ML20059A869
| ML20059A869 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/20/1993 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-93-00163, GNRO-93-163, NUDOCS 9401030171 | |
| Download: ML20059A869 (3) | |
Text
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F ENTERGY.
- E"S""" """ '
Pcet Gibcon.MS 39150 Tet 601437 7800 C. R. Hutchinson We FW21ont '
December 20, 1993 quan Gurd G# tkaar Ctation U.S.
Nuclear Regulatory Commission
. Mail Station P1-137 Washington,.D.'C. 20555 Attention:
Document Control-Desk
SUBJECT:
Grand Gulf Nuclear Station Unit l' i
Docket No. 50-416 License;No. NPF-29 Response to Violation for Failure to Follow' Work Instructions-During LPRM Maintenance-
-l Report No.' 50-416/93-15, dated 11/19/93 (GNRI-93/00197)
GNRO-93/00163 Gentlemen:
Entergy Operations, Inc. hereby submits the response to the Notice of Violation 50-416/93-15-01 Yours tru o
CRH/RR/
' attachment cc:
Mr.
R..H. Bernhard(w/a)
Mr. H. W. Keiser(w/a)
Mr. R. B. McGehee (w/a)
Mr.
N.-S.
Reynolds (w/a) i Mr. H. L. Thomas (w/o)
Mr. Stewart;D. Ebneter (w/a)
- Regional Administrator-U.S.-Nuclear Regulatory-Commission Region II 101 Marietta St.,
N.W.,
Suite 2900 Atlanta,-Georgia 30323 Mr.'P.'W.
O'Connor-i Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission =
Mail Stop 13H3 Washington, D.C.
20555 0'
pJQC 4
oa M[bl-9401030171 931220 i
PDR. ADOCK'05000416 i
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Attachment to GNRO-93/ col 63
- Page 1 of 2 Notice of Violation 93-15-01 Technical Specification 6.8.1.c requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix 'A' ofRegulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 recommends that procedures for performing _
maintenance which can affect the performance of safety related equipment should be properly preplanned and performed in accordance with written procedures and documented instructions.
Administrative Procedure 01-S-07-1, Control of Work on Plant Equipment and Facilities, requires that all maintenance work be accomplished using written and approved work documents and/or work instructions.
Contrary to the above, on October 11,1993, under-vessel maintenance personnel disconnected 39 additional local power range monitor (LPRM) detectors not specified in the maintenance work order.
i 1.
Admission or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
11.
The Reason for the Violation,if Admitted i
On October 11,1993, contract personnel prepared to disconnect LPRM detectors in accordance with approved work instructions. The contractor had trained the individual in the particulars of the task which was assigned. Upon entering the under-vessel area, personnel discovered that most connectors were sealed with Raychem rather than rubber boots. The individual removed Raychem from some of the detectors. However, difliculty
.I was encountered during the removal of these seals. In order to reduce time and dose, the j
individual began to cut the cables rather than trying to remove the seals. The individual had used this method at another facility (an earlier vintage BWR). Even though the work package specified the appropriate LPRM detectors to be disconnected, the individual 4
developed a mind-set that an entire LPRM string (all four detectors) would have to be removed to complete the replacement activity. Therefore the cables for all four detecto_rs were cut instead of the specific detectors documented in the work package. The individual cut 15 of the 20 specified LPRM locations. Upon becoming aware of the error, the individual informed the appropriate supervision.
The responsible technician did not refer to the work package to ensure work was being performed on the specified equipment and in accordance with work instmetions.
i Attachment to GNRO-93/00163 Page 2 of 2 III.
Corrective Steps Which Have Been Taken and Results Achieved All further under-vessel work was stopped until appropriate technicians could be re-trained on proper Raychem practices.
The responsible individual was relieved of duties.
Under-vessel contract personnel were re-trained in procedure techniques and Quality responsibilities.
The incident'was reviewed'with other under-vessel contract personnel, emphasizing verbatim compliance.
Appropriate supervision reviewed all work performed by the responsible individual.
The affected LPRMs were repaired in accordance with approved work instructions.
IV.
Corrective Steps to be Taken to Preclude Further Violations This event will be reviewed with appropriate outage personnel as a part of RF07 action items to ensure incoming personnel are aware of this occurrence and are aware of proper Raychem procedures and Q. A. requirements.
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