ML20086D914
| ML20086D914 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/21/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-91-00187, GNRO-91-187, NUDOCS 9111260313 | |
| Download: ML20086D914 (3) | |
Text
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T Entergy c"' ' a < o a 'a'ia"
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Operations 7
_ _ _ ~. _. _. _ _
l November 21, 1991 l
l 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 18 dated 11-23-91 (GNRI-91/00225) l GNR0-91/00187 Gentlemen:
Entergy Operations, Inc. hereby submits the response to Notice of Violation 50-416/91-18-01.
Yours truly, 1
@ rCm WTC/RR:cg attachment cc: Mr. b. C. Hintz (w/a) l Mr. J. L. Mathis (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 l
U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager (w/a)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop.13H3 Washington, D.C.
20555 P
VIOL 9118/SCMPFLR d
9111260313 911121 E..
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Attachment to GNRO-91/00187 Page 1 Notice of Violation 91-18-01 j
Technical Specification 4.3.4.2.3 requires that the end-of-cycle recirculation pump trip system (EOC/RPT response time of each trip function shown in Table 3.3.4.2-3 shall)be demonstrated to be within limits at least once per 18 months. Each test shall include two turbine control valve channels from one trip system and two turbine stop valve i-channels from the other trip system such that all channels are tested at least once per 36 months.
Contrary to the above, on October 3,1991, the licensee discovered that the testing of the end-of-cycle recirculation pump trip response time had 1
not been performed in accordance with surveillance requirement 4.3.4.2.3.
The response times of the turbine control valves and stop valves in the same trip system instead of the opposing trip system had been tested each 18 months since 1987.
I.
Admission or-Denial of the Alleged violation Entergy' Operations, Inc. admits to this violation.
J l
II.
The Reason for the Violation, (. Admitted The schedule developed in 1986 designated the improper group of' channels to be surveilled.
This scheduling did not consider the staggered schedule of the surveillance requirement.
The procedure used in 1986 for scheduling surveillances_was judged to contain inadequate guidance regarding the EOC/RPT response time surveillance scheduling requirement.
III. The Corrective S+eps Which Have Been Taken and the Results Achieved A.
Performance of the surveillance was conducted successfully on October 5, 1991 on the affected trip system channels to comply with Technical Specification 4.3.4.2.3 requirements.
B.
An evaluation of surveillances, not automatically scheduled by the Station Information Management System (SIMS), was performed. Additionally, all surveillances with special scheduling requirements were reviewed. No other non-conformances were identified.
C.
Procedure 17-S-05-8 has been amended to include verification of compliance with technical specification scheduling requirements for staggered surveillance schedules which exceed the capability of SIMS.
l VIOL 9118/SCMPFLR
9 Attachment to GNRO-91/00187 Page 2 D.
An evaluation of the EOC/RPT logic testing schemes using a time dependent unavailability model was performed.
The evaluation concluded that there was no increased risk of failure to perform a safety function introduced by the erroneous surveillance testing situation.
The evaluation took no credit for the fact that portions of the alternate trip system channels had been tested.
E.
Based on the above evaluation, the erroneous surveillance testing situation did not increase the risk of failure.
Consequently, the safety and health of the general public was not compromised by this event.
IV.
The Corrective Steps Which Will Be Taken to Preclude Further Violation A.
The irformation in the sit 15 surveillance task module will be enhanced to ensure proper scheduling of surveillances.
B.
Clearer guidance on scheduling surveillances will be developed in procedure 17-5-05-8.
V.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by February 12, 1992.
VIOL 9118/SCMPFLR
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