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UNITED STATES 8
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NUCLEAR REGULATORY COMMISSION h
f WASHINGTON, D. C. 20$$$
-j MEMORANDUM'FOR:
Cer=issicner Victor Gilinsky FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
GRAND GULF SURVEILLANCE PROCEDURES Your memo of March 2, 1984, posed four questions on the problems identified with the Grand Gulf surveillance procedures.
Enclosed is the NRC staff's response to those questions.
William J. Dircks
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Executive Director for Operations
Enclosure:
Answers to Surveillance Procedure Questions cc w/ enc 1:
Chairman Palladino Comissioner Roberts Comissioner Asselstine Comissioner Bernthal 3
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ENCLOSURE
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J ANSWERS TO SURVEILLANCE PROCEDURE QUESTIONS 1.
"How many of the Grand Gulf licensed operating staff were originally examined by the NRC on the plant-specific simulator?
In the case of those who where (SIC) examined on another simulator, did the operating and emergency procedures that were used apply to Grand Gulf or to a different plant design?"
Response
There are twenty-nine (29) individuals currently on the Grand Gulf licensed operating staff.
Some individuals have taken both plant specific and non-plant specific simulator examinations.
Five (5) individuals (of 29) were originally administered plant 4
specific simulator licensing examinations by the NRC.
Twenty-two (22) individuals (of 29) were originally administered non-plant specific simulator licensing examinations by the NRC on the General Electric Perry Simulator.
The Grand Gulf operating.and i
emergency procedures in effect at the time of these examinations were utilized as much as practicable.
However, since these examinations were' conducted on a non-plant specific simulator, certain portions of 1
these examinations may have required the use of the Perry Simulator procedures.
Two (2) individuals (of 29) were not originally administered any simulator examinations, since their licensing examinations occurred after the NRC had discontinued administering non-plant specific simulator examinations but prior to Grand Gulf's simulator becoming operational.
It is important to note, however, that the Region II Operator Licensing Section on February 13-24, 1984, administered full plant oral and simulator examinations (equivalent to an initial licensing examination) 1, to twenty-six (26) individuals on the Grand Gulf licensed operator staff.
These examination utilized " current" plant ope, rating and emergency procedures as well as the Grand Gulf plant specific simu-lator.
Twenty-three (23) individuals passed these examinations.
The three (3) individuals who failed and the three (3) individuals who have not yet taken these NRC examinations have been removed from licensed duties and will not be returned until they have satisfactorily completed an NRC administered examination.
2.
"At present approximately how many errors or discrepancies in the plant surveillance procedures (as opposed to the technical specifications) does l
the staff estimate were made at Grand Gulff How many of these have been corrected?"
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Enclosure' 2
4 Rescense NRC Region II has not made an independent count of the number of surveil-lance procedures that needed correction.
However, as a condition.of the October 1982 Confirmation of Action Letter issued by Region II, MP&L submitted a documenting,sumary report after their surveillance procedure review effort; the problems found, the corrective action taken, and the probable consequences had no corrective action been taken.
That report, i
designated AECM-83/0622 "GGNS Unit 1 Surveillance Review Program Results" was sent to the Region II on December 1,1983 with copies to R. C. DeYoung.
IE, and the NRC docket files.
For the past year and a half resident and regional-based inspectors have monitored the licensee's actions to revise their surveillance procedures to assure that they conform with the technical specifications. Accordingly Region II believes that AECM-83/0622 provides an adequate estimate of the number of errors or discrepancies.
At Grand Gulf there are approximately 510 surveillance procedures.
In response to question 2. AECM-83/0622 states that there were approximately 709 errors or discrepancies identified by the licensee in the surveillance procedures.
It is emphasized that there were many instances of multiple.
problems with a single procedure.
The number 709 is the item count and not the number of procedures that required revision.
1 The licensee has infomed Region II that all known discrepancies in surveil-lance procedures required for nomal operation (as distinguished from ~
refueling or other special evolutions for which procedures are not yet needed)havebeencorrected.
Region II has audited selected procedures to i
determine if they are adequate.
We conclude, based on our audit, that the i
procedures are adequate pending resolution of a number of licensee identified items.
3.
"How many errors were not merely typographical?"
Response
Based on the Region II review of AECM-83/0622, 46 of the 709 items requiring changes were typographical.
Thus 663 errors were not merely typographical.
4.
"How many errors involved surveillance checks that did not apply to the as-built plant?"
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Response
j Based on the Region 11 review of AECM-83/0622, 32 surveillance procedures were affected by Technical Specification changes which were requ. ired to be made to conform to the as-built plant.
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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. B O X 18 4 0, J A C K S O N, MIS. sis SIP PI 3 9 2 05 December 1,198$
NUCLEA2 PRODUCTION DEPARThagNT
=E U. S. Nuclear Regulatory Comission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30303 Attention:
Mr. J. P. O'Reilly, Regional Administrator
Dear Mr. O'Reilly:
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-13 File 0260/L-835.0 GGNS Unit 1 Surveillance Review Program Results AECM-83/0622 Nuclear Regulatory Commission (NIlC) Inspection Report No. 50-416/82-67 dated December 10, 1982, transmitted several violations that identified numerous GGNS Surveillance Program deficiencies. Mississippi Power & Light (MP&L) responded to the NRC violations in a letter (AECM-83/436) dated January
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21, 1983.
In this response MP&L committed to establish a Surveillance Review Program to rewrite as necessary all surveillance procedures to ensure technical adequac7 and compliance to Technical Specifications.
MP&L has implemented numerous corrective actions to ensure that all surveillance procedures are technically adequate and in compliance with the Technical Specifications and a program has been established to effectively incorporate, control, and implement regulatory requirements.
The attached report describes the generic problems discovered during the review effort and the corrective actions implemented to correct surveillance deficiencies.
Yours truly,
). $ Y L. F. D ale h Manager of Nuclear Services EBS/SHH: sap Attachment ec:
(See Next Page)
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AECM-83/0622 MISSISSIPPI POWER & LIGHT COMPANY Pcg2 2 cc: Mr. J. B. Richard (w/a)
Mr. R. B. McGehee (w/o)
Mr. T. B. Conner (w/o)
Mr. G. B. Taylor,(w/o)-
Mr. Richard C. DeYoung Director (w/a)
Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Document Control Desk (w/a)
U. S. Nuclear Regulatory Conadssion Washing.an, D. C. 20555 1
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Table of Contents
' Summary.
Section 1': Generi'c Problems'
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A.
Non-Incorporation of Technical Specification Items B.
Procedural Non-Compliance with Technical Specification Definitions C.
Non-Incorporation of Amended Technical Specifications D.
Non-Conservatism E.
Mis-Scheduling of Required Surveillances F.
Inadequate Document Cross-Reference G.
Head Correction Problems H.
Technical Specification Non-Conformity to As-Built Conditions
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Technical Spec 1fication Inconsistency J.
Technical Specification Editorial or Nomenclature Errors K.
Proposed Technical Specification Changes Section 2 - Corrective Actions 0
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SUMMARY
This report is a ' final su-ry of all problems encountered in the GGNS Surveillance Program.
' Inadequate surveill'ance profedures ieri a risult'of in'adequat'e programmatic' controls over surveillance activities.
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l Section 1 documents the problems discovered in the surveillance program review effort and the probable consequences of each generic problem.
An estimate of the number of procedures associated with each generic problem is provided in 1
the asscciated discussion of each problem.
Section 2 describes the corrective actions used to ensure that all surveillance procedures are technically adequate and in compliance with the Technical Specifications and the program established to effectively incorporate, control, and implement regulatory requirements.
All surveillance procedures have been reviewed for adequacy.
All procedu,res identified as inadequate which are needed for Operational Conditions 2, 3, and 4 have been rewritten, reviewed, and approved, and, as necessary, associated surveillances have been reperformed for the applicable operational 1
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SECTION 1 Generic Problems A.-
Nyn-Incorporation' of Technical Specification Items
.. The fell wing. specific problems were.found.by the Surveillance...Rev_iew Teac involving surveillance procedures that did not adequately indorporate all Technical Specification requirements:
l.
Procedures did not exist to. perform the surveillances required by Technical Specifications. Thirty-eight procedures were affected.
2.
Procedures did not test all the equipment required.
Eighty procedures were affected.
i 3.
The motor operated valve thermal overload protection functional test l
requirements of Technical Specification 4.8.2.1 ~and Technical Specification 4.8.4.2.3 were incorrectly or inadequately covered by procedures.
i Twenty-nine procedures were affected.
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Procedures did not test every valve, breaker, or snubber required by the Technical Specifications. Thirty-four procedures were affected.
5.
One procedure was changed prior to an ODCM rerision, which would permit the change.
The probable consequences of non-incorporation of Technical Specification ite=s are:
a 1.
The inability t satisfy Technical Specification operability requirements, resulting in entry into an LCO action statement.
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Uncertainty of the actual operational status of equipment not tested.
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Operation of equipment not in compliance with Technical Specifications.
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SECTION 1 i
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B.
Procedural Non-Compliance with Technical Specification Definitions The following specific problems were found by'the Surveillance Review Team involving procedural non-compliance with Technical Specification j
Definf.tf ons : '
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1.
Procedures did not check every alarm required by Technical Specification Definitions 1.4 and 1.6.
Fifty-four surveillance i
procedures were affected.
j 2.
Procedures did not specify the acceptance criteria for channel j
checks.
Forty surveillance procedures were affected.
3.
Calibration procedures did not adequately include a functional test i
as required by Technical Specification Definition 1.4 Fifty i
surveillance procedures vere affected.
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4.
Channel calibration procedures did not check the entire parameter sensing loop (pressure transmitter and trip unit) as required by 1
Technical Specification Definition 1.4 Twenty-eight surveillance
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procedures were affected.
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The Logic System Functional Test did not take into account the.
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required " series of sequential, overlapping or total system steps" so that the entire logic system could be considered tested per Technical Specification Definition 1.22. ' Forty-seven surveillance
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procedures were affected.
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Some equipment response times were not covered by procedures. This invalidated the required " series of sequential, overlapping or total i
i steps" concept so that the entire system response time, as defined in Technical Specifications 1.12, 1.13, 1.19, and 1.34. was inaccurate. Ten surveillance procedures were affected.
The probable consequences caused by non-compliance with Technical i
Specification Definitions aret i
1.
The inability to satisfy Technical Specification operability requirements, resulting in entry into an LCO action statement.
i 2.
Uncertainty of the actual operational status of equipment not I
j tested.
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Operation of equipment not in compliance with Technical l
Specifications.
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SECTION 1 4
I, C.
Non-Incorporation of Amended Technical Specifications Administrative Procedure 01-5-06-12,' Revision 5. "GGNS Surveillance ~
. Program", had no effective. program to ensure that surveillance procedures i
wererevisedto.compl[withamendedTechnicalSpect_fications. The
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p'robaBle consequencea of an ineffec'tive' v'pdate prosres'would have been j
the performance of surveillances that were not in compliance with the i
GGNS Technical Specifications.
D.
Non-Conservatism j
Procedu're acceptance'criterias were less conservative than Technical
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Specifications required.
For example, some instrument setpoints used j
tolerances not within the limits of Technical Specifications or erroneously listed incorrect units.
Twenty-three procedures were affected.
1 The probable consequences of this problem would have been the operation of equipment not in compliance with Technical Specifications.
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E.
Mis-Schedulium of Required Surveillances The following speciff e mis-scheduling problems involving required I
i surveillances were discovered by the Surveillance Review Teams i
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1.
Procedures incorrectly stated the surveillance frequency I
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requirements.
Seventy procedures were affected.
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2.
Procedures incorrectly stated and/or did not include the operational l
conditions for which the surveillance was applicable. Eighty-one
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procedures were affected.
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Time response procedures incorrectly stated the required test i
frequency of individual channels or subsections. Thirty-five j
procedures were affected.
l The probable consequences of mis-scheduling required eurveillances are i
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Surveillance requirements not satisfied before the late date.
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would require entry into an LCO action statement.
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2.
Surveillance procedures not being performed during.the applicable operational conditions.
This would require entry into an LC0 action l
statement.
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Surveillances being performed at a greater rate than the Technical i
specification requires. This would not violate Technical i
Spe'cifications but could create a manpower shortage for performing 4
other required surveillances.
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SECTION 1 F.
I_nsdequate Document Cross-Reference i
The following specific problems involving'inad'equa'te document cross-references were discovered by the Surveillance Review Team:
li ' irodedides 'specifyldg " normal"%alve'pcis'itiotr'tiere bot"in accordance' with the. Technical Specifications, FSAR, or the System Operating Instructions. Thirteen procedures were affected.
i 2.
Steps were not provided in surveillance procedures to return safety related valves and switches to their " normal" or "as found" i
positions upon completion of a test when their positions were changed as a result of a surveillance.
Sixteen procedures were affected.
3.
Procedures referenced'a System Operating Instruction or Integrated j
Operating Instruction to perform a surveillance or sequence of steps, however, the SOI or IOI did not actug11y perform the 3
surveillance or sequence of steps to the desired end result.
i Fourteen procedures were affected.
j The probable consequences of this problem would have been 3
l 1.
Surveillance requirements not being performed, resulting in the i
entry into an LCO action statement.
2.
Equipment not returned to the " normal" operational configuration at surveillance completion.
C.
Head Correction Tactors The calibration procedures of pressure transaftears were found to be inaccurate due to miscalculation of the transmitter head factor. The miscalculation was the result of using head height of the transmitters' l
designed location, but not the specific as-built transmitter location.
All procedures which calibrate pressure transmitters were reviewed and corrected, as necessary, for this problem. The operation of pressure, flow, and level detection devices and their associated trips or alarms outside the allowed tolerances established by Technical Specifications is i
a probable consequence of the inaccurate head correction problem.
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SECTION 1 H.
Technical Specification Non-Confornity to As-Built Conditions Changes were made to the Technical Specifications to account for as-built plant conditions.
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inadvertent errors in the Technical Specifications when the license was issued rather than to change any physical features of the plant.
The procedures satisfying Technical Specification surveillance requirements have been reviewed by the Surveillance Review Team for compliance with the changes. The procedures have been revised as necessary. The probable consequences of not revising the procedures would have been non-compliance with Technical Specification surveillance requirements.
Table 1 references the amended Technical Specification number, the document containing the Technical Specification change technical evaluation, the number of surveillance procedures affected, and summary of the Technical Specification change.
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l Table 1 Technical Surveillance Specification AECM Number Procedures 1
Number (1 ten Number)
Affected Summary of the Technical Specification Change Gabla 2.2.1-1 83-0314 7
HoreconservativesetpointsperNSSSspecificationsI (1)
Dabla 2.2.1-1 83-0356 4
Revised setpoint values more conservative than current' values.
Umbla 3.3.4.2-2 (4) l Gabla 3.3.2-1 83-0180 I
Addition of valves to listing.
(29) l Dabla 3.3.2-2 83-0370 8
Reflects actual conditions rather than nominal conditions.
(4)
Gabla 3.3.2-2 83-0338 2
Revision of setpointa per NSSS specification, within bounds of Dabla 3.3.3-3 (2s3) previous analysis.
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psygloggg.dthlarinstrumentation.
(16)
Gabla 3.3.3-2 83-0356 2
Revised values more conservative than previous analysis.
l (1)
Gabla 3.3.3-2 83-0370 11 Revised timer delay to inrwrporate tolerance, still within bounds of (5) analysis.
ihbla 3.3.7.1-1 &
83-0207 I
installed Gabla 4.3.7.1-1 (11) over approved fuel storage area.
Gable 3.3.7.3-1 &
83-0180 2
D g gg g in y J ~ _ O N h ama-mom &sereds tifferehtfal j
Tempassasaamssf&qhenWdeOmgeggjped parameter, Gabla 4.3.7.3-1 (30)
Dabla 3.3.7.12-1 &
83-0180 2
A" --ric laalatiol g Q fg h m Q m g g isolation
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Gabla 4.3.7.12-1 (19) provided by vent &:t; ion exhaust monitor.
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Technical Surveillance Specification AECH Number Procedures Number (Item Number)
Affected Susumary of the Technical Specification Change 3/4.6.1.3 83-0314 1
Change reflects that pressure instrumentation is provided for each 3/4.6.2.3 (10)
&&sa heK ilAsa-the.-pip;10%deg seal system air tanks (flasks).
rabla 3.7.4-2 83-0314 2
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(14) rabia 3.7.6.5-1 83-0254 3
Provides proper notation for hose station locations..
(6) rabia 3.7.8-1 83-0207 I
Lower temperature limits agree with actual qualification temperature (4) as required by NRC evaluation.
rabia 3.8.4.1-1 83-0180 2
Revised the Trip Setpoint for the 6.9 KV circuit breakers to reflect (14) the locked rotor current rise due to residual voltage'.
Provides equivalent protection of equipment.
rabia 3.8.4.2-1 83-0180 3
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(23) 5.9.1 83-0180 1
Saltic]nuar.:rataMaterleeAs,,
(26) 5.9.1 83-0207 1
na..h -asaser:veaussi:bfeakest testing to be conducted by another (6) suitable means.
I eiMr shot eeanoth. san 4 separately; test still L.I.3.1.4 83-0370 1
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retained as part of another test.
rabia 4.3.3.1-1 83-0314 5
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' g R.-#dHtnr onlys testing of ~overa11' delay.
(5) not individual inputs.
L. 6.1.4 83-0338 1
Original values from purchase specification, revised values from (8) functional test.
L.6.4.4
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61- '--* 4-alhdadtin /slPA systemte not required.4pmeAtsuf' (7)
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J Lis A A Ul4 I Technical Surveillance Specification AECM Number Procedures Number (Ites Number)
Affected Summaary of the Technical Specification Change 4.6.6.3.D.2 83-0338 1
Reflects a more conservative pressure drop for filter bank.
(9) p 4.6.6.3.D.3 83-0314 1
Change adds " manual initiation" to the Ifat of SCTS actuation I
(11) signals and allows verification of test signals by LOGIC SYSTEM F11NCTIONAI. TEST.
4.6.7.I 83-0207 1
Deleted since
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naneJgissedhggy (12) 6 not applicable to CCNS.
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,4.7.2 83-0207 2
Deleted since CCNS design i h y44sen se& h m byp43s (5) 4.7.2.D.2 83-0314 1
Change adds " manual initiation" to the list of CR emergency (13) flitration system actuation signals and allows verification of test signals by LOGIC SYSTEM FUNCTIONAL TEST.
0.8.1.1.1 83-0338 3
Deletes surveillance requirement es8mga (12) ht c?- - -M
-5 5=!raggg, 0.8.I.1.2 83-0207 10 Revised to reflect faster Diesel Generator start time; agrees with (9)
NRC evaluation.
0.8.1.1.21.16 83-0180 3
The word " engine" replaced the word " generator" such that itemi f (22) reads " engine bearing temperature high (11 and 12 only). ' Item j was appended to reflect applicability to D/G 13 only.
Usbla 4.8.2.1-1 83-O f80 2
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_ _7-eype w w limits reflect manufacturer's (15) speciffemtions.
p.8.3.t.1 &
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. sufficient 3.8.3.2.1 (12) voltage instrumentation present on busses on LCs.
p.9.12 83-0180 1
Jameser,epsjggpps2Netis.pst alshransf eresysteg i
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Technical Surveillance i Specification AECM Number Procedures
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Number (Ites Number)
Affected Summary of the Technical Specification Change l 3.6.4. 4.6.1.1 83-0449 58 Nomenclaturecorrections,additionofvalvestosurve[111ancetables..
l Tables 3.3.2-1, 3.3.2-2 (1) reduction in closure times to agree with accident anglysis, l 3.3.2-3, 3.6.4-1, and adjustment of closure times to agree with AMSE Section XI testing, l 3.6.6.2-1. and 4.3.2.1-1; realignment of valve groups according to isolation actuation.
' and 33/4.6.4. 53/4.6.6 83-0492 (1) l 4.4.7 83-0492 I
Revised to allow MSIV and any other valves that can be tested in
! Tabla 3.6.4-1 (2) other than COLD SHUTDOWN or REFUELING to be tested with the plant hot but before reaching 600 psig.
l i Tabla 3.3.3-1 83-0422 3
Redefines " operability" range for llPCS until first refueling outage l4.3.3.1-1 (15) due to water level instrumentation inaccuracies at low pressure.
Tabla 3.6.4.1 83-0356 2
jockey pumps; needed to prevent potent::aI~q)ic tripping of'RHRdamage from ggygpl;_Juho (18) i 4.4.2.1.2.b.
83-0338 3
Provisions of Technical Specification 4.0.4 suspended'to allow plant l 4.5.2.2.1.b (7) to attain operating conditiona necessary of ADS trip system l Tabla 3.3.3-1 surveilfance testing (one time Technical Specification exception).
l 4.1.3.1.4.a 83-0422 1
Provisions of Technical Specification 4.0.4 suspended to allow plant j
(13) to attain operating conditions necessary for scram discharge volume j
surveillance testing (one~ time Technical Specification exception).
Tabla 3.3.2-1 83-0356 12
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Tabla 3.3.3-1 (16)
Tabla 3.3.7.1-1 83-0356 0
Increases the number of minimum operable channels.
(10)
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3.4.2.1 83-0314 2
Change revises the drift allowance for the relief valve function of (8) the safety / relief valves to coincide with the design ' specification of these valves."
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Technical Surveillance Specification AECM Humber Procedures Numbe r (Iten Number) _ Affected Sussmary of the Technical Specifiestion Change 3.4.2.2 83-0314 2
Change revises the drift allowance for the relief valve function of (9) the safety / relief valves to coincide with the designgspecification of these valves.
L.7.6.2 (8)
___* -d-fdfay7aNinuir system for surveillance.
3.7.6.2 83-0422 3
3.7.6.4 83-0422 4
g esseelevererbut-nohvalugg.
Redefinition L.7.6.3 (3) of actuat;on and system operability surveillance.
k.7.6.4 tabla 3.8.4.1-1 83-0370 2
A se &,. __,fa1==ce; revision of L.I.3.2.5 83-0356 1
Allows entry into operational mode to test after maintenance or (9) modifications.
L.3.7.5-1 83-0422 1
Increases surveillance frequency for hydrogen analyzers.
(12)
L.5.1.5 83-0370 5
Reflects test line pressure requirements to conform to ASME (8)
Section II.
L. 6. 6.1.3. 2 83-0370 1
Increase in pressure requirement.
(11)
Erdubpkiripheder46'""t" *=" EMS **Tigerfar. Theater continuity assured by L.6.6.3 83-0449 (Re-1 L.7.2 (3)*
submittal other elements of testing.
E3/4.6.6 of 83-0422 E3/4.7.2 Item 14 83-0356. Item 2)
L.O.6.3.D.3 83-0314 3
Redefinition of functional testing, actual component performance (11) test on same schedule 1
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Technical Surveillance
!Specificarica AECM huzber Procedures N= sher (Ites Number)
Affected Summary of the Technical Specification Change 4.8.1.I.2 83-0338 3
3546mdenskahadd&se-revisch'to agree with FSAR.
(13) p 4.8.1.1.2 83-0422 3
Reflects rated losd of diesel generators.
(10) 4.8.1.12.D.2 83-0422 3
Revisica due to nomenclature; largest load agrees with component (2) table in FSAR.
4.7.2.D.2 83-03I4 3
Redefinition of functional testing; actual component performance test (13) on same schedule.
Tabla 3.3.3-1 83-0422 O
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JEhdemme*Fdether, they clarify that the required functions of the Base Figure 3/4.3-1 HPCS initiation instrumentation do not always include injec'tf on and that false indications of reactor water level due to 1nstrumentation
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design and calibration requirements do not affect the' safe operation of the plant. Changes to table applicable until restart following the first refueling outage.
Change to base figure is a permanent change.
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1 SECTION 1 1.
Technical Speeffication Inconsistency a
Several modifications were made to Technical Specifications to maintain 4
4 internal consistency within the Technical Specifications. None of the changps, M olved'a significant relaxation bf the'cr~1teria used to
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establish" safety limits'or'th'e' bases 'for ifalting safety ' system settings or limiting conditions for operation.
These administrative changes affected several surveillance procedures that the Surveillance Review Team revised as necessary to reflect the amended Technical Specification.
The consequence of not revising Technical Specifications and procedures would be the potential misinterpretation of surveillance requirements.
l Table 2 references the amended Technical Specifications, the document containing the technical evaluation of the change and the number of procedures affacted.
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I SECTION 1 Table 2 Technical Specification.
,..AECM Surveillance.
Sec. tion Number Proceduree Affekted 3.2.2 83-0338 1
Table 3.3.2-2.
83-0180 2
Table 3.3.6.2 &
83-0180 1
Section 4.1.4.2 3.7.1.3. 4.7.1.3 83-0314 2
3.8.1.1 83-0356 2
Table 4.3.3.1-1 83-0370 9
Table 4.3.3.1-1 83-0180 6
Table 4'.3.6.1-1 83-0180 2
Table 4.3.6.1-1 83-0180 4"
Table 4.3.7.12-1 83-0207 3
4.5.3.1. 4.6.3.1 83-0370 4
4.7.7.2 83-0422 (Resubmittal of 83-0314, Item 15) 3 4.8.4.3 83-0422 1
Table 4.3.7.5-1 83-0422 2
3.1.3.1 83-0422 0
Table 3.3.4.2-1 83-0207 4
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SECTION 1 J.
Technical Specification Edito' rial or Nomenclature Errors Several*nodifications were'made to T'echnical. Specifications which were administrative in nature and were necessary.to. correct editorial and nomenclat'ure. errors.. None,,of these changes, involved a, significant.
relaxation of the criterta used to establish safety limits or the base.
s for limiting safety system settings or limiting conditions for operation.
The consequences of not revising Technical Specifications would have been the possible misinterpretation of Technical Specification requirements.
1 Table 3 references the amended Technical Specification and the document I
containing the technical evaluation of the change.
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SECTION 1 I
i Table 3 Techn1 cal Specification AECM Section-Number AECM Item Number
_. u Table 3.3.2-1
,s 83-0180
,6 4.4.6.1.3 83-0207 3
4.8.1.1.2.d.9 83-020'7 13 6.5.2.8 83-0207 22 3.7.5 83-0254 1
Table 3.3.2-1 83-0314 3
Table 3.3.3-3 83-0314 4
Table 3.3.7.1-1 83-0314 6
Table 4.3.7.12-2 83-0314 7
j Table 3.3.7.1-1 83-0338 5
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- 4. 6. f. 3 83-0338 10 1
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3.11.1.1 83-0338 15 l
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1 3.11.1.2 83-0338 15 l
3.11.2.2 83-0338 15 3.11.2.3 83-0338 15 3.7.10; 4.7.10 83-0370 2
and 83-0565 3
Table 3.6.4-1 83-0180 1
Table 3.6.4-1 83-0180 2
Table 3.3.3-2 83-0180 5
i Table 3.6.4-1 83-0180 9
3.1.3.2.B 83-0180 10 Table 4.3.7.11-1 83-0180 11 Table 1.1 83-0180 17 Table 3.6.6.2-1 83-0180 18
SECTION 1 Technical Specification AECM Section Number AECM Item Number Table 3.3.7.1-1 83-0180 21
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Table-3.3. 7.5-1 83-0180.
24 Table 3.3.2-1 83-0180 27 Table 3.3.2-2 83-0180 27 Table 3.3.2-3 83-0180 27 Table 4.3.2.1-1 83-0180 27 Table 3.3.7.2-1 83-0180 32 Table 4.3.7.2-1 83-0180 32 3.11.1.3 83-0180 34 6.9.1.12.K 83-0207
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Table 4.3.1.1-1 83-0207 2
Table 3.3.3-2 83-0207 7
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Table 3.3.2-3 83-0207 10 Table 4.3.7.11.1 83-0207 17 3.5.1 83-0207 20 4.7.4 83-0207 21 4.7.5.3 83-0254 2
3.3.2; 3.6.6.1; 3.6.6.2; 83-0314 2
3.6.6.3; 3.7.1.1.3; 3.7.2; 3.8.1.2; 3.8.2.2; 3.8.3.2; Table 3.3.2-1; 3.3.7.1-1; 4.3.2.1-1; 4.3.7.1-1 Table 3.3.7.9-1 83-0411 1
and 83-0565 1
Table 4.3.1.1-1 83-0422 1
Table 3.7.6.6-1 83-0422 4
3.3.7.9; Table 3.7.8-1.
83-0 22 5
6.9.1.5; 6.9.1.12-83-0565 17 6.5.2.2 83-422 9
f SECTION 1 l
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Proposed Technical Specification Changes I
(
Due to the large number of Technical Specification changes required, the changes were prioritized, based upon the operational mode requirements necessary to. achieve criticality,. power as,cension..and.conumercial e
operation.
Some proposed changes have been received as' Technical Specification Amendments 7, 8, 9, 10, and 11 while others are undergoing NRC review or being prepared by MP&L for NRC submittal.
Table 4 provides a list of Technical Specifications yet-to-be amended and the document containing the technical evaluation of the change.
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SECTION 1 i
Table 4 Proposed change's to Technical Specifications Technical AECM Number Speciffiation (IEen Numbai)
Summary l
3.3.2-1.2.E 83-0356 Resolves Technical Specification 4.3.2.1-1.2.E
( 8) conflict to perform required Condenser Vacuum Surveillance.
Table 3.3.7.9-1 83-0253 Deletion of some smoke detectors.
( 8) 3.4.2.1 83-0373 Reflects a design change to SRV
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( 1) low-low set logic.
Table 3.6.4-1 83-0356 To support implementation of a design (18) change package needed to correct a design deficiency.
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Table 3.6.4-1 83-0449 Makes basis for maximum valve
( 2) isolation times consistent; compli (Partial sub-with ASME Section II requirements.
mittal of 83-0373, Item 4) 3.7.6.4 83-0254 Revision to conform with as-built GGNS 4.7.6.4
( 5) design.
4.7.6.3.1 4.7.6.3.2.3.1 3.9.2.C 83-0207 Redefinition of applicability
]
(19) requirements.
)
4.3.7.5-1 83-0356 Alternate method for calibration of (13) containment /drywell area radiation monitors.
4.3.7.5-1 83-0356 Increases calibration frequency.
(14) 4.5.1.C.2.3 83-0356 Maintain consistency between Technical (11)
Specifications and system design specfficatione.
,4.5.1.C.A.2.A 83-0356 Correction to LCPI A & B low pressure (15) setpoints to reflect plant design.
4.7.6.1.1.E.1 83-0254 Deletion of requirement not applicable
( 3)
.to GGNS design.
4.7.6.1.3.A.
83-0254 Provide consistency between GGNS
( 4)
Technical Specifications and Standard Technical Specifications of NUREG-i
_. _, ~ _ _ _ _ _ _ _ _ _ _ _. _ _.. _ _ _ _ _ _ _ _.. _ -. _ _ _ __. 0123 a. _ _, _ _ _ _ _ _ _ _ _ _. _. _ _ _
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SECTION 1 l
Technical AECM Number l
Specification (Item Number)
Summary 4.8.1.1.2.A.5 83-0356
. Modification of requirements to better _
4.8.1.1.2.D.9~
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- 5).
. represent actual plant design and to comply with the intent of, Regulatory Guide 1.108.
4. 8.1.1. 2. D.'2 83-0207 Maintain consistency with the largest (15) single load that can be applied to ESF busses during planned testing of the diesel-generators.
6.5.2 83-0180 Change the Advisor to Vice-President Nuclear Operations from a non-voting member to a voting member of the SRC.
6.5.2.10 83-0180 Maintain consistency with Operational Quality Assurance Manual regarding audits'of SRC written reports.
4.8.2.1.D.2.B 83-0356 Revision of Division 2 125 Volt D.C.
( 6) battery load profile to reflect as-built plant conditions and a planned change in the Division 2 inverter.
4.3.4.2.3
.83-0356 Corrects the specification and bases B 3/4.3-3
( 7) to accurately reflect the breaker are suppression requirement. The basis change clarifies the definition of the EOC-RPT system response time.
3.7.6.2 83-0338 Addition of spray / sprinkler system 4.7.6.2.C (11) surveillance requirements; deletion of visual inspecions of pre-action sprinklers.
4.4.2.1.2.B 83-0338 Allows entry into Operational 4.4.2.2.1.B
( 7)
Condition 2 without performing the Table 3.3.3-1 valve opening part of the LOGIC SYSTEM FUNCTIONAL TEST.
4.8.4.3.B 83-0314 Revision of setpoint tolerances to (16) agree with equipment design specifications.
4.9.6 83-0314
-To incorporate additional plant (17) features not covered by Technical Specifications.
6.5.2.2 83-0338
. Reflect change in MP&L corporate (14) structure.
3.3.1 83-0565 Conformance of Technical (18)
Specifications with the Standard j
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SECTION 1 Technical AECM Number Specification (Item Number)
Summary
)
3.1.3.2 83-0565
, Redefinition of Technical
,. 32).
,.Specifica, tion appli.cability._
(
requirements.
f Table 3.3.3-2 83-0565 Revision of setpoints per NSSS (24) specifications, within bounds of previous analysis.
Table 3.3.2-3 83-0565 Pipe break detection circuitry (10) modification for compliance with generic letter 83-02.
j 3.3.3 83-0565 Utilization of the most limiting'LPCI
( 6) response time to maintain consistency with FSAR.
3.3.3.2
~83-0565 Revision.of reference evaluation of
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3.3.5-2 (21) suppression pool level instrumentation
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to maintain consistency with plant design.
3.3.6-1 83-0565 Redefinition of operational condition 4.3.6-1 (13) applicability requirement.
3/4.3.7.1 83-0565
' Inclusion of data inadvertently Table 3.3.7.1-1
( 5) omitted by the NRC in Amendment 7.
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3.4.1.4 83-0565 Redefinition of requirement
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( 4) applicability.
j 3.6.2.5 83-0565 Reflects incorporation of one of the
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B3/4.6-3 (22)
Humphrey concerns into plant design.
3.7.1.1 83-0565 Revised to reference all applicable 4.7.1.1
( 9) operational conditions.
Table 3.7.6.5-1 83-0565 Addition of fire hose stations to j
(23) list.
1 Table 3.7.8-1 83-0565 Change of temperature limits and (33) changes to conform to Standard Technical Specifications.
l Table 4.3.3.1-1 83-0565 Addition of surveillance requirement -
(28) inadvertently omitted from Technical i
Specifications.
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SECTION 1 Technical AECM Number Specification (Item Number)
Summarv
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4.3.7.6.C 83-0565 Change SRM minimum count rate
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Table 3.3.,6-2.
neutron source; within bounds of G.E.
( 1) setpoints to prevent replacement of
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Rod Drop Analysis re-analysis.
Table 4.3.7.12-1 83-0565 n'-
_1" mmsentanessakafe (19) s h e' -
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Figure 6.2.2-1 83-0565 Chan~ge to Unit Organization Chart for (35) more effective utilization of personnel resources.
6.5.1.2 83-0565 Expansion of PSRC membership.
(20)
Table 3.3.8-1 Unassigned (Not yet submitted)
Table 3.3.8-1 Unassigned Minimum operable channels listed are (Not yet too few.
submitted)
Table 3.3.5-1 83-0642 Minimum operable channel should be
( 1) four for low-lov level.
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i SECTION 1 9
Proposed Technical Speciffcations changes to correct editorial and nomenclature errors..
AECM Number
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(Item Number) 1 Technical Specification-Table 3.3.1-1 83/0565 (27) 3.3.2 83/0565 Table 3.3.2-2 (16) 3.3.3 83/0565 Table 3.3.3-1 (7)
Table 3.3.7.1-1 83/0565 Table 4.3.7.1-1 (2)
(Resubmittal of AECM-Table 3.3.7.12-1 83/0370 Item 6)
Table 3.4.3.2-1 83/0565 Table 3.4.3.2-2 (8)
B3/4.6.1.7 83/0565 (14) 4.5.3.1 83/0565 3.6.3.1 (15)
B3/4.6.3 3/4.6.7 83/0565 (12)
Table 3.7.4-2 83/0565 (31) 3.8.1.2 83/0565 (11)
Table 3.8.4.2-1 83/0565 (25) 4.8.1.1.2.D.9 83/0565 (26) 5.1.3 83/0565 Figure 5.1.1-1 (29)
Figure 5.1.3-1 6.10.2 83/0565 (30)
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. 's SECTION 1 AECM Number Technical Specification (Item Number) 1 Table 3.7.6.6-1 83/0422 (Resubmittal of
..(4)
AECM-83/0.254, Item 7) 4.8.4.2.1.A 83/0356 4
(12) 4.3.4.2.3 83/0356 (Not a Technical B3/4.3.3 (7)
Specification Change - one time exemption to the operating license) 1 O
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s SECTION 2 l
Corrective Action l
The following describes the corrective actions used to ensure that all i
Technical Specifications and Surveillance Procedures are technically adequate; and.'the. program established to effectively. incorporate.. control and implement regulatory requirements:
1.
A Surveillance Review Team, headed by the Technical Engineering Supervisor, was established to review / rewrite all existing and new surveillance procedures to ensure technical adequacy and compliance to GGNS Technical Specifications and 10CTR50 - Appendix J.
A preliminary j
review of compliance with ASME Section II regulations, which are not required until commercial operation, was conducted.
2.
- A standard criteria checklist was developed to serve as a review guideline and method of review documentation.
i 3.
A surveillance punchlist was established and maintained to identify and track discrepancies internally within the Surveillance Team. This included all procedural problems, needed Technical Specification changes, j
and programmatic problems encountered by the Surveillance Review Team.
4.
The Integrated Operating Instruction and Operating Logs were reviewed by j
the Surveillance Review Team to ensure that the surveillance requirements
)
j associated with operational mode changes are adequately incorporated.
5.
Revision 6 of 01-S-06-12. "GGNS Surveillance Program Administrative Procedure" was written to ensure prompt incorporation of Technical i
Specification changes into applicable surveillance procedures.
6.
R'evision 0, 09-S-05-7, "GCNS Technical Specifications / Surveillance Program Master Cross-Index" was developed and issued to aid plant personnel in the use of Technical Specifications and Surveillance j
Procedures.
l 7.
A cross-reference index of surveillance procedure requirements to o'perational mode requirements was developed to aid plant personnel in the -
use of Technical Specifications and Surveillance Procedures.
3
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8.
The computerized surveillance scheduling program was reviewed by the Surveillance Review Team to ensure procedures are scheduled in accordance with Technical Specification requirements.
This presently is an effective program, however, the Review Team is looking at other methods to further enhance the program.
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9.
Section Level Procedure Philosophy Statements and Technical Specification Position Statements are being prepared as necessary to document the clarification of specific procedures and technical specification
]
requirements as an aid to plant personnel.
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10 To satisfy the requirements of the.Logie System Functional Tests per l
Technical Specification Definition 1.22, the following overall test philosophy was developed by the Surveillance Review Team:
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SECTION 2 Instrument calibration procedures are used to accomplish testing from the sensor to a convenient overlap point in the logic. A functional test then overlaps with the calibration procedure and verifies the logic and the required action of the actuated device.,
11.
Insteidofratesting'equipmenttest'edinanotherprocedureto'obtainan
~
equipment response time from which a system response time could be calculated, the following approach was developed to satisfy system response time testing per Technical Specification Definitions 1.12, 1113, 1.19, and 1.34:
l System Response Time Test procedures were revised to reference the procedure and step to which equipment response times were tested.
Thir data is collated to produce a series of sequential, overlapping or total steps such that the entire system response time is measured.
1 12.
Applicable Plant Quality Deficiency Reports, Material Non-Conformance Reports and Quality Assurance Corrective Action Requesta concerning the Surveillance Program were reviewed and corrective actions were coordinated with MP&L QA and Plant Quality.
i
- 13. The " Grand Gulf Nuclear Station Operations Enhancement Program", was.
l established to improve the short and long-term safety, reliability, and operating effectiveness of the Grand Gulf Nuclear Station. More specific goals include:
Improve management controls necessary for safe and reliable 4
operations.
l Increase the proficiency and quality of licensed personnel.
Emphasize procedure awareness and regulatory concern.
1 Establish efforts to' improve the utilization / effectiveness of management and licensed operating personnel.
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
j
,I WAsHlNOTON. D. C. 20556 l
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MEMORANDUM FOR:
William J. Dircks, Executive Director for Operations FROM:
James P. O'Reilly, Regional Administrator SUSJECT:
GRAND GULF SURVEILLANCE PROCiDURES-The enclosed memorandum is the proposed response to Comissioner Gilinsky's March 2,1984, memorandum on Grand Gulf Surveillance Procedures.
James P. O'Reilly
Enclosure:
Proposed Response to Comissioner Gilinsky's memo of 3/2/84 cc w/ encl.:
Harold R. Denton Richard C. DeYoung N
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