05000416/LER-1996-002, Forwards LER 96-002-00 Re Routine Maint Rendering HPCS EDG Inoperable

Forwards LER 96-002-00 Re Routine Maint Rendering HPCS EDG Inoperable

ML20100M616
Person / Time
Site:	Grand Gulf
Issue date:	02/26/1996
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20100M619	List: 05000416/LER-1996-002, Forwards LER 96-002-00 Re Routine Maint Rendering HPCS EDG Inoperable 05000416/LER-1996-002-02, :on 960126,routine Maint Rendered HPCS EDG Inoperable Due to Leak from Lube Oil Strainer.Personnel Counseled & Strainer Tighten
References
GNRO-96-00017, GNRO-96-17, NUDOCS 9603050437
Download: ML20100M616 (2)

LER-1996-002, Forwards LER 96-002-00 Re Routine Maint Rendering HPCS EDG Inoperable

Event date:
Report date:
4161996002R00 - NRC Website

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j Port Gnmn MS 39150 Ts C01437 2800 C. R. Hutchinson l

wrwa aw,m VWl3 0.04 Of.'enF dff y h February 26,1996 U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. 20555 Attention:

Document Control Desk l

SUBJECT:

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 l

Licesnse No. NPF-29 l

Vcluntary Report / Routine Maintenance Renders High Pressure Core Spray EDG Inoperable l

LER 96-002-00 l

I GNRO-96/00017

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i Gentlemen:

- q Attached is Licensee Event Report (LER)96-002 which is a Voluntary Report. In the course l

of preparing this LER, several discussions were held with your staff concerning 10 CFR 50.72 and 50.73 reporting requirements. Our view on reportability is discussed below.

i The Emergency Dicsel Generator (EDG) associated with the High Pressure Core Spray (HPCS) system is unique in that the Technical Specifications (TS 3.8.1 note) provide flexibility to l

administratively declare the HPCS system inoperable if the HPCS EDG is inoperable. Once l

having administratively declared the HPCS system inoperable, operability of the HPCS EDG is no longer necessary, and additional time is availabic to restore the HPCS EDG to an operable status.

This flexibility (which is present in the improved Technical Specifications and was more explicitly stated in the previous Grand Gulf Technical Specifications) raises an interesting l

question concerning reportability under 10CFR50.72/73. Although the HPCS system has been administratively declared inoperable for purposes of compliance with TS 3.8.1, the ability of the system to perform its safety function remains intact. Furthermore, the HPCS system continues to meet the Technical Specification definition of operability:

"A system, subsystem, division, component, device shall be OPERABLE or have OPERABILITY when it is r,apable of performing its specified safety function (s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function (s) are also capable of performing their related support function (s) "

9603050437 960226 ok3 PDR ADOCK 05000416:

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February 26,1996 GNRO-96/00017 Page 2 of 3 In applying this definition to the HPCS system which is declared inoperable for adminimistrative purposes, it is necessary to look at the functioning of the HPCS system itself and the relevant support systems, in this case the electrical power systems for HPCS.

As noted above, the HPCS system remains capable of performing its safety function. The HPCS EDG is inoperable and therefore cannot fulfillits supporting role. However, the

" normal" electrical power system is available for HPCS. Consequently, the HPCS system meets the definition of " operable".

In this situation, when the HPCS system has been administratively declared inoperable for purposes of TS 3.8.1, it does not constitute a failure (i.e., available to perform its safety function) with respect to reportability requirements. Consequently, we do not believe that suc a condition meets the conditions for reportability under 10CFR50.72/73.

Yo re t uly, m

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i tachment cc:

Mr. J. E. Tedrow (w/a)

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

Mr. N. S. Reynolds (w/a)

Mr. J. W. Yelverton (w/a) l Mr. Leonard J. Callan (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission Region IV i

611 Ryan Plaza Drive Suite 400 l

1 Arlington, TX 76011 Mr. Paul W. Donohew Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 i