ML20116B328
| ML20116B328 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/22/1996 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-96-00085, GNRO-96-85, NUDOCS 9607290214 | |
| Download: ML20116B328 (5) | |
Text
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Pa!! G:r:sn MS 3940 lW 601.;37 2630 C. R. Hutchinson w r,.
s, July 22,1996 I, i;$.
U.S. Nuclear Regulatory Commission l
Mail Station P1-137 s
l Washington, D.C. 20555 i
Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 l
License No. NPF-29 Reply To A Notice e n lpinn o
RCIC System and m Not Properly Aligned
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.; to Procedures Report No. 50-416mo-10 (GNRI-96/00136), dated 06/21/96 GNRO-96/00085 Gentlemen:
l Entergy Operations, Inc. hereby submits the response to Notice of Violation 50-416/96-10-01.
Yours truly,[
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CRH/CDH b h.N~
attachment j
cc:
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. J. E. Tedrow (w/a)
Mr. J. W. Yelverton (w/a)
Mr. Leonard J. Callan (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011 l-Mr. J. N. Donohew (w/a)
Office of Nucicar Reactor Regulation
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i U.S. Nuclear Regulatory Commission
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Mail Stop 13H3
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Washington, D.C.
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Attachment I ts CNRO-9W00085 P ge 1 of 4 Notice of Violation 96-10-01 i
During an NRC inspection conducted from Ap. 2 i through May 25,1996, one violation of NRC requiremants was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (60 FR 34381; June 30,1995) the violation is listed below:
1 Technical Specification 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended m i
Regulatoiy Guide 1.33, Revision 2, Appendix A, February 1978.
l Appendix A of Regulatory Guide 1.33 recommends written procedures for operation of safety-related systems and recommends written procedures for abnormal, offnormal, or alarm conditions.
I l
Procedure 04-1-01-E51-1, " Reactor Core Isolation Cooling System," specifies, in part, requirements to properly align the system under standby conditions.
Procedure 04-1-02-lH13-P870, " Alarm Response Instruction for Panel IH13-P870,"
provides guidance for responding to various control panel alarms in accordance with plant l
procedures. Procedure 04-1-01-IP41-1, " Standby Service Water System," specifies, in part, requirements to properly align the system upon an actuation or under standby conditions.
Contrary to the above:
l 1.
From April 18-21,1996, following check valve testing operators failed to assure that the reactor core isolation cooling system was properly aligned in accordance with Procedure 04-01-E51-1. Specifically, operators failed to assure that Valve E51F010, reactor core isolation cooling pump suction from the condensate storage tank, was open and that Valve E51F031, reactor core isolation cooling pump suction from the l
suppression pool, was closed.
L.
On May 22,1996, followmg a spunous Standby Service Water (SSW) B actuation and receipt of a SSW Pump B Low Discharge Pressure alarm, operators failed to implement Procedure 04-01-02-lH13-P870 in that they did not verify proper system configurations in accordance with Procedure 04-1-01-lP41-1. Specifically, operators I
dkl not verify that Valve IP41-F001B, SSW B pump discharge isolation, opened upon the. system startup nor did they ~ure that the system was in an appropriate i
standby lineup I.
Admission or Denial of the Allested Violation l
Entergy Operations, Inc. admits to this violation.
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1 I
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l l-Attachment I ts QNRO-96/00085 P ge 2 of 4 H.
The Reason for the Violation, if Admitted 1.
The root cause of the misalignment of the Reactor Core holation Cooling (RCIC) System was a less than adequate procedure. The System OperaSng Instruction'(SOI) for the RCIC System provides detailed instmetions for both system startup and various flowpath valve alignments.
In the section of the SOI which provides the instructions for recirculating RCIC back to the suppression pool, the operator is directed to ensure that the RCIC suction is lined up to the suppression pool by opening valve E51-F031. In the
" Shutdown" section of the SOI, suppression pool suction valve realignment is not l-addressed. Instead, this SOI section directs Attachment V be performed. Attachment V l
indicated an ' auto' position but did not indicate an open or closed position for valve l
E51-F031 and the valve was not repositioned. The SOI was not adequate to ensure RCIC L
was returned to its normal SOI lineup.
i A contributing cause of this event was a less than adequate questioning attitude on the i
part of the operator. The reactor operator did not question the fact that the suction valves o
had been re-positioned during the surveillance and were not returned to an "as found" position after the evolution. When the SOI did not direct the valves be returned to an as l
found position, questioning on the part of the reactor operator would have allowed others I
on the operating shift to be aware of the situation and possibly correct the condition.
An additional contributing cause of this event was less than adequate communication of
(
operator expectations on the part of management. Interviews with operations personnel
)
i indicate that the practice of checking that RCIC was in a standby lineup was not a practice performed by many operators. Checking RHR, LPCS and HPCS lineups during turnover i
was a practice performed by all operators. However, the expectation to check all the l
system alignments, if not during turnover, sometime during their watch standing was not a
.l clearly defined expectation.
2.
Subsequent investigation of the inadvertent start of SSW "B" revealed that the insulating barrier between two terminals of panel 1GD21-5 had been broken away which could have resulted in the inadvertent contact of the maxi-grabber test probe with one of the terminals and, therefore, contributed to the initiating event.
1 A contributing cause of the initiating event was less than adequate communication of expectations to the electrician on what to do when encountering an unexpected situation or condition. Although the electrician did question the situation when he could only see one terminal with a receptacle for a banana type jumper, the electrician proceeded on with the task using a maxi-grabber test probe which resulted in its inadvertent contact with one of the terminals.
An additional cause of the initiating event was that, since the banana plug was black, it j
could not be readily seen within the bundle of black and blue wires in the panel. A more contrasting color would have allowed the electrician to locate the banana plug and use it j
rather than the terminal above TBI-11.
i
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6 Attachment I13 CNRO-96/00086 P ge 3 of 4 The root cause of the event being cited;was less than adequate communications between the reactor operator and shin supervision. The reactor operaior stated to shift supervision 3
that the "1" valve (P41-F001B) had not opened but received no acknowledgment. This ss a missed oppoitunity for a decision to have the flowpath alignment corrected. The reactor operator did not advocate his concern or adhere to the desired method of communication or current management expectations.
An additional contributing cause of this event was less than adequate communications of expectations. After the event had been analyzed and the reason for the inadvertent start of SSW "B" determined, a panel walkdown by the reactor operators was not performed.
j Although considered a reasonable expectation, this has not been strongly communicated.
HL Corrective Steps which Have Been Taken and Results Achieved 1.
Immediate corrective actions were:
Surveillance procedure 06-OP-lE51-M-0001, RCIC Monthly Operability l
Verification, was performed on April 21,1996. This returned valve E51-F010 to an open position and closed valve E51-F031.
Quality Deficiency Report (QDR) 96-0090 was initiated to document the event and initiate corrective actions.
SOI 04-1-01-E51-1, Reactor Core Isolation Cooling System, was revised and issued. This revision requires Attachment II, Remote Operated Valve Lineup Checksheet, to be performed after RCIC shutdown.
A training session was presented to on-shift Operations licensed personnel which covered the apparent causes for all configuration control events since the beginning of 1995. Senior Operations Management conveyed their expectations for the following:
Control Room Panels responsibility Response to actuation of systems Questioning Attitude Procedural Compliance Pre-job Preparation Procedure Placekeeping Self-checking
)
Communications 2.
Immediate corrective actions were:
SSW "B" was declared inoperable and documented by LCO 96-0496. A system fill and vent was performed in accordance with the SSW System SOI. Work Order 166615 was performed to verify proper operation of P41-F001B. The system was returned to operation and the LCO cleared.
QDR 96-0113 was initiated to document the event and initiate corrective actions for the inadvertent start signal.
Incident Report 96-05-05 war, initiated.
Condition Identification 055687 was initiated to repair the broken insulator.
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Attachment i13 CNRO-96/00085 1
P ge 4 of 4 A training session was presented to on-shill Operations licensed personnel which e
covered the apparent causes for all configuration control events since the beginning of 1995. (A common training session was conducted in response to both events.)
Senior Operations Management conveyed their expectatyns for the following:
- . Control Room Panels responsibility Response to actuation of systems
. Questioning Attitude Procedural Compliance Pre-job Preparation Procedure Placekeeping i
Self-checking
- Communications The expectation that Electrical Department personnel should stop and investigate or correct unexpected situations or conditions was discussed with Electrical Maintenance personnel during a standdown meeting on June 20,1996.
IV.
Corrective Steps to be Taken to Preclude Further Violations 1.
Long term corrective actions are:
Written management expectations regarding responsibility for control room panel e
walkdowns will be developed.
A panel enhancement will be developed to help licensed operators determine the required SOI position for selected valves on the P870/P601 panels.
2.
Long term corrective actions are; Written management expectations regarding panel walkdowns to verify proper e
operation following system actuation will be developed.
j Banana plugs and jacks of a more contrasting color will be used in panels
]
e IGD 11-4, IGDil-5, IGD 21-4 and IGD 21-5.
The methods of banana plug installation on all panels will be reviewed.
l V.
Date When Full Compliance Will be Achieved The above actions shall be completed by September 20,1996.