ML20126E701
| ML20126E701 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf |
| Issue date: | 12/22/1992 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-92-00152, GNRO-92-152, NUDOCS 9212290274 | |
| Download: ML20126E701 (5) | |
Text
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.m E.ntergy Operations,inc.
cr~ENTERGY
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W. T. Cottne December 22, 1992 nw
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U.S.
Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C.
20555 Attention:
Documbat Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response to Violation for Failure to Follow Vendor Manual Procedure Report No. 50-416/92-26, dated 11/24/92 (GNRI-92/00238)
GNRO-92/00352 Gentlemen:
Entergy Operation, Inc. hereby submits the response to the Notice of Violation 50-416/92-26-01.
Yours truly, eo reacet-WTCfRSJ/
cc:
Mr.
R. H.
Bernhard Mr.
D.
C.
Hintz Mr.
R.
B. McGehee Mr.
N.
S.
Reynolds Mr. H.
L. Thomas Mr. Stewart D.
Ebneter Regional Administrator U.S.
Nuclear Ragulatory Commission Region II 101 Marietta St.,
N.W.,
Suite 2900 Atlanta, Georgia 30323 Mr.
P.
W.
O'Connor (w/2; Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Mail Stop'13H3 Washington, D.C.
20555
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December 22. 1992 GNRO-92/00152 Page 2 of 2
)
bec:
Mr.
P. E. Alberstadt-(w/a)
Mr. C. A..Bottomiller (w/a)
Mr. R.
W.
Byrd (w/a)
Mr.
L.
F.
Daughtery (w/a)
Mr. M. A. Dietrich (w/a)
Mr. J.
L.
Ensley (ESI) (w/a).
Mr. J. J..Fisicaro (ANO) (w/a)
Mr.
C.
C.
Hayes, Jr. (w/a)
Mr.
C.
R. Hutchinson-(w/a)
Mr.
L. W.
Laughlin-(W3) (w/a)
Ms.
F. K.
Mangan (w/o)'
Mr. J. R. McGaha (w/a)
Mr. M. J. Meisner (w/o)
Mr. R. V..Moomaw (w/a)
Mr.
D.
L. Pace (w/a)
Mr.
R.
L. Patterson (w/a)
Mr. T.
E.
Reaves, Jr. (w/a) i
-Mr. J. L. Robertson-(w/a)
Mr R. S. Johnson (w/2)
Mr.
G. A. Zinke (w/a)
Required Reading Coordinator (w/a)
SRC Secretary (w/a)
File (LCTS/RPTS) (w/a) i File (Hard Copy) (w/a)
File (NS&RA) ' (w/a)
. File (Central)
(7)
INPO Records Center Suite 1500 1100 Circle 75 Parkway i
. Atlanta, Georgia 30339 Mt.
F. A.
Spangenberg Illinois Power Company L
Clinton Power Station l'
L P.O.
Box 678 L
linton, Illinois 61727 l--
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Attachment I to GNRO-92/00152 Page 1 of,3 Notice of Violation 92-26-01 10 CFR 50, Appendix B, Criterion VI, Document Control, requires that measures be established to control the issuance of documents,such as inscructions, procedures,and-drawings, including changes thereto,which prescribe all activities affecting quality. These measures shall assure that documents, including changes,are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed.
Administrative procedure 01-S-05-4, Control of Vendor / Technical Manuals, Revision 12, paragraph 6.7 requires that manuals that are lost and later found be returned to Document Control for disposition.
Paragraph 6.8 of the subject procedure further specifies that personnel who receive-manuals that are lost-and later found be-returned to Document Control for disposition.
Paragraph 6.8 of the subject procedure further specifies that personnel who receive manuals, revisions,or information from vendors should send'this information to Document Control for processing.
Contrary to the above,the controlled copy of vendor ' Lube Manual' located in the control room was reported as-lost, removed from the controlled list,later found and placed -
back in servico,without being returned to Document Control for disposition.
This resulted in the use of an uncontrolled document for determining lubrication requirements for plant l
equipment.
Additionally, subsequent vendor supplied proposed ' Lube Manual' recommendations dated October 1990 were received on site for-comments. This new ' Lube Manual' contained errors which were being resolved between plant staff and Mobil.
I.
Admission or Danial of tie Alleg.ed Viola 11RD 1
Entergy operations, Inc. admits to this violation.
II.
The Reason-for the Violation, if_Admitteg.
-During the first quarter of 1990, Document Control personnel recalled controlled copy number 15 of the lubrication vendor nanual-from the main control room,in order to update the l-manual. Control room personnel were unable to locate the manual and generated a
Lost Manual Form
'in accordance with Administrative Frocedure 01-S-05-4.
Copy. number 15 was then removed from the active vendor manual records.
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Attachment I to GNRO-92/00152' Page 2 of:3 Subsequent to the_ completion of the_ lost report,the manual was' located'and used to specify lubrication for plant equipment.
It was later discovered that the manual'was miasing two previous updates.
An updated replacement manual was then issued by Document Control.
The first update consisted of specified oil requirements for P75D012A/B/C/D, starting air drying tower regulating valve _
lubricators.
Prior to this revision there were_no specific oil requirements for the lubricators.
The second update-added a new recommendation for the condenser _-tube-cleaning system ball recirculation pump and motor,N71C003A/B.
The Operations vendor manual did not contain the official 1N71C003A/B requirements but did contain a markup which specified Mobil Vactra Light Oil for the pump bearings.
This was the only portion of the vendor manual _ update _used by Operations as they do not add oil to the_ motor bearings.
The cause of the lack of administrative-control of' vendor manuals contained'in the control room was due to the responsible administrative specialists unfamiliarity of required processing of vendor manuals.
The cause of failure to follow procedure for processing of-the vendor manual update is unknown due to the' discontinued employment of the-involved System Engineer.
III. Corrective Steos Rhich Have Deen Taken and Resq_lte Achieved A new copy of the-' Lube Manual' was placed in the control room to replace the out of date manual.
The importance of adhering to the vendor manua3 update process was discussed with the responsible Performance and-System Engineering personnel.-Additionally a method has been setup to handle future revisions-more effectively.
Performance and System Engineering-reviewed selected-trip sensitive or production systems vendor manuals to verify no immediate concerns exist regarding lube oils that would affect these systems.
For-the ' Lube Manual',the_ vendor and the responsible engineer has set up~a method to better handle future revisions.
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Attachment I to GNRO-92/00152 Page 3 of-3 IV.
Corrective Steps to be Taken to Preclude Further Violations The importance of adhering to the vendor manual' update process will be stressed with the operations administrative specialist.
A review of vendor manuals is being conducted by Operations to determine which vendor manuals should remain in their inventory as controlled documents.
Following this review the manuals chosen to remain will be verified to contain the latest updates.
V.
Date When Full Compliance Will Be Achieved These actions will be completed by January 15, 1993.