ML20236G468

Submits Response to Violations Noted in Insp Rept 50-416/98-05.Corrective Actions:Door Closed Immediately After Reported Open

ML20236G468
Person / Time
Site:	Grand Gulf
Issue date:	06/26/1998
From:	Hagan J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-416-98-05, 50-416-98-5, GNRO-98-00054, GNRO-98-54, NUDOCS 9807060258
Download: ML20236G468 (6)

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o Entergy Operations,Inc.

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P O. Box 756 v

EE Port Gibson, MS 39150 Tel 601437 6408 Fax 601437 2795 l

Joseph J. Hagan Vice Presdent ope <ations Grand Gutt Nuclear Stanon June 26,1998 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention: Document Control Desk j

Subject:

Grand GulfNuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 ReplyTo A Notice OfViolation Report No. 50-416/98-05 Dated 05/28/98 (GNRI-98/00075)

GNRO-98/00054 Gentlemen:

Entergy Operations, Inc. hereby submits the Reply to Notice of Violation 50-416/98-05-02 and Notice of Violation 50-416/98-05-04 for Grand Gulf Nuclear Station. These Notices of Violation were issued as a l

result ofNRC Inspection 50-416/98-05 which was conducted April 5 through May 16,1998.

l Yours truly, f

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JJH/CDH/JEO/cdh

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attachments:

1) Response to ? o ice of Violation 50-416/98-05-02

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2) Response to Notice of Violation 50-416/98-05-04

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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. Ellis W. Merschoff(w/a)

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Regional Administrator U.S. Nuclear Regulatory Commission l

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 Commission Mail Stop 13H3 9907060259 990626 Washington, D.C. 20$55 PDR ADOCK 050C0416 vv39 G

PDR

-a Att:chment I of GNRO-98/00054 Page 1 cf 2

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Response to Notice of Violation 98-05-02 Technical Specification 5.4.1.a states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operations),"

Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, Section 3.s. (2)(a), recommends procedures for startup, operations, and shutdown of emergency power sources.

Procedure 04-1-01-P75-1, " Standby Diesel Generator Systeir

'lon 50, Paragraph s

3.33, requires that if the diesel generator control cabins.. m -, are left open or unlatched, they must not be left unattended. Otherwise, the respective diesel generator should be declared inoperable.

Contrary to the above, on April 21,1998, the inspectors found the back doors on Diesei Generator Control Cabinet 1H22-P400 in the Division 1 standby diesel generator room standing wide open and unattended and the Division 1 diesel was not declared inoperable.

This is a Severity Level IV violation (Supplement 1) (50-416/9805-02).

L Admission orDenial of the Violation Entergy Operations admits to this violation.

I IL The Reason for the Violation, if Admitted This event was identified by the GGNS Resident Inspector. Subsequently, GGNS provided written notification of this event to the NRC in LER 98-002. In that LER GGNS outlined the l

apparent cause of this event and corrective actions. This response to Notice of Violation l

50-416/9805-02 summarizes information contained in LER 98-002.

An exact determination of when and why the door was open could not be made. Because the cabinet doors being closed is not an abnormal situation, it is difficult to absolutely determine when exactly the doors were confinned shut. We have reasonable assurance the doors were observed closed at approximately 0943 hours0.0109 days <br />0.262 hours <br />0.00156 weeks <br />3.588115e-4 months <br /> on 4/21/98. However, there is some indication the doors may have been opened and unattended prior to this event. The cause of this event is failure to comply with system operating instruction 04-1-01-P75-1 which requires that when the doors are open they be attended or that the diesel generator be declared inoperable.

Attachment I of GNRO-98/00054 i

Page 2 of 2 HL Corrective Steps Which Have Been Taker: and Results Achieved

. The door was closed immediately after it was reported open.

• The need to ensure seismic compliance was reinforced with operators making rounds in t

l the building.

• A search of past. events demonstrated that this was an isolated occurrence, so no further l

action is considered necessary.8 i

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l IV.

Corrective Steps to be Taken to Preclude Further Violations There are no outstanding correc ive actions associated with this event.

V.

Date When Full Compliance Will be Achieved Closure of the EDG cabinet doors brought GGNS into full compliance. All actions have been

- completed.

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1) The search of past events did reveal a previous occurrence, however, the time timt has elapsed since this previous occurrence leads GGNS to consider this issue an isolated event.

Attachmelt IIof GNRO-98/00054 PIge 1 of 3 Response to Notice of Violation 98-05-04 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 i

circumstances and shall be accomplished in accordance with these procedures and I

drawings.

' Procedure 15-S-01-106, " Scaffold Erection," Revision 0, Paragraph 6.2.2, requires that scaffolding built in a Seismic Category I building, including the auxiliary building, or its the vicinity of safety-related equipment be assembled in accordance with Standard GGNS-CS-05. Paragraph 7.4 requires that an independent inspection be completed to ensure al! Standard GGNS-CS-05 requirements have been met.

j Standard GGNS-CS-05, " Standard for Erection of Scaffolding in Safety-Related Areas,"

Revision 0, Paragraph 4.2.8, requires that scaffolding, its bracing, and ledders be kept a minimum of 6-inches away from all r,afety-related systems or components.

Any encroachment on this separation requires nuclear plant engineering approval.

Contrary to the above, on April 8,1998, Scaffold 09-1881 was assembled so that it contacted safety-related reactor core isolation cooling system instrument tubing.

Nuclear plant engineering approval was not requested, no evaluation was performed,-

and the independent verification was not performed.

This is a Severity Level IV violation (Supplement 1) (50-416/9805-04).

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Admission or Denial of the Violation Entergy Operations, Inc. admits to this violation.

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l IL The Reason for the Violation, if Admitted j

The root cause of the RCIC room scaffolding problem was attributed to several causes. These causes are:

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e Failure to' train all personnel on the scaffolding standard.'

I e Failure of the supervisor to ensure independent verification was performed after assembly.

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• Procedural weakness in that no detailed tool was available to aid in identification of site i

requirements.

o Poor communication between the Crew Forman and the General Forman I

e Problems with the training / guidance of the personnel handling the scaffold tracking system.

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i Attachm:nt II of GNRO-98/00054 P.tge 2 of 3 An additional root cause of the deficient condition was not training the crew that assembled the RCIC Room scaffold prior to erecting the scaffold. The training, which covered verbatim compliance with GGNS CS-05 and approved scaffold design, was a corrective action of GGCR 1997-1129-00. The corrective action was completed on 4/9/98. However, the deficient scaffold was built on 3/28/98.

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i HL Corrective Steps Which Have Been Taken and Results Achieved

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Immediate corrective actions were:

1) Seismic II/I scaffold installations in safety related structures were stopped until

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existing scaffolds could be inspected and discrepancies repaired.

2) The RCIC room scaffold found to be in noncompliance was immediately removed to preclude any further seismic separation concerns.

3) All scaffolds located in seismic II/I areas were walked down, with the assistance of Nuclear Plant Engineering (NPE), and discrepancies fourd v ere evaluated and/or corrected.

4) In addition to the required independent verification by Plant Modification &

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Constmetion (PM&C), NPE performed independent inspection of all seismic II/I scaffolding erected the previous shift in safety-related areas.

5) All craft foremen responsible for the installation of plant scaffolding were retrained on their responsibilities related to the safe and procedurally correct installation of seismic II/I scaffolding.

6) A review of all seismic II/I scaffolds installed in Category I structures was conducted prior to reaching mode 2 following Refueling Outage Nine.

This review was conducted to ensure that all seismic II/I concerns were addressed as plant systems that had been inoperable were brought back into service.

7) Training for the crew that erected the deficient scaffold was completed on 4/9/98.

This training, a corrective action of GGCR 1997-1129-00, covered verbatim compliance with GGNS CS.05 and approved scaffold design.

l IV.

Corrective Steps to be Taken to Preclude Further Victations Interim corrective actions are:

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1) Procedure 15-S-01-106, " Scaffold Erection", will be revised to includelrequire:

the responsibilities of the Independent Verifiers for scafrokling e

I GGNS CS-05 training for all carpenters before they can build / inspect seismic II/I scaffolds crew foremen or members that perform construction or Operations walkdowns e

i to participate in pre-job briefings a post construction review of all seismic II/I scaffolds performed by design e

engineering until permanent program changes a.e defined through the PM&C peer group.

E Attachment II of GNRO-98/00054 l

Pcge 3 of 3 l

2) A checklist with the seismic requirements from GGNS CS-05 will be created to aid in the post installation scaffold erection review for seismic II/I scaffolds. This checklist, l

to be included in procedure 15-S-01-106, will also be used by the Independent Verifier l

to ensure that all seismic II/I concerns for scaffold near safety-related components or l

systems are properly addressed.

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3) To enhance the present scaffold processes, a list of responsibilities for the Scaffold Coordinator will be developed and included in procedure 15-S-01-106.

1 Long Term corrective actions are:

1) An assessment of scaffold processes at other Entergy facilities will be conducted thrcugh the PM&C Peer Group. Engineering Personnel will also be involved in the assessment. An enhancement program will be developed to build quality into the l

existing scaffold process.

This enhancement program will include evaluation of interim corrective actions. Process enhancements for the scaffold program will be brought back to the CARB for approval.

V.

Date When Full Compliance Will be Achieved i

. Completion ofimmediate corrective actions resulted in full compliance. All interim and long term corrective actions to prevent further violations will be completed by February 15,1999.

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