ML20101S273

Responds to NRC Re Violations Noted in Insp Rept 50-416/92-12.Corrective Actions:Stenciling Removed from Uncontrolled Painting Program & Initial Operator Training Program Will Be Revised to Emphasize Component Labeling

ML20101S273
Person / Time
Site:	Grand Gulf
Issue date:	07/10/1992
From:	Cottle W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GNRO-92-00085, GNRO-92-85, NUDOCS 9207170034
Download: ML20101S273 (6)

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A kI' I July 10, 1992 *$^~x-U.S. Nuclear Regulatory Commission

!. Mail Station P1-137 Washington, D.C. 20555

. Attentions Document Control Desk

SUBJECT:

Grand Gulf Nuclear Station.

Unit 1 Docket No. 50-416 License No.-NPF-29 Report No. 50-416/92-12 dated June'11, 1992 GNRI-92/00130)

GNRO-92/00085

Gentlemen:.

.Entergy Operations, Inct hereby submits the response to Notice of Violation 50-416/92-12.

We' share your concern that the cited violations-reflect an adverse trend.of. inattention to procedural details which must be aggressively pursued. In that respect, we'fouiid that a particularly effective actim for the drywell purge violation was to have a non-licensed

. operator conduct the shift briefings describing the circumstances sun ounding the violation. Peer interaction on this matter appears to

.have greatly enhanced communication and understanding of the

. deficiency. We will continue to explore fresh and innovative approaches to resolving problems such as presented by this violation.

-Yours-truly, w r r-- _.

WTC/RSJ/cg .

attachments:- 1. Notice of Violation 92-12-01 2.. Notice of Violation 92-12-02 gk

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- ' July 10.1992 GNR0-92/00085 Page ' cf j cc: Mr. D. C. Hintz (w/ )

Mr. J. L. Mathis (w Mr. R. B. McGehee ( )

Mr. N. S. Reynolds a)

Mr. H. a. Thomas (w o)

I Mr. Stewart D. Ebneter (w/a)

Regional Administrator U.S. Nuclear Regulatory Conunission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager (w/2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Mail Stop 13H3 Washington, D.C. 20555 VIOL 1201 - 2

Attachment I to GWRO-93/00085 Page 1 of 2

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Notice of Violation 92-12-01 Technical Specification 3.6.7.3 requires that two independent drywell purge system subsystems shall be operable in operational modes 1 and P.

Contrary to above, both divisions of drywell purge system were inoperable from 6:00p.m. April 9 to 7:00a.m. April 10, 1992 (approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />),  !

due to incorrect valve operation without initiating the power reduction  !

requirements of TS 3.0.3. l

1. Admission or Denial of the Alleged Violation Entergy Operations Inc. admits to this violation.

II. The Reason for the Violation, if Admitted On April 9,1992 cooling water to Division 2 drywM purge compressor was isolated to perform type C LLRT of its containmect isolation valves. During the test, difficulty was experienced with the test equipment and the valve lineup was changed to expand the test boundary. A non-licensed operator was dispatched with the required lineup procedure. The operator was expected to verify that valve P41F2448 was closed, initial the valve lineup procedure data sheet, and then proceed to containment to open a vent valve. A component locator aid was )osted outside the room. This is distributed as information by t1e Heelth Physics (HP) grou) and used by station personnel in locating the correct area of t1e room to find a component, thereby saving time and reducing exposure. The HP component locator aid listed and designated valve P41F244 (not P41F244A or P41F2448). The valve was located in an upper region of the room and accessed via ladder. The valve had P41F244 stenciled on the valve body which was visible from the floor. The operator closed valve P41F244A, not realizing that he had selected the wrong valve.

LLRT of containment isolation valves for Division 2 drywell purge compressor cooling water was completed on April 10, 1992. P41F244B was reopened as part of the division 2 restoration.

The error was discovered on April 14, 1992 while performing valve lineup for LLRT of containment isolation valves for Division 1

, drywell purge compressor cooling water. P41F244A was found in the closed position contrary to tne system operating instruction. With valve P41F244A closed, Division 1 drywell purge s.vstem was inoperable. This was concurrent with Division 2 drywell purge system being inoperable to facilitate LLRT. P41F244A had been closed for approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> while Division 2 drywell purge system was inoperable. Both division were inoperable. This was nonconforming l with Technical Specification 3.6.7.3. Therefore, the plant was in Technical Specification 3.0.3 for approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.

VIOL 1201/SCMPFLR

Attachment I to GNRo-92/00085 Page 2 of 2 The cause of this event was the incomplete component designation stencilled on the valve. Components were stencilled in an informal process as part of the painting program at the plant. The process did not assure accurny of identification and designations.

A contributing factor was inattention to detail by the operator. The operator failed to verify the unique label on the valve (which indicated the component correctly). Personnel are expected to check the unique component label when identifying or manipulating components or equipment. Although the individual had discussed the task and valve location in the control room with the control room supervisor before embarking on the duty, inadequate job briefing also contributed to the event. The operator found the valve open and proceeded to close it when he was to verify that the valve position was closed. The operator thought that P41F244 was P41F2448 and proceeded to close the valve, thereby isolating SSW cooling water to the Division 1 drywell purge compressor. The operator observed from the floor the stencil painted on the valve body indicating it as P41F244. This detail agreed with the component locator aid and reinforced the error. in addition, P41F244B was not shown on the HP component locator aid even though it is in the same room.

111. Corrective Steps Which Have Been Taken and Results Achieved Corrective actions resulting from this event include a 100% walkdown verification of painted stencils on components in the power block and correction of all incorrect or incomplete stencils. Stenciling has been removed from the uncontrolled GGNS painting program and is being incorporated into administrative procedure 01-S-06-43, Component Identification and Labelinc. The incomplete stencil on valve P41F244B has been correctec . The HP locator aid has been revised to correctly designate the valves.

Immediate training was given to operators which emphasized the importance of the expected actions and results of self-verification while manipulating plant components and expected actions by operators when incomplete or incorrect labeling is discovered in the plant.

Operations supervisors were trained on the elements of complete pre-job briefings and informed of the event.

IV. Corrective Steps to be Taken to Preclude Further Violations Initial operator training will be revised to emphasize the component labeling program, concepts of human er m , and proper self-verification techniques. This wi.. be completed prior to commencing the next non-licensed operator class.

V. Date When Full Compliance Will Be Achieved The next non-licensed operator class is expected to commence by November 30, 1993.

VIOL 1201/SCMPFLR

Attcchm:nt 11 to GNRo-92/00085 Page 1 of 2

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Notice of Violation 92-12-02 Technical Specification 6.8.lc requires that written procedures shall be established, implemented and maintained covering surveillance and test activities of safety related equipment.

Surveillance procedure 06-0P-1821-R-0006, " Containment Drywell and Auxiliary Building Isolation Valves functional Test", steps 5.3.5b and 5.3.5c required that the operator niace the reactor water sample valve logic 8 and C test switches to the test position.

Contrary to the above, during performance of surveillance procedure 05-0P-1821-R-0006 on April 21, 1992, the operator mistakenly actuated the test switches for reactor water cleanup system (RWCU) logic instead of the specified re&ctor water sample valve test switches. This resulted in closure of the RWCU inboard containment isolation valves.

I. Admission or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.

I'. The Reason for the Violation, if Admitted On April 21, 1992, a licensed operator was assigned to assist with performance of surveillance procedure 06-0P-1821-R-0006, Containment 3 Drywell and Auxiliary Isolation Valves Functional Test. During perfonnance of Attachment 11 in which the reactor water sample valve isolation logic is tested, the operator proceeded to activate each reactor water saaple isolation logic test switch on two separate control room panels as instructed by procedure. The opeutor inadvertently activated the RWCU isolation logic test switches ,

instead.

Just prior to assisting with the reactor water sample valve surveillance, the operator was involved with RWCU maintenance activities which included removing an RWCU system filter from service. The previous activity obscured the operator's train of thought in that he proceeded to activate RWCU switches instead of the reactor water sample switches as specified by the surveillance l procedure. The RWCU system logic test switches are adjacent to the l reactor water sample logic test switches on both panel sectors.

The cause is attributed to inattention to detail and inadequate practice of self-verification.

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VIOL 12olfSCMPFLR

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Attachm:nt 11 to GNRO-92/00085 t

Page 2 of 2 -

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' ~III. Corrective Steps Which Have Been Taken and Results Achieved E

As-airesult of this event,- the Conduct of Operations-procedure, 01-S-06-2 and the Control and Use of 0)erations Section procedure, 02-S-01-2 were modified to implement t1e Management Standard of self-verification to provide self-verification guidelines for use during performance of operating and surveillance procedures, valve line-up man',pulations, and red tag clearances.

The-Training Department has initiated program changes to instill ,

better word habits on self-verification during licensed and l inon-licensed operator continuing training.  ;

'Other.recent persnnnel: error occurrences were given management

- attention through site meetings and distribution of. newsletters to i reiterate the .importance of self-verification during performance of work tasks. ,

-The responsible operator was counselled on his inadequate practice of ,

self-verification.  ;

IV. Corrective Steps to be Taken to Preclude Further Violations The 1 raining Department-will initiate changes to the initial licensed and non-licensed operator training program to instill better work j

. hebits' on. self-verification. ,

'V. Date When Full Compliance Will Be Achieved This.will be completed priorf to November 30, 1993.

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