ML20209D767
| ML20209D767 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/01/1999 |
| From: | Hughey W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-97-05, 50-416-97-5, 50-416-99-02, 50-416-99-2, GNRO-99-00051, GNRO-99-51, NUDOCS 9907140018 | |
| Download: ML20209D767 (19) | |
Text
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h[J EntIrgy operttions,Inc.
PO. Box 756 Port Gbson, MS 39150 l,.
Tel 0014374470 i
, July 1,1999 W.K.Hughey twcw Nadeur S#et/ & RO7.Jld1CFy Affss i
U.S. Nuclear Regulatory Commission l
Document Control Desk Washingtcn, D.C. 20555
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Attention:
Document Control Desk
Subject:
G and Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Reply to inspection Report Report No. 50-416/99-02 Dated May 18,1999 (GNRI-99/00030)
GNRO-99/00051 l
Gentlemen:
Entergy Operations, Inc. hereby submits a response to inspection Report (IR) 50-416/9E-02. The inspection involved a safety system engineering inspection conducted February 22-26 and March 8-12,1999. The inspection also included a review of the 10 CFR 50.59 program, engineering staffing and backlog, and review of previous NRC inspection findings.
The IR identified some general areas of concem and two non-cited violations (NCVs). We appreciate the thoroughness of the inspection by the team and the insights provided to us. However, in reviewing the report, we identified some
'I apparent misconceptions by the inspection team that warrant further explanation.
The report addresses the NRC's view in some areas without offering the l
corresponding discussion of the licensee's differing opinion that we had with the inspectors in some instances, we have had the benefit of additional time to review the circumstances surrounding issues raised by the inspectors and now have additionalinformation to share. We believe that the inclusion of this additional information would provide a more complete picture of the issues. In this respect, qj we appreciate your inclusion of the Entergy white papers with the IR. However, fy there are specific areas that warrant additional discussion beyond that provided by
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the Entergy white paper. These areas concem the inspection team comments i
regarding closure of violat:on 50-416/9705-03, the division ll1 emergency diesel generator lube oil sump levels, and setpoint and scaling calculations. These are i
discussed in Attachment 1.
9907140018 990701 DR ADOCK 0 6
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GNRO-99/00051 ~
Page 2 of 5 l
I Additionally, there were a number of examples of UFSAR " discrepancies" identified by the team that Entergy does not consider to be discrepancies. Sdne of these were addressed in the Entergy white paper included as an attachment to the IR. We feel such discussion is important given that the NRC inspectors considered the identification of multiple [ emphasis added] discrepancies as the basis for concluding l
that a potential weakness involving the overall fidelity of the UFSAR and the L
adequacy of the UFSAR review project may exist. ' Entergy's differing views of some -
l of the discrepancies are provided below and in Attachment 2. When reviewing the UFSAR for accuracy, it is important to differentiate between discrepancies (i.e.,
l those conditions where the plant is in conflict with the UFSAR) and areas where the information may be improved in presentations or description but is neither material in terms of the design, operating or licensing basis).
- Based upon the NRC comments, the contractor performance has been re-evaluated in regards to the UFSAR reviews. Of the 20 identified discrepancies in the IR, Entergy contends that 10 were not discrepancies. In fact the IR states that the team concurred with Entergy's assessment that some of the items were more misleading than incorrect. Of the 10 remaining discrepancies,3 involved issues previously identified by either the contractor or the licensee. Two, while incorrect, were f
determined to be at a level of detail beyond the scope of the review expected of the contractor. The remaining 5 discrepancies were arguably within the contractor scope of review and therefore were expected to have been identified by the contractors. it should be noted that the contractors had identified three of the discrepancies to some extent and that the Entergy reviewers may have very well identified the specific concems discussed in the report. For example, the issue conceming the diesel air start filters and strainers arrangement not matching the UFSAR description had been noted as a discrepancy by the contractor. Although the issue conceming its operational performance, i.e. that the pressure sensor was upstream of the strainers and would therefore not detect pressure downstream of the strainers as described, had not been specifically identified, it is likely that the operational performance issue would have been identified by Entergy reviewers either during our review or when the discrepancy was resolved at a later date. We, as the NRC, are disappointed that these disc *epancies had not been clearly identified, but reemphasize that the Entergy eview of the contractor's work had not been completed at the time of the inspection. Overall, Entergy contends the contractor performance on design bases proje::t work has been acceptable.
- However, there have been isolated cases of poor contractor performance and Entergy has taken the appropriate steps to address the performance issues to
. ensure a quality end product.
Entergy also contends that the statems...t "W., team did not believe that the licensee's review would have likely identifiea most of the discrepancies identified by
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GNRO-99/00051 g
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, the team." was overly broad and we are not aware of the basis for this statement. In l.
fact, of the system reviews which had been completed as of June 3,1999, Entergy had identified an additional 36 UFSAR disparities (including actual errors and information needing clarification) over the 84 disparities identified by the contractors.
At the time of the SSEl exit these Entergy reviews had not been completed. In accordance with the design basis project plan Entergy is required to review and approve all contractor work. This approach was designed to obtain a second level review by the site design engineers who maintain ownership of the final product.
This second level review ensures contractual obligations are met and additionally provides the design engineers an opportunity to comment on and make Improvements on a broader sce!e as compared to the contractor review; thus the additional 36 UFSAR disparities.
l Summarizing the 10 actual discrepancies discussed above, 3 were clearly previously identified, 3 were partially identified by the contractors, 2 were not identified by the contractors, and 2 were outside of the contractor's scope. As previously noted Entergy's reviews had not been completed at time of the inspection i
exit. We feel confident that completion of the Entergy review process would have captured the majority of these 10 discrepancies identified during the inspection.
This is based on the fact that Entergy reviews completed to date have identified a number of both issues that were within the contractor's scope and which were beyond the scope of the onginal project plan used by the contractors for performing their reviews.
~ One of the insights provided by the inspection was that a detailed review of Regulatory Guides associated with the systems was not performed nor was it an l
expectation by Entergy that this level of review be performed. The team raised four L
issues related to Regulatory Guides. Even though the issues were not considered l
true discrepancies as either noted in the Entergy white paper or Attachment 2, we nevertheless plan to expand our UFSAR review to include certain Regulatory Guides associated with system requirements.
r Entergy understands the importance of maintaining the UFSAR complete and i
accurate. We have, as far back as 1984, placed a great deal of emphasis on l
ensuring the accuracy of the GGNS UFSAR (see Attachment 3). In all of these
. events, our philosophy and focus has been to ensure consistency between the i-design, operating and licensing bases of the plant. Although the UFSAR may contain some information that is unclear or in error, the results from various reviews, assessments, and inspections associated with the UFSAR provide a high riegree of confidence that these discrepancies do not materially affect the ability of safety I
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 l
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GNRO-99/00051 Page 4 of 5 results of these reviews also have not revealed any recurring failures to meet the requirements of 50.71(e) that would indicate current programmetic fa'ilures. Many of the discrepancies or ambiguities identified are early problems 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 technically sound 50.59 evaluations.
Consistent with our philosophy, our current UFSAR review efforts are intended to focus resources to ensure compliance with the design, operating, and licensing bases. GGNS initiated the review program with the scope and resources that we
' believe is consistent with the safety significance of our findings to'date. 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 years compared to previous years. In addition to the contractor system reviews, j
we have also completed or are in the process of completing reviews by members of the Entergy staff. These reviews include line-by-line reviews of important sections or chapters such as Chapter 15, Accident Analyses; Chapter 13, Conduct of I
Operations; Chapter 11, Radioactive Waste Management, and Section 6.3, Emergency core cooling systems. Entergy has also increased the scope of the design basis project to include a line by line verification of UFSAR Sections 7.3 and 7.4 and a similar verification review of the Appendix 3A description of GGNS compliance with selected NRC Regulatory Guides. The UFSAR is also being reviewed by electronic search of special topics such as operating condition restrictions associated with testing and to ensure UFSAR consistency with the Improved Tech Specifications.
Following completion of current UFSAR review efforts, GGNS plans to further improve UFSAR ownership across site departments. This initiative includes the I
development of a fidelity document which incorporates guidance from NEl 98-03 (after the latest versio'n is issued) and assigns UFSAR information owners. The l
expectation would be that the department owners would review all future changes to those sections as well as reviewing those sections for general fidelity in day-to-day usage.
We wish to thank the NRC for the insights provided by this inspection and
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appreciate your consideration of these additional comments in formulating your final opinion regarding these findings and programs.
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- GNRO-99/00C51 -
Page 5 of 5.
1 Should you have any questions regarding these comments or issues, please feel free to call me.
Yours truly, i
/RWB attachments: (1)
Discussion of IR 50-416/99-02 Comments -
(2).
UFSAR Statements Incorrectly Categorized as Errors (3)'
GGNS UFSA,4 Review Program cc:
Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter) (w/a) -
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011 Mr. S. P. Sekerak, NRR/DLPM/PD IV-1 (w/2)
U.S. Nuclear Regulatory Comm',sion One White Flint North, Mail Stop 13D18 11555 Rockville Pike Rockville, MD 20852-2378 l
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Attachm:nt 1 to GNRO-99/00051 Page 1 of 5 Discussion of IR 50-416/99-02 Comments l
4 Closure of Violation 50-416/9705-03 The inspectors closed violation 50-416/9705-03 with the following comments:
l The cover letter to IR 50-416/99-02 stated:
The team identified that the corrective actions taken in response to two previous violations (one involved past Updated Final Safety Analysis Report discrepancies) and several condition reports did not address oridentify the l
causes of the problems, were limited in scope, or were not fully effective in correcting the problem.
j Additionally, section E.8 to the IR stated-The team noted that the scope of the corrective actions applied to this i
violation was limited in that the review for similarproblems was limited to Revision 6 of the Updated Final Safety Analysis Report. Revisions prior to j
Revision 6 were performed with contractor support, and subsequent revisions were allprocessed 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 ajustification that the problems were unique to Revision 6.
i This particular issue involved a UFSAR figure that was not deleted in Rev. 6 of the UFSAR when the Unit 2 construction permit was cancelled. A new figure reflecting single unit operation was added, but the old figure indicating two unit operations was l
not deleted, even though the UFSAR Change Notice (CN) indicated that it should have been deleted. A quick check of the UFSAR CN for the cancellation of unit 2 showed that additional pages were also not updated correctly. This review was then expanded to all of Rev. 6 for the reasons noted in the Condition Report (CR). The CR stated "It should be noted that this was an extensive FSAR update with a compressed time schedule and the first update to be completed with all in-house personnel (previous updates utilized contractor support)."
The review of the Rev. 6 documents involved approximately 4 man-weeks of effort reviewing each page of Rev. 6 update package. In addition, GGNS performed reviews that were not explicitly documented in the CR response. As discussed with the inspector, we found [during our complete review of Rev. 6) that most of the errors were evident by the fact that the page revision index indicated that the pages should have been Rev. 6, but were not, in addition to this complete review of the Rev. 6 update package, we also compared all pages (regardless of the revision number], of L
the UFSAR with the page revision index. This additional review, although not clearly l
documented in the CR, did not reveal any similar problems as compared to the Rev.
Attichm nt 1 to GNRO-99/00051 Page 2 of 5 6 update package. This provided reasonable assurance that these administrative problems (i.e., not including all submitted changes in the update) were limited to Rev.6 for the reasons noted above.
While these actions were not explicitly' documented in the CR disposition and closure, we had discussed our additional actions with the inspector. We believe that it is inappropriate to characterize the issue as "the licensee did not have a justification that the problems were unique to Revision 6." While you may not agree with our conclusions or the basis for our conclusions, the statement that the licensee
' did not have a bstification is in our view inappropriate.
Division ill Emergency Diesel Generator Lube Oil Sump Level
-IR excerpts from Section E.2.2b of the IR stated:
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 specification basis for the increased consumption rate. At the start of the inspection, the licensee could not verifyif the diesel generator was operating within the design basis during extended runs.
The team was satisfied that the licensee's current operating procedures ensured that the Division III emergency diesel generator was meeting the
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technical specifications and the design bases.
The licensee's handling of this event was lacking in that it appeared that the i
final resolution of the issue was driven by the questioning from the team.
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Comment:
It was GGNS personnel's questioning attitude that first raised this concern, and resolution was being pursued under the GGNS corrective action program prior to the team inspection. We are not aware of any other licensees that have pursued quantification of actual lube oil consumption and adjusted lube oil inventory based on actuallube oil consumption. Furthermore, there is currently no Technical Specification surveillance or otner regulatory requirement to conduct any such quantification of lube oil consumption. The Technical Specification Bases for surveillance requirement 3.8.3.2 specifically requires the lube oil inventory be maintained to support at least 7 days of maximum expected post LOCA load based on vendor supplied consumption rates for the run time of the engine. The tests and i
. subsequent actions were licensee initiated without regulatory prompting or intercession.-
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GtIRO-99/00051 Page 3 of 5 it is important to note that activities by GGNS to evaluate and resolve division ll1 lube oil inventory concerns have consisted of two separate issues - the first being (a) inventory bayonet gage level verification concerns related to Tech Spec requirements; and the second, (b) lube oil consumption concerns.
The first issue was identified by Condition Report (CR) 96-0174 on 10/18/96 At that time, the only concern was establishing proper levels to be maintained on the bayonet gage for various operating conditions (standby vs. running). The s
Engineering Request (ER) that precipitated the lube oil sump calibration (ER l
97/0682-00-01) was dated September 97. The second issue, lube oil consumption concerns, did not arise until 6/21/98 when operations generated CR 98-0733. On 6/26/98 activities were begun to determine lube oil consumption rate. The sump calibration data collection and engine lube oil consumption tests were completed in spring and summer of 1998. An operability determination was made at the conclusion of tta consumption test on 8/14/98 and new lube oil level requirements were established based on the consumption rates. It was felt that these actions were adequate and conservative and the remaining work could be prioritized and scheduled along with other engineering activities. It was a coincidence that Engineering Report 99-0005 was completed on March 8,1999. The entire issue was licensee initiated and continues to be tracked by the CR process.
GGNS finds two team statements confusing: "At the start of the inspection, the licensee could not verify if the diesel generator was operating within the design basis during extended runs." The second team statement: "The team was satisfied that the licensee's current operating procedures ensured that the Division 111 emergency diesel generator was meeting the technical specifications and the design bases."
GGNS has maintained compliance with system operating procedures, which support the design and licensing basis of the system. All of the effort by GGNS to define the lube oil consumption and the lube oil sump volume were made to confirm and support this design basis, in conclusion, it is the opinion of GGNS that the response was timely and commensurate with the safety significance of the issue. Throughout this time period, GGNS continued to ensure that the Div Ill engines were operated and maintained in accordance w;th existing licensing basis requirements. The Technical Specification values and the basis for those values as defined in the Bases of the Technical Specifications were also met.
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GNRO-99/00051 L
Page 4 of 5 Setpoint and Scaling Calculations The following-comments are provided relative to statements made in section E1.2.1.b regarding setpoint and scaling calculations.
'The team noted that the methodology did not identify or define Technical Specification allowable values with respect to the methodology's allowable values."
The methodology is given in Instrumentation and Controls (l&C) Standard GGNS-JS-l 09, ' Methodology for the Generation of Instrument Loop Uncertainty & Setpoint l
Calc'ulations'. This l&C standard was reviewed by the Inspection Team as noted in I
the IR. Section 3.1.1 of the standard defines allowable value as the maximum acceptable deviation of the process variable from the nominal trip setpoint toward the analytical limit for which the trip function is not required. The intent of setpoint l
calculations is to confirm that the Technical Specification allowable value is conservative relative to the calculated allowable value. Section 4 defines L
methodology for calculating the allowable value given an analytical limit. The I
difference between the allowable value and the analytical limit includes loop calibration uncertainties which account for measurement and test equipment uncertainties. In addition, the difference between the analyticallimit and the allowable value includes loop uncertainties for the device, process measurement, primary element, and insulation resistance effects. The difference between allowable value and the setpoint accounts for loop drift between calibrations. This methodology is consistent with General Electric Instrument Setpoint Methodology.
' Therefore, the methodology ensures that appropriate uncertainties are accounted for i
in establishing the setpoint with respect to the analytical value.
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'The team reviewed Calculation JC-Q1P75-90040, Standby Diesel Generator Fuel Oil Day Tank Volume and Level Setpoint Calculation, Revision 3, for
-level switches 1P75-LIS-N602A/B... 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 ' inaccuracies or uncertainties."
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.One of the purposes of the. subject calculation is to establish setpoints for the level
. instruments associateo with the day tanks. The setpoint for level switches 1P75-LIS-N602A/B is based on the requirements of Reg. Guide 1.137 which invokes ANSI N195-1976. The ANSI standard states: "Each diesel shall be equipped with day or integral tank or tanks whose capacity is sufficient to maintain at least 60 minutes of operation at the level where oil is automatically added to the day or integral tank or tanks. This capacity shall be based on the fuel consumption at a load of 100% of the continuous rating of the' diesel plus a minimum margin of 10%." The calculation also L
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establishes the volume of the day t&%s and correlates required volume to tank level.
The tank level determined for the required volume plus a 1.5" margin is stated as the setpoint because the level requirement is based on a standard value and not on an equipment operating limit.~ As a result, instrument accuracy and loop uncertainties are not critical to the application. Therefore, the calculation does not consider the type of level sensor or bop components. The system design ensures that the installation utilizes components suitable for the application.
Attichm:nt 2 to GNRO-99/00051 Page 1 of 7 UFSAR Statements Incorrectly Categorized as Errors.
Inspection Report Section E.1.1.1.b 3.
Updated Final Safety Analysis Report, page 9.5-30, indicated that the standby diesel engine and the high pressure core spray diesel engine can operate for a minimum of 30 days without additionaljacket water being required. Tne 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.
Comment:
This item was not addressed in our white paper, as we were not aware that this was being considered a discrepancy. This UFSAR statement on page 9.5-30 regarding the ability to operate the EDG for 30 days without the need for Jacket water makeup is true for the nornni (non-degraded) system condition. During our design basis review effort, the contractor identified this UFSAR statement as having no apparent design or regulatory basis.
Nonetheless, an informal calculation was performed in 1998 that concluded that the system could operate for 30 days without makeup (assuming the system is in a non-degraded condition -1.e., no leakage).
The Inspection Report statement "The licensee had previously identified that this statement could not be met" refers to a temporary condition of excessive system leakage for which we determined that the system s'hould be considered degraded but operable with a 7-day supply under the guidance of Generic Letter 91-18. The system leakage was subsequently corrected.
Temporary degraded conditions that deviate from the UFSAR should not be considered a UFSAR discrepancy. In addition, although the 30-day statement appeals to have no basis, the system design can accommodate this and is therefore consistent with the UFSAR.
5.
Updated Final Safety Analysis Report, page 9.5-37, indicated that the standby diesel generator air-start system piping was installed at an elovation lower l
than the engine inlet, and was provided with a drip leg to provide for removal l
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 I
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7 Attachmsnt 2 to GNRO-99/00051 Page 2 of 7 system piping 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.
Comment:
As addressed in our white paper, we agree that these statements could be improved with additional clarifications as to the extent of the system piping that is installed lower than the engine inlet. But we do not agree in principle that the statement should be considered an error or discrepancy (i.e., an l
example of a NCV). The statement correctly describes provisions for water removalincluding the design attributes of the system supply piping being
. installed at an elevation below the air start valves. The text does not state that all system piping is below the elevation of the engine inlet and is taken too literally to mean "all system piping".
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 severalnonconformances to the Regulatory Guide or to the standard it endorsed (ANSI N195-1976, " Fuel Oil Systems for Standby Diesel-Generators ~). These nonconformances are i
listed below:
(a)
Suction from the day tanks was essentially from the bottom l
(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.I.137-l/-2) of the nonconformance with the Regulatory Guide / ANSI Standard in this regard. The licensee initiated Condition Report CR-GGN-1999-0325 to document this discrepancy.
The team did not consider the day-tank fuel oli suction configuration to represent an operational concem because, historically, sediments have not been a concem in these tanks.
Comment:
As stated in our white paper on this issue, the GGNS design is such that the suction is not off the very bottom of the tank, but is installed off-center of the lowest point of the bottom. As noted in the report I
there is no operational concern as demonstrated by a lack of sediment collection in these tanks. We believe this meets the intent of the Regulatory Guide and agree that clarification should be added to
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Attachm mt 2 to
- l'O-99/00051 Page 3 of 7 Appendix 3A to clarify how the intent is met, but a not agree that this should be considered a discrepancy.
(b)
Flame arrestors were not installed in the fuel oil storage tank gooseneck ; snts. 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-l/-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
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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 operationalconcem.
Comment:
As stated in our White Paper on this subject, we do not consider this to be a discrepancy because RG 1.137 does not invoke this section of the ANSI. Therefore, no exception to the RG is required.
l RG 1.137 position C.1.h states:
"Section 7.5 of the standard includes requirements for fire protection i
for the diesel-generator fuel-oil system. The requirements of section
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7.5 are not considered a past of this regulatory guide since this subject i
is addressed separately in more detailin other NRC documents. Thus a commitment to follow this regulatory guide does not imply a
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commitment to follow the requirements of Section 7.5 concerning fire protection."
i Therefore, a licensee can comply with the Regulatory Guide without taking an exception to ANSI N195-1976 regarding the fire protection requirements.
(c)
. ANSIN195-1976, 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 l
from sources outside the plant site following any limiting design-basis event, whicheveris 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 initiated to review this matter. Because of the nearby availability of many fuel oil sources, the team did not believe that the worst-case replenishment time would exceed 7 days.
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Attachmsnt 2 to GNRO-99/00051 Page 4 of 7 Comment:
We have conducted additional research on this item since issuance of our white paper, which categorized this as vague or misleading wording rather than a discrepancy. We have concluded that a detailed and documented evaluation, beyond that addressed in the UFSAR, is not required to determine a worst-case replenishment time. During the initiallicensing of GGNS, the NRC accepted a 7-day onsite fuel oil storage supply based on reasonable assurance of availability of sources and ability to deliver those sources. Since it was reasonable to conclude that additional fuel oil could be obtained within 7 days, no formal evaluation of a maximum delivery time was required. It appears from the latter statement in the above NRC team inspection comments that the team also concluded that the fuel oil could reasonably be obtained within 7 days.
Prior to initial licensing, GGNS FSAR section 9.5.4.3 stated that replenishment resources could be obtained locally and 25 to 40 miles away. During initiallicensing, the NRC requested GGNS to provide a listing of these sources and discuss their delivery under abnormal environmental conditions (i.e., dust storm, high winds, heavy rain, etc.). The response is documented as Q&R 040.46. GGNS identified some local sources and a Vicksburg company with both barge and I
truck terminals as possible suppliers and noted that these sources were not under contract. The GGNS response also described the availability of diesel fuel stored at the Natchez Steam Electric Station and the Baxter Wilson Steam Electric Station. The' reply noted that access to US Highway 61 and river barges provided adequate access even during abnormal weather conditions.
The above discussion was a general assessment that provided j
reasonable assurance of fuel delivery within 7 days'. The NRC review staff accepted this response by issuance of the operating license and accompanying Technical Specifications that established the 7-day i
onsite fuel supply requirement.
It is noted that the Natchez Steam Electric Station no longer maintains the storage of diesel fuel. That discrepancy was noted as being identified by the licensee and is addressed by item 2 in section E.1.1.1 of the report.
(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 oilis automatically added to the day tank. The day-
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GNRO-99/00051 Page 5 of 7 lank level at which the associated transferpump star 1s corresponded to a volume sufficient to maintain only 30 minutes (not 60 minutes) of operation. Although the team did not have an operational concem with this design feature, there was not a clear exception taken in the Updated Final Safety Analysis Report (on page 3A.I.137-l/-1) to this apparent inconsistency with the Regulatory Guide.
Comment:
i This item was not addressed in our white paper since we were not aware that this was being considered a discrepancy. We maintain that there is no discrepancy related to compliance with the above ANSI 1
section. Per Calculation JC-Q1P75-90040, Rev. 2, and Drawing J-KB1692 the Div.1 and 2 transfer pumps turn on at 39 inches in the tanks which is equivalent to 439 gallon in the day tank. This amount of fuel oil is sufficient for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of operation plus 10% margin per the ANSI Standard. The low level alarms for these tanks actuate at the level which is equivalent to the amount of fuel required for 30 minutes of engine operation at full load (approximately 200 gallons). This is per GGNS Tech Spec requirements.
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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-Q1 P75-90190, ' 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 66 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
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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 concem existed.
Comment:
This item was also not addressed in our white paper. The UFSAR is correct in stating the usable capacity of the tanks. In fact, the usable capacity is actually more than stated due to the unaccounted for volumes in the tank ends. The calculations referred to in the report were developed to determine required capacity rather than : sable capacity. These calculations determined that 61,914 gallons were required for Division 1 and 41,158 gallons were required for Division 3. The 62,000 gallons and 41,200 gallons
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Attachm:nt 2 to j
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GNRO-99/00051
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Page 6 of 7 j
discussed are the Tech Spec required values which are rounded up (for simplicity and conservatism) from the actual required values determined by the calculations. The tank levels presently used to verify the Tech Spec
. requirements do not take credit for the amount of fuel in the tank ends which is a very conservative approach.
. Inspection Report E1.2.1.b 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 ofpreferred power or a loss-of-i coolant accident signal once the onsite sources were supplying power to all sequencedloads on the buses. This statement was misleading because it was true, independent of the power supply status of the onsite sources.
i Comment:
l We agree that this statement is more misleading than incorrect and should be considered for clarification but should not be considered a discrepancy.
Inspection Report E8.8.b 3
The team discovered several errors in the latest revision of the Updated Final Safety Analysis Report, as described in Sections EI.I.I and EI.2.1 of this report. In addition to these findings, two engineering drawings the team used as part of the detailed engineering inspection of the plant's standby diesel generators were observed to contain the wrong revision:
Updated Final Safety Analysis Report Figure 9.5-011, " Standby Diesel Generator System Unit 1"(Division I) was Revision 30 of P&lD M-1070A
. dated October 31,1997, whereas the current revision of P&lD M-1070A was
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Revision 31 dated November 11,1998.
Updated Final Safety Analysis Report Figure 9.5-012, ' Standby Diesel Generator System Unit 1"(Division II) was Revision 26 of P&lD M-1070B dated October 3,1997, whereas the current revision of P&lD M-1070B was Revision 27 dated November 13,1998.
i Comment:
The inspection Report noted in s0ction E8.8.b that the latest revision of the UFSAR was completed on November 11,1998 (the actual submittal date was November 19,1998). Per 10CFR50.71(e), the UFSAR revision "shall bring i
the FSAR up to date as a minimum of 6 months prior to the date of filing the
)
revision."
i
e Attachmsnt 2 to GNRO-99/00051 Page 7 of 7 Therefore, the revisions of the drawings discussed above are not required to be updated in the UFSAR until the next revision scheduled for May,2000.
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j Attichm:nt 3 to GNRO-99/00051 Page 1 of 2
- GGNS UFSAR Review Program The GGNS UFSAR is expected to. be maintained accurate and complete with emphasis placed on that information regarding aspects of safety and licensed activities. 10CFR
' 50.34(b) provides the general requirements for FSAR content. The requirements l
include: a description of the facility, a presentation of the design bases, limits on i
operation, and the safety analyses of systems, components and structures as well as I
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 particular,10 CFR 50.34(b) states, The description shall be sufficient to permit understanding of system designs and their l
relationships to safety evaluations.
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- 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 hav been found to be inconsistent.' Although the UFSAR contains some
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informatior'
.t is unclear or in error, the results from various reviews, assessments, and inspectiont,sociated with the UFSAR provide a high degree of confidence that these I
discrepan 3 do not materially affect the ability of safety systems to perform their design
. function anc. that an appropriate level of defense-in-depth protection is being maintained l
In accordance with NRC regulations. The results of these reviews also have not l
revealed any recurring failures to meet the requirements of 50.71(e) that would indicate current programmatic failures. Many of the discrepancies or ambiguities identified are l
early problems associated with the original writing or revising the UFSAR. In addition, l
reviews, assessments, and inspections have not found any significant issues regarding l-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. GGNS and its contractors dedicated approximately 7000 person-days to this extensive review. 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 prt. xtures that implemented the requirements to ensure that these requirements were l
being properly maintained.
In the wake of the Millstone issues in 1996, Entergy conducted a sampling assessrnent 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 NEl 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
F e
Attichmcnt 3 to GNRO-99/00051 Page 2 of 2 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 UFSAR 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 failure identified.
As a result of the Entergy assessment and the 50.54(f) letter regarding the adequacy and availability of design basis information, GGNS initiate.,d 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 years compared to previous years. The efforts include various types of UFSAR 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 UFSAR properly reflects this information when applicable. This revie' did not include a
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w line-by-line 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 of the consistency and accuracy of the design, operating and licensing bases. We believe the best utilization of finite resources is to address UFSAR discrepancies as we do other
- issues; commensurate with the safety significance. Consistent with this philosophy, Entergy believes it is not only prudent but appropriate to focus our resources in ensuring consistency and accuracy of the design, operating and licensing bases of the plant.
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