ML20011F217

Responds to NRC 900131 Ltr Re Violations Noted in Insp Rept 50-416/89-30.Corrective Actions:Quality Deficiency Rept Initiated to Document & Resolve Incident & Incident Rept & Reportable Events Procedure Enhanced

ML20011F217
Person / Time
Site:	Grand Gulf
Issue date:	02/23/1990
From:	Cottle W SYSTEM ENERGY RESOURCES, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AECM-90-0034, AECM-90-34, NUDOCS 9003020140
Download: ML20011F217 (3)

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-:-:- System) M';"i";'"

V Port G'bson MS 39'5

- b. e 7 le1601437 6809 William T. Cottle

' Vice headert

! February 23, 1990 U.S. Nuclear Regulatory Commission Mail Station P1-137 Q. Washington, D.C. 20555 Attention: Document Control Desk i

Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station-Unit 1 Docket I?o. 50-416-License No. NPF-29 Report No. 50-416/89-30 Dated 1/31/90 (MAEC-90/0017)

AECM-90/0034

-System Energy' Resources, Inc. hereby submits response to violation 50-416/89-30-01.

Yours truly, eo PP_- -

WTC:cg Attachment oc: Mr. D. C. Hintz (w/a)

Mr. T.11. Cloninger (w/a)

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

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

Mr.11. L. Thomas (w/o)

.Mr.11. O. Christensen (w/a)

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. L. L. Kintner, Project Manager (w/a)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 14B20 Washington, D.C. 20555 9003020140-900223 ll)

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E . Notice of Violation 89-30-01 Technical Specifications 3.4.6.1.b, Pressure / Temperature Limits,. requires that the reactor vessel metal temperature shall be limited with a maximum reactor 6 coolant cooldown of.100"F in any one hour period. With any of the above limits exceeded, restore the. temperature to within the limits within 30 minutes; perform an engineering evaluation to determine the effects of the out-of-limit-conditions on the structural integrity of the reactor coolant system; determine that the reactor coolant system remains acceptable for. continued operations or be in at least Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, on December 30, 1989, following a manual reactor scram, the unit exceeded the maximum reactor coolant cooldown rate for the reactor vessel bottom head drain with a 125"F.cooldown in a-one hour period. The' licensee failed to identify the excessive cooldown prior to plant restart on December 31, 1989 and when identified on January 12, 1990, the licensee failed-to perform an engineering evaluation to determine that the reactor coolant ..

system structural integrity remained acceptable for continued operations within-the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shutdown requirement. -The evaluation was not performed until

-January 15, 1990.

1. Admission or Denial of The Alleged Violation System Energy Resources, Inc. (SERI) admits to the alleged violation.

This violation had no effect on the health and safety of the public.

.e II. . Reason For The Violation If Admitted This violation occurred due to the following reasons:

A. .The failure to recognize the out-of-limit cooldown rate-was.

primarily due to programmatic daficiencies. The Scram Recovery:

procedure provided data sheets.for logging temperatures for a heatup/cooldown record. The data sheets also required review signatures after completion by the Control Room Operator and the Shift Supervisor. However, the data sheets did not include

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acceptance critoria and did not clearly assign responsibility for determining if out-of-limit conditions existed. Additionally, the post Trip Analysis procedure did not require a check of heatup or cooldown rates to ensure acceptability prior to plant restart.

B. The failure to initiate an engineering evaluation was due to verbal misunderstandings between Operations Staff and the licensed Shift Superintendent located in the Control Room.

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The-Insident'ReportwaswritkenbyOperationsStaffinthe

.f administrative office and carried to the Shift Superintendent to-make required notifications and initiate appropriate Technical-6 Specification actions. Based on the conversation with the l Operations Staff, the Shift Superintendent concluded that the.

required Technical Specification actions had already been accomplished.

Complete details of this event are documented and reported in

Licensee Event Report Number 90-001.

III. Corrective Actions Which Have Been Taken And Results Achieved ye A Quality D'eficiency Report (QDR #010-90) was initiated to document and if resolve this incident. As a result, the-following corrective actions have been taken:

1. Integrated Operating Instructions Data Sheets have been changed to require-an evaluation of the temperature differe.ntial at every 60 minute segment to identify any out-of-limit heatup/cooldown rates.

Additionally, completed data sheets require a' final documented determination of whether or not the recorded conditionn are acceptable when compared to administrative and Technical Specification acceptance criteria.

2. The post. Trip Analysis Procedure (01-S-06-26) has been changed to require a check of the acceptability of the cooldown/heatup rates.

3. A memorandum was issued to the Operations Staff and to the Shift m Superintendents informing them of the incident and the-expectations of distinct communications and thorough research in-the resolution' of operational concerns.

?IV. _The Corrective Steps Which Will Be Taken To Avoid Further Violations SERI considers the actions taken in Section III adequate to preclude recurrences of this nature. However, as an additional measure, SERI will enhance the Incident Report and Reportable Events procedure s, -(01-S-06-5) to pronet more complete reviews for Technical Specification compliance.

V. Date When Full Compliance Will Be Achieved Full compliance has been achieved except for Section IV. Changes to procedure 01-S-06-5 will be implemented by April 30, 1990.

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