AECM-87-0148, Forwards Response to Violations Noted in Insp Rept 50-416/87-14.Corrective Actions:Test Procedure 06-OP-1C41-M-0001 Revised & Standby Liquid Control a & B Tested Successfully on 870616 & 17,respectively

Forwards Response to Violations Noted in Insp Rept 50-416/87-14.Corrective Actions:Test Procedure 06-OP-1C41-M-0001 Revised & Standby Liquid Control a & B Tested Successfully on 870616 & 17,respectively

ML20236H889
Person / Time
Site:	Grand Gulf
Issue date:	07/31/1987
From:	Kingsley O SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
AECM-87-0148, AECM-87-148, NUDOCS 8708050379
Download: ML20236H889 (3)

Text

, .,

.l 1

EVETEM ENERGY RESOUNCEE, INC.

OtM9 D Kmst.Ev. JR EINY$1cns July 31, 1987 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk

, Gentlemen:

SUBJECT:

~ Grand Gulf Nuclear Station Unit l' Docket No. 50-416 License No. NPF-29 Report No. 50-416/87-14 dated July 1, 1987 (MAEC-87/0160)

AECM-87/0148 l System E;ergy Resources, Inc. hereby submits response to violation j 50-416/87-14 03.

Yours t ly,  !

t ODK:mbl ' -

Attachment cc: Mr. T. H. Cloninger (w/a)

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

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

Mr. H. L. Thomas (w/o)

Mr. R. C. Butcher (w/a)

Dr. J. Nelson Grace, Regional Administrator (w/a)

U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner, Project Manager (w/a)

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission l 7920 Norfolk Avenue Bethesda, Maryland 20814 6

hh ADO 0 }

J18AECM87072701 - I e a oorn { arm wrem acsrm l <sowvue w me so,. um cw,s . /[o

, [

l

]

i Notice of Violation 50-416/87-14-03 )

The Technical Specification 6.8.1.c requires that written procedures shall be established,_ implemented and maintained covering surveillance and test activities of safety related  !

equipment.

Contrary to the above, in June 1987 surveillance procedure 06-0P-1C41-M-0001, Standby Liquid Control System Operability, was j inadequate as evidenced by unsuccessful implementation, I unnecessary lifting of a protective relief valve, test tank overflow, and difficulties experienced by the' operator to follow the procedure.

I. Admission Or Denial Of The Alleged Violation l-System Energy Resources, Inc. (SERI) admits to the alleged violation. This violation had no affect on the health and safety of the public. i II. The Reason For The Violation If Admitted It should be noted that the SLC system is a difficult system to test, due to hydraulic pulsations from the positive displacement {

l pump. However, this particular situation occurred'due to: i l

A. Although test procedure 06-0P-1C41-M-0001 was adequate to verify technical specification requirements, this specific test procedure did not provide the operator with adequate procedural guidance at the time this observation was made.

B. There was a lack of sufficient management oversight as evidenced by the degree of specific management attention necessary to resolve this concern and the lack of adequate pre-job planning.

l C. The operator performing the test misunderstood the procedure and failed to discuss this with the Shift Superintendent.

I l D. The Shift Superintendent and the operator did not fully understand the concept of " verbatim compliance."

III. The Corrective Actions Which Have Been Taken And The Results Achieved A. Following the June 10 performance of 06-0P-1C41-M-001, the procedure was revised and on June 15, 1987, SLC "A" was successfully tested followed by a successful test of SLC "B" on June 16, 1987.

I l

l J12 MISC 87073101 - 2 1

m

B. The General Manager directed each Plant Staff manager to begin a self-monitoring program to improve procedural adherence and heighten management oversight concerning surveillance testing. Supervisors are now required to perform monitorings of selected surveillance and to document their findings. In particular, the SLC system surveillance are now monitored by Operations management. This program is now implemented and its progress is being tracked.

Additionally, each superintendent has reviewed this incident in meetings with his people.

C&D. Management's position on verbatim compliance has been clarified. This clarification has been impressed on those involved with the violation as well as other Plant Staff personnel involved in the performance surveillance procedures.

Included in this clarification was a discussion of step-by-step procedural adherence and expected personnel actions to be taken in cases where clarification is needed. This has been documented to the General Manager and will strengthen SERI's ability to more closely follow procedures step-by-step and with verbatim compliance.

IV. The Corrective Steps Which Will Be Taken To Avoid Further Violation SERI considers the action in 3 above sufficient to prevent further violation.

V. Date When Full Compliance Will Be Achieved Full compliance has been achieved.

J12 MISC 87073101 - 3