ~ 4 REGULATION. } i BWR EXPERIENCED j REGULATORY EXPERIENCED UTILITY / PLANT EXPERIENCED ARCHITECT / ENGINEER EXPERIENCED AVERAGE YEARS OF UUCLEAR EXPERIENCE > 12 YEARS i ] 4 s i
IMPELL THIRD PARTY REVIEW SPECIFIC IMPELL WORK ACTIVITIES GGNS TECHNICAL SPECIFICATION REVIEW PROGRAM (TSRP) TSRP PROCEDURE AND PROCESS REVIEWS PPOCEDURE ADEQUACY PROCESS IMPLEMENTATION IMPELL INDEPENDENT REVIEW 0F SELECTED DESIGN FEATURES GGNS/BWR-6 UNIQUE FEATURES 0THER FEATURES AS-BUILT P K " DES. .NPUT" TO TSRP AS-BUILT DOCUMENTATION REVIEWS DOCUMENTATION REVIEWS (TSRP PACKAGES) COMPLETENESS DFPTH OF REVIEW INFLUENCE OF OPEPATIONS PERSONNEL OVER-RELIANCE ON STS PERSONNEL QUALIFICATIONS MP8L QUALITY ASSURANCE MP8L TSRP PRIORITIZATION PROCESS l -- - - - - -- - - - ---- - J
IMPELL THIRD PARTY REVIEW INDEPENDENT RE'!IEW OF SELECTED GGNS DESIN FEATURES LIST OF FEATURES REVIEWED FEATURE RATIONALE i DRYWELL PURGE SYSTEM UNICUE TO BWR-6/MK III DESIGM HYDR 0GEP IGNITION SYSTEM UNIQUE TO BWR-6/MK III DESIGN 4 CONTROL RODS (ROD CONTROL AND UNIOUE TO PWR-6 DESIGN INFORMATION SYSTEM) HORIZONTAL FUEL TRANSFER UNIQUE TO GGNS DESIGN SYSTEM (FOR BWRs) CRANE TRAVEL - SPENT FUEL UNICUE TO BWR-6/MK III AND AND UPPER CONTAINMENT SPECIFIC GGNS DESIGN FUEL STORAGE POOLS DETAILS CONTAINMENT SPRAY 10 DINE REF0 VAL CREDIT NOT C0PMON TO BWR-5s STANDBY GAS-TREATMENT SYSTEM INFLUENCED BY MK III CONTAINMEFT AMD SPECIFIC GGNS DESIGN DETAILS i s
IMPELL THIRD PARTY REVIEW INDEPENDENT REVIEW 0F SELECTED GGNS DESIGN FEATURES LIST OF FEATURES REVIEWED FEATURE RATIONALE CONTAINMENT AND DRYWELL INFLUENCED BY MK III CONTAINf!ENT HYDROGEN RECOMBINER SYSTEM. AND SPECIFIC GGNS DESIGN DETAILS SECONDARY CONTAINMENT INTEGRITY NOT UNICUE, BUT INFLUENCED BY SPECIFIC GGFS DESIGN DETAILS FIRE SUPPRESSION SYSTEM STRONGLY INFLUENCED BY SPECIFIC j GGNS DESIGN DETAILS i D.C. SOURCES INFLUENCED BY SPECIFIC GGNS DESIGN DETAILS i i 1 m.
IMPELL THIRD PARTY REVIEW GENERAL PROGRAMMATIC OBSERVATIONS PERSONNEL QUALIFICATIONS WERE COMMENSURATE WITH SPECIFIC 4 AREAS OF. RESPONSIBILITY PARTICIPATION AND INFLUENCE OF PLANT PERSONNEL, INCLUDING LICENSED OPERATIONS PERSONNEL,.WAS APPROPRIATE MPEL QUALITY ASSURANCE WAS ACTIVELY INVOLVED AND PEPFORMED THOROUGH REVIEWS DEPTH OF REVIEW BY LR0s WAS GENERALLY VERY GOOD: LINEAGE-BACK TO FSAR SUPPORTING DOCUMENTS AND OTHER RELEVANT DESIGN DOCUMENTS LEVEL 0F DOCUMENTATION WAS GENERALLY VERY GOOD-THE THRESH 0LD FOR IDENTIFICATION OF " PROBLEM SHEETS" BY LR0s i WAS LOW 4 7&'
- POTENTIAL OVER-RELIANCE ON STANDAPD TECHNICAL SPECIFICATIONS DISCREPANCIES OF MINOR SIGNIFICANCE HAVE BEEN IDENTIFIED RESOURCE DEDICATION REFLECTED MANAGEMENT COMMITMENT TO A THOROUGH, OUALITY JOB STRONG MPEL MANAGEMENT INVOLVEMENT AND ATTENTION PROGRAMMATIC ENHANCEMENT ACTIVITIES WERE IMPLEMENTED AS WORK PROGRESSED COOPERATION AND OPENNESS OF ALL PARTICIPANTS
) (Q M aj A pa &. rv< J 3 Amma%'b'$f
i'. IMPELL THIRD PARTY PEVIEW PROGRAMMATIC RECOMMENDATIONS /MP8L RESPONSE, MP8L QUALITY ASSURANCE SHOULD PERFORM AUDITS OF WORK PROCESS FOR WORK PERFORMED OFF-SITE BY LR0s, i (RECOMMENDATION ACCEPTED: AUDITS HAVE BEEN CONDUCTED) MP8L SHOULD CONSIDER PERFORMING A DISCRETE REVIEW 0F GGNS/BWR-6 FK III. UNIQUE DESIGt! FEATURES TO FURTHER CONFIRM THE RESULTS OF THE TSRP. (RECOMMENDATION ACCEPTED: PROGRAM HAS BEEP INITIATED) MPF.L MANAGEMENT SHOULD REINFORCE ITS COMMITMENT TO A CUALITY JOB, EVEN AT THE EXPENSE OF THE TSRP SCHEDULE, PARTICULAR EMPHASIS ON THE RPD REVIEWS, (RECOMMENDATION ACCEPTED: ORIGINAL RPD SCHEDULE SI.IPPED A WEEK) MP8L SHOULD ENSURE THAT THERE IS APPROPRIATE FEEDBACK FROM RPD TO LR0s 0F DISPOSITION OF THEIP INPUT, WITH SUFFICIENT OPPORTUNITY FOR FEEDBACK, (RECOMMENDATION ACCEPTED AND IMPLEMENTED) l l
l IMPELL THIRD PARTY REVIEW TSRP SPECIFIC OBSERVATIONS (PRELIMINARY) INDEPENDENT REVIEW 0F SELECTED GGNS DESIGN FEATURES FEATURES HAVE BEEN ADDRESSED IN GGNS T.S. CONSISTENCY OF DESIGN PARAMETERS IN DOCUMENTS LEVEL OF DETAIL IN GGNS T.S. INFLUENCED BY STS POTENTIAL OVERRELIANCE ON STS FOR LEVEL OF DETAIL TSRP PRIORITIZATION PP,0 CESS l PRIORITIZATION CRITERIA WERE APPROPRIATE PRIORITIZATION CRITERIA WERE APPLIED UNIFORMLY l APPLICATION OF CRITERIA APPEARS TO BE CONSERVATIVE j EXTENT OF EVALUATION / DELIBERATION IS VERY GOOD 1 OVERRELIANCE ON STS INVESTIGATED THROUGH A NUMBER OF IMPELL ACTIVITIES RESULTS INCONCLUSIVE MINIMAL, IF ANY, ACTUAL SAFETY SIGNIFICANCE l l AS-BUILT REVIEW l " DESIGN INPUT" TO TSRP WAS ADEQUATE' " DESIGN INPUT" WAS UTILZIED APPROPRIATELY BY LP0s PROCUREMENT SPECIFICATION / FIELD VERIFICATION CONFIRMS l i " DESIGN INPUT" ADE0VACY j i l 1 I
IPPELL THiF3 PARTY REVIEV TSFP SPECIFIC CESERVATIONS (PRELIMINARY) (CONTI?iUED) l C0F?tETENESS" 0F GGNS TS (INCLUSICN OF UNICUE FEATURES) 1 IMPE,,S,it.,Derth....,t s nEVl a. Cr n, d ..t t - P o,.e e.i a,l l \\, S,,.,,. L - e: t 4 t r: 0F GGNS UNIQUE DESIGN FEATUFES INDICATES THAT THEY FAVE EEEN ADECUATELY ADDP.ESSED 15 GC!!S TS Iv :LL ::L m.m_S s h"s : Ii 'n'0m.n ::
- n. m.:a s 10.cU.s..r:
r ..e-r u.- CCNFIRM TS COVEPAGE 0.: GGNS U?'!CSE FEATURES (FPEL Fi.S l INITIATED SUCH A FECGRAM) l "CCPPLETENESS" CF GGNS TS (LEVEL OF DETAIL) 1 LEVEL OF DETAIL OF GGNS TS IS ECUIVALENT TO Cr : 6 t r. THAN CURRENT NEC/ INDUSTRY FEACTICE \\ l 1 i i I l i i i i I 1 l 1 i i 1 i i
IMPELL THIRD PARTY REVIEW STATUS OF IMPELL ACTIVITIES 4 TSPP PROCEDURAL AND PROCESS REVIEWS ARE ESSENTIALLY COMPLETE-i OTHER TSRP ACTIVITIES WILL BE COMPLETED BY APRIL 5, 1984 3 EXECUTIVE
SUMMARY
BY APRIL 6, 1984 FINAL REPORT BY APRIL 13, 1984 L, i I i I s i
IPPELL THIRD PARTY REVIEW CONCLUSIONS (PRELIMINARY) BASED UPON ITS REVIEW 0F THE GGNS TSRP AND ASSUMING TH'AT THE TSRP IS CARRIED OUT TO FRUITATION AS PRESENTLY CONSTRUCTED, IMPELL CONCLUDES: THAT THE TSRP PROCESS AND RESULTS PROVIDE ADE0UATE ASSURANCE THAT THE GGNS T.S., AS REVISED TO REFLECT THE RESULTS OF THIS PROGRAM, ACCURATELY REFLECT THE GGNS DESIGN ANALYSES AND THE AS-BUILT PLANT, WHILE THE POSSIBILITY REMAINS THAT UNDISCOVERED T.S. DISCREPANCIES MAY STILL EXIST, IT IS l UNLIKELY THAT SUCH DISCREPANCIES WOULD BE OF SUBSTANTIAL SAFETY SIGNIFICANCE, THAT THE TSRP PROCESS AND RESULTS PROVIDE ADE00 ATE ASSURANCE THAT THE GGNS T.S., AS REVISED TO REFLECT THE RESULTS OF THIS PROGRAM, APPROPRIATELY REFLECT THE UNIOUE DESIGN FEATURES OF GGNS. IMPELL BELIEVES THAT IT WOULD BE PRUDENT TO CONFIRM FURTHER THE T.S. COVERAGE OF GGNS UNIQUE FEATURES: MP8L HAS INITIATED SUCH A CONFIRMATORY PROGRAF, THAT THE TSRP PROCESS AND RESULTS PROVIDE ADECUATE ASSURANCE THAT THE GGNS T.S., AS REVISED TO REFLECT THE RESULTS OF THIS PROGRAM, MEET OR EXCEED CURRENT NRC/ INDUSTRY STANDARDS FOR THE LEVEL OF DETAIL TO BE INCLUDED IN T.S. THAT THE GGNS T.S., AS REVISED TO REFLECT THE RESULTS OF THIS PROGRAM, WILL BE ADEQUATE TO ENSURE SAFE OPERATIOP 0F THE PLANT, m
s 70 GRAND GULF NUCLEAR STATION TECHNICAL SPECIFICATIONS REVIEW PROGRAM APRIL 4, 1534 AGENDA I, INTRODUCTION AND PURPOSE J. B. RICHARD II, SIGNIFICANT PROGRAM FEATURES J. B. RICHARD
- III, PROGRt.M FINDINGS AND SIGNIFICANCE R. JACKSON (BECHTEL)
G. Si1ERWOOD (GE) C L. TYRONE J. C. ROBERTS 1 ( IV. CAUSES OF TECHNICAL SPECIFICATION J. P. McGAUGHY INCONSISTENCIES V, TECHNICAL SPECIFICATION CHANGE CONTROL L. F. DALE PROGRAM VI. FSAR/ PLANT CONSISTENCY T. H. CLONINGER VII. CUALITY ASSURANCE AUDIT T. E. REAVES VIII. THIRD PARTY REVIEW J. GUIBERT (IMPELL) IX,
SUMMARY
J. B RICHARD J. E. CROSS X, OPTIONAL DISCUSSION OF TECHNICAL C. L. TYRONE SPECIFICATIONS REVIEW PROGRAM LESS SIGNIFICANT FINDINGS,
} {C( 6 /n'ntUp C I. PURPOSE A. TECHNICAL SPECIFICATIONS 1. TO DEMONSTRATE THAT TECHNICAL SPECIFICATION REVIEW i PROGRAM HAS BEEN A F0PMAL, CONTROLLED, AND WELL-DOCUMENTED PROCESS THAT WILL YIELD ACCURATE AND ADEQUATE TECHNICAL SPECIFICATIONS 2. TO DISCUSS AND CHARACTERIZE SIGNIFICANCE OF FINDINGS FROM THE TECHNICAL SPECIFICATION REVIEW PROGRAM 3. TO DISCUSS THE CAUSES OF TECHNICAL SPECIFICATION INACCURACIES 4. TO CONFIRM THAT: 0 TECHNICAL SPECIFICATIONS ARE ACCURATE AND ADEQUATE FOR SAFE OPERATION OF GGNS O TECHNICAL SPECIFICATION INACCURACIES IDENTIFIED i DUPING PROGRAM DO NOT CONSTITUTE SIGNIFICANT HAZARDS CONSIDERATIONS. O TECHNICAL SPECIFICATION I.NACCURACIES RESULTED FROM INFORMAL DEVELOPMENT PROCESS B. FINAL-SAFETY ANALYSIS REPORT 1. TO DEMONSTRATE THAT FSAR DEVELOPMENT WAS CONTROLLED BY A FOPMAL PROGRAM AS DIFFERENTIATED FROM AN IFFORMAL DEVELOPMENT PROCESS UTILIZED FOR TECHNICAL SPECIFICATI0'NS 2. TO CONFIRM THAT FSAR AND SUPPORTING DOCUMENTATION CONFORM TO THE PLANT .. ~ w y-ww .-,i n --c.-, ,y + ~..
i' II. SIGNIFICANT PROGRAM FEATURES s 1 A. MANAGEMENT CONTROL AND ATTENTION B. PIORITIZATION CRITERIA i. C, QUALITY ASSURANCE D. THIRD PARTY REVIEW E. OVERVIEW 0F 0RGANIZATIONAL STRUCTURE i J b 4 I 1 i i - 1 t i-i l 1 i i 4 i l 5 ,,-.._r-_.,,. .,-,.-y, ,..-.-my .,.r..~. --,,,.r.., .,.r-,.,,y.,
4 II. A. MANAGEMENT CONTROL AMD ATTENTION ) e MP&L DEVELOPED PROGRAM AND INTEGRATED RESOURCES OF BECHTEL AND GE e MP8L PERSONNEL FILLED ALL KEY POSITIONS e PROJECT MANAGER PEPORTS DIRECTLY TO SR VICE PRESIDENT - j NUCLEAR l e OPERATING STAFF INTIMATELY INVOLVED INCLUDING SROS e NECESSARY RESOURCES MADE AVAILABLE TO IMPLEMENT A HIGH-QUALITY PROGRAM j e WORK DONE TO DEFINITIVE, APPROVED PROCEDURES e CONSISTENT CRITERIA USED TO EVALUATE SIGNIFICANCE OF FINDING o PROGRAM RESULTS AND FINDINGS WELL DOCUMENTED o CUALITY ASSURANCE INVOLVED VIA REVIEW AND AUDIT e STEERING COMMITTEE CONTINUOUSLY MONITORS PROGRAM AND SUPPORTS PROJECT MANAGER AS NECESSARY 4 e CONTINUOUS EVALUATION AND EXPANSION OF WORK SCOPE AS i DETERMINED TO BE PRUDENT e SAFETY REVIEW COMMITTEE REVIEWING PROGRAM AND IMPLEMENTATION e SR. VICE PRESIDENT - NUCLEAR MONITORS PROGRAM ON DAILY BASIS e PPESIDENT MONITORS PROGPAM THROUGH WEEKLY 4 MANAGEMENT / EXECUTIVE STATUS AND PROGRESS MEETINGS ( i .. -. ~. - -. --.---.-, -
l j II B. PPIORITIZATION CRITERIA ( PRIORITY 1: PROBLEMS NEEDING RESOLUTION - SHORT TERM PRIORITY 2: PROBLEMS / ENHANCEMENTS NEEDING RESOLUTION - LONG TERM PRIORITY 3: TECHNICAL SPECIFICATION CHANGE NOT JUSTTFIED (RESPONSE REQUIRED) 4 1 t I i i
II, C. QUALITY ASSURANCE e DIRECTLY INVOLVED SINCE PROGRAM INCEPTION e ASSISTED IN ESTABLISHING PROGRAM QUALITY REQUIREMENTS e OUALITY ENGINEER ASSIGNED To PROJECT MANAGER'S STAFF e QUALITY ASSURANCE SECTION DEVELOPED AUDIT PLAN e QUALITY ASSURANCE SECTION INVOLVEMENT DURING WORK: REVIEW AND APPROVAL OF PROCEDURES THREE CEPTIFIED AUDITORS ASSIGNED FULL-TIME REAL-TIME AUDITS OF PROCESS ON-SITE AUDITS OF PROC'ESS AT BECHTEL AND GE HOME OFFICES EVALUATION OF ADEQUACY AND EFFECTIVENESS OF REVIEW FUNCTIONS NUCLEAR SITE QA MANAGER AVAILABLE ON CONTINUOUS BASIS TO ADDRESS QUALITY CONCERNS 0 QUALITY ASSURANCE ABLE TO OBSERVE PROCESS, IDENTIFY CONCERNS, AND OBTAIN RESOLUTION IN TIMELY MANNER ) \\ i
II, D. THIRD PAPTY REVIEW 0 TO PROVIDE INDEPENDENT ASSESSMENT OF PROGRAM EFFECTIVENESS i INCLUDING REVIEW PROCESS AND REVIEW RESULTS O INDEPENDENCE REPORT DIPECTLY TO SR VICE PRESIDENT - NUCLEAR INDEPENDENT DEFINITION AND IMPLEMENTATION OF WORK SCOPE AND ACTIVITIES TOTAL AND FREE ACCESS TO PERSONNEL, RECORDS, AND MEETINGS OF MP8L AND PARTICIPATING OPGANIZATIONS INDEPENDENT DETERMINATION AND SELECTION OF STAFF 0 THIRD PARTY PROVIDED RECOMMENDATIONS TO SP VICE PPESIDENT - NUCLEAR ON POTENTIAL PROGRAMMATIC CONCERNS AS IDENTIFIED 0 REPORTS PRELIMINARY REPORT OF FINDINGS AND CONCLUSIONS DUE APPIL 6, 1984 FINAL REPORT DUE APPIL 11, 1984
i s SR.VICE PRP.51 DENT 3RICLEAR = STEERINC ggg i , ASSURANCE 1 MANAGER PRO.fECT MANAGER ,s'- aw" ' ASFT. PROJECT MANACPR TECH SPEC DIRET AtffMDRITT RECORDS CONTROL-MANAGER CODEDINATI(NI AMD EIFEDITING l lqtfALITY l 3 SCllEDULER ENGINEER I I 1 1 l i 1 i REVIEW. g NSSS/anP RETS I ADDITNTSTRATIVE PRIORITIZATIud,4 MANAGER 9tABIACER MAllACEg AND DIRECTION } WSITE MANAGER REVIEN l TEAll I I I i i i IISSS ROP ~~ ~~ CE NAIIACER .MAIIACRit REDITEL a PROJECT ORCANIEATION ....F. ee........................................<....................................... DenRMAL ORGANIZATICII l PSRC 'l 1 ~ NUCLEAR Pl.AIIT IIUG. EAR PLANT STAFF j i ENrINEER198C SERVICES / i / SRC J / b FIGURE D-1: Review Organization i
O 4 4 III. PROGRAM FINDINGS AND THEIR SIGNIFICANCE A. BECHTEL / M B. GENERAL ELECTRIC C. MPat
'BECHTEL REVIEW 0F TECHNICAL SPECIFICATIONS l l 1. BASIS l GGNS TECH SPECS AS MARKED BY MP&L WITH PUNCHLIST ITEMS STANDARD TECH SPECS FOR BWR6 AS PROVIDED BY MP&L V i, FSAR THROUGH AMENDMENT 57 SER THROUGH SUPPLEMENT 4,. AS-BUILT DRAWINGS AS PROVIDED BY MP&L D0R ESTABLISHED BY SECTION-II. REVIEW SCOPE REVIEW GGNS TECH SPEC AGAINST STANDARD TECH SPEC FOR CONSISTENCY AND COMPLETENESS REVIEW 6GNS, TECH SPEC AGAINST FSAR AND SER FOR CONSISTENCY REVIEW 6GNS TECH SPEC AGAINST AS-BUILT PLANT FOR CORRECTESS J11. REVIEW PROCESS .~ PER MPSL PROCEDURE 4 i SECTION REVIEWED BY A RESPONSIBLE ENGINEER l SECTION INDEPENDENTLY CHECKED DOCUENTATION PEVIEWED FOR COMPLETENESS, CORRECTNESS, AND PROCEDlfRE C0 rLIANCE BY SUPERVISOR INDEPEICENT TECHNICAL REVIEW PERFORMED BY REVIEW l CDPRITTEE i DOCl#ENTATION REVIEED FOR COMPLETENESS, CORRECTNESS, AND PROCEDURE COPPLIANCE BY PROJECT COORDINATOR i SURVEILLANCES FOR PROCEDURE COMPLIANCE PERFORMED BY l P90KCT IWALITY ENGIEER OF ALL PACKAGES SUBSEQUENT., l 70 ISSE
- '..BEDICATD ESOURCES e
o 6
i BECHTEL REVIEW 0F TECHNICAL SPECIFICATIONS (CONTINUED) IV, DOCUMENTATION STANDARD DOCUMENTATION FORMS FROM THE MP8L PROCEDURE ARE USED INTERNAL REVIEW SIGNOFF SHEET.USED REQUESTS FOR AS-BUILT WALKDOWNS IS DOCUMENTED STANDARD TRANSMITTAL USED TO ISSUE REVIEW PACKAGES PCOL SAFETY EVALUATION PREPARED IF TECH SPEC CHANGE IS REQUIRED MARKED-UP FSAR PAGES INCLUDED IN REVIEW PACKAGE AS NEEDED TECH SPEC SECTION REVIEWED INCLUDED IN PACKAGE PUNCHLIST PROBLEM SHEET REVIEWED INCLUDED IN PACKAGE IF APPLICABLE ' V. CONCLUSIONS ONCE CHANGES WE HAVE IDENTIFIED HAVE BEEN DISPOSITIONED .THEN TS WILL BE CONSISTENT WITH FSAR, STS, SER, AND AS-BUILT PLANT O e =q
b c =_ v.==. i_ => c_ r~i :. I c..c m/ I ~a = r. __ w c=:ng c_m = i_ r_u..y t ra s.e==c t e t e > g ne s eCC.=.= _ k.:. o a.e e.s v p.cru..e:r s Ue:n v li GRAND GULF NUCLEAR STATION TECHNICAL S?ECIFICATICF a s..".f c.n :.{ e..=a.s ur-~ v p w i STD TECHNICAL SPECI.:ICATIONS.0? EWR 5 G.:. ". A. GU'..:,",Ur.i ,'..:. s s n* s In.a.c.e +..:. s.u.. C,Lrc..:I,e,.v. rig n.vry a :i,- c l l G'AN7 Gt'f ; sNUr.t n'. .c t e.s c.r.: t.u..:.a.r.ic.a. ei,,..:r.w w,t 4. eve e M L Ini. u AS-EUILI PEGV!DED EY ??EL EEVIEW SCOPE GRAND GULF NUCLEA? STATION TECHNICAL SPECl?iCATION VS 4 .=.c e : n. S::. I AS-EUILTS EWR/6-STS FROCESS 4 GE PROCEDURE FOR ENGINEERING FEVIEW OF SAFETY SYSTEF.S 4 ? ONE OVER CNE REVIEW I i ,i OVER 65 GE ENGINEERS INCLUDED
i f RESULTS OF GENERAL ELECTRIC REVIEW 0F GRAND GULF TECHNICAL SPECIFICATIONS i REVIEWED TS AGAINST FSAR, SER, DESIGN, a "AS-BUILT" REVIEW DONE BY GE ENGINEERS AT SITE AND IN SAN JOSE JOB DONE TO GE'S NUCLEAR PRACTICES EMPHASIS ON SAFETY SIGNIFICANCE I l MANY " NITS" a CONSERVATISMS NO MAJOR DESIGN ISSUES OR ERRORS ) i -l WHEN IDENTIFIED CHANGES HAVE BEEN IMPLEMENTED, GE BELIEVES l GRAND GULF TECHNICAL SPECIFICATIONS WILi. BE CONSISTENT WITH THE SER, FSAR, DESIGN AND AS-BUILT 4 ) GE BELIEVES THAT GRAND GULF TECHNICAL SPECIFICATIONS PROVIDE l BASIS FOR SAFE OPERATION AT 57. NOW, AND FULL POWER WHEN l PRIORITY l'S ARE IMPLEt'ENTED l 4 l 1 f i l + i
s [ PROGRAM FINDINGS AND THEIR SIGNIFICANCE ./ TECH SPEC PROBLEM SHEETS (TSPS) PRIORITY METHOD AND CRITERIA DISCUSSION OF TSPS RESULTS DISCUSSION OF CONSISTENCY MATRIX p 8 s
TECH SPEC PROBLEM SHEETS (TSPS) EFFECTIVE METHOD OF DOCUMENTING TECH SPEC REVIEW FINDINGS 240 TSPS DOCUf'ENTED RESULTS FROM PREVIOUS REVIEWS 116 TSPS DOCUMENTED RESULTS FROM THIS REVIEW LARGE NUMBER OF TSPS PROBLEM SHEETS RESULTS FROM: THOROUGH REVIEW - LOW THRESH 0LD FOR INCLUDING ITEMS-EMPHASIS ON DOCUMEflTING RESULTS < NOT ALL TSPS REOUIRE TECH SPEC CHANGE MUST LOOK BEYOND NUMBERS AT TSPS DETAILS TO UNDERSTAND IMPORTANCE OF FINDINGS PRIORITY FLAGS RELATIVE IMPORTANCE OF TSPS 9 4
METHOD OF ESTABLISHING TSPS PRIORITIES TSPS PRIORITIES DERIVE FROM APPLYIt!G: OBJECTIVE ATTRIBUTES OF PRIORITY DEFINITIONS SUBJECTIVE ENGINEERING JUDGEMENT PRIORITIES RESULT FROM DISCUSSION AND CONCURRENCE AMONG RPD' MEMBERS 't i I I l i
~_ 1 4 TECH SPEC PROBLEM SHEET (TSPS) PRIORITY DEFINITIONS i 1 PRIORITY I PROBLEMS NEEDING RESOLUTION - SHORT TERM j A. SAFETY SIGNIFICANT ITEM WHICH WOULD REQUIRE PLANT SHUTDOWN, I j PROHIBIT PLANT STARTUP, OR REQUIRE OTHER PLANT ACTIONS T0 l REESTABLISH SAFE OPERATING CONDITIONS, i B. EXISTING TECH SPEC IS NONCONSERVATIVE WITH RESPECT TO FSAR OR j j SUPPORTING DOCUMENTS (E.G., APPROVED DESIGN SPECS, SER, ETC.), i i MPal REQUIRES NRC CONCURPENCE AND/0R RESOLUTION PRIOR TO NEXT j CRITICALITY, i j C. EXISTING TECH SPEC IS NONCONSERVATIVE WITH RESPECT TO FSAR OR ] SUPPORTING DOCUMENTS (E.G., APPROVED DESIGN SPECS, SER, ETC.), i MPal RE0 VIRES NRC CONCURRENCE AND/0R RESOLUTION PRIOR TO l EXCEEDING 5 PERCENT THERMAL POWER, 1 l 1 i i i l i t l t l 1 i i i l i i I
TECH SPEC PROBLEM SHEET (TSPS) PRIORITY DEFINITIONS (CONT'D) PRIORITY 2 PROBLEMS / ENHANCEMENTS NEEDING. RESOLUTION - MID TO LONG TERM A. EXISTING CONDITION COULD RESULT IN UNNECESSARY CHALLENGES TO SAFETY SYSTEMS OR PLANT TRANSIENTS OR IS REQUIRED TO ENHANCE PLANT SAFETY, B, ERRORS OP CONFUSING ITEMS IN TECHNICAL SPECIFICATIONS WHICH WILL NOT RESULT IN NONCONSERVATIVE OPERATION WITH A REASONABLE DEPENDENCE ON ADFINISTRATIVE CON 7ROLS/ PLANT KNOWLEDGE /0PERATIONAL PRACTICES: LICENSING COMMITMENTS WHICH RECU!RE A TECH SPEC CHANGE: ITEMS DETERMINED BY MPEL TO BE IMPORTANT, C, COULD RESTRICT POWER LEVEL, UNNECESSARILY REQUIRE C0flTROLLED PLANT SHUTDOWN, UNNECESSARILY RESTRICT MODE CHANGES (E.G., 3.0.4 EXEMPTIONS JUSTIFIED), OR PESTRICT REFUELING OPERATIONS, D. TYP0 GRAPHICAL ERPORS AND ENHANCEMENTS / CONCERNS WHICH DO NOT FALL INTO A HIGH PRIORITY E. PROBLEMS WITH, OR ENHANCEMENTS TO TECH SPEC SECTIONS OTHER THAN 3/4 (E G., ADMINISTRATIVE CONTROLS, BASES, ETC,) F, OVERCONSERVATIVE TECH SPECS FOR WHICH CHANGES ARE COST-JUST!FIED G. PENDING DESIGN CHANGES (ENHANCEMENTS) WHICH REQUIRE TECH SPEC CHANGES H. PENDING DESIGN / ANALYSIS (E G., MAXIMUM EXTENDED OPERATING DOMAIN, EXXON FUEL, SINGLE RECIRC LOOP OPERATION, ETC ) 1. OTHERS
4 1 TECH SPEC PROBLEM SHEET (TSPS) PRIORITY DEFINITIONS (CONT'D) PPIORITY 3 TECH SPEC CHANGE NOT JUSTIFIED BUT DOCUMENTED RESPONSE IS PE0VIPED A, ENGINEERING /0PERATIONAL JUSTIFICATION EXISTS FOR NOT CHANGING THE TECH SPEC, DOES NOT INVOLVE DEVIATION FROM STS. I B, OTHER ITEMS FOR WHICH THE TECll SPECS DO NOT REQUIRE CHANGE. MAY REQUIRE CHANGES TO OTHER DOCUMENTS (E,G., FSAR), 1 i l l 1 i i j
TSPS DISCUSSION BEFORE 3/1/84 MP8L/NRR 11AD IDENTIFIED 240 TSPS WITH 16 PRIORITY 1 ITEMS: FROM SURVEILLANCE REVIEW FROM NRR PROOF AND REVIEWS FROM MPal GGTS REVIEWS FROM REGION 11 INSPECTION ITEMS n116 TSPS GENERATED DURING THIS REVIEW WITH 7 PRIORITY 1 -l ITEMS C S' ALL PRIORITY 1 ITEMS SUBMITTED OR TO BE SUBMITTED AS PCOL'S PRIORITY I ITEMS INCLUDE !TEMS FROM THIS REVIEW AND UNRESOLVED ITEMS FROM PREVIOUS REVIEWS.
\\ ) 1 j l TECHNICAL SPECIFICATION PROBLEM SHEET BREARDOWN i P90GLEst SMEETS cNEATED FROM TECM. SPEC. REVIEW EFFORT I i J l i lA: REQUIRES S/D; PREVENTS S/U i 120_ II6 REQUIRES ACTION TO EST. gas SAFETY IB: NEED FOR RESTART i Ic: NEED TO EXCEED 5% POWER 84_ so AND BEFORE BUILDING FISSION ( PRODUCT INVENTORY [ j mg 7, ) Munata 2: MID/LONG TERM RESOLUTION 3: No T.S. CHANGE REQUIRED smarts sa 3 i M. I 29 24_ I2 i ~ ( 4 3 i i i caAmo PRI. IA PRI. IB PRI. IC PRt. 2 FRI. 3 total OF Peos. StrTS. CENERATED { emon TEcm. l sPac. Revisu ~ i 1 4
TOTAL TSPS 356 TSPS REQUIRING PHYSICAL 0 PLANT CHANGE TSPS ADDING NEw TECH SPEC 1 TSPS ADDING To EXISTING 17 TECH SPECS TSPS DELETING EXISTING 0 TECH SPECS ) i i i l i i I 4 i
CONSISTENCY MATRIX TSPS EVALUATED AND INCLUDED IN CONSISTENCY MATRIX ACCORDING TO CERTAIN GROUND RULES MATRIX SHOWS DIFFERENCES BETWEEN GGTS AND: FSAR SER STS AS-BUILT PLANT 0THER AREAS OF TECHNICAL SPECIFICATIONS OTHER (ADDITIONAL CATEGORY FOR COMPLETENESS) FROM MATRIX WE DETERMINED THAT: 53 DIFFERENCES BETWEEN GGTS AND FSAR " 12 DIFFERENCES BETWEEN GGTS AND SER 48 DIFFERENCES BETWEEN GGTS AND AS-BUILT PLANT ' DIFFERENCES ALSO IDENTIFIED BETWEEN GGTS AND STS, OTHER AREAS OF GGTS, AND OTHER
RESOLUTION OF REVIEW COMMENTS e FOUR PHASES OF DISPOSITION / REVIEW RPD COMMITTEE RPD MANAGER QUALITY ENGINEER PROJECT MANAGER 0 THREE CONFIRMATORY ACTIONS JOINT PARTICIPATION OF LR0 REVIEWERS LR0 VERIFICATION OF DOCUMENTATION FINAL VERIFICATION BY LR0 AFTER CLOSURE H19sD2
STS UTit.!!ATics con REV!EWs AND JUSTIFICATIO'i e STS USED As A GUIDE e FSAR, SER, As-Eu1LT DcCu.v.ENTs ALsc UsED e ENGINEERING /l!CENs!NG bases OVERRIDE SIS CCNsIDERATIONs H19D3
'.* : v e. ~,.n c y c: t ~ =.. ; ; v i. s. ; z. T:r.u c. a e. r. in.n r.en. LEO REVIEW FSAP, SER, As-Eu!LT, CESIG'! MiALYSIS S.:. C. c,. e v..- :~e uo. > /.v.:. :..r :. r : e s. ..s.,, r e,fl +.. MP&L CEVELO;ED Gut 0ELINEs 1 I l i 1 I I I 1 l l l I e i 1 1 1
METHODOLOGY USED TO DETERMINE COPRECT MODE APPLICABILITY LR0 PEVIEW FSAR, SER, DESIGN ANALYSIS SRO BACKGROUND / EXPERIENCE RPD PEVIEW MP&L DEVELOPED GUIDELINES
I e IV, CAUSES OF TECHNICAL SPECIFICATION INCONSISTENCIES A, EVOLUTION OF GGNS TECHNICAL SPECIFICATIONS B, CONTRIBUTING FACTORS TO TECHICAL SPECIFICATION INCONSISTENCIES t e
EVOLUTION OF GGNS TECFNICAL SPEC'IFICATIONS o 1977-78: BWR 6 STS REVIEW GROUP PREPARED BWR6 VERSION OF STS o 1979: NRC GUIDANCE TO MARK-UP LATEST NRC STS o 1979: MP&L PLANT OPERATING STAFF DEVELOPED INITIAL GGNS SPECIFIC TECH SPECS BASED ON LATEST NRC STS (BWR 3/4, MARK 1) o 1979-80: MP&L RECEIVED MULTIPLE FORMAL AND INFORMAL 3 VERSIONS OF NRC STS l} S/:d W f Y BWR 3/4 MARK I BWR S MARK 11 o DECEMBER 1980: MP&L FORMALLY SUBMITTED INITIAL GGNS TECH SPECS FORMALLY (NOT REVIEWED BY NRC) o MAY 1981: NRC PROVIDED MP&L DRAFT GGNS TECH SPECS (ESSENTIALLY BWR S) TO MARK UP AND RESUBMIT JUNE 1981 I l o JANUARY 1982: INFORMALLY RECEIVED PROOF AND REVIEW COPYa i o JUNE 1982: GGNS OL ISSUED o 1982-83: IDENTIFICATION OF DISCREPANCIES .___J
CONTRIBUTING FACTORS TO TECl-NICAL SPECIFICATION INCONSISTENCIES o FIRST OF KIND PRODUCT LINE AND NO STS o INFORMAL NRC/MP&L REVIEW PROCESS o LACK OF PROCEDURAL CONTROL UNDER QA PROGRAM VERSUS DESIGN CONTROL AND FSAR CONTROL o INSUFFICIENT MANAGEMENT ATTENTION o INSUFFICIENT REVIEW BY PLANT OPERATING STAFF, BECHTEL, AND GE FOLLOWING RECEIPT OF PROOF AND REVIEW COPY o NO FINAL REVIEW UNTIL APPENDIX A RECEIVED WITH OL e
i V. TECHNICAL SPECIFICATION CHANGE CONTROL PROGRAM A. GOVERNING PROCEDURES i e NSAP 2,6 - OPERATING LICENSE AMENDMENT e NSAP 2,23 - OPERATING LICENSE MANUAL e NSAP 9.5 - CONTROL OF THE TECHNICAL SPECIFICATIONS B. PROGRAM CHARACTERISTICS e RESPONSIBILITIES CLEARLY ESTABLISHED e SEQUENCE OF ACTIVITIES DEFINED e REQUIRED DOCUMENTATION AND USE OF FORM DOCUMENTS e MASTER TRACKING LOG ON ALL TECHNICAL SPECIFICATION CHANGE PACKAGES e ADDRESSES CHANGES ORIGINATING FROM INSIDE AND OUTSIDE MP&L e FEEDBACK TO ORIGINATING ORGANIZATIONS e KNOWLEDGEABLE ENGINEERS COORDINATE REVIEW OF TS CHANGE REQUESTS AND DEVELOPMENT OF AMENDMENT APPLICATIONS e COORDINATION WITH APPROPRIATE ORGANIZATION DURING REVIEW AND DEVELOPMENT PROCESS e SPECIFIES FORM AND CONTENT FOR AMENDMENT APPLICATIONS PSRC AND SRC REVIEW AND APPROVAL PRIOR TO SUBMITTAL e l e REVIEW OF AS-ISSUED AMENDMENTS FOR ACCURACY e CONTROLLED DISTRIBUTION TO MANUAL HOLDERS WITH RETURN RECEIPT
m a_n.A d-w-A5 a-4 A -2 6: o4-. .a s - as .-s 4 .e+. e m e-e ,_,v---m., 1 VI. FSAR CONSISTENCY A. DESIGN CONTROL B. FSAR CONTROL C. DESIGN /FSAR/AS-BUILT INTERFACE D. RESULTS OF TECHNICAL SPECIFICATIONS REVIEW PROGRAM E. CONCLUSIONS ) i l d 9 4 1 1 I 1 1 J l j i i 1 \\ I ,,._....___,_,,,_.,...-...-_.-_-_._.-_m_ . _ - ~..,.,...-., _.,,..,..._,, -._.. -, _, -,.,,
i i. VI,A, DESIGN CONTROL l 4 PRE - 0/L - SUBSTANTIAL BECHTEL/GE EXPERIENCE LEVEL LONG TERM GE EXPERIENCE ON BWR'S 1 BECHTEL DESIGN PROJECT TEAM - NUMEROUS PERSONS > 5 YEARS CONTINUOUSLY ON GGNS j COMPREHENSIVE PROJECT PROCEDURES LINKING TIMELY DESIGN - l CONSTRUCT - DEVIATION - AS-BUILT FEEDBACK CONTINUOUS AND EFFECTIVE QUALITY ASSURANCE EFFECTIVENESS SHOWN IN PERFORMANCE MEASUREMENT RESULTS, SUCH AS I/E BULLETIN 79-14 REVIEW j NUREG 0588 SITE AUDIT I NRC MANDATED INDEPENDENT DESIGN REVIEW EFFECTIVE STARTUP AND PRE-OP PROGRAM i ) POST-0/L DESIGN / CONFIGURATION CONTROL PATTERNED AFTER BECHTEL 1 { OTHER OPERATING PLANT EXPERIENCE l DESIGN - CONSTRUCT - OPERABILITY CLOSELY LINKED i j t _ -.,,, ~,
I f VI. B. FSAR CONTROL e FSAR PREPARED TO CONTENT LEVEL CONSISTENT WITH 10CFR50.34 e PRE-0/L-DESIGN /AS-BUILT /FSAR CONSISTENCY ASSURED BY DETAILED FORMAL PROCEDURE DIRECTLY LINKED WITH 4 CONSTRUCTION / DESIGN /AS-BUILT CONTROL PROGRAM REVIEW OF ALL DESIGN CHANGES FOR FSAR IMPACT CONTROLS TO TRACK FSAR CHANGES ONCE IDENTIFIED PROCEDURES TO ENSURE TECHNICAL CORPECTNESS OF FSAR l CHANGES VS.' DESIGN /AS-BUILT i e POST-0/L-DESIGN /AS-BUILT /FSAR CONSISTENCY ASSURED BY DETAILED FORMAL PROGRAM DIRECTLY LINKED TO GGNS CONFIGURATION MANAGEMENT SYSTEM REVIEW OF CHANGES FOR SAFETY AND FSAR-IMPACT IN ACCORDANCE WITH 10CFR50.59 CONTROLS TO TRACK INITIATION, REVIEW AND SUBMITTAL WITH ALL PROPOSED FSAR CHANGES FOR TECHNICAL CORPECTNESS AND AS-BUILT IMPACT. i e QUALITY ASSUPANCE PROGRAM HAS AND WILL CONTINUE TO APPLY TO FSAR CONTROL l i 4 } ) I e i
. ~. -......_.. _ _.. _ _ _. _. _ E r i VI, C, DESIGN /FSAR/ PLANT INTERFACE 4 l 4 DESIGN I NRR NRR CONTRACTORS REGION 11 IDVP g lDVP OA i ~ V i FSAR PLANT l 0 l REGION 11 IDVP 1 ERT I WALKDOWNS j PRE 0P AND STARTUP TESTING i i 5 ) l I I t 4 l-i l l-4 ) 1 i i ' ~ _,., - _.. - ~ - - - -. - -
t j VI. D. RESULTS OF TECHNICAL SPECIFICATIONS REVIEW PROGRAM SUBSTANTIAL REVIEW 0F FSAR ACCOMPLISHED AS PART OF TECHNICAL i SPECIFICATIONS REVIEW PROGRAM (TSRP) ,L INCONSISTENCIES WILL BE DISPOSITIONED PER APPPOVED PROCEDURES l INCONSISTENCIES EVALUATED AND DETERMINED NOT T0: i IMPACT CONCLUSIONS OF THE SAFETY ANALYSES, AS REPORTED IN THE FSAR REQUIRE DESIGN CHANGES CHANGES THE SER CONCLUSIONS, IN MP8L'S JUDGEMENT l I l i
VI. E, CONCLUSIONS e EXPERIENCED AE AND NSSS VENDOR TEAM UTILIZED e STANDARD, PROCEDURALIZED APPROACH TO DESIGN AND CONFIGURATION CONTROL, P.0TH PRE AND POST OL e THOROUGH 0A INVOLVEMENT e INDEPENDENT ASSESSMENTS HAVE CONFIPMED CONTROL OF DESIGN /FSAR/ PLANT INTERFACES e CURRENT TSRP REPRESENTS SUBSTANTIAL SAMPLING OF FSAR CONSISTENCY EVALUATION OF THESE RFSULTS SUPPORT." Pal'S POSITION THAT THE FSAR AND SUPPORTING DOCUMENTS ADEQUATELY CONFORM To THE PLANT '. i S 9
e VII. QUALITY ASSURANCE AUDIT AUDIT DEPTH - OVER 20% OF TOTAL PACKAGES NSSS/GE 25% B0P/BECHTEL 18% ADMINISTRATIVE 25" RADIOLOGICAL / ENVIRONMENTAL 22% FINDINGS: HIGH LEVEL 0F MANAGEMENT INVOLVEMENT MANAGEMENT EMPHASIS IN PERFORMING A QUALITY REVIEW ASSIGNMENT OF TWO FULL TIME PROJECT QUALITY ENGINEERS TO PROJECT TEAM INDEPENDENCE OF OVALITY ASSURANCE WAS STRESSED, RESPECTED AND MAINTAINED INVOLVEMENT OF MP8L SENIOR REACTOR OEPRATORS DEDICATION OF SENIOR TECHNICAL PERSONNEL BY BOTH BECHTEL & G.E. IDENTIFICATION OF INCONSISTENCIES BETWEEN THE T/S AND FSAR HAS BEEN ACCOMPLISHED IN SUFFICIENT DEPTH TO ESTABLISH THE RELIABILITY OF THE T/S REVIEW PROCESS ADDITIONAL ITEMS OF INCONSISTENCY IDENTIFIED INITIAL REVIEW / EVALUATION BY LRO AND RPD GROUPS CLASSIFIED QA FINDINGS AS EITHER NOT SIGNIFICANT OR WITHIN THE PURVIEW 0F ENGINEERING JUDGEMENT,
l EXAMPLES l I l TECHNICAL SPECIFICATION FSAR j -HEPA FILTER FLOW RATE -N0 ESF FILTER TRAIN l 4000 CFM 10% CAPACITY EXCEEDS j 4000 CFM R.G. 1.52 REV, 2 -R G. 1,52 REV. 1 l (MARCH 1978) (JULY 1976) RCIC. INITIATED BY LOW -RCIC INITIATED BY j LOW WATER LEVEL LOW-WATER LEVEL i j REACTOR COOLANT PH -REACTOR COOLANT PH EXCEEDING LIMITS FOR EXCEEDS LIMITS FOR GREATER THAN 72 HRS., 24 HRS., REACTOR l BE IN AT LEAST STARTUP WILL BE PLACED IN l WITHIN 6 HRS. SHUTDOWN I i 1 l 5 ) I a -,n-
F-4 5 i _... SE?AP. ATE FAFTOUT 3Y I?? ELL CO??CFATION W O S L
f 1 3 m IX.
SUMMARY
A. PROGRAM PROVIDED ASSURANCE THAT UNIT CAN BE OPERATED SAFELY AND IN ACCORDANCE WITH LICENSE B. PROGRAM THOROUGH AND COMPREHENSIVE; MANY INSIGNIFICANT-INCONSISTENCIES IDENTIFIEDJ HIGH DEGREE OF CONFIDENCE IN RESULTS C. RESULTS N0 INCONSISTENCIES OF SIGNIFICANT SAFETY CONCERN NO PHYSICAL CHANGES REQUIPED IN THE PLANT TECHNICAL SPECIFICATIONS CONSISTENT WITH FSAR, SER AND PLANT LICENSED PLANT CONSISTENT WITH AS-BUILT PLANT NO INDICATION OF PPOBLEMS WITH PLANT LICENSING, 5 DESIGN OR CONSTRUCTION TECHNICAL SPECIFICATIONS ACCURATE AND ADEQUATE FOR SAFE OPERATION ABOVE 5: POWER WITH PRIORITY l l CHANGES INCORPORATED j D. LICENSEE HAS COMPLETED ITS REVIEW PROGRAM AS PLANNED i PCOL'S FOR NECESSARY TECHNICAL SPECIFICATION CHANGES ARE BEING SUBMITTED TO NRC UPON NRC APPROVAL OF NECESSARY TECHNICAL SPECIFICATION CHANGES, PLANT AND LICENSEE READY TO i RESTART AND BEGIN POWER ASCENSION PROGRAM E. NEED EXPEDITED NRC ASSISTANCE o ISSUANCE OF PROPOSED AMENDMENTS USING EXIGENT PROCEDURES l RESTART f ISSUANCE OF Futt-POWER LICENSE I o 5 V =}}