ML20042B495

Forwards Addl Responses to License Qualifications Branch Requests for Info & Revisions to FSAR Necessitated by Recent Organizational Changes

ML20042B495
Person / Time
Site:	Grand Gulf
Issue date:	03/23/1982
From:	Dale L MISSISSIPPI POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20042B496	List: ML20042B495 ML20042B504
References
AECM-82-49, NUDOCS 8203250366
Download: ML20042B495 (67)

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O . B O X 16 4 0, J A C K S O N , M I S S I S S I P P .-0 9 9- 5 a M(D March 23, 1982 Y NUCLE AR PHo00CTION DEPARTMENT N

, , .y' yg-L U. S. Nuclear Regulatory Commission -

": y, -1ri Office of Nuclear Reactor Regulation C t[ "2I982%

Washington, D.C. 20555 ( A.q au

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Attention: Mr. Harold R. Denton, Director g/ /d

Dear Mr. Denton:

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SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 File No. 0260/L-334.0/L-350.0 Additional Response to Concerns of Licensee Qualification Branch AECM-82/49 In this letter Mississippi Power & Light Co. (MP&L) operator of Grand Gulf Nuclear Station on behalf of Middle South Energy, Inc. and South Mississippi Electric Power Association, is subm'.tting responses to specific concerns expressed by the Licensee Qualifications Branch as well as changes made in the FSAR necessitated by recent organizational changes at MP&L.

As Grand Gulf Nuclear Station (CGNS) Unit No. 1 approaches the operational phase, Mississippi Power & Light Company (MP&L), operator of GGNS on behalf of Middle South Energy, Inc. and South Mississippi Electric Power Association, has made certain organizational changes to insure a smooth transition for operation of Unit 1, resumption of construction of Unit 2 and the most expeditious use of the Grand Gulf staff.

Attachment A to this letter presents a brief description of the details to be found in Attachments 1 through 13.

Should you have any questions, please advise.

Yours truly, l

, d. e O OI L. F. Dale l Manager of Nuclear Services PJR/JDR:ph Attachments g /

cc: See next page 8203250366 820323 PDR ADOCK 05000416 PDR A

Member Middle South Utilities System ,

- AECM-82/49 MIE2I2,IIPPI POWER Q LIGHT COMPANY-i cc: Mr. N. L.:Stampley (w/a)

Mr..R. B. McGehee (w/a)

Mr.'T. B. Conner'(w/a)

Mr. G. B. Taylor (w/a)

Mr. Richard C. DeYoung, Director'(w/a)-

. 0f fice of : Inspection '& Enforcement U.'S. Nuclear Regulatory Commission

. Washington, D..C. 20555 ,

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Attachment A AECM-82/49

SUMMARY

OF ATTACHMENTS Attachmentjl: 'A brief summary of-organization changes recently made at Grand Gulf Nuclear Station.

Attachment 2: Revised organization charts in FSAR subsection 13.1.

Figures 13.1-1,-13.1-la.and 13.1-2 have been revised and a.new Figure 13.1-lb has been added to-reflect the organizational changes.

Attachment 3: Revised pages from FSAR subsections 13.1 and 14.2.

Changes have been made in these subsections that incorporate the organizational changes.

-Attachment 4: Nuclear Production Policy and Organization Manual, Appendix-8.4, Nuclear Production Department Operational Assessment Review Policy.

In letter from L. F. Dale to Harold R. Denton, AECM-82/12, dated January 18, 1982, a draft of Appendix 8.4 was included as Attachment 3A of said letter. This was in response to NUREG-0737, Action Item I.C.5. Attachment 4 is the revised current version of said Appendix.

Attachment 5: Nuclear Plant' Engineering Procedure 01-701, On site Document

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Review.

Attachment 6: Nuclear Plant Engineering Procedure 01-702, Off site. Document Review.

Attachment 7: Nuclear Plant Engineering Procedure 01-704, Operational Analysis Section Reports.

, Attachments 5, 6 and 7 are reviewed, and approved i procedures that are provided as additional responses to l NUREG-0737, Action Item I.C.5.'

l ' Attachment 8: Proof and Review copy of Technical Specification Section-6.5.2, Safety Review Committee.

Attachment 9: MP&L's version of Technical Specification Section 6.5.2.

Attachment 10: Basis for MP&L version of Technical-Specification Section 6.5.2.

I l Attachments 8, 9 and 10 are submitted in response to a l request made during a January 25, 1982 telephone conversation l between Mr. R. H. Benedict of your organization and members of our staff concerning the Safety Review Committee. The Proof and Review pages, Attachment 8 are all from the January 5, l

1982 issue except for the February 1,1982 issue of page 6-11 which contains a minor revision.

Attachment 11: Resume of Douglas L. Hunt, Training and Administrative Superintendent.

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Attachm:nt A AECM-82/49 Attachment 12: Resume of Ted H. Cloninger, Assistant Site Manager Attachment 13: Resume of Curtley C. Hayes, Nuclear Plant Quality Superintendent.

Attachment 11 and 12 are revised resumes based on changes in job functions. Attachment 13 is a new resume.

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Attechment 1 AECM-82/49 GRAND GULF ORGANIZATIONAL CHANGES ,

1. Tlie' Site. Manager _will continue ~to coordinate the activities of the Architect-Engineer in the completion of all' remaining design and construction activities related to Unit-1.

2. The Manager of Project Engineering will_ become the Project Manager for Unit 2 reporting directly to the Senior-Vice President - Nuclear. In this capacity he will coordinate the activities of the Manager of Construction and the Project Engineers on all design and construction activities related to Unit 2. During_the phase out of Unit 1 design and construction activities he will assist the Site Manager as Assistant Site Manager.

3. The Startup Manager and his staff are being transferred to report to the Nuclear Plant Manager. The Startup_ Manager will be responsible for the remaining Checkout Turnover effort related to Unit 1.

4. The Manager of Quality Assurance will report directly to the Senior Vice President - Nuclear.

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GG Attachm:nt 3 FSAR AECM-82/49 CHAPTER 13.0 CONDUCT OF OPERATIONS 13.1 ORGANIZATIONAL STRUCTURE OF APPLICANT 13.1.1 Management and Technical Support Organizations The Mississippi Power & Light Company (MP&L), Middle South Energy, Inc.

(MSEI), and the South Mississippi Electric Power Association (SMEPA) are engaged in the design, construction, maintenance, testing, and operation of the Grand Gulf Nuclear Station with MP&L acting for itself and as agents for MSEI and SMEPA who own the facilities. MP&L is an operating subsidiary of Middle South Utilities, Inc. , a registered public utility holding company.

Other principal subsidiaries of Middle South Utilities, Inc. includ,e Arkansas Power & Light Company, Louisiana Pow 2r & Light Company, and New Orleans Public Service, Inc. These subsidiaries constitute an integrated public utility system called the " Middle South System." MSEI is a wholly owned subsidiary of Middle South Utilities, Inc created to own and finance the Grand Gulf Nuclear Station for the Middle South System. The South Mississippi Electric Power Association is a rural electrification administration cooperative which has purchased a percentage of the ownership of Grand Gulf Nuclear Station from MSEI and has also authorized MP&L to act as its agent in the design, construction, maintenance, testing, and operation of the facilities.

MSEI has contracted the Bechtel Power Corporation of Gaithersburg, Maryland to provide engineering, procurement, construction, quality assurance, and component testing services for the Grand Gulf Nuclear Station. Bechtel has been continuously engaged in construction and engineering since 1898, including services on nuclear power plants for other utilities, and is therefore considered qualified to provide the services required for the Grand Gulf Nuclear Station design, construction, procurement, quality assurance, and startup.

MSE1 has contracted the General Electric Company to design, fabricate, and deliver the single-cycle, boiling water nuclear steam supply system and the first core of nuclear fuel, and to provide technical direction for the installation and startup of this equipment.

13.1.1.1 Design and Operating Responsibilities The overall responsibility for the design review and approval construction, testing, and operation of the Grand Gulf Nuclear Station has been assigned by the President and Chief Executive Officer of Mississippi Power & Light Company and delegated to the Senior Vice President - Nuclear of Mississippi Power &

Light Company. He coordinates all phases of plant activities for the owners as well as Mississippi Power & Light Company. He is assisted by the l Mississippi Power & Light Company 13.1-1 C8rg9

GG FSAR Site Manager for the completion of design and construction activities for Unit one, by the Mississippi Power & Light Company Assistant Vice President -

Nuclear Production in the licensing, nuclear fuels management, nuclear plant engineering, records management, startup, operation and maintenance phases and in overall management control of Unit One and by the MP&L Manager of Quality Assurance. The Assistant Site Manager will become the Unit 2 Project Manager and will report to the Sr. Vice President - Nuclear and will be assisted in carrying out his responsibilities by the Project Engineering staff, and the Manager of Construction. The Assistant Vice President - Nuclear Production is assisted by the Nuclear Plant Manager, the Manager of Nuclear Plant Engineering and the Manager of Nuclear Services. l 13.1.1.1.1 Design and Construction Activities (Project Phase) j The Assistant Vice President - Nuclear Production is responsible for nuclear l plant engineering, licensing, nuclear fuel cycle management, records management, s and overall management control of Unit One including budgeting, administration,.

and contract administration. The Unit 2 Project Manager will report to the Senior Vice President - Nuclear and will be responsible for project engineering, construction, procurement and pre-operational testing of Unit Two. The Site Manager reports to the Senior Vice President - Nuclear for completion of Unit I work and engineering as well as construction and design of the Emergency offsite facility. His organization is located on site, and he provides direction to the Bechtel and GE engineering, procurement, and construction organizations in all activities'necessary to complete and test plant systems. Priorities and direction for his activities are provided by the Nuclear Plant Manager who has been assigned the responsibility for the timely completion and Fuel Load of Unit 1. The Site Manager is assisted in this capacity by the Assistant Site Manager. Project Engineering reports to the Assistant Site Manager and provides review and approval authority of all engineering aspects of the plant design. The Assistant Site Manager ensures coordination between MP&L and contractor / vendor organizations and timely resolution of engineering matters. He directs the activities of the Project l Engineering organization and the Construction Manager.

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13.1.1.1.1.1 Principal Site-Related Engineering Work The principal site engineering activities accomplished under contract for Mississippi Power & Light Company towards the construction and operation of tbc Grand Gulf Nuclear Station are:

a. Meteorology A preoperational meteorological monitoring program was established at the site on August 2, 1971 to provide those meteorological factors

[ that bear upon plant design, operation, and safety. During the first two annual cycles, the meteorological systems were calibrated by professional metcorologists and technicians employed by Woodward-Envicon (now Woodward-Clyde Consultants). The tower and equipment are being maintained and calibrated by the Instrument Control Section under the direction of the Plant Staff Maintenance Superintendent.

This program is discussed in Section 2.3.

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GG FSAR for the preparation, maintenance and testing of the GCNS Emergency Plan and Corporate Emergency Plan Procedures to provide effective management of any real or anticipated emergency at GGNS.

13.1.1.1.3.2.3 Administrative and Business Services The Administrative and Business Services Section is responsible for providing general support to the Nuclear Services group and Nuclear Production in the areas of: budget development, consolidation, and presentation; cost monitoring and reporting; procurement activities involving policy variations; negotia-tions, placement, and administration of contracts (except those involving nuclear fuel); and development and maintenance of procedural control documents.

This group performs other functions to support Nuclear Services in areas such as interface with the quality assurance organization for nonconformance tracking and resolution, scheduling, and handling of special tasks.

13.1.1.1.3.2.4 Nuclear Records Administration Section The Nuclear Records Administrction Section is responsible for all general clerical work for Nuclear Services, including a computerized filing system, document microfilming system, and nucleer services record storage.

13.1.1.1.4 Quality Assurance The Manager of Quality Assurance is responsible for implementing the Corporate Quality Assurance Programs in all phases of plant activities; he reports directly to the Senior Vice President - Nuclear. The detailed responsibilities assigned to the Manager of Quality Assurance and the Quality Assurance Staff are described in Section 17.2 of the FSAR (MP&L Operational Quality Assurance Manual - Topical MPL-TOP-1A, accepted by the NRC).

13.1.1.1.4.1 Quality Assurance Operations Supervisor The Quality Assurance Operations Supervisor reports to the Manager of Quality Assurance and is located at the plant site. He reviews Plant Quality Procedures for the Manager of Quality Assurance; provides for working and quality interface and direct communication with the Plant Quality Superintendent; and directs the quality assurance staff located at the plant site in auditing, monitoring, and reviewing plant site activities (including the activitics of the plant staff, the plant quality staff, the startup staff, i

and onsite contractors and consultants) to verify implementation of the Operational Quality Assurance Program. He has the authority, as delineated in the appropriate Quality Assurance Procedure, to initiate action to 13.1-12d C8rg3 i

, GG FSAR is assisted by Division Managers who are responsible for the performance of all divisional activities in accordance with company policies, methods, and procedures..

The Vice President and Secretary of the Company and Chief Financial Officer is responsible for all financial, security, treasury, and accounting functions; reviewing, interpreting, and implementing rulings of regulatory authorities with respect to financial and accounting matters and rates and service policy; preparing'and maintaining minutes of corporate proceedings, including directors' and stockholders' meetings; custody of permanent corporate records; economic forecasts, budgetary procedure and control; proceedings before regulatory bodies involv'ng rates, service policy, and financial and accounting matters; and liaison with the Middle South Computer Center on all company data processing requirements. '

13.1.1.2.1.2 Senior Vice President - Nuclear The corporate organization which provides the na responsibility for the

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operation of the company is shown in Figure The ultimate responsi-bility for the safe and reliable operation .e Grand Gulf Nuclear Generating Station rests with the MP&L Senior Vice President - Nuclear who reports to the President and Chief Executive Officer. The Senior Vice President - Nuclear is responsible for overall design, construction, operation, maintenance, quality-assurance, and availability improvement of'all nuclear power production and

related facilities; licensing and compliance with'all applicab.le regulatory

requirements for design, construction, operation, and maintenance of nuclear power plants; and safety and security of all nuclear power production and related facilities. He is assisted by the organizations of the Assistant Vice President - Nuclear Production for operations phase activities, the Site Manager for completion of Unit one design and construction activities, and the-Manager of Quality Assurance; who are responsible for management and technical support functions for the Grand Gulf Nuclear Station. The Assistant Vice President - Nuclear Production is responsible for overall operations, mainten-ance, nuclear plant engineering, and availability improvement _of all nuclear production facilities; licensing in compliance with all applicable regulatory requirements; and safety and security of all 13.1-16 C8rg4

CG FSAR nucicar power production facilities. The Manager of Quality Assurance is responsible for verifying impicmentation of the Corporate Quality Assurance Programs in all phases of plant activities. The MP&L Management and Technical Support Organization for the Grand Gulf Nuclear Station is shown in Figure 13.1-1A and 13.1-1B.

13.1.1.2.1.3 Assistant Vice President - Nuclear Production The Assistant Vice President - Nuclear Production reports directly to the Senior Vice President - Nuclear. He is directly responsible for management and direction of all activities associated with the efficient, safe, and reliable operation of the station and his activities and responsibilities are fully dedicated to matters concerning the safe nuclear production of electric energy. He shall provide general management direction for the following activities:

The establishment and approval of the qualification requirements for all plant staff positions

. The establishment and approval of qualification requirements for all offsite staff management positions that support safety-related activities at the plant

. The establishment and supervision of functional units providing review of operational activities that are independent of the plant staff

. The requirements established for the nucicar plant industrial security plan, fire protaction program, and plant staff training program

. The periodic assessment of plant staff training

. The review of NRC nuclear power plant inspection reports

. The review of deficiencies and violations of plant procedures and Technical Specifications requirements, and concurrence with corrective

, action taken to preclude recurrence

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. The Safety Review Committee and the Plant Safety Review Committee, l serving as chairman of the Safety Review Committee l . The certification for operators and senior operatars completed pursuant to Sections 55.10(a)(6) and 55.33(a)(4) and (5) of 10 CFR Part 55; and the certification of plant personnel in the category of managers

. The establishment and promulgation of nuclear operating policy 13.1-17 C8rg5

CG FSAR The Assistant Vice President - Nuclear Production is assisted in management and technical support activities for Grand Gulf Nuclear Station by three managers as shown in Figure 13.1-1A. The Nuclear Plant Manager organization's managenent and technical functions for Grand Gulf Nucicar Station is described in subsection 13.1.2. The Manager of Nuclear Plant Engineering and the Manager of Nuclear Services organizations' management and technical functions for Grand Gulf Nuclear Station are as described below:

13.1.1.2.1.3.1 Nuc1 car Plant Engineering The Manager of Nucicar Plant Engineering reports directly to the Assistant Vice President - Nuclear Production.

The Manager of Nuclear Plant Engineering is assisted by several principal engineers who are each responsibic for work within their assigned discipline.

Initially, principal engineers will be assigned in the disciplines of mechanical, electrical, civil / structural, environmental, and operational support (operations analysis and maintenance) engineering. The organization chart for this group is shown in Figure 13.1-1A.

In addition to the principal engineers, this staff will include secretarial and administrative personnel. The Nuclear Plant Engineering staff shall include at least one person in each of the areas listed below who is qualified and designated to provide technical support to the plant staff. Those persons designated by the Manager of Nuclear Plant Engineering will be kept up-to-date on plant systems, equipment, and problems so they can promptly assist the Plant staff in the event they are needed. Their job assignments will be primarily related to engineering activities associated with the Grand Gulf Nuclear Station. Their training will be aligned to ensure they are kept current on matters such as plant modification, plant problems, and problems on other similar plants, and to keep them prepared to provide support to the Plant staff in the event of an emergency. In cases where more than one qualified person in each area is required to support accident response, the Manager of Nuclear Plant Engineering may designate persons from ether staffs, provided such persons are assigned full-time in the designated area of responsibility. Such persons will be obtained from other organizations within GGNS or frem the Architect-Engineer, the NSSS vendor or other nuclear oriented companies,

n. Mechanical, structural, thermal-hydraulic, fluid systems, metallurgical, and materials

b. Electrical, instrumentation, and controls 13.1-18 C8rg6

GG FSAR 13.1.1.2.1.4 Project Manager for Grand Gulf Nuclear Station, Unit Two The Project Manager for Grand Gulf Nuclear Station Unit Two will report directly to the Senior Vice President - Nuclear and will be responsible for engineering, construction, project procurement, and preoperational testing activities. lie l

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f GG FSAR will be assisted in management and technical support activities for Grand Gulf Nuclear Station by the Manager of Construction, and the Project Engineering

, Staff as shown in Figure.13.1-1B. The Project Manager's . staff will include

! HP8L construction, and engineering personnel augmented by administrative

personnel and contracted employees as necessary to place Unit Two of CGNS into commercial operation. At that time, all assigned management and technical i support functions will be transferred to the Assistant Vice President -

Nuclear Production for the duration of the operations phase.

13.1.1.3 Qualifications of Technical Support Personnel for Operations The following members of the corporate staff available for the technical support of the Grand Culf Nuclear Station possess those qualifications of i education, experience, and skills commensurate with their level of responsibility that provides reasonable assurance that decisions and actions during the operation and maintenance of the CGNS units will not constitute a j hazard to the health and safety of the public. The qualifications for nuclear plant staff personnel are described in subsection 13.1.3.

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13.1.1.3.1 Senior Vice President - Nuclear

! The Senior Vice President - Nuclear shall hold a bachelor's degree in science

or engineering in a field associated with power production. He shall have at least 10 years experience associated with power plant design, construction and, operation, of which at least 5 years must be nuclear-related experience.

The Senior Vice President - Nuclear may authorize deviations from the qualification requirements stated below and in subsection 13.1.3.

l l 13.1.1.3.2 Assistant Vice President - Nuclear Production l

The Assistant Vice President - Nuclear Production shall have a bachelor's degree in science or an engineering degree in a technical discipline generally associated with power production and have at least 10 years of broad experience associated with power plant design, construction, and operation.

He shall have at least 5 years of nuclear power plant design, construction, or operation experience. The qualifications of the Assistant Vice President -

Nuclear Production meet these requirements and are detailed in Appendix 13A.

13.1.1.3.3 Managers The Manager of Nuclear Plant Engineering and the Manager of Nuclear Services shall have demonstrated operational and engineering management capability in their areas of responsibility. Both of these managers shall have a bachelor's degree 13.1-20 C8rg8

CG FSAR

b. To demonstrate the capability of safety-related structures, components, and systems to meet performance requirements

c. To effect fuel loading in a safe manner

d. To demonstrate, where practical, that the plant is capable of withstanding. anticipated transients and postulated accidents

e. To evaluate and demonstrate, to the extent possible, plant operating procedures to provide assurance that the plant staff is knowledgeable about the plant and procedures, and is fully prepared to operate the facility in a safe manner

f. To bring the plant to rated capacity and sustained power operation 14.2.2 Organization 14.2.2.1 Grand Gulf Startup Organization .

The Startup Organization (Startup) has the responsibility and authority to conduct all startup testing for GGNS Units 1 and 2. The Startup Organization is directed by the Startup Manager who reports directly to the Nuclear Plant l

Manager for matters relating to construction phase, preoperational phase testing and startup phase testing. Startup is a composite of MP&L, Bechtel, l General Electric (GE) Startup Engineers, and Consultant Startup Engineers.

The Bechtel Project Startup Engineer and the GE Site Operations manager, as senior Startup representatives of their companies, serve on the Startup Manager's staff, providing advice, assistance, and consultation. Figures 13.1-2 and 14.2-2 illustrate the GGNS Plant Staff and GGNS Startup Organiza-tions and their interrelationships.

14.2.2.2 MP&L Startup Manager l

The MP&L Startup Manager has complete authority to control the conduct of the Startup program through acceptance and rejection of test procedures and results, by establishing and enforcing administrative controls and policies, and through general surveillance of Startup activities. The MP&L Startup Manager is delegated the responsibility for the administration and control of the Startup organization. He ensures the review of all test results and accepts or rejects them. He is responsible for the production of all procedures. He coordinates requests for Operations, Maintenance, Plant

Quality, Technical, Construction, and Administrative staff support with the j appropriate Plant Staff personnel as requested.

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GG FSAR tests, and prepare and analyze test results. They will provide 24-hour shift coverage, beginning with fuel loading, working directly with the MP&L Shift Test Supervisors. They report to the STD&A lead engineer.

14.2.2 15 Interfacing Organizations 14.2.2.15.1 MP&L Project Engineering During startup, MP&L's project engineering staff may provide support to the GCNS startup program.

MP&L's project engineering staff is headed by the Assistant Site Manager.

Project engineering organization and responsibilities are described in l subsection 13.1.1.

14.2.2.15.2 MP&L Project Construction The MP&L construction supervisor represents MP&L in all matters relating to construction. He will provide startup with construction support and information concerning construction progress; and will expedite startup requests for construction assistance or action.

14.2.2.15.3 MP&L Quality Assurance MP&L Quality Assurance performs monitoring and audit functions during all testing phases. For the Component Test Phase, MP&L Quality Assurance monitors, reviews, and audits Bechtel QA, QC. Bechtel QA/QC is responsible for developing and implementing the Bechtel quality aspects of the Component Test Program. The functions of MP&L Quality Assurance and Plant Quality concerning quality activities from the preoperational test phase through commercial operation are described in Section 17.2.

14.2.2.15.4 GGNS Plant Staff The plant staff is responsible for the operations phase of the station and will assume responsibility for the operation and maintenance of plant systems upon turnover to MP&L. The Plant Manager has reporting to him the assistant Plant Manager, the Nuclear Support Manager, the plant quality supervisor, and the security supervisor. Chapter 13 details their duties and general responsi-bilities. In regard to testing, these supervisors will be responsible for:

a. Assigning and supervising plant personnel to support the testing program

b. Providing technical expertise to review test procedures and results 14.2-9 C53rgl

Attachment 4 AECM-82/49 4 1

1 Appendix 8.4 Nuclear Production Department Operational Assessment Pcview Policy STATDENT The collective operational experiences of the nuclear power production industry in addition to the operational experiences at Grand Gulf Nuclear Station are sources of information which can provide valuable and timely insight into areas of operation, plant characteristics, plant design and personnel training, which might not otherwise be apparent or which might not have been e::pected or considered. 'Ihe careful and ccmpetent review of such experiences as they relate to the operation of Grand Gulf Nuclear Station will serve to identify, where existing, the need for corrective actions to be taken to prevent the occurrence or recurrence of events which could contribute to unsafe plant operation.

It is the policy of the Nuclear Production DepartJrent that all members of the Department nust continually consider all sources of operating cyperience information in the light of how each experience and the reactions to it relate to the overall safe and efficient operation of Grand Gulf Nuclear Station. 'Ib this end a formal program of controlled review of applicable operating experience will be established and Jill require the direct involvement of management and supervisory personnel.

RESIONSIBILITIES The Manager of Nuclear Plant Engineering through the Principal Engineer

- Operational Analysis is responsible for the establishment of an Operational Assessment Review Program. He will establisit procedures which provide for:

1. the collection of information concerning operational experi-ence both at Grand Gulf Nuclear Station and elsewhere in the nuclear power production industry.

2. the review and screening of such information for applicability to Grand Gulf Nuclear Station and, if applicable, the assess-ment of its effect on plant operations.

3. the controlled dissemination of such information to members of the Nuclear Production Departnent who are responsible for review of the information for inplication or effect on any facet of Grand Gulf Nuclear Station operations.

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Appendix 8.4

4. the recording, follow up and close out of any action indicated as required by the review.

Procedures will be configured to provide for the following elements:

1. Clear identification of organizational responsibilities for review of operational experience informtion, for dissemina-tion of applicable and inportant informtion to all persons who would require or consider the information useful in the performance of their responsibilities, and for recamending the establir.hment of training and/or retraining requirements.

2. Clear identification of all steps necessary to establish and follwup required actions.

3. Identification of required recipients of jnformation for review or other action.

4. Provision of methods to identify and quickly disseminate high priority informtion.

5. Provisions to screen out extraneous or unimportant informa-tion.

6. Provision of methods to assure that conflicting o contradic-tory informtion is identified and, upon resoluti n, forwarded to appropriate personnel.

7. Provision for internal audit of the progam.

All Managers reporting to the Assistant Vice President - Nuclear Production are responsible for ensuring that documents listed below for which they have primary responsibility for review or action are forwarded to the Principal Engineer - Operational Analysis for his assessment in accordance with this policy.

SOURCES OF OPERATING EXPERIENCE INFORMATION

1. USNRC issred docurrents concerning nuclear pwer plant testing and tpiration.

a. IE Bulletins

b. IE Circulars

c. IE Information Notices

d. Ictters

e. Inspection Reports

f. Reports to Congress on Abnormal Occurrences (t0 REG 0090)

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Appendix 8.4

2. NPD issued documents

a. Incident Reports

b. Licensee Event Reports

c. Nonroutine reports required by regulations

d. Audit Reports

e. PSRC/SRC meeting minutes

3. Institute of Nuclear Power Operation

a. Significant Event Reports (SERs)

b. Significant Operating Event Reports (SOERs)

c. Notepad entries

4. Equignent supplier technical bulletins and correspondence related to the perfonnance of systems or cmponents.

5. Any other docunents, letters, memorandums, etc. , relating to plant testing or operations.

6. Any other document that the Manager believes should be assessed in accordance with this policy.

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[ Attachment 5

• NUCLEAR PLANT ENGINEERING AECM-82/49 ADMINISTRATIVE PROCEDURES MANUAL O

Procedure No.: 01-701 Revision: 0 Date: February 1, 1982 Safety Related ONSITE DOCUMENT REVIEW O [M[/af, Prepared: /[/6[8L Reviewed: ((& /[/f!72 0;ibrational/ Analysis Prini: Engr.

/ ((A [C[ede Mafager of QA '

d.

Approved: A fe, f 2

agef of' Nuclear Plant,4ngineerfng List of Ef fective Pages

Page Revision 1-5 0 Attachments I-IV 0 0

' GRAND GULF NUCLEAR STATION # ^

ITitle: Onsite Document Review l Procedure No.: 01-701 lRavision: OlPage: 1l .

I I I I I 1.0 PURPOSE This procedure provides guidelines for the independent safety review of Onsite Documents forwarded to the Principal Engineer of Operational Analysis Section by the Plant Staff and Quality Assurance. When reviews are completed, copies of Incident Reports, Potentially Reportable Deficiency (PRD) reports and other Onsite Documents deemed to be safety-related will be forwarded to the manager of the originating group.

2.0 RESPONSIBILITY 2.1 Assistant Vice-President, Nuclear Production, assigns managers to carry out their responsibilities as defined in this procedure.

2.2 Nuclear Plant Manager, through designated individuals, is responsible for forwarding an informational copy (see Definitions) of the Incident Report to the Principal Engineer of Operational Analysis Section in accordance with Re ference 3.1.

2.3 Manager of Quality Assurance, through designated individuals, is responsible for forwarding an informational copy (see Definitions) of the Potentially Reportable Deficiency (PRD) Report to the Principal Engineer Operational Analysis Section in accordance with References 3.2 and 3.

2.4 Principal Engineer of Operational Analysis Section (OAS) is assigned by the Manager of Nuclear Plant Engineering the responsibility for receiving and processing Onsite Documents.

2.5 Document Safety Review Coordinator of the Operational Analysis Section is assigned by the Principal Engineer the responsibility for performing the following actions: (1) Check subject documents for indications of repartability; (2) Coordinate the independent technical and safety review; (3) Review the Onsite Document package completed by the Investigating Engineer; and (4) Transmit the completed package to the Principal Engineer for approval and internal close-out.

2.6 Investigating Engineer of Operational Analysis Section is assigned by the Principal Engineer to: (1) Perform independent evaluations and/or analyses, as needed; (2) Develop reconunendations to the Nuclear Plant Manager or Manager of Quality Assurance as needed; and (3) Complete the review summary per this procedure.

3.0 REFERENCES

3.1 Plant Administrative Procedure , 01-S-06-3 e cidest Reports / Reportable Events 3.2 Quality Assurance Procedure, 16.20, Reporting of Deficiencies as Required by 10CFR50.55(e) v

. GRAND CULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING l

Title:

Onsite Document Review l Procedure No.: 01-701 l Revision: 0lPegn: 2l -

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W 3.3 Quality Assurance Procedure, 16.30, Reporting of Deficiencies as Required by 10CFR21 3.4 Plant Administrative Procedure, 01-S-05-1, Operation and Control of the Central Documents and Records System 3.5 Operational Quality Assurance Manual (MPL-TOP-1A), 2.5.8 3.6 Cuidelines for Utility Management Structure and Technical Resources, NUREG-0731, September,19"O 3.7 Clarification of TMI Action Plan Requirements, NU REC-0737 3.8 Grand Gulf Nuclear Scation Technical Specifications, Section 6.2.3 4.0 ATTACllMENTS 4.1 Attachment I, Flow Chart of Onsite Document Review Process ,

4.2 Attachment II, OAS Document Log Form 701.1 4.3 Attachment III, Document Review Summary Sheet , Form 701.2 f\

N/ 4.4 Attachment IV, Recommendations Memo, Form 701.3 5.0 DEFINITIONS 5.1 Onsite Documents will include but are not limited to:

5.1.1 Incident Reports 5.1.2 Potentially Reportable Deficiency (PRD) Reports 5.2 The Incident Report is a multipart form (Reference 3.1), used to record the pertinent information regarding a variation from normal or intended plant operational conditions or parameters.

5.3 The Potentially Reportable Deficiency Report is a multipart form (Reference 3.2), and used to record the pertin'ent information regarding a deficiency as defined under 10CFR 50.55(e) and 10CFR 21.

5.4 Informational copy is a legible reproduction of an original document.

For such documentation, a response is not required.

6.0 DETAILS 6.1 The Principal Engineer (OAS) or his designee will receive for review On ,

site Documents as illustrated in Attachment I:

(a')

GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING 1

'lTitle: Onsite Document Review l Procedure No.: 01-701 l Revision: OlPage: 3l l l I I l

An informational copy of all Incident Reports (with attached

~

6.1.1 Licensee Event Report, if applicable) shall be forwarded to the Operational Analysis Section (OAS) by the Nuclear Plant Staff Technical Section as indicated in Reference 3.1.

6.1.2 One copy of all Potentially Reportable Deficiency Repo. is shall be

. forwarded to OAS by Quality Assurance as indicated in Reference 3.2 and 3.3.

6.2 The Document Safety Review (DSR) Coordinator will enter the document into the OAS Document Log, Form 701.1, for Onsite Documents.

6.3 The DSR Coordinator shall fill out the following parts of the onsite Document Review Summary Sheet , Form 701.2:

1 i

6.3.1 Number and title.

6.3.2 Date of document.

6.3.3 Date assigned for completion.

6.3.4 Name of the Investigating Engineer assigned by the Principal l- Engineer to review the document.

A' 6.4 The DSR Coordinator will file one copy of the document in the OAS onsite document file along with a copy of the onsite Document Review Summary Sheet, Form 701.2.

6.5 The DSR Coordinator will check the document for indications of a major deficiency, major degradation, or substantial safety hazard, any one of which may constitute a reportable condition. He shall evaluate the i document for Code of Federal Regulation reporting considerations, in particular: 10 CFR Parts' 21, 50, and 71; 49 CFR Parts 170 through 189; and for violations of Technical Specifications and the FSAR.

6.6 Further action is required as illustrated in the flow chart of the Onsite Document review process (Attachment I) if: (1) the Coordinator suspects the occurrence of a potentially reportable condition, and/or, (2) the Coordinator disagrees with the determination stated in the document. At this point, he shall notify Plant Staff or Quality Assurance of the concerns. An Investigating Engineer will be directed to perform an independent Technical and Safety Review consisting of evaluations and/or analysis, as needed. An informational copy will be sent to the Supervisor of Nuclear Safety.

6.7 The Investigating Engineer will evaluate the document for possible technical and safety concerns covering, but not limited to, the following areas:

6.7.1 Potential for personnel safety hazards 6.7.2 Potential for equipment damage /inoperability l , _ _ ~ _ _ _ ___.___ _ _ _ _ _ , . _ _ _ _ _ _ _ . _ _ . - _ _ _ _ _ - . - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _

GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING l

Title:

Onsite Document Review l Procedure No.: 01-701 lRsvision: 0lPage: 4l l l l l 1 m) 6.7.3 Potential for recurrence 6.7.4 Potential for loss of unit availability 6.7.5 Conformance with Technical Specifications and FSAR 6.8 The Investigating Engineer shall summarize his findings using the Document Review Summary sheet (Form 701.2). If no recommendations are made, he shall sign the form and processing will continue as given in steps 6.13 through 6.18.

6.9 The Investigating Engineer will prepare a Recommendations Memo, Form 701.3, as follows:

6.9.1 Address the Memo to the Nuclear Plant Manager with copies to the Asst. Plant Manager and Nuclear Support Manager for reviewed Incident Reports.

6.9.2 Address the Memo to the Quality Assurance Manager with copy to the Field Operations Supervisor for reviewed PRD's.

6.9.3 Indicate the " response due date". Mark "INF0" in this space if the Memo is to be sent for information only.

O 6.9.4 Indicate the " response priority" (time frame in which the recipient should respond) by circling " RED" for within 5 working days , " YELLOW" for within 10, " GREEN" for within 20, and "INF0" for no response required.

6.9.5 Indicate the subject of the Memo and reference documents or letters.

6.9.6 Provide a brief background of the investigation, a description of the problem or concern, and the proposed actions that the recipient section should take in order to resolve the concern.

6.10 The Recommendations Memo (Form 701.3) and any related material shall be reviewed by the Document Safety Review Coordinator and signed by the Principal Engineer. The DSR Coordinator shall enter the letter "R" from the " Code of Action Taken" Table on the OAS Document Log (Form 701.1) into the column entitled " Action Taken" to signify that the Memo is being sent to the appropriate section.

6.11 The section which receives the Recommendations Memo (Form 701.3) will be requested to: (1) Evaluate recommendations expressed in the Memo, (2)

Prepare a written response, as needed, indicating proposed or planned actions, and (3) Return the response to OAS within the time frame

~~ indicated.

%.)'

GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING ITitle: Onsite Document Review l Procedure No.: 01-701 l Revision: OlPage: 5l l l l l l 6.12 The Investigating Engineer will incorporate the response into the Onsite Document package.. He will review the response, record his comments on the Document Review Summary Sheet (Form 701.2), and sign the fo rm.

6.13 The Document Safety Review Coordinator shall review the document package.

He shall record his comments on the Document Review Summary Sheet (Form 701.2), and sign the form.

6.14 The Principal Engineer shall sign his approval on the Doaument Review-Summary Sheet (Form 701.2) when the investigation is comp 4ete. The OAS Document Log (Form 701.1) for Onsite Documents shall be updated by the DSR Coordinator.

6.15 The Principal Engineer shall forward to the Nuclear Plant manager copies of Incident Reports reviewed by QAS which are deemed to be safety-related.

6.16 The Principal Engineer shall forward to the Quality Assurance manager copies of PRD Reports reviewed by OAS which are deemed to be safety-l related.

6.17 - A copy of the document package shall be processed into Central Documents and Records in accordance with Reference 3.4 and 3.5.

O 6.18 Reports identified as safety-related will be presented to the Safety Review Committee (SRC) for review.

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GRA!1D GULF NUCLEAR STATIO!1 NUCLEAR PLA!3T ENGINEERING 01-701 Revision 0 Attachment I Page 1 of 1

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QUAEITY ASSUHAPEE g y lP.R D REPORT l l INCIDENT REPORT l DSR COORDINATOR CHECK REPORTABILITY AND CDNCURRENCE

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Attachment III Page 1 of I w.Y EXAMPLE OF DOCUMENT REVIEW

SUMMARY

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Related Documents:

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-EXAMPLE OF RECOMMENDATIONS MEMO, FORM 701.3 9

GRAND CUlf NUCLEAR STATION OPERATIONAL ANALYSIS (NPE)

FORM 701.3 DATE RESPONSE DUE:

Page 1 of RECOMMENDATIONS MEMO MEMO 10: RESPONSE PRIORITY: RED / YELIXM / CREEN / INFO (Circle applicable one)

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SUBJECT:

FILE: ONPE: PMI:

REFERENCES:

BACKCROUND RECOPOtENDATIONS :

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Investigat ion Completed by: /

Investigating Engineer Date Reviewed by: /

Docume nt Safety Review Coordinator Date

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Principal Engineer, Operational Analysis Date c-: Nuclear Safety Supervisor, Nuclear Services ee

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-- Attachment 6

,- AECM-82/49 NUCLEAR PLANT ENGINEERING ADMINISTRATIVE PROCEDURES MANUAL Procedurs No.: 01-702 Revision: 0 Date: February 1, 1982 Safety Related 0FFSITE DOCUMENT REVIEW Prepared; f/hfky, /flF/02 i

Reviewed: fhhw /f/[fV Z l // $o~

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Operational Analysis Prin'c. Engr. Managere45f QA Approved: @ /d, /2-Manage # Nuclear Plant Enggering '

List of Effective Pages:

Page Revision 1-6 0 Attachments I-VIII O

- GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING 9

l

Title:

Offsite Document Review l Procedure No.: 01-702 l Revision: OlPage: 1l l l l l l v) 1.0 PURPOSE The purpose of this procedure is to provide guidance for the administration and independent safety review of IE Bulletins, IE Circulars, IE Informational Notices, INPO Significant Event Reports, INP0/NSAC Significant Operating Experience Reports , Licensing Event Reports, and other similiar event reports, and GE Service Information Letters (GE/SILS).

2.0 RESPONSIBILITY 2.1 Assistant Vice-President, Nuclear Production assigns managers who carry out their responsibilities as defined in this procedure.

2.2 The Principal Engineer of Operational Analysis Section (OAS) is assigned by the Manager of Nuclear Plant Engineering the responsibi-lity for recieving and for processing Offsite Documents directed to GGNS.

He shall transmit to the Nuclear Service Manager the Close-Out Memo for the closed-out document package with copies to the Vice-President of Nuclear Production and other Group Managers listed on distribution.

The Document Safety Review Coordinator is a member of the Operational 2.3 Analysis Section assigned by the Principal Engineer (OAS) the re-

- sponsibility for performing the following actions: (1) Screening 0s Offsite documents for applicability to GGNS; (2) Writing and distri-buting requests for evaluations to be performed by the appropriate MP&L Group, consultant, or supplier; (3) Tracking document evaluations and receiving responses; (4) Coordinating the independent safety review; (5)

Reviewing the Of fsite Document package complu'ed by the Investigating Engineer; and (6) Transmitting the completed package to the Principal Engineer for approval and close-out.

2.4 The Investigating Engineer ia a member of the Operational Analysis Section assigned by the Principal Engineer (OAS) to: (1) Flag potentially reportable deficiencies during document screening; (2)

Evaluate the document and review document evaluations performed by others; (3) Perform independent evaluation and/or analyses as needed; (4)

Contact originating organizations for clarification, if needed; (5)

Develop recommendations to the Nuclear Plant Manager, as needed; and (6)

Complete the review suama' r y and the Close-Out Memo per this procedure.

l

! 2.5 Nuclear Plant Manager is responsible for ensuring that the appropriate

< Plant Staff sections: (1) Evaluate recommendations expressed in the Recommendations Memo, (2) Determine actions required to resolve problams and concerns, if solutions have been not. already been established, and

! (3) Prepare a response to OAS, as needed, indicating proposed or planned

! actions.

O

GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING l

Title:

Offsite Document Review l Procedure No.: 01-702 IRevision: OlPage: 2l l l 1 l I s

2.6 As determined by screening, the Principal Engineer or his designee may request in formation , technical evaluations or recommendations from one or more managers of Nuclear Production Groups or outside parties on matters relating to IE Bulletins, Circulars, Information Notices, INP0/

NSAC documents, NRC Licensee Event Reports or other plant safety matters.

Outside parties may include, but are not limited to, suppliers, consul-tants and/or other non-nuclear MP&L groups,

3.0 REFERENCES

3.1 Plant Administrative Procedure 01-S-06-13, IE/INP0/NSAC Documents 3.2 Plant Administrative Procedure 01-S-05-1, Operation and Control of the Central Document and Records System 3.3 Operational Quality Assurance Manual (MPL-TOP-IA) 2.5.8 3.4 Cuidelines for Utility Management Structure and Technical Resources, NUREG-0731, September,1980 3.5 Clarification of TMI Actioa Plan Requirements, NUREG-0737 3,6 Grand Gulf Nuclear Station Technical Specifications, Section 6.2.3 3.7 Operational Quality Assurance Manual (MPL-TOP-1 A) 3.4.2, 3.5.6 4.0 ATTACHMENTS 4.1 Attachment I - OAS Document Log, Form 701.1 4.2 Attachment II - Document Review Summary Sheet, 701.2 4.3 Attachment III - Flow Chart of Offsite Document Review Process 4.4 Attachment IV - Close-Out Memo, Form 702.1 4.5 Attachment V - Document Routing Sheet, Form 702.2 4.6 Attachment VI - Telephone Call / Conversation Report, ' Form 702.3 4.7 Attachment VII - Recommendations Memo, Form 701.3 4.8 Attachment VIII - Resolution Summary Sheet, Form 702.4 5.0 DEFINITIONS 5.1 Of fsite Documents will include, but are not limited to: (1) IE O

V Documents; (2) INP0/NSAC -Documents, (3) GE/SILS; (4) NRC Licensee Event Reports.

CRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING l

Title:

Offsite Document Review l Procedure No.: 01-702 l Revision: 0lPage: 3l

--q l l l l l s_/

5.2 IE Documents - IE Documents are IE Bulletins, IE Circulars, and IE Information Notices sent by the NRC to license holders, holders of construction permits, and applicants. These documents express some concern of the Nuclear Regulatory Commission about a problem which the commission feels may be of a generic nature. The bulletin or circular may require a written reply within a specified time or may be issued for information only. Whether or not a written reply is required, the recipient is required to investigate and resolve any concern that is found to apply to its facility and to document the investigation and resolution.

5.3 INPO/NSAC Documents - INP0/NSAC Documents identify significant operating experiences to the licensee and are originated by the Institute of Nuclear Power Operations (INPO) or the Nuclear Safety Anlysis Center (NSAC) respectively. These may be of two types; Signi ficant Event Reports (SER), issued by INPO using a system called NOTEPAD, and Significant Operating Experience Reports (SOER), mailed by INP0/NSAC to member utilities. The SOER's are color coded to denote the type attention required. Red denotes immediate attention, yellow denotes prompt attention, and green denotes normal attention.

5.4 GE SILS - General Electric distributes Service Information Letters (SILS)

I) to its customer utilities to allow experience gained at a BWR site to be

-# shared by all BWRs.

6.0 DETAILS 6.1 Upon receipt, the Of fices Services Supervisor of Plant Staff and the Nuclear Safety Supervisor of Nuclear Services will forward copies of IE Documents and INP0/NSAC Documents, directed to GGNS, to the Principal Engineer in accordance with Reference 3.1.

6.2 The Document Safety Review (DSR) Coordinator will enter the document into the OAS Document Log, Form 701.1, for of fsite documents. The log will serve as a chronological listing and close-out record of all Of fsite Documents directed to the Operational Analysis Section for information, review or action.

l 6.3 The DSR Coordinator will fill cut the following sections of the of fsite Document Review Summary Sheet, Form 701.2:

6.3.1 Name and Title 6.3.2 Date of Document 6.3.3 Date assigned for completion O

V

GRAND CULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING l

Title:

Offsite Document Review l Procedure No.: 01-702 l Revision: OlPage: 4l 1 I i q

J l l 6.4 The DSR Coordinator will file one copy of the document in the OAS offsite document file along with a copy of the offsite Document Review Summary Sheet, Form 701.2.

6.5 The DSR Coordinator will conduct a preliminary screening evaluation and direct the document for action as shown in the flow chart of the offsite document review process (Attachment III) and described as follows:

6.5.1 If it is determined that: (1) the subject matter is not applicable to GGNS, or (2) the matter has already been evaluated review and resolved, the offsite Document Review Summary Sheet (Form 701.2) and the Close-Out Memo, Form 702.1, will be completed stating the reason that no further action is required. Process-ing will continue as given in steps 6.18, 6.19, and 6.20.

6.5.2 If the subject matter is for information only, the offsite Document Review Summary Sheet (Form 701.2) will be completed and filed in the OAS offsite document file. Copies will be circulated to the organizations designated on the Document Routing Sheet, 1 Form 702.2.

! 6.5.3 If an Of fsite Document is not closed out and further action is i

) required as a result of preliminary screening, then an evaluation by other sections or organizations and an independent Technical and Safety Review by OAS is required.

6.5.4 Upon Notification by the Coordinator that further action is required, the Principal Engineer shall assign responsibility for a subject document to an OAS Investigating Engineer.

6.6 As required, the Coordinator will write the request (s) for a technical evaluation.

7 6.7 If the screening indicated that reporting considerations should also be I addressed in the request for a technical evaluation, then this will also l

be indicated on the offsite Document Review Summary Sheet (Form 701.2) along with the reference codes, specifications, etc.

6.8 Requests will generally be sent to Plant Staff section(s) when the subject matter concerns operation of the plant. When the subject matter concerns design of and/or modifications to the plant , then the request may be sent to the Manager of Nuclear Plant Engineering by the Principal l Engineer. The Document Routing Sheet (Form 702.2) will be used as a cover to direct requests for evaluations.

j 6.9 The Document Safety Review Coordinator will receive the written responses l g (reports) for evaluations performed by "others", and incorpotate these Q into the document package.

F GRAND GULF NUCLEAR STATIOJ NUCLEAR PLANT ENGINEERING l

Title:

Offsite Document Review l Procedure No.: 01-702 l Revision: OlPage: 5l n l I I I I

<_Y 6.10 The Investigating Engineer will evaluate responses from cognizant sections and communicate with them for a resolution of any questions concerning the evaluation using the Telephone Call / Conversation Report, Form 702.3, for a record.

6.11 The Investigating Engineer will evaluate the document for possible technical and safety concerns covering, but not limited to, the following areas:

6.11.1 Potential for personal safety hazards 6.11.2 Potential for equipment damage /inoperability 6.11.3 Potential for recurrence 6.11.4 Potential for loss of unit availability 6.11.5 Conformance with Technical Specifications and FSAR

( 6.12 The Investigating Engineer shall summarize his finding using the l Document Review Summary Sheet (Form 701.2). He will prepare a

- Recommendations Memo, Form 701.3, as follows:

6.12.1 Address the Memo to the Nuclear Plant Manager and/or Nuclear Services Manager as appropriate, with copies to the Nuclear Safety Supervisor.

l

6.12.2 Indicate the " response due date".

[

6.12.3 Indicate the response priority (time frame in which the recipient should respond) by circling " RED" for within 5 working days, " YELLOW" for within 10 working days, and

" GREEN" for within 20 working days.

6.12.4 Indicate the subject of the Memo and reference documents or

! letters.

6.12.5 Provide a brief background of the investigation, a description of the problem or concern, and the proposed actions that the recipient section should take in order to resolve the concern.

6.13 The Recommendations Memo (Form 701.3) and any related material will be reviewed by the Document Safety Review Coordinator and the Principal Engineer (OAS). The DSR Coordinator shall enter the letter "R" from the i " Code of Action Taken" Table on the OAS Document Log (Form 701.1) into the column entitled " Action Taken" to signify that the Memo is being sent to the appropriate section.

i

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GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING l

Title:

Offsite Document Review l Procedure No.: 01-702 l Revision: o!Page: 6l

)

v l I I I I 6.14 The section which receives the Recommendation Memo (Form 701.1) will be requested to: (1) Evaluate recommendations expressed in the Memo, (2)

Determine actions required to resolve problems or concerns, (3) Prepare a written response , as needed, indicating proposed or planned actions, and (4) Return the response to OAS within the time frame ind icat en'.

6.15 The Investigating Engineer will review the section response and determine if his concern has been resolved satisfactorily. He may communicate with the section using the Telephone Call / Conversation Report (Form 702.3) for a record. The Investigating Engineer may initiate another Recommendations Memo if he considers that the action taken as a result of his first memo did not adequately address the concern.

6.16 When the concern has been resolved and a mutually acceptable response developed , t'ae Investigating Engineer will prepare a Resolution Summary Sheet, Form 702.4, that provides a summary of: (1) the recommendations ,

(2) the resonse(s), (3) action planned or taken, and (4) any comments.

6.17 Upon completion of the investigation, the Document Safety Review Coordinator shall review the document and any material prepared by the Investigating Engineer. The DSR Coordinator shall signify his review of the investigation on the Document Review Summary Sheet (Form 701.2).

6.18 The Investigating Engineer / Document Safety Review Coordinator shall prepare a Close-Out Memo (Form 702.1). When this memo is signed by the Principal Engineer, the memo will be sent to the Nuclear Services Manager with copies to the Asst. Vice-President Nuclear Production, Nuclear Plant Manager, the Training Superintendent, and the QA Manager.

6.19 The Principal Engineer shall forward to the Plant Manager copies of closed-out document packages deemed to be safety-related.

6.20 The closed-out document package, with the original forms and reports, shall be processed into Central Docunents and Records per Reference 3.2 and 3.3 with a copy to the OAS files.

GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING 01-702 Revision 0 Attachment I Page 1 of I e

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01-702 Ravision 0 At taclanen t II Page I of 1

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SUMMARY

SHEET, FORM 701.2 GRAND CULF NUCLEAR STATION OPERATIONAL ANALTStB (NPE)

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, DOCUMENT REVIEW

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SUMMARY

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GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING 01-702 Revision 0 Attachment III Page 1 of 1

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GRAND CULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING

.01-702 Revision 0 Attachment IV Page 1 of 1

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l EXAMPLE OF CLOSE-0UT MEMO, FORM 702.1 1

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CRAND CULF NUCLEAR STATION OPERATIONAL ANALYSIS (NPE)

FORM 702.1 CLOSE-OUT MEMO 1

l- MEMO TO: Nuclear Services Manager DATE:

FROM: Principal Engineer of Operational Analysis Sectio:t

SUBJECT:

Document Type, Number, Title Fitz: 0292/0294/ ONPE: PMI:

REFERENCES:

BACKCROUND - A brief suimmary of the document.

DISCUSSION - A short statement (or question) identifying the concern to CGNS.

ACTION & SOLITf10N - A summary of actions taken and how it is to resolve the concern to CGNS. If some long ters actiun is required, the means to ensure this action is completed will be included in this section (for example, plant staf f may have issued a task card on a given date to ensure a tes t was completed.)

When this memo is signed by the Principal Engineer, the file for the document wilt be closed.

cc. Asst. Vice President , Nuclear Product ion .

Nuclear Plant Manager Quality Assurance Manager Training Superintendent File (Project)

File (PMI)

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GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING 01-702 RIvision 0 Attachment V Page 1 of I

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v EXAMPLE OF DOCUMENT ROUTING SHEET, FORM 702.2 CRAND CULF NUCl2AR STATION OPERATIONAL ANALYSIS (NPE)

FORM 702.2 DOCUMENT ROUTINC SHEET

SUBJECT:

NUMBER: TITLE:

FILE: 0292/0294/ ONPE:

DATE:

DISTRIBUTION ACTION LETTER (PMI) DATE PRIORITY RESPONSE DUE

1. Nuclear Plant Manager

2. Nuclear Support Manager

3. Aden. & Training Supt.

4. Technical Supt.

5. Nuclear Plt. Qual. Supt.

6. Asst. Nuclear Plt. Mgr.

7. Operations Supt.

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, 8.

9.

Maintenance Supt.

Chen/ Rad Control Supt.

10. React or Engr. Supv.

!!. Maintenance Engr. Supv.

12. Technical Engr. Supv.

13. Licensing, Plant Staff

14. Nuclear Services Manager i 15. Quality Assurance Mgr.

16. Nuclear Plant Engr. Mrg.

17. Site Manager

!!8. l CODE FOR ACTION TAKEN:

1 - ROUTED FOR INFORMATION ONLY, (NO RESPONSE REQUIRE 2)

E - ROUTED FOR EVALUATION, (RESPONSE REQUIRED BY DUE DATE)

PRIORITY CODE:

RED - REQUESTED TO PESPOND WITHIN FIVE WORKING DAYS (! WEEE)

YELLOW - REQUESTED TO RESPOND WITHIN TEN WORKING DAYS (2 WEEKS)

CREEN ~ REQUESTED TO RESPOND WITHIN TWENTY WORKING DAYS (4 WEEKS)

ACKNOWLEDGEMENT:

I have received the subject document and have

[ ] comments attached

( ) no comments attached Initials /Date v

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GRAND GULF NUCLEAR STATION NUCLEAR PLAhT ENGINEERING

.01-702 Revision 0 Attachment VI Page 1 of 1 O

EXAMPLE OF TELEPHONE CALL / CONVERSATION REPORT, FORM 702.3 CRAND CULF NUCLEAR STATION OPERATIONAL ANALYSIS (NPE)

FORM 702.3 Fage I cf TELEPHONE CALL / CONVERSATION REP 0"T COPY TO:

BY OF ROUTE ,

TO OF DATE 19 TIME SUBJ ECT NUCLEAR QA (IS) (IS NO2) APPLICABLE ACTION REQUIRED (NO) (YES) BY FILE NOS.

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GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING 01-702 Revision 0 Attachm'nt VII Paga 1 of 1 EXAMPLE OF RECOMMENDATIONS MEMO, FORM 701.3 CRAND CUtf NUCLEAR STATION OPERATIONAL ANALYSIS (NPE)

FORM 701.3 DATE RESPONSE DUE:

I Page 1 of o

RECOMMENDATIONS MEMO MEMO TO: RESPONSE PRIORITY: RED / YELLOW / CREEN / ThTO (Circle applicable one)

FROM:

SUBJECT:

FILE: ONPE: PMI:

REFE PINCES:

BACKGROUND

/

RECL.PTNDATIONS :

(Attach additional sheets, if necessary)

Investigat ion Cornpleted by: /

Invest igating Engineer Date Reviewed by: /

Docu me nt Safety Review Coordinator Date Approved by: /

Principal Engineer, Operational Analysis Date cc: Nuclear Saf ety Supervisor, Nuclear Services

P

. e GRAND GULF NUCLEAR STATION NUCLFAR PLANT ENGINEERING

e.01-702 Revision 0 Attachment VIII Page 1 of 1 EXAMPLE OF RESOLUTION

SUMMARY

SHEET, FORM 702.4 CRAND CULF NUCLEAR STATION OPERATIONAL ANALYSIS (NPE)

FORM 702.4 Page 1 of RESOLUTION SLMMARY SHEET Numbe r:

Title:

Date of Document: Date Review Due:

Investigating Engineer Assigned:

Related Documents:

BACKCROUND:

SUMMARY

OF ACTION PLANNED OR TAKEN:

(Attach additional sheets, if necessary)

Investigation Completed by: /

Investigating Engineer Date Reviewed by: /

Document Safety Review Coordinator Date Approved by: /

Principal Engineer, Operational Analysis Date I

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Attachment 7

!: AECM-82/49 O NUCLEAR PLANT ENGINEERING ADMINSTRATIVE PROCEDURES MANUAL Procedure No: 01-704 Revision: 0 Date: February 1, 1982 Non-Safety Related OPERATIONAL ANALYSIS SECTION REPORTS, O

Prepared: My _ /[///87- ,

Reviewed: '

/ / 7 F 2_ / (( ,

[6 tye C Operational' Analysis P'inc. En r. Managdh of QA Approved: . m m lo,/[8#

Manageffof Nuclear Plant Engineeggiiig List of Ef fective Pages:

Page: Revision:

, 1-3 0 Attachments I-II O O

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GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING

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Title:

Operational Analysis Section Reports l Procedure No.

l 01-704 l Rev. 0 lPage 1 l l l

l 1.0 PURPOSE This procedure provides guidelines for the preparation, review, and approval of section reports documenting the activities of the Operational Analysis Section (OAS).

2.0 RESPONSIBILITIES 2.1 Principal Engineer of Operational Analysis Section (OAS) is assigned by the Manager of Nuclear Plant Engineering the responsibility for ensuring that OAS reports are prepared in accordance with this procedure; and for reviewing, approving, and submitting reports to other Nuclear Plant Engineering Sections , Plant Staff Sections, Quality Assurance, or Nuclear Services as appropriate.

2.2 The Principal Engineer (OAS) may originate a section report or assign the responsibility to members of the OAS staff.

l 2.3 The Investigating Engineer of Operational Analysis Section will originate a section report when concluding an assignment which warrants such a repcrt.

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3.0 REFERENCES

3.1 Plant Administrative Procedure 01-S-05-1, operation and Control of Central Document and Records System 3.2 Operational Quality Assurance Manual (MPL-TOP-1A), 2.5.8 4.0 ATTACHMENTS 4.1 Attachment I, Section Report Cover Sheet, Form 704.1 4.2 Attachment II, Section Report Log, Form 704.2 4.3 Attachment III - Document Routing Sheet, Form 702.2 4.4 Attachment IV - Telephone Call / Conversation Report , Form 702.3 5.0 DEFINITIONS None 6.0 DETAILS

6.1 Operational Analysis Section (OAS) reports will be written to document x/ activities assigned to the Investigating Engineer. Activities may include, but are not limited to the following

6.1.1 Safety-related informational exchanges with other BWR sites, suppliers, and/or outside organizations.

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i GRAND CULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING

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Title:

Operational Analysis Section Reports l Procedure No.

l 01-704 l Rev. 0 l Page 2 l l l

l 6.1.2 Reviews of maintenance activities and investigation of high frequency repair items in safety-related systems.

6.1.3 Evaluations of safety related component and plant reliability.

6.1.4 Investigations of off-normal operating conditions and events that could affect the safe shutdown of the reactor.

6.1.5 Investigations of unit forced outages for recurrence control.

6.1.6 Administrative Evaluations of Plant Staff sections performed at the request of tne Safety Review Committee (SRC).

6.2 The Operational Analysis section reports will include a signed Cover t Sheet, Form 704.1. The body of the report should incorporate the following:

6.2.1 Abstract - a brief explanation of the reasons for the report, the extent and direction of the report, and the conclusions of the report.

6.2.2 References - A list of documents , letters, drawing, or Telephone Call / Conversation Reports relevant to the report.

6.2.3 Attachment - A list of supporting documents enclosed with the report including tables and figures .

6.2.4 Background - A section delineating the reasons for the work covered by the report and any historical foundations involved.

6.2.5 Discussion - A section detailing the work performed in the investigation.

6.2.6 Summary and Conclusions - A section summarizing the results of the work performed and listing the conclusions of the report.

6.2.7 Enclosures - Supporting documents listed under Attachment.

6.3 The Investigating Engineer shall have the report draf t reviewed for technical content by a second cognizant engineer.

6.4 The Principal Engineer (OAS) shall review the draf t report and sign his approval on the Cover Sheet (Form 704.1) when the report is in satisfactory form.

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6.5 Approved section reports will be entered into the Section Report Log, Form 704.2, by the Principal Engineer (OAS).

F CRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING

/O

Title:

Operational Analysis Section l Procedure No.01-704 l Rev. 0 lPage 3 l

( j l l Reports l l l l 6.6 If the Principal Engineer (OAS) determines that a technical evaluation by sections other than OAS is required, then the request will be written by the Investigating Engineer.

6.7 Requests for technical evaluation will generally be sent to Plant Staff section(s) when the subject matter concerns operation of the plant. When the subject matter concerns design of and/or modifications to the plant ,

then the request may be sent to the Manager of Nuclear Plant Engineering by the Principal Engineer. The Document Routing Sheet, Form 702.2, will be used as a cover to direct requests for evaluations.

6.8 The Investigating Engineer will evaluate responses from cognizant sections and comnunicate with then for a resolution of any questions concerning the evaluation, using the Telephone Call / Conversation Report, Form 702.3, for a record.

6.9 Evaluation Reports and Telephone Call / Conversation Reports (Form 702.3) produced in steps 6.7 and 6.8 shall be attached to the section the OAS section report file.

N

) 6.10 A copy of the document package shall be processed into Central Documents and Records in accordance with Reference 3.1 and 3.2.

O 4

g GRAND GULF NUCLEAR. STATION NUCLEAR PLANT ENGINEERING 01-704 Revision O Attachment I Page 1 of 1

' EXAMPLE OF OAS REPORT COVER, FORM 704.1

s. -

NUCLEAR PLANT ENGINEERING OPERATIONAL ANALYSIS SECTION.

FORM 704.1 TITLF.

REPORT 100.

DATE PREPARED: /

DATE REVIEWED: /

SECOND COGNIZANT ENGINEER DATE APPROVED: /

PRINCIPAL ENGINEER OPERATIONAL ANALYSIS DATE I

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• GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING S01-704 Revision O Attachment II Page 1 of 1 O

EXAMPLE OF SECTION REPORT LOG, FORM /04.2 GRAND CULF NUCLEAR STATION OPERATIONAL ANALYSIS (NPE) ,

FORM 704.2 SECTION REPORT LOC INITIALS REPORT INVEST. PRINC. 5 NUMBER TITLE DATE ENCR. ENCR.

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GRAND GULF NUCLEAR' STATION NUCLEAR PLANT ENGINEERING 1

01-704 Rtvisien 0 AttachrDent III Page 1 of 1

,,m

_s EXAMPLE OF DOCUMENT ROUTING SHEET, FORM 702.2 GRA D CULP NUCLEAR STATION OPERATIONAL ANALYSIS (NP,E)

FORP 702.2 DOCUMENT ROUTING SHEET SUBJECT NUMBER TITLEt FILE: 0292/0294/ ONPE:

DATE:

DISTRIBiff!ON ACTION LETTER (PMI) DATE PRIORITY RESPONSE DUE

1. Nuclear Plant Manager

2. Nuclear Support Manager

3. Aden, & Training Supt.

4. Technical Su .

5. Nuclear Plt. Qual. Supt.

6. Asst. Nuclear Plt. Mgr.

7. Operations Supt.

} 8. Maintenance Supt.

\_/ 9. Chem / Rad Cont rol Supt.

10. Reactor Engr. Supv.

11. Maintenance Engr. Supv.

12. Technical Engr. Supv.

13. Licensing, Plant Staff

14. Nuclear Services Manager

15. Qualit y Assurance Mgr.

I6. Nuclear Plant Engr. Mrg.

17. Site Manager 18.

CODE FOR ACTION TAKEN:

I - ROUTED FOR INFORMATIO't ONLY, (NO RESPONSE REQUIRED)

E - ROUTED FOR EVALUAT10N, (RESPONSE REQUIRED BY DUE DATE)

PRIORITY CODE:

[

l RED - REQUESTED TO RESPOND WITHIN FIVE WORKING DAYS (1 WEEK)'

l YELLOW - REQUESTED TO RESPOND WITHIN TEN WORKING DAYS (2 WEEKS)

CREEN - REQUESTED TO RESPOND WITHIN TWENTY WORKING DAYS (4 WEEKS)

• l l ACKNOWLEDGEMENT:

I have received the subject document and have

[ ] coernents attached

[ ] no conunent s attached i

Initials /Date

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. . GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING i* 01-704 Rivision 0 Attachment IV Page 1 of I b/

.\ EXAMPLE OF TELEPHONE CALL / CONVERSATION REPORT, FORM 702.3 CRAND CULF NUCLEAR STATION OPERATIONAL ANALYSIS (NFE)

FORM 702.3 Page 1 of TELEPHONE CALL / CONVERSATION REPORT COPY TO:

sY Or ROUTE ,

TO OF DATE 19 TIME SUBJECT NUCLEAR QA (IS) (IS NOT) APPLICABLE ,

ACTION BEQUIRED (NO) (YES) BY FILE NOS.

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Attachment 8 AECM-82/49 O

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ADMINISTRATIVE CONTROLS * - - - - - - - - - - - - -

3 RECORDS 6.5.1.8 The PSRC shall maintain written minutes of each PSRC meeting that, at a minimum, document the results of all PSRC activities performed under the responsibility and authority provisions of these Technical Specifications.

Copies shall be provided to the SRC. -

1 6.5.2 SAFETY REVIEW COMMITTEE (SRC)

FUNCTION 6.5.2.1 The SRC shall function to provide independent review and audit of l designated activities in the areas of:

a. nuclear power plant operations

b. nuclear engineering

c. chemistry and radiochemistry

d. metallurgy

e. instrumentation and control

f. radiological safety

g. mechanical and electrical engineering

h. quality assurance practices -

COMPOSITION 6.5.2.2 The SRC shall be composed of the:

Chairman: Assistant Vice President for Nuclear. Production Member: Manager of Nuclear Plant Engineering.

Member: Manager of Quality Assurance Member: Manager of System Nuclear Operations, Middle South Services, Inc.

Member: Nuclear Plant Manager Member: Manager of Nuclear Services Member: Corporate Health Physicist Member: Principal Engineer, Operations Analysis Member:

• Advisor to the Assistant Vice-President, Nuclear Operations Two additional members shall be consultants to Mississippi Power and Light Company consistant with the recommdndations of the Advisory Committee on Reactor Safeguards letter, Mark to Palachino, dated October 20, 1981.

ALTERNATES

~

6.5.2.3 All alternate . members sh'111-be, appointed in writing by the SRC

% Chairman to serve on a temporary basis; h.owev.er,.no more than two alternates shall participate as voting m'embets in SRC activities at any one time.

n .

• Non voting member. -

JAN 5 1982 GRAND GULF-UNIT 1 6-9 ,

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ADMINISTRATIVE CONTROLS CONSULTANTS 6.5'.2.4 Consultants, in addition to those required in Specification 6.5.2.3, l shall be utilized as determined by the SRC Chairman to provide expert advice to th6 SRC.

MEETING FREQUENCY 6.5.2.5 The SRC shall meet 6t least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per six months thereafter. .

QUORUM 6.5.2.6 The minimum quorum of the SRC necessary for the performance of the SRC review and audit functions of these Technical Specifications shall consist of the Chairman or his designated alternate and at least 6 SRC members including alternates. No more than a minority of the quorum shall have line respons'ibility for operation of the unit.

REVIEW 6.5.2.7 The SRC shall review:

a. The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.

b. Proposedchangestoprocedures,equipmentorsyitemswhichinvolve an unreviewed safety question as defined in Section 50.59, 10 CFR.

c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

d. Proposed changes to Appendix A Technical Specifications or this Operating License.

e. Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance,

f. Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.

g. Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification to the Commission.

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h. All recognized indication,s'of an unanticipated deficiericy in some aspect of design or, operation of stiuctures, systems, or components that could affect nuclear safety.

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Reports and meetings minutes of the PSRC.

UAN 5 1962

, GRAND GULF-UNIT 1 6-10

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./ i I i ADMINISTRATIVE CONTROLS ' ~ -- ~ ~ ' ' '

AUDITS 6.5.2.8 Audits of unit. activities shall be performed under the cognizance of the SRC. These audits shall encompass:

a. The conformance of unit operation to provisions contained within the Appendix A Technical Specifications and applicable license conditions at least once per 12 months.

b. The performance, training and qualifications of the entire unit staff at least once per 12 months.

c. ~

The results of actions taken to correct deficiencie's occurring in unit equipment, structures,. systems or method of operation that affect nuclear safety at least once per 6 months. '

d. The performance of activities required by the Operat'.. 71 Quality Assurance Program to meet the criteria of Appendix "B", 10 CFR 50, at least once per 24 months.

e.

TheEmergencyPianandimplementingprpceduresatleastonceper 24 months.

- f. -The Security Plan and implementing procedures at least once per

(--

24 months.

g. Any other area of unit operation contidered appropriate by the SRC or the Senior Vice President - Nuclear.

h. The Fire Protection Program and implementir.g procedures at least once per 24 months.

i. An independent fire protection and loss prevention inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.

J. An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 36 months.

k. The radiological environmental monitoring program and the results thereof at least once per 12 months.

1. The 0FFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

m. The PROCESS CONTROL PROGRAM and implementing procedures for solidification of radioactive wastes at least once per 24 months.

( . n. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, February 1979, at least once per 12 months.

GRAND GULF-UNIT 1 6-11 fEB 1 1982

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ADMINISTRATIVE CONTROLS AUTHORITY 6.5.2.9 The SRC shall report to and advise the Senior Vice President - Nuclear on those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.10 Records of SRC activities shall be prepared, approved and distributed as indicated below:

a. Minutes of each SRC meeting shall be prepared, approved and forwarded to the Senior Vice President - Nuclear within 14 days following each meeting.

b. Reports of reviews enccmassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the Senior Vice President -

Nuclear within 14 days following completion of the review.

c. A'udit reports encompassed by Section 6.5.2.8 above, shall be forwarded to the Senior Vice President - Nuclear and to the management positions responsible for the areas audited within 30 days after completion of the audit by the auditing organization.

6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 The following actions shall be taken for REPORTABLE OCCURRENCES:

a. The Commission shall be notified and/or a report submitted pursuant to the requireaents of Specification 6.9.

~

b. Each REPORTABLE OCCURRENCE requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification to the Commission shall be reviewed by the PSRC and submitted to the SRC and the Senior Vice President - Nuclear.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a. The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within one hour. The Senior Vice President - Nuclear and the SRC shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the PSRC. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon unit components, systems or structures, and (3) corrective action taken to prevent recurrence,

'" c. The Safety Limit Violation Report. shall be submitted to the Commission, the SRC and'the Senior Vice President - Nuclear within 3 14 days of the violation. . . ,.

d. Critical operation of the unit shall not be resumed until authorized by the-Commission. .

i ,.

, GRAND GULF-UNIT 1 6-i2 !JAN 5 1982

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Attachment 9 AECM-82/49 ADMINISTRATIVE CONTROLS RECOPDS 6.5.1.8 The PSRC shall raintain written minutes of each PSRC meeting that, at a minimum, document the results of all PSRC activities _ performed under the responsibility and authority provisions of these Technical Specifications. Copies shall be provided to the Assistant Vice President for Nuclear Production and the SRC.

6.5 2 SAFETY REVIEW COMMITTEE (SRC)

FUNCTION 6.5.2.1 The SRC shall function to provide independent review of designated activities in the areas of:

a. nuclear power plant operations

b. nuclear engineering-

c. chemistry and radiochemistry

d. metallurgy

e. instrumentation and control

f. radiological safety

g. mechanical and electrical engineering

h. quality assurance practices COMPOSITION 6.5.2.2 The SRC shall be composed of the:

Chairman: Assistant Vice President for Nuclear Production Member: Manager of Nuclear Plant Engineering Member: Manager of Quality Assurance Member: Manager of System Nuclear Operations, Middle South Services, Inc.

Member: Nuclear Plant Manager Member: Manager of Nuclear Services Member: Corporate Health Physicist Member: Principal Engineer, Operations Analysis Members: Two experienced outside consultants ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the SRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in SRC activities at any one time.

M6B1

ADMINISTRATIVE CONTROLS CONSULTANTS 6.5.2.4 Consultants, in addition to those already noted in subsection 6.5.2.2, shall be utilized as determined by the SRC Chairman to provide expert advice to the SRC.

- MEETING FREQUENCY 6.5.2.5 The SRC shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per six months thereafter. The SRC may conduct emergency meetings via a conference call or other electronic means that allows open discussion between all members necessary to fulfill the requirements for a quorum.

QUORUM 6.5.2.6 The minimum quorum of the SRC necessary for the performance of the SRC review function of-these Technical Specifications shall consist of the Chairman or his designated alternate and at least 6 SRC members including alternates. No more than a minority of the quorum shall have line responsibility for operation of the unit.

REVIEW 6.5.2.7 ~ The SRC shall review:

a. The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

d. Proposed changes to Appendix A Technical Specifications or this Operating License.

e. Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f. Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.

M6B2 m _ _ _ -_ _ . - _ ,

. ADMINISTRATIVE CONTROLS

g. Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification to the Commission.

h. All recognized indications Sf an unanticipated deficiency in some aspect of design or operation of structures, systems, or:

components that could affect nuclear safety,

i. Reports and meeting minutes of the PSRC.

AUDITS.

6.5.2.8 The SRC shall review the results of audits of nuclear activities conducted in accordance with the MP&L Operational Quality Assurance Manual. Audits shall be conducted and results shall be reviewed in the areas of:

a. The conformance of unit operation to provisions contained within the Appendix A Technical Specifications and applicable license conditions at least once per 12 months.

b. The performance, training and qualifications of the entire unit staff at least once per 12 months.

c. The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months,

d. The performance of activities required by the Operational Quality' Assurance Program to meet the criteria of Appendix "B", 10 CFR 50, at least once_per 24 months.

e. The Emergency Plan and implementing procedures at least once per 24 months,

f. The Security Plan and implementing procedures at least once per 24 months.

g. Any other area of unit operation considered appropriate by. the SRC or the Senior.Vice President Nuclear.

h. The Fire Protection Program and implementing procedures at least once per 24 months.

i. The independent fire protection and loss prevention inspections and audits that shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.

j. The inspections and audits of the fire protection and loss prevention program that shall be performed by an outside-qualified fire consultant'at' intervals no greater than 36 months.

M6B3

r ADMINISTRATIVE CONTROLS

k. The radiological environmental mor.itoring program and the

' results thereof at least once per 12 months.

1. The-OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

m. The PROCESS CONTROL PROGRAM and' implementing procedures for solidification of radioactive wastes at least once per 24 months.

n. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, February 1979, at least once per 12 months.

AUTHORITY 6.5.2.9 The SRC shall report to and advise the Senior Vice President Nuclear on those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.10 Records of SRC activities shall be prepared, approved, and distributed as indicated below:

a. Minutes of each SRC meeting shall be prepared and forwarded to the Assistant Vice President Nuclear Production for approval and subsequent transmittal to the Senior Vice President -

I Nuclear and all members of the Safety Review Committee within 14 days following each meeting.

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l M6B4 L .,

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Attechment 10 AECM-82/49

^ Bases for Changes in Safety Review Committee (SRC)

Technical Specification Subsection 6.5.2

1. Removal of Advisor 'to Assistant Vice President-Nuclear Operations Subsection 6.5.2.2 Basis: This Advisor attends SRC meetings as a non-voting member.

Since the advisor is a temporary position and it is contemplated that the position will last no longer than one year following the fuel load of Unit 1. It is-noc desirable to include temporary conditions in the Technical Specifications after acceptance. Technical Specifications can only be changed by an Amendment and requires a formal notice. subject to the possi-bility of the hearing process. 10 CFR 50.91, 10 CFR 2.105 (a) (3) and (7).

2. The wording of 6.5.2.4, Consultants, has been changed from "... required in specification..." to "...already noted in subsection..."

Basis: The prologue of subsection 6.5.2.2, "The SRC shall be composed of..." already establishes the composition of the SRC as a requirement. The applicant has removed redundant language in 6.5.2.4. Emphasis added.

3. Subsection 6.5.2.5, Meeting Frequency. The applicant has added a sentence permitting the conductance of ". . . emergency meetings. . ." (only)

". . .via a conference call or other electronic means. . .". Emphasis added.

Basis: "There is a geographical separation of up to 300 miles of the voting members of the SRC and, based on the experience of other operating reactors, the applicant anticipates a number of changes to the Technical Specifications as well as other documents that would require a' review by the SRC. Subsection 6.5.2.7.d. This could cause costly, and otherwise unnecessary, shutdown of the facility.

4. It is requested the first sentence and the beginning of the second sentence of the Standard Technical Specifications be revised to read as follows:

"6.5.2.8 The SRC shall review the results of' audits of nuclear activities conducted in accordance with the MP&L Operational Qu'ality Assurance Manual. Audits shall be conducted and results shall be reviewed in the areas of: ..."

Basis: The above wording is necessary in order to make the GCNS Technical Specifications compatible with the NRC accepted MP&L Operational QA Topical Report MPL-TOP-1A Revision 2 (6/1/81).

For your review, the pertinent paragraphs from Policy 18.0, AUDITS are given below:

"18.3 APPLICABILITY The requirements of this policy apply to all internal and external audits performed by or for MP&L during the operational phase of nuclear power plant activitics.

B72ph1

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18.4 RESPONSIBILITY 18.4.1 Responsibilf.ty and authority for the MP&L audit program are. delegated.to the Manager of-Quality Assurance. He is responsible for the development and implementation of a program of planned and documented audits to verify compliance with all aspects of the Operational Quality Assurance Program and to assess its effectiveness. He is responsible for assuring that procedures are developed, in accordance with the requirements of this policy. to provide for both internal and external cudits. He is responsible for performance of audits to verify plant conformance to the Technical Specifications; audits of operational phase activities (includingLactivities of the Plant Quality Organization and Startup Organization); and audits of contractors and suppliers performing on-site and.

off-site activities. He shall also assure that audit results are documented and reported to appropriate management, and that prompt corrective action is taken to eliminate nonconformances detected during the course of audits.

18.4.2 The Safety Review Committee is responsible for independently reviewing the written reports of all audits of operating plant activities. The Plant Safety Review Committee also reviews such audit reports."

18.5 REQUIREMENTS 18.5.1 A comprehensive program of a planned and documented audits shall be established and implemented by the Quality Assurance Organization to verify compliance with all aspects ^of the Quality Assurance Program.

The audit program shall be carried out in accordance with written approved procedures which address the requiremen'. s of this policy.

18.5.2 The audit program shall provide for both internal and external audits. Internal audits shall include audits of the procedures and performance of all MP&L organizations whose activities affect the quality of safety-related structures, systems and components. External audits shall include audits of the practices, procedures and instructions of contractors and suppliers who provide safety-related material, equipment or services..."

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r "18.5.4 l Audit's of operating' plant activities shall include, as a minimum, those specified in-the Technical Specifications for the applicable nuclear generating. station.

18.5.5 Audits shall be performed by' trained,_

qualified personnel not having direct responsibilities in the areas being audited. -Qualification and training requirements for: auditors shall be-established and documented and records of auditor qualifications shall be maintained and kept current. Personnel selected for quality assurance audit assignments shall

-have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited."

In'recent cases (e.g. AP&L's'Arksnsas Nuclear One) the NRC required its QA organizations to perform audits, not the independent Review Committee. The, NRC QA Branch in Bethesda'has reviewed and accepted MP&L's method of addressing the audit criteria of Appendix B to 10CFR50, NRC Regulatory Guide 1.144'and ANSI N45.2.12.

NOTE: .It is suggested that the NRC reviewer questioning this proposed revision to the Technical Specifications contact Mr. Walter P. Haass or Mr. Jim Conway of the NRC QA Branch.

One of the generic clarifications approved by:the NRC QA Branch in Revision 2 to MPL-TOP-1A (6/1/81) was predicated on this type wording change in the Technical Specifications. Rejection of this wording should be discussed in detail with' the NRC QA Branch.

5. 6.5.2.10, Records. Changes in wording have been made for consistancy with the proposed changes in subsection 6.5.2.8.

COMMENTS: The wording of 6.5.2.8 subsection (1) and (j) has been changed for*gramatical and functional consistancy.

The Commission's addition of subsections (k), (1), (m) and (n) is acceptable to the applicant. Other minor revisions were-discussed with and found acceptable to the Licensee Qualifications Branch.

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Attachment'll 60 '

AECM-82/49-FSAR Resume No. 13 i

Name: Douglas L. Hunt-Birthdate: 1939 Formal Education and Training:

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High School - Graduate . .

Navy Machinist ~.A School - Great Lakes, Michigan,_1959 Navy Nuclear Power School, Mare Island, California, .1962 Navy A1W Prototype, Qualified Mechanical Reactor Operator,~1963 Navy. Submarine School, New London, Connecticut, 1964 Navy S5W- Reactor, Qualified Engineering Watch Supervisor, 1965-1969 Navy' Instructor Training Course, 1968

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S5W System Maintenance School, 1969 Navy Nuclear Welding and Non-Des. v5 - ive Examination Methods, -

Qualified Level II Navyship* 2 0-1500-1, 1970 Navy Quality Assurance Shipbuild .g Program, Electric' Boat, Groton, Connecticut, 1970-Auditor Training, Electric Boat,.t:oton, Connecticut,'1971 Light Water Breeder Reactor (LWBR) Technology, Duquesne Light Co.,

Shippingport, Pennsylvanic, 1974 GE BWR-6 Nuclear Technology - Engineer's Course, 1980

, Hinds Jr. College - 1978-1981; Night Classes -~44 Semester Hours

[ Experience:

1956 - 1977 United States Navy Aircraft Carrier and Fleet Oiler Duty, Machinist Mate 1

Nuclear Submarine Duty, Qualified all Engineering Watch j' Stations including Engin'eering Watch Supervisor.

! Naval Reactors Representative, (Warrant 0fficer) - Electric

! Boat Shipbuilding, Groton, Connecticut. Responsibilities i included performance of audits 'and surveillance of Electric l~ Boat Nuclear Quality . Assurance Program and assignment as Joint -

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. Test Group and Joint Refueling Group Member'for Naval Reactors l (overhaul and new construction submarines).

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F GG FSAR-Douglas L. Hunt - Continued Naval Reactors Representative, (Warrant Officer) - Electric

-Boat Shipbuilding, Groton, Connecticut. Responsibilities

( included performance of audits and surveillances of subcontractors performing modifications to accommodate light water breeder reactor conversion. Assisted Duquesne Light

Company in developing 10CFR50 QA Program (plant was previously.

under naval reactors QA). Was member of Joint Test Group and -

Joint Refueling. Group, 1974-1977.

1977 - Present Mississippi Power and Light Company Jackson, Mississippi l%intenance Planner at Grand Gulf Nuclear Station -

Coordinated efforts with subcontractor to begin preservice inspection. Established schedules, approved procedures and interfaced with authorized inrpector and QA to. establish baseline inspection techniques in accordance with ASME Section XI.

1 Assistant Maintenance Supervisor at Grand Gulf Nuclear Station -

Responsible fue supervision of production craf ts (mechanics, electricians and' instrumentation control) in Maintenance.

Directly involved in recruiting efforts to fill craft and l supervisor positions in maintenance. _ Also responsible for i establishing and outfitting maintenance shops, developing procedures and instructions for maintenance activities.

Nuclear Plant Quality Superintendent - Responsible for the review and monitoring of the on-site GGNS operations'QA program as well as the supervision, training and certification of Plant Quality Representatives and inspection personnel.

Also provided QA/QC guidance and. training to plant staff.

Reported directly to the Plant Manager.

Training and Administrative Superintendent at Grand Gulf-Nuclear Station - The Training and Administrative Superintendent is responsible for implementing the Grand Gulf l

Nuclear Station Training Program. The Training and Administrative Superintendent schedules all plant personnel P for training and retraining, directs and coordinates the plant training instructors, and maintains records of completed training. He reports to the Nuclear Support Manager for direction. The Training Supervisor, Simulator Supervisor, Administrative Supervisor, and Security Training Supervisor report to the Training and Administrative Superintendent.

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Attachment 12 GG AECM-82/49 FSAR Resume No. 6 Name: Ted H. Cloninger Birthdate: 1946 Formal Education and Training:

B.S. Mechanical Engineering, University of North Carolina at Charlotte, 1970 Bettis Atomic Power Laboratory; USAEC-Westinghouse Corp.-Reactor Engineering School - 1972 Experience:

1966 - 1970 Grinnell Corporation, Industrial Piping Division, Kernersville, North Carolina.

Piping Engineer - Work consisted of preparation of fabrication drawings for power piping systems, performance of thermal stress analysis calculations and preparation of cost estimates for power piping installations.

1970 - 1971 Duke Power Company, Charlotte, North Carolina Engineer - Work consisted of writing design reports for nuclear power plant fluid system designs, supervision of power

. piping system designs from a functional stress analysis and

, economic standpoint In addition prepared schedules for the above work to support the overall design schedule of oconee nuclear power plant.

'1971 - 1975 U. S. Atomic Energy Commission /U. S. Navy, Division of Naval Reactors, Washington, D.C.

Worked as a member of the staff for Admiral H. G. Rickover at the Division of Naval Reactors, duties:

i l Project and Managing Engineer - In this position involved in i design and development efforts related to the Light Water Breeder Reactor Project (LWBR). The LWBR Project is an effort to develop an alternative to the liquid metal fast breeder reactor concept.

Supervised engineers responsible for modifying the existing Shippingport Atomic Power Station to support the operation of the.first LWBR reactor core. ,

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GG FSAR Ted H. Cloninger - Continued Working within the overall LWBR Project, responsible for approval of contractor conceptual and detailed designs of new and modified fluid systems. Included in this position was responsibility for approval of equipment and piping material specifications.

1975 - 1979 Duke Power Company, Charlotte, North Carolina Mechanical Project Engineer - Mechanical Project Engineer overall responsible for all mechanical design and engineering activities for the William B. McGuire Nuclear Station including (1) overall project coordination and direction of design groups, (2) approval of all project design schedules, design manpower allocations, design budgets, etc., (3) review and approval of precurement evaluations, design software,.

etc., (4) preparation of periodic reports both written and verbal for management, (5) directing field engineering activities of the Mechanical Design Department as required to solve erection problems identified by Construction Department, (6) funct'ioning as the focal point'for all contacts with-outside suppliers, consultants, etc. as necessary to resolve major problems affecting the Project, and (7) serving as a member of the Joint Startup Group comprised of seven key persons from each of the company's major. depart-ments with responsibility for managing the startup ef Unit No. I of the M.Guire Station.

Project Manager for Mechanical Equipment Procurement -

Managing a team of engineers responsible for specification preparation, bid evaluation and order placement of all capital equipment for the Catawba Nuclear Station including communications with many large equipment suppliers in the United States using a " face-to-face" approach to the l

resolution of design and scheduling problems.

1979 - Present Mississippi Power and Light Company Jackson, Mississippi Manager, Nuclear Plant Engineering - Reporting to the Vice

President - Nuclear Production, had overall corporate responsibility for engineering activities related to the l operation of the Grand Gulf Nuclear Station. In carrying out

! these responsibilities, managed an in-house staff of 30

engineers with multi-disciplined backgrounds. Also responsible for direct C31m

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GG FEAR Ted H. Cloninger - Continued management of the Project Architect-Engineer's engineering staff as well as the NSSS supplier's engineering staff.

Manager of Project Engineering - The Nuclear Project Engineer was responsible for all project engineering coordination, for-engineering interfaces between the Site Management staff, Nuclear Production staff, and other Project organizations as required, the review of A-E/ Contractor Procurement,

. maintaining the GGNS Q-List, and processing nuclear steam supplier invoices.

Assistant Site Manager - Reports to Site Manager on design and construction activities, coordinates activities of Construction Manager and Project Engineering staff.

Professional Membership:

Registered Professional Engineer h

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r- 7 Attachmint 13

.gg AECM-82/49 FSAR Resume No.

Name: Curtley Curtis Hayes, Jr.

Birthdate: 1952 Formal Education and Training:

B.S. Industrial Technology, Mississippi State _ University, 1974 Intro. to Section III -V & XI, ASME Code, 1977 Basic Principles of Nondestructive Testing, Rockwell International, 1977' BWR/6 Design and Fundamentals, Cencral Electric, 1978 Auditor Training, Bechtel, 1978 GE BWR/6 Grand Gulf Technology, 1978 MP&L Plant Quality Training, 1978 Middle South Services Lead Auditor Training, 1979 Grand Gulf Nulcear Station Blueprint Reading, 1980 Leadership Supervisory Training, MP&L 1980 Deficiency Screening Training, MP&L, 1980

-Statistical Quality Control, 1978 Experience:

1974 - 1977 , Chicago Bridge & Iron Nuclear Co.

Quality Control Inspector'- Certified in accordance with ANSI N45.2.6-1973 as a Level II inspector. Responsibilities included maintaining dimensional control through designated dimensional-examination of fabricated pieces, assembly fitups and overall nuclear reactor pressure vessel dimensions including the proper documentation of each inspection. Obtained training in nondestruc-tive testing and inspections, basic welding' techniques and principles of Quality Assurance. Utilized optical equipment including jig transit, tilting level, builders level, thcotolite and plumb aligner; mechanical measuring equipment including inside micrometer, outside ,

micrometer, vernier, vernier angle gauge, depth micrometers and tape measures.

1977 - Present: Mississippi-Power & Light Co., Jackson, Mississippi 1977-1980 Sr. Plant Quality Representative - Certified as Level II Quality Inspector in accordance with ANSI N45.2.6-1973. Certified as Sr. Quality Assurance Engineer in accordance with plant proce-dures. Responsibilities included monitoring and review of Grand Gulf Nuclear Station plant activities, procedures and work functions for conformance to Operational QA program. Handled and controlled QA records; prepared quality procedures, instructions, program-reviews and reports. Participated in the training and indoctrination of plant staff personnel in the requirements of the OPS QA Program.

Additional responsibilities included receipt inspection of nuclear spare parts and components; trend analysis of deficiencies; and review of vendor contracts and site procurement documents. Assisted in development of plant procurement procedure and the computerized Requirements Procedures Tracking System (RPTS).

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f l GG FSAR 1980-1982 Startup Test Supervisor - Responsibilities included preparation of preoperational and acceptance test procedures utiliz-ing drawings, technical specifications, and vendor manuals; super-vision of startup testing in accordance with written procedures and within the guidelines of the Grand Gulf Startup Manual. Additional responsibilities include review and acceptance of system turnover packages and supervision of craf t personnel performing maintenance on startup controlled systems.

1982-Pressent Nuclear Plant Quality Superintendent - Responsible for the rev4.ew and monitoring of the GGNS onsite operational QA program as well as the supervision, training, certification of Plant Quality Representatives and inspection personnel. Also provided QA/QC guidance and training to plant staff personnel. Reports directly to the plant manager.

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