IR 05000458/1990002

Ack Receipt of Re Violations Noted in Insp Rept 50-458/90-02

ML20062A897
Person / Time
Site:	River Bend
Issue date:	10/08/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 9010230209
Download: ML20062A897 (2)

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.In Reply Refer To:

Docket: 50-458/90-02

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Gulf States Utilities ATTN: James C. Deddens

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SeniorVicePresident(RBNG)

P.O. Box 220 St. Francisv111e, Louisiana 70775 Gentlemen:

Thank you for your letter of September 18, 1990,. which provided a revised response to our letter and Notice of Violation dated April 6, 1990. We have reviewed your revised schedule for full compliance and find that it remains responsive to the concerns raised in our Notice of-Violation. We will review the implementation of your corrective actions during a future inspection to N i

determine that full compliance has been achieved and will be maintained.,

Sincerely, OdelnalGigned By: .

Thomas P.Gwynn Samuel J. Collins, Director Division of Reactor Projects l cc:

Gulf States Utilities ATTH: J. E. Booker, Manager-Nuclear Industry Relations P.O. Box 2951 Beaumont Texas 77704

Bishop. Cook, Purcell & Reynolds ATTN: Mark. Wetterhahn, Es .

1401 L Street, N. L L Washington, D.C. 20005 i- ,

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Gulf States Utilities ATTN: Les England, Director Nuclear Licensing-P.O. Box 220 St. Francisville Louisiana 70775 RIV:RI:PSS C6 C:PS$h D:DR : RP f JCoJ11ns CJohnson/cjg /f TStetka to /4 /90 g /0/4 /90 LJCa p/4 /90 lanP'N '

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Gulf States Utilitie !

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,> 'Mr. J. David McNeill, III  ;

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William G. Davis Es ;

Department of Justic 'l

- Attorney General's- Office P.O.~ Box 94095 i Baton Rouge, Louisiana- 70804-9095-  ;

H. Anne Plettinger

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L 3456 Villa Rose Drive , t

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L Baton Rouge, Louisiana -70806 President of West Feliciana E Police Jury -'

1 P.O. Box 1921 St. Francisville,. Louisiana 70775- '

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Cajun Electric Power Coop. In ATTH: Philip G. Harris 10719 Airline Highway P.O. Box 15540 Baton Rouge, Louisiana 70895 Department of Environmental Quality ATTN: William H. Spell, Administrator Radiation Protection Division P.O.. Box 14690 Baton Rouge, Louisiana. 70898 U.S. Nuclear Regulatory Commission ATTN: Resident Inspector

'P.O. Box 1051 St. Francisville, Louisiana 70775'

U.S~ Nuclear Regulatory Commission

ATTN: Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

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bec distrib by RIV:-

R. D. Martin Resident Inspector

DRP; Section Chief (DRP/C)

Lisa Shea, RM/ALF Mls System l DRSS-FRPS RSTS Operator-ProjectEngineer(DRP/C) RIV File -

L DRS Senior Resident Inspector, Cooper l Senior Resident. Inspector, Fort Calhoun T. Stetta C. Johnson '

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Alvth 0END 5t Att0N 0-0$f Of 8lCf DDR 220 St fitANCisvtLLt L0utslANA ?O776 ARE A CODI 604 C35 6364 346 4661 September 18 , 1990

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RBG 33596 File Nos. G9.5, G15. SEP 211990 U. S. Nuclear Regulatory Commission

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Document Control Desk Washington, D.C. 20555

, Gentlemen:

River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/90-02 Pursuant -to 10CFR2.201, this letter revises Gulf States Utilities Company's (G$U) response dated May 7, 1990 to the Notice of Violation for NRC Inspection Report No. 50-458/90-02. The inspection was conducted by Messr Johnson, Singh and Murphy during the period of January 22 - 26, 1990 of activities authorized by NRC Operating License NPF-47 for River Bend Station-Unit 1(RBS). This letter is being submitted at this time pursuant to a

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conversation with Mr. L. Constable today. Revisions to the original response-are denoted in the attachment by change bars in the margi Should you have any questions, please contact M England at (504)381-414 t

Sincerely, f

I 3 . Odell Manager-Oversight River Bend Nuclear Grcup Attachment

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cc: 'U. S. Nuclear Regulatory Comiss16n Region IV j 611 Ryan Plaza Drive Suite 1000 >

Arlington TX 76011 i Senior Resident Inspector Post Office Box 1051 St. Francisville LA 70775-9&ieWo//o ?W-

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UNITED STATES OF AMERICA ,

NUCLEAR REGULA'!ORY COMMISSION STATE OF IDUISIANA )

PARISH OF WEST FELICIANA ) -

Docket No. 50-458 '

In the Matter of )

GULF STATES (ITILITIES COMPANY )

(River Bend Station - Unit 1) .

AFFIDAVIT '

W. H. Odell, being duly sworn, states that he is a Manager

- Oversight for Gulf States Utilities Company; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and. belie , . H. Odell '

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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /8A day of

/M1d-mlHA , 1990. My Commission expires with Lif AllLLOYL 0. ANAAOY Claudia F. Hurst Notary Public.in and for West Feliciana Parish, Louisiana

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ATTACWENT REPLY TO NOTICE OF VIOLATION 50-458/9002-02 (SEVERITY LEVEL III) ,,_

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REFERENCES Response to Violation - Letter from J. C. Deddens to U. S. NRC, dated May 7, ,

199 Notice of Violation - Letter from S. J. Collins to J. C. Deddens, dated April 6, 199 Enforcement Conference Summary - Letter from S. J. Collins to J. Deddens, i dated March 26, 199 I Notice of Enforcement Conference - Dated March 6,199 Inspection Report -

Letter from Collins to J. C. Deddens, dated '

February 26, 199 Licensee Event Report No.89-036 - Letter from J. Booker to NRC, dated I November 16, 1989, Rev. I dated January 31, 199 VIOLATION Operating License NPF-47 Section C.10., states that GSU shall comply with the requirements of the fire protection program as specified in " Attachment 4." '

Attachment 4 to Operating License NPF-47, " Fire Protection Program .

Requirements," states that GSU shall implement and maintain in effect all '

provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment 22 and as approved in the SER dated May 1984 and Supplement 3 dated August 1985 subject to Provisions 2 and 3 below (which are not applicable here).

Tables 2 and 5 of GSU design specification 240.201, " Fire Analysis and Evaluation Criteria and Evaluation Method Including Results and Conclusions for 10 CFR 50, Appendix R Fire Hazards Analysis," part of the approved fire protection program described above, list motor-operated valves for which electrical powgr is assumed to be removed during plant operation Contrary to the above, from November 1985 to October 1989, GSU did not implement and maintain in effect all provisions of the approved fire protection program in that when River Bend Station was operating during this period, electrical power had not been removed from 19 motor-operated valves

! listed in Tables 2 and 5 of design specification 240.201 as having power j removed during plant operation Page 1 of 6

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REASON FOR THE VIOLATION Of the nineteen valves assumed in the FHA to have electrical power removed, four were listed in the Final Safety Analysis Report (FSAR), Section 9A.2.1.2, as high/ low pressure interface valves. These four valves, plus two additional valves associated with steam condensing mode of residual heat removal (RHR), did have power removed during initial startup. Two of these valves, IE12*MOVF009 and 1E12*MOVF040, were subsequently reenergize VALVE 1E12*MOVF009 Valves 1E12*MOVF009 and IE12*M0VF008 are the containment isolation valves for the RHR shutdown cooling mode suction lin This is a high/ low pressure interface between the recirculation system and the RHR shutdown cooling mode pipin The FSAR required one of the pair to have electrical power remove Meeting this requirement of the FSAR also met the assumption for power removal in the FH In Supplement 3 to the Safety Evaluation Report for River Bend Station, August 1985, and a GSU letter dated August 6, 1985, a commitment was made to add a keylock switch in the control circuitry of IE12*MOVF008 to " lock out (block) control of the valve (E12*F008) from both the control room and the remote shutdown panel." The switch was to be installed in the motor control center (MCC) located in the auxiliary building and was not to disable the valve position indication in the control room or the remote shutdown panel Modification request (MR) 85-0956 was initiated and installed in November 1985 to add the keylock switch to the control circuitry for 1E12*MOVF00 Both valves were then energize During the design for the MR, the engineer perceived concerns with locating the switch in the auxiliary building at the MC There were no keylock switches available that could be qualified for the harsh post accident environment in this area. There was also a concern about operator access to the switch during a post accident environment. Due to these concerns, the keylock switch was relocated to the remote shutdown panel in the control buildin In this location, the keylock switch provided easy operator access yet still prevented inadvertent opening of IE12*MOVF008 during a transfer of control from the main control room to the remote shutdown pane The design in the MR and the 10CFR50.59 safety evaluation failed to recognize the concerns associated with fire exposure and subsequent spurious actuation of both the IE12*MOVF008 and 1E12*MOVF009 velves. With the keylock switch located in the remote shutdown panel and the manner in which it was installed in the control, circuitry, a single fire in either the remote shutdown panel or the main c6ntroT room could cause spurious actuation of both valves. With the electrical power restored to both valves after the MR, the assumptions in .

the FHA were violate ;

An inadequate design analysis for MR 85-0956 is considered to be the root !

cause for violating the assumptions of the FHA as related to 1E12*M0VF00 Several factors contributed to the inadequate design analysis. An inadequate i depth of investigation as part of the design development failed to reveal the FHA assumption A lack of familiarity with the FHA and no formal training in the requirements of the FHA on the part of individual system engineers ;

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contributed to this oversight of the FHA. Coupled with this was a deviation from the modification procedure. The modification procedure required a fire protection checklist to be completed if fire protection issues were affecte The fire protection checklist was not prepared, and no review by the design fire protection engineer was performed. The lack in depth of documentation in the methods and assumptions used in the FHA contributed not only in the initial oversight but also in the delay in discovery of the problem. The lack of maturity in the engineering organization during the trans.. ion of responsibility from the architect / engineer to GSV also contributed to the oversight. At the time of installation of the MR, fire protection engineering responsibility was divided among GSV Nuclear Plant Engineering, ;

GSV Technical Staff, the architect / engineer design office, and the architect /

engineer Site Engineering Grou VALVE 1E12*M0VF040 .j Valves 1E12*MOVF040 and 1E12*M0VF049 are the system interface isolation valves between the RHR system and the radwaste syste This is considered a high/ low pressure interface only during the steam condensing mode of RHR. A license condition prohibits use of the steam condensing mode of RHR at River !

Bend Statio Due to this, Engineering Evaluation and Assistance Request ,

(EEAR) 87E-0216 was initiated in May 1987 to evaluate re-energizing IE12*MOVF040 since it is not a high/ low pressure interface valve with steam condensing mode of RHR disable The EEAR was answered in June 1987 with the required changes to the FSAR and operating procedures to allow energizing the r valve. Included in these operational procedure changes was a revision to A0P-0031, " Shutdown from Outside the Main Control Room". This revision .<

required verification that 1E12*M0VF040 was in the closed position if the 'A' .

division of RHR was in shutdown cooling prior to transfer of control from the ;

main control room to the remote shutdown roo Although subsequent reviews for separation showed that this situation was ;

acceptable, the FHA was not revised at the time to delete the assumption of removing power on this valv It is not clear that the FHA and its assumptions were considered in the evaluation proces The oversight ;

associated with EEAR 87E0216 can be attributed to the same root causes as i associated with MR 85-095 ,

REMAINING VALVES The remaining thirteen valves that had not had electrical power removed as assumed in the FHA remained energized due to oversight during the original preparation of operational procedures in 1985. This oversight was most *

probably caused by a lack of awareness by the developers of the procedures of the FHA and* its assumptions. The FSAR listed only those valves that were required to have power removed due to high/ low pressure interface consideration The valves listed in the FSAR were proceduralized to have power removed but those that were only contained in the FHA were overlooke Valve 1821*MOVF019 is not a high/ low pressure interface valve but does represent a potential loss of coolant pat Valve IB21*M0VF019 is an isolation valve for the main steam drain lines. A fire in the main control room could cause spurious actuation of this valve and the other valves in series with this valve. This would allow reactor coolant to bypass the main ,

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steam isolation valves directly to the condense Coupled with the Appendix R-required assumed loss of offsite power, the condenser could be pressurized causing the rupture of the air relief diaphragms on the low pressure turbin Although of minor safety significance, this would represent an uncontrolled discharge to the turbine building atmospher CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The immediate corrective action that was taken in October 1989 upon discovery of the problem was to remove the electrical power from valves IE12*M0VF009 and 1821*MOVF01 Power was removed from these two valves due to inaccessible locations in the drywell and main steam tunnel. A fire wa tch was initiated for the other valves along their control circuitry until the separation required by 10CFR50, Appendix R could be verified. By November :

13, 1989, the review for adequate separation for those valves was completed verifying that the necessary separation did exist. During that time period, the requirenent for removal of power from 1E12*MOVF009 and IB21*MOVF019 was verified since adequate separation did not exist-for these potential loss of coolant paths. Adequate Appendix R separation does not exist in the main control room for either valve and does not exist in the remote shutdown room for IE12*MOVF00 The verification of divisional separation for thirteen of -

the valves and removal of power for two of the valves, along with the four valves which have had power removed since 1985, put the plant in a condition that was in compliance with the basis of the FHA for these valves. MR 90-0003 was issued on January 25, 1990 to revise the FHA to reflect the  ;

current status of the valves in the plan As pa rt of the corrective action, Engineering Analysis performed safety -

assessments of the spurious opening of 1821*MOVF021 and 1E12*M0VF009 due to fires in the main control room and the remote shutdown panel. (Note that IB21*MOVF019 was open with the downstream valve IB21*H0VF021 close "

Therefore, the safety assessment for containment bypass via 1821*MOVF019 focused on the probability of spurious actuation of 1821*H0VF021 due to fire, to create an open bypass pathway.) Details of these assessments are provided in the referenced Licensee Event Repor The probabilistic risk assessment (PRA) for 1821*MOVF021 indicated that the probability for a steam release from the condenser was approximately 1.9 E-04 over the time the valve was energized. The radioactivity releases from this event were determined to remain below 10CFR20 and 10CFR100 limit Therefore, the safety significance of this event is lo The PRA for IE12*M0VF009 examined the likelihood of an interfacing system

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LOCA and estimated the core damage frequency (CDF) for this event as 5.8E-0 This is a factor of 100 below the total CDF of 5.0E-06 for RBS. Therefore,

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l j the safety significance of this event is also lo Due to the heightened awareness of the FHA and the lack of incorporation of specific requirements associated with the valves, GSU Quality Assurance performed from January 1 - Februa ry 7, 1990 a Safety System Functional Inspection (SSFI) of the FHA as related to the energized valves. The SSFI l identified several recommendations for operator actions from the FHA that l

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were not reflected in the plant Prefire Strategies. The SSFI also identified

two instances where the necessary electrical jumpers were not available for potential fire-induced repairs required for equipment necessary to achieve cold shutdow The affected Prefire Strategies were revised by March 8, 1990, to add the reconcendations for operator action from the FHA. The electrical jumpers and work packages for the repairs necessary to equipment for cold shutdown were fabricated and staged by January 26, 199 An initial review of the FHA by Design Engineering was completed in January 1990 to verify the consistency of the existing design and operational procedures. This review was done in conjunction with review of the Prefire Strategies to ensure all actions or plant conditions assumed in the FHA were contained in the Prefire Strategies or other plant procedures. No other inconsistencies other than those already detailed were identifie In addition to the actions taken to correct the sp;cific condition with the valves and FHA, additional progrannatic actions have been taken over the last few year In 1987, responsibility for fire protection engineering was consolidated in Design Engineering. This minimized the potential for errors due to confusion over engineering responsibility. Procedural compliance has improved throughout River Bend. The need for procedural compliance has been emphasized to all managers and supervisor The Design Engineering supervisors review and evaluate each QA unsatisfactory finding (unsats) and Quality Assurance Finding Report assigned to Design Engineering. The results of those evaluations are discussed in Design Engineering staff meetings to determine if trends in unsats are developing and to correct those trends early. This has resulted in a significant decrease in the number of unsats generated against Design Engineering document The modification procedure has been revised to require increased depth of design bases evaluation and documentatio This will help preclude an oversight of the FHA and its requirements in the futur CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Although the corrective actions that have been taken to date bring the plant into a state of full compliance with the operating license, additional corrective actions are necessary to ensure a similar situation does not occur in the future. The corrective actions are separated into three areas: the FHA and associated procedures, modification requests, and trainin As stated above, an initial review of the FHA has been performed. A final review and veH fication of the FHA will be performed by an independent contracto In addition, the independent contractor is to provide fully detailed documentation of the design bases and assumptions of the FH Additional verification of the consistency between the FHA and plant procedures will be perfonned by the independent contracto This will be followed by another SSFI performed by GSU Quality Engineering to evaluate implementation and effectiveness as outlined in the FH To ensure that no additional modification requests with similar oversights exist, a review of MRs engineered from the time GSU assumed control of the Page 5 of 6

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design modification process to January 20, 1987 will be perfonned. This review will be done to ensure that adequate documentation exists for potential impact on the FH After January 20, 1987,the fire protection f checklist was required to be completed for all MRs. If the review of MRs engineered prior to that date indicates the problem may extend beyond January 20, 1987, the scope of the review will be increase t In order to increase the general awareness of the Fire Hazards Analysis and its requirements, a training program on the FHA is to be develope The training program will be provided to all engineers who perform modification requests and safety evaluations. In addition to the engineers, the members of the Facility Review Committee and appropriate operations personnel will be given training on the FHA. The training for the operations personnel will include the recommended operator actions that are included in the FH In addition to the corrective actions that are being done to prevent a recurrence, an investigation is being pursued to allow operations to energize 1821*MOVF019 during startup phases of plant, without continuous opera tor attendance at the valve's MCC. This investigation is evaluating the amount of time that would be required to pressurize the condenser and rupture the air relief diaphragms with the reactor at various power levels and pressure These times will be evaluated to determine at what pressure level or power level adequate time is available for ensuring isolation of the main steam drain lines in the event of a main control room fir Until the investigation is completed, this valve will remain under current control DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED As of Ma rch 8, 1990, with the issuance of the revised Prefire Strategies, ;

River Bend Station was in compliance with the Fire Protection Program as required by its operating licens Further corrective actions will be accomplished per the following schedule:

- The contract has been awarded to NUS Corporation for the FHA review and documentation, the proposed schedule requires the work to be complete by January 15, 199 Review of the MRs will be complete by February 28, 199 The follow-up SSFI to evaluate the implementation and effectiveness of revised procedures regarding the FHA will be performed by July 199 Implementat, ion of the training program will be complete during the second quarter 1991'. '

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