ML20206U398
| ML20206U398 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/18/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206U390 | List: |
| References | |
| 50-416-99-02, 50-416-99-2, NUDOCS 9905250198 | |
| Download: ML20206U398 (74) | |
See also: IR 05000416/1999002
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-416
License No.:
Report No.:
50-416/99-02
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Waterloo Road
Port Gibson, Mississippi
Dates:
February 22-26 and March 8-12,1999
Inspectors:
M. Runyan, Senior Reactor Inspector, Engineering and Maintenance Branch
P. Alter, Resident inspector, Project Branch A
W. McNeill, Reactor inspector, Engineering and Maintenance Branch
J. Whittemore, Senior Reactor inspector, Engineering and Maintenance Branch
Accompanying
H. Anderson, Consultant
Personnel
B. Gupta, Consultant
Approved By:
Dr. Dale A. Powers, Chief, Engineering and Maintenance Branch
Division of Reactor Safety
ATTACHMENTS:
Attachment 1:
Supplemental Information
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Attachment 2:
Design Engineering White Paper
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Attachment 3:
Instrument Setpoint Program
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9905250198 990518
ADOCK 05000416
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EXECUTIVE SUMMARY
Grand Gulf Nuclear Station
NRC Inspection Report No. 50-416/99-02
Enaineerina
A noncited violation was identified concerning an unusually high number of errors that
were identified in the Updated Final Safety Analysis Report. The licensee's prior
contracted review had missed many of the discrepancies identified by the team. The
licensee's onsite review of the subject sections had not yet taken place. None of the
errors resulted in an operability concern. However, the number of errors identified
suggested a potential overall fidelity problem with the Updated Final Safety Analysis
Report, as well as suggested weaknesses regarding the adequacy of the Updated Final
Safety Analysis review and update project (Sections E1.1.1, E1.2.1, and E8.8).
A noncited violation was identified for failure to ensure that Valve P81-F032A, " Engine A
Air Motors (2) Air Supply," which provides starting air to the high pressure core spray
dit:sel generator, remained open, as required. The team found this valve to be partially
closed. A concern was ider,tified that the design of the system combined with licensee
operating policies (these va ves were not locked open) could result in failure to detect
mispositioned diesel air supply valves. The team did not find any requirement for the
licensee to lock these valves open; although, this is the normal industry practice given
the importance of these valves and their susceptibility to mispositioning (Section E1.1.3).
.Setpoint and scaling calculations did not exist for many of the technical specification
parameters associated with the diesel generators, and a setpoint calculation reviewed
by the team was observed to be marginal, in that it did not address loop uncertainties or
sensor types and installations. The adequacy of the bases for instrument setpoints was
considered unresolved pending further NRC review (Section E1.2.1).
The licensee was satisfactorily implementing the requirements of 10 CFR 50.59 for
applicable changes, tests, and experiments. Initial training for individuals performing
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safety evaluations was adequate; although, formal requalification training was not being
conducted (Section E2.1).
The corrective action program was effective in the identification of design and design
basis issues related to the emergency diesel generators. With respect to problem
resolution, ono notable exception involved an issue related to the Division 111 emergency
diesel generator lube oil inventory, where an excessive oil consumption problem created
inconsistencies between the technical specification bases and the design bases.
Additionally, the team identified three other instances in which the corrective actions
were either limited in scope or did not fully resolve the problems (Section E2.2).
The licensee's temporary modification program was sensitive to design issues and
effectively preserved the design bases for equipment and systems affected by
temporary alterations. However, a problem was identified concerning the
documenting of justification for temporary alterations that remained open past
the original corrective action due date. However, a recent NRC inspection (NRC
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Inspection Report 50-416/99-03) of the li:ensee's corrective action program identified a
concern with the control and tracking of tamporary or interim solutions, some of which
may have been used instead of the modifcation process (Section E2.3).
Five motor-operated valves had marginal thrust capabilities to perform their design
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safety functions. Depending on the available thrust margins, this could result in a trip of
the torque switch and a valve stopping in midcycle. The licensee intended to modify
these valves during the next two refueling outages (Section E8.1).
Corrective actions for two previous violations were limited in scope (Sections E8.2
and E8.3).
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Report Details
Summary of Plant Status
The unit was shutdown during the first week of the inspection to repair a mein condenser boot
seal. The unit operated at full power during the second week of the inspection.
111. Enaineerina
E1
Conduct of Engineering
E1.1
Diesel Generators and Ventilation - Mechanical
E1.1.0
System Description
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The plant included three separate, independent diesel generator systems (two standby
diesel generator systems and one high pressure core spray system diesel generator
system). Each of these diesel generator systems was housed in a dedicated room.
Each system had a separate, outside underground fuel oil storage tank with capacity
sufficient to operate the respective diesel generator under postulated loading conditions
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for a period of 7 days. Fuel oil was transferred by a dedicated fuel oil transfer pump
from the respective storage tank to the associated diesel generator day tank. Each
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diesel generator had a separate engine lubrication system. Each diesel generator had
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an air-start system that was rnaintained at an adequate capacity to enable at least five
successive start attempts without recharging. Each diesel generator's jacket cooling
water system removed heat during operation and provided a " keep warm" function
during standby conditions. Each diesel generator room had a separate ventilation
system to provide room temperature control and a sufficient supply of incoming air to
support the combustion process.
E1.1.1
Desian Review
a.
Inspection Scope (93809)
The team reviewed mechanical calculations, drawings, procedures, test results,
licensing and design basis information, other related documentation, and the as-
installed plant condition to ascertain the consistency and accuracy of design information
pertaining to the diesel generators, supporting ventilation systems, and associated
switchgear.
b.
Observations and Findinas
The team identified several discrepancies involving the Updated Final Safety Analysis
Report, design calculations, and drawings as discussed below. Unless stated, these
items were not previously identified by the licensee.
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Updated Final Safety Analysis Reoort Discrepancies
1.
Updated Final Safety Analysis Report, page 9.5-24, indicated that the high
pressure core spray diesel generator day tank was located above the
suction elevation of the motor-driven fuel oil pump to assure a slight positive
pressuie at the pump inlet. This elevation difference was questioned by the
team during the plant walkdown. In response, the licensee initiated Condition
Report CR-GGN-1999-0256 to document that the day-tank was actually slightly
below the suction elevation of the motor-driver. fuel oil pump by a small amount
(several inches). The team determined that the as-built configuration did not
present an operational concern because the elevation differences were not large
enough to cause a net positive suction head problem.
2.
Updated Final Safety Analysis Report, pages 9.5-25a/26, indicated that Entergy
Mississippi, Inc., has fuel oil storage facilities at two of its conventional power
plants - Baxter Wilson Steam Electric Station (had 50,000 barrels storage
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capacity) and Natchez Plant (had a 5,000 barrel storage capacity). The storage
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facilities at both of these plants were stated as being rnaintained at 50-percent
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capacity or greater. The licensee had previously identified and confirmed that
these capacities were not maintained as indicated in the Updated Final Safety
Analysis Report. The team determined that the failure to meet the stated
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capacities did not represent an operational concern because other sources of
fuel oil were available.
3.
Updated Final Safety Analysis Report, page 9.5-30, indicated that the standby
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diesel engine and the high pressure core spray diesel engine can operate for a
minimum of 30 days without additional Jacket water being required. The licensee
had previously identified that this statement could not be met. The team
determined that the manual makeup capability was sufficient to ensure continued
operability of the diesel engines.
4.
Updated Final Safety Analysis Report, Table 9.5-3, incorrectly indicated a heat
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removal design margin of 175 percent for the diesel generators (Divisions I and
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ll). This should have been 34 percent. The team determined that the 34 percent
margin was satisfactory.
5.
Updated Final Safety Analysis Report, page 9.5-37, indicated that the standby
diesel generator air-start system piping was installed at an elevation lower than
the engine inlet, and was provided with a drip leg to provide for removal of any
water, which may accumulate in the lines. After being questioned by the team,
the licensee's representatives reviewed drawings and determined that the
system piping between the air receivers and the engine inlet was not always at
an elevation lower than the engine inlet. However, the air-start system piping
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installation was configured so that drainage of moisture would be toward the drip
legs and away from the inlet air-start solenoid valves to the diesel generators.
Therefore, the team determined that the piping, as configured, would not be
vulnerable to moisture accumulation.
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6.
Updated Final Safety Analysis Report, page 9.5-37a, indicated that the
performance of the diesel generator air-starting system filters and strainers for
the standby diesel generators was monitored by a pressure sensor located just
upstream of the solenoid valves, which admit air to the air header on the engine.
The report also stated that the pressure sensor detected pressure downstream
of the final strainer. During the walkdown, the team observed the pressure
sensor, but noted that it was not located just upstream of the solenoid valves and
was also not located downstream of the final strainer. The team determined that
the installed pressure sensor configuration did not cause an operability problem
but that it did raise a concern related to the ability to detect mispositioned valves
in the air-start system, which is discussed in Section E1.1.3 of this report.
7.
The Updated Final Safety Analysis Report, Chapter 3, discussion of a
commitment to Regulatory Guide 1.137, " Fuel-Oil Systems for Standby Diesel
Generators," January,1978, did not list several nonconformances to the
Regulatory Guide or to the standard it endorsed (ANSI N195-1976, " Fuel Oil
Systems for Standby Diesel-Generators"). These nonconformances are listed
below:
(a)
Suction from the day tanks was essentially from the bottom (only slightly
offset from the bottom), whereas ANSI N195-1976, Section 6.1," Tanks,"
stipulated that the suction from the day or integral tank or tanks shall be
from above the tank bottom. No exception was identified in the Updated
Final Safety Analysis Report discussion (on page 3A.1.137-1/-2) of the
nonconformance with the Re Mory Guide / ANSI Standard in this regard.
The licensee initiated Condition Report CR-GGN-1999-0325 to document
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this discrepancy. The team did not consider the day-tank fuel oil suction
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configuration to represent an operational concern because, historically,
sediments have not been a concern in these tanks.
(b)
Flame arrestors were not installed in the fuel oil storage tank gooseneck
vents. The Updated Final Safety Analysis Report included a statement
that the flame arrestors were not installed. However, no exception was
identified in the Updated Final Safety Analysis Report discussion (on
page 3A.1.137-1/-2) of the nonconformance with the Regulatory
Guide / ANSI Standard in this regard (which required that flame arrestors
be installed). Condition Report CR-GGN-1999-0325 was initiated to
document this discrepancy. Based on the configuration of the vents and
the lack of proximate, credible ignition sources, the team did not consider
the absence of the flame arrestors to constitute an operational concern.
(c)
ANSI N195-1976, Section 5.2," Single-Unit Nuclear Stations," indicated
that the onsite oil storage shall be sufficient to operate the minimum
number of diesel-generators following the limiting design basis accident
for either 7 days or the time required to replenish the oil from sources
outside the plant site following any limiting design-basis event, whichever
is longer. The licensee's representative was unable to locate
documentation that an evaluation was performed to determine the worst-
case replenishment time. Condition Report CR-GGN-1999-0331 was
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initiated to review this matter. Because of the nearby availability of many
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fuel oil sources, the team did not believe that the worst-case
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replenishment time would exceed 7 days.
(d)
ANSI N195-1976, Section 6.1, " Tanks," indicated that day-tank capacity
shall be sufficient to maintain at least 60 minutes of operation at the level
where oil is automatically added to the day tank. The day-tank level at
which the associated transfer pump starts corresponded to a volume
sufficient to maintain only 30 minutes (not 60 minutes) of operation.
Although the team did not have an operational concern with this design
feature, there was not a clear exception taken in the Updated Final Safety
Analysis Report (on page 3A.1.137-1/-1) to this apparent inconsistency
with the Regulatory Guide.
8.
Updated Final Safety Analysis Report, page 9.5-23, Section 9.5.4.2, indicated
that each standby diesel generator fuel oil storage tank included a usable
capacity of 62,000 gallons. This number was identical to the technical
specification requirement. Calculation MC-01P75-90190," Diesel Fuel Storage
Requirements for the Division i Diesel Generator," Revision 1, determined a
usable capacity of 61,914 gallons, which was then " rounded up" by 86 gallons to
62,000 gallons. The corresponding calculation for the high pressure core spray
diesel generator resulted in 41,158 gallons, which was also rounded up by 42
gallons to the Updated Final Safety Analysis Report / technical specification value
of 41,200 gallons. However, the team noted the calculation conservatively did
not include the much larger additional volumes that would be contained in the
ends of the horizontal tanks. These would more than offset the
nonconservatisms introduced by the rounding up operations. Therefore, no
operational concern existed.
9.
Updated Final Safety Analysis Report, page 9.5-23, Section 9.5.4.2, indicated
that, for each standby diesel generator, the fuel not consumed by the engine was
returned to the fuel oil drip tank from which it was pumped and returned to the
day tank by the fuel oil drip return pump. In response to the team's questions,
the licensee confirmed that this statement was not completely accurate because
it neglected the flow of unconsumed fuel oil from the injector pumps, which was
also routed back to the fuel oil day tank.
Combined with the discrepancies identified in Sections E1.2.1 and E8.8 of this report,
these errors raised a general concern with the fidelity of the Updated Final Safety
Analysis Report. However, no operability concerns were raised as a result of the
identification of these discrepancies.
10 CFR 50.71(e) requires that the safety analysis report be periodically updated to
ensure that the material contained in this document remains accurate. The licensee's
failure to correctly update the items discussed above and those items listed in
Sections E1.2.1 and E8.8 of this report represent a violation of 10 CFR 50.71(e).
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The licensee was in the process of reviewing the Updated Final Safety Analysis Report
for accuracy and had not completed reviews of any of the sections reviewed by the
team. The team noted that the first-stage contractor reviews of these sections had
missed many of these discrepancies. The team did not believe that the licensee's
review would have likely identified most of the discrepancies identified by the team.
However, becana none of the discrepancies involved a safety or operability concem
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and the ;;censee immediately placed each discrepancy into their corrective action
program, this Severity Level IV violation is being treated as a noncited violation
(50-416/9902-01), consistent with Appendix C of the NRC Enforcement Policy. This
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violation is in the licensee's corrective action program as various condition reports that
were initiated to document these items (i.e., 1999-0256,1999-0325,1999-0331,
1999-0319,1999-0317,1999-0279, and 1999-0261).
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Following the onsite inspection, the licensee submitted to the NRC an " Engineering
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White Paper" (Attachment 2) to explain their position regarding the Updated Final Safety
Analysis Report discrepancies identified by the team. The white paper acknowledged
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the discrepancies, but emphasized the lack of safety significance resulting from the
identified errors and the fact that some of the items were more misleading than
incorrect. The team concurred with this assessment.
Desian Calculation Discrecancies
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Calculation 7.6.9C, " Diesel Generator Fuel Oil Supply System - Calculate the Discharge
Pressure for the Diesel Generator Fuel Oil Transfer Pumps," Revision C, was based on
seven 90-degree elbows in the fuel oil transfer line from the underground transfer
pumps to the respective fuel oil day tanks. The sketch contained in the calculation
indicated there were eight 90-degree elbows. The licensee's representative verified
from plant drawings that there were actually more than eight 90-degree elbows in the
respective lines. The licensee initiated Condition Report CR-GGN-1999-279 to
document this discrepancy. Based on the available margin, the team confirmed that this
discrepancy did not affect the operability of this system.
Calculation 7.6.26, " Standby Diesel Generator System - To Determine the Line Size for
the Discharge Line from PSVF026 A & B," Revision 0, did not address, in evaluating the
potential back pressure on the relief valve, that there would be flow in the subject
discharge line from both the relief valve (when the relief valve is open) and the injector
pumps' lubrication flow (when the diesel generator is running). The calculation
conservatively evaluated the flow from the relief valve through the discharge line at
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35 gallons per minute, and evaluated a maximum allowable backpressure on the relief
valve of 4 pounds per square inch. The calculation did not address the cor$stant
backpressure on the relief valve, which would result from the injector pumps' lubrication
flow when the diesel generator was running. Because this effect was enveloped by the
other conservatisms in the calculation, the team had no concerns with the final result of
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the calculation.
The team noted that these calculational discrepancies did not affect the operability of
the affected systerns.
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Drawina Discrepancy
The "as-surveyed" elevation levels from Calculation SC-1P75-LT-N004, " Standby
Diesel Generator Fuel Oil Day Tank Volume and Level Instrumentation Scaling
Calculation (1 P75-LT-N004A&B,1 P81-LT-N004)," Revision 0, were identified by the
team to differ from Drawing J-1692, " Level Setting Diagram Standby Diesel Generator
Fuel Oil Day Tank A (B) Q1P75A004A (B)," Revision 5. In response to the team's
finding, the licensee issued Condition Report CR-GGN.1999-0328. The team evaluated
the olevation differences, which were in the range of severalinches, to be of no
operational concern.
c.
Conclusions
The team identified several discrepancies in the Updated Final Safety Analysis Report.
This was identified as a concern related to the fidelity of this document. The subject
sections of the Updated Final Safety Analysis Report were reviewed previously by a
licensee contractor as part of the fidelity review program (discussed in Section E8.8 of
this report). This review missed many of the problems found by the team. However, the
licensee had not completed the onsite review of the contractor's work. While none of
the errors resulted in an operability concern, multiple problems were identified by the
NRC as noted further in Sections E1.2.1.b and E8.8.b.
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' The team identified several minor errors in calculations and drawings but did not
consider the number or nature of these items to be excessive. None of the
discrepancies identified resulted in an operability concern.
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E1.1.2
Surveillance Test
a.
Inspection Scope (93809)
The team reviewed surveillance test documentation in relation to fuel oil transfer pump
inservice performance, starting air receiver tank / starting air system leakago testing,
starting air admission solenoid valve operation, relief valve set pressure testing, and
Jacket water cooler and heat exchanger performance.
b.
Obsenvations and Findinas
No significant concerns were identified concerning these test results. However, the
team noted that there existed a potential for instrument measurement uncertainties to
mask the results of the starting air receiver tank and starting air system leakage tests.
This was because the measured leakage was often less than the instrument uncertainty.
However, because tra measured leakage was less than the limiting values, the team
considered the results to be acceptable.
c.
Conclusions
Surveillance test results reviewed by the team were satisfactory.
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E1.1.3
System Walkdown
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a.
Insoection Scoce (93809)
Team members participated in a walkdown of the standby diesel generators (Divisions I
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and 11), the high pressure core spray diesel generator (Division Ill), and associated
ventilation systems. The plant walkdown, however, concentrated on the Division I and
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lli diesel generator rooms and associated equipment.
b.
Observations and Findinas
At 11 a.m. on February 23,1999, the team found High Pressure Core Spray Diesel
Generator Starting Air System Manualisolation Valve P81-F032A," Engine A Air Motors
(2) Air Supply," partially closed. The valve's self-locking operating lever was found
unlatched with the lever not in line with the system flow path. The three other
corresponding isolation valves were found to be fully open, as required. The system
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engineer who was present at the time informed the control room and the team verified
that the valve had been restored to a fully open position by 1 p.m. on the same day.
The licensee initiated Condition Report 1999-0235 and performed a valve lineup
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verification on the high pressure core spray diesel generator starting air system.
No other mispositioned valves were discovered. The licensee speculated that the valve
was inadvertently bumped during maintenance work.
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The position of Valve P81-F032A was not routinely checked on the nonlicensed
operators, "Outside Rounds Sheet," Revision 102. A valve lineup was also not required
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as part of Surveillance Procedure 06-OP-1P81-M-0002,"HPCS Diesel Generator
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Functional Test," Revision 104. The system engineer reported that the position of this
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valve was monitored by a low pressure switch, PSL-N111 A, located downstream of the
valve, which causes a " Low Air Pressure" alarm locally and a common trouble alarm in
the control room. The team determined that a low pressure condition would not be
sensed by this pressure switch during a static standby condition with Valve P81-F032A
in a throttled position, in that significant pressure losses would only occur in the high-
flow conditions accompanying an engine start. However, in this instance, the other pair
of air-start motors for that engine would have been available, as well as both sets of air-
start motors for Engine B. Therefore, with starting air available to at least one half cf
the high pressure core spray diesel generator air-start motors, there was no operability
concern. Based on engineering judgment, the team considered the as-found
configuration of Valve P81-F032A to be such that there would have been no significant
restriction of air flow to the air-start motors. Based on these considerations, the team
agreed with the licensee's assessment that operability was not affected by this incident.
Grand Gulf Technical Specification, Section 5.4.1, requires that written procedures be
established, implemented, and maintained for the following activities: (a) the applicable
procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February
1978. The requirement applies to system operating procedures for the high pressure
core spray diesel generator. System Operating Instruction 04-1-01-P81-1,"High
Pressure Core Spray Diesel Generator," Revision 44, Attachment 1," Manual Valve
Lineup Checksheet," requires Valve P81 F032A to be open. The failure to maintain
Valve P81-F032A in the open condition was a violation of Technical Specification 5.4.1.
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Because the high pressure core spray diesel generator remained operable and
immediate corrective action was taken by the licensee, this Severity Level IV violation is
being treated as a noncited violation (50-416/9902-02), consistent with Appendix C of
the NRC Enforcement Policy. This violation is in the licensee's corrective action
program as Condition Report 1999-0235.
The team identified a cor.cern related to the licensee's decision to not lock open the air-
start valves on the three divisions of diesel generators. As mentioned above, the
downstream pressure sensors would not detect a partially closed valve, nor would
operator rounds identify this condition. Therefore, if redundant air-start valves were in a
partially closed position, the diesel generator could potentially be unable to start;
although, this condition may not be discovered until the next monthly functional test.
The team discussed this concern with the licensee and determined that no regulatory
requirements were applicable to this matter.
In discussions following the exit meeting, the licensee's representative stated that the air
start valves were not locked open because they were redundant and no single valve
being out of position could cause a loss of function. This reasoning followed the
licensee's interpretation of single-failure protection. On the other hand, valves that
could singly defeat safety-related functions if mispositioned were placed into the locked
valve program. The team acknowledged the licensee's policy, but still considered the
general industry practice of locking these valves open to be prudent considering the
critical nature of these valves and their susceptibility to being mispositioned.
c.
Conclusions
A noncited violation was identified for failure to ensure that Valve P81-F032A, * Engine A
Air Motors (2) Air Supply," remained open as required. The licensee's detection
capability of mispositioned diesel generator air supply valves was limited.
E1.2
Diesel Generators and Ventilation - Electrical
E1.2.0
System Description
Normally, offsite power supplies the nonsafety-related buses and three 4.16 kV safety-
related Engineered Safety Features Buses 15AA,16AB and 17AC. On degraded
voltage or loss of voltage from offsite power sources, each engineered safety features
bus is supplied by its own standby diesel generator. The loss-of-offsite power or the
loss-of-coolant accident signals automatically start the standby diesel generators.
Standby diesel generator operation is supported by the auxiliary subsystems (fuel oil,
lube oil, jacket water, etc.) and by 4.16 kV engineered safety features distribution and
diesel generator building ventilation systems. In the event of a loss of offsite power or a
loss-of-coolant accident, all the loads are shed from engineered safety features buses
(except the loads connected by 480 motor-control centers) and are then reconnected
back to the bus sequentially after the diesel generators are supplying adequate voltage
and frequency.
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E1.2.1
Desian Review - Electrical
a.
Inspection Scoce (93809)
The team reviewed design documents including the Updated Final Safety Analysis
Report, design calculations, specifications, and drawings to determine the plant's
conformance to the design basis.
b.
Observations and Findinas
Updated Final Safety Analysis Reoort Discrepancies
The team identified several discrepancies in the Updated Final Safety Analysis Report,
as discussed below.
1.
Updated Final Safety Analysis Report, Section 8.3.1.1, page 8.3-1, stated that
during normal operation, with all three engineered safety features transformers
available, each division of load (i.e., Division I,11, and Ill) is supplied from a
separate winding of each two-winding engineered safety features transformer.
However, Division ll and Division lll were being supplied from the same
transformer (Engineered Safety Features Transformer 21). The team
determined that this configuration was acceptable from an operational standpoint
because Transformer 21 was capable of supplying the design loads with an
acceptable voltage profile and redundancy was maintained with two of the three
transformers lined up to supply power.
2.
Updated Final Safety Analysis Report, Figure 8.3-0078 (Grand Gulf Drawing E-
1026, "One Line Meter and Relay Diagram,120 and 240v ac Uninterruptible
Power Supplies" ), did not accurately represent the current plant configuration.
This figure, as identified by licensee records, was identical to Drawing E-1026,
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Revision 10, while the current plant drawing was Drawing E-1026, Revision 12.
The differences between these two drawing revisions were minor, mainly
consisting of changes to informational notes.
3.
Updated Final Safety Analysis Report, Section 8.3.1.1.3, page 8.3-9, stated that
the load shedding and sequencing system did not prevent load shedding of the
emergency buses in response to a loss of preferred power or a loss-of-coolant
accident signal once the onsite sources were supplying power to all sequenced
loads on the buses. This statement was misleading because it was true,
independent of the power supply status of the onsite sources.
4.
Updated Final Safety Analysis Report, Figure 8.3-9, and associated load
sequencing Drawing E-1039, erroneously showed a 0.9-second time delay for a
degraded voltage relay versus 9.0 seconds stated in the technical specifications.
This discrepancy was an editorial problem only.
5.
Updated Final Safety Analysis Report, Table 8.3-9, listed Load 1R20 FDR
Breaker 152-1603 (transformer for drywell chi!!ers) twice; once on page 3 and
again on page 4. There was no operationalimpact associated with this error,
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6.
Motor-operated valve loads were not accounted for within a listing of engineered
safety features bus standby diesel loads in Updated Final Safety Analysis
Report, Tables 8.3-1 and 8.3-2, and within Calculation E-DCP82/5020-1,
" Transient Loading on Diesel Generators during Load Sequencing," Revision A.
Even when motor-operated valves do not actuate, they require loading for
indicating lights, relays, etc. Additionally, motor-operated valves could actuate at
any time when certain operating conditions exist. As such, motor-operated
valves should have been included within the engineered safety features bus
loads for the standby diesel generators. The team confirmed that the failure to
list motor-operated valves within the loading analysis did not result in an
operability concern, as sufficient margin was available to account for motor-
operated valve operation.
These discrepancies, in combination with those discussed in Sections E1.1.1 and E8.8
of this report, were indicative of a fidelity problem with the Updated Final Safety Analysis
Report. This concern, along with the enforcement aspects of this issue, are discussed
in Section E1.1.1 of this report.
Technical Specification Bases and Plant Confiauration
The team identified the following two errors within the technical specification bases:
1.
Technical Specification Bases, page B 3.8-2, stated, "The load shedding
sequencer circuits actuate on loss of offsite power or a loss-of-coolant accident
signal. The system starts the diesel generators and, if an undervoltage exists on
a Division i or ll bus, it sheds nonvital loads from the affected bus." The team
identified two discrepancies associated with this description. The load shedding
sequencer sheds the loads whether bus undervoltage exists or not. Secondly,
all loads, including safety-related loads, would be shed except 480 V load
centers and motor-control centers. The team considered the as-built design of
this system to be acceptable, and the error to be editorial in nature.
2.
Technical Specification Bases, page B 3.3-226, stated that nominal trip setpoints
for plant instruments were specified within setpoint calculations. It further stated
that the analytical limits were derived from the limiting values of the process
parameters obtained from the safety analysis, and that the allowable values were
derived from the analytical limits, corrected for calibration, process, and some of
the instrument errors. However, there were no setpoint calculations delineating
the analytical setpoint values. This issue is further discussed below.
Setooint and Scalino Calculations
The team reviewed calculations and other documents to verify that the plant's analytical
parameters were properly represented in instrument setpoints and that scaling
calculations provided the required relationship of technical specification parameters
(such as fuel oil quantity in gallons) to the indicated plant values (such as a graduated
,
scale on a level indicator).
.
.
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The team reviewed a document entitled, " Methodology for the Generation of Instrument
Loop Uncertainty & Setpoint Calculations," GGNS-JS-09, Revision 0. The team noted
that the methodology did not identify or define technical specification allowable values
with respect to the methodology's allowable values. In response to the team's
questions, the licensee's representative stated that the methodology's analytical value
was the same as technical specification analytical value. Based on this response, the
team commented that the difference oetween the analytical value and the setpaint was
not adequate since it did not include measuring and test equipment uncertainties in the
difference. The narrow difference between the setpoint and the analytical value might
result in technical specification parameters being out of limits.
The team found that the licensee did not have setpoint and scaling calculations for
technical spec ~fication parameters involving the diesel generators. Also, no
,
documentation existed for recording loop uncertainties in the absence of formal setpoint
calculations. The licensee could not demonstrate the amount of loop uncertainties
(including measuring and test equipment) in support of the current setpoints.
The team reviewed Calculation JC-01P75-90040, " Standby Diesel Generator Fuel
Oil Day Tank Volume and Level Setpoint Calculation," Revision 3, for Level
Switches 1P75-LIS-N602A/B. These switches start the fuel oil transfer pump to transfer
dieseliuel from the storage tank to the day tank. The calculation relied on the day-tank
volume calculation to determine the inches of tank height (37.5 inches) where the
transfer pump should start. The calculation used 39 inches (allowing 1.5 inches margin)
as the setpoint to start the fuel transfer pump. The calculation did not include any
details about the type of level sensor, level sensor installation, type of level loop
components, or the compilation of any loop in accuracies or uncertainties.
1
The team reviewed Technical Specification Surveillance Requirement 3.8.3.1.a (fuel oil
1
storage tank 262,000 gallons of fuel for Diesel Generators 11 and 12). The team asked
for information that translated the tank volume to the indicated values including loop
i
uncertainties. Typically, a scaling calculation would have information about the tank
volume and level sensor details, including an installation drawing and other information
on other loop components such as the transmitter and indicator. A scaling calculation of
this type would compile total loop uncertainties, as applicable to the indicator, which was
used to meet the technical specification variable. However, the licensee did not have
j
any such calculation or documentation.
The licensee's setpoint calculational program did not address all the technical aspects
typically supporting setpoint and scaling calculations. The team was generally able to
determine that the current technical specification setpoints relating to the diesel
generators appeared conservative, but noted that the accompanying documentation was
not comprehensive. The adequacy of the bases for instrument setpoints will remain
)
unresolved pending further NRC review (50-416/9902-03).
I
Following the onsite inspection, the licensee submitted a document entitled " Instrument
Setpoint Program" (Attachment 3) to explain their position regarding the instrument
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t
setpoint program. This paper acknowledged the lack of calculational support for many
of the safety related setpoints in the plant, but emphasized that the methodologies used
t
to establish the setpoints were technically sound, and that the existing setpoints were
conservative. The team acknowledged this information. Through further inspection, the
NRC will determine whether the licensee's conclusions are accurate.
c.
Conclusions
The team did not identify any operability concerns related to the electrical design of the
diesel generators or associated ventilation and switchgear.
Numerous errors were identified within the Updated Final Safety Analysis Report, which,
when combined with those errors discussed in Section E1.1.1 of this report, raised a
concern with the general fidelity of the Updated Final Safety Analysis Report, and the
adequacy of the licensee's Updated Final Safety Analysis Report update and review
project.
The team determined that setpoint and scaling calculations did not exist for many
technical specification parameters, and one setpoint calculation reviewed by the team
was observed to be marginalin that the extent and quality of setpoint and scaling
documentation appeared to be lacking.
E1.2.2
Surveillance Test
a.
Insoection Scope (93809)
The team reviewed diesel generator electrical surveillance procedures to determine their
j
conformity with the plant's design and licensing bases. The team reviewed the
functional test and calibration data for the degraded voltage and loss of voltage
,
setpoints test performed on February 3,1999.
b.
Observations and Findinas
The reviewed surveillance procedures were satisfactory. The results of the test
described above were documented properly and test results were within acceptable
limits.
c.
Conclusions
The team did not identify any concerns related to surveillance testing of the diesel
generator electrical design features.
E1.2.3
System Walkdown
a.
Inspection Scope (93809)
The team conducted a walkdown inspection of the electrical portions of the standby
diesel generators and high pressure core spray diesel generator.
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b.
Observations and Findinas
The team found the visible electrical features of the diesel generators and suppor1
subsystems to be in acceptable condition,
c.
Conclusions
The electrical portions of the standby diesel generator and support system equipment
were in visually acceptable condition.
E1.2.4
Modifications
a.
Insoection Scoce (93809)
The team reviewed three modifications associated with the Division I and ll standby
diesel generators day-tank high level alarm and hardware evaluation in regard to
fire-induced failures of safety-related circuits,
b.
Observations and Findinas
The team found that these modifications were performed properly
c.
Conclusions
Modifications reviewed by the team were found to be acceptable.
E2
Engineering Support of Facilities and Equipment
E2.1
Evaluation of 10 CFR 50.59 Safety Evaluation Proaram
a.
Insoection Scone (93809)
The team reviewed procedures and other documentation, safety evaluations, and the
training and qualification program to determine whether the licensee was properly
implementing the requirements of 10 CFR 50.59,
b.
Observations and Findinas
Procedures
The team determined that the procedures defining the 10 CFR 50.59 program were
{
consistent with the requirements of 10 CFR 50.59.
!
Imolementation
The team reviewed 28 safety evaluations. Through discussions with licensee
representatives, the team was able to resolve all questions concerning these
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evaluations. In each case, the team concluded that the licensee's determination that an
unreviewed safety question did not exist was correct. Generally, the documentation in
{
the safety evaluations was adequate in scope to understand the issues without a need
to reference other documents.
Trainino and Qualifications
To be qualified to perform or review a 10 CFR 50.59 evaluation, an individual must have
completed an approved training course and be designated as a reviewer. The site
management was responsible for determining the technical competence of each
reviewer to perform evaluations in any particular area. The team reviewed various
I
training documents and determined that the level and depth of the training was
appropriate and consistent with the procedural guidelines.
'
However, there was no requireinent for formal requalification training on a periodic
basis. In response to this observation, the licensee's representative stated that there
were two rneans by which performers and reviewers of safety evaluations received
continuing training. First, the plant safety rcview committee's review of each safety
evaluation was viewed as a defacto requalification, in that, the individual would receive
feedback for any problems identified in one's work. The team considered this policy to
be adequate hr those individu@ who performed or reviewed evaluations on a regular
basis, but many reviewers did not coutinely perform evaluations. The second means of
continuing training was the required reading of quarterly safety evaluation newsletters,
which discussed ongoing issues related to violations of 10 CFR 50.59 and related policy
matters. The team reviewed a sampe of the newsletters and observed that they could
effectively enable such training. The 'icensee's representative also stated that the site
would be converting to an Entergy-wide 10 CFR 50.59 procedure before the end of
1999. The licensee's representative anticipated that this new procedure would provide
for requalification training; although, a final decision on this matter was still pending.
The team reviewed the licensee's list of approved 10 CFR 50.59 safety evaluators. A
total of 433 individuals were qualified as of October 26,1998.
c.
Conclusions
The licensee was satisfactorily implementing the requirements of 10 CFR 50.59 for
applicable changes, tests, and experiments. Initial training for individuals performing
safety evaluations was adequate; although, formal requalification training was not
offered at the time of the inspection.
E.2.2 Condition Reoorts
a.
inspection Scope (93809)
The team reviewed licensee Procedure 01-S-03-10,"GGNS Condition Report,"
Revision 3, and the condition reports listed in the attachment that reported anomalies
for the emergency diesel generators and their supporting systems. The sample was
selected to assess the effectiveness of the corrective action system to identify and
address design and design basis issues related to the emergency diesel generators.
.
.
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I
b.
Observations and Findinas
Division 111 Emeraency Diesel Generator Lube Oil Sumo Level
Condition Report 1996-0174, initiated by operations personnel, requested engineering to
define operability limits for the lube oil sump levels in the Division ill emergency diesel
generator lube oil sumps for standby and loaded conditions. (The level in the sumps
varied with the engine condition.)
According to the Updated Final Safety Analysis Report, Sections 9.5.7.2.1 and 9.5.7.2.2,
the Division 111 diesel generator lube oil sump tanks contained a sufficient quantity of oil
for 7 days of diesel generator operation at rated load without adding lube oil.
Table 9.5.6 of the Updated Final Safety Analysis Report also indicated that the total
capacity of each Division lli engine lube oil sump was 306 gallons with 234 gallons
usable.
According to Grand Gulf Nuclear Station System Design Criteria,"HPCS [high pressure
core spray) Diesel Generator System," Revision 0, Section 4.21, the high pressure core
spray (Division Ill) diesel engines ". . . shall have a lube oil pan with capacity to hold
sufficient usable lube oil for 7 days operation at rated load without replenishing the sump
lube oil inventory."
Technical Specification 3.8.3.B required that the usable sump inventory be at least
101 gallons. A level below 101 but greater than or equal to 87 gallons required the
emergency diesel generator to be declared inoperable if inventory was not restored to at
least 101 gallons within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. According to a licensee representative, the crankcase
dipsticks " FULL" and " LOW" marks equated to respective usable inventories of 101 and
87 gallons. The basis for Technical Specification 3.8.3.B was to provide sufficient oil to
operate at full load for 7 days, assuming the normal lube oil consumption rate. The
normal consumption rate, according to the vendor, was 0.6 gallons per hour and,
therefore,101 gallons of usable inventory would meet the 1-week (168 hour0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />)
requirement. With sump inventories less than a 7-day supply (below the " FULL" mark),
it was acceptable to operate with a 6-day supply (corresponding to 87 gallons) after
entering a 48-hour action statement that allowed time to replenish the oilinventory. Any
inventory less than or equal to the dipstick " LOW" mark would immediately place the unit
j
in an inoperable condition.
This documented guidance was complicated by the exhibition of different inventories
during standby and loaded conditions. The licensee had established that this difference
in inventory amounted to about 40 millimeters less on the dipstick when the unit was
running and loaded. The solution arrived at by the licensee was to calibrate and mark
the dipstick above the " FULL" mark, and maintain the inventory at least 40 millimeters
above the dipstick " FULL" mark in the standby condition. Thus, when a loaded run was
commenced, the drawn down oil inventory would be at the " FULL" mark and the facility
license condition would be satisfied. This action was completed and Condition
Report 1996-0174 was closed.
_-
_____
.
.
-19-
Condition Report 1998-0733 identified that under loaded conditions, the Division ill
tandem diesel engines were consuming oil at greater than the normal rate. Testing
eventually revealed a consumption rate of about 0.95 gallons per hour, which was about
'
60 percent above the vendor stated normal rate of 0.6 gallons per hour. The two
elements of oil consumption during operation of the equipment were thought to be oil
leakage anct the buming of oilin the engine during the combustion process. The
licensee was unable to quantify how much oil was leaking from the engines and how
much was being consumed by the combustion process.
The team recognized an additional complication that the licensee had not considered.
The pressure in a running engine crankcase is normally less than atmospheric due to a
crankcase scavenging system designed to minimize the buildup of explosive gasses in
the crankcase. For a running engine, the crankcase atmosphere is continuously
evacuated through a pressure regulating system to the turbo-blower. Because the
open-ended tube for the dipstick extends down into the sump inventory, there is
potential to displace the oil level in the tube and distort the level measurement if there is
a pressure difference between the crankcase and the room atmosphere. Therefore,
with a lower pressure in the engine crankcase, the dipstick would produce a reading
lower than the actual sump level. According to the licensee's representative, a
temporary sump level standpipe consisting of a clear plastic hose attached to a drain
line below the sump level was used for level indication during some of the engine test
runs. The same level anomaly would be produced for this configuration unless the
upper end of the standpipe was exposed to crankcase pressure. The licensee could not
provide a normal value for the crankcase pressure as this parameter was not logged or
recorded.
The licensee's representative stated that no exhaust gas analysis had been performed
to determine if lube oil was being consumed (burned) by the cylinder combustion
process, but inspections requiring some engine teardown were planned to see if this
problem existed. An engineering evaluation in Condition Report 1998-0733 steted that
burning oil would have made the engine exhaust gas dark and noticeable. The team
disagreed and believed that the combustion of lube oil in the engine cylinders would
have resulted in light blue or gray exhaust, similar to Otto-Cycle (gasoline) engines.
l
One solution considered by the licensee was to increase the sump inventory. However,
the standby level was already maintained 40 millimeters (1.57 inches) above the " FULL"
mark, and according to the vendor there was a max mum of 5 inches between the
extreme limit of engine crankshaft motion and the dipstick " FULL" mark. It was
undesirable for the crankshaft to interface with or rotate into the sump lube oil. In the
l
interim, the licensee had received conflicting data from the vendor regarding the sump
I
capacity and the usable portion of that capacity. Eventually, the licensee undertook
efforts to determine the exact volume of oil in the engine sump at various levels and to
further determine if there existed a usable volume that would meet the technical
I
specification basis for the increased consumption rate. At the start of the inspection, the
licensee could not verify if the diesel generator was operating within the design basis
(
during extended runs.
1
!
l
1
r
.
.
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Engineering Report GGNS-99-0005," Evaluation of DIV lli D/G Lube Oil Sump Volume,"
dated March 8,1999, was provided to the team on March 9,1999. The report indicated
that through an onsite testing effort and extensive consultation with the vendor, the
licensee had determined the following:
3.
Volume to " LOW" mark on dipstick was 58.8 gallons
4.
Volume to " FULL" mark on dipstick was 191.97 gallons
5.
Usable volume below the " LOW" mark was 19.67 gallons
Therefore, the total usable volume of 152.84 (191.97 - 58.8 + 19 67) gallons at the
dipstick full mark was not sufficient for 7-days operation, as indicated in the technical
specification basis. The licensee determined that 10 mm above the " FULL" mark would
satisfy the higher consumption rate. In order to accommodate the perceived drawdown
of 40 mm level between standby and full-load conditions, the licensee established a
standby level of 50 to 80 millimeters (1.97-3.15 inches) above the dipstick " FULL" mark.
The team was satisfied that the licensee's current operating procedures ensured that
the Division lli emergency diesel generator was meeting the technical specifications and
the design bases. However, the team determined that, because of the excessive oil
consumption rate, the design criteria and design basis were not consistent with the
technical specification limits or bases. Also, the team was unsure if the licensee had
accurately determined the oil consumption rate. The licensee was aware of the need to
address the differences that existed among the design criteria, the design bases, and
the license limit / bases.
The licensee's handling of this event was lacking in that it appeared that the final
resolution of the issue was driven by the questioning from the team. However, the team
determined that the safety significance of the event was low because the licensee was
capable of adding lube oil while the unit was operating.
Installation of Wrona Breaker
Condition Report 1997-0758 reported the installation of a wrong breaker in a safety-
related application for the Division I emergency diesel generator jacket water heater.
This problem was identified during post-maintenance testing and the incorrect breaker
was never placed into service. The new breaker that was installed was a spare breaker
from a cubicle in the same switchboard. Apparently, craft personnel performing the
work order met the intent of Procedure 07-S-01-205," Conduct of Maintenance
Activities," Revision 102, as they verified that the new breaker model number was
identical to the breaker that was replaced. However, unknown to craft personnel, the
current transformer that provided input to the breaker trip coil was different in the new
breaker; hence, the breaker overcurrent trip setpoint was different.
The team determined that a failure of the work control and planning processes was a
contributing cause of the problem. However, the licensee had not addressed this
potential generic issue in the scope of their corrective actions. Because of this
omission, the team determined that the licensee's corrective actions for this condition
report were weak.
.
.
-21-
Division II Emeraency Diesel Generator Load Transients
Condition Report 1997-0014 reported load transients on the Division 11 emergency diesel
generator during a test run. According to a licensee representative, this was a second
occurrence of this anomaly. The licensee performed extensive troubleshooting to
identify the cause(s) of the event, but no cause was found. Licensee maintenance
personnel replaced a motor-operated potentiometer in the engine speed control system
load-control circuitry. Subsequent testing of the removed potentiometer did not indicate
a cause of the event, and the event could not be duplicated. The unit was tested
successfully and returned to operable status.
The team inquired about the licensee's plans if the transients occurred again. Licensee
engineering personnel explained to the team that a binder had been developed to
provide effective troubleshooting guidance. The binder contained uncontrolled,
undated, and unapproved information to assist licensee personnel in performance of
troubleshooting for any problem with Division I or ll emergency diesel generators. The
guidance was generic and there was no specific plan or troubleshooting start point for a
repetitive transient load event. The team considered this approach to be weak,
considering that it involved a potential event that could render the diesel generator
j
inoperable, and for which a cause had not been identified.
Relief Valve Cyclina
Condition Report 1999-0212 reported that the Division 11 standby service water pump
relief valve would not reseat during a quarterly pump run for inservice pump testing.
This safety-related system supplies cooling water to the Division 11 emergency diesel
generator. The team reviewed this event to determine if the operability of the
emergency diesel generator would be impacted by failure of this valve to reseat.
The team found this to be a recurring problem that the licensee had not fully addressed.
The 6-inch relief valve was set to lift at 159 +/- 5 psig and had remained open in the test
(recirculation) mode with system pressure at 138 psig. Licensee personnel provided a
vendor specification sheet that indicated that the valve was designed to provide a
20 percent blowdown and, therefore, would not reseat until underseat pressure dropped
'
to about 127 psig. Thus, the valve lifting and staying open at 138 psig was not an
anomaly. The valve's reseat pressure could not be attained until the flow path to the
i
residual heat removal heat exchanger was automatically established. Automatic
l
positioning of system valves to establish flow to the heat exchanger normally took about
1 minute. Therefore, the relief valve opened and remained open during system testing,
and opened and reseated after approximately 1 minute on normal system startup.
The team performed further review to determine whether the valve sticking open (failing
to reseat on normal system startup) would decrease the standby service water flow rate
below that used in the safety analysis. The team determined that with the valve stuck
fully open, given the pump performance indicated and trended by the licensee's
.
.
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inservice testing program, the assumed accident flow rate would be met. Therefore,
operability of the emergency diesel generators was not impacted. However, the team
determined that it was poor engineering practice to risk valve degradation and failure by
allowing a relief valve to open on every system startup, which, according to the
licensee's engineering staff, could total as many as 60 times per year.
c.
Conclusions
The team concluded that the corrective action program was generally effective in the
identification of design and design basis issues related to the emergency diesel
generators. An issue related to the Division ill emergency diesel generator lube oil
inventory, where an excessive oil consumption problem created inconsistencies
between the technical specification and the design bases, was indicative of a lack of
questioning attitude. The team also identified three other issues in which the causes
were not identified or addressed, or the corrective actions did not fully resolve the
problem.
E.2.3 Temoorary Alterations
a.
Inspection Scope (93809)
The team reviewed licensee Procedure 01-S-06-3," Control of Temporary Alterations,"
Revision 28, and all open temporary alterations. After these reviews, the team
performed an assessment to determine if the licensee's implemented temporary
alteration program effectively preserved the existing design bases.
b.
Observations and Findinos
There were 19 open temporary alterations, six of which were past the originally-
established corrective action due dates. The oldest open temporary alteration
(93-00230) was installed in 1992 to lift instrument leads to preclude nuisance
annunciator alarms from a failed condensate pump vibration monitoring probe.
According to a licensee representative, the probe could only be replaced when the pump
was removed from the system for overhaul, which was not scheduled in the near future.
The team considered this to be valid reason for the lengthy duration of this temporary
modification. The inspectors determined that four additional temporary alterations that
were past their corrective action due dates also had valid reasons for remaining open.
Additional review and discussion with the licensee representative revealed that the work
needed to close Temporary Alteration 97-0012 (tank manway covers removed for
submersible pump access) had been performed prior to the end of 1998. However, the
personnel responsible for closing out the temporary alteration had not been informed
and the item remained open. Once the condition was identified, the licensee initiated
the closure process.
The team also determined that the appropriate drawing for Temporary
Alteration 98-0032 (M-0180, which depicted a discharge register above test equipment
.
.
-23
in the hot chemistry lab) had not been updated to reflect the configuration of the
alteration (which had installed a blank to preclude dust and dirt intrusion to the
instruments). However, the drawing was not classified as operations sensitive or critical
and, therefore, according to Procedure 01-S-06-3, was not required to reflect the
temporary alteration configuration.
A licensee operations representative stated that he intended to initiate a procedure
'
improvement to require the generation of documentation of approval for extending the
required corrective action completion dates and to better define the qualifications and
j
responsibilities of personnelinvolved in the process.
j
The team did not identify any example where the design bases was compromised by a
temporary alteration. However, as identified in a separate NRC inspection (NRC
Inspection Report 50-416/99-03), a concern has been identified relative to the licensee's
control and tracking of temporary or interim solutions. It appeared that the licensea, on
occasion, used such temporary or interim solutions in lieu of the modification process.
c.
Conclusions
The licensee's temporary alteration program effectively preserved the design bases for
equipment and systems affected by temporary alterations. However, the team noted
that, in a number of instances, there was a lack of documented justification for
temporary alterations that remained open past the initial corrective action due dates.
A recent NRC inspection (NRC Inspection Report 50-416/99-03) identified a concern
relative to the licensee's control and tracking of temporary or interim solutions. It
appeared that the licensee, on occasion, used such temporary or interim solutions in lieu
of the modification process.
E8
Engineering-Miscellaneous issues (92903)
E8.1
(Ocen) Insoevtion Followuo item 9603-01: review long-term justification for
methodology and assumed valve factors.
During a previous inspection, the NRC noted that two motor-operated valve groups had
been assigned bounding valve factors that appeared non-conservative and which were
not adequately justified by test-based evaluations.
The licensee had completed additional testing to support the valve factors assigned
to the two subject motor-operated valve groups: Powell 600/900 pound class gate
valves and Powell 150 pound class gate valves. The team concluded that the additional
tests performed on two valves in the 150 pound class were adequate to establish the
assignment of a 0.62 valve factor to this group. However, the additional tests performed
on two valves in the 600/900 pound class group did not provide sufficient justification for
the 0.5 valve factor assigned to this group. The two valve tests revealed valve factors of
.
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0.48 and 0.50. These results, combined with previous test results from this group, did
not provide confidence in the 0.5 group valve factor. That is, there appeared to be a
high probability that some of the valves in this group (that had not been tested) could
have valve factors greater than 0.5. If this were the case, the estimated thrust loads
would be less than actual. Depending on the available thrust margins, this could result
in a trip of the torque switch and a valve stopping in mid-cycle.
The team reviewed a listing of valves in the Powell 600/900 pound class and the current
available margins for these valves based on a 0.5 valve factor. The listed margins did
not account for rate of loading. Six valves (01G33F028, Q1B21F016, Q1821F019,
Q1E51F059,01E51F063, and 01G33F039) had control switch trip margins that were
between 10 and 20 percent, and these were the most marginal of the 35 valves in the
group. Given that the rate of loading (which is often in the range of 10-15 percent) was
not included in the margin calculation and that the 0.5 valve factor was not adequately
justified, the team was concerned that some of the valves in'this group may be marginal
in terms of their ability to open or close against design basis differential pressure and
flow conditions. However, the team did not consider these valves to be inoperable
because of other conservatisms in the analysis. The concern was of less significance
with Valve O1E51F063 since it was limit positioned and would not experience a rate of
loading effect. The licensee intended to perform margin-enhancing modifications to the
five valves listed above (except for 01E51F063) during Refueling Outages 10 and 11
(October 1999 and approximately March 2001).
The team considered the marginal status of the five valves to be potentially significant.
Consequently, this item was left open pending completion of the planned modifications.
E8.2
(Closed) Violation 50-416/9705-01: design control issues rela' ted to (1) two alarm
response procedure updates and (2) ensuring an adequate drain path for normal and
expected standby service water pump shaft seat leakage.
The licensee issued Condition Reports GGCR 1997-0297-00 and GGCR 1997-0294-00
in response to the two alarm response procedures. Corrective actions established in the
condition reports revised setpoints contained in the procedures in question and reviewed
other alarm procedures to detect other potential similar errors (none were found). The
team considered these corrective actions to be satisfactory.
Condition Report GGCR 1997-0264-01 was issued in response to the drainage issue.
A floor drain was installed in the room in question after the room had been sealed to
prevent flooding from external sources. Actions to prevent recurrence included
revisions to Procedures 02-S-01-21, * Plant Change Review and Training," Revision 5,
Section 6.0; and 01-S-16-1, " Plant Change implementation," Revision 102,
Attachment Xil. Thesc revisions strengthened the required review of design changes
to determine the impact on procedures and equipment. The team considered these
corrective and preventive actions satisfactory to resolve the violation.
Although the team considered the licensee's actions to be acceptable to resolve this
violation, weaknesses were observed in the corrective action process in that no other
action was apparently taken to determine the extent of the condition. Regarding the first
two examples, the licensee did not review other procedures (operations, surveillance,
.
.
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calibrations, etc.) to assure that other design changes were properly incorporated into
procedures. In the second example, the licensee considered the design change
associated with the sealing of the room to be unique. However, the team considered
the development of the scope of corrective actions to be limited. The licensee did not
review other design changes to assure that changes did not have similar adverse effects
on the equipment modified.
E8.3 (Closed) Violation 50-416/9705-03: failure to update the Updated Final Safety Analysis
Report with the latest material developed related to (1) incomplete cooling tower failure
analysis, (2,3) fuel pool heat load increase dues to reracking the spent fuel pool (two
examples), (4) change from 2-unit to 1-unit facility, and (5) an inaccurate figure with
respect to a peak heat rate for the ultimate heat sink.
The licensee issued Condition Report GGCR 1997-0262-01 to address the five
examples of this violation. Corrective actions established in the condition report revised
Updated Final Safety Analysis Report, Tables 9.2-16 and 9.2-17, and Figures 9.2-5
and 9.2-6a in response to items 2 through 5 listed above. Example 1 was documented
in Condition Report GGCR 1996-0552-00. The licensee planned to revise Updated
Final Safety Analysis Report, Table 9.2-2, when calculations were completed.
Preventive actions were also established. The licensee issued a memorandum to the
engineering staff management expressing expectations on reporting Updated Final
Safety Analysis Report discrepancies. The team considered these corrective and
preventive actions satisfactory to resolve the violation.
The team noted that the scope of the corrective actions applied to this violation was
limited in that the review for similar problems was limited to Revision 6 of the Updated
Final Safety Analysis Report. Revisions prior to Revision 6 were performed with
contractor support, and subsequent revisions were all processed independently by the
licensee. The licensee's review of Revision 6 identified that 10 of the 71 change notices
had discrepancies associated with them. The licensee did not have a justification that
the problems were unique to Revision 6.
Although not directly tied to the corrective actions scheduled for this finding, an effort
has been undertaken by the licensee to perform a fidelity review of the Updated Final
Safety Analysis Report. This project is discussed in Section E8.8 of this report.
E8.4 (Closed) Inspection Followuo item 50-416/9705-04: adequacy of long-term freeze
protection measures.
The licensee had previously documented this item within Condition
Report GGCR 1996-0553-00 before it was identified by the NRC in 1997. This condition
report was open at the time of the current inspection. However, most of the corrective
actions were complete in response to recommendations within Engineering Request
96/1022-00, Revision 2. Current freeze protection measures required a start of a
standby service water pump rather than just a start of the fans. In addition, scaffolding
was to be installed in case of freezing conditions for safe access to observe ice
accumulation. The team considered these measures to be more workable than
previous measures and to be satisfactory to resolve this item.
m
..
9
-26-
E8.5 (Closed) Inspection Followuo item 50-416/9705-05: unexplained pump performance
curve discrepancies.
The licensee addressed this item within Condition Reports GGCR 1997-0438-00 and
GGCR 1997-0365-00. The licensee established that the discrepancies between the
curves were caused by instrument errors associated with the standby service water
pumps and by calculational errors associated with the high pressure core spray pumps.
' The team noted that the discrepancies did not affect the operability or design bases of
the pumps. Corrective actions were to replace the inaccurate instruments and to correct
the calculations. These corrective actions have been completed. The licensee's
representative reported that differences did not exist between other pump vendor curves
and the baseline data. The team considered that these actions were satisfactory to
resolve the item.
E8.6
Enaineerina Backloa
,
a.
Insoection Scooe (93809)
- The team reviewed the licensee's engineering backlog and the manner in which it was
being trended, in addition, the team discussed the backlog with appropriate licensee
personnel,
b.
Observations and Findinas
The engineering backlog consisted of engineering requests, open modifications, open
corrective action items, work orders on engineering hold, and other miscellaneous
items. For design engineering, the backlog had increased from approximately 370 items
in July 1997 to approximately 560 in January 1999. The system engineering backlog
= bad' increased over the same time period from approximately 480 to 590 items.
However, the increased backlog was primarily a result of a November 1998 change in
the corrective action program software, which began tracking individual corrective action
items for each condition report. This software change fully accounted for the increased
numbers of items listed above. Therefore, the team determined that the actual
engineering backlog had been relatively constant since July 1997.
l
1
.
c.
- Conclusions
The team concluded that the engileering backlog had been maintained relatively
constant.
E8.7 ' System /Desian Enaineerina Staffina
a.
Insoection Scope (93809)
The team discussed the status of the onsite engineering staffing with the applicable
department managers. In addition, the team interviewed some of the system and
design engineers.
.
.
-27-
b.
Observations and Findinas
The system engineering department consisted of approximately 28 engineers and first-
line supervisors, with each system engineer being responsible for four to eight systems.
The design, system, and performance engineering groups were in the process of being
1
l
reorganized. The system engineers interviewed stated that the number of onsite
engineers had changed little over the past few months. However, many systems and
projects had been re-assigned as the engineering departments were reorganized. The
result of these changes within onsite engineering had led to a decrease in the average
individual engineer's experience level with respect to the current systems and project
areas assigned.
c.
Conclusions
Onsite engineering support was in the process of reorganization. As a result, there had
been a decrease in the individual engineer's experience level within project areas and
l
systems assigned.
I
E8.8 Updated Final Safety Analysis Reoort Update and Review Proarams
a.
Inspection Scope (93809)
The team reviewed the licensee's program for reviewing and updating the Updated
Final Safety Analysis Report. The team reviewed Grand Gulf Administrative
Procedure 01-S-15-10, " Control of Licensing Documents," Revision 101, used in
part to track changes to the Updated Final Safety Analysis Report and portions of
the " Grand Gulf Nuclear Station Design Bases initiatives Program Plan," dated
December 16,1998, which is used to monitor the current Updated Final Safety
Analysis Report review effort.
b.
Observations and Findinas
Updated Final Safety Analysis Report Uodate Proaram
l
The latest revision of the licensee's Updated Final Safety Analysis Report was
completed on November 11,1998. Subsequently,20 of the 33 controlled copies of the
,
Updated Final Safety Analysis Report were replaced with electronic computer disc
copies in January 1999. In addition, a controlled copy of the Updated Final Safety
j
Analysis Report was placed on the licensee's Internet home page. The licensing
document control process initiated and tracked changes to the Updated Final Safety
Analysis Report in accordance with Procedure 01-S-15-10. A master tracking system
computer program maintained the linkage among the various licensing control
documents, engineering work documents, and the corrective action program.
The team discovered several errors in the latest revision of the Updated Final Safety
Analysis Report, as described in Sections E1.1.1 and E1.2.1 of this report. In addition to
these findings, two engineering drawings the team used as part of the detailed
f
engineering inspection of the plant's standby diesel generators were observed to contain
the wrong revision:
.
._
_.
_ _ _ _ _ _ _
_ _ _ _ _ -
.
.
-28-
Updated Final Safety Analysis Report Figure 9.5-011, " Standby Diesel Generator
System Unit 1" (Division l) was Revision 30 of P&lD M-1070A dated October 31,
1997, whereas the current revision of P&lD M-1070A was Revision 31 dated
November 11,1998.
Updated Final Safety Analysis Report Figure 9.5-012," Standby Diesel Generator
i
System Unit 1" (Division ll) was Revision 26 of P&lD M-1070B dated October 3,
)
1997, whereas the current revision of P&lD M-10708 was Revision 27 dated
j
November 13,1998.
'
Updated Final Safety Analysis Report Review Proaram
The licensee initiated the " Updated Final Safety Analysis Report Consistency Review
Project," in response to the November 9,1996, NRC letter issued under 10 CFR 50.54
requiring licensees to provide added confidence and assurance that their plants are
operated and maintained within their design bases. The licensee had incorporated this
project into a larger " Design Bases Initiatives Program." The project began in March
1997 when offsite contractors began a consistency review of 16 systems within the
Updated Final Safety Analysis Report. These reviews were completed and delivered to
the licensee in December 1997 and January 1998. A second group of 8 systems was
added to the scope of the project in late 1998. The licensee planned to include another
6 systems to be reviewed by the end of 2000.
The project, as outlined in Project instruction "GGNS Updated Final Safety Analysis
Report Consistency Review Project," Revision 2, required, in part, a line-by-line review
of the Updated Final Safety Analysis Report for identification of system-related attributes
and verification that they were consistent with relevant design basis information (system
design criteria, calculations, modifications, design correspondence, etc.). The licensee
project manager reported that none of the offsite contractor system reviews had been
'
approved by the onsite engineering departments. There were approximately
450 deficiencies and open items identified by the offsite contractors. The licensee
had a goal to complete their review of these discrepancies by the end of 1999.
The team determined that the initial Updated Final Safety Analysis Report consistency
review performed by the offsite contractors did not identify many of the discrepancies
identified by the team. The team discussed with the licensee's management the need to
consider this fact when conducting their scheduled onsite reviews of this material.
Based on the number of discrepancies identified during this inspection, the team
considered the general fidelity of the Updated Final Safety Analysis Report to be in
question pending the results of further reviews to be conducted by the licensee. This
matter is further discussed in Section E1.1.1 of this report.
c.
Conclusions
The licensee's ongoing Updated Final Safety Analysis Report update and review
pmjects did not identify multiple discrepancies that were identified by the team during
the inspec' ion. This was indicative of a potentially broader problem involving the fidelity
of the Updated Final Safety Analysis Report.
_ _ _ - _ _ _ _
_ _ - - _
.
.
-29-
M8
Maintenance-Miscellaneous issues (92902)
M8.1 (Closed) Inspection Followuo liem 50-416/9701-03: tracking licensee actions related to
equipment unavailability.
The licensee documented this item in Condition Report GGCR 1997-0227-00. The
three examples discussed in the NRC inspection report were corrected and the impact
of the corrections did not affect their Maintenance Rule program status. Preventive
actions included revisions to the shift supervisor's turnover checklist, plant supervisor's
turnover checklist, and the plant status checksheet, so that operations personnel would
be more aware of the Maintenance Rule program requirements to report unavailability.
The Maintenance Rule coordinator reviewed historical records and established that no
additional hours of unavailability were missed as a result of the oversight by the
operations staff. The team found that a recent period of unavailability of the emergency
diesel generators was properly reported. The team considered these actions
satisfactory to resolve the item.
M8.2 (Closed) Inspection Followuo item 50-416/9701-06: structures monitoring program.
In response to this item, the licensee revised Engineering Report GGNS-96-0075,
" Assessment of Grand Gulf Compliance with the Guidelines of NEl 96-03," Revision D,
sn unnumberad document entitled," Maintenance Rule for Monitoring the Condition of
Structures," Revision 1, and Procedure GGNS-C-399.0," Maintenance Rule for
Structures inspections," Revision 3. These revisions identified the structures in the
scope of the Maintenance Rule program and established a basis for their inclusion. The
revisions also ir ciuded identification of the risk-significant structures.
V. Manaaement Meetinas
XI
Exit Meeting Summary
'
The team presented the preliminary inspection results in an exit meeting to members of
licensee management on March 11,1999. A supplemental exit meeting was conducted
by telephone on May 18,1999. The licensee's management acknowledged the findings
presented.
The licensee's staff was asked whether any materials examined during the inspection
should be considered proprietary. The licensee's management stated that no
proprietary information was reviewed by the team.
3
.
-
.
ATTACHMENT 1
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
A. Barfield, Manager, Mechanical / Civil Engineering
R. Byrd, Licensing Supervisor
N. Deshpande, Supervisor, Design Engineering
J. Edwards, Manager, Planning and Scheduling
A. Goel, Site 50.59 Coordinator
E. Harris, Superintendent, System Engineering
C. Holifield, Senior Licensing Engineer
,
C. Lambert, Director, Design Engineering
i
M. Renfroe, Manager, Engineering Programs
J. Roberts, Director, Quality Programs
J. Venable, General Manager
W. White, Engineering Supervisor
i
NRC Personnel
D. Powers, Chief Engineering and Maintenance Branch
J. Russell, Acting Senior Resident inspector
INSPECTION PROCEDURES USED
37001
10 CFR 50.59 Evaluations
92902
Followup- Maintenance
92903
Followup-Engineering
93809
Safety System Engineering Inspection
ITEMS OPENED, CLOSED, DISCUSSED
Opened
50-416/9902-01
UFSAR Discrepancies
50-416/9902-02
Failure to Maintain Diesel Generator Air Start Valve
Open
50-416/9902-03
instrument Setpoint Program Weaknesses
.
.
-2-
Qlpsed
50-416/9701-03
IFl
Track Licensee Actions Related to Equipment
Unavailability
50-416/9701-06
IFl
Structures Monitoring Program
50-416/9705-01
Design Control Discrepancies
50-416/9705-03
Failure to Update the UFSAR with the Latest Material
Developed
50-416/9705-04
IFl
Adequacy of Long-Term Freeze Protection Measures
50-416/9705-05
IFl
Unexplained Pump Performance Curve Discrepancies
50-416/9902-01
UFSAR Discrepancies
50-416/9902-02
Failure to Maintain Diesel Generator Air Start Valve
Open
Discussed
50-416/9603-01
IFl
Review Long-Term Justification for Methodology and
Assumed Valve Factors
DOCUMENTS REVIEWED
Procedures
01-S-06-24, " Safety and Environmental Evaluations," Revision 103
316 "10 CFR 50.59 Safety Evaluations," Revision 12
EDP-032, Nuclear Plant Engineering Desk Top Procedure, " Instrument Loop Uncertainty and
Setpoint Calculations," Revision 1
GG-1-LP-OTH-50591.00," Lesson Plan, Non-Licensed Training, Licensing Basis 50.59
(Lesson 1)," Revision 0
GG-1-LP-OTH-50592.00, " Lesson Plan, Non-Licensed Training,10 CFR 50.59 Safety
Evaluations (Lesson 2)," Revision 0
GG-1-HO-OTH 5059M.00," Lesson Plan, Non-Licensed Training, Licensing Basis 50.59
Manual," Revision 0
01-S-06-3," Control of Temporary Alterations," Revision 28
01-S-03-10, "GGNS Condition Report," Revision 3
a
l
.
3-
04-1-02-1H22-P400-1 A-C1, " Alarm Response instruction - Diesel Fuel Oil Tanks High Low,"
Revision 10
04-1-03-A30-1, " Equipment Performance Instruction - Cold Weather Protection, Non-Safety
Related," Revision 10
06-OP-1 P75-M-0001, " Surveillance Procedure - Standby Diesel Generator (SDG) 11 Functional
Test, Safety Related," Revision 107
07-S-24-P75-E001 A-1, " Preventive Maintenance instruction - Division 1 Diesel Generator
Starting Air System Leakage Test, Safety Related," Revision 2
07-S-24-P75-E001 B-1, " Preventive Maintenance Instruction - Division 2 Diesel Generator
Starting Air System Leakage Test, Safety Related," Revision 1
06-EL-1R21-M-0001, "4.16 kV Degraded Voltage Functional Test and Calibration,"
Revision 102
06-OP-1 P81-M-0002, "HPCS Diesel Generator 13 Functional Test," Revision 104
06-OP-1R21-M-0002 Attachment I, "Div. I Load Shedding and Sequencing Functional Test,"
Revision 100
01-S-15-10," Control of Licensing Documents," Revision 101
GG-UFSAR-CR-01, "GGNS UFSAR Consistency Review Project," Revision 2
04-1-01-P81-1, High Pressure Core Spray Diesel Generator," Revision 44, November 18,1998
Guidelines
"10 CFR 50.59 Guidelines," Revision 5'
"10 CFR 50.59 Review Program Guidelines," Revision 1
Safety Evaluations
94-0058-R02, " Evaluation 93/0050, Revision 1," December 10,1996
94-0072-R00, " Evaluation of MCP 94/1014 & SCN 94/0001 A to M-273.0," April 18,1996
95-0026-R01," Technical Specification Update through Amendment 120," August 21,1997
95-0080-R00, "DCP 91/042-1 Rev. 0," March 19,1996
95-0085-R00, " Evaluation of MCP 95/1020," May 13,1997
95-0097-R00, "MNCR 0206-95, Supplement 1," February 6,1996
.
.
-4-
96-0004-R00, " Licensing Document Change Request 96-0004, UFSAR 4.2.3.3.10," March 21,
1996
96-0019-R00, "DCP 89/0069," February 17,1998
96-0023-R00," Evaluation of Various P&lD and UFSAR Changes," July 9,1996
96-0040-R00, "MCP 95/1042," April 29,1997
96-0074-R00," TEMP. ALT. 96/0014," August 29,1996
96-0080-R00, " Evaluation of ER 96/0514," Revision 0, October 17,1996
96-0112-R00, "ER 96/0803-01-00 (GGCR 1996-0270-00)," November 1,1996
97-0012-R00, "ER 96/J056-00-00," November 11.,1997
97-0031-R00," Evaluation of MCP/1002, SCN 97/0002A to MS-02, and SCN 97/0006A to
M-189.3," January 14,1998
l
98-0035-R01, " Evaluation of Mechanical Standard 48.0, Revision 6, Core Operating Limits
1
'
Report," May 12,1998
97-0037-R00," Evaluation of ER 96/0964-00-00," October 2,1997
97-0073-R00, " Calculation XC-01G41-97007, Rev.0," October 21,1997
$
97-0076-R00, " Evaluation of ER 97/0588-00," dated April 24,1998
97-0083-R00," Evaluation of Spent Fuel Pool Time-to-Boil," February 10,1998
97-0093-R00, " Evaluation of ER 97/0114-00-00," December 18,1998
97-0096-R00," Evaluation of Temporary Alteration 97-0013," December 12,1997
f
97-0103 R00, " Evaluation of ER 97/0352-00-00," March 28,1998
98-0040-R00," Evaluation of TSR 98-008," April 28,1998
98-0018-R00," Evaluation of Various FSAR changes," March 3,1998
{
98-0019-R00, " Evaluation of ER 96/0936-04, SCN 98/0002A," April 3,1998
98-0079-R00," Evaluation of ER 98/0558-01, October 10,1998
98-0094 R00," Evaluation of LDC# 1998092, November 11,1998
1
.
-5-
Condition Reports
1996-0144
1996-0447
1997-0914
1997-1393
1999-0279
1996-0146
1997-0014
1997-0942
1998-0733
1999-0308
1996-0147
1997-0152
1997-0944
1998-1423
1999-0325
)
1996-0174
1997-0438
1997-0981
1998-1512
1999-0328
'
1996-0247-
1997-0744
1997-1032
1999-0212
1999-0331
1996-0393
1997-0758
1997-1197
1999-0218
1996-0442
1997-0851
1997-1317
1999-0256
Enaineerina Reauests
ER 96/1014-00
ER 97/0588-00
ER 97/0682-00
ER 97/0682-01
Enaineerina Reports
GGNS-99-0005," Evaluation of DIV lli D/G Lube Oil Sump Volume," dated March 8,1999
Temoorary Alterations
'
93-0023
98-0014
98-0020
98-0025
98-0032
97-0008
98-0015
98-0021
98-0027
98-0033
97-0012
98-0017
98-0023
98-0028
99-0008
98-0002
98-0018
98-0024
98-0029
1
Calculations
2.2.11.0, " Standby Service Water System - Net Positive Suction Head Requirements for
dbndhv 9arvice Water Pumps," Revision E
7.6.4B, " Diesel Generator Fuel Oil System - Sizing of Diesel Generator Fuel Oil Transfer Pumps
(Flow Capacities)," Revision B
7.6.9C, " Diesel Generator Fuel Oil Supply System - Calculate the Discharge Pressure for the
Diesel Generator Fuel Oil Transfer Pumps," Revision C
7.6.26," Standby Diesel Generator System - To Determine the Line Size for the Discharge Line
from PSVF026 A & B," Revision 0
JC-01 P75-90040, " Standby Diesel Generator Fuel Oil Day Tank Volume and Level Setpoint
Calculation," Revision 3
MC-Q1111-90197," Emergency Core Cooling System Network Configuration Evaluation,"
Revision 0
.
.
-6-
MC-01P41-97020 " Determination of Minimum Allowable Standby Service Water Flows (Loss
of Coolant Analysis Lineup) to Safety Related Heat Exchangers," Revision 1
MC-01 P41-97035, " Standby Service Water Heat Exchanger Thermal Performance Instrument
Uncertainty," Revision 1
MC-O1P75-90190, " Diesel Fuel Storage Requirements for the Division i Diesel Generator,"
Revision 1
MC-01P75-91119," Maximum Allowable Leakage from Division I and 11 Diesel Generators
Starting Air Storage Tanks," Revision 0
MC-01P81-88022, " Division 111 Diesel Generator Fuel Oil Transfer System Study for Material
Nonconformance Report 1173-86," Revision 0
MC-01P81-90188, " Diesel Fuel Storage Requirements for the Division lli Diesel Generator,"
Revision 1
l
MC-01X77-85005, " Cooling Requirements for Division I and 11 Diesel Generator Control
Cabinets," Revision 1
SC-1P75-LT-N004, " Standby Diesel Generator Fuel Oil Day Tank Volume and Level
Instrumentation Scaling Calculation (1P75-LT-N004A & B,1P81-LT-N004)," Revision 0
E-DCP82/5020-1," Transient Loading on Diesel Generators during Load Sequencing,"
Revision A
EC-01R20-91040," Verification of Protective Coordination for Motor Control Centers and
Associated Feeders," Revision 0
Calculation E-49, "MCC Overcurrent Protection," Revision 0
EC-O1111-90028," Load Flow & Voltage Drop Analysis Report Attachment 7A2," Revision 0
Condition Identification
Cl# 076570, Work Order # 00220628 " Identified as - Cable Tray @ South End of DIV1 D/G
under Exhaust Silencer has Insul. Material that Needs Cleaned," Reported Date March 04,
1999
,
Drawinas
E-1042," Logic Diagram Engineered Safeguards Feature Division i Diesel," Revision 9
M-1070-A, " Piping and instrumentation Diagram - Standby Diesel Generator System Unit 1,"
Revision 31
.
.
7
M-1070-B, " Piping and Instrumentation Diagram - Standby Diesel Generator System Unit 1,"
Revision 27
M-1070-C, " Piping and Instrumentation Diagram - Standby Diesel Generator System Unit 1,"
Revision 15 -
M-1070-D, " Piping and Instrumentation Diagram - Standby Diesel Generator System Unit 1,"
Revision 13
J-1692," Level Setting Diagram Standby Diesel Generator Fuel Oil Day Tank A(B)
01P75A004A(B)," Revision 5
Fidelity Review
GGNS-98-0057, " Grand Gulf Nuciear Station - System Design Criteria Review / Updated Final
Safety Analysis Report Consistency Review, Standby Diesel Generator System - Attachment
6.6, Discrepancy Form"
OlN# P75-65, " Consistency Review (System Design Criteria Review / Updated Final Safety
Analysis Report Consistency Review) - Subject: In the fourth paragraph of Section 9.5.6 3, the
reference to . . . ." (Fidelity evaluation discrepancy) December 27,1998
Material Nonconformance Reoort
Material Nonconformance Report 0269-87, December 1,1987
Memoranda
GIN: 92/00968," Subject: System P75 Setpoint Calculation - Start Air Pressure Available, Diesel
A (B) (Emergency Start Lockout at 120 psig," February 21,1992
Proarams
Program Plan Change Notice No.98-006 against Program Plan No. GGNS-M-189.1," Pump
and Valve Inservice Testing Program," Revision 8
Reports
9645-M-018.0," Qualification Test for De Laval Engine Generator Set, Grand Gulf Nuclear
Stations #1 & #2, Middle South Energy, Inc., Engine Unit No.1," Revision 2 and specifically
Test Number 2.6.4," Starting Air System - Starting Air Compressor Capacity Test,"
December 29,1976
Startuo Field Reoorts
Startup Field Report (SFR) No.1-M-403, " Subject: M-1070A and M-1070B, Revision 7,"
March 6,1980
.
.
-8-
Startup Field Report Reply No.1-M-403, " Standby Diesel Generator / P75 - Disposition,"
March 6,1980
Test Data - Air Droo Results
E-Mail, "D. R. Franklin to T. E. Dykes, - Subject 'Most Recent Air Drop Test,'" February 23,
1999
Work Order 00218010," Perform 1P75E001B Standby Diesel Generator Starting Air System
Leakage Check," December 29,1998
Work Order 00218011 " Perform 1P75E001 A Standby Diesel Generator Starting Air System
Leakage Check," December 29,1998
Test Data - Fuel Transfer Pumo Performance
" Standby Diesel Generator Fuel Transfer Pump IP75C002A - Inservice Testing Performance
Results," Summary for dates between May 24,1988, through November 17,1998
" Standby Diesel Generator Fuel Transfer Pump 1P75C002B - Inservice Testing Performance
Results," Summary for dates between January 8,1988, through December 12,1998
"High Pressure Core Spray Diesel Generator Fuel Transfer Pump 1 P81C001 - Inservice
Testing Performance Results," Summary for dates between May 28,1987, through
December 12,1998
Test Data - Heat Exchanaer Performance
" Thermal Data (Jacket Water Cooler / Heat Exchanger Performance Data) for P75B004A,"
several dates
" Thermal Data (Jacket Water Cooler / Heat Exchanger Performance Data) for P75B004B,"
several dates
" Thermal Data (Jacket Water Cooler / Heat Exchanger Performance Data) for P81B001 A,"
i
several dates
Test Data - Relief Valve Results
Work Order 00068480, " Remove, Test, and Reinstall Safety / Relief Valve, Check Setpoint
Pressure . . . Fuel Oil Return Line PSV 1P75F026A," March 26,1992
Work Order 000105483," Remove, Set Pressure Check & Adjustment and Reinstall
Safety / Relief Valve . . . Fuel Oil Return Line PSV 1P75F026B," August 31,1993
F
,
i
-
-9-
1
Desian Basis Documents
Updated Final Safety Analysis Report Sections 8.1,8.2 and 8.3
Technical Specification Sections 3.3.8.1,3.8.1,3.8.2,3.8.3, and their bases
One Line Diaarams
E-0001, " Main One Line Diagram," Revision 26
E-1006,"One Line Meter & Relay Diagram 4.16 kV BOP Bus 13 AD," Revision 13
E-1007, "One Line Meter & Relay Diagram 4.16 kV BOP BUS 14AE," Revision 17
E-1008, "One Line Meter and Relay Diagram 4.16 kV ESF System Buses 15AA & 16AB,"
Revision 17
E-1009,"One Line Meter and Relay Diagram 4.16 kV ESF System Bus 17AC," Revision 9
E1022, "One Line Meter & Relay Diagram 125V DC Buses 11DD,11DE & 250V DC
BUS 11DF," Revision 26
E1023,"One Line Meter & Relay Diagram 125V DC Buses 11DA,11DB & 11DC," Revision 33
E-1025, " Meter & Relay Diagram * 24V DC System," Revision 13
E-1026,"One Line Meter and Relay Diagram 120V AC ESF Uninterruptible Power Supplies,"
Revisions 10 and 12
Loaic Diaarams
E-1039, " Logic Diagram - Load Shedding & Sequencing Panel," Revision 17
E-1042, " Logic Diagram ESF Division I Diesel," Revision 9
E-1043, " Logic Diagram ESF Division 11 Diesel," Revision 6
Schematic Control Drawinas for Diesel Start Circuits
E-1110-012 "P75 Stand-by Diesel Generator Sys Div. I Train A Start & Stop Circuit,"
Revision 15
E-1110-013, " Stand-by Diesel Generator Sys Div. I Train 8 Start Circuit," Revision 17
E-1111-012. "P75 Stand-by Diesel Generator Sys Div.11 Train A Start & Stop Circuit,"
Revision 12
.
[
.
.
-10-
E-1111-013,"P75 Stand-by Diesel Generator Sys Div.11 Train B Start Circuit," Revision 13
Modifications
96-0641, " Standby Diesel Generator Day Tank High Level Alarm"
97-0443," Fire-induced Failures Affecting Safety-Related Systems"
97-0645," Replacement of Dresser Couplings of EDG Cylinder Head"
instrument Setooints and Scalina Calculations
GGNS-JS-09, " Methodology for the Generation of instrument Loop Uncertainty & Setpoint
Calculations," Revision 0
JC-01P81-N036A-1,"HPCS Diesel Generator Starting Air interlocks 1P81N036A/B,
1P81N107A/B, and 1P81N108A/B Setpoint Calculations," Revision 0
JC-O1P75-90040," Standby Diesel Generator Fuel Oil Day Tank Volume and Level Setpoint
Calculation," Revision 3
JC-01X77-N6001," Instrument Loop Uncertainty and Setpoint Determination for System X77,
Loop N600, N601, N602 Diesel Generator Room Fan Speed Control," Revision 1
j
JC-O1P81-N111-1," Uncertainty Calculation for the HPCS Diesel Generator Starting Air
Pressure Loops," Revision 0
,
SC-1 P75-LT-N004, " Standby Diesel Generator Fuel Oil Day Tank Volume and Level
Instrumentation Scaling Calculation," Revision 0
i
MC-01P75-90190, " Diesel Fuel Storage Requirements for the Division i Diesel Generator,"
l
Revision 1
)
Miscellaneous Documents
MC-01P75-91119, " Maximum Allowable Leakage From Division I and 11 Diesel Generators
i
Starting Air Storage Tanks," Revision 0
04-1-01-R21-17," System Operating Instruction ESF Bus 17AC," Revision 3
04-1-01 R21-16," System Operating Instruction ESF BUS 16AB," Revision 11
I
04-1-01-R21-15, " System Operating instruction ESF BUS 15AA," Revision 8
Project Plans
"GGNS UFSAR Review Project," January 1998
'
" Grand Gulf Nuclear Station Design Bases initiatives Program Plan," December 16,1998
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Reports
GGNS-98-0016, "UFSAR Consistency Review for 4.16 kV ESF Division I & il Distribution
i
System (R11 & R12)," May 19,1998
i
GGNS-98-0032, "UFSAR Consistency Review for High Pressure Core Spray Diesel Generator
System (P81)," January 19,1998
GGNS-98-0057, "SDC Review & UFSAR Consistency Review for Standby Diesel Generators
,
(P75)," Decernber 30,1998
]
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ATTACHMENT 2
DESIGN ENGINEERING WHITE PAPER
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ATTACHMENT 3
INSTRUMENT SETPOINT PROGRAM
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ATTACHMENT 1
SUPPLEMENTAL INFORMATION
,
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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A. Barfield, Manager, Mechanical / Civil Engineering
R. Byrd, Licensing Supervisor
N. Deshpande, Supervisor, Design Engineering
J. Edwards, Manager, Planning and Scheduling
A. Goel, Site 50.59 Coordinator
E. Harris, Superintendent, System Engineering
C. Holifield, Senior Licensing Engineer
C. Lambert, Director, Design Engineering
)
M. Renfroe, Manager, Engineering Programs
1
J. Roberts, Director, Quality Programs
)
J. Venable, General Manager
j
W. White, Engineering Supervisor
NRC Personnel
D. Powers, Chief, Engineering and Maintenance Branch
J. Russell, Acting Senior Resident inspector
INSPECTION PROCEDURES USED
37001
10 CFR 50.59 Evaluations
92902
Followup- Maintenance
92903
Followup-Engineering
93809
Safety System Engineering Inspection
ITEMS OPENED, CLOSED, DISCUSSED
.
Opened
50-416/9902-01
UFSAR Discrepancies
50-416/9902-02
Failure to Maintain Diesel Generator Air Start Valve
Open
50-416/9902-03
Instrument Setpoint Program Weaknesses
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Closed
50-416/9701-03
IFl
Track Licensee Actions Related to Equipment
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Unavailability
-50-41&9701-06
IFl
Structures Monitoring Program
.50-416/9705-01
Design Control Discrepancies
50-416/9705-03
Failure to Update the UFSAR with the Latest Material
Developed
50-416/9705-04
IFl
Adequacy of Long-Term Freeze Protection Measures
50-416/9705-05
IFl
Unexplained Pump Performance Curve Discrepancies
50-416/9902-01
UFSAR Discrepancies
50-416/9902-02
Failure to Maintain Diesel Generator Air Start Valve
Open
Discussed
50-416/9603-01
IFl
Review Long-Term Justification for Methodology and
Assumed Valve Factors
DOCUMENTS REVIEWED
Procedures
01-S-06-24, " Safety and Environmental Evaluations," Revision 103
i
316,"10 CFR 50.59 Safety Evaluations," Revision 12
EDP-032, Nuclear Plant Engineering Desk Top Procedure," Instrument Loop Uncertainty and
Setpoint Calculations," Revision 1
GG-1-LP-OTH-50591.00," Lesson Plan, Non-Licensed Training, Licensing Basis 50.59
'
(Lesson 1)," Revision 0
~ GG-1-LP-OTH-50592.00, " Lesson Plan, Non-Licensed Training,10 CFR 50.59 Safety
Evaluations (Lesson 2)," Revision 0
GG-1 HO-OTH-5059M.00," Lesson Plan, Non-Licensed Training, Licensing Basis 50.59
Manual," Revision 0
01-S-06-3," Control of Temporary Alterations," Revision 28
01-S-03-10,"GGNS Condition Report," Revision 3
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-3-
04-1-021H22-P400-1 A-C1, " Alarm Response Instruction - Diesel Fuel Oil Tanks High-Low,"
Revision 10
04-1-03-A30-1, " Equipment Performance instruction - Cold Weather Protection, Non-Safety
Related," Revision 10
06-OP-1P75-M-0001, " Surveillance Procedure - Standby Diesel Generator (SDG) 11 Functional
Test, Safety Related," Revision 107
07-S-24-P75-E001 A-1, " Preventive Maintenance Instruction - Division 1 Diesel Generator
Starting Air System Leakage Test, Safety Related," Revision 2
07-S-24-P75-E0018-1, " Preventive Maintenance Instruction - Division 2 Diesel Generator
Starting Air System Leakage Test, Safety Related," Revision 1
06-EL-1R21-M-0001, "4.16 kV Degraded Voltage Functional Test and Calibration,"
Revision 102
06-OP-1P81-M-0002, "HPCS Diesel Generator 13 Functional Test," Revision 104
06-OP-1R21-M-0002 Attachment I, "Div. I Load Shedding and Sequencing Functional Test,"
Revision 100
01-S-15-10," Control of Licensing Documents," Revision 101
GG-UFSAR-CR-01, "GGNS UFSAR Consistency Review Project," Revision 2
04-1-01-P81-1, High Pressure Core Spray Diesel Generator," Revision 44, November 18,1998
i
Guidelines
'
"10 CFR 50.59 Guidelines," Revision' 5
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"10 CFR 50.59 Review Program Guidelines," Revision 1
Safety Evaluations
.
94-0058-R02, " Evaluation 93/0050, Revision 1," December 10,1996
94-0072-R00, " Evaluation of MCP 94/1014 & SCN 94/0001 A to M-273.0," April 18,1996
95-0026-R01," Technical Specification Update through Amendment 120," August 21,1997
95-0080-R00, "DCP 91/042-1 Rev. 0," March 19,1996
95-0085-R00, " Evaluation of MCP 95/1020," May 13,1997
4
95-0097-R00, "MNCR 0206-95, Supplement 1," February 6,1996
.
.
-4-
96-0004-R00, " Licensing Document Change Request 96-0004, UFSAR 4.2.3.3.10," March 21,
1996
96-0019-R00, "DCP 89/0069," February 17,1998
96-0023 R00," Evaluation of Various P&lD and UFSAR Changes," July 9,1996
96-0040-R00, "MCP 95/1042," April 29,1997
96-0074-R00," TEMP. ALT. 96/0014," August 29,1996
96-0080-R00, " Evaluation of ER 96/0514," Revision 0, October 17,1996
96-0112-R00, "ER 96/0803-01-00 (GGCR 1996-0270-00)," November 1,1996
97-0012-R00, "ER 96/0056-00-00," November 11,1997
97-0031-R00, " Evaluation of MCP/1002, SCN 97/0002A to MS-02, and SCN 97/0006A to
M-189.3," January 14,1998
98-0035-R01," Evaluation of Mechanical Standard 48.0, Revision 6, Core Operating Limits
Report," May 12,1998
97-0037-R00, " Evaluation of ER 96/0964-00-00," October 2,1997
97-0073-R00, " Calculation XC-O1G41-97007, Rev.0," October 21,1997
97-0076-R00, " Evaluation of ER 97/0588-00," dated April 24,1998
97-0083-R00, " Evaluation of Spent Fuel Pool Time-to-Boil," February 10,1998
97-0093-R00, " Evaluation of tsR G7/0114-00-00," December 18,1998
97-0096-R00," Evaluation of Temporary Alteration 97-0013," December 12,1997
97-0103 ROO, " Evaluation of ER 97/0352-00-00," March 28,1998
98-0040-R00," Evaluation of TSR 98-008," April 28,1998
98-0018-R00," Evaluation of Various FSAR changes," March 3,1998
98-0019-R00," Evaluation of ER 96/0936-04, SCN 98/0002A," April 3,1998
98-0079-R00," Evaluation of ER 98/0558-01, October 10,1998
98-0094-R00," Evaluation of LDC# 1998092, November 11,1998
.
.
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Condition Reports
1996-0144
1996-0447
1997-0914
1997-1393
1999-0279
1996-0146
1997-0014
1997-0942
1998-0733
1999-0308
1996-0147
1997-0152
1997-0944
1998-1423
1999-0325
1996-0174
1997-0438
1997-0981
1998-1512
1999-0328
1996-0247
1997-0744
1997-1032
1999-0212
1999-0331
1996-0393
1997-0758
1997-1197
1999-0218
1996-0442
1997-0851
1997-1317
1999-0256
Enaineerina Reauests
ER 96/1014-00
ER 97/0588-00
ER 97/0682-00
ER 97/0682-01
Enaineerina Reports
GGNS-99-0005, " Evaluation of DIV lli D/G Lube Oil Sump Volume," dated March 8,1999
Temoorarv Alterations
93-0023
98-0014
98-0020
98-0025
98-0032
97-0008
98-0015
98-0021
98-0027
98-0033
97-0012
98-0017
98-0023
98-0028
99-0008
98-0002
98-0018
98-0024
98-0029
Calculations
2.2.11.0, " Standby Service Water System - Net Positive Suction Head Requirements for
Standby Service Water Pumps," Revision E
7.6.48, " Diesel Generator Fuel Oil System - Sizing of Diesel Generator Fuel Oil Transfer Pumps
(Flow Capacities)," Revision B
7.6.9C, " Diesel Generator Fuel Oil Supply System - Calculate the Discharge Pressure for the
Diesel Generator Fuel Oil Transfer Pumps," Revision C
7.6.26, " Standby Diesel Generator System - To Determine the Line Size for the Discharge Line
from PSVF026 A & B," Revision 0
JC-01 P75-90040, " Standby Diesel Generator Fuel Oil Day Tank Volume and Level Setpoint
Calculation," Revision 3
MC-C1111-90197," Emergency Core Cooling System Network Configuration Evaluation,"
Revision 0
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1
MC-01P41-97020," Determination of Minimum AUowable Standby Service Water Flows (Loss
of Coolant Analysis Lineup) to Safety Related Heat Exchangers," Revision 1
MC-01 P41-97035, " Standby Service Water Heat Exchanger Thermal Performance instrument
Uncertainty," Revision 1
MC-01P75-90190, " Diesel Fuel Storage Requirements for the Division i Diesel Generator,"
Revision 1
MC-01P75-91119, " Maximum Allowable Leakage from Division I and 11 Diesel Generators
Starting Air Storage Tanks," Revision 0
MC-Q1P81-88022, " Division Ill Diesel Generator Fuel Oil Transfer System Study for Material
Nonconformance Report 1173-86," Revision 0
MC-01P81-90188, " Diesel Fuel Storage Requirements for the Division ill Diesel Generator,"
Revision 1
MC-01X77-85005, " Cooling Requirements for Division I and 11 Diesel Generator Control
Cabinets," Revision 1
SC-1P75-LT-N004, " Standby Diesel Generator Fuel Oil Day Tank Volume and Level
Instrumentation Scaling Calculation (1P75-LT N004A & B,1P81-LT-N004)," Revision 0
i
E-DCP82/5020-1, " Transient Loading on Diesel Generators during Load Sequencing,"
Revision A
j
EC-01R20-91040, " Verification of Protective Coordination for Motor Control Centers and
Associated Feeders," Revision 0
Calculation E-49,"MCC Overcurrent Protection," Revision 0
EC-01111-90028," Load Flow & Voltage Drop Analysis Report Attachment 7A2," Revision 0
Condition identification
Cl# 076570, Work Order # 00220628 " Identified as - Cable Tray @ South End of DIV1 D/G
under Exhaust Silencer has insul. Material that Needs Cleaned," Reported Date March 04,
1999
Drawinas
E-1042," Logic Diagram Engineered Safeguards Feature Division I Diesel," Revision 9
M-1070-A, " Piping and Instrumentation Diagram - Standby Diecel Generator System Unit 1,"
Revision 31
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,
M-1070-B," Piping and Instrumentation Diagram - Standby Diesel Generator System Unit 1,"
Revision 27
M-1070-C, " Piping and Instrumentation Diagram - Standby Diesel Generator System Unit 1,"
'
Revision 15
M-1070-D, " Piping and instrumentation Diagram - Standby Diesel Generator System Unit 1,"
Revision 13
,
J-1692," Level Setting Diagram Standby Diesel Generator Fuel Oil Day Tank A(B)
01P75A004A(B)," Revision 5
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Fidelity Review
GGNS-98-0057, " Grand Gulf Nuclear Station - System Design Criteria Review / Updated Final
Safety Analysis Report Consistency Review, Standby Diesel Generator System - Attachment
6.6, Discrepancy Form"
OlN# P75-65," Consistency Review (System Design Criteria Review / Updated Final Safety
Analysis Report Consistency Review)- Subject: In the fourth paragraph of Section 9.5.6.3, the
reference to . . . ." (Fidelity evaluation discrepancy) December 27,1998
Material Nonconformance Report
Material Nonconformance Report 0269-87, December 1,1987
Memoranda
GIN: 92/00968," Subject: System P75 Setpoint Calculation - Start Air Pressure Available, Diesel
A (B) (Emergency Start Lockout at 120 psig," February 21,1992
Proarams
Program Plan Change Notice No.98-006 against Program Plan No. GGNS-M-189.1," Pump
and Valve Inservice Testing Program," Revision 8
Reports
9645-M-018.0, " Qualification Test for De Laval Engine Generator Set, Grand Gulf Nuclear
Stations #1 & #2, Middle South Energy, Inc., Engine Unit No.1," Revision 2 and specifically
Test Number 2.6.4, " Starting Air System - Starting Air Compressor Capacity Test,"
December 29,1976
Startuo Field Reports
Startup Field Report (SFR) No.1-M-403," Subject: M-1070A and M-10708, Revision 7,"
March 6,1980
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Startup Field Report Reply No.1-M-403, " Standby Diesel Generator / P75 - Disposition,"
March 6,1980
Test Data - Air Droo Results
E-Mail, "D. R. Franklin to T. E. Dykes, - Subject 'Most Recent Air Drop Test,'" February 23,
1999
Work Order 00218010, " Perform 1P75E001B Standby Diesel Generator Starting Air System
Leakage Check," December 29,1998
Work Order 00218011, " Perform 1P75E00.1 A Standby Diesel Generator Starting Air System
Leakage Check," December 29,1998
Test Data - Fuel Transfer Pumo Performance
" Standby Diesel Generator Fuel Transfer Pump 1P75C002A - Inservice Testing Performance
Results," Summary for dates between May 24,1988, through November 17,1998
" Standby Diesel Generator Fuel Transfer Pump 1P75C002B - Inservice Testing Performance
Results," Summary for dates between January 8,1988, through December 12,1998
"High Pressure Core Spray Diesel Generator Fuel Transfer Pump 1P81C001 - Inservice
Testing Performance Results," Summary for dates between May 28,1987, through
December 12,1998
Test Data - Heat Exchanaer Performance
" Thermal Data (Jacket Water Cooler / Heat Exchanger Performance Data) for P75B004A,"
several dates
' Thermal Data (Jacket Water Cooler / Heat Exchanger Performance Data) for P75B004B,"
several dates
" Thermal Data (Jacket Water Cooler / Heat Exchanger Performance Data) for P818001 A,"
several dates
.
Test Data - Relief Valve Results
Work Order 00068480, " Remove, Test, and Reinstall Safety / Relief Valve, Check Setpoint
Pressure . . . Fuel Oil Return Line PSV 1P75F026A," March 26,1992
Work Order 000105483," Remove, Set Pressure Check & Adjustment and Reinstall
Safety / Relief Valve . . . Fuel Oil Return Line PSV 1P75F026B," August 31,1993
,
, . .
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Desian Basis Documents
.
Updated Final Safety Analysis Report Sections 8.1,8.2 and 8.3
Technical Specification Sections 3.3.8.1,3.8.1,3.8.2,3.8.3, and their bases
One Line Diaarams .
E-0001, " Main One Line Diagram," Revision 26
E-1006, "One Line Meter & Relay Diagram 4.16 kV BOP Bus 13 AD," Revision 13
E-1007, "One Line Meter & Relay Diagram 4.16 kV BOP BUS 14AE," Revision 17
E-1008,"One Une Meter and Relay Diagram 4.16 kV ESF System Buses 15AA & 16AB,"
Revision 17
E-1009, "One Line Meter and Relay Diagram 4.16 kV ESF System Bus 17AC," Revision 9
E1022,"One Line Meter & Relay Diagram 125V DC Buses 11DD,11DE & 250V DC
BUS 11DF," Revision 26
E1023, "One Line Meter & Relay Diagram 125V DC Buses 11DA,11DB & 11DC," Revision 33
E-1025," Meter & Relay Diagram * 24V DC System," Revision 13
'
E-1026,"One Line Meter and Relay Diagram 120V AC ESF Uninterruptible Power Supplies,"
Revisions 10 and 12
Loaic Diaorams
E-1039, " Logic Diagram - Load Shedding & Sequencing Panel," Revision '17
E-1042, " Logic Diagram ESF Division I Diesel," Revision 9
E-1043, " Logic Diagram ESF Division ll Diesel," Revision 6
Schematic Control Drawinas for Diesel Start Circuits
E-1110-012, "P75 Stand-by Diesel Generator Sys Div. I Train A Start & Stop Circuit,"
Revision 15 -
E-1110-013," Stand-by Diesel Generator Sys Div. I Train B Start Circuit," Revision 17
j
E-1111-012, "P75 Stand-by Diesel Generator Sys Div.11 Train A Start & Stop Circuit,"
Revision 12
.
'
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'
E-1111-013, "P75 Stand-by Diesel Generator Sys Div. Il Train B Start Circuit," Revision 13
Modifications
)
96-0641," Standby Diesel Generator Day Tank High Level Alarm"
97-0443," Fire-Induced Failures Affecting Safety-Related Systems"
97-0645," Replacement of Dresser Couplings of EDG Cylinder Head"
Instrument Setooints and Scalina Calculations
GGNS-JS-09," Methodology for the Generation of instrument Loop Uncertainty & Setpoint
Calculations," Revision 0
JC-01P81-NO36A-1, "HPCS Diesel Generator Starting Air Interlocks 1P81NO36A/B,
1P81N107A/B, and 1P81N108A/B Setpoint Calculations," Revision 0
JC-01P75-90040, " Standby Diesel Generator Fuel Oil Day Tank Volume and Level Setpoint
Calculation," Revision 3
JC-01X77-N600-1," Instrument Loop Uncertainty and Setpoint Determination for System X77,
Loop N600, N601, N602 Diesel Generator Room Fan Speed Control," Revision 1
JC-01P81-N111-1, " Uncertainty Calculation for the HPCS Diesel Generator Starting Air
Pressure Loops," Revision 0
SC-1P75-LT-N004, " Standby Diesel Generator Fuel Oil Day Tank Volume and Level
Instrumentation Scaling Calculation," Revision 0
MC-01P75-90190, " Diesel Fuel Storage Requirements for the Division i Diesel Generator,"
Revision 1
Miscellaneous Documents
MC-OIP75-91119," Maximum Allowable Leakage From Division I and ll Diesel Generators
Starting Air Storage Tanks," Revision 0
04-1-01-R21-17, " System Operating instruction ESF Bus 17AC," Revision 3
04-1-01-R21-16, " System Operating Instruction ESF BUS 16AB," Revision 11
l
04-1-01-R21-15," System Operating Instruction ESF BUS 15AA," Revision 8
i
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Project Plans
"GGNS UFSAR Review Project," January 1998
" Grand Gulf Nuclear Station Design Bases Initiatives Program Plan," December 16,1998
_ - _ _
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Reoorts
GGNS-98-0016 "UFSAR Consistency Review for 4.16 kV ESF Division I & ll Distribution
System (R11 & R12)," May 19,1998
GGNS-98-0032,"UFSAR Consistency Review for High Pressure Core Spray Diesel Generator
System (P81)," January 19,1998
GGNS-98-0057, "SDC Review & UFSAR Consistency Review for Standby Diesel Generators
(P75)," December 30,1998
i
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A1TACHMENT 2
DESIGN ENGINEERING WHITE PAPER
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Design Engineering White Paper
to provide EOI's view of
NRC Safety System Engineering Inspection
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UFSAR Discrepancies Issues
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Y hita Paper to Address NRC SSEI UFSAR Discrepancies Issus
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During the NRC exit meeting held on 3/1IM9 for the GGNS Safety System Engineering
Inspection (SSEI) for the Standby Emergency Diesel Systems and Support Sptems, the
NRC inspection team leader expressed a concern over the number oMscrepancies noted
by the team during the course of the inspection. Since there were no operability issues
identified from the discrepancies, the main concem was over the aggregate number of
discrepancies.
The NRC team requested additional feedback on the station's view of these findings. The
purpose of this white paper is to review, categorize, and summarize the discrepancies
noted by the NRC sad provide EOI's perception of those findings.
While we do not believe that these findings materially affect any safety or licensed
activities of the facility or indicate any current programmatic breakdown in the UFSAR
update process, we believe the GGNS review efforts warrant additional discussion. We
also believe that the specific inspector concerns can best be put into perspective by
identifying the nature of the discrepancies and distinguishing between information that
should be improved for clarity and that information that is technically wrong (i.e., errors).
GGNS UFSAR and Review Proer.am
The GGNS UFSAR is expected to be maintained accurate and complete with emphasis
on that information regarding aspects of safety and licensed activities.10 CFR 50.34(b)
provides the general requirements for FSAR content. The requirements include: a
i
description of the facility, a presentation of the design bases, limits on operation, and the
'
safety analyses of systems, components and stmetures as well as safety analyses of the
facility as a whole. The emphasis of these descriptions and analyses are on the
performance requirements, bases, and technicaljustifications which show that safety
functions can be accomplished. In panicular,10 CFR 50.34(b) states, "The description
shall be sufficient to permit understanding of system designs and their relationships to
safety evaluations."
The GGNS UFSAR consists of 19 volumes and in many cases provides excessive details
that are not necessary for the understanding of how the system is capable of performing
its safety function in relation to safety analyses. In other cases, the absence of detail may
lead to an incomplete understanding of the system design or operation. In addition, the
GGNS UFSAR contains redundant information in different sections, which at times have
i
been found to be inconsistent. Although the UFSAR contains some information that is
unclear or in error, the results from various reviews, assessments, and inspections
associated with the UFSAR provide a high degree of confidence that these discrepancies
do not materially affect the ability of safety systems to perform their design function and
that an appropriate level of defense-in-depth protection is being maintained in accordance
with NRC regulations. The results of these reviews also have not revealed any recurring
failures to meet the requirements of 50.71(c) that would indicate current ,'rogrammatic
failures. Many of the discrepancies or ambiguities identified are early eroblems
-
.
White P per to Address NRC SSEI UFSAR Discrep;ncies Issue
.
associated with the original writing or revising the UFSAR. In addition, reviews,
assessments, and inspections have not found any significant issues regarding the quality
or conclusions of 50.59 safety evaluations which indicate that the UFSAR information is
of sufficient quality to support correct 50.59 evaluations.
GGNS has conducted several review initiatives beginning as early as 1984 to provide
assurance that the terms and conditions of the operating license and NRC regulations are
being complied with. In 1984, GGNS conducted a review to ensure that the Technical
Specifications were consistent with the FSAR, the SER, and the plant as-built design. In
1987 and 1988. GGNS conducted two independent reviews of the entire UFSAR to
ensure consistency and proper implementation of procedurally required activities. Over
3,000 items were entered into a plant database and cross-referenced to procedures that
implemented the requirements to ensure that these requirements were being properly
maintained.
In the wake of the Millstone issues in 1996, EOI conducted a sampling assessment of the
sites' UFSARs to determine with reasonable assurance the fidelity of and compliance
with the UFSAR. This initial review initiative was later adopted by NEI as a model for
other licensees. The general nature and scope of any discrepancies found by the reviews
were considered in order to determine whether additional significant resources should be
diverted to a comprehensive review effort. Some discrepancies were found in the GGNS
UFSAR, however no safety issues were identified. While some corrections and
clarifications were needed, the UFS AR was found to be reasonably accurate and most of
the discrepancies were found to be from original FSAR introduced errors. There were no
significant current programmatic failures identified.
As a result of the EOI assessment and the 50.54(f) letter regarding the adequacy and
availability of design basis information, GGNS initiated a review program with the scope
and resources that we believe is consistent with the safety significance of our findings. In
addition, personnel awareness of UFSAR discrepancy issues were heightened as has been
demonstrated by an increased number of Condition Reports written over the past two
i
years compared to previous years. The efforts include various types of UFS AR reviews
as described below:
1. Line-by-line reviews.
These reviews are a complete review of chapters or sections that may not be
considered in a system review but are judged to be susceptible to errors or to have
unclear wording.
2.' System consistency reviews
The UFSAR is being reviewed for identification of system related attributes which are
verified to be consistent with relevant system design basis information (i.e., SDCs,
calculations, modifications, design correspondence, etc.). Also, the system
commitment database information is reviewed to ensure the UFS AR properly reflects
this information when applicable. This review did not include a line-by-line
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White Peper to Address NRC SSEI UFSAR Discrepancies Issu
.
verification of compliance with Regulatory Guides associated with system design
guidance.
3. Review of miscellaneous topics
)
The UFSAR is also being reviewed by electronic search of special topics such as
{
operating condition restrictions associated with testing and UFSAR consistency with the
Improved Tech Specifications.
The present and past GGNS UFSAR review efforts are not designed to make the UFSAR
100% accurate cover to cover, but rather to provide reasonable assurance that plant
i
operation is consistent with the intended design and licensing basis. We believe the best
{
utilization of finite resources is to address issues commensurate with the safety
significance. Based on the nature of the items found to date, diversion of significant
.
additional resources to this review effort beyond what is already planned does not appear
I
warranted.
NRC Inspection Findings
The NRC inspection team findings are generally consistent with the type of discrepancies
identified during our previous reviews in that they are not the types of errors that raise
operability issues or otherwise materially affect safety or licensed activities. In addition
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many are mistakes or ambiguities introduced early in the original writing of the FS AR or
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during early UFSAR updates. We believe that the concerns can best be put into
perspective by identifying the nature of the discrepancies and distinguishing between
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information that should be improved for clarity and that information that is technically
wrong (i.e., errors). Based upon review of the discrepancies three categories have been
identified:
Vague / Misleading Wording - the wording of the UFSAR section was not technically
incorrect but led to the misunderstanding of the description or requirement. In our
opinion, we believe these should not be categorized as errors, but rather as areas needing
improvement or clarification.
Incorrect / Outdated Information - the description in the UFSAR was incorrect or had not
been revised to reflect changes made to the plant design or operation.
Typographical / Administrative Errors - these could be either technical or merely editorial
in nature and include one discrepancy that involved a missing figure from one controlled
copy of the UFSAR.
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The attached discussion categorizes each issue according to the above types of findings.
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Discussion of Discrepancies:
' A. Category:
Vague / Misleading Wording (Not Incorrect)
1. UFSAR Section 9.5.6.3 (Safety Evaluation for Diesel Starting Air Systan)
UFSAR Section 9.5.6.3 (page 9.5-37),3"' paragraph, states:
"... The system piping is installed at an elevation lower than the engine inlet, and is
provided with a drip leg to provide for removal of any water which may be present in the
lines..."
The inspector noted that not all of the air start system piping was below the engine inlet,
the portion coming from the top of the storage tanks is above the engine inlet.
Subsequent investigation by Design Engineciing found that the starting air for the
Division 1 and 2 diesels leaves the starting air storage tanks (2 per engine) at
approximately elevation 149' and that the engine inlet is at approximately 142'7" (for the
"B" and "D" trains "A" and "C" engine inlets are at approximately 143'7"). The portion
of the piping above the engine inlet elevation is approximately 21 feet long. Prior to
entering the engine the piping (for all four starirg air trains) drops to at least 136'4" for
some portion of it's run (the length of the portion below the engine inlet is at least 15
feet) and does include a drip leg for water removal as described in the UFSAR.
The UFSAR Consistency Reports for both the P75 and the P81 systems correctly
included this UFSAR Section for discussion but neither identified a discrepancy.
Thus, while this section is not literally correct (i.e. It overstates how much of the
system piping is below the engine inlet elevation), it is correct in its conclusion that
the starting air system piping design provides adequate provision for water removal
from the engine starting air. We agree that additional clarifying information is
needed.
2. UFSAR Section 8.3.1.1.3
UFSAR Section 8.3.1.1.3, page 8.3-9,5* paragraph, states:
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"The load shedding and sequencing system does not prevent load shedding of the
emergency buses in response to a loss of preferred power or a LOCA signal once the
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onsite sources are supplying power to all sequenced loads on the buses."
The use of the word " preferred" is misleading. This gives the impression that the
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discussion is about the offsite power source rather than emergency diesel
generators. Subsequent paragraph b has the same wording problem. We agree that
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clarification is needed. (It should be noted that the Load Shedding and Sequencing
system (system R21-1) has not yet had a Design Basis review.)
Discussion of Discrepancies:
A. Category:
Vague / Misleading Wording (Continued)
3. UFSAR Section 9.5.8.3
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UFSAR Section 9.5.8.3 (page 9.5-45,2 paragraph) which discusses the NEMA 12 (i.e.
dustproof) electrical enclosures associated with diesel generator electrical equipment -
appears to contain a typographical error " flyings". It was believed that this should be
" filings" or " flying insects".
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Subsequent investigation by Design Engineering found that the term " flyings" is a
correct (if somewhat esoteric) technical term for " materials of a larger particle size
than dust which are not normally in suspension in air" (Reference: Crouse-Hinds
definition of terms. Note that NFPA 70, National Electrical Code,1990 Edition,
paragraph 500-7(a); and OSHA Standards; Part 1910.334; Subpart S(d) both make
use of the term " flyings").
4. UFSAR Appendix 3A (ComDliance with NRC Regulatory Guides)
The inspector noted that in UFSAR Appendix 3A, there was no exception to our
commitment to Regulatory Guide 1.137 regarding the use of flame arrestors on fuel oil
storage tank vents in accordance with section 7.5 of ANSI N195-1976.
UFSAR Appendix 3A states that GGNS complies with the January 1978 (Revision 0)
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version of this Reg. Guide. This Reg. Guide in general invokes the standards of ANSI
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N195-1976. However, section 7.5 of ANSI N195-1976 is specifically excluded from the
Regulatory Guide.
RG 1.137 position C.I.h states:
" Section 7.5 of the standard includes requirements for fire protection for the diesel-
generator fuel-oil system. The requirements of section 7.5 are not considered a part
of this regulatory guide since this subject is addressed separately in more detail in
other NRC documents. Thus a commitment to follow this regulatory guide does not
imply a commitment to follow the requirements of Section 7.5 concerning fire
protection."
Therefore, exception to section 7.5 of ANSI N195-1976 should not he required for
compliance with RG 1.137.
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In Q&R 040.48 of the FSAR, the NRC requested that we revise some FSAR figures
to show name arrestors on the fuel storage tank vent lines like we did on the day
tank vent lines. Our response was provided in revised subsection 9.5.4.3. which
states that flame arrestors are not provided.
Discussion of Discrepancies:
A. Category:
Vague / Misleading Wording (Continued)
5. UFSAR Appendix 3A (Compliance with NRC Reeulatory Guides)
Appendix 3A states that GGNS complies with the January 1978 (Revision 0) version of
this Reg. Guide. This Reg. Guide invokes the standards of ANSI N195-1976.
Regulatory Guide 1.137 Fuel Oil Systems for Standby Diesel Generators includes the
following requirements which are not met at GGNS:
Section 6.1 of RG 1.137 specifies that the day tank suction shall be above the bottom of
the tank.
The GGNS day tank design is such that the suction is not off the side of the tank and
does not include a standpipe. However, the suction is not on the very bottom of the
tank (suction is off center and approximately 1" above the very bottom of the tank).
6. UFSAR Annendix 3A (Compliance with NRC Regulatory Guides)
Appendix 3A states that GGNS complies with the January 1978 (Revision 0) version of
this Reg. Guide. This Reg. Guide invokes the standards of ANSI N195-1976.
Regulatory Guide 1.137 Fuel Oil Systems for Standby Diesel Generators includes the
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following requirements which are not met at GGNS:
Section 5.3 of ANSI N195-1976 specifies that the fuel cil storage shall be sufficient for
seven days of operation or the time required to replenish the oil from sources outside the
plant site following a design bases event or accident, without interrupting the operation of
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the diesel (s), whichever is longer.
The evaluation of the ability to replenish oil within seven days described in the
UFSAR (Section 9.5.4.3) appears to have been informal (insufnciently detailed) and
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there is no action plan in place to ensure that this can be done. However, there is no
specific requirement in the Reg. Guide for either a formal evaluation or that an
action plan be developed and maintained regarding the seven day replenishment
criteria.
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Discussion of Discrepancies (Continued):
B. Category:
Incorrect / Outdated Information
1. UFSAR Section 8.3.1.1
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UFSAR Section 8.3.1.1, page 8.3-1,2 paragraph, states:
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"The ESF loads are divided in'to three divisions, each fed from an independent ESF bus...
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During normal operation, with all three ESF transformers available, each division of load
(i.e., Division 1,2, and 3) is supplied from a separate winding of each two-winding ESF
transformer..."
We believe that this may have been interpreted in the past as correct because each ESF
transformer is a two winding transformer and each division ofload is supplied from a
separate winding. There may have been some confusion also since the original design
was for the three transformers to supply both of the planned GGNS units (six ESF
busses). However, we agree that this description is not in accordance with present GONS
operating procedures which establish the preferred lineup with the 15AA bus being
powered off ESF transformer 11 while buses 16AB and 17AC are powered by ESF
transformer 21 (ESF transformer 12 from Port Gibson line is not used because the Port
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Gibson supply was felt to be less reliable than the other supplies ).
The GGNS procedure consistency review noted this UFSAR section but stated that "The
load distribution of ESF buses among ESF transformers is a function of the Load
Sequencing System as discussed in Section 8.3.1.1.3 (R21-1) and should be verified with
that system."
It should be noted that the Load Shedding and Sequencing system (system R21-1)
has not yet had a Design Basis review.
2. UFSAR Section 9.5.4.2
UFSAR Section 9.5.4.2, page 9.5-24, states:
"Each standby diesel generator is provided with a 100-percent capacity engine-driven fuel
oil pump... The day tanks are located above the suction elevation of the engine driven
pumps to assure a slight positive pressure on the inlet to the pumps, even at low fuel
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level."
The inspector noted that the UFSAR Section 9.5.4.2 discussion regarding relative
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elevation of the day tank vs. the engine driven fuel pumps arrangement (i.e. that the day
tank level is above the fuel pump suctions) did not appear to be true of the HPCS diesel
based upon what he observed during the NRC team walkdown of the system. His
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question was: Is the day tank elevation really higher than the inlet elevation of the fuel
oil booster pumps?
Discussion of Discrepancies (Continued):
B. Category:
Incorrect / Outdated Information (Continued)
2. UFSAR Section 9.5.4.2 (Continued)
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The UFSAR paragraph describing the fuel oil arrangement for the HPCS engines (page
9.5-24,6* paragraph) states that "...The day tank is located above the suction elevation of
the motor-driven pump to assure a slight positive pressure on the pump inlet."
Subsequent investigation by Design Engineering found that the minimum HPCS
day tank elevation (i.e. the level at which the fuel oil transfer pump turns on) is
approximately 6 inches above the motor driven fuel pump inlet piping connection
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(which is the end of the fuel oil piping going to the motor driven pump shown on the
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piping isometric) but approximately 2 inches below the centerline of the HPCS
engine motor driven pumps (not shown on the piping isometric) and therefore is not
correct. However, per information from the HPCS DG vendor manual, both of
these pumps need only 12 feet of suction pressure (absolute) and therefore there is -
no operability concern even at minimum HPCS day tank level.
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It is worth noting that, while the system P75 UFSAR Consistency Report did not
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identify this statement concerning the fuel oil piping arrangement as a discrepancy,
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it did identify the need for a review of available NPSH to the fuel oil pumps and the
need to clarify exactly what was meant by the wording in this section.
3. UFSAR Section 9.5.6.3
UFSAR Section 9.5.6.3, page 9.5-37a,1" paragraph, states:
"The performance of the DGSS filters and strainers for the standby diesel generators is
monitored by a pressure sensor located in each of the starting air lines just upstream of
the solenoid valves which admit air to the air header on the engine. The pressure sensors
detect pressure downstream of the final strainer in the system and signal an alarm on the
engine control panel when the starting air pressure is low ."
The actual configuration is that the strainers are downstream of the pressure
switches and therefore this description of the configuration and function of the
pressure switch is incorrect.
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It is worth noting that the System P75 UFSAR Consistency Review Report did
identify a problem with the description in this section not being correct (but did not
identify the exact same discrepancy regarding the pressure sensor being upstream of
the inlet strainers),
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Discussion of Discrepancies (Continued):
B. Category:
Incorrect / Outdated Information (Continued)
4. UFSAR Finure 8.3-007B
UFSAR Figure 8.3-007B was noted to be two revisions out of date.
No record of LDC transmittal could be found for these later revisions to E-1026. It
was noted that neither the E-1026 drawing nor UFSAR Figure 8.3-007B contain
cross-references to the other in their title block, this may have been a contributing
cause.
5. UFSAR Anoendix 3A (Compliance with NRC Renulatory Guides)
Section 2G of RG 1.137 states that provision should be made for adding fuel to the
storage tanks at low tank levels while the engine is mnning without causing sediment
contamination of new fuel.
It does not appear that any such provision has been made in the GGNS design.
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Discussion of Discrepancies (Continued):
C. Category:
Typographical / Administrative Errors
1. UFSAR Firure 8.3-9
UFSAR Figure 8.3-9 was noted to have a typographical error:
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"L.O.R" should be "LO.P"
2. UFSAR Firure 8.3-9
UFSAR Figure 8.3-9 was noted to have an error:
0.9 second time delay should be 9.0 seconds.
It should be noted that the Load Shedding and Sequencing system (system R21 1)
has not yet had a Design Basis review.
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3. UFSAR Table 8.3-9
Table 8.3-9 has 'lR20 FDR BRKR 152-1603 (XFMR FOR DRYWELL CHILLERS)'
listed twice, once on page 3 and again on page 4, additionally, the comments in the
" Remarks" column is not the same for each listing.
4. UFSAR Firure 9.2-06A
UFSAR Figure 9.2-06A was noted to be missing from the UFSAR set provided to the
NRC audit team.
This UFSAR set was immediately decontrolled and designated "For Information
Only" pending a page check. A spot check was conducted of three other controlled
UFSAR sets and all were found to properly include this figure. The omission is
therefore considered an isolated case regarding maintenance of an EOI manual.
The updated figure had been submitted to the staff in accordance with
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Summary
A total of 15 UFSAR discrepancies were identified by the NRC review team during the
course of the SSEI. The breakdown by category was:
Six discrepancies for vague / misleading wording.
Five discrepancies for Incorrect / Outdated Information.
Four discrepancies were Typographical / Administrative Errors.
Of the six identified " discrepancies" in the vague / misleading wording category the first
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two involved a minor description or wording problem. The third identified discrepancy
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(" flyings") is technically correct but alternate wording might be considered since this a
somewhat esoteric term. The fourth discrepancy related to the ANSI N195-1976 standard
for fuel oil storage tank vent flame arrestors is not truly a discrepancy since Reg. Guide 1.137 already takes exception to this requirement. The remaining two discrepancies are
related to Reg. Guide 1.137 requirements which, strictly speaking, have actually been met
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by GGNS.
Of the five discrepancies in the Incorrect / Outdated Information category three involved
minor wording or description problems, one involved failure to properly update
drawings / figures, and one involved incomplete compliance with Regulatory Guide 1.137
requirements (or failure to properly take exception to the requirement).
Of the four discrepancies in the typographical error category one was an insignificant
spelling error ("L.O.R." vs. "L.O.P."), one was a minor UFS AR figure error (0.9 vs. 9.0
seconds), one involved a duplicate table listing, and one involved improper mamtenance
of one controlled UFSAR set.
As was stated in the GGNS response to the NRC 50.54 (f) letter:
1. "... As an enhancement, selected systems / sections of the FSAR will be reviewed for
consistency with the supporting engineering documents. Licensing basis
improvements will be developed as appropriate."
A line-by-line review of the entire UFSAR for typographical and minor technical errors
was not intended. It was (and is) not believed that a massive review of this sort is
necessary or worthwhile. Per the GGNS response the review was performed for selected
systems only. A number ofinconsistencies and errors (i.e., typographical and minor
technical errors) have been noted by the review contractors during the course of their
consistency reviews and it is expected that still more will be found when the review
reports are reviewed by GGNS design engineering staff. The GGNS design engineering
reviews for systems P75, P81, R21, R21-1, and X77 have not yet been completed.
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It is current GGNS practice to identify and correct such errors when they are noted (using
either the Consistency Review Report Discrepancy process or the Condition Report
process, as required).
~ The Design Basis review scope was clearly intended to identify significant
' inconsistencies between the UFSAR and the design and regulatory basis documentation.
Given the type of discrepancies identified to date, GGNS plans to continue the UFSAR
consistency review as identified in the response to the 50.54(f) letter. Additionally, based
on the SSEI review discrepancies related to compliance with NRC Regulatory Guide 1.137, a review of GGNS compliance with selected NRC Regulatory Guides is planned.
Consistent with our current practice, the scope of this review may be expanded based on
the scope or nature of the findings resulting from the review.
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ATTACHMENT 3
INSTRUMENT SETPOINT PROGRAM
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INSTRUMENT SETPOIN f PROGRAM
The purpose of this paper is to address the observations of the
Instrument Setpoint Program made during the Safety System Engineering
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Inspection during February 22-26 and March 8-12,1999. The observations
indicated that the program appeared to be an area of weakness based on the
lack of setpoint calculations for some applications and setpoint calculations
which were not considered to be adequate.
10CFR50 Appendix A provides part of the regulatory basis for programs
to establish and maintain instrument setpoints. General Design Criterion
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(GDC) 13, Instrumentation and Control, requires in part that instrumentation
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be provided to monitor variables and systems, and that controls be provided to
maintain these variables and systems within prescribed operating ranges. GDC 20, Protection System Functions, requires in part that the protection system be
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designed to initiate operation of appropriate systems to ensure that specified
acceptable fuel design limits are not exceeded. Regulatory Guide 1.105,
' Instrument Setpoints', describes a method for complying with the regulations
with regard to ensuring that the instrument setpoints in systems important to
safety initially are within and remain within the specified limits.
The
regulations require that where a limiting safety setting is specified for a
variable on which a safety limit has been placed, the setting be so chosen that
automatic protective action will correct the most severe abnormal situation
anticipated before a safety limit is exceeded. The Reg. Guide endorses the
requirements established in ISA-S67.4-1982 for ensuring that instrument
setpoints in safety-related systems are initially within and remain within the
Technical Specif~ication limits. GGNS is not committed to Reg. Guide 1.105
as noted in UFSAR Appendix 3A based on the applicability date given in the
Instrumentsetpoint. doc
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guide. However, GGNS has established a program to generate and maintain
instrument loop uncertainty and setpoint calculations. The methodology
employed by this program is defined in GGNS Instrumentation and Control
Standard JS-09 and is based on ISA RP67.04, Part 2, Methodologies for the
Determination of Setpoints for Nuclear Safety-Related Instrumentation. This
recommended practice provides guidance for the implementation ofISA-S67-
04, Part 1. The GGNS program also employs methodology based on NEDC- 31336P-A, General Electric Instrument Setpoint Methodology.
Entergy Operations has established a corporate philosophy regarding
instmment uncertainties and their consideration at all EOI sites.
This
philosophy is discussed in Design Engineering guidance and incorporated into
site-specific standards. The philosophy recognizes that the formality and level
of detail provided to document instrument uncertainty and setpoints may vary
with respect to the importance to nuclear safety. The following types of
instrumentation applications typically require formal calculations due to their
high level of safety importance: safety-related Technical Specification
Limiting Safety System Setpoints (LSSS), safety-related Non-Reactor
Protection System Setpoints (instrumentation with active safety functions), and
Regulatory Guide 1.97 Type A Parameters. The methodology applied or the
necessity for a calculation should be commensurate with the safety
significance of the function evaluated.
The focus of the subject inspection was the emergency diesel generator
systems and their supporting auxiliary systems including the ventilation
system. The applicable Technical Specifications for these systems include
Section 3.3.8.1, Loss of Power Instrumentation (LOP), and Section 3.8,
Electrical Power Systems. The LOP instrumentation specification contains
allowable values for loss of voltage and degraded voltage setpoints. The
setpoints are established from original design criteria to support the equipment
connected to the bus. The setpoint values have been confirmed in detailed load
flow and voltage drop analyses from the bus down to the connected load. The
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sensing devices that monitor bus voltage are bi-stable devices which are highly
accurate and repeatable. However, margin is added in surveillance procedures
to account for the uncertainty associated with these devices and the calibration
equipment. It is noted that technical specification bases discuss setpoint
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calculations which specify nominal setpoints.
This bases section was
incorrectly incorporated from the generic improved technical specification
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bases in NUREG-1434 and did not consider the existing analyses. The voltage
drop analyses adequately demonstrate that sufficient power is available to
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emergency buses to support successful operation of the required safety
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functions during accident conditions.
Section 3.8 of the Technical Specifications contains requirements for AC
power sources (3.8.1 ) and for Standby Diesel Engine parameters including fuel
oil, lube oil and starting air (3.8.3). Section 3.8.1 also includes parameters
- related to the availability of the onsite AC power source such as fuel oil day
tank volume and fuel oil transfer system automatic operation. The values for
these parameters in the GGNS Technical Specifications are based on the
requirements of Reg. Guide 1.137 which state that the day tank shall maintain
a volume equivalent to 60 minutes of operation at the level where fuel oil is
automatically added and shall alarm at a level equivalent to 30 minutes of
operation. ~ GGNS maintains an instrument setpoint calculation for these
parameters which establishes nominal trip setpoints telated to analysis of fuel
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oil consumption rates for each diesel. It was noted during the inspection that
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this calculation does not include a rigorous application of instrument
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uncertainty. The basis established for the treatment of this parameter was that
the requirements being met are nominal values derived from standard practice.
The 60-minute and 30-minute volume requirements are not ultimate limits for
operation of the diesel. Therefore, there are no requirements for inclusion of
uncertainty.
The calculation demonstrates that the instrumentation is
appropriate for the application. This graded approach is consistent with
Section'4.0 ofISA S67.04, Part I which recognizes that for setpoints that may
not have the same level of stringent requirements as limiting safety system
setpoints, such as those that are not credited in the safety analyses or that do
not have limiting values, the setpoint determination methodology could be less
rigorous.
Section 3.8.3 of the Technical Specifications includes volume
requirements for fuel oil storage tank and lube oil volume as well as starting
air receiver pressure. The lube oil is measured via a dipstick directly in the
lube oil reservoir and the required volume is considered a nominal value.
There are no setpoint calculations for this measurement. The fuel oil storage
tank volume is measured by level instrumentation in the tank. The technical
specification requirement is based on inventory required for seven days of
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operation at maximum expected post-LOCA loading coaditions. These load
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requirements are conservatively calculated with margin including an allowance
for uncertainty in the level measurement used to confirm the volume. The
level is monitored by Operations personnel- to ensure the Technical
Specification value is met. There are no instrument uncertainty calculations
based on the inclusion of uncertainty in the fuel consumption analysis. In
addition, alarm setpoints are established at nominal values based on original
design criteria. These alarms serve to alert operators of changing conditions.
Uncertainties are adequately controlled by use ofinstrumentation that has been
properly chosen and that is maintained and calibrated in accordance with
established site practices.
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The starting air pressure requirements in the Technical Specifications are
based on a minimum capacity for a required number of start attempts. The air
pressure value is confirmed by conservative design analysis of the system and
is maintained by procedure with margin to account for various uncertainties.
Sufficient margin is maintained for Division I and II to ensure performance of
the function. The Division III Diesel Generator has initiation logic with
starting air pressure interlocks. A setpoint calculation is maintained for these
interlocks based on the safety function performed by the instrumentation. The
pressure switches utilized are direct acting with no electronic components.
Therefore, the loop uncertainty is limited to the accuracy of the switches.
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Environmental effects are negligible based on the location of the switches.
The setpoints were established as nominal volumes by the diesel manufacturer
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and were determined to be acceptable for their application. This approach is
consistent .with the setpoint methodology in Standard JS-09 discussed
previously. An instrument uncertainty calculation is also maintained for the
Division III starting air pressure loops which are categorized as Reg. Guide 1.97 variables and are required for post accident monitoring. This calculation
accounts for applicable environmental conditions to determine the total loop
uncertainty associated with the measurement in accordance with the
methodology in Standard JS-09. These calculations were discussed during the
inspection.
Additional system setpoints required for operation of the diesel generators
were reviewed and determined to be adequate based on design requirements
established by the manufacturer. In many cases the switches are utilized as
logic devices to indicate that conditions have been met and instrument
accuracy was not considered to be critical for the applications. Therefore,
setpoint calculations have not been performed for these instruments. The
setpoints are maintained under design control and calibrated in accordance
with established site practices.
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GGNS does maintain detailed instrument setpoint calculations for
safety-related active function setpoints that are performed in accordance with
standard methodology. There are presently almost fifty instrument setpoint
calculations for parameters included in the Technical Specifications and over
thirty instrument uncertainty and setpoint calculations for safety related
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parameters which have been performed in accordance with the standard
methodology.
It is noted that the systems reviewed during the recent
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inspection have only a limited number of these calculations. Based on
discussion of the applications above, however, it is felt that the existing
analyses are appropriate and meet applicable requirements. In addition, the
setpoint program established at GGNS is considered acceptable for providing
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assurance that automatic actions will occur before safety limits are exceeded.
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