ML20141J395
| ML20141J395 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/22/1997 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-97-03, 50-416-97-3, GNRO-97-00045, GNRO-97-45, NUDOCS 9705280069 | |
| Download: ML20141J395 (4) | |
Text
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Enttrgy Oper:Uons,Inc.
Z" PO. Box 756 Port Gibson. MS 39150 Tel 601437 6408 i
Fax 601437 2795 Joseph J. Hagan Vice President May 22, 1997
$*nTC %e,3,31,n i
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 i
Response to Notice of Violatiori 50-416/97-03-01, Failure to Follow Procedure Report No. 50-416/97-03, dated 04/24/97, (GNRI-97/00058)
GNRO-97/00045 i
1 Gentlemen:
l Notice of Violation (NOV) 50-416/97-03-01 cited Grand Gulf Nuclear Station (GGNS) for failure to follow procedure in that stepe contained in GGNS administrative procedure to initia<e a condition report (CR) upon discovery,f a deficiency were not timely.
The NOV presented the re.. 3n for the violation as personnel wanting to start their long weekend, l
therefore delaying initiating a CR until the following Moncay. This incorrect conclut. ion resulted from a j
miscommunication during a meeting between NRC inspectors and involved perso;1nel. This has been discussed and clarified with the inspectors. Additionally, in a discussion with Mr. Pat Gwynn, Director, l
Division of Reactor Safety, we were advised to request a review of the miscommunication issue. As l
such, this review is requested.
l There were other complicating factors that led to this violation. The fact that the condition in question had been previously identified in deficiency documents as a generic issue, gave personnel the false l
assurance that operability had already been addressed. Additionally, the concepts of immediately and promptly are more easily defined and applied to new items of discovery and there was a general feeling that this was not a new item due to the previous history. GGNS recognizes the importance of rigorously following the non-conformance process and that required reviews may not be bypassed. As such, actions are being taken to ensure all personnel are fully aware of the procedural requirements and expectations in this area.
9705280069 970522 SR ADOCK 050004 6 l lll hf 2700G0
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l May 22, 1997 GNRO-97/00045 l
Page 2 of 2 i
GGNS acknowledges that initiating the CR upon discovery of the condition would have prevented the l
circumstances which led to this violation. Therefore, GGNS admits to this violation and the '
l attachment to this letter contains the GGNS response to NOV 50-416/97-03-01, Yours truly,
+ x xy JJH/JEO/jeo attachment Response to Notice of V;olation 50-416/97-03-01 i
cc:
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Ms. K. D. Weaver (NRC Resident) (w/a)
Mr. J. W. Yelverton (w/a) j Mr. Ellis W. Merschoff (w/a) j l
Regional Administrator Region IV l
U.S. Nuclear Regulatory Commission l-611 Ryan Plaza Drive Suite 400 e
- Arlington, TX 76011 f
Mr. J. N. Donohow, Project Manager (w/2)(w/a)
Office of Nuclear Reactor Regulation
{
U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 1-l l
i i
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Attachment to GNRO-97/00045 i
Page 1 of 2 Notice of Violation 97-03-01 Technical Specification 5.4.1.a. states, in part, that written procedures shall be i
implemented covering the applicable procedures recommended in Appendix A of J
Regu'atory Guide 1.33, " Quality Assurance Program Requirements (Operations),"
Revision 2, February 1978.
Item 1 of Appendix A to Regulatory Guide 1.33 recommends administrative procedures covering safety-related activities.
Administrative Procedure 01-S-03-10, "GGNS Condition Report (CR)," Revision 0, Paragraph 6.1.1 stated, in part, that any individual or organization at Grand Gulf 4
Nuclear Station shall initiate a condition report whenever a non-conformance, material non-conformance, or potential reportable event is discovered.
Contrary to the above, on February 27,1997, a design engineer failed to implement the requirements of Procedure 01-S-03-10 in that a non-conformance was identified i
in the leak testing of the containment isolation valves associated with the residual j
heat removal system test return piping to the suppression pool and a condition report was initiated four days later, not when the non-conformance was identified.
This is a Severity Level IV violation (Supplement 1) (50-416/9703-01).
l.
The Reason for the Violation,if Admitted On March 3,1997 a Condition Report (CP) was initiated to address Design Engineering concerns with the method for leak rate testing certain containment penetrations. Notice of Violation (NOV) 50-416/97-03-01 was issued when the NRC Resident inspector was informed by the initiating design engineer that the condition was identified on, February 27,1997.
This was four days prior to initiation of a CR. The delay in initiating the CR did not allow Operations to perform a timely operability review.
Investigation determined that policy guidance / management expectations were not well defined or understood. Plant administrative procedure specifies that a CR be written whenever a deficiency is discovered. The importance of timely initiation of a CR was missed by persons involved in this event.
Persons involved did not recognize the need for initiating a CR right away due to the fact that containment penetrations had been addressed earlier as part of a generic issue. Discussion held at the time of the decision to dehy the CR concluded that no new operability concern was raised by the containment penetrations in question.
t Attachment to GNRO-97/00045 Page 2 of 2 d
initiating a CR upon discovery of this condition, in accordance with existing procedure, would have provided operations the opportunity to perform a 4
timely operability review.
II.
Corrective Steps Which Have Been Taken and Results Achieved 1.
The Director, Design Engineering, transmitted a memo on March 27,1997 to Design Engineering personnel definirig his expectations and procedural requirements when non-conformances are identified.
2.
Expectations for timely initiation of problem resolution through the CR process was discussed with GGNS personnel during the April 16,1997
'Standdown' meeting.
3.
Accountability meetings have been conducted with the individuals involved These actions have raised the awareness of select plant personnel and clarified procedural and management expectations concerning timely initiation of CRs.
Ill.
Corrective Steps to be Taken to Preclude Further Violations 1.
Plant Management will issue a memo to plant personnel defining condition report expectations.
2.
Engineering manangement will conduct training with engineers covering the condition report initiation process.
IV.
Date When Full Compliance Will be Achieved All actions are scheduled to be completed by June 16,1997.