ML20127B347

Forwards Branch Comments & Recommendations for Changes to Tech Specs Following Rereview to Verify That Tech Specs Properly Derived from Analyses & Evaluation Included in Fsar.Tech Specs Acceptable,W/Exception of Items Identified

ML20127B347
Person / Time
Site:	Grand Gulf, 05000000
Issue date:	03/05/1984
From:	Rosa F Office of Nuclear Reactor Regulation
To:	Houston R Office of Nuclear Reactor Regulation
Shared Package
ML19263A614	List: AECM-84-0133, Advises NRC of Completion of Operator Recertification Program,Per 831118 Commitment.Deficiencies in Training That Remain Open Will Be Closed in Near Future.One Licensed Reactor Operator Undergoing Remedial Training AECM-84-0204, Special Rept 84-017/0:on 840304,Fire Doors 1A401 & OC219 Blocked Open to Support Maint Activities.Fire Watches Established Until Doors Restored AECM-84-0226, Responds to 840323 Confirmation of Action Ltr Re Verifying Removal of Certain Individuals from Licensed Duties.Util Has Evaluated Licensed Operators to Determine If Deficiency Identified Applicable to Other Operators.Related Info Encl AECM-84-0239, Provides Info Re Plant Discrepancy Repts to Assure That Any safety-related Hardware or Procedural Deficencies Properly Dispositioned,Per 831205 Confirmatory Action Ltr.Procedural Revs Instituted.Related Info Encl ML20126D262 ML20126D273 ML20126D322 ML20126D343 ML20126D352 ML20126D357 ML20126D360 ML20126D363 ML20126D376 ML20126D380 ML20126D392 ML20127A505 ML20127B023 ML20127B328 ML20127B331 ML20127B336 ML20127B341 ML20127B347 ML20127B352 ML20127B358 ML20127B363 ML20127B365 ML20127B370 ML20127B373 ML20127B377 ML20127B381 ML20127B384 ML20127B389 ML20127B408 ML20127B440 ML20127B520 ML20127B524 ML20127B530 ML20127B533 ML20127B542 ML20127B803 ML20127B808 ML20127B888 ML20127B893 ML20127B922 ML20127B927
References
FOIA-84-459 NUDOCS 8403160091
Download: ML20127B347 (10)

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. NUCLE AP. REGULATORY COMMISSION

. i j WASHINGTON D. C. 20555

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.... g se MEMORANDUM FOR: R. W. HoustoI[, As'sistant Director for Reactor Safety Division of Systems Integration FROM: Faust Rosa, Chief, Instrumentation & Control Systems Branch Division of Systems Integration

SUBJECT:

RE-REVIEW 0F GRAND GULF TECHNICAL SPECIFICATIONS

Reference:

Memorandum from F. Rosa to C. Thomas, dated October 31,1983,

Subject:

Grand Gulf-Unit 1 ;

ICSB Review of Technical Specifications.

The Instrumentation and Contfol Systems Branch (ICSB) has re-reviewed the Grand Gulf technical specifications to verify that the technical spe-cifications were properly derived from the analyses and evaluation inclu-ded in the FSAR as reviewed in the staff's SER. As Enclosure 1, I am providing our comments and recommendations for changes resulting.from our, review. As Enclosure 2, I am providing a list of the technical specifi-cations reviewed by the ICSB.

Of the 14 items included in Enclosure 1,13 were previously identified in the referenced memorandum. Items numbered 33 4 and 9 have been modified to reflect additional infomation received subsequent to the issuance of the referenced memorandum. It is our understanding that the 13 items are cur-rently being reviewed by the licensee, however, none have been resol'ved and/or included in the Grand Gulf Technical Specifications to date. Item number 14 is new, having evolved from our review of a technical specifica-tion change requested by the applicant.

With the exception of the items identified in Enclosure 1, the ICSB has detemined that the Grand Gulf-Unit 1 Technical Specifications are accep-table.

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Faust Rosa, Chief .

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,- Instrumentation & Control Systems Branch Division of Systems Integration 1

Enclosures:

As stated cc: R. Capr 2 J

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Enclosure 1 ICSB COMMENTS AND RECOMMENDED CHANGES FOR THE GRAND GULF-UNIT 1 TECHNICAL SPECIFICATIONS

1. By memorandum dated December 3'0, 19'82, from R. Mattson to D. Eisenhut the ICSB proposed technical specification changes to address the opera-l bility'of the remote shutdown systems required under the provisions of

T 19. These changes impose limiting conditions for operation and

-illance requirements on transfer switches, control circuits and both channels of monitoring instruments for the remote shutdown system.

It was recommended in the DeceEber 30, 1982, memorandum that these l changes. be implemented immediately on OL reviews. Therefore, Section ,

3/4.3.7.4 of the Grand Gulf-Unit 1 Technical Specifications should be modified to include these recommendations.

2. By memorandum dated October 12, 1983, from R. Mattson to D. Eisenhut the ICSB proposed technical specification changes to address the opera-bility of the post accident monitoring instrumentation required under '

the provisions of NUREG-0737 Supplement #1. These changes update the Standard Technical Specifications to reflect the Regulatory Guide 1.97, I Revision 2 graded approach to operability requirements depending on the importance to safety of the measurement of a specific variable. It was recommended in the October 12, 1983, memorandum that these changes be im-plemented immediately on OL reviews. Therefore, Sections 3/4.3.7.5 and 6.8.3 of the Grand Gulf-Unit 1 Technical Specifications should be modified to include these recommendations.

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3. Current surveillance requirements for the reactor protection system (i.e.,

I reactor trip, engineered safety features actuation and supporting features) l and the reactor core isolation cool'ing system specify testing of the final actuation logic (i.e., the AND function of the one-out-of-two taken twice logic: A or C AND B or D) at refueling outage intervals. This actuation l

,3,g circuitry (including the circuits associated with supporting features)

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.I should be tested more frequently (e.g., semi-annually) commensurate with 3/y. 3 . 5 i

, the importance of the safety functions perfomed by these systems.

By letter dated October 13, 1983 from A. Schwencer (NRC) to J. P.

McGaughey (MP&L) the NRC staff requested additional infomation re-garding the frequency of testing actuation circuitry. By letter dated Februa ry 17, 1984 from G. F. Dale (MP&L) to H. Denton (NRC) the licensee proposed to provide additional infomation on test intervals by March 2, 1984.

The completion of the ICSB's review of the technical specifications is pending receipt and review of this infomation.

4. The ICSB. has identified deficiencies in the method used to establish 21 the protection system trip setpoints and allowable values contained .

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in the technical specifications for recent Bk'R OLs. The licensee

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is currently participating in a Bk'R Osners Group study on instrument setpoints and will be providing a setpoint methodology position state-

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ment. At this time we have identified One deficiency in the se: point i

methodology used for Grand Gulf involving the treatment cf trip unit drift. The n=nerical difference between the technical specifica icn's trip setpoints and allowable vilues.should be that quantity of the in-stru. ent uncertainty allotted for the trip unit drift and calibration ac-curacy. , The numerical difference beiween the trip se: points and allowable

-- values for Grand Gulf include both trip unit drift and senser drift. ~ This t-L

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insufficient drift allowance at the allowable value could per=i: continued 2/434 operation with instrument channels that wo;1d not a::uate safety systems to 3

terminate transients or citicate accidents within the bounds specified in the FSAR* analyses. Therefore, the Grand Gulf-Unit 1 Technical 5;ecifica-tion's trip se: points a,nd allowable values should be revised to include an allowance for enly the drift associated with that portion of the instrument channer tested at 31 day intervals (i.e., trip unit) and an alicwance for trip unit calibration inaccuracy between the trip se: point and the allow-able value. Additional changes to the Grar.d Gulf-Uni: 1 Technical Speci-i fications may be required folicwing cur review of the licensee's method-a ology nosition statement.

5. By letter dated October 11, 1983 fram J. ",:Gau;by (Kp&L) to H. Denton fa ; : ! (NRC) the licensee proposed changes to the Grand Gulf-Unit 1 Technical 1

Specifications that address the RCIC actuation instrumentation. We have reviewec the proposed changes and found them acceptable. A discussion on the prc;osed changes is contained in the IC55 input to Sup;le ent No. 5 cf the SER. The Grand Gulf-Unit 1 Technical Specifica:icns snoulc te revised accordingly.

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6. By letter dated October 14, 1983 from L. Dale (MP&L) to H. Denton the licensee committed to propose revisions to the Grand Gulf-Unit 1 Tech-nical Specifications. The proposed. changes will require more frequent

.ygg calibrations of components in the containment isolation actuation instru-men _tation. We have reviewed the prop' o sal and found it acceptable. A discussion on the proposal is contained in the ICSB input to Supplement No. 5 of the SER. The Grand Gulf-Unit 1 Technical Specificctions should T

be revised accordingly.

7. The Bases Section for Specification 3/4.3.1 entitled " Reactor Protection System Instrumentation" includes the following statement: "The system

! meets the intent of IEEE 279 for nuclear power plant protection systems". -

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"d M E S We recommend that this statement be deleted. A detailed discussion on i

i the conformance of the Grand Gulf-Unit 1 design to the NRC's regulatory 1

1 requirements is contained in the SER.

Technical Specification 3/4.3.8 entitled " Plant Systems Actuation

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Instrumentation" includes the requirements applicable to the containment spray system. By letter dated September 12, 1983, from L. Dale to H.

Denton the licensee identified a potential problem with regard to the minimum operable channels requirements of the Grand Gulf-Unit 1 Technical ,

Specifications that address this systen. It appears that the requirements

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address only one-half of the instruments provided. The licensee has stated that the worst case single failure ,would be limited to the disabling of the initiation of one spray loop.whenqperating with one-half of the instruments provided. The system has been designed such that any single failure within the ac.tuation instrumentation will not prevent actuation at the systems level when all of the actuation instruments provided are operable. There-fore, to enhance pi' ant safety we recommend that the minimum channels oper-able requirement for the drywell pressure tiigh, containment pressure high

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and reactor vessel, low actuat. ion signals be revised from the present one per tri.p. system to two per trip system and that an appropriate action statement be developed to address operation with one or more channels per trip system inoperable.

9. Specification 3/4.3.1 entitled " Reactor Protection System Instrumentation" and Specification 3/4.9.1 entitled " Reactor Mode Switch" address the oper-ability requirements and surveillance requirements for the reactor mode switch. The requirements address only those circuits associated with the shutdown and refuel position. The mode switch is provided to select the protective functions appropriate for each mode of reactor operation -

shutdown, refueling, startup and power operations. In addition to the protective functions of reactor trip (six trip inputs) and primary con-tainment isolation (one trip input) the mode switch enables / bypasses 1

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control rod blocks, operation of the suppression pool nakeup system, re-fueling interlocks and monitor,ing functions which are provided to con-trol operations within prescribed bounds. Therefore, we recommend that the Grand Gulf-Unit 1 Technical Specifications include limiting condi-tions for operation and surveillance requirements that include consider-ation of the other safety-related functions accomplished by the mode switch.

10. Specification 3/4.7,.1 entitled " Service Water Systems" addresses the surveillance requirements for the standby service water (SSW) system.

These requirements include a periodic demonstration of the operabil-ity of the circuits that automatically reposition valves servicing safety-related equipment. The SSW system (including the SSW pumps, SSW cooling tower fans and automatic system valves) is initiated auto-matica11y upon occurrence of a LOCA or startup of any of the ESF sys-tems it serves. In addition, the SSW system is initiated automat-ically on a loss of offsite power through the associated load sequenc-ing circuits. Currently the Grand Gulf-Unit 1 Technical Specifica-tions address only those circuits associated with the SSW system's valves. To ensure the operability of the automatic actuation of the SSW system pumps and cooling tower fans we recommend that Specifica-

. tion 4.7.1.1 be revised to ir:1ude periodic testing of the actuation circuitry for these components.

11. Specification 3/4.6.3 entitled " Suppression Pool" addresses the opera-bility requirements and surve1}llanc'$ requirements for the suppression pool . This specification does not address the suppression pool make-up system. The suppression pool makeup system provides water from the upper c'ontainment pool to the suppression pool by gravity flow after a LOCA ~and is classified as an ESF system at Grand Gulf. The systen is automatically initiated 30 minutes after a..LOCA is detected or on a low-low, suppression pool level following a LOCA. The suppression pool makeup system consists of two independent and redundant subsystems.

The ' actuation logic for each subsystem is a one-out-of-two arrangement of level sensors. We recommend that appropriate Grand Gulf-Unit 1 Techni-cal Specification limiting conditions for operation and surveillance requirements be developed to address this ESF system.

12. Specification 3/4.7.3 entitled " Reactor Core Isolation Cooling System" addresses the operability of the reactor core isolation cooling system (RCIC). The design of the RCIC system includes protective features to automatically shut down the turbine by tripping the trip and throttle valve closed if any of the following conditions are detected: turbi ne overspeed, high turbine exhaust pressure, RCIC isolation signal from logic A or B, or low pwnp suction pressure. To ensure the reliability l

l of these features, the availability of RCIC system and to enhance plant i

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safety these features should be included in the operability and surveil-lance requirements.

13. The high pressure / low pressu system interlocks prevent overpressuriza-tion of the low pressure systems that connect to the reactor coolant pressure boundary. Specification 3/4.4.3.2 entitled " Reactor Coolant System Leakage" address the operability of the isclation valves with respect to leak-tight. integrity and the instrumentation provided to monitor valve leakage, however, this specification does not address the valve interlocks. The [ollowing valves are interlocked to prevent valve opening until pressure pemissives are satisfied: E12-F009, E12-F008, E12-F053, E12-F023. E12-F087, and E38-F001. To ensure the reliability of these features and to enhance plant safety we recommend that appropriate limiting conditions for operation and surveillance re-quirements be included in the Grand Gulf-Unit 1 Technical Specifications.

14. By letter dated September 12, 1983 from A. Schwencer (NRC) to J. Mc s Gaughey (MP&L) the NRC staff requested additional infomation to re-

_ M3 A solve concerns regarding the minimum number of operable instrument nou 2A30 channel requirements contained in the Grand Gulf Technical Specifica-tions, and additional infomation regarding the licensee's interpreta-tion of the. definition of the tems " trip functions", " channel" and .

3 " trip systems" contained in the Grand Gulf technical specifications.

By letter dated September 12, 1983 from L. F. Dale (MP&L) to H. Denton

Enclosure 2

- GRAND GULF - UNIT 1 TECHNICAL SPECIFICATIONS SECTIONS REVIEWED BY ICSB 1.0 Definitions.-- ,

2.2.1 Reactor Protection System Instrumentation 3/4.1.3.5 Control Rod Position Indication 3/4.1.4.2 Rod Pattern Control System 3/4.3.1 , R actor Protection System Instrumentation 3/4.3.2 Isolation Actuation Instrumentation 3/4.3.3 Emergency Core Cooling System Actuation Instroentation 3/4.3.4 Recirculation Pump Trip Actuation Instrumentation 3/4.3.5 / Reactor Core Isolation Cooling System Actuation Instrumentation 3 /4. 3.6 Control Rod Block Instrumentation 3/4.3.7.4 Remote Shutdown Monitoring Instrumentation 3/4.3.7.5 Accident Monitoring Instrmentation 3 /4. 3. 7. 6 Source Range Monitors 3/4.3.7.7 Traversing In-Core Probe System 3/4.3.8 Plant Systems Actuation Instrmentation 3/4.6.3.1 Suppression Pool 3/4.7.1 Service Water Systems 3/4.7.3 Reactor Core Isolation Cooling System l 3/4.4.3 Reactor Coolant System Leakage 3/4.4.2.2 Safety Relief Valves Low-Low Set Function 3/4.9.1 Reactor Mode Switch GB3 + r etewec: 4 -c w us ,

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