ML20007C343

Responds to NRC 960812 Ltr Re Violations Noted in Insp Rept 50-416/96-11.Considers Requirements of 10CFR Appendix B Criterion V as Having Been Met & Denies NOV 416/96-11

ML20007C343
Person / Time
Site:	Grand Gulf
Issue date:	09/11/1996
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GNRO-96-00104, GNRO-96-104, NUDOCS 9609200026
Download: ML20007C343 (7)

Text

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=~2 ENTERGY 'tT" f~"*" '""

rbn Grtes n. LG 39150 Tv V;1437 2b:0 C. R. Hutchinson mreo.g nw -

Owv ti, 'k y An j

" eptember 11,1996 U.S. Nuclear Regulatory Commission Mail Station P1-37

. Washington, D.C. 20555 i Attention: Document Control Desk

Subject:

Grand Gulf Nuclear Station Docket No. 50-416  !

License No. NPF-29 Respc'se to Notices of Violation 50-416/9611-04 Report No. 50-416/9611, dated 08/12/96 (GNRI-96/00168) j I

GNRO-96/00104 I

Gentlemen:

Entergy Operations, Inc. submits the response to Notices of Violation 50-416/9611-04.

Notice of Violation (NOV) 50-416/9611-04 stated that Grand Gulf Nuclear Station (GGNS) was in violation of Criterion V of 10 CFR Appendix B, which states in part, that activities affecting quality shall be prescribed by documented procedures and drawings of a type apprcpriate to the circumstances and shall be accomplished in accordanc3 with these procedures and drawings.

Guidance for development of such procedures, drawings, and instructions is contained in Regulatory Guide (Reg Guide) 1.33, revision 2, section D. 4. This section states, in part ,

instructions for energizing, filling, venting, draining, startup, shutdown and changing modes of I operation should be prepared, as appropriate. Listed under item w. (2) (a) is Eniergency Power Sources (e.g., diesel generator, batteries).

' Procedures in effect at the time of the subject violation met the requirements of Reg Guide 1.33 for the Standby Diesel Generators. Therefore GGNS considers the requirements of 10CFR Appendix B Criterion V as having been met and denies Notice of Violation 416/9611-04.

Yours truly, g 0 , G.R.H t A s. ,

i CRH/JEO/

attachment: Response to Violation 50-416/9611-04 ~]~ [ h{

I cc: Mr. J. E. Tedrow (w/a)

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

Mr. N. S. Reynolds (wla)

- Mr. J. W. Yelverton (w/a) g "3 (Continue Ne Page)

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9609200026 960911 PDR ADOCK 05000416 G PDR l 4

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o l September 11, 1996 I

GNRO-96/00104 Paga 2 of 3

.. cc: (Continued) i

' Mr. Leonard J. Callan (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission ,

Region IV 611 Ryan Plaza Drive, Suite 400 Arling?cn, TX 76011 Mr. J.14. Donohew, Project Manager (w/2)

Office of Nuclear Reactor peculation j U.S. Nuclear Regulatory Cornmission Mail Stop 13H3

Washington, D.C. 20555 4

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September 11, 1996 GNRO-96/00104 Page 3 of 3 r,c: Mr. D. R. Franklin (w/a)

Ms. C. W. Gunn (wla)

Mr. S. C. Mooney (w/a)

Mr. J. E Owens (w/a)

Mr. G. D. Swords (w/a)

Required Reading Coordinator (w/a)

SRC Secretary (wla)

File F. CTS /RPTS)(w/a)

File(Central)(w/a)(

File (NS&RA)(w/a) 7)

.NPO Records Center (w/a) 700 Galleria Parkway Atlana, Georgia 30339-5957 Mr. W. T. Donovan (wta) lilinois Power Company Clinton Power Station Mail Stop V-920 P.O. Box 678 Clinton, Illinois 61727 l

ccmail:

l Mr. P. W. Alberstadt (ECH) Mr. M. G. Hurley l

Mr. C. A. Bottemiller Mr. C. R. Hutchinson Mr. O. P. Bulich (RB) IEA(ANO) i Mr. R. W. Byrd Ms. S. B. Mahoney Mr. W. i . Clark Ms. J. M. Manzella (W3)

Mr. D. G. Cupstid Mr. J. R. McGaha (RB)

Mr. J. P. Czaika Mr. M. J. Meisner Mr. c. F. Dale Mr. D. C. Mims (ANO)

Mr. L F. Daugntery Mr. L. B. Moulder Mr. G. G. Davie (W3) Mr. R. V. Moomew Mr. J. G. Dewease (ECH) Mr. F. T. Philpot (ANO) l Mr. C. M. Dugger (W3) Mr. T. E. Reaves (ECH)

Mr. C. W. Elisaesser Mr. J. C. Rcberts Mr. J. L. Ensley (ESl) Mr. J. L Robertson Mr. J. J. Fisicaro (W3) Mr. M. A. Smith (ANO)

Mr. T. W. Gates (RB) Mr. R. L Thomas (ECH)

Mr. T. J. Gaudet (W3) Mr. T. H. Thurmon Ms. C. W. Gunn Mr. J. E. Venable Mr. R> D. Ingram Mr. D. W. Vinci(W3)

! Mr. J. J. Hagan Mr. D. H. Wells (RB) l Mr. C. C. Hayes l

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Attachment to GNRO-96/00104 Page 1 of 2 1 I

Notice of Violation 9611-04 I

Criterion V of Appendix B to 10CFR 50 states, in part, that activities c"ecting 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 drawings.

Contrar/ to the above, an activity affecting quality was not properly prescribed by procedures appri criate to the circumstances in that Procedures 06-OP-1P75-M-0001, " Standby Diesel Genemtor 11 Functional'.est," Revision 100 and 06-OP-1P75-M-0002, " Standby Diesel

Generator 12 Functional Test," Revision 100, did not provide direction for properly maintaining the oil level in the govemor or for periodically checking the governor oil level during operation of the standby diesel generrlors.

1. Admission or Denial of the Alleoed Violation Entergy Operations, Inc. denies this violation.

II. The Reason for the Violation Denial On April 24,1996 the monthly surveillance ted nf the SDG was performed with a visiting resident inspector observing. After the SDG was started the visiting inspector noted that the govemor oillevel appeared to drop out of the indication range of the sightglass. The inspector questioned the system engineer about the operation of the govemor and proper

! oil level to be maintained in the sightglass while the SDG was in operation. Later the

! inspector noted a sticker on the govemor pertaining to oil level stipulations. The inspector reviewed the surveillance and daily rounds and concluded that the procedural controls were deficient in that they failed to provide adequate procedures for ensuring continued operation of the SDG. This resulted in the issuance of Notice of Violation 50-416/9611-04.

The notice of violation stated that procedures "did not provide direction for properly maintaining the oil level in the govemor or for periodically checking the govemor oil level i during operation". Grand Gulf Nuclear Station (GGNS) maintains that the procedures in l place prior to the April 24,1996, event did provide for maintaining oil level and did call for l periodic monitoring of govemor level. GGNS procedures 06-OP-1P75-M-0001 and M-0002 did call for verifying proper oil level prior to SDG start. The Building Rounds required monitoring govemor oil level daily. These procedures are only for performing surveillance (one hour runs) and do not require extended run times for the diesels. i l

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.The vendor manual for the SDG did contain information related to the govemor, however j this information did not contain information on specific frequency for monitoring of the i govemor oil level. Only after contacting the sub-component vendor and reviewing a f manual not supplied by the venotr (Cooper) was a recommendation discovemd to check j the govemor oil levelimmediately following start-up of the SDG.  :

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GGNF aelieves that the approved vendor for the SDG is the proper source for information i used in the development of procedures. Information from other sources, including sub-  !

component stickers should be reviewed by the SDG vendor prior to use to ensure that it does not aaversely affect the original SDG design qualification.

As always, GGNS looks for improvements that can enhance the safety and reliability of its

, equipment. We therefore appreciate the feedback from the visiting resident inspector

related to monitoring of the SDG govemor oil level. We agree that there was room for j- SDG procedural enhancement in this area and changes have a! ready been made.

However, GGNS does not ha!! ave this situation constitutes a violation as cited in

! inspection report 50-416/9611.

i i lit. Corrective Steps Which Have Been Taken and Results Achieved l Changes were made to Operations SDG Standard Operating instruction, and monthly i surveillance procedures to include spacific written criteria for maintaining govemor oil levels and for level monitoring frequency while the SDG is running. Also, written

] guidance for adding oil to the govemor was included in the changes.

4 Changes were made to Operations Daily Round Criteria for the diesel govemor to verify sightglass oillevelis within 1/8 inch of the top of the sightglass.

N. Corrective Stoos to be Taken to Preclude Further Violations I SDG 18 month surveillance and operability verification surveillance will be changed prior to i completion of RF08.

V. Date When Full Comoliance Will be Achieved i

e N actions are scheduled to be complete by the end of RF08.

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CONCURRENCE REVIEW FORM v

SECTION I l

RESPONSE DUE: 09/11/96 l' GNRO-96/00104 Rev.0 (NRC Reauired or Target)

SUBJECT:

Response to Notices of Violations 9611-04. Iriadeouate Procedure for Monitorina SDG Govemor Oil Level 41S-19y Flef /10/96 [

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9/10/96

/NRC Docurient Preparer Date RTsponsible Section Date Manager / Superintendent l

i Commitment Concurrence i SECTION 11 i Responsible Organizatior Locations Committront Primary / Secondary Due Date Attachment 1, Page 2, SDG 18 monthry surveillance and Ops operability verification surveillance RF08 Section IV -

will be changed prior to completion j of RF08.

This letter contains commitments requiring procedural implementation YES (X) NO ( )

i UFSAR Pote .. sal impact Classification i SECTION lil UFSAR impad: No X Yes if Yes:

A) List UFSAR sectir.,ns/ tables /

figures affected and describe nature of UFSAR B) UFSAR revision affected: Current Future C) Additionalcomments:

SECTION IV Concurrence i Review Required Y N

() (X) -

)

VP, Engineering /Date (X) _()  % ~ 0. P. Hs t4,2eq Up(rajons GGNS/Date (X) () _c al er, Plant i

() /X)

Director, Design l Engineerin te

() / h4 T!Id!fd I

(X)

DirtiIctof, Nucleg Safety & s Regulatory Affairs /Date

()Q () See h%Le) %et (M.MclL-an)

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