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EA-99-305 - Grand Gulf 1 (Entergy Operations, Inc.)February 22, 2000 EA 99-305 William A. Eaton, Vice President
Dear Mr. Eaton: This refers to your letter dated February 4, 2000, responding to the four apparent violations described in the subject inspection report. Our inspection reviewed the circumstances surrounding a bearing failure which rendered the high pressure core spray (HPCS) diesel generator inoperable on September 9, 1999. You described this event in Licensee Event Report 1999-004 dated October 12, 1999. The results of our inspection were provided to your staff during the inspection exit meeting on December 10, 1999, and the inspection report was issued on January 7, 2000. Based on the information developed during the inspection and the information that you provided in your February 4, 2000, response to the inspection report, the NRC has determined that four violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. The violations are related to the failure of the HPCS diesel generator, which was caused by your staff's failure to resolve issues surrounding the correct oil level needed for the HPCS diesel generator bearing. In July 1998, your staff recognized a conflict between the nameplate data and a vendor drawing for the amount of oil needed for the bearing. Without resolving this inconsistency, your staff lowered the oil level in the HPCS diesel generator east end bearing (to address questions about "frothing" in the oil) to less than the minimum specified in the controlled vendor drawing on July 9, 1999. On September 9, 1999, the HPCS diesel generator bearing failed during the performance of Surveillance 06-OP-1P81-R-0001, "HPCS Diesel Generator 18 Month Functional Test," Revision 104. The most probable cause of the failure was inadequate lubrication of the bearing due to an insufficient supply of lubrication oil. The violations cited in the attached Notice involved: (1) exceeding the Technical Specification 3.8.1 limiting condition for operation regarding the emergency diesel generators; (2) failing to include the diesel generator bearings as a potential cause for the "Generator RTD Temp Hi" alarm in the applicable alarm response instruction; (3) revising a work package that changed the degree of the impact statement to the plant without the required reviews; and (4) failing to initiate condition reports on two separate occasions when nonconformances were discovered. The safety significance of these violations is that the HPCS diesel generator, if called upon, would not have been able to perform its intended safety function for approximately 74 days. The HPCS diesel generator is the independent onsite power supply for the HPCS emergency core cooling system and is the only source of emergency AC power for plant safety equipment during a station blackout (loss of offsite power coincident with a failure of the Division I and II standby diesel generators). Therefore, these four violations are classified in the aggregate in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600 as a Severity Level III problem. In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III problem. Because your facility has not been the subject of escalated enforcement actions within the last 2 years, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Your corrective actions included establishing a significant event response team (SERT), resolving inconsistent information regarding the oil level, reviewing configuration control practices, reviewing this condition with engineering personnel, addressing the alarm response instruction, reviewing practices regarding maintenance work packages, reviewing practices regarding information tags, discussing with engineering department staff management expectations regarding condition reports, and resolving questions about frothing/aeration in the diesel generator bearing oil. Based on these actions, we have determined that credit for the Corrective Action factor is warranted. Therefore, in recognition of your prompt and comprehensive corrective actions, and the absence of previous escalated enforcement action, I have been authorized not to propose a civil penalty in this case. In your February 4, 2000, letter, you expressed concern with our characterization that the SERT Root Cause report failed to be self-critical or thorough. Our characterization was based on the fact the report did not address two items which we considered to be failed barriers. In recognition that the SERT team did consider these two items, we agree with you that the SERT report was self-critical and thorough. The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in Inspection Report No. 50-416/99-19, LER 1999-004, and your February 4, 2000 letter. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, your February 4, 2000 letter, and any further response you choose to provide will be placed in the NRC Public Document Room.
Docket No. 50-416 Enclosure: Notice of Violation cc (w/encl): Wise, Carter, Child & Caraway Winston & Strawn Sam Mabry, Director President, District 1 General Manager The Honorable Richard Ieyoub Office of the Governor Mike Moore, Attorney General Dr. F. E. Thompson, Jr. Robert W. Goff, Program Director Vice President Director, Nuclear Safety Vice President, Operations
During an NRC inspection conducted on November 29 through December 10, 1999, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
These violations represent a Severity Level III problem (Supplement I). The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in Inspection Report No. 50-416/99-19, LER 1999-004, and your February 4, 2000 letter. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21. Dated this 22nd day of February 2000 |
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