ML20132G785
| ML20132G785 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/18/1996 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-96-00142, GNRO-96-142, NUDOCS 9612270042 | |
| Download: ML20132G785 (3) | |
Text
- _
-=
Ent:rgy Operations,Inc.
O P.O. Box 756 Port Gibson, MS 39150 Tel 601437 6408 Fax 601437 2795 Joseph J. Hagan Vice President December 18,1996 operatorm Grand Gulf Nuclear Staten 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 Reply To A Notice Of Violation Failure To Perform Required TS Surveillance Report No. 50-416/9617 (GNRI-96/00234), dated 11/25/96 /
GNRO-96/00142 Gentlemen:
e Entergy Operations, Inc. hereby submits the response to Notice of Violation 50-416/96-17-01.
During the preparation and review of the response to the violation of Technical Specification Surveillance requirement 3.3.6.2.1 (50-416/96017-01) questions were raised by plant staff as to why a violation instead of an NCV was issued. In keeping with Grand Gulf's efforts to continually 3
improve we wouM take this opportunity to increase our understanding of the regulations as j
explained in NUREG 1600 and the NRC Inspection Manual 0610 section 05.02 - Thresholds of i
Significance, in reviewing this event it is not clear to us what specific criteria were used to determine that this event was of "more-than-minor" significance. To ensure our safety focus, we would appreciate further clarification of how these guidelines are used in this event.
Yours truly, C
JJH/CDH i
attachment Respo Notice of Violation 50-/416/96-07-01 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) i Regional Administrator U.S. Nuclear Regulatory Commission tj}
Region IV 611 Ryan Plaza Drive Suite 400 fp l
Arlington, TX 76011
,If Mr. J. N. Donohew (w/a) n Office of Nuclear Reactor Regulation e60044 u.S. Nuciear Reguiatory Commission Mail Stop 13H3 Washington, D.C.
9612270042 961218 PDR ADOCK 05000416 G
Attachment I t3 CNRO 96/00142 P:ge 1 c.f 2 Notice of Violation 96-17-01 Technical Specification Surveillance Requirement 3.3.6.2.1 states, in pcrt, to perform a channel check every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for secondasy containment isolation instrumentation, which includes the fuel handling area pool sweep exhaust radiation high high instmmentation.
i Contrary to the above, from September 20-22,1996, five required channel checks for the fuel handling area pool sweep exhaust radiation high high instrumentation were not performed in that operators read and recorded data from incorrect alternate instrumentation.
L Admission or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
II.
The Reason for the Violation. if Admitted The root cause of the missed surveillances was less than adequate work practices in that self-checking and error detection techniques were not applied to ensure the correct trip unit numbers were denoted on the information tag. Although the incorrectly identified trip unit is very similar to the desired trip unit, self-verification of the task did not detect the error when placing the information tag. Operators performed five subsequent surveillances by reading the information tag hanging on the cavity of the removed recorder and verabatimly following the directions provided on the information tag. However, if they i
had verified the name of the trip units being read against the parameter being measured on J
the Tech Spec rounds, they could have detected the error earlier.
A contributing cause of the missed surveillances was that there was no peer check performed to verify the accuracy and correctness of the task performed by the reactor operator. If performed, a peer check had the potential to reveal the incorrect trip unit numbers specified on the information tag. Correction of this deAcient condition as a result of the peer review could have been accomplished prior to exceeding any Tech Spec and/or TRM time limits.
i III.
Corrective Steps Which Have Been Taken and Results Achieved The correct trip units were checked and channel checks were completed with j
e satisfactory results.
The information tag was removed and replaced with a tag which denoted correct e
trip units numbers.
The use of self verification techniques and the use of the peer checks was discussed e
with the reactor operator and shift supervisor.
The violation and use of peer checks were discussed with each shift via night orders e
and shift supervision.
Labels were permanently installed adjacent to each Control Room ventilation radiation monitor that is used for Tech SpecfrRM data collection and has an associated trip unit which senses the same parameter. The labels specify the trip
. =. -.
Attachment i12 CNRO-96/00142 PIge 2 cf 2
. w-units to be used for Tech Spec /TRM data collection when the recorder is out of uMm.
IV.
Corrective Steps to be Taken to Preclude Further Violations All corrective actions have been completed. No fmther actions are planned in response to this violation.
1 V.
Date When Full Compliance Will be Achieved All corrective actions have been completed.
l 4
1 h
I I
]
f i
i 1
0 3
4 1
,