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March 30, 1984 Docket No. 50-416 MEMORANDUM FOR: Frank J. Miraglia, Assistant Director for Safety Assessment Division of Licensing l
FROM:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
SUBJECT:
REVIEW 0F GRAND GULF TECHNICAL SPECIFICATION PROGRAM The details of the MP&L program to completely review the Grand Gulf Technical Specifications were presented to the staff in a meeting on March 9,1984 (Enclosure 1) and in a submittal dated March 18, 1984 (Enclosure 2).
In view of the concerns expressed at the Commission Briefing on March 20, 1984, we request that you review their program for adequacy to accomplish the intended objectives. Please provide your evaluation by April $ 1984.
OO T r
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WASHINGTON. O. C. 20555
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March 21, 1984 c
e Docket No. 50-416 LICENSEE:
Mississippi Power & Light Company FACILITY:
Grand Gulf Nuclear Station, Unit 1
SUBJECT:
SUMMARY
OF MARCH 9, 1984, MEETING WITH MP&L TO DISCUSS TECHNICAL SPECIFICATION REVIFl4 PROGRAM On March 9, 1984, a meeting was held in Bethesda, Maryland to discuss MP&L's proposed program and schedule for the review of the Grand Gulf Unit 1 Tech-nical Specifications. The meeting was attended by representatives of HRC, 4
MP&L, consultants to MP&L, GE and Bechtel. An attendence list is enclosed (Enclosure 1). A copy of the vugraphs used by MP&L for their presentation is also enclosed,(Enclosure 2).
J. Rir%i (Sr. VP) briefly described the overall program and indicated that Floyd tr.wi s (Chrm.-Middle South Utilities) and Donald Lutken (Pres. MP&L) were 4
coninitted r.: a full effort on the Technical Specification review. A total of 135 people nre working full time, 7 days a week on the program.
The Technical Specifirct'ons will be reviewed in total (100%) from top to bottom and will be verifieu to be in accordance with the FSAR, SER and as-built plant. All reviews will be fully documented to support the acceptability of each Tech-nical Specification section.
J. McGaughy (VP) discussed the details of the program as given in the enclosed vugraphs. The project utilizes 55 people from GE (NMSS) and 42 from Rechtel
.(AE-Constructor).
C. Tyrone (MP&L) will manage the overall project wnile P. Jackson (Bechtel) and A. Smith (GE) will have charge of their respective company's effort.
In addition to the various management personnel frcm MP&L, two SR0's will review all acceptances and recommendations.
Each section review will involve a minimum of four (4) people.
MP&L intends to have two people in reside _nce in Bethesda to facilitate daily contact with the staff as needed. MP&L management tentatively plans a regular weekly meeting with the staff to discuss status of the. review.
The MPtl review is scheduled to be completed in five we.eks, on or about April 6, icPo.
As of March 9,1984, MP&L has identified some 235 proposed changes tnat will require staff review. The bulk of these represent additional changes from those identified by MP&L in their previous review from November 1982 to September 1983. Approximately 35 of these items have been previously sub-mitted to the staff in the time period from September 1983 to February 1984.
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Of.the remainder, approximately 100 items were the subiect of discussions held at the plant in late January 1984 involving NRR, Region II and MPFL representatives. The other 100 items have resulted from further NRC concents or from MP&L reviews.
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.. There was a concern about the present review being performed by the same personnel as had been involved in previous incomplete or unsatisfactory reviews.
MP&L indicated that this was a more thorough review involving all levels of technical personnel and especially involving the NSSS designer, the AE-Constructor and the plant SR0s. Other than GE and Bechtel, MP&L had not attempted to obtain other reviewers from industrial or commercial nuclear plant sources.
The first review meeting with the staff is tentatively scheduled for March 14, 1984, to look at proposed changes and discuss priorities.
% a0. M_ ^k M. D. Houston, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosures:
As Stated cc: See next page 1
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GhAND GULF Mr..J. P. McGaughy Vice President Nuclear Production Mississippi Power A Light Company P.O. Box 1640 Jackson, Mississippi 39205 c'c: Robert R. McGehee, Esquire Wise, Carter, Child, Steen and Caraway l
P.O. Box 651 Jackscn, Mi sissippi 39205 Troy B. Conner, Jr., Esquire Conner and Wetterhahn 1747 Pennsylvania Avenue, N.W.
Washington, D. C.
20006 Mr. Ralph T. Lally Manager of Quility Middle South Energy, Inc.
225 Baronne Street P.O. Box 61000 New Orleans, Louisiana 70161 Mr. Larry Dale Mississippi Power & Light Company P.O. Box 1640 Jackson, Mississippi 39205
.Mr. R. W. Jackson,, Project Engineer Grand Gulf nuclear Station Bechtel Power Corporation Gaithersburg, Maryland 20760 Mr. Alan G. Wagner Senior Resident Inspector Route 2, Box 399 i
Port Gibson, Mississippi 39150 t
James P. O'Reilly, Regional Administrator-U.S. Nuclear Regulatory Commission, Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 9
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Meeting Attendees March 9, 1984 NRC MP&L T. Novak J. Richard (Sr. VP) 4 F. Miraglia J. McGaughy (VP)
G. Meyer L. Dale
.1. Joosten (GCM)
- 1. Cross A. Schwencer G. Cesare M. Wagner S. ilobbs D. Brinkman J. Roberts C. Julian (RII)
C. Tyrone L. Kintner J. Green (Consultant)
D. Hoffman D. Houston Bechtel G_E 4
R. Jackson A. S7ith W. Gilbert 1
J. Leatherman O
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3 GRAND GULF NUCLEAR STATION TECH SPEC REVIEW PROGRAM MARCH 9, 1984 I.
INTRODUCTION i
II.
OBJECTIVES III.
MANAGEMENT CONTROL REQUIREMENTS IV.
ORGANIZATION V.
CRITERIA AND SCOPE OF REVIEW VI.
PROCEDURE FOR REVIEl.' AND CLOSUPE VII.
SCHEDULE n
VIII.
NRC INTERFACE IX.
SUMMARY
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OBJECTIVES i
VERIFY CONSISTENCY OF TECHNICAL SPECIFICATIONS
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VERSUS THE PLANT, FSAR AND SER IDENTIFY, SUBMIT AND OBTAIN TIMELY ISSUANCE OF CORRECTIONS ASSURE ACCURACY AND ADEQUACY OF TECHNICAL SPECIFICATIONS 4
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KEY POSITIONS FILLED BY MP&L Ff4PLOYEES B
O PROJECT MANAGEP REPORTS TO SENIOP VICE PRESIDENT-NLCLEAD j
o CONTROLLED BY DEFINITIVE, APPPOVED PROCEDUREc o
DOCI.NENTATION ESTABLISHED TO SUPPORT EACH TECH SPEC SECTION O
Aub! TABLE PROGRN4 WI'H CA AUDITS PERF0PMED o
ALL NEEDED RESOURCES TO BE MADE AVAILABLE 1
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1 SR.VICE PRESIDENT NtlCLEAR J. I:ichard lS EERING J. McCauchy
.. Dale COMMITTEE a
J. Cross T. Cloninger i
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nsultant) l; PROJECT MANAGER Bechtel Member C. Tyrone R. Fron GE Member ASST. PROJECT MANAGER j
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SCllEDULER ENGINEER i
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4 NSSS/ BOP RETS ADMINTSTRATIVE AND DIRECTION M
MANAGER MANAGER MANAGER MANAGER I
D. S t( nestreet L. McKay C. Burgess J. lioberts i
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A. McCurdy S. liutchins PROJECT ORGANIZATION
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NORMAL ORGANIZATION
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DIRECT AUTil0RITY
COORDINATION AND EXPEDITTNG
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SAFETY LIMITS COMPLETE AND IN ACCORDANCE WITH DESIGN ANALYSIS LIMITING CONDITIONS FOR OPEPA'10N (LCO)
REFLECT THE NECESSARY FUNCTIONAL CAPABILITY OR PENORMANCE LEVEL OF
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EQUIPMENT REQUIPED FOR SAFE OPEPATION BASEP ON DESIGN ANALYSEC ACTION STATEMENTS VERIFY ACTION STATEMENTS ARE CONSISTENT WITH DESIGN ANALYSES SUPvEILLANCES TEST TYPES ACEOUATELY ADDRESS DESIGN REQUIREMENTS AND ALLOW CONSERVATIVE OPEPATION DUPING TESTING BASES CORPECT AND IN ACCORDANCE WITH' DESIGN ANALYSES DESIGN FEATUPES ENSURE DESIGN FEATUPES ARE CORPECTLY DESCRIBED ADMINISTRATIVE CONTPOLS VERIFY CONSISTENT WITH LlCENSING COMMITMENTS
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AND RESOLUTION DIRECT AND DISPOSITION
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NORMAL NPD DEVELOP l ORGANIZATION JUSTIFICATION l FOR RESOLUTION i
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REVIEW AND CHANGE NOT NEEDED FOR AGREEMENT WITH NRC EXCEEDING 5%
POWER CHANGE NEEDED FOR EXCEEDING 5% POWER g
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BECHTEL PRIORITY l - NEEDED PRIOR TO EXCEEDING 5% POWER.
PRIORITY 2 - NEEDED BUT NOT PRIOR TO' EXCEEDING 5% POWER.
PRIORITY 3 - POSSIBLY NEEDED FOR CLARITY.
0THER 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 14 - REVIEW AND RESOLUTIONS COMPLETE FOR B0P SCOPF.
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.
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4 MP&L/t1PC INTERFACE BETHESDA 0FFICE (FULL TIME' STAFF 0F 2) 4 DAILY-Il0RKING MEETINGS FOR PROBLEM P.ESOLUTION AtlD INTERFprE BRING HIGH PRIORITY ITEMS TO NRC ATTEt1TI0t! IMMEDI ATELY PEGULAR h'EEKLY MEETitlGS J
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i MPal/NRC INTERFACE SCHEDULE TECH SPEC REVIEW MANAGEMENT MEETING 3/9 OBTAIN NRC INPUT 3/9 INEL REVIEW NRR PROOF & REVIEW REGION II REPORT (WEEK OF 2/20 INSPECTION)
OTHER INFORMATION j
INITIATE INTERFACE WITH NRR PROJECT MANAGEP.
3/13 FIRST REVIEW AND PRIORITIZATI0f: MEETING 3/14 8 15 REGULAR WEEKLY MEETINGS 3/21 8 22 (TENTATIVE SCHEDULE) 3/28 8 29 4/4 - 6 MP&L CERTIFICATION LETTER NOT LATER THAN 4/9 i
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MP&L DEDICATED TO A QUALITY AND TIMELY PP.0GPAM o
COPHITMENT OF SUBSTANTIAL RESOUPCES TO SUPPOPT PPOGRAM o
NEED NRC AVAILABILITY AND SUPPORT o
PROGPAM WILL YIELD ASSURANCE OF ADEQUATE AND ACCUPATE TECH SPECS TO SUPPOPT GGNS OPERATION S
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MISSISSIPPI POWER & LIGHT COMPANY i
Helping Build Mississippi
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5 March 18, 1984 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. Harold R. Denton, Director
Dear Mr. Denton:
SUBJECT:
Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 License No. NPF-13 File 0260/L-860.0 GGNS Technical Specification Review Program AECM-84/0183 Your letter to Mississippi Power & Light (MP&L) Company, dated February 24, 1984, requested MP&L to perform a review of the Grand Gulf Nuclear Station (GGNS) Technical Specifications and certify that they accurately reflect the plant, the FSAR, and the SER analyses. An interim response was submitted to your office on March 8, 1984 (MP&L letter serial AECM-84/0154) to advise you that MP&L has undertaken a detailed review of the GGNS Technical Specifications to confirm their accuracy and adequacy for safe operation of Grand Gulf No. 1.
MPSL met with your staff on March 9,1984, to present the proposed review program and to elicit your cooperation and support in this effort.
This submittal represents the formal documentation and description of the GGNS Technical Specification Review Program presented to your staff in the March 9, 1984 meeting. The program, as described herein, is considered to be fully responsive to recent Nuclear Regulatory Commission questions / concerns surrounding the Grand Gulf Technical Specifications. The program is estimated to require a total of five weeks to complete, is presently on schedule and is estimated to end on April 6, 1984.
It is MP&L's intention to formally respond to your February 24, 1984 letter no later than April 9, 1984.
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' MISSISSIPPI POWER & LIGHT COMPANY F2 Your cooperation and support is requested, as discussed in the program description, to ensure that the program objectives - can be met in a timely and quality fashion.
Please advise if you have any questions regarding this submittal.
I Yours truly, W
L JPM:Im N
Attachment
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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 J
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i GRAND GULF NUCLEAR STATION TECHNICAL SPECIFICATION REVIEW PROGRAM PROGRAM DESCRIPTION MISSISSIPPI P0bER & LIGHT COMPANY MARCH, 1984 ADI
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d GRAND GULF NUCLEAR STATION TECHNICAL SPECIFICATION REVIEW PROGRAM i
A.
Introduction B.
Objectives and Review Concept C.
Management Control Requirements D.
Organization and Review Execution i
E.
Review Scope and Criteria
. i 21.
F.
Review and Closure Process G.
MP&L/NRC Interface H.
Schedule I.
Summa ry 9
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T A.
Introduction The NRC letter to Mississippi Power & Light Company (MP&L), dated February 24, 1984, requested a review of the Grand Gulf Nuclear Station (GGNS) Technical Specifications be provided wi;hin 10 days of receipt of that letter.
Based on various discussions held with 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 the station technical specifications and associated documentation.
The Technical Specification Review Program was described to the NRC j
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 commitments in this matter. Where possible, clarifications and additional detail have been included 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 Program will be properly categorized and dispositioned according to approved procedures. The overall goal is to assure accurate and adequate specifications.
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 be documented and dispositioned according to the program's procedures.
.B.
Objectives and Review Concept The primary objectives of the Review Program are as follows:
l.
To verify consistency of the plant's technical specifications with the as-built plant configuration, the FSAR, and *.he NRC
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Staff's Safety Evaluation Report (SER) on GGNS (NUREG-0831).
l 2.
To identify, submit, and support issuance of necessary changes to the technical specifications in a timely manner.
L 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 that the technical specifications are consistent with (1) the as-built plant configuration and (2) the current FSAR and SER as amended through Supplement No. 4.
To accomplish this,:the review criteria will be used to evaluate the specifications ahainst as-built documentation; where appropriate, field walk-downs will be conducted.
This review concept uses' the current technical specifications (through Operating License Amendment No. 12) as the basis for i
review and compares that basis against the above noted documents.
To provide assurance that technical specification related commitments contained in various licensing documents are considered y
in the review, a computerized commitment tracking system will be i;
utilized.
Use of this system is discussed further in Section E.
i In addition to the review of the technical specifications against the above described documents, a comparison of the GGNS Technical Specifications to the BWR-6 Standard Technical Specifications (STS) 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.
Additional detail on the review scope, method, and criteria is presented in Sections E and F.
C.
Management Control Requirements Several measures have been incorporated into the Review Program to ensure a quality result.
Some of the more significant management controls are 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 j.
Senior Vice President - Nuclear.
1 3.
The Review Program activities will be conducted and controlled
'I in accordance with a definitive, approved procedure.
.t 4.
The review of each technical specification section and disposition of discrepancies identified will be thoroughly documented.
=4 5.
The Review Program is fully auditsble, and Quality Assurance will conduct audits of the Program's implementation and a
effectiveness.
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Significant management attention has been focused on this very critical activity. All resources necessary to implement and execute this program will be made available.
7.
To provide an independent assessment _ of 'the progr m's effectiveness, MP&L management has retained Impell Corporation to review the program, inspect work activities in progress, and provide a report on the adequacy of the program.
D.
Organization and Review Execution 5
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 directly responsible for the program's implementation and effective execution.
By reporting to the highest level of 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 alignment also 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 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 F.chtel.
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.
2.
Review Organizations
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At the core of the program's organization are four principal Three groups conduct detailed reviews of specific groups.
areas, and the fourth group evaluates the detailed review i
results, assigns priorities, and coordinates appropriate i
corrective actions.
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Consistent with the program's review concept (Section B), the l
review organization is configured to use the technical specifications as the base document to which other licensing and design documents will be compared. insure a thorough' review This conce E
l specifications.
In keeping with this approach, the technical L
specifications have been divided into three major areas.
L These three areas are defined as:
1.
Technical specifications primarily associated with equipment or systems provided by the Nuclear Steam System Supplier (NSSS) or by the Balance of Plant (BOP)
- supplier, 2.
Radiological effluent technical specifications, and 3.
_ Technical specifications related to administrative areas or controls.
A lead review organization is assigned to each of the above.
. listed a.reas.
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 supervised by the NSSS/ BOP Manager, who is an MP&L employee.
Reporting to the NSSS/ BOP Manager are the NSSS Manager and the BOP Manager, both of whom are MP&L employees. These two managers coordinate the activities of the NSSS review organization and the BOP review organization. These three managers are located on site.
Also reporting to the NSSS/ BOP Manager is an Onsite Review Team (ORT). This, team is composed, as a minimum, of the following:
(a) A GE or BPC engineer.
(b) An MP&L NPE engineer.
(c) An MP&L Senior Reactor Operator.
The initial review for the NSSS/B0P Review Group will be conducted by GE and BPC as the lead review organizations
'(LRO), each according to a defined Division of Responsibility (DOR) for the technical specifications. This review will in-L part be conducted at the LRO's home office, with some field i
' verification conducted at the plant site. The total number of i
personnel involved in the NSSS/ BOP review, including all l
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/B0P Group Manager who then asrigns 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 summary, 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/B0P 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 necessa ry.
This position will be filled continuously for at least the initial month of review and, thereafter, on an "as-needed" basis.
2.2 RETS and Administrative Review Groups The Radiological Effluent Technical Specification (RETS)
Review Group and Administrative Review Group have a substantially smaller scope than that of the NSSS/B0P Review Group. Both groups are supervised by MP&L employees, specifically selected for their background and experience in their respective areas. The RETS review effort is directed by the MP&L Manager of Radiological and Environmental Services.
The Administrative Review Group is directed by a knowledgeable engineer from the MP&L Quality Assurance organization.
Both groups, upon generation of a specification review package, 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.
This group consists of representatives from Nuclear Plant Engineering (NPE), Plant Staff, Nuclear Safety & Compliance (Nuclear Services), and selected consulting engineers.
The role of this group is discussed in more detail in Section F.
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Review Scope and Criteria 1.
Review Scope 1.1 Specific Objectives in Technical Specificati n Sections As discussed in Section B, the review objectives are to review the technical specifications and verify consistency with principal design and licensing documentation. The Review Program's objectives relative to the specific sections of the technical specifications are discussed below:
(a) Safety Limits - Verified to be complete and in 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 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.
~
(h) Administrative Controls - Verified.o be consistent with relevant licensing commitments.
Each lead review organization, based on the technical 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 majority 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:
GE/BPC - These organizations, reporting to their respective MP&L NSSS or B0P 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 defined in the approved DOR. Their review will also cover all Definitions, Bases or Design Features associated with an assigned specification.
AD8
7 RETS Review Group - This group, as the title implies, will review primarily technical specifications Sections 3/4.11 and 3/4.12, effluent and radiological monitoring, respectively. :0ther appropriate areas will be assigned by the DOR. The 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:
Section 1.0 - Definitions Section 5.0 - Design Features 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.
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)
- Applicable to P.ETS 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 outstanding items previously identified in several MP&L 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 appropriate corrective action directed and tracked.
AD9
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,.,n.,_g As a matter of completeness, steps will be taken to identify and properly resolve open commitments in the FSAR and other licensing documents that relate to the technical specifications. Toaccomplishthijtaskthe already existing Licensing Commitment Tracking System-(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, SER and supplements, 1
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 specifications 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 i
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.
Priority 2:
Problems / enhancements requiring resolution.
All items included here are considered to have minimum or ng safety significance where operations above 5% power is clearly justified from a "significant safety hazard consideration" aspect.
Items in this priority are, therefore, considered to be required, if at all, on a long term schedule.
Priority 3:
Items classified in this priority are generally 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, t
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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 case, have insufficient safety'sigdificance 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
.t' Overall Process and Procedural Controls
~
1.
1 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, identified in Figure D-1, and presents the process through the
. ultimate closure of the review packages. In some cases, closure includes the NP&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 c
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 This specification with any potential problems identified.
package, is then forwarded to the RPD Group for further '.
processing. The RPD Group will review the package, regardless t
of the absence or presence of discrepancies identified by the l
primary review group.
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 L
to the same criteria that is applied to any item identified in the current Review Program.
Items determined to involve a l
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E potential technical specification change will be assigned an appropriate priority by the RPD Group and processed along with those items identified in the Review Program.
i 3.
Review, Prioritization, and Direction Group Activities The primary functions of the RPD Group are to:
(1) evaluate findings forwarded to it, (2) assign priority to potential changes to the ' specifications, (3) direct necessary corrective action, and (4) concur with findings or adequacy of completed or proposed corrective actions.
Upon evaluation of a documentation package (or item identified from outside source), the RPD Group has the following general options to select:
(1) Concur that no discrepancies exist which require additional actions; recommend closure to Project Manager.
(2) Find that a potential specification change is warranted, 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 support is required. This assistance is provided by normal organizations within MP&L's Nuclear Production Department.
Examples 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 package.
It should be noted that it is not MP&L's intention to maintain 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 means, utilizing currently existing procedures for changes to the technical specifications. Adequate closure documentation will be established in all cases.
4.
Processing of Potential Technical Specification Changes Once a potential specification change is identified, the development of a " Proposed Change to the Operating License" AD12 r r: L
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(PCOL) package is initiated. The initial step here is to l
generate proper " marked up" pages of the affected current technical specification (s) and to develop adequate justification for the proposed change. Justifica[ ion 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 FCOL package development is addressed entirely in existing administrative procedures.
,s j
As shown in Figure F-1, with the development of the proposed change's justification, MP&L will r.equest an ir. formal l
discussion and tentative agreement, if possible, with NRC Staff representatives on the proposed change. This step is primarily to agree on the significance of the item, the l
assignment of proper priority, and adequacy of jt.stification.
l If MP&L and the NRC concur that the change requires processing l
prior to exceeding 5% power, then the PCOL will be processed l
and formally submitted without delay. The PCOL review process includes formal safety committee review (Plant and Corporate).
l l
If the subject change is agreed upon to have a longer term priority, 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 l
actions directed and accepted by the RPD Group. For l
corrective actions incomplete at the time of package closure, I
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 As discussed with the NRC Staff in the meeting held March 9, 1984, MP&L has taken immediate steps to provide optimum support of the
,(
NRC Staff review associated with this program.
For the duration of
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the Review Program, MP&L will staff a local Bethesda, Maryland l
office with two full-time MP&L employees from the Nuclear Services 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 l
and principal staf f reviewers to support expeditious problem resolution and to maintain effective communications on the status l
[
of MP&L and NRC ef forts. These meetings should also provide a convenient means for bringing high priority items to the NRC's l
immediate attention. Weekly meetings are proposed to provide l
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proper NRC/MP&L communications at a management level and also to efficiently utilize specific expertise, as required, to resolve problematic items.
AsindicatedinFigureF-1,MP&LintendstoprovidetbNRC preliminary information regarding potential specification changes.
This is the responsibility 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 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 known to date. The program has been estimated to require 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 l
changes. By that time the NRC and MP&L will have also discussed 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 p' ents the program's schedule, including principal milestons.
MP&L will respond to the NRC letter on this matter (Eisenhut to Richard, dated February 24, 1984) no later than the conclusion of the program's fifth week, i.e., April 9, 1984.
I.
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 Culf technical specifications.
Substantial resources have been dedicated to support this program 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 ef fort.
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 i
March 12, 1984.
Steps such as these and, in general, a close l
working relationship and dedication of resources are requireil to i
ensure a timely and efficient execution of the program.
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i Overall, providing the dedication and efficient use of resources and effective communication between the NRC and MP&L, this Review Program will meet schedule objectives and yield the necessary i
assurance that the Grand Gulf technical specifications {are adequate and accurate, that is, consistent with the plant's destgn basis and sufficient to support safe operation.
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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.).
y 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 57. Thermal Power.
2.
Problems / Enhancements Needing Resolution - 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 or confusing items in Technical Specifications which will not result in non-conservative operation with a reasonable dependence on administrative controls / plant knowledge / operational practice ; 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-Justified.
- 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 1
product inventory considerations (generally priority IB do not involve dealing with high fission product inventories while priority IC which is associated with higher power levels may involve dealing with high fission product inventories), and relative safety significance of systems.
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TABLE E-1 (Continued) i I'
C.
Design Changes which require Tech Spec changes.
H.
Pending design / analysis (e.g., Maximum Extended Operating Domain, Exxon Fuel, Single Recire Loop Operation, etc.).
1 1.
Others.
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3.
Tech Spec change not justified.
A.
Item is generic and not included in STS.
l B.
Others.
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WASHINGTON, D. C. 20555 k,f.dh.//
APR 10 9 j
NOTE T0: 6 FROM:
W. Butler
SUBJECT:
CSB RELATED INPUT RE:
IDENTIFICATION OF MP&L TECHNICAL SPECIFICATION PROBLEM SHEETS TIIAT NEED RESOLUTION FOR LOW POWER OPERATION The CSB has completed the initial phase of the review request under TACS No. 54458. The review involved identifying those Technical Specification (TS) problem sheets for the Grand Gulf Nuclear Station, Unit 1, as prepared by MP&L, that need resolution for low power operation.
Three items are felt to fall into this category. They are items 292, 293, and 306. Enclosed are our comments on the problem sheets themselves that should be addressed.
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Enclosure:
As stated Containment Systems Branch, DSI l
cc:
R. W. Houston I
L. Kintner D. llo f fman l
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TECHNICAL SPECIFICATION PROBLEM SHEET Item Number:
306 Priority:
1B Val Malafew
/3-21-84 Identified By Date Responsible Supervisor Tech Spec
Reference:
Table 3.6.4-1 Tec.h Spec Page: 3/4 6-27 to 6-44 Problem
Title:
Containment and Drywell Isolation Valves 1.
Problem Description (Tech Spec, FSAR, SER, GE Design, Other):
Table 3.6.4-1 does not presently include combustable gas control system valves E61-F002 Q B; F004A & B; and the upper containment pool drain system valve G41-F265.-
gs~d~r vety it%N40Fm
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a ~{entit' hip W~
,rF--# {M _McamWConcerning valve isolation time used in the analyses of potential offsite releases.
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MP&L, in a letter from Mr. L. F. Dale to Mr. H. R. Denton, dated August 29, 1983,(AECM-83/0492), requested the maximum isolation times for these valves be changed from the present 30 seconds to 42 seconds.
2.
Safety Significance:
There is no safety significance concerning the valve omission, since valves E61-F002A & B and F004A & B are governed by the more restrictive requirements of Technical Specification 3/4.6.5.
Valve G41-F265 is operated only during a refueling outage, and if inadvertently lef t open, the resultant leakage into the drywell would be detected by the drywell leakage detection system.
owever, if the specified closing times for the RWCU pump suction valves aM not within the GE analytical limits, this may result in a radiological release llowing a RWCU pipe break in excess of previously analyzed releases, g
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TECHNICAL SPECIFICATION PROBLEM SHEET Item Number:
292/)(,3 Priori ty:
IB R. C Clayton
/3-19-84 R. Slovic Identified By Date Responsible Supervisor 4.6.1.3. d.2 [/], [., 2,.3,,.(, Q Tech Spec
Reference:
Tech Spec Page: 3/4 6-6 / g/t/ f ](,
Air Flask Pressure (Containment Air Lock)/(DA\\ll'r/4 A w. I C( h)
Problem
Title:
1.
ProblemDescriptjof(}e TechnicalSpecification4.6.1.3.gh, Spec,FSAR,SER,GEDesign,Other) d.2 requires verifying seal air flask pressure to be greater than or equal to 60 psig.
Technical Specification 4.6.1.3.d.3/./.t-a 4 J2 requires v.erifying that the system pressure does not decay more than 2 psig from 90 psig within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Based on this allowable pressure decay rate, the seal air flask pressure should be changed from 60 psig to a value at least 30 psig above the minimum required inflatable seal pressure. This will ensure adequate inflatable seal pressure for at least 30 days with no air sup;sy.
2.
Safety Significance:
' {"
None.
This change will ensure sufficient seal air flask pressure to maintain inflatable seal pressure above the minimum required value.
3.
Anticipated Resolution:
Performanevaluattp.n.todetermineifthe60psigvalueinTechnical t u. <
. ca, a r-Specification 4.6'..1.3.d.2should[bechangedandtowhatvalue.fBasedonthe results of that evaluation, recommend appropriate changes to the Technical Specifications.
4 NRC Response to item (NRR/IE):
NRC Notified:
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