ML20081K165
| ML20081K165 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/23/1995 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-95-00031, GNRO-95-31, NUDOCS 9503290004 | |
| Download: ML20081K165 (4) | |
Text
.
Ent:rcy Cptrctirna,Inc.
T cc:- E N T E R G Y
- se Ptat Gtson MS 39150 Tel 601437 2800 o
C. R. Hutchinson u e Mxra h 4?Q30Ts Gnrc Guf Nnw Smen l
l March 23,1995 l
l U.S. Nuclear Regulatory Commission Mail Station P1-137 l
Washington, D.C. 20555 l-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 inadequate Work Instructions for Spare Breakers Report No. 50-416/94-21-03 (GNRI-95/00050), dated 02/24/95 GNRO-95/00031 Gentlemen:
Entergy Operations, Inc. hereby submits the response to Notice of Violation 50-416/94-21-03.
Notice of Violation 50-416/94-21-03 stated that during a system engineer walkdown of the 4160 Volt AC distribution system, it was discovered that spare breakers on the DIV I and DIV ll
('
Engineered Safety Features (ESF) busses were in the disengaged position. Since this position was a j
configuration for which seismic qualification had not been evaluated, it was initially concluded that this candition could have resulted in damage to safety reeted equipment in both divisions if a seismic event had occurred while the breakers were not engaged. Although this condition was reported by phone to the NRC on January 17,19f 5, a subsequent design engineering evaluation determined that a seismic event would not have risulted in a failure of the DIV l and DIV 11 ESF busses nor would it significantly affect other components such that plant safety would be compromised. Therefore, this event has since been determined not reportable.
f 280078 9503290004 950323 PDR ADOCK 05000416 0
PDR I
M' arch 23, 1995 GNRO-95/00031
.r--
l I -
PAGE 2 OF 3 r.
1 Plea let me know if we can provide additional information regarding this violation.
I Yours truly, i
CRH/CDH attachment l
l cc:
Mr. J. E. Te&ow (w/a)
Mr. H. W. Keiset(w/a)
Mr. R. B. McGetoe (w/a) l Mr. N. S. Reynofds (w/a) j Mr. H. L. Thomas (w/o) l Mr. Stewart D. Ebneter (w/a)
Regional Adruinistrator U.S. Nucler.r Regulatory Commission l
Region il 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor (w/a)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 l
l l
I i
_____-_-__-_--_______---___--_-------__--_-_---_----_-_----J
=
Attachment I t3 GNRO-95/00031 1-Page 1 of 2 Notice of Violation 94-21-03 Technical Specification 6.8.1.a requires that written procedures be established implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 recommends procedures to be in place for the control of maintenance, repair, replacement and modification work. Administrative Procedure 01-S-07-1, Cor. trol of Work on Plant Equipment and Facilities, paragraph 6.6.5 requires, in part, that the maintenance planner / responsible field engineer is responsible to ensure that a work package is complete and information is accurate before issue. This includes ensuring that seismic
)
qualification requirements are properly identified and/or referenced.
Contrary to the above, maintenance work packages 00123485 and 00126277, for work on both the Division I and Division II 4160 volt emergency bus spare breakers were inadequate, in that specific instructions for placing these breakers back into a seismically secured position after the completion of work were not included. This resulted in the seismic basis not being maintained for the Division I bus between June 1994 and January 1995, and for the Division II bus between October 1994 and January 1995.
I.
Admission or Denial of the Allemed Violation Entergy Operations, Inc. admits to this violation.
t II.
The Reason for the Violation. if Admitted On January 12,1995, while conducting a walkdown of the 4160 Volt AC distribution system, a system engineer found two spare ITE SkV breakers (152-1502 & 152-1602) in the " disengaged' position. This was a configuration for which seismic qualification had not been evaluated. This generated concern since the spare breakers were located on both the DIV I and DIV II ESF busses. Operations personnel immediately racked the spare breakers into a seismically qualified position and the system engineer generated a Material i
Non-conformance Report (MNCR 0010-95). In response to the MNCR, a design engineering evaluation was performed. This evaluation determined that, although the breakers were left in a non-qualified position, a seismic event would not have resulted in a i
failure of DIV I and DIV II ESF busses nor significantly affected other components such
[
that plant safety would be compromised.
j i
In 1990 an NRC Electrical Distribution System Functional Inspection (EDSFI) was conducted at GGNS. NRC inspectors expressed a concern that spare circuit breakers may not be properly secured for a seismic event. To address these concerns, plant personnel conducted an inspection to verify the spare breakers to be in a seismically qualified position. Additionally, Maintenance and Operating procedures were revised to distinguish between the seismically qualified ' disconnect' position and the unqualified
'rackedout' posit lon, otherwise known as ' disengaged'.
i i
I
- i Attachment I 13 GNRO-96/00031
'l Pge2d2 II.
The Reason for the Violation. if Admitted (cont'd)
.s Recent activities involving the spare 4160 Volt circuit breakers had been completed in June and October of 1994. Due to maintenance on the DIV I and DIV II Diesel Generator output breakers, Electrical Maintenance exchanged them with the spare breakers installed on the 15AA and 16AB busses. The removed Diesel Generator circuit breakers were then refurbished and placed in the spare breaker cubicle on the 15AA and 16AB busses in the disengaged position.
The root cause of this condition is that the actions taken in response to the concerns of the 1990 EDSFI inspection team did not adequately address all actual work processes which could affect spare breaker position. Routine maintenance and special work order instructions were not considered in the scope of the previous actions.
III.
Corrective Steos Which Have Been Taken and Results Achieved The breakers were immediately racked to a seismically qualified position.
A Material Non-conformance Report was written which included a design engineering evaluation. The evaluation determined that, although the breakers were left in a non-qualified position, a seismic event would not have resulted in a failure of DIV I and DIV II ESF busses nor significantly affected other components such that plant safety would be compromised.
As an interim measure, labels were posted on the safety related ITE SkV breaker cubicles which caution personnel not to leave disengaged breakers unattended. This visual aid heightens Maintenance and Operations personnel awareness of proper breaker configuration.
Applicable System Operating Instructions were revised to include the required position for the spare breakers stored on the DIV I and DIV II ESF busses.
IV.
Corrective Steps to be Taken to Preclude Further Violations Revise guidance in Maintenance Instmetion 07-S-12-42, ' Inspection and Testing of ITE 5kVPower Circuit Breakers', to include a description of the seismically qualified positions for the breakers.
Incorporate enhancements into the Station Information Management System (SIMS) to include seismic information of Maintenance Instruction 07-S-12-42, ' Inspection and Testing ofITE SkVPower Circuit Breakers '.
V.
Date When Full Compliance Will be Achieved The above actions shall be completed by July 20,1995.
j