ML20141M101
| ML20141M101 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/26/1992 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-92-00033, GNRO-92-33, NUDOCS 9204010102 | |
| Download: ML20141M101 (10) | |
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WW Entergy OperaHons,inc..
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W T. Cottle m ;-,
,..e March 26 1992 s
U.S. Nuclear Regulatory Commission Mail Station PI-137 Washington, D.C.
20555 Attention: Document Contral Desk
SUBJECT:
Grand Gulf Nucirar Station Unit 1 Docket No. 50-416 License No NPF-29 Report No. 50-416/92-02, dated February 25, 1992 (GNRI-92/00038)
GNRO-92/00033 Gentlemen:
Attached is the Entergy Operations, Inc, response to the Notices of Violation identified in NRC-Inspection Report 50-416/92-02.
The violations identified ir. the subject Inspection Report are areas which warrant improvement.
Entergy Operations is equally concerned about these areas is placing special emphasis on:
proper communications, attention to detail, teamwork, adherence to procedures, pride in your work and continuous improvement.
Since Entergy Operations is preparing for its fifth refueling outage, high performance in these areas is a necessity to have a successful outage.
These areas will continue to be monitored and management will continue to-explore methods-to preclude further occurrences.
Yours tr ly,
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. L-March 26.-1992 GNR0-92/00033 Page 2 of 3 cc: Mr._0 - C. Hintz (w/a)
Mr. R. B. McGehee (w/a)
Mr. N. ' S, Reynold; (w/a)
Mr. H. l.. Thomas w/o Mr. J. L. Mathis w/a Mr. Stewart D. Ebneter (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager (w/a)
Office of. Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C.
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-VIOL 9202.
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Attachment I to GNRO-93/00033 page 1 of 2 Notice of Violation 92-02-01 Technical Specification 6.8.1.a requires that written procedures i
be established, implemented and maintained covering the
~
applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 states that instructions for startup and shutdown should be prepared for the Standby Service Water System. System Operating Instruction (SOI),
j 04-1-01-p41-1, Standby Service Water Sysrom provides directions for stsrtup and shutdown of the Standby service Water (SSW) system.
Contrary to the above, on January 8, 1992, while shutting down the
'A' SSU system, the pump was not secured por the SOI and continued to pump water through the relief valve.
I.
Admission or Denial of the Alleced Vi_plation Entergy Operations,-Inc. admits to this violation.
II.
The Reason for tile _Eqlafig.ndf_Admittgj on January 8, 1992, while returning the SSW
'A' cystem to standby, operations personnel failed to stop the SSW
'A' pump, as required by procedure. The pump operated approximately 30 minutes with the discharge and recirculation valve closed. The only flow path available was through the dischargt relief valve upstream of the discharge isolution valve.
The failure of the operator to secure the pump was due to inattention to detail.
III.' The Corrective Steps Wltich Egye been TA)sen and the Epsults Achtsyng
'A.
A nonconformance report was initiated as a result of the incident. The Inservice Testing procedure was performed to verify operability of the pump. Based on the results of the east, the pump was declared operable. The relie. valve showed no sign of leakage during the test.
D.
A review of the SOI was performed to evaluate the need for changes. It was determined that-no procadural changes were necessary.
VIo.
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Attachment I to GNRO-92/00033 Page 2 of 2 4
C.
The operator involved was disciplined by Operations Management.
D.
Other operations personnel were nado aware of the incident with emphasis on attention to detail.
IV.
The corrective Steps Which Will De Tak.en To Prqplus9_
Further Violation A.
Entergy Operations feels that no further corrective actions are warranted at this time.
V.
Date When Full compliance Will De Achieved All corrective actions have been completed.
Attachment II to GNRO-92/00033 Page 1 of 3 Notice of Violation 92-02-02 Technical Specification 6.8.1.a requires that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 requires that Administrative procedures be in place for authorities and responsibilities for safe operation.
Operations section Procedure 02-S-01-17, control of Limiting Conditions for Operation, Section 2.1 states that the shift supervisor is responsible for documenting situations which exceed the Limiting conditions for Operations described in Technical Specifications.
Contrary to the above, on January 14, 1992, the shift supervisor fail to recognize, or document entering a Limiting Condition for Operation when work was authorized on a containment isolation valve (RHR A Suppression Pool Suction Valve) which rendered the valve inoperable.-
I.
Admisgion or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
II.
The Reason for the Violatiqn, If Admitted On January 14, 1992, work was authorized by the operations shift supervisor on the
'A' Residual Heat Removal suction valve from the suppression pool. The scope of the work order
-(WO) was to investigate the failure of the valve to open after being-giving an open signal. In the WO, maintenance personnel were instructed to calibrate the thermal overloads in accordance with plant procedure 07-S-12-82 if calibration was necessary.-The plant procedure requires that the breaker for the overload device be de-energized.
During the conversation between the shift supervisor and Electrical Maintenance personnel, the supervisor did not realize the-full scope of the work to be performed, in that the breaker for the valve would be opened during the evolution, thus rendering the valve inoperable during the maintenance.
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Attachment II to GNRO-92/00033 Page 2 of 3 The cause of-the incident was poor verbal communication and work practices by the shift supervisor.
The shift supervisor involved wes not normally assigned to shift and-was standing a quarterly proficiency watch (QPW),
which is required to maintain an active Senior Reactor Operator (SRO) License. The QPW ia the mechanism used to enhance the work skills and verba.. communications of the licensed personnel not normally assigned to shift.
Operation management expectations are that extra controls be exercised by the remainder of the shift management crew, and a heightened awareness in the control room when QPWs are being performed.
The controls were successful in identifying the improper evaluation, after the work was started.
Controls also ensured the proper LCO was documented and appropriate actions were taken by the shift to place the valve in a position that met the !CO action statement within the required time limits. However, tne controls were not effective in ensuring the work was properly evaluated before the work started.
III. The Cqrrective SteDs Which Have bee _p Talen and thg_
Rengits Achieved A.
The shift supervisor and the two other SROs involved were removed from shift and retrained.
Proper verbal communications and work practices were emphasized to the shift supervisor.
Operations management's expectations of controls and heightened awareness during-QPWs wera emphasized to all SROs.
Following training, the personnel involved were placed back on shift.
B..
Other operations personnel were nade aware of this incident.
Management expectations during QPWs were-communicated to the shift management on other crews and the SROs who are currently standing QPWs.
C.
The shift supervisor was counselled on the occurrence.
IV.
The Co.rrective steps Which Will Be T.Aken_To Pr.e_clude Further Violation A.
Entergy Operations feels that the above corrective actions are appropriate to preclude recurrence.
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Attachment._II-to GNRO-92/00033 Page 3 of 3' V.
Date When FulLQpmD11anc.g W111__1LQqhieve_4 All corrective accions have been completed at this time.
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Attachment III to GNRO-92/00033 Page 1 of 3 Notice of Violation 92-02-03 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may necessary for the licensee to comply with the regulations in 10 CFR Part 20 and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Technical Specification 6.12.2 requires, in part, that areas accessible to personnel with radiation levels such that a major portion of the body could receive in one hour a dose rate greater than 1000 mrom shall be provided with locked doors to prevent unauthorized entry and that these doors shall remain locked except during periods of access by personnel under an approved Radiation. Work Permit (RWP) which shall specify the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in that area.
Contrary to the above, on November 13, 1991, an entry was made into a posted Transient Very High Radiation Area greater than 1000 mrem /hr en an RWP that did not authorize Very High Radiation Areas. Although radiological conditions may not have been greater than 1000 mrom/hr at the time of the entry, a survey for gamma t
done was not performed to evaluate the extent of the radiation hazard that was present.
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I.
bgmission or Denial of the Alleced Viglatign Entergy Operations, Inc. admits-to this violation.
e' II.
--Th_e Reason for the Violation, If Admittad The following occurrence was identified by a recent Quality Programs audit of the HP department.
On October 24, 1991, a Health Physics (HP) technician provided coverage for a weekly operations surveillance of the drywell airlock door seals. The surveillance requires entry into an area that is posted Transient Very High Radiation (TVHR) Area. The HP technician entered the area on a RWP that did not address the entrance of personnel into TVHR areas and performed an inadequate survey (e.g.,
no gamma survey was performed).
- ~, __
Attachment III to GNRO-92/00033 Page 2 of 3 Following the HP survey, Operations personnel entered the area to perform the surveillance on an inappropriate RWP due to the HP technician not re-posting the area.
A normal work practice of the HP section is to survey the area with a portable monitor; then re-post the area if the results of the survey permit. In this case, the HP technician failed to perform this duty.
The HP supervisor considered the assignment to be a routine evolution and did not consider the new employee's lack of experience. Therefore, the pre-job briefing did not include details to reinforco *he requirements to ensure the task was adequately performed.
There are three causes associated with the occurrence.
The failure.of the HP supervisor to conduct an adequate pre-job briefing.
The technician was not familiar with potential radiological hazards which existed in the traversing in-core proben (TIPS)-area. This particular task was not a part of tho qualification card. Therefore, the technician was not familiar with TIPS nor the task.
The technician had the mindset that there was no potential for.a gamma hazard due to having verified that the TIPS were red tagged in their stored position.
III. : The CorrJetive Steps Whic. h Hnve beeJ1_Taken and the _
Ecpults Achievqs A.
UP lab personnel were trained with an emphasis on the need for adequate pre-job briefings and surveys.
B.
A standing order was issued and training was conducted with the HP supervisors stressing the importance of 1considering the cualifications and experience of personnel prior to the assignment of tasks.
C.
The -HP supervisor was counseled on the intportance of documenting deficiencies when they are identified.
o Attachment III to GNRO-92/00033 Page 3 of 3 IV.
TA9_qqrIgg_qily_9_picp3 Which_]illl Bo Taken To PrecJ3Lt1L FurtheL Violatica A.
The proper IIP practices concerning access to (transient) VilR 1rean (e.g. TIPS area) Will becomo a part of the qualification training of IIP technicians.
V.
Date When Fyl.L Qompliango Will D3_hghi_9vod The action will be implemented by April 30, 1992.
.