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UNITED STATES 8
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 8
lER 0 91984
- ....o MEMORANDUM FOR: Commissioner Gilinsky FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
GRAND GULF SURVEILLAflCE PROCEDURES Your memorandum of itarch 2,1984 posed four questions on the problems identified with the Grand Gulf surveillance procedures.
Enclosed is the staff's response to those questions.
D William'J. Dircks Executive Director for Operations
Enclosure:
Answers to surveillance procedure questions cc: Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal OGC OPE SECY I
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i ENCLOSURE q
ANSWERS TO SURVEILLANCE PROCEDURE QUESTIONS 1.
"How many of the Grand Gulf licensed operating staff were originally i
examined by the NRC on the plant-specific simulator?
In the case of those
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who where (SIC) examined on another simulator, did the operating and i
emergency procedures that were used apply to Grand Gulf or to a different plant design?"
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Response
i There are twenty-nine (29) individuals currently on the Grand Gulf licensed i
operating staff. Some individuals have taken both plant specific and j
non-plant specific simulator examinations.
Five (5) individuals (of 29) were originally administered plant specific simulator licensing examinations by the NRC.
1 Twenty-two (22) individuals (of 29) were originally administered non-plant specific simulator licensing examinations by the NRC on the i
General Electric Perry Simulator.
The Grand Gulf operating and j
emergency procedures in effect at the time of these examinations were utilized as much as practicable. However, since these examinations i
were conducted on a non-plant specific simulator, certain portions of 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 l
after the NRC had discontinued administering non-plant specific
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simulator examinations but prior to Grand Gulf's simulator becoming l
operational.
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Sion II Operator Licensing Section on February 13-24, 1984, administered full plant oral and simulator examinations (equivalent to an initial licensing examination) to twenty-six (26) individuals on the Grand Gulf licensed operator j
staff. These examination utilized " current" plant operating and i
emergency procedures as well as the Grand Gulf plant specific simu-lator. Twenty-three (23) individuals passed these examinations. The l
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 the staff estimate were made at Grand Gulf? How many of these have been l
corrected?"
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.o Encl'sure 2
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Response
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 summary report after their surveillance procedure review effort, documenting the problems found, the corrective action taken, and the probable consequences had no corrective action been taken. That report, 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 j
the number of procedures that required revision.
The licensee has informed Region II that all known discrepancies in surveil-lance procedures required for normal operation (as distinguished from refueling or other special evolutions for which procedures are not yet needed) have been corrected. Region II has audited selected procedures to 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.
1 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?"
Response
Based on the Region II review of AECM-83/0622, 32 surveillance procedures were affected by Technical Specification changes which were required to be j
made to conform to the as-built plant.
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