IR 05000458/1995025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/95-25 on 960109

ML20149L521
Person / Time
Site:	River Bend
Issue date:	02/22/1996
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mcgaha J ENTERGY OPERATIONS, INC.
References
NUDOCS 9602270040
Download: ML20149L521 (5)

Text

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pa alc% UNITED ST ATES

, A *. NUCLEAR REGULATORY COMMISSION

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FEB 2 21996

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Entergy Operations, In ATTN: John R. McGaha, Vice President -

Operations, River Bend Station P.O. Box 220 St. Francisville, Louisiana 70775 SUBJECT: NRC INSPECTION REPORT 50-458/95-25 Thank you for your letter of February 1,1996, in response to our letter and Notice of Violation dated January 9, 1996. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violatio Also, on February 12, 1996, from conversations between Mr. David Lorfing of your staff and Mr. Greg Pick of our staff, we understand that your In-House Event

Analysis group will complete their independent review to assess the adequacy of the root cause and corrective actions related to a sampling of Licensee Event Reports from 1994 and 1995 by April 1, 1996.

] We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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bcu wu J. E. Dyer, t irector p Division of Reactor Projects Docket: 50-458 License: NPF-47 cc:

Entergy Operations, In ATTN: J. W. Yelverton, Executive Vice President and Chief Operating Officer P.O. Box 31995 Jackson, Mississippi 39286-1995 Entergy Operations, In ATTN: Jerrold G. Dewease, Vice President Operations Support P 0. Box 31995 Jackson, Mississippi 39286-1995 i

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Entergy Operations, In Entergy Operations, In ATTN: Michael B. Sellman, General Manager Plant Operations P.0. Box 220 St. Francisville, Louisiana 70775 Entergy Operations, In ATTN: James J. Fisicaro, Director Nuclear Safety River Bend Station P.O. Box 220 St. Francisville, Louisiana 70775 Wise, Carter, Child & Caraway ATTN: Robert B. McGehee, Es l P.O. Box 651 Jackson, Mississippi 39205 Winston & Strawn ATTN: Mark J. Wetterhahn, Es i 1401 L Street, i Washington, D.C. 20005-3502 ,

Entergy Operations, In ATTN: - J. E. Venable, Manager - Licensing P.O. Box 220 St. Francisville, Louisiana 70775 The Honorable Richard P. Ieyoub Attorney General ,

P.O. Box 94095 i

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Baton Rouge, Louisiana 70804-9095 H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, Louisiana 70806 President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 Cajun Electric Power Coop. In ATTN: Larry G. Johnson, Director Systems Engineering 10719 Airline Highway P.O. Box 15540

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Baton Rouge, Louisiana 70895 l

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Entergy Operations, In William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135 j l

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P FEB 221996 Entergy Operations, In bec!tsID s {IE01)4 p ,

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L. J. Callan Resident Inspector Branch Chief (DRP/D) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

Project Engineer (DRP/D) Senior Resident Inspector (Grand Gulf)

MIS System DRS-PSB RIV File Branch Chief (DRP/TSS)

Senior Resident Inspector (Cooper)

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DOCUMENT NAME: R:\_RB\RB525AK.WFS To receive copy of desument, Indicate in her "C" = Copgwithout enclosges T = Copy with enclosures T = No copy PE/DRP/0,,o l C:DRP/Q _d/,4:0RPrA6l

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OFFICIAL RECORD COPY 27000g

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FEB 221996 Entergy Operations, In i bec to DMB (IE01)

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L. J. Callan Resident Inspector Branch Chief (DRP/D) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

Project Engineer (DRP/D) Senior Resident Inspector (Grand Gulf)

MIS System DRS-PSB RIV File Branch Chief (DRP/TSS)

Senior Resident Inspector (Cooper)

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DOCUMENT NAME: R:\_RB\RB525AK.WFS To receive copy of document, indicate in box:"C" = Cop 4without enclosges *E* = Copy with enclosures "N" = No copy PE/DRP/D,,o l C:DRP/D gh:DRPpA6l l l GAPick W PHHarW'// JEDyeV k ,

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OFFICIAL RECORD COPY

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James J. Fisicaro DirectOf

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February 1,1996 g 6@ j U.S. Nuclear Regulatory Commission Document Control Desk Mail Stop PI-37 Washington, D.C. 20555 Subject: Reply to Notice of Violation 50-458/9525-01 & 03 River Band Station - Unit I / Docket No. 50-458/95-25 File Nos. G9.5, G15. RBG-42414 RBF1-96-0036 Gentlemen:

Pursuant to 10CFR2.201, attached please find Entergy Operation's response to the notice of violation described in NRC Inspection Report (IR) 95-25. This Inspection Report cited two l separate violations. The first violation involved incorrect application of 10CFR50, Appendix l

' A', GDC 55 to two instrument lines for positive control of containment integrity. The second l violation involved a missed technical specification surveillanc Entergy Operations agrees with these violations. We share your concern and recognize the importance or positive control of containment integrity and adequacy of corrective actions in the licensee event reports. We have, therefore, taken immediate corrective measures and have planned additional long term measures to address these important issues. The response to the first violation (458/9525-01) is attache The response to the second violation (458/9525-03) is documented in the Licensee Event Report (LER) 50-458/95-009-00 dated December 1,1995. River Bend Station management places a high emphasis on the adequacy of root causes and corrective actions for significant conditions including LERs. Special root cause expertise is provided for investigating significant conditions and the Corrective Action Review Board (CARB), consisting of managers and directors, reviews these investigat!Ons for adequacy. As a result of this effort, substantial improvements have been observed in the corrective action program. This is evident through both EOI and NRC reviews of the progra S 5 A ItU7P5Ui/cr 4p ._ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _

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Reply to Notice of Violation 50-458/9525-01 & 03 February 1,1996 RBF1-96-0036 j

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RBG-42414 Page 2 of 2 The In-House Event Analysis (IHEA) group at River Bend Station, which consists of highly trained root cause analysis personnel, plans to review a representative sample of River Bend Station LERs from January 1,1994, through December,1995, to assure adequacy of the root causes and corrective actions. Based on this review, necessary action will be take ,

If you have any questions, please call David Lorfing at (504) 381-415 {

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Sincerely,

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cc: U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Sr. Resi&st Inspector P. O. Box !051 St. Francisville, LA 70775 INPO Records Center

, 700 Galleria Parkway Atlanta, GA 30339-3064 Mr. C. R. Oberg Public Utility Commission of Texas 7800 Shoal Creek Blvd., Suite 400 North Austin, TX 78757 Louisiana Department of Environmental Quality Radiation Protection Division P.O. Box 82135 Baton Rouge, LA 70884-2135 ATrN: Administrator

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ATTACHMENT REPLY TO A NOTICE OF VIOLATION 458/9525-01 Violation 10CFR Part 50, Appendix A, General Design Criterion 55 states, in part, that each line that is part of the reactor coolant pressure boundary and that penetrates primary reactor containment shall be l provided with one automatic isolation valve inside and one locked closed isolation valve outside I l

of containment unless it can be demonstrated that the containment isolation provisions for a specific class oflines are acceptable on some other dermed basi Contrary to the above, as of October 30,1995, a primary containment penetration included a line that did not meet containment isolation provisions in that the low pressure core spray instrument line did not contain one locked closed isolation valve outside of containment and no other demonstrated provisions were identified as acceptabl l Reason For The Violation Entergy Operations Inc., concurs with this violation. The instmment lines associated with the aforementioned Low Pressure Core Spray (LPCS) pressure transmitter and with a similar instrument line associated with the Residual Heat Removal (RHR) Loop C pressure transmitter were not identified as part of the containment isolation boundary during the original River Bend licensing process, or during a subsequent review of valve locking requirements in 198 Investigation of the violation concluded that 10CFR50, Appendix A, General Design Criteria 55 was incorrectly applied in these cases. One of the factors contributing to the incorrect interpretation was the unusual instrument line configuration which is not specifically addressed in the regulatory guidance for instrument line containment isolation or Emergency Core Cooling System (ECCS) influent line isolation. Another factor was that manual valves, similar to those used as the isolation boundary for leakage monitoring connections, were present on the instrument root connectio There was no adverse impact on the plant operation or safety as the instrument valves were in their correct closed position prior to adding the locking device Corrective Steps That Have Been Taken and The Results Achieved Condition Report 95-1145 was initiated to document the described condition and implement

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corrective actions. The appropriate valves for the LPCS and the RHR Loop C pressure transmitters were sealed closed. A detailed review of the piping and instrumentation diagrams showing the containment penetrations listed in Updated Safety Analysis Report Table 6.2-40 was completed. There were no additionalinstances oflines in the containment isolation boundary without a defined, accepted isoi tion basi Pagt: 1 of 2

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Corrective Steos That Will Be Taken To Avoid Further Violations The Updated Safety Analysis Report will be revised to identify the LPCS and RHR pressure transmitter vent and drain valves as part of the containment isolation boundary and to include their defined basis for compliance with 10CFR50, Appendix A, GDC 55. Piping and instmmentation diagrams and applicable procedures will be revised to identify these valves as locked closed. Additional guidance will be included in the engineering procedure for determining valve locking requirement Date When Full Compliance Will Be Achieved The current configuration of the LPCS and RHR Loop C pressure transmitter lines are in compliance with 10CFR50 Appendix A, GDC 55 requirements. Full compliance will be achieved by March 31,1996, when the license change document to revise the Updated Safety Analysis Report documenting the defined basis for the instrument line valve locking requirements will be complete .

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