IR 05000416/1997003
| ML20141F721 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/26/1997 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hagan J ENTERGY OPERATIONS, INC. |
| References | |
| 50-416-97-03, 50-416-97-3, NUDOCS 9707030148 | |
| Download: ML20141F721 (6) | |
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SUBJECT:
NRC INSPECTION REPORT 50-416/97-03 ~
Dear Mr. Hagan:
Thank you for your letters (GNRO-97/00045 and GNRO-97/00049) of May 22,1997, in response to our letter and Notice of Violation dated April 24,1997. We have reviewed your replies and find them responsive to the concerns raised in our Notice of Violation.
in the response to Violation 50-416/9703-01, you stated: "The NOV presented the reason for the violation as personnel wanting to start their long weekend, therefore delaying initiating a CR until the following Monday. This incorrect conclusion resulted from miscommunication during a meeting between NRC inspectors and involved personnel. This has been discussed and clarified with the inspectors. Additionally, in a discussion with Mr. Pat Gwynn, Director, Division of Reactor Safety [ sic), we were advised to request a review of the miscommunication issue. As such, this review is requested." Also, in disensions with your staff, your staff identified that the conclusions provided in the cover letto. did not completely reflect the inspection report conclusions.
Regional management has performed the requested review, which included discussions with the inspectors who performed the inspection. A discussion was also held with the inspectors regarding the clarification that was provided by Grand Gulf personnel with respect to miscommunications that may have occurred. During this discussion, the inspectors stated that the issued inspection report accurately reflects the results. These ! results were discussed with K. Hughey, Director, Nuclear Safety, and D. Bost, Director, Design Engineering, of your staff on June 25,1997, to confirm the accuracy of the inspection report.
Based on review, we have determined that the inspection report accurately describes the results of the inspection; consequently, no changes will be made to the published report.
We acknowledge that the cover letter did not completely reflect the conclusions of the report related to this matter.
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We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincer ,
- , . ' omas P. Gwyn, D' ect r Division of React oje ts Docket No.: 50-416 License No.: NPF-29 cc: Executive Vice Fresident 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 Sam Mabry, Director Division of Solid Waste Management Mississippi Department of Natural Resources P.O. Box 10385 Jackson, Mississippi 39209 President Claiborne County Board of Supervisors Port Gibson, Mississippi 39150 Manager of Operations Bechtel Power Corporation P.O. Box 2166 ! ! Houston, Texas 77252-2166 i - -
- I l- . . Entergy Operations, Inc.
-3-General Manager Grand Gulf Nuclear Station Entergy Operations, Inc.
P.O. Box 756 , Port Gibson, Mississippi 39150 The Honorable William J. Guste, Jr.
, Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005 Office of the Governor State of Mississippi Jackson, Mississippi 39201 Mike Moore, Attorney General Frank Spencer, Asst. Attorney General State of Mississippi P.O. Box 22947 Jackson, Mississippi 39225 Dr. F. E. Thompson, Jr.
State Health Officer State Board of Health P.O. Box 1700 Jackson, Mississippi 39205 Eddie S. Fuente, Director State Llaison Officer Division of Radiation Health Mississippi Department of Health P.O. Box 1700 Jackson, Mississippi 39215-1700 Vice President Operations Support Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 ! ! ! _ _
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-4- . Director, Nuclear Safety . and Regulatory Affairs l Entergy Operations, Inc.
.j - P.O. Box 756 Port Gibson, Mississippi 39150 ,
Vice Fresident, Operations . Grand Gulf Nuclear Station Entergy Operations, Inc.
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DOCUMENT NAME: R:\\_GG\\GG703AK.KDW To receive copy of document, indicate in box: "C" = Copy withe.ut enclosures "E" = Copy with enclosures "N" = No copy D:DRP l fj _ l l RIV:PE:DRP/D C:DRRD f ! GAPick;dfM PHH$rMj) TPGwynn [[7 l 6A15/97 6/g/j@y 6g97 ' 1 " O EFIClAL RECORD COPY j r l l
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, - PO Box 756 l Ih ~~~~ ! Port G.bson MS 3915o Tei 601437 6408 f, Fax 601437 2795 __ ..., ~ l' Joseph ' Sce F es dent operanons May 22, 1997
I orano owear stanen .- ' .. j I i U.S. Nuclear Regulatory Commission Mail Station P137 Washington, D.C. 20555 Attention: Document Control Desk Subject: Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Response to Notice of Violation 50-416/97-03-01 Failure to Follow Procedure Report No. 50-416/97-03, dated 04/24/97, (GNRI-97/00C58) GNRO-97/00045 Gentlemen: Notice of Violation (NOV) 50-416/97-03-01 cited Grand Gulf Nuclear Station (GGNS) for failure to follow procedure in that steps contained in GGNS administrative procedure to initiate a condition report (CR) upon discovery of a deficiency were not timely.
The NOV presented the reason for the violation as personnel wanting to start their long weekend, therefore delaying initiating a CR until the following Monday. This incorrect conclusion resulted from a miscommunication during a meeting between NRC inspectors and involved personnel. This has been discussed and clanfied with the inspectors. Additionally, in a discussion with Mr. Pat Gwynn, Director, Division of Reactor Safety, we were advised to request a review of the miscommuniccoon issue. As such, this review is requested.
There were other complicating factors that led to this violation. The fact that the condition in question had been previously identified in deficiency documents as a generic issue, gave personnel the false assurance that operability had already been addressed. Additionally, the concepts of immediately and promptly are more easily defined and applied to new items of discovery and there was a general feeling that this was not a new item due to the previous history. GGNS recognizes the importance of rigorously following the non-conformance process and that required reviews may not be bypassed. As such, actions are being taken to ensure all personnel are fully aware of the procedural requirements and expectations in this area.
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t ' May 22, 1997 GNRO-97/00045 Page 2 of 2 J
l GGNS acknowledges that initiating the CR upon discovery of the condition would have prevented the circumstances which Pd to this violation Therefore. GGNS admits to this violation and the attachment to this lette :ontains the GGNS response to NOV 50-416/97-03-01.
Yours truly, Ek/s L+ uyaa.
v - JJH/JEO/jeo attachment Response to Notice of Violation 50-416/97-03-01 cc: Mr. L. J. Smith (Wise Carter) (w/a) Mr. N. 5. Reynolds (w/a) Ms. K. D. Weaver (NRC Resident) (w/a) Mr. J. W. Yelverton (w/a) l Mr. Ellis W. erschott (w/a) Regional Adrrinistrator Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)(w/a) Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 > i
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s.. ~ - -. - . . - - -. ~-- - .., - . ... .- . l* . . i-i r l-. ! Attachment to GNRO-97/00045 ! Page 1 of 2 ' Notice of Violation 97-03-01 Technical Specification 5,4.1.a. states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operations)," Revision 2, February 1978.
- Item 1 of Appendix A to Regulatory Guide 1.33 recommends administrative procedures covering safety-related activities.
, ' Administrative Procedure 01-S-03-10 "GGNS Condition' Report (CR)," Revision 0, Paragraph 6.1.1 stated, in part, that any individual or organization at Grand Gulf Nuclear Station shall initiate a condition report wt.enever a non-conformance, material non-conformance, or potential reporuble event is discovered.
Contrary to the above, on February 27,1997, a design engineer failed to implement the requirements of Procedure 01-S-03-10 in that a non-conformance was identified in the leak testing of the containment isolation valves associated with the residud heat removal system test retum piping to the suppression pool and a condition report was initiated four days later, not when the non-conformance was identified.
This is a Severity Level IV violation (Supplement 1) (50416/9703-01).
, I, The Reason for the Violation,if Admitted On March 3,1997 a Condition Report (CR) was initiated to address Design Engineering concems with the method for leak rate testing certain , containment penetrations. Notice of Violation (NOV) 50-416/97-03-01 was ' issued when the NRC Resident inspector was informed by the initiating design engineer that the condition was identified on, February 27,1997.
This was four days prior to initiation of a CR. The delay in initiating the CR did not allow Operations to perform a timely operability review.
Investigation determined that policy guidance / management expectations were not well defined or understood. Plant administrative procedure specifies that v. CR be written whenever a deficiency is discovered. The importance of' timely initiation of a CR was missed by persons involved in this event.
Persons involved did not recognize the need for initiating a CR right away -
due to the fact that containment penetrations had been addressed earlier as l_ part of a generic issue. Discussion held at the time of the decision to delay ' the CR concluded that no new operability concem was raised by the containment penetrations in question.
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. -. - . . - _ -. ? .: , , ..- I* l r L Attachment to GNRO-97/00045 ' ' Page 2 of 2 i Initiating a CR upon discovery of this condition, in accordance with existing >
procedure, would have provided operations the opportunity to perform a timely operability review.
II.
- Corrective Steps Which Have Been Taken and Results Achieved f $ .1.
The Director, Design Engineering, transmitted a memo on March 27,1997 to ' Design Engineering personnel defining his expectations and procedural requirements when non-conformances are identified.
2.
Expectations for timely initiation of problem resolution through the CR ' process was discussed with GGNS personnel during the April 16,1997 'Standdown' meeting.
] I 3.
Accountability meetings have been conducted with the individuals involved ' These actions have raised the awareness of select plant personnel and clarified procedural and management expectations concoming timely
' initiation of CRs.
I III.
Corrective Steps to be Taken to Preclude Further Violations 1.
Plant Management will issue a memo to plant personnel defining condition report expectations.
, 2.. Engineering manangement will conduct training with engineers covering the condition report initiation process.
IV.
' Date When Full Compliance Will be Achieved All actions are scheduled to be completed by June 16,1997.
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_ _. _ _ e E . , Entergy operatians. Inc.
O n PO Box 756 /l Pyt Gtton MS 39150 '
Tet 601437 64C8 Fax 601437 2795 Joseph lC0P'tSse^t Opercors orara cac ey sm on May 22,1997 U.S. Nuclear Regulatory Commission Mail Station PI 137 Washington, D.C. 20555 Attention: Document Control Desk
Subject: Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 Ucense No. NPF-29 Reply To A Notice Of Violation Two Examples of the Failure to Follow Radiological Protection Procedures Report No. 50-416/97-03 (GNRI-97/00058), dated C4/24/97 GNRO 97/00049 Gentlemen: Entergy Operations, Inc. hereby submits the response to Notice of Violation 50-416/9703-03.
Yours truly, h3 . JJH/MJL attachment Response to Notice of Violation 50-416/97-03-03 cc: Mr. L. J. Smith (Wise Carter) (w/a) Mr. N. S. Reynolds (w/a) Ms. K. D. Weaver (w/a) Mr. J. W. Yelverton (w/a) Mr. Ellis W. Merschoff (w/a) Regional Administrator U.S. Nuclear Regulatory Commission Region IV i 611 Ryan Plaza Drive Suite 400 l Arlington, TX 76011 l Mr. J. N. Donohew (w/a) ' Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission i Mail Stop 13H3 Washington, D.C.
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. -. ,. -. - - - - - . .. - - -. - -. .- -.. -.- - . - - -. , Attachment I t3 GNRO-97/00049
, P:ge 1 of 2 . . , ,. Notice of Violation 97-03-03 l Technical S pecification 5.4.1.a states, in part, that written procedures shall be . implemented covering the ap? cable procedures recommended in Appendix A of
ti Regulatory Guide 1.33, "Quaity Assurance Program Requirements (Operations)," ' j Revision 2, February 1978.
f Item 7 of Appendix A to Regulatory Guide 1.33 reco'umends procedures for i control ofradioactivity.
. Procedure 08-S-02-50, " Radiological Surveys and Surveillances," Revision 101, ) ' Section 8.6 stated, in part, that results of radiation, contamination and airborne i radiological surveys are documented using an approved HP form and/or plant survey map.
' , Procedure 01-S-08-2, " Exposure and Contamination Control," Revision 103, Section 6.7.1 stated in part, that all radiation workers at GGNS are required to be aware of the radiolo,gical conditions (radiation, contamination and airborne levels) [ in any posted area beTore entry.
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Contrary to the above: - \\ ! 1.
A contamination survey performed on February 27 or 28 was not i ! documented on an approved HP form, and !
2.
On March 10 and March 14 the radiological area survey map that provided information to the r,adiological worker was not updated to - " melude the location of the contamination area and the value of the
contamination levels that were identified on Valve E22-FO94.
$ . i This is a Severity Level IV violation (Supplement IV) (50-416/97003-03).
- i } L Admission or Denial of the Allened Violation .d Entergy Operations, Inc. admits to this siolation.
IL The Reason for the Violation, if Admitted 1. Procedures and vadons do not clearly specify which surveys should be documented. In addition, some health physics personnel place a low priority on - documenting surveys that indicated no change in contamination levels, WaHy when the results of the survey indicate the area is not contaminated, the area is posted , correctly, and the documentation as it currently exists reflects the conditions of the survey.
2. Health physics personnel did not have a consistent undwstanding ofwhat is expected to be entered on wall maps. Health physics procedures and standing orders were vague and unclear as to the expectations for whether or not catch basins should go on wall maps.
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.. ... -... - - -.. - -. -.. _ - - - _.. - -.. --- .. -. -.. Attachment I t3 CNRO-97/00049
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Page 2 of 2 . ' HL Corrective Steos Which Have Been Taken and Results Achieved ! ! L Immediate corrective actions were: l l l 1. The Notice of Violation (NOV) was distributed to Health Physics (HP) personnel. HP l ! supervision also discussed the NOV with HP personnel.
! l l 2. The wall map for the reom in question was updated to reflect the catch basin.
l IV.
Corrective Steos to be Taken to Preclude Further Violations The following corrective actions should preclude further violations as a result of events auch'as 'l the two cited in this violation: 1. Health physics personnel will ensure contaminated catch basins are documented on - wall maps.
i 2. Health physics procedures will be updated to clarify which radiological surveys to document and informetion to' include on wall maps.
3. The topics ofdocumenting surveys and updating plant wall maps will be discussed at the next Health Physics Training Review Group for inclusion in the upcoming health l physics training cycle.
' 4. Health Physics standing orders will be revised as wa===7 to clarify survey documentation requirements and information to ' clude on wall maps.
m 5. Health physics standing orders will be reviewed for clarity.
V.
Date When Full Comoliance Will be Achieved The above actions shall be completed by October 1,1997.
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