ML20217J490
| ML20217J490 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/13/1997 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-97-19, GNRO-97-00097, GNRO-97-97, NUDOCS 9710210130 | |
| Download: ML20217J490 (7) | |
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Entergy Operations. Inc.
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1 PO.e a 766
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Port Gibson. MS 39150 Tel 601437 6408 Fax 601437 2795 Joseph J. Hagan vice Present G Nxtes $:aton U.S. Nuclear Regulatory Commission Mail Station PI 37 Washmgton, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Reply To A Notice Of Violation Report No. 50416/97 19-00 (GNRI-97/00148), dated 09/12/97 GNRO-97/0D097 Gentlemen:
Entergy Operations, Inc. hereby submits the Reply to Notice of Violation 50-416/97-19-01, 50-416/97 03 and 50-416/97-19-04 for Grand Gulf Nuclear Station. These Notice of Violations were issued as a result of NRC Inspection 50-416/97-19, which was conducted August 3 through September 6,1997.
Yours truly, JJH/CDH/CEB/
attachments:
1)
Res Notice of Violation 50-416/97-19-01 2)
Response to Notice of Violation 50-416/97-19-03 3)
Response to Notice of Violation 50-416/97-19-04 cc:
Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter)(w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. J. W. Yelverton (w/a)
I Mr. Ellis W. Merschoff(w/a) y Regional Administrator J
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U.S. Nuclear Regulatory Commission
- Q1n.
3 Region tv
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611 Ryan Plaza Drive Suite 400 Arlington,TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation gggggg U.S. Nuclear Regulatory Commission 1
..s Mail Stop 13H3 Washington, D.C. 20555 l
9710210130 971013 l
PDR ADOCK 05000416.
O PDR _
Att:chment i of GNRO-97/00097 P:ge I of 2 Response to Notice of Violation 97-19-01 Technical Specification 5.4.1.a require, in part, that the licensee implement the applicable procedures reco nmended in Regulatory Guide 1.33, Revision 2, Appendix A,1978. Regulatory Guide 1.33, Appendix A Section 4.w(2)(a) recommends procedures for the operation of diesel generators.
Procedure 04-1-01-P81-1, "High Pressure Core Spray Diesel Generator," Revision 41, and Procedure 04-1-01-P75-1, " Standby Diesel Generator System," Revision 47, implemented this requirement.
Procedure 04-1-01-P81-1, Section 4.1.2.d.(7) and Procedure 04-1-01-P75-1, Section 4.8.2.e, require verification that all fuel oil duplex strainers end filters are selected to one strainer / filter at a time.
Contrary to the above, as of August 11,1997, the duplex filter selection levers for the High Pressure Core Spray and the Division 1 Standby Diesel Generators, were in the "Both" position such that two strainers / filters were selected.
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Admission or Denial of the Violation Entergy Oncrations, Inc. admits to this violation.
II.
The Reason for the Violation, if Admitted The apparent cause of this condition was inadequate review of a change and its affect on other procedures. In 1994, a memorandum was written to address the fact that the system operating instructions (SOI) used by plant operators for Standby Diesel Generator (SDG) system line up, did not specify that filter / strainer selector levers be place in either the "Left or "Right" position (only one filter / strainer in service at a time). The memorandum only addressed the SOls, it did not address other procedures (e.g. maintenance procedures).
Therefore, procedural changes made to the SOls specifying that the indicating lever for SDG filter / strainers be placed in either the "Left" or "Right" position were not incorporated into the maintenance procedures.
Ill.
Corrective Steps Which Have Been Taken and Results Achieved immediate corrective actions were:
- 1. The filter strainers on the Division 1 and 2 SDGs were checked. A selector lever was found to be in the "Both" position on the Division 1 SDG.
- 2. All SDG filter levers were verified to be in the "Right" or "Left" position (only one filter / strainer in service at a time).
- 3. A Condition Report (CR) GGCR 1997-0898-00 was written to document and correct the procedural discord.
Att:chment i of GNRO-97/00097 Page 2 of 2 IV.-
Corrective Steps to be Taken to Preclude Further Violations Long term corrective actions are:
- 1. All procedures pertaining to the SDG filter / strainer maintenance will be reviewed to ensure that they are in line with the Sols.
- 2. The CR describing this event will be provided to the Training Review Group for review and possible incorporation into Engineering Support Personnel Training.
- 3. This event will be included in the required reading program.
V.
Date When Full Compliance Will be Achieved All actions are scheduled to be completed by March 31,1998.
l Att:chment 11 of GNRO-97/00097 I4ge 1 of 2 Response to Notice of Violation 97-19-03 10 CFR 50, appendix B, Criterion 111, requires that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions.
The design control measures shall also provide for verifying or checking the adequacy of design, such as by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.
Contrary to the above, as of August 22,1997, design control measures had not assured that the battery racks were returned to the seismically tested configuration after the batteries were replaced in both divisions in accordance with Design Change Package 91/0112, Revision 0, in April and May 1992.
I.
Admission or Denial of the Alleged Violation Entergy Operaticns, Inc. admits to this violation.
II.
The Reason for th Violation,if Admitted The root cause of the battery-to-end rail gaps was a less than adequate procedure. A thorough review of C&D Vendor Manual 460000247, Seismic Qualification Package QP 10 and C&D Test Report VL-765-03 determined there was no definite direction nor specific instruction regarding 'no gap' for seismic requirements between the rails and the battery rack. Regarding seismic installation, the vendor manual only stated " earthquake protected racks are similar to standard racks, but are of heaviu construction. In all cases, earthquake protected racks are supplied with special retaining rails to reotrict cell i
movement."
III.
Corrective Syps Which flave Been Taken and Results Achieved Immediate corrective actions were:
1 Condition Report GGCR1997-0928-00 was written which determined the batteries seismically qualified even with this discrepancy.
- 2. Engineering Request (ER) 97/0643-00 was written to evaluate the battery-to-end rail gaps.
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' 1 of GNRO-97/00097 Page 2 of 2 IV.
Corrective Steps to be Tak n to Preclude Further Violations Long term corrective actions are:
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A supplement to ER 97/0643 will be generated that will provide for clarification of the vendor manual to reflect specific instructions with a cautionary statement regarding ?no gap' between the intermediate batteries or the end batteries with the side rails and engineer:ng instructions and Design Change Document drawings will be provided for installation requirements and modification of the existing racks to ensure that the final arrangement results in conte. between the batteries and the end rails.
- 2. Restore the battery racks to the seismically tested configuration.
V.
Date When Fui. Compliance Will be Achieved The above etions shall be completed prior to startup following RFO9.
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Att:chment til of GNRO-97/00097 P:ge l of 2 Response to Notice of Violation 97-19-04 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings.
Updated Final Safety Analysis Report Section 8.1.4.4.1 requires that cable separation be maintained in accordance with Regulatory Guide 1.75 (January 1975), " Physical Independence of Electrical Systems."
Regulatory Guide 1.75 states that IEEE Std-384-1974, " Criteria for Separation of Class lE Equipment and Circuits," sets forth criteria for separation of circuits and equipment that are redundant.
IEEE Std-384-1974, requires that Non-Class 1E circuits be separated from Class 1E circuits by the minimum separation requiren.ents or become associated circuits.
Contrary to the above, as of August 21, 1997, the licensee had no procedure to control the installation of extension cords to ensure that the required separation from safety-related cable was maintained.
I.
Admission or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
II.
The Reason for the Violation,if Admitted The criteria related to electrical separation requirements for temporary power cords was not specifically addressed by plant procedures. Prior to the initiation of GGCR 1997-0926-00, Plant Staff was not aware that temporary power cords should be reviewed for appropriate separation (as non-safety related circuits), in accordance with Reg. Guide 1.75.
Reg. Guide 1.75 invokes IEEE 384 for most of the detailed separation requirements for Class lE systems. IEEE 384 requires that non-Class IE circuits be physically separated from Class IE circuits by specified minimum distances, be analyzed for acceptability, or be treated as associated circuits. Design Engineering has determined that as a general rule, separation criteria in (Engineering Standard) ES-02 may be used for temporary power cords in order to satisfy the requirements ofIEEE 384 and Reg. Guide 1.75.
l Att:chmnt III of GNRO-97/00097 P ge 2 of 2 III.
Immediate Corrective Steps Which Ilave Been Taken and Results Achieved immediate Corrective Actions were:
- 1. An immediate walkdown by plant personnel was performed. An additional 20 cables were found that may not meet the appropriate separation requirements. All suspect cables were either rerouted, de-energized or successfully evaluated for acceptable separation.
- 2. Initial guidance to plant departments regarding separation requirements for temporary power cords was provided until a more structured method could be put in place.
IV.
Corrective Steps Taken to Preclude Further Violations Long term corrective actions are:
- 1. Provide more detailed guidance or training on the present guidance to appropriate plant personnel regarding separation criteria of temporary power cables.
- 2. GGNS will develop specific criteria for routing of temporary power cords and incorporate into design standard.
- 3. GGNS will develop or revise an existing plant procedure (s) to incorporate separation requirements.
- 4. The requirements of revised standard and procedure, related to temporary power cords, will be communicate to plant personnel.
- 5. Inspection for other potential ES-02 deviations by walkdowns in inaccessible areas when plant conditions permit.
o V.
Date When Full Compliance Was Achieved As outlined above, the corrective actions to rectify the finding of Notice of Violation 97-19-03 are being implemented though a phased-in approach, thus allowing sufficient time for a comprehensive response to the root causes of this condition. The immediate
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corrective a<:tions are complete. Long term corrective action I will be completed by November 28,1997. All the remaining long-term corrective actions will be completed prior to startup following RFO9.
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