GNRO-2008/00073, Reply to Notice of Violation EA-98-295

Reply to Notice of Violation EA-98-295

ML083181213
Person / Time
Site:	Grand Gulf
Issue date:	11/13/2008
From:	Krupa M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-98-295, GNRO-2008/00073, IR-08-004
Download: ML083181213 (5)

Text

,.Entergy

'C-~

Entergy Operations, Inc.

7003 Bald Hill Fjoad PO. Box 756 Port Git)SOIl, MS 39150 Tel 601 A37 669A Michael A. Krupa Director Nuclear Safety Assurance GNRO-2008/00073 November 13,2008 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Document Control Desk

Subject:

Reply to Notice of Violation EA-98-295 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Reference:

GNRI-2008/00092, NRC Integrated Inspection Report Dated 10/17/08

Dear Sir or Madam:

Entergy Operations, Inc. (EOI) hereby submits the Reply to Notice of Violation EA 295 for Grand Gulf Nuclear Station. This Notice of Violation was issued in NRC Inspection Report 05000416/2008004. The inspection was conducted during the period of June 22 through September 20, 2008. EOI concurs that the overall findings of the inspection are valid in that the specific example identified is indicative of failure to follow established station procedures.

Should you have any questions or require clarification of our response, please contact this office at 601-437-6219.

Yours truly, MAKlJEO:jeo attachment: Response to Notice of Violation; EA-08-295

GNRO-2008/00073 Page 2 cc: NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

u. S. Nuclear Regulatory Commission ATTN: Mr. Elmo E. Collins, Jr. (w/2)

Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 u.S. Nuclear Regulatory Commission ATTN: Mr. Carl F. Lyon, NRRlADRO/DORL (w/2)

ATTN: ADDRESSEE ONLY ATTN: U.S. Postal Delivery Address Only Mail Stop OWFN/8 81 Washington, D.C. 20555-0001

ATIACHMENT1 RESPONSE TO NOTICE OF VIOLATION EA-OS-295 GNRO-2008/00073

Attachment to GNRO-2008/00073 Page 1 of 2 RESPONSE TO NOTICE OF VIOLATION I. Cited Violation During an NRC inspection conducted on June 22 through September 20, 2008, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings," states in part, that activities affecting quality shall be accomplished in accordance with prescribed procedures.

Contrary to this requirement, from March 16 through July 9, 2008, the licensee failed to accomplish an activity affecting quality in accordance with prescribed procedures.

Specifically, the licensee failed to perform an adequate inspection of probable maximum precipitation door seals protecting safety-related equipment as prescribed in Procedure 07-S-14-310, "Inspection of Mechanical Seals on Doors," revision 5.

This violation is associated with a Green SDP finding.

II. The Reason for the Violation Entergy admits to the violation as described in the inspection report. Specifically, "the licensee failed to accomplish an activity affecting quality in accordance with prescribed procedures." This violation was the result of personnel failure to follow plant procedure 07-S-14-310, "Inspection of Mechanical Seals on Doors".

III. Corrective Steps Which Have Been Taken and Results Achieved Appropriate actions were taken to address the inadequate performance of the inspection for the individual involved. Additionally, during a shop brief, expectations for properly following procedures, with particular emphasis on inspection of PMP door seals, was covered with all personnel who may perform this work.

Compensatory measures for deficient PMP door seals specified in plant procedure 07-S-14-310, "Inspection of Mechanical Seals on Doors," were implemented.

Implementation of the compensatory actions brought GGNS back into procedural compliance on July 09, 2008.

As a result of this violation seal inspection frequency was evaluated and determined to be a possible contributing factor. To address this possible contributing factor the inspection frequency was changed from yearly to quarterly. This change was recently implemented and therefore sufficient data is not yet available to validate the acceptability of this change.

Attachment to GNRO-2008/00073 Page 2 of 2 IV. Corrective Steps to be Taken to Preclude Further Violations As stated previously, the inspection frequency was changed therefore going forward PMP door seals will be inspected on a quarterly basis rather than yearly.

V. Date When Full Compliance Will be Achieved Entergy returned to full compliance with the procedure by reestablishing the compensatory actions on July 9, 2008.