ML20065B809
| ML20065B809 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/28/1994 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-94-00049, GNRO-94-49, NUDOCS 9404040145 | |
| Download: ML20065B809 (4) | |
Text
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-:-:- ENTERGY Entergy Operations,Inc.
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Jh; March 28, 1994 C. R. Hutchinson U.S.
Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C.
20555 Attention:
Document Control Desk
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response to Violation for Failure to Review and Update Fire Protection Elements and Documents Report No. 50-416/94-05, dated 02/25/94 (GNRI-94/00053)
GNRO-94/00049 Gentlemen:
Entergy Operations, Inc. hereby submits the response to the Notice of Violation 50-416/94-05-01.
Yours truly,
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't f 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)
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 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C.
20555 040016 9404040145 940328 PDR ADOCK 05000416
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Attaciunent to GNRO-94/00049 t
Page1of3 Notice of Violation 94-05-01 Technical Specification (TS) 6.8.1.f requires that written procedures be established, implemented and maintained covering the Fire Protection Program implementation. License Condition 2.C.(41) requires that Entergy Operations, Inc. implement and maintain in effect all provisions of the approved Fire Protection Program.
1.
Administrative Procedure, Ol-S-16-1, Plant Design Change Implementation, Section 6.3, requires the review of design changes by specific interfacing plant organizations. The review requires the identification and documentation of those procedures, programs, material requirements, and operator training which must be revised as a result of the design change.
Contrary to the above, on February 18, 1989 and January 11, 1991, Administrative Procedure 01-S-16-1 was not adequately implemented in that the Operations Section reviews, of procedures, programs, training, or material requirements affected by Design Change Packages (DCPs) 85-0050, Snubber Test Facility, and 88-050, Expanded Protected Area, did not identify that fire brigade Fire Preplans needed to be updated; the transient combustible control program required revisions for Fire Area 59 in accordance with the Fire Hazards Analysis description, and fire brigade re-training was required for areas affected by the modifications.
2.
Operations Section Procedure 02-S-01-18, Control of Fire Preplans, established for implementing controls c,f Fire Preplans as an element of the plant Fire Protection Program, requires, in part, that the Fire Preplans be reviewed on an annual basis and revised when changes or modifications are made to plant structures, systems, or components.
Contrary to the above, as of January 28,1994, Operations Section Procedure 02-S-01-18, effective November 8,1991, was not adequately implemented in that the plant Fire Preplans, Revision 0, used for fighting fires in safety-related plant aieas had not been reviewed and revised on an annual basis since their originalissuance.
I.
Admission or Denial of the Alleced Violation Entergy Operations, Inc. admits to this violation.
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Attachment to GNRO-94/00049 -
Page 2 of 3 c
II.
The Ileason for the Violation,if Admitted Fire Pre-Plans Not Revised To Reflect Modification During the subject inspection, modifications were found that had affected certain portions of Fire Protection Program. Ilowever, appropriate documentation had not been updated to reflect modification implementation.
Plant personnel are required to review impact of modification on their respective organization and processes. The review is performed and documented to inform plant engineering of potential impacts that have been identified.
This review sheet was routed to operations personnel to determine impact of the subject modifications. The review was completed and returned to engineering. However, the fire protection group did not have an opportunity to review the proposed changes prior to l
implementation.
Operations section procedures establish guidelines for operations review of modifications for impact. This includes, fire protection procedures, training, etc. The procedure check sheet was being inappropriately marked as not needing Fire Protection review.
Corrective Actions Fire Protection personnel have been added to the review cycle of all modifications that come to Cperations for impact reviews.
Annual Review of Fire Pre-Plans Not Performed Operations section procedures required an annual review of the Fire Protection Pre-Plans.
L The last review was performed in 1991. The review was not performed in 1992 nor in 1993. The investigation revealed that even though the document was controlled by the Operations organization, the Document Control Organization was not involved in the -
process to ensure timely review of the document.
The Root Cause also identified a major contributing factor, in that, personnel responsible for the review left the company and there was no flag to make personnel aware that the i
review was due.
Corrective Actions All Fire Pre-Plans will be reviewed as soon as possible and appropriate changes made. In addition, the Document Control Organization will issue a notice for the annual review.
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Attachment to GNRO-94/00049 Page 3 of 3
- II.
Corrective Steps to be Taken to Preclude Further Violations 1
This incident will be routed to appropriate personnel in accordance with the Required Reading Program.
Entergy believes that the above corrective actions are adequate to prevent recurrence.
IV.
Date of Full Compliance Will be Achieved The above corrective actions are scheduled to be completed by December 30,1994.
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