ML20082T094
| ML20082T094 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/12/1991 |
| From: | Cottle W CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-91-00163, GNRO-91-163, NUDOCS 9109180097 | |
| Download: ML20082T094 (3) | |
Text
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e~ - Entergy Operations F"T" """ " '"*-
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W. T. Cottle September 12,1991 s
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. 50-416/91-13 Dated 08/23/91 GNRO-91/00163 I
Gentlemen:
Entergy Uperations, Inc. hereby submits the response t Violation 50-416/91-13-02.
o Notice of Yours truly, MF A WTC/RR/cg t_
attachment: Notice of Violation 50-416/91-13-02 cc:
Mr. D. C. Hintz Mr. R. B. McGehee(w/a)
(w/a)
Mr. N. S. Reynolds (w/a Mr. J. L. Mathis ((w/a)) )
Mr. H. L. Thomas w/o Mr. Stewart D. Ebneter Regional Administrator (w/a)
U.S. Nuclear Regulatory Commission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager Office of Nuclear Reactor Regulation (w/a)
U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C.
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Attachment to GNR0-91/00163 Page 1 Notice of Violation 91-13-02 10 CFR 50, Appendix B, Criteria V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings. Surveillance procedure 06-CH-1023-V-0040, Sam)1ing the Drywell Atmosphere D-23 System, Revision 22, states that a gra) sample must be taken and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the particulate and gaseous portions of the drywell fission product monitor are inoperable.
Contrary to the above, on July 14, 1991, Chemistry failed to follow procedure, 06-CH-1D23-V-0040, for analyzing a sample within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the gaseous and particulate monitors were declared inoperable.
Even though the monitor was declared inoperable, the required channels were in operation during the time in question.
I..
Admission or Dcnial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
II.
The Reason for the Violation, If Admitted During maintenance which required the fission products monitor to be isolated, the Action Statement for Technical Specification (TS) 3.4.3.1 was entered.
This action requires grab samples of the drywell atmosphere to be obtained and analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Entergy Operations personnel obtained the sample but did not analyze within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit.
Even though the requirement was stated in Sections 1 and 2 of the-applicable surveillance procedure, the Chemist did not perform the required actions.
The analysis of the sample exceeded the TS time limit by 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 20 minutes.
The Chemist's knowledge of the particular surveillance requirement was deficient.
This particular surveillance and TS action are somewhat different from the ma,iority of the other surveillances and TS actions for inoperable monitors.
This TS action requires the sample to be obtained and analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Whereas other actions for inoperable monitors may require the sample to be taken at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, the Chemist thought the action had been completed by pulling the sample within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit. The grab sample was analyzed on July 14, 1991 and the results did not indicate abnormal reactor coolant leakage in the drywell.
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LAttachmentLto GNR0-91/00163
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'Page 2
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-III.The Corrective Steps Which Have been Taken To Preclude Further Violation A.-
-All Chemists were briefed on the incident to heighten their awareness of TS actions for inoperable monitors.
They were also instructed to perform more detailed discussions with the Operations Shift Supervisor-concerning Chemistry actions to meet TS requirements.
B.
The Chemist involved was counselled and instructed on proper review of the Control Room Limiting Conditions for Operation (LCO) log book.
C.
The Chemistry LC0 Tracking Status Board has-been improved to d
increase clarity-of time. requirements and the necessary actions.
D.
The Surveillance procedure was revised to establish administrative controls which would require the sample to.be
-obtained.and analyzed in a more timely manner.
Additionally,
-the-revised procedure requires the Chemist to initial the data package after obtaining the sample and again upon completion of the analysis.
IV. Date When Full Compliance Was Achieved Full compliance was achieved September 6, 1991.
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