IR 05000458/1993011
| ML20036B606 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/21/1993 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Graham P GULF STATES UTILITIES CO. |
| Shared Package | |
| ML20036B607 | List: |
| References | |
| EA-93-060, EA-93-60, NUDOCS 9305260115 | |
| Download: ML20036B606 (5) | |
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NUCLEAR REGULATORY COMMISSION i
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8 611 RYAN PLAZA ORIVE. SUITE 400 o,
ARLINGTON, TEXAS 760114064
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Docket:
50-458 l
l Gulf States Utilities ATTN:
P. D. Graham Vice President (RBNG)
P.O. Box 220 St. Francisville, Louisiana 70775 i
SUBJECT. NOTICE OF VIOLATION AND P30 POSED IMPOSITION OF CIVIL PENALTY -
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$50,000 (NRC INSPECTION REPORT N0. 50-458/93-11)
i This is in reference to the inspection conducted February 25-March 30, 1993, at the River Bend-Station r.aclear power plant, St. Francisville, Louisiana.
This inspection was conducted specifically to review the circumstances I
surrounding two events that occurred on February 25 involving the operation of interlock mechanisms on the containment personnel airlock.
A-report documenting the results of this inspection was issued on April 12, 1993. On April 21, 1993, you and other Gulf States Utilities (GSU) representatives j
attended an enforcement conference in the NRC's Arlington, Texas office to discuss NRC's preliminary conclusion that potentially significant violations of NRC requirements and plant Technical Specifications had occurred. This conference was open to public observation in accordance with the terms of a pilot program begun by the NRC in July 1992.
The violations described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved:
1) the failure to perform an adequate evaluation to determine whether an unreviewed safety question existed prior to permanently modifying the containment and drywell airlock interlock mechanisms described in the River Bend Station safety analysis report on October 25, 1991 (the NRC notes that the interlock mechanisms were effectively modified a year earlier, in October 1990, when ' power was removed from the electrical portion); 2) the failure to maintain the containment airlock interlock mechanisms in an operable condition per Technical Specification 3.6.1.4 between October 1990 and March 1993; and 3) the failure to perform an adequate containment airlock surveillance-test to ensure'that only one airlock door could be opened at one time.
The circumstances surrounding these violations are-described-in more detail in the
,ection report.
Fror the NRC's perspe i.e, the n.ost significant failure on the part of GSU is its failure to understand the design bases for the contain'nent and drywell airlock interlock mechanisms. This appears to be the root cause of these violations.
Because GSU did not recognize the
l necessity of maintaining the electrical portion of the interlock system, plant
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staff proceeded to disable the electrical portion of both the containment and drywell airlock mechanisms.
This created a potential for breaching the i
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integrity of the containment structure when personnel were passing through the
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Gulf States Utilities-2-airlock. Modifying the design of the facility, as described in the plant safety analysis report, and not conducting an adequate safety analysis to determine whether the modification created an unreviewed safety question are of significant regulatory concern to the NRC.
Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
(Enforcement Policy) 10 CFR Part 2, Appendix C, these violations are classified in the aggregate as a Severity Level III problem.
Although the NRC considers these violations significant from a regulatorf perspective and from an overall safety perspective -- because they created a
potential threat to the safety of licensed activities -- we acknowledge, as GSU pointed out during the enforcement conference. that the actual effect on the safety of the f acility was minimal because there are only three documented instances in which the integrity of the containment structure was breached i
(two in February 1993 and an additional instance in 1986 that GSU brought to
the NRC's attention at the conference), each involving very brief periods of i
time and each having been promptly recognized and corrected.
The NRC also
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recognizes that GSU ras taken corrective action to enhance its procedures for conducting safety ana. lyses when facility modifications are made, to ensure the proper coeration of the containment and drywell airlock interlock mechanisms and to conduct a routine surveillance test that ensures that the interlock mechanisms work as designed and as described in design documents.
To emphasize the importance of understanding the plant design bases and ensurir,g that modifications do not result in a reduction of the intended level of safety, I have been authorized to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $50,000 for the Severity Level III problem described above and in the Notice. The base
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value of a civil penalty for a Severity Level III problem is $50,000.
The civil penalty adjustment factors in the Enforcement Policy were considered and resulted in no net adjustment to the base value.
In considering the
" Identification" factor, the NRC determined that a 50-percent increase was warranted because the electrical interlock unreviewed safety question was i
identified by the NRC inspectors and would not have been discovered had it not been for the pursuit of the inspectors.
This increase was balanced against a
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50-percent decrease based on GSU's corrective actions, discussed above.
The
remaining adjustment factors were considered but no further adjustments were i
determined to be appropriate.
You are required to respond to this letter and should fallow the instructions
specified in the enclosed Notice when preparina your response.
In your i
response, you should document the specific actions taker, and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future
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inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of l
this letter and its enclosure will be placed in the NRC Public Document Room.
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. Gulf States Utilities-3-The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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Sincerely, O
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Milhoan
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legional Administrator Enclosure:
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Notice of Violation and Proposed Imposition l
of Civil Penalty-Gulf States Utilities ATTN:
J. E. Booker, Manager-tJ. clear Industry Relations l
P.O. Box 2951 l
Beaumont, Texas 77704 l
Winston & Strawn l
ATTN: Mark J. Wetterhahn, Esq.
l 1401 L Street, N.W.
Washington, D.C.
20005-3502 Gulf State 3 Utilities ATTN:
Les England, Director Nuclear Licensing P.O. Box 220 St. Francisville, Louisiana 70775
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Mr. J. David McNeill, 111 William G. Davis, Esq.
Department of Justice Attorney General's Office P.O. Box 94095 t
Baton Rouge, Louisiana 70804-9095 H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, Louisiana 70..
President of West Feliciana Police Jury
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P.O. Box 1921 St. Francisville, Louisiana 70775
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. Gulf States Utilities-4-Cajun Electric Power Coop. Inc.
ATTN:
Philip G. Harris 10719 Airline Highway P.O. Box 15540 Baton Rouge, Louisiana 70895 Hall Bohlinger, Administrator Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135
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H0 DISTRIBUTION:
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CA JTaylor, EDO JSniezek, DEDR HThompson, DEDS TMurley, NRR JPartlow, NRR/ADP JLieberman, OE (4)(1-single sided)
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l Enforcement Officers RI, RII, RIII, RV FIngram, PA DWilliams, OIG EJordan, AE0D BHayes, 01 DCS RIV DISTRIBUTION:
JMilhoan JMontgomery ABBeach>TPGwynn SCollins>AHowell JGagliardo*Ecollins WSmith>0 Loveless JGilliland CHackney WBrown GSanborn>RWise>EAFile LWilliamson RIV Files RSTS Operator MIS Coordinator
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