ML20073R058
| ML20073R058 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/29/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-91-00087, GNRO-91-87, NUDOCS 9106040426 | |
| Download: ML20073R058 (3) | |
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~ o~as we Tei(01 076408 W. T. Cottle va newn Eg +m t er G'a n 3 } th kx M tsn May 29, 1991 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 Report No. 50-416/91-07-01 Dated 04/29/91 (GNRI-91/00089)
GNR0-91/00087 Gentlemen:
Entergy Operations, Inc. hereby submits the response to Notice of Violation 50-416/91-07-01.
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attachment: Notice of Violation 50-416/91-07-01 cc:
Mr. D. C. Hintz (w/a)
-Mr. R. B. McGehee (w/a) 1 Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas w/o)-
Mr. J. L. Mathis w/a)
Mr. F. W. Titus ( /a)
Mr. Stewart D. Ebneter (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner, Project. Manager (w/a)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 11021 Washington, D.C.
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i V10L9107/SCMPFLR - 1 9106040426 910529 0
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Attachment to GNR0-91/00087
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Page 1 Notice of Violation 91-07-01 Technical Specification 6.8.1.c requires that written procedures be established, implemented, and maintained covering activities associated with surveillance and test activities of safety related equipment.
Administrative Procedure. 01-5-06-12, GGNS Surveillance Program Section 6.8 required the test performer to make the initial review of the test results.
Section 6.8.6 required the shift superintendent / supervisor perform a review, and Section 6.8.9 required the superintendent's designee to perform a review of the test result for technical accuracy.
Contrary to the above, on February 13, 1991, the operator performing (NOA) the LPCI/RHR quarterly functional test failed to adequately ; view the test package.
In addition, the shift supervisor and superintendent performed an inadequate review in that the results of the ISI portion of the test were incorrectly classified as acceptable when the test should have been determined unacceptable.
1.
Admission or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
II.
The Reason for the Violation, If Admitted Entergy Operations personnel transcribed incorrect data into a functional test data package, which was used to calculate inservice inspection (ISI) data.
The subsequent reviews of the completed surveillance did not identify the erroneous data.
Upon completion of the test, the test results (i.e., acceptable, unacceptable) are recorded on the Surveillance Procedure Data Package Cover Sheet.
The procedure did not require each data entry to be verified for accuracy.
Therefore, only the calculated data would be reviewed to ensure ISI criteria were met. The accuracy of the ISI data entries was only reviewed by the ISI Coordinator, after the fact.
Additionally, the format of the procedure required the test performer to transpose data between pages within the surveillance data package.
III. The Corrective Steps Which Have been Taken and the Results-Achieved A.
A Quality Deficiency Report was initiated to document the deficiency and the 'B'-Residual Heat Removal Pump was declared inoperable.
The ISI portion of the surveillance which verifies that the ISI criteria are met was successfully completed on February 19, 1991.
V10L9107/SCMPFLR - 3 1
' Attachment to GNR0-91/00087; e*
Page 2 B.
An evaluation was performed to determine if the pump actually failed to meet ISI criteria during the previous test.
Based on the evaluation, the ISI: calculated'value data-point' exhibited'less deviation from the manufacturer's pump curve than the previous surveillance test ~. Therefore,1 the pump was considered operable as a result'of the surveillance, even though the data may not have exactly met the.ISI acceptable ranges.
C.
A Human Performance Evaluation (HPE)-identified several IST Surveillance procedures which may be subject to errors due to transposition of data between pages.
j IV.
The Corrective Steps Which Will Be Taken To Preclude further-Violation A.
Surveillance' Procedure 06-0P-1E12-Q-0024 will-be changed to-eliminate the transposition of' data between pages. ~The surveillance will also be revised to require licensed-operators to review data entries for accuracy upon completion of the test.-
B.
A review will be performed to determine if-procedure-revisions are necessary for ISI Surveillance procedures identified during the HPE.-
1 V.
Date When full Compliance Will-Be Achieved Full compliance will be achieved by July 1, 1991.
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