ML20210C148
| ML20210C148 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Grand Gulf |
| Issue date: | 03/04/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Asselstine NRC COMMISSION (OCM) |
| Shared Package | |
| ML082401831 | List: |
| References | |
| FOIA-86-126, FOIA-86-127, FOIA-86-131, FOIA-86-80 EA-84-075, NUDOCS 8603110074 | |
| Download: ML20210C148 (3) | |
Text
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" MEMORANDUM FOR: Comissioner Asselstine FROM:
Victor Stello, Jr.
Acting Executive Directdr for Operations
SUBJECT:
SECY 86-29 RESPONSE TO MISSISSIPPI POWER AND LIGHT COMPANY (GRAND GULF) TO PROPOSED CIVIL PENALTY FOR MATERIAL FALSE STATEMENTS REGARDING TECHNICAL SPECIFICATIONS (EA 84-75)
In your February 6, 1986 memorandum to me on the subject issue, you indicated "...that the agency still did not, at the time of the NOV, fully understand what was in the Grand Gulf tech specs." On this basis, you
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posedthe[ollowingquestionsfor.whichyourequestedanswersfromthe staff:
1)
To what extent do the errors in the Notice of Violation reflect an inadequate understanding or review of the Grand Gulf technical specifications?
2)
To what extent does this suggest a need to apply more resources to the review of technical specifications?
3)
Are existing technical specification review procedures adequate to ensure an understanding of the sufficiency of technical specifications?
Enclosed is the staff's response to each question.
Original signed by 3Iloter Stelle Victor Stello, Jr.
Acting Executive Director for Operations
Enclosure:
DISTRIBUTION As stated Central Files E00 #001404 cc w/ enclosure:
' EDO Reading Chairman Palladino Comissioner Roberts HDenton/DEisenhut Commissioner Bernthal Commissioner Zech Glainas/DCrutchfield OPE OGC ERossi/ DBL:F0B Reading IE SECY DBL:F0B Ticket File RBenedict/0Vassallo MVirgilio/EButcher CONTACT:
EAdensam/JAxelrad R. Benedict, NRR RBernero/VStello
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OELD/0CA(3)/SECY(3)
NM7% brP PPAS (ED0#001404) w/ incoming (5520 Document Name: CMM PPR)
LKriesel/JRoe/TRehm
- Please see previous concurrence page.
JSniezek/JTaylor/JNGrace DBL:F0B DBL:F0B PPAS:BWRAB DHFST:TSCB DBL:PD#3 DBL:AD-BWR RBenedict:ajs* DVassallo*
MVirgilio*
EButcher*
EAdensam* Glainas*
02/21/86 02/21/c6 02/21/86 02/21/86 02/21/86 02/21/86 IE DBL:DIR NRR:D/DIR NRR:DIR A/EDO JAxelrad*
RBernero*
DEisenhut HDenton VStello
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02/21/86 02/24/86 02/ /86 02/ /86 02/ /86 1
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STAFF RESPONSES TO COMMISSIONER ASSELSTINE'S OUESTIONS ON THE GRAND GULF TECHNICAL SPECIFIC #TICN5 1)
To what extent do the errors in the Notice of Violation reflect an inadequate understanding or review of the Grand Gulf technical specifications?~
Response
The errors-in the Notice of Violation were attributable not to an inadequate understanding of the Grand Gulf technical specifications but to the informality of the technical specification review process at the time the Grand Gulf Technical Specifications were reviewed and to the consequent difficulty in recreating the history of the review which involved many formal and infonnal comunications. By the time the staff began to develop the Notice of Violation, most of the people who had been involved in the review of the original Grand Gulf submittal in 1980 and 1981 were gone.
Also, we have already explained that the records documenting the review were inadequate and, as a result, some of the examples chosen were inappropriate. As described below, this process has since been changed.
2)
To what extent does this suggest a need to apply more resources to the review of technical specifications?
Response
As we indicated previously, we believe that the Grand Gulf situation is L
unique. The technical specifications that were issued to other licensees prior to Grand Gulf have not shown problems of a similar magnitude, nor have those issued since. As a result of the experience with the Grand Gulf technical specification review, resources assigned to development of technical specifications were tripled. The staff believes that this increase in resources, coupled with the changes'in procedures as described in the response to Question No. 3 below, have been adequate to prevent similar situations from occurring.
3)
Are existing technical specification review procedures adequate to ensure an understanding of the sufficiency of technical specifications?
[
Response
It is not clear what is meant by the phrase " understanding of the sufficiency of technical specifications" as used in this question. However, if-its intent is to question whether or not the technical specifications are sufficient to provide adequate limitations on plant operation such that there is reasonable assurance that such operation will not jebpardize public health and safety, then our response to the question is "Yes, we believe the technical specification review procedures are adequate."
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(ResponsetoQuestionNo.3 continued)
The technical specification review process which has been previously described to the Commission, was improved, following the Grand. Gulf situation, by including:
More formal documentation between the staff and the' applicant during the technical specification development process.
Audit inspections by the Regions to confirm that the technical specifications match the as-built design of the plant.
Certification by the NRR staff of the accuracy of the technical specifications.
Certification by an independent contractor, based on an audit review of the technical specifications, the FSAR and the staff's Safety Evaluation Report.
Certification by the applicant that the technical specifications are consistent with the as-built plant, the FSAR and the staff's
~ Safety Evaluation Report.
We believe that these procedures have significantly increased our level of-confidence in the adequacy of the technical specification review process.
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