ML20112A632

Responds to Weakness Noted in Insp Rept 50-416/96-02.Plan to Resolve Stem Corrosion Issue Provided

ML20112A632
Person / Time
Site:	Grand Gulf
Issue date:	05/15/1996
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GNRO:96-00058, GNRO:96-58, NUDOCS 9605210384
Download: ML20112A632 (5)

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= ENTERGY ETld!*"'"*' '"*-

Port Gbson,MS 39150 Tel 601437 2800 i

c. n. Hutchin.on

May 15,1996 voe Presrmni Operanons Graro come stavn l

4 l U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 L Attention: Document Control Desk f

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Subject:

Grand Gulf Nuclear Station l Docket No. 50-416 License No. NPF-29 Response to NRC Inspection Report 50-416/96-02 l ]

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GNRO: 96/00058

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t Gentlemen:

l We appreciated the recent opportunity to conduct an engineering self assessment as an altemative to a full scope NRC inspection. These cooperative efforts are important to us

! because they have the potential to lessen the regulatory impact / burden on both licensees 1

l l and NRC staff while ensuring that the assessment area is thoroughly and appropriately evaluated. j i

We have completed review of NRC Inspection Report 50-416/96-02 containing the results of the inspection conducted to determine the effectiveness of our self assessment of the engineering and corrective action programs at GGNS. Overall, the inspection report fairly assesses the strengths, weaknesses, and opportunities for improvement of our engineering and corrective action programs.

i Since the focus of self-assessments is broader than a compliance-based inspection, we i

were initially apprehensive conceming the inspection's ability to distinguish between self-assessment findings that constituted deficiencies (for which corrective action would be necessary) and self-assessment findings that were enhancement recommendations (which are outside the regulatory scope, and whose implementation would be elective). Our experience with the inspection and our review of the inspection report made it clear that the l inspectors were sensitive to this concem and were able to discriminate between assessment findings within and without regulatory scope.

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PDR ADOCK 05000416 G PDR t p

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. May 15, 1996 l ' GNRO-96/00058 l Page 2 of 5 l

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Although we and the NRC expended more resources than we would have liked for this assessment / inspection effort, we believe such expenditure represents our common desire to do it right the first time. As we gain more experience, we anticipate that future self-assessment / inspection efforts will result in a net reduction of licensee and regulator t resources.

One area of inspection focus merits clarification - our plans and actions regarding the valve stem on the reactor core isolation cooling (RCIC) pump turbine govemor. The inspection report contains the misimpression that GGNS "did not plan to inspect or replace the valve j stem...during the next outage." We also understand that this misconception was the j subject of some discussion by the SALP Board.

! As you know, GGNS received a copy of Region IV's inspection report of Terry Turbine I activities in late 1995. GGNS was not the subject of the inspection report as we were not in Region IV when the inspection occurred. Upon receipt we initiated an immediate review to identify areas of improvement at Grand Gulf. This review was in progress during the engineering assessment / inspection in January,1996.

During the course of the inspection, a GGNS engineer provided draft information to the

! NRC inspectors which gave the impression that we planned no action to address the RCIC stem corrosion issue. The draft was a work in progress that had not yet been reviewed by .

engineering management and did not reflect GGNS' position on the RCIC stem corrosion issue.

Although the details are not clear at this point, we believe that separately from the written j drsft information, we verbally provided to the inspectors, the resident inspector and some 1 i

Region IV management the following information about our plans to resolve the stem corrosion issue:

. We had implemented a program of inspections and functional testing of the stem

! since September,1994, based on operating experience at other Entergy Operations facilities, j e The stem must be replaced, however at the time of the inspection, engineering was evaluating appropriate stem materials to ensure that a replacement stem would not introduce similar or new failure mechanisms e Replacement of the stem during the scheduled February RCIC outage (this is probably the " outage" referred to in the inspection report) was not possible due to long lead-time on stem replacements l . The stem would be replaced during the July,1996 RCIC outage. Subsequently, we

, have determined to use Ferralium F-255 as the replacement stem material.

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, May 1,5, 1996

' GNRO-96/00058 Page 3 of 5 l

i We think this misunderstanding was a combination of reliance on early draft information, verbal information that may not have reached the correct parties, and schedule pressure that did not allow issuance and rebuttal of the inspection report prior to the SALP Board meeting. In any case, the GGNS response to the RCIC stem issue as documented in the inspection report is atypical of our approach to engineering issues, which is why we felt it worthwhile to correct this misunderstanding.

We appreciate the opportunity to provide feedback on this inspection report. And, as we've discussed in such forums as the January ANS/ Region IV conference, we believe that it would be worthwhile to further discuss the self-assessment / inspection process to  !

enhance safety and resource benefits in future joint efforts.

If you have any questions, please contact Mr. Danny G. Bost at (601) 437-6270.

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Yours truly, i

a t ,

CRH/MJM/be attachment

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" May 15,1996 GNRO-96/00058 Page 4 of 5 cc: Mr. R. B. McGehee Mr. N. S. Reynolds Mr. J. E. Tedrow Mr. H. L. Thomas Mr. J. W. Yelverton Mr. L. J. Callan (Reg IV)

Mr. T. P. Gwynn (Reg IV) .

Mr. C. Vandenburgh (Reg IV)

Mr. T. F. Stetka (Reg IV)

Ms. L. J. Smith (Reg IV)

Mr. J. N. Donohew, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission .

Mail Stop 13H3 Washington, D.C. 20555

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GNRO-96/00058 Page 5 of 5

! bec: Mr. D. G. Bost

! Mr. C. A. Bottemiller -

Mr. R. W. Byrd '

i Mr. L. F. Daughtery l Mr. L. F. Dale Mr. J. G. Dewease i Mr. J. J. Hagan l l Mr. C. C. Hayes, Jr.

Mr. M. J. Meisner Mr. R. L. Patterson l- Mr. J. C. Roberts i Mr. T. H. Smith 1 Mr. J. E. Venable File (LCTS/RPTS)

File (Hard Copy)

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