05000416/LER-1993-007

LER 93-007-00:on 930723,violation of OL Condition 2.C.(38) Occurred Due to Access Points Not Clearly Marked to Identify Envelope Boundary.Marked Access panels.W/930826 Ltr

ML20056G019
Person / Time
Site:	Grand Gulf
Issue date:	08/26/1993
From:	Hutchinson C, Ruffin R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GNRO-93-00106, GNRO-93-106, LER-93-007, LER-93-7, NUDOCS 9309010169
Download: ML20056G019 (5)

LER-2093-007,

Event date:
Report date:
4162093007R00 - NRC Website

text

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he Entergy Operations,Inc.

ENTERGY " = =

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August 26, 1993 er

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U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. 20555 Attention: Document Control Desk

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Violation of Operating License Condition 2.C.(38)

Control Room Envelope LER 93-007-00 GNRO-93/00106 Gentlemen:

Attached is Licensee Event Report (LER) 93-007-00 'Jhich is an interim report.

Yours truly,, - ,

( /{W CR[RR/

attachment cc: Mr. R. H. Bernhard(w/a)

Mr. H. W. Keiser(w/a)

Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

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 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555

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Grand Guir Nuclear Station 05000-416 01 of 04 IliL E 14)

Violation of Operating License Condition 2.C.(38) Control Room Envelope EVENT DATE (5) LER NUMBER (C) _ REPORT NUMBER (7) OTHER FACILITIES INVOLVED (8)

MON T H DAV Yt. AH YL AN St Out NtlAs N{. vissiv4 MONTH Dat T L Afd S AcIUTY NAME [K. iced! Nt MtM R NuuotR NUMBE R N/A 05000 i ActUIY NAME DOCM 1 NOMHL N 07 23 93 93 007 00 08 26 93 N/A 05000 OPERATING TH;S REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR $ (Chect( one or more (11)

MODE (9) 1 20.402(b) 20 405(c) 50.73(a)(2)(iv) 73.71(b)

POWER 20 405(a)(1)(i) 50 36(c)(1) 50 73(a)(2)(v) 73 71(c)

LEVEL (10) 100 20 405(a)(1)(n) 50 30(c)(2) 50.73(a)(2)(vn) OlHER 20 405(a)(1)(ni) 50 73(a)(2)(i) 50 73(a)(2)(vm)(A) gylq** a' a 20 405(a)(1)(tv) 50 73(a)(2)(n) 50 73(a)(2)(vm)(B) Violation of oL 20 405(a)(1)(v) 50 73(a)(2)(in) 50.73(a)(2)(x) Condition 2.C.(38)

LICENSEE CONTACT FoR THis LER (12)

NAMt ua e tNvManw,u,.A, c->

Riley Ruffin / Licensing Specialist 601-437 2167 COMPLETE ONE LINE FoR EACH COMPONENT FAILURE DESCRIBED IN THis REPORT (13) cAva systou coMoontwr MANorAcTuNtw stg igt cAva sysrtM cou e va uANuiAcium a Ni A t EXPECTED """ D^' 't ^k SUPPLEMENTAL REPORT EXPECTED (14)

X YEs No submission 12 03 93 i e m w.w. s m cToo souMsmou t.* To DATE (15)  !

ABsT RACT comino ma u .. . . . m ..m.wm ..w.a.o m.-m i. mo On July 23,1993, plant personnel were in preparation to perform a functional test of the Control l Building Fire Detection System as required by GGNS Technical Requirements Manual. The test is j performed at least once per 184 days. In order to test two of the nine required smoke detectors, the ,

associated access panel had to be removed. Prior to the start of the applicable portion of the  !

surveillance, it was noted that the access panel was a part of the control room envelope boundary.  !

Opening this panel would introduce an open area of approximately 576 square inches which would  ;

exceed the allowable opening area introducing an opening of this size would have required a review

. by the Plant Penetration Coordinator. This review had not been performed. Therefore, this portion of the surveillance was not performed. A subsequent review was performed to identify prior tests which {

have opened the access panel without the proper reviews. Even though each performance of the i

test violated the OL Condition, only three cases were cited to substantiate prior violations of the OL Condition. Neither in-the-field personnel nor control room personnel realized that the access panel was a part of the envelope boundary. Plant personnel did not regard the access panel as a penetration. Thev were unaware that this type opening should be controlled by plant procedures governing work on penetrations. The procedure governing the functional test did not reference the penetration control procedure which would have caused personnel to perform a more in-depth evaluation of the opening of the access panel. An investigation is still in progress to determine the root cause of this occurrence. A supplemental report will be submitted by December 03,1993.

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Grand Gulf Nuclear Station Os000-416 93-007-00 2 oF 04 iL A7 (# fr4we sm* es runawort, yao emfafgweeJ M4wea of NHC f woiMSAJ(f TJ A. Reportable Condition  ;

Operating License (OL) Condition 2.C.(38) requires the control room leak rate to be maintained within 590 cubic feet per minute (cfm). The 590 cfm flow rate equates to an opening of approximately 20 square inches (sq. in.). An opening which exceeded this area was introduced in the control room envelope boundary during the performance of a required surveillance. The opening of this penetration was performed outside our current administrative controls. This was a violation of the l above OL Condition and is being reported pursuant to OL Condition 2.F.

l B. Initial Conditions At the time of discovery, the plant was in OPERATING CONDITION 1 with reactor thermal power at approximately 100 percent. Reactor coolant temperature was approximately 529 degrees F, t

C. Description of Occurrence l

l On July 23,1993, plant personnel were in preparation to perform a functional test of the Control Building Fire Detection System [lC} as required by GGNS Technical Requirements Manual. The test is performed at least once per 184 days. In order to test two of the nine required smoke detectors (Attachments XIV and XVil of the surveillance procedure), the associated access panel had to be removed. Prior to the start of Attachment XIV of the surveillance, it was noted that the access panel was a part of the control room envelope boundary. Opening this panel would introduce an open area of approximately 576 sq. in. which would exceed the allowable opening area. Current administrative

controls required a review to be performed by the Plant Penetration Coordinator prior to removal of the panel. However, the review had not been performed. Therefore, this portion of the surveillance was not performed.

A subsequent review was performed to identify prior tests which opened the access panel without proper review. Even though each performance of the test violated the OL Condition, only three cases were cited to substantiate prior violations of the OL Condition.

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D. Apparent Cause Based on a review of the incident, several factors have been identified which allowed this occurrence.

J Neither field personnel nor control room personnel realized that the access panel was a part of the envelope boundary. Even though Design Engineering had performed an evaluation and identified the envelope boundaries, access points had not been clearly marked to prevent uncontrolled opening.

Plant personnel did not regard the access panel as a penetration. They were unaware that this type opening should be controlled by plant procedures governing work on penetrations. Plant personnel I did not realize that opening the access panel would require review by the Penetration Coordinator as specified by plant procedures.

The procedure governing the functional test did not reference the penetration control procedure which would have caused personnel to perform a more in-depth evaluation of the opening of the access panel.

E. Corrective Actions An investigation is currently in progress to determine the root cause of this occurrence.

The applicable attachments of the surveillance procedure were changed to ensure plant personnel realized the impact of removing the access panels.

i Further evaluations are being performed to determine appropriate administrative measures to l maintain control room habitability during the performance of the surveillance.

Access panels which are a part of the envelope boundary will be marked as such to ensure that boundary penetrations will be controlled by our existing programs.

Plant personnel will be trained to heighten their awareness of this incident and the identified causes.

These are preliminary actions taken to preclude recurrence. However, further actions will be evaluated upon completion of the root cause analysis.

A supplemental report will be submitted by December 03,1993

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Grand Gulf Nuclear Station 05000-416 93-007-00 4 OF 04 rus tu m.sia. . aa a ,ae maam m- a we m xm cm F. Safety Assessment The OL requirement is in place to ensure control room habitability is maintained during accident conditions.

The surveillance was performed at least once per 184 days. The amount of time the access panel was actually open has been estimated to be approximately 10 minutes each time the test was performed. Based on operating history, there have been no occurrences which have adversely affected control room habitability during the performance of the test.

Therefore, the addressed condition did not compromise the health and safety of the public.

G. AdditionalInformation Entergy industry identification System (Ells) codes are identified in the text within brackets [ ].

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