ML19350B996

Responds to NRC 810119 Ltr Re Violations Noted in IE Insp Rept 50-416/80-24.Corrective Actions:Affected Packages Reviewed,Documents Corrected & Entered Into Package for Completion

ML19350B996
Person / Time
Site:	Grand Gulf
Issue date:	02/13/1981
From:	Stampley N MISSISSIPPI POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19350B997	List: ML19350B996
References
AECM-81-67, NUDOCS 8103240615
Download: ML19350B996 (5)

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/O MISSISSIPPI POWER & LIGHT COMPANY .

Helping B uild Mississippi Edhhibididd5 P. O. B O X 16 4 0, J A C K S O N , MISSISSIPPI 39205 February 13, 1981

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Office of Inspection & Enforcement 4 g u) f U. S. Nuclear Regulatory Commission to Region II E l 101 Marietta Street, N.W.

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Atlanta, Georgia 30303  ; I'I/IR D 37pg Attention: Mr. J. P. O'Reilly, Director' Dr 8.t:

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Dear Mr. O'Reilly:

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SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 6 416/4 @

File 0260/15525/15526 RII: AGW 50-416/80-24 IE Inspection Report of October 1-30, 1980 AECM-81/67 Mississippi Power & Light Ccmpany received a Notice of Violation as Appendix A to your letter dated January 19, 1980 which transmitted IE Inspection Report 80-24. Three separate items of noncompliance were identified in the report.

Although our response to the Notice of Violation was due February 12, 1981, Mississippi Power & Light is submitting the attached res,onses on this date as discussed with Mr. Austin Hardin of the NRC on Frgruary 12, 1981.

Yours truly,

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ATR:mt Attachments A - Infraction 416/80-24-01 B - Infraction 416/80-24-02 C - Deficiency 416/80-24-03 cc: See page 2 Member Middle South utilities System

i MISSISSIPPI POWER O LI2HT CCMPANY Mr. J. P.' 0'Reilly AECM-81/67 NRC- Page 2 cc: .Mr. N. L. Stampley .

Mr. R. B. McGehee Mr. T. B., Conner Mr. Victor Stello,, Director ~ '

I DiYision $P Insp~ecEiori &" Enforcement

'U.-S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. G. B.' Taylor South Miss. Electric Power Association P. O.' Box-1589 Hattiesburg,-MS. 39401 t

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Attachment A to AECM-81/67 Page 1 of 1 INFRACTION 416/80-24-01

1. Corrective Steps Taken and Results' Achieved The affected packages were reviewed and the required documents were corrected and entered into the packages to make them complete.

2. Corrective Steps Taken to Avoid Further Noncomplianta CT0' turnover. procedure 4.16 was revised on 11/10/80. The procedure

- , 4.. . cAchanges, accomplished.the.following:

More clearly defined the differences between walkdown and turnover packages.

Simplified the walkdown packages.

-- Reduced the possibility of different interpretation of pro-cedure contents by individuals using the procedure, by better defining the overall program.

Incorporated separate inventory records for turnover-packages.

'and walkdown packages.

Lectures on the. procedure change were conducted November 17, 1980 through November 20, 1980 by group leaders.

Those personnel.not in attendance at the lectures noted above will be indoctrinated by February 20, 1981 or upon returning to work and prior to assuming their assigne'd duties.- Attendance rosters for

--the training willibe available in'the CTO office..

3., Date to Achieve Full' Compliance

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' ' Ftill c$mp1'i$nc"e"will be acliihEd' $n'FSbruary 20, "19.81'. ' ~

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. c Attachment B to AECM-81/67 Page 1 of 1 INFRACTION 416/80-24-02 The infraction, as written in Appendix A, is not accurate in that it

' fails'to completely quote or accurately paraphrase the referenced Bechtel Construction Work Procedures Manual WP/P-3, Paragraph 6.1.4.

Your Appendix A, Item B, reads:"Bechtel Construction Work Procedures Manual WP/P-3 paragraph 6.1.4 states cups (sic) shall be in place on pipe and equipment openings." The complete referenced sentence reads:

"Cap s shall be in place on pipe and equipment openings as required." ,

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While it.is de, sired that. caps je kept.in place,when work or tes. ting.

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activities'are'not in. progress, it is-not a requirem'ent' Since there are'

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no regulations which' require caps to be installed, and since the con-trolling Bechtel procedure makes their installation optional (as re-quired), MP&L does not feel that the item of noncompliance is valid and requests that the citation be withdrawn. MP&L and Bechtel have delegated the authority to make the decision relative to the specific need for

! caps to the responsible field or CTO Engineer.

1 Although we do not feel that a citation is valid, MP&L does acknowledge the possibility that ambiguity may exist in_the current procedure.

Therefore, the applicable portions of CTO Manual, Chapter 4, Section 16,

. as outlined below, will be revised via a Change Notice. New paragraph 4.5.5 will be added to include the following requirements for temper-ature detector well caps.-

" Caps will'be required-to be in place at the time of system turn-over to MP&L, unless otherwise directed by MP&L."

The CTO Procedure 4.'16 willLbe revised and implemented on or before March 6f1981. *

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a Attachment C to AECM-81/67 Page 1 of 1 DEFICIENCY 416/80-24-03

'l. Corrective Steps Taken'and Results Achieved The Temporary Alteration Log and Temporary Alteration Request were closed October 29, 1980 based on verification of the system status.

The' alteration tags were located in the Test Supervisor's posses-sion and subsequently destroyed in accordance with procedure. A review of the Startup Test Procedure was performed to ensure that the procedure required removal of the temporary alteration. A review of all outstanding. temporary alterations was performed and

' ' n("additionar dificisncie'swere:noted. - '

2. Corrective Steps Taken'to Avoid Further Deficiency

'All Startup Personnel had gone through a Startup Manual Orientation refresher training session on August 26, 1980, at which time Tem-porary Alterations were discussed. An internal Startup reading assignment of plant Operations Manual procedure 01-S-06-3 was made September 29, 1980 through November 4, 1980, which was after the actual deficiency occurrence but prior to its finding. Further, a memo'was issued February 9, 1981 to all Startup Personnel on con-trol of system Temporary Alterations to aid in obtaining a more detailed understanding of the Temporary Alterations procedural requirements.

3. Date to Achieve ~ Full Compliance We are-in full compliance at this time.

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