ML20198N934
| ML20198N934 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/14/1998 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-97-18, GL-86-10, GL-88-12, GNRO-98-00005, GNRO-98-5, NUDOCS 9801210260 | |
| Download: ML20198N934 (10) | |
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Entergy operations inc.
=Entergy PO. box 766 Port Gibun MS 3940
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Joseph J. Hagan v4e P<ese U Une sen January 14, 1998 U.S. Nuclear Regulatory Commission Mail Station P137 Washington, D.C. 20555 Attention.
Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Dockei No. 50-416 License No. NPF-29 Reply to a Notice of Violation Report No. 50-416/97-18 (GNRI 97/00190), dated 11/25/97 GNRO 98/00005 Gentlemen:
Entergy Operations, Inc. is hereby submitting the response to Notice of Violations 50-416/97-18 02 and 03. This Notice of Violations was issued as a result of NRC Insprntion Number 50-416/97-18, conducted during the period J August 4,1997 through August 22,1997 at Grand Gulf Nuclear Station.
Entergy Operations takes its responsibility for operating and maintaining the Grand Gulf Nuc'63r Station very seriously. Part of this responsibility includes correcting conditions adverse to quality if the identified conce n is in non-compliance with NRC regulations. Given the need to be responsive and non argumentative, Entergy Operations takes extraordinary care with denying a vlotation.
Given our responsibility for ensuring compliance with our licensing basis, we have carefully evaluated the identified violations and must deny both as further explained in the attached reports. For vio!ation 97-18-02, Entergy Operations is having difficulty undeistanding the NRC's position that an individual component failure can be construed to be a failure to maintain and implement a comprehensive program, such as the fire protection program. Especially given that in the described incident, it was our program which caused the identification and rework of the component.
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GNRO-98/00005 Page 2 of 2 We have even greater difficulty understanding how the issues raised by us in our Quality Frograms audit of the Fire Protection Program placed the plant outsides its design basis. We believe that the plant was capable of shutting down, cooling down, maintaining shutdown and mitigaung the consequences of an accident despite the discrepancies found during the Quality Programs audit.
Because of this, we respectfully deny the two violations contained in Notice of Violation 50-416/9718.
vours truly, l
CEBIcg/
attachment:
1)
Response to Notice of Violation Number 50-416/97-18-02 2)
Response to Notice of Violation Number 50-416/97-18-03, with Addendum - Summary of Conditien Reports cc:
Ms. J. L. Dixon-Herrity, GGNS Senior Resident (wla)
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (wlo)
Mr. E. W. Merschoff (wla)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory *,ommission Mall Stop 13H3 Washington, D.C. 20555
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GNRO 98/00005 Page 1 of 3 Response to Notice of Violation Number 60 416/9718 02 Amendment 82 to NRC License Nc. NPF 29, Grand Gulf Nuclear Station Unit 1 Facility Operating License Condition 2.C.(41), requires the licensee to implement and maintain the 6pproved Fire Protection Program as described in the Updated Final Safety Analysis Report.
Grand Gulf Nuclear Station Updated Final Safety Analysis Report Section 9.5.3.2.3,
- Emergency Lighting Sys;em,' Revision 10, states, in part, that
- Backup de lighting with battery packs are provided for areas essential to 'he operation of equipment required for safe shutdown as tabulated in Table 9.515 and along access routes between these areas where critical tasks are carried out during emergencies." Table 9.5-15 lists the access routes to the auxiliary building elevation 119 foot electrical switchgear rooms as an area where emergency lighting is provided.
Contrary to the above, on or about the period of January 17 29,1997, the approved fire protection program as described in the Updated Final Safety Analysis Report was not fully implemented. Emergency Light 1T92S222A, an emergency light that was describod in the Updated Final Safety Analysis Report approved fire protection prograrr, and provided along the access route to the switchgear rooms, was t'ot capable of performing its function and no compensatory actions had been taken.
This is a Severity Level IV violation (Supplement 1) (50-416/97-18 02).
1.
Admission or Denial of the Alleged Violation Entergy Operations, Inc. denies this violation.
Basis for Denial GGNS Licensing Bases:
The plant lighting system is described in Section 9.5.3 of the Updated Final Safety Analysis Report (UFSAR). This description details the three subsystems which comprise the lighting system. The subsystems are a) normallighting (AC and DC), b) essentiallighting (AC) and c) emergency lighting (DC). UFSAR Table 9.515 Lighting System Tabulation provides a listing of these systems by location and type for easy comparison.
UFSAR Sect!ons 9.G.3.2.1
- Normal Lighting System',9.5.3.2.2
- Essential Lighting System',
and 9.5.3.2.3
- Emergency Lighting System", provide an in-depth description of each subsystem, including their function.
UFSAR Section 9.5.1.6, ' Equipment Operability", explicitly identifies GGNS's requirements for compensatory measures and operability considerations with regards to fire protection equipment. This section refers to UFSAR Appendix 16A for specific requirements removed from the Technical Specifications and relocated to the UFSAR per Generic Letters 86-10 and 88 12.
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Att:chment 1 to:
GNRO 98/00005 Page 2 cf 3 UFSAR Section 9.5.3.4, " Tests and Inspect;ons', stipulates the performance of weekly tests and inspections of the DC Lighting System to ensure operability of the automatic switches and other components of the system.
UFSAR Table 9.511, ' Fire Protection Program Comparison With NRC Requltements',
delineates the specific methods for compliance with NRC requirements. This table details Quality Assurance requirements cnd implementation plans for the Fire Protection Program.
GGNS Position:
Approval of the G and Gulf Fire Protection Program was received via Amendment No. 82 (on August 23,1991) to Facility Operating License NPF 29. The licensing basis as described above is virtually unchanged from that approved by the NRC in the associated Amendment *2 Safety Evaluation P.eport. The specific part dealing with emergency lighting has not changed from that submitted for NRC review and approval.
The approved plan contains the operability and compensatory requirements for those portions of the Fire Protection System as specified in UFSAR Appendix 16A. This section of the UFSAR has neier included requirements for the Emergency Lighting System. Since this section consin of the verbatim transfer of information from the Technical Specifications, it is clear that there has never been a requirement for establishing compensatory measures fur inoperable emergency lighting expressed by the NRC prior to this inspection report, i
The Grand Gulf Fire Protection Program does require that the Emergency Lighting System fall under the Quality Assurance Program as detailed in tne UFSAR Table 9.511, Section C.2 (Startup Testing and Operational Phase). This UFSAR section invokes Policy 16-Corrective Action of the Quality Assurance Program as a means to ensure proper operation and maintenance of the Emergency Lighting System at GGNS.
l The Corrective Action Program allows the utilization of Condition Identifiers (Cis) and Work l
Ordert. (WOs) to document and repair maintenance items at GGNS. As stated la the inspection report, it was the Corrective Action Program that identified the deficiency and ensured that the emergency light in question was restored to operable status in approximately 12 days from time of discovery.
GGNS also reviewed the stated violation in terms of timeliness of corrective actions. Given the lack of explicit guidance, we could question the approximate 12 days that the light was out of service in terms of its timeliness. Timeliness is a function of the safety significance of the l
issue. Given that the subject emergency light provided light only for access routes and did not l
directly support the performance of any critical tasks, we have concluded that the 12 days was timely. Therefore, it would appear that the Corrective Action Program worked just as expected. A deficiency was documented and corrective actions in a time period commensurate with the safety significan, of the issue were taken.
Given the defense in depth afforded by the three separate lighting systems described in UFSAR Section 9.5.3, the impact on safety for having one non functioning backup emergency light has a negligible impact on the ability to achievs and maintain safe shutdown of the plant m the event of a fire.
Att:chmInt i to:
GNRO 98/00005 Page 3 of 3 Additionally, the Off Normal Event Procedure ' Shutdown From The Remote Shutdown Panel *, 05-1-02-ll 1 Revision 24, contains a note alerting the operators to carry an emergency flashlight in case of a loss e. offsite power as an added layer of defense. While possession of portable lighting is not intended ar, a replacement for fixed emergency lighting, this contingency plan invoked on an intermittent basis, in oui spinion, provides a comparable a
mechanism for satisfying the intent of 10CFR50 Appendix R, Section Ill.J.
Since 10CFR50 Apoendix B provides licensees a permissiveness to determine
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timeliness of corrective action based upon the importance to safety of a particular structure, system or component and that the approved Grand Gulf Fire Protection Program has never contained a requirement for establishing compensatory measures for inoperable emergency lighting, Entergy Operations denies the stated violation.
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Att2chment 2 tm GNRO-98/00005 Paga 1 of 2 Response to Notice of Viclation Number 50-416/9718 03 10 CFR50.73,(a)(2)(ii)(B) requires. In part, that a licensee event report be submitted within 30 days after discovery of n "mdition of the nuclear power plant that is outside the design basis of the plant.
Contrary to the above, as of August 22,1997, the licensee had not submitted a licensee event report for conditions thrst resulted in the fire protection system being i
operated outside the design basis cf the plant. These condit!ons included numerous fire protection program violations identified in Quality Systems At.:it Report QPA 09.0197, dated April 14,1997. The audit found that the fire protection program was not being adequately implemented and identified numeaus conditions that deviated from fire protection system design basis described in the Updated Final Safety Analysis Report.
This is a Severity Level IV violation (Supplement l} (50-416/97-18-03).
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Admission or Denial of the Alleged Violation Entergy Operations, Inc. denies this violation.
Basis for Denial 4
This violation is for failure to report, in an LER, problems found during an assessment of the Fire Protection Program. The inspector be!ieved that these problems represented a condition that was 'outside the design bases of the plant'. The reporting requirement for this condition are 10CFR50.73.(a)(2)(ii) and 10CFR50.72(b)(1)(ii).
As noted in the statements of considerations for 10CFR50.73(a)(2)(ii) and 10CFR50.72(b)(1)(ii) these reporting requirement entail the paragraph of each respective regulation in its entirety. When this paragraph is interpreted in this manner and utilizing the clarifications in the statements of consideration and NUREG 1022 (Rev.
0), the intent of this reporting criteria is clearly for conditions where the plant was seriously degraded or in an unanalyzed condition. We believe that while the Fire Protection Program Audit identified numerous concerns, the cumulative items identified do not represent a condition that satisfies the reporting threshold of 10CFR 50.72 and 10CFR50.73. Rather the issues documented in the fire protection audit are a reflection of our rigorous and comprehensive corrective action program coupled with our strong commitment to exceeding regulatory requirements. In fact, one of the conclusions stated early in the audit report was that all regulatory requirements were met and thus correcting any noted deficiencies identified during the audit would have been considered program enhancements.
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Att: chm:nt 2 to:
GNRO t$/00005 Page 2 of 2 Specifically, the audit report concluded that the Fire Protection Program meets the intent of Branch Technical Position APCSB 9.5.1 and applicable regulations. While the report does go on to say that the fire protection program is not being adequately implemented based on the number of deficiencies documented during the audit, a review of the deficiency documents found them to be mainly administrative issues or deviations from strict interpretations of the procedures, with no adverse impact on plant safety or the functionality of the fire protection system.
Additionally, we interpret that the phrase "outside the design basis of the plant
- to mean the inability of the plant to 1) shutdown the reactor and maintain it in a safe shutdown condition; 2) remove residual heat: 3) control the release of radioactive material; or 4) mitigate the consequences of an accident. For fire protection, the design basis is Criterion 3 fire protection. Specifically, Criterion 3 requires that structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
Noncombustible anct heat resistant materials shall be used where ever practical throughout the unit, particularly in locations such at the containment and control room.
u det9ction and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Fire fighting systems shall be designed to assure that their rupture or inadvertent uperation does not significantly impair t.5 safety capability of these structures, systems, and components.
The 10 CRs referenced in the audit report are summarized in the Addendum to this attachment. Of the 10 CRs written,4 were related to penetrations / separation criteria. Of these 4 CRs, only 2 CRs required entry into a TRM LCO. Two of the CRs were found to be of no issue. Of the remaining 6 CRs, 3 CRs were administrative problems,2 CRs were not related to the fire protection program and the remaining CR dealt with back-flow through floor drains. While the drains required repair, this condition did not prevent the fire protection system from perfc. ming its intended function.
Taken as a group, none of the CRs were reportable; as noted, only 2 CRs required entry into a TRM LCO. While some repairs were required, the ability of the fire protection system to perfc>m its intended function was never compromised. Thecefore, the plant was not outside, of its design basis as a result of the CRs referenced in this audit.
It is Grand Gulf's opinion that the cumulative effect of the issues documented in Quality Assurance Audit Report OPA 09.01-97 do not represent a significant problem with the fire protection system that would prevent the plant from meetir g its design basis. Further, we do not believe it to be consistent with generalindustry practice to report a condition as "outside the design basis of the plant
- simply based on the number of issues identified. Rather eacn individual issue and the curnulative affect must be reviewed for impact on the ability of the plant to perform its intended design basis. Given that the fire protection system was never degraded to the point that it would have significantly impacted the ability of the plant to perform its intended design function, Entergy Operations denies the stated violation.
Add ndurn to Att:chrn:nt 2 of:
GNRO 98/00005 Page 1 of 3 AUDIT'DATF5:
January 27, through February 28,1997 During the audit there were 11 negative finding with 10 resulting in CRs (Condition Reports) and 1 being corrected during the audit. It did not affect quality or safety.
There were 11 Cls (Condition Identifiers) written during the audit. The details can be found in the respective sections of the report.
%'i CR Number Date Written Summary GGCR1997-0146-00 2/11/97 Approximately 1/2' dia'neter hole through the wall that separates the Division 1 electrical switchger.r area (SZ100C202) ar.d the Div 311attery Room (SZ100C209) ref. A 0851 & A 0630). SZ10 structure, IPMD207 CO2 deluge system. Dettrmined to be not reportchie.
GGCR19970180-00 2/24/97 &
Four fire brigad: members went beyond the 3 month regular
& GGCR1997-01f,0 2/27/97 planned meetings criteria in 1996. 10-S-03 'I section 6.5 states. -
cach brigade member shall attend regular e, d meetings at ! cast 01 every three months. Ilowever, according to FSAR 98.8.1. Sentence 3 refrcsher training will be conducted quarterly.
According to the way the quarterly meetines are being applied, a fire brigade member could have a meeting m the first day of one J
quarter then they could have one the last day of the next quarter.
j This CR is still open. Fire Brigade members also did not retain qualifications from participation in required drills. These were intermittent and/or administrative issues and had no impact on the design basis of the plant.
GGCR19970216-00 3/5/97 Fire protection audit / walk down identified several concerns : (1) air flowing up through drains into Control Bldg. Air source appears to be sewer gases from the Control Bld sanitation sump. Sump t
level control appears within settings of Cotnponent Data Base (CDB), however floor d,ain piping in'.o sump is above watet level.
Appears 93' ilVAC is at a higher pressure than upper eley's.
Possible contributi'g causes appear to be associated with IIVAC lineup, flow balance, Bldg press & design / condition of Control Bldg sanitation sump / floor drains. Drains with dry leg drains have a reverse water flow valve but no functional scaling mechanism against air flow. Air flow in could affect CO concentratian after 2
deluge, carry CO to a non-desirable area, reduce overall air 2
quality & carry a variety of heahh hazards. Evalm closing SZl8F001 A to prevent possible interface with sewer system gases, sump has a non working backflow preventer ref WO4183574.(2) noted deficiencies: loss / partial loss of loop seals on 111' in Div 2 Ba'kry Room & ESF Swgr area drains; ref. M A0075, M-0220.Elev 148' & 189' cable spreading area drains missing cover grates, backflow preventers not restrictirg air flow, some backflow preventers missing. Tho.e with missing covers may restrict floor debris from getting into them.
Potentially affected Systems are PM, Zi7, Z51,277, Zl8, P46.
(3) Control Bldg generic implications, suggested corrective action
- verify drains ability to flow - reference Control Bldg flooding calculations, replace missing / damaged / non-functional : covers
& backflow preventers, refill drains with loop seals. evaluate
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Addendum t3 Attachment 2 of:
GNRO 98/00005 Page 2 of 3 GGCR1997 0216 l
Control Bldg flVAC flow balance, evaluate operating level of 1
sanitation sump, evaluate installing a loop seal internal to the Continued Sanitation sump for those drains with dry legs. Evaluation found that did not effect fire protection, repairs are needed for some components.
GGCR19970218-00 3/5/97 Potentially t'.egraded file barrier & missing conduit fire / gas seal.
r item # 1: potentially degraded CMU wall 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire barrier. 93 '
Control Bldg access area llVAC Room SZ100Cl25 cast wall which separates the 11VAC toom from the li.P. Supervisors office & the ll.P. Break Room. Approx.10 holes, 8 being approx.1/2' in dia
& 2 being approx. 3/8' in dia. These holes require grouting. The holes appear to be from through bolts, all thread rod being removed, 4 holes could be verified to have been grouted on one side, being the side of the wall in its adjacent room. Jtem #2 :
empty Div i conduit IBDR$ABil, approx. 5' conduit, is pulling air up through it. 148' Control Bldg Unit 2 side. De conduit gows up through electrical chase on 166' to a lloffman caclosue in the electrical chase behind SAS. On Elev 177', Could not determine the destination the conduit leaving the enclosure box on 177'. TRM LCO entered Determined to I. not reportable.
GGCR1997-0222-00 3/6/97 During audit QPA 09.0197 it was discovered that there are approximately 144 MWO type CI's, with approximately 120 having not been fully assigned. Some of these CI's are up to 5 years old. From looking at these CI's on the SIMS screen it appears that a majority of the CI's have never been screened or perio tically reviewed or status updated. This is in violation of 07 S-01205, sections 2.6 and 2.7,15-S-01 1, section 6.2.3 and 15-S41 101, section 2.4. These were considered to be minor issues.
Iktermined to be not reportahic.
GGCR19970243-00 3/11/97 Violation of Divisional separation ref ES02 steps 6.2.2 & 6.3.1 being I' & 1* minimum separation. Criteria for this application when less than l' requires that both divisions cables be fully enclosed by either a conduit or a solid & covered cable tray.
ESF Div i & ESF Div 2 electrical divisional & fire protection separation criteria. Div 1 conduit IBARNR07, control Bldg to aux. Blds penetration enclosure box IBAA0T21 cover is open exposing approx. 6* to 8' of the Div i cable. This Div 1 enclosure cover cannot be closed without removing the cover from its hinge due to its proximity to & interference wkh Div 2 covered cat >le tray IBBMS10. The approximate distance betweco these two items is less than l'. Evaluation found not to be a fire issue; not reportable.
GGCR19970245-00 Potentially non evalcated seismic concern. Several large power cables that appear to be spared are hung over the southeast structural steel support that braces the south CMU wall & the ends of the cables are laying on cable tray these large power cables appear to originate from cable tray IBET2,QZA which provides a drop into 1521901 though no cables were actually observed to be entering the feeder breaker from this tray. The cab!cs leave tray IBETDZQA travel approx. 3' in air crossing the south wall upper support brace and continue to tray _,TWQ16(pa-tial #) where they dead end a spares. Evaluation by engineering found no concern exists.
l Addendum to Attachment 2 of; C'
GNRO 98/00005 Page 3 of 3 GGCR1997-026100 3/13/97 Penettnion CE-261D is not scaled as shown on drawing A 0873A.
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This penetration is located in the east wall of room OC406, Control Bldg. Elev 148-0, area 258. Thi. cmiition was highlighted during QPAN.0197. Erni ist,a found a fire barrier was not neceer.aryl changed Fire Protectice Prap.
GGCR1997-0283-00 3/19/97 Possible tobacco usage in the control Bldg 189 elev. Ref housekeeping procedure 01.S-07 9. Discovered during audit QPA.
I 09.0197. Copenhagen can found in Z77 IWAC Room OC 708, j
southwest corner, under duct work.
A s suple of the unistrut cable tray support bases anchored to the floor are darker & it appears that there may have teen tobacco i
products spit on them since the last time they were cleaned. This r
area also appears to meet a,es cleanliness other than mentioned above and the unistrut bracing mentioned does not ap; war to have had any additional increase in buildup since originally obsen>ed.
Management restricted the presence of Tobacco and food into the power block.
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