ML20199H756
| ML20199H756 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/21/1998 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-97-21, GNRO-00009, GNRO-9, NUDOCS 9802050115 | |
| Download: ML20199H756 (5) | |
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Entergy Operstlor:2,Inc.
PO tion 7!4 h hh Pwl Git,t.ott MS :0150 C
Tel 001437 6408 F or 601437 270'.
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h u=y21.1998 0.*O w.... -
U.S. Nucient Regulatory Comminion Mail Station PI 37 Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit i Docket No. 50-416 License No.NPF 29 Reply To A Notice Of Violation Report No. 50-416/97 21 (GNRI 97/00195), dated 12/05/97 GNRO 98/00009 Gentlemen:
Entergy Operations, Inc. hereby submits the Reply to Notice of Violatior 50-416/97 21-01 for Grand Gulf Nuclear Station. 'Ihis Notice of Violation was issued as a result of NRC Inspection 50-416/97 21 which was conducted October 19 through November 29,1997.
Yours tmly, W
d y d /dtp u/,
JJil/CDi{/cdh attachrnents:
- 1) Response to Notice of Violation 50-416/97 2101 cc:
Ms. J. L. Dixon lictrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter)(w/a)
Mr. N. S. Reynolds (w/a)
Mr. II. L. 'Ihomas (w/c)
Mr. Ellis W. Merschoff(w/a)
N". U))
Regional Administrator c
U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Driw Suite 400 Arlington,TX 76011 Mr. J. N. Donohcw, Project Manager (w/2)
Omoc of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conunission Mail Stop 13113 I),, y J. 1 Washington, D.C. 20555 9902050115 990121 PDR ADOCK 05000416 O
PDR a
Attachme-t I of GNRO-98/000M Page 1 of 4 Response to Notice of Violation 97-21-01 10 CFR Part 50, Appendix B, Criterion V, 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 drawin0s.
Procedure 15 S-01106, " Scaffold Erection," Revision 0, Paragraph 6.2.2, requires that scaffold built in a Seismic Category I building, including the auxiliary building, or in the vicinity of safety-related equipment be assembled in accordance with Standard GGNS-CS-05.
Standard GGNS CS-05, " Standard for Erection of Scaffciding in Safety-Related Areas,"
Revision 0, Paragraph 4.2.8, requires that scaffolding, its bracing, and ladders be kept a minimum of 6 inches away from all safety-related systems or components. Any encroachment on this separation requires nuclear plant engineering approval.
Procedure 01 S-07-43, " Safe Handling of Loose items inside the Plant," Revision 1, Paragraph 5.11, states that equipment; piping; condult; cable trays; instrumentation; heating, ventilation, and air conditioning; and their associated supports are not considered structural elements and cannot be used for securing loose items without nuclear plant engineering approval.
Contrary to the above:
- 1. On October 28, 1997, Scaffold 08 779 was assembled so that it contacted the insulation on the small gauge pipe just down stream of containment atmosphere sample inlet Valve 1P33F572A, a safety-related valve. Nuclear plant engineering approval was not requested and no evaluation was performed (50-416197021-01).
- 2. On November 10,1997, three steel stanchions, used by health physics personnel, were suspended from an overhead safety-related cable tray and its associated supports. Nuclear plant engineering approval was not requested and no evaluation was perform 6d (50416/97021-01).
This is a Severity Level IV violation (Supplement 1).
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Attachmnent I of GNDO-9840009 Page 2 of 4
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L Admission or Denial of the Violation Entergy Operations, Inc. admits to this violation.
IL The Root on for the Violation, if Admitted Example 1: In this example, the procedure wn fhllowed requesting an engineering evaluation of the scaffolding. However, the jn nnel constructing the scaffolding assumed the engineering evaluation includes et.lssion to dente from CS-05, " Standard for Erection of Scaffolding In Safety-Re(ated areas". Sections 4.2.8 of GGNS Civil Standard CS-05 identifies the requirement for a 6 inch separation between a scaffold and all safety-related components. However, in the scaffold evaluation checklist (Appendix A of GGNS Civil Standard CS-05), thb requirement is not specifmally identified which allows misinterpretation of an engineering evaluation request approval. The approval of a scaffold design issued for implementation by NPE does not imply ihai a deviation from the spacing requirement of GGNS Civil Standard CS-05 is allowed unless specifically stated. Therefore, the root cause of the condition was less tlan adequate procedures.
A contributing cause was that the procedure was not followed correctly, Under the present procedural guidelines, tags are hung at the time of scaffold completion stating that the scaffold has been built in accordance with OSHA and plant standards. For safety-related scaffold, an independent verification for compliance with GGNS Civil Standard CS-05 is required prior to scaffold release for use. No additional tags are required for safety-related scaffold, but an additional sigaature by the independent verifle, is required on the Scaffold Request Form. In this example, the independent verification was completed but a signatuie was not obtai ed.
Example 2: The root cause of the condition os failure to follow procedure 01-S-07-43, " Safe Handling of Loose Items Inside the Plant".
A contributing cause was a less than adequate questioning attitude on the part of *he Health Physics (HP) technician who transited the area shortly after the stanchions were hung.
A second contributing cause was inadequate corrective actions for Condition Report GCCR 1997-0750. This Condition Report documented a ladder being secured to a non-structural cable tray without an engineering evaluation performed. Corrective actions for this Condition Report included training for several departments on site but did not include the Health Physics department.
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, c Attactument I of GNRO-9a/00009 Page 3 of 4 o
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Corrective Steps Which Have Been Taken and Results Achieved i
Immediate corrective actions were:
(Example 1) a) Scaffold was reworked to allow greater than six inches of clearance between vertical bracing and the affected P33 system process sampling line.
b) Discussions were held with scaffold installation carpenters to clarify:
- All scaffold, scaffold bracing, and ladders must maintain six inches of cleart.nce from all safety-related components.
3 e - Unless specifically stated, there is no allowed deviation from the requirements of GGNS Civil Standard CS-05.
- All Seismic II/I scaffold murt have an indapaadant verification of installation perfonned, with required signatures completed in Section B.2 of the scaffold request
- ticket, c) All Seismic II/I scaffolding was walked down and inspected.
d) Condition Report GGCR 19971129-00 was written to document this condition and to track long term corrective actions to completion.
Immediate corrective actions were:
(Example 2) a) The stanchions were untied and removed from the safety-related cable tray and its associated uni-stmts.
b) HP conducted a walkdown to ensure that no HP stanchions or ropes were tied to safety i-related equipment or cable trays.
- c) Condition Report GGCR 1997-1181-00 was written to document this condition and to track long term correctiw actions to completion.
I Immediate corrective actions were:
(Examples I and 2)
-a) To stress the importance of following the requirements of established programs (including instances such as Examples 1 &2), the General Plant Manager issued a site-wide notice on December 18, 1997, to all site personnel. This site correspondence -
required selected departmental first line supervisory personnel to review this issue with direct reports and return signed documentation of this review to the Plant Manager, b) In responding to this violation, GGNS reviewed its past performance in the area of following the requirements of established site programs. This review uncovered a e
potentially negative trend in the area of human performance with regard to followirig program / procedure requirements. - Rather than addressing issue by issue as they occur, GGNS has initiated a significant Condition Report (GGCR 1998-0027) to investigate the generic implication of this potential adverse trend.
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Aetachmen Ieroco.easessee
. Page 4 of 4 N. ' Corrective Steps to be Taken to Proclude Further Violations 4:
i lang term corrective actions are:
l (Example 1) f a) GGNS Civil Standard CS-05," Standard for Erection of Scaffolding In Safety-Related Areas", Attachment A (the checklist), will be revised to follow the speci6c steps i
outlined in Section 4.2 of the standard. Correct sequemial placement of activities in the l
attachment will help eliminate confusion between the standard and the checklist, b) Meetings will be held.vith all PM&C scafrok! carpenters to discuss the *mcident with the scaffold request, to clarify the importance of vedutim compliance with GGNS Civil Standard CS-05 and any approved scaffold designs and explain the revised checklist in GGNS Civil Standard CS-05.
Long term corrective actions are:
(Example 2) a) Condition Report GGCR 19971181-00 will be presented to Health Physics personnel (The majority of HP personnel have already reviewed this information, however; due to personal conflicts not everyone has received this briefing) The following items will be covered:
The requirement to not secure loose items to safety related components The need to contact engineering personnel to determine if equipment or e
o components are safety-related The need to maintain a questioning attitude at all times e
Management's expectations that these requirements be followed o
n 1
V.
Date When Full Comollance Will be Achieved All actions are scheduled to be completed by April 10,1998.
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