ML20134D157
| ML20134D157 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/11/1996 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20134D150 | List: |
| References | |
| NUDOCS 9610150120 | |
| Download: ML20134D157 (4) | |
Text
Entsrgy opsrations,Inc.
C. R. Hutchinson i
p g
September 11,1996 SEPl6 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Response to Notices of Violation 50-416/9611-04 Report No. 50 416/9611, dated 08/12/96 (GNRI-96/00168)
GNRO-96/00104 Gentlemen:
Entergy Operations, Inc. submits the response to Notices of Violation 50-416/9611-04.
Notice of Violation (NOV) 50-416/9611-04 stated that Grand Gulf Nuclear Station (GGNS) was in violation of Criterion V of 10 CFR Appendix B, which states in part, that activities affecting quality shall be prescribed by documented procedures and drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures and drawings.
Guidance for development of such procedures, drawings, and instructions is contained in Regulatory Guide (Reg Guide) 1.33, revision 2, section D. 4. This section states, in part instructions for energizing, filling, venting, draining, startup, shutdown and changing modes of operation should be prepared, as appropriate. Listed under item w. (2) (a) is Emergency Power Sources (e g., diesel generator, batteries).
Procedures in effect at the time of the subject violation met the requirements of Reg Guide 1.33 for the Standby Diesel Generators. Therefore GGNS considers the requirements of 10CFR Appendix B Criterion V as having been met and denies Notice of Violation 416/9611-04.
Yours truly, n 0, G. A'.H. tch s.,
CRH/JEO/
attachment:
Response to Violation 50-416/9611-04 cc:
Mr. J. E. Tedrow (w/a)
Mr. R B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. J. W. Yelverton (w/a)
(Continue Next Page) l 9 4,5 9610150120 961009 363 PDR ADOCK 05000416 G
4 September 11, 1996 GNRO-96/00104 Page 2 of 3 t
l cc:
(Continued)
Mr. Leonard J. Callan (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 P an Plaza Drive, Suite 400 t
Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 l
i
Attachment to GNRO-96/00104 Page 1 of 2 Notice of Violation 9611-04 Criterion V of Appendix B to 10CFR 50 states, in part, that activities affecting quality shall be prescribed by documented procedures and drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures and drawings.
Contrary to the above, an activity affecting quality was not properly prescribed by procedures appropriate to the circumstances in that Procedures 06-OP-1 P75-M-0001, " Standby Diesel Generator 11 Functional Test," Revision 100 and 06-OP-1P75-M-0002, " Standby Diesel Generator 12 Functional Test," Revision 100, did not provide direction for properly maintaining the oil level in the govemor or for periodically checking the govemor oil level during operation of the standby diesel generators.
1.
Admission or Denial of the Alleaed Violation Entergy Operations, Inc. denies this violation.
11.
The Reason for the Violation Denial On April 24,1996 the monthly surveillance test of the SDG was performed with a visiting resident inspector observing. After the SDG was started the visiting inspector noted that the govemor oil level appeared to drop out of the indication range of the sightglass. The inspector questioned the system engineer about the operation of the govemor and proper oil level to be maintained in the sightglass while the SDG was in operation. Later the inspector noted a sticker on the govemor pertaining to oil level stipulations. The inspector reviewed the surveillance and daily rounds and concluded that the procedural controls were deficient in that they failed to provide adequate procedures for ensuring continued operation of the SDG. This resulted in the issuance of Notice of Violation 50-416/9611-04.
The notice of violation stated that procedures "did not provide direction for properly maintaining the oil level in the govemor or for periodically checking the govemor oil level during operation". Grand Gulf Nuclear Station (GGNS) maintains that the procedures in place prior to the April 24,1996, event did provide for maintaining oil level and did call for periodic monitoring of govemor level. GGNS procedures 06-OP-1P75-M-0001 and M-0002 did call for verifying proper oil level prior to SDG start. The Building Rounds required monitoring govemor oil level daily. These procedures are only for performing surveillance (one hour runs) and do not require extended run times for the diesels.
O i
Attachment to GNRO-96/00104 Page 2 of 2 The vendor manual for the SDG did contain information related to the govemor, however this information did not contain information on specific frequency for monitoring of the i
govemor oillevel. Only after contacting the sub-component vendor and reviewing a manual not supplied by the vendor (Cooper) was a recommendation discovered to check the govemor oillevelimmediately following start-up of the SDG.
GGNS believes that the approved vendor for the SDG is the proper source for information used in the development of procedures. Information from other sources, including sub-component stickers should be reviewed by the SDG vendor prior to use to ensure that it does not adversely affect the original SDG design qualification.
As always, GGNS looks for improvements that can enhance the safety and reliability of its equipment. We therefore appreciate the feedback from the visiting resident inspector related to monitoring of the SDG govemor oil level. We agree that there was room for SDG procedural enhancement in this area and changes have already been made.
However, GGNS does not believe this situation constitutes a violation as cited in inspection report 50-410/9611.
Ill.
Corrective Stoos Which Have Been Taken and Results Achieved Changes were made to Operations SDG Standard Operating Instruction, and monthly surveillance procedures to include specific written criteria for maintaining governor oil j
levels and for level monitoring frequency while the SDG is running. Also, written guidance for adding oil to the govemor was included in the changes.
Changes were made to Operations Daily Round Criteria for the diesel govemor to verify sightglass oillevelis within 1/8 inch of the top of the sightglass.
N.
Corrective Stoos to be Taken to Preclude Further Violations SDG 18 month surveillance and operability verification surveillance will be changed prior to completion of RF08.
V.
Date When Full Compliance Will be Achieved All actions are scheduled to be complete by the end of RF08.
l
-