IR 05000416/1996013
| ML20128M721 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/09/1996 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9610160166 | |
| Download: ML20128M721 (5) | |
Text
' e
g A' " %i UNIT E D STATES
.
J,
. It NUCLEAR REGULATORY COMMISSION
$
,/
j REGloN lv g
[lgr,A
t g
i S
- ' 'F 611 RY AN PL AZA DRIVE. SulTE 400
- t9.....f
ARLINGTON TEXAS 76011 8064 OCT 9 1996 C. R. Hutchinson, Vice President Operations - Grand Gulf Entergy Operations, Inc.
P.O. Box 756 Port Gibson, Mississippi 39150
SUBJECT: NRC INSPECTION REPORT 50-416/96-13 Thank you for your letter of September 26,1996,in response to our letter and Notice of Violation dated August 28,1996. We have reviewed your reply and find it s
responsive to the concerns raised in our Notice of Violation. We will review the i
implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely,
'
J
,
h J. E. Dyer, Director i
Division of Reactor Projects Docket No. 50-416 License No. NPF-29 cc:
Executive Vice President and Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 Winston & Strawn 1400 L Street, N.W. - 12th Floor Washington, D.C. 20005-3502 9610160166 961009 PDR ADOCK 05000416 G
PDit
_...
._-......
_ _ _ _ __ _._ _.. _.. _ _. _...- _ -..._._ _ ~ _ _ _ _ _ _ _ _ _ _. -
-...
.
.
Entergy Operations, Inc.
-2-Sam Mabry, Director Division of Solid Waste Management Mississippi Department of Natural Resources P.O. Box 10385 Jackson, Mississippi 39209 I
President Claiborne County Board of Supervisors Port Gibson, Mississippi 39150 Mr. Rod Rogers 68-7 Bechtel Power Corporation Nuclear Operating Plant Services
,
9801 Washington Boulevard Gaithersburg, Maryland 20878-5356 General Manager Grand Gulf Nuclear Station Entergy Operations, Inc.
P.O. Box 756 i
Port Gibson, Mississippi 39150 The Honorable William J. Guste, Jr.
I Attorney General j
Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005 l
Office of the Governor State of Mississippi Jackson, Mississippi 39201 Mike Moore, Attorney General i
Frank Spencer, Asst. Attorney General State of Mississippi P.O. Box 22947
.
'
I Jackson, Mississippi 39225
i Dr. F. E. Thompson, Jr.
State Health Officer
State Board of Health
P.O. Box 1700 l-Jackson, Mississippi 39205 i
$
.
y
-
_
,
-
..
.
O Entergy Operations, Inc.
-3-Eddie S. Fuente, Director State Liaison Officer
Division of Radiation Health Mississippi Department of Health P.O. Box 1700 -
Jackson, Mississippi 39215-1700 Vice President Operations Support I:atergy Operations, Inc.
F.O. Box 31995 Jackson, Mississippi 39286-1995 i
Director, Nuclear Safety
'
and Regulatory Affairs Entergy Operations, Inc.
P.O. Box 756 Port Gibson, Mississippi 39150 Vice President, Operations Grand Gulf Nuclear Station Entergy Operations, Inc.
P.O. Box 756 Port Gibson, Mississippi 39150 i
i
.,, _ _
,
_,..,
,
_
_...
.
__
__ _
_ _. _. _.
_
_. _ _ - _. _ _ _.._. _ _._ ___. _
t
,,
p
i OCT 9 1996
'
,
Entergy Operations, Inc.
-4-t
,
i
-
MiF...._ --DMB (IE01) - --
j bec distrib. by RIV:
I i
'
}
L. J. Callan Senior Resident inspector (River Bend)
!
)
DRP Director DRS-PSB i
!l Branch Chief (DRP/D)
MIS System Project Engineer (DRP/D)
RIV File
,
l Branch Chief (DRP/TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
!
Resident inspector (Grand Gulf)
?
!
,
4 i
!
!,
'
i i
-
!
I
i
5 i
<
!
i t
i
i e
l DOCUMENT NAME: R:\\_GG\\GG613AK. JET
]
To receive copy of document, indicate in box: "C" = Copy without enclosures E" = Copy with enclosures "N" = No copy PE:DRP/D C:DRP/D
,g D:DRP
-
mp l
GAPick;cm@(
PHHgggf,Q JEDyerf l
j 10 4/96 10/$$6A 10A /96
,
j
'
OFFICIAL RECORD COPY
)
!
'\\
!
160917
...
_
_
_
..
... _ _. _.
_.. _ - _
_
_. _._ _ _
__. __.. _.
. _.-. _ - _. -
_
l
-
'
,
OCT 9 1996 Entergy Operatior', Inc.
-4-l
,
bec to DMB (IE01)
i bec distrib. by RIV:
.
L. J. Callan Senior Resident inspector (River Bend)
l DRP Director DRS-PSB l
Branch Chief (DRP/D)
MIS System
'
Project Engineer (DRP/D)
RIV File
Branch Chief (DRP/TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
i Resident inspector (Grand Gulf)
l
!
i
!
!
i i
,
i
!
!
.
,
.
!
i
!
l DOCUMENT NAME: R:\\ GG\\GG613AK. JET l
To receive copy of document. Indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures "N" = No copy PE:DRP/D C:DRP/D
,g D:DRP mp
.
i GAPick;cm@(
PHHgggy.I,Q JEDyerf l
104/96 10/$$6A 10Ay /96
'
OFFICIAL RECORD COPY
!
.;
r
'.
c_c Ente,gy e ~ u o-
.i~.
Operations
.
~~'
_
_.
_. _. _
._
_;
September 26, 199t'
U.S. Nuclear Regulatory Commission
\\
Mail Station P1-37 i
Washington. D.C, 20555 g
Attention:
Document Control Desk Subject:
Grand Gulf Nuclear Station
Docket No. 50-416 License No. NPF-29
'
Reply To A Notice Of Violation Failure to Follow Procedure for Performance of a Local Leak Rate Test on Containment Penetration Number 65
'
l Ref erenee: NRC Inspectioa Report No. 50-416/96 13 (Item M1.3), dated August 28,1996
,
,
GNRO 96/OO110 Gentlemen:
Entergy Operations, Inc. hereby submits the response to Notice of Violation 50-416/96-13-01.
t Yo rs tr
.
t A
Jose
.Hagan Vi esident, Operdfions Grand Gulf Nuclear Station
'
JJH/CEB
,
attachment
}
cc:
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. J. E. Tedrow (w/a)
Mr. J. W. Yelverton (w/a)
Mr. Leonard J. Callan (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan plaza Drive Suite 400 Arlington, 'tX 76011
Mr. J. N. Donohew (w/a)
'
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3
,
Washington, D.C.
t
'
ct~T-G O O 3 ai,, n m,, o in (
V I JV
%Wi V "
-
- _ --_.
-
_
.
--
.
-
- _ _ _ _ -
,
-
,
,
Attachm:;nt I to GNRO-96/00110 Pag 31 cf 3
,
,-
Notice of Violation 96-13-01 I
i During an NRC inspection conducted from July 7 through August 17,1996 at the Grand Gulf Nuclear Station, one violation of NRC requirements was identified. In accordance with the
'
" General Statement of Policy and Procedure for NRC Enforcement Actions" NUREG-1600, the violation is listed below:
Technical Specification 5.4.1.a states, in part, that written procedures shall b6
implemented covering the applicable activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
j
I Paragraph 8 of Appendix A to Regulatory Guide 1.33 recommends procedures for
penetration leak rate tests.
Procedure 06-ME-lM61-V-0001, " Local Leak Rate Test," Revision 103 states that Valve TV-14 be opened and later checked open to pressurize the penetration being tested. This i
step is to be accomplished before obtaining test data.
i Contrary to the above:
1.
On July 24,1996, procedure 06-ME-lM61-V-0001 was not properly implemented during a test of containment penetration Number 65, in that personnel did not open
Valve TV-14 prior to obtaining test data. Failure to properly implement the procedure resulted in improper performance of the local leak rate test (LLRT) for the penetration being tested.
I.
Admission or Denial of the Alleged Violation Enteigy Operations, Inc. admits to this violation.
II.
The Reason for the Violation,if Admitted 1.
The root cause of the failure to properly implement Procedure 06-ME-lM61-V-0001, which manifested itself in the improper performance of the LLRT on Containment Penetration Number 65, was determined to be an inadequate procedure. The specific inadequate elements of the procedure and their adverse impact during performance of the LLRT on Containment Penetration Number 65 were determined by the root cause analysis to be; 1) multiple actions per procedural step, and 2) excessive details within the procedure that are not applicable to the performance of the test being performed.
A contributing cause of this event was less than adequate communication by the maintenance technicians. Interviews with the maintenance technicians performing the test indicate that three way communication was not utilized at all times during the performance of the test evolution.
However, the expectations of three way communications with one individual reading the procedure and another individual executing the procedure steps were not clearly understood by the personnel performing the tes _ - - -. - - -. -
!.
,
Attachm:nt I to GNRO 96/00110 Pags 2 of 3
'
Additional contributing causes of this incident were the absence of a place keeping i,
mechanism within the procedure to verify completion of each step when performed and lack of concise labeling of the test panel valves to be manipulated. The work pack utilized by maintenance technicians only contain the applicable data collection sheets.
The standard practice is to obtain a controlled copy of the required procedure instructions from records storage. Upon completion of the respective task, the controlled copy of t procedure is returned to records storage. Since any field notes or markings made on the procedure during performance of the task would degrade the procedure's usefulness, no place keeping methodology was utilized. Additionally, lack of procedure place keep was further exasperated by inadequate valve labeling which required the maintenance technicians to flip back and forth between the procedure's instructions and a reference drawing within the procedure to facilitate identification of valves to be manipulated.
GGNS agrees with the findings of the inspection report, in that Procedure 06-ME-lM61-V-0001 was improperly implemented during performance of the LLRT on Containment Penetration Number 65. However, the inspection report also notes that the inspector believed that the test would not have been successfully completed without the inspect prompting. We disagree with this conclusion. As noted in the inspection report, the test was in progress when the inspector pointed out to test personnel that the test valve was closed. We believe that test personnel, as pan of the test restoration process, would have identified that the test valve was closed and re-performed the test.
III.
Corrective Steps Which Have Been Taken and Results Achieved 1.
Immediate corrective actions were:
The mechanical maintenance technicians received a written reprimand for failure
.
to observe established practices for self verification of work activities.
The LLRT test rig was upgraded by installation of proper permanent labeling.
- QDR 96-0183 was generated to document the event and to initiate corrective
.
actions, and Mechanical Maintenance Procedure 06-ME-lM61-V-0001 was revised to clarify
.
the specific steps that were improperly implemented.
Interim corrective actions planned are:
Provide QDR 96-0183 to mechanical maintenance personnel via the Required
.
Reading Program to heighten awareness to this event.
Provide contracted mechanical ma'ntenance personnel which will be performing
.
LLRTs with traming to ensure their competency and proficiency in performing LLRTs in accordance with the GGNS maintenance program requirements.
Review all additional LLRT test panels to identify and install appropriate labeling
.
to ensure valves are clearly identified.
.
.
.
,
s Attachm:nt I t3 GNltO 96/00110 Paga 3 cf 3
.
.
IV.
Corrective Steps to be Taken to Preclude Further Violations 1.
Long term corrective actions are:
The surveillance test procedure, 06-ME-1M61-V-0001 " Local Leak Rate Test",
.
will be further enhanced to separate multiple actions within a single step to facilitate human factors.
A method and expectation for procedure place keeping will be developed and
.
communicated to mechanical maintenance personnel.
Expectations for the use of three way communication will be developed and re-
.
enforced to all mechanical maintenance personnel.
Review all additional LLRT test panels to identify and install appropriate labeling j
e to ensure valves are clearly identified.
V.
Date When Full Compliance Will be Achieved As outlined above, the corrective actions to rectify the fimdings of this inspection report are being implemented through a phased in approach, thus allowing sufficient time for a comprehensive
'
response to the root causes of this event. The immediate corrective actions are complete. The above interim corrective actions will be completed by October 18,1996, prior to commencement of the 8th refueling outage. All of the above corrective actions, including the long-term corrective j
actions, shall be completed by June 30,1997.
i
,
l j