ML20117P654

Responds to NRC Re Violations Noted in Insp Rept 50-416/96-11.Corrective Actions:Plant Mod & Const Will Develop & Implement Scaffold Erection Procedure

ML20117P654
Person / Time
Site:	Grand Gulf
Issue date:	09/05/1996
From:	ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20117P651	List: ML20117P654
References
NUDOCS 9609240424
Download: ML20117P654 (3)

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C. R. Hutchinson September 5,1996

.1 U.S. Nuclear Regulatory Commission Mail Station P1-137 '

Washington, D.C. 20555  !

-_ s Attention: Document Control Desk

SUBJECT:

Grand Gulf Nuclear Station, Unit 1  !

Docket No. 50-416 License No. NPF-29 Reply To A Notice Of Violation  !

Scaffolds Not Built in Accordance With Standard GGNS-CS-05 Report No. 50-416/96-11(GNRI-96/00168)

GNRO 96/00101 Gentlemen:

Enter y Operations, Inc. hereby submits the response to Notice Of Violation 50-416/96-11-02.

Yo s truly, l

AG/C 4 a ment cc: Mr. R. B. McGehee (w/a)

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

Mr. J. E. Tedrow (w/a)

Mr. J. W. Yelverton (w/a)

Mr. Leonard J. Callan (w/a)

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011 Mr. J. N. Donohew Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 9609240424 960917 PDR ADOCK 05000416 G PDR

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? . Attachmsnt I of GNRO-96/00101 Pags 1 of 2 l

- 1 Notice Of Violation 96-11-02 '

Criterion V of Appendix B to 10 CFR Part 50 states, in part, that activities affecting quality shall be prescribed by documented procedures and drawings of a type aporopriate to the circumstances and shall be accomplished in accordance with these procedures and drawings.

Appendix A to the Quality Assurance Program states that the licensee shall comply with the requirements of Regulatory Guide 1.29, " Seismic Design Classification." Paragraph C.2 of Regulatory Guide 1.29 requires that nonseismic structures whose failure could reduce the '

functioning of systems important to safety are to be constructed so that a seismic event would 3

not cause such failure. Standard GGNS-CS-05, " Standard for Erection of Scaffolding in Safety- l Related Areas," Revision 0, contained guidance to properly restrain the scaffold and specified applicable scaffold components that included footing, joints, and bracing.

Contrary to the above, on April 26 and June 8,1996, activities affecting quality were not accomplished in accordance with prescribed procedures and drawings in that scaffolds, erected in "A" and "B" Residual Heat Removal and Low Pressure Core Spray pump rooms, were not built in accordance with Standard GGNS-CS-05.

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Admission or Denial of the AllW Violation I Entergy Operations, Inc. admits to this violation, ll. The Reason for the Violation. If Admiw On June 17,1996, the resident inspector found scaffolding erected at valves E12F024A, E12F024B, and E12F012 not built in accordance with Standard CS-05. These valves are located in the Residual Heat Removal (RHR) and Low Pressure Core Spray (LPCS) pump rooms. The inspector informed the licensee, who responded by performing an immediate walkdown of the scaffolding. This walkdown also included all 11/1 (two-over-one) Seismic scaffolding. Quality Deficiency Report (QDR) 146-96 was initiated to document this occurrence.

An Operability Review was performed due to the deficiency in the erected scaffolding. The '

Operability Resolution found that that the safety-related equipment would have still performed as designed.

The root cause of the deficiency was lack of adequate procedural guidance for the erection of scaffolding in the plant. Contributing causes were the utilization of scaffolding evaluations performed prior to Standard CS-05 being issued, and no requirement for independent verification to ensure scaffolding was constructed to Standard CS-05.

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. AttachmInt I of GNRO-96/00101 9 Pega 2 of 2 4

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i Corrective Stoos Which Have Been Taken and Results Achieved

1. A walkdown was performed to ensure all seismic scaffolds were erected in accordance with Standard CS-05. Any scaffolding not in conformance was reworked.

2. Beginning immediately, an independent review is required after the completion of all ll/l (two-over-one) Seismic scaffolds. All existing II/l Seismic scaffolds were inspected to j ensure their compliance with Standard CS-05.

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' 3. The Scaffold Request form was revised. The revision requires an independent review after the completion of 11/1 (two-over-one) Seismic scaffold to ensure the requirements of the j engineering evaluation or Standard CS-05 are met.

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! 4. All scaffolding evaluations performed prior to January 1,1993, will not be utilized. Any

evaluation made prior to this date may not be in compliance with Standard CS-05.

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IV. Corrective Stoos to be Taken to Preclude Further Violations 1

l 1. Plant Modification & Construction will develop and implement a Scaffold Erection procedure.

l l V. Date When Full Compliance Will be Achieved

! The development and implementation of the Scaffold Erection procedure will be completed by j September 30,1996.

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