IR 05000458/1996013
| ML20128M738 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/09/1996 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mcgaha J ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9610160170 | |
| Download: ML20128M738 (5) | |
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NUCLEAR REGULATORY COMMISSION
- i REGloN IV
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611 RYAN PL AZA DRIVE. SUITE 400
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5,,....J AR LtNGToN. TE XAS 76011 8064 OCT 9 1996 John R. McGaha, Vice Preside nt - Operations River Bend Station Entergy Operations, Inc.
P.O. Box 220
^t. Francisville, Louisiana 70775 SUBJECT: NRC INSPECTION REPORT 50-458/96-13 Thank you for your letter of September 23,1996,in response to our letter and Notice of Violation dated August 23,1996. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely,
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l, J. E. Dyer, Director j
Division of Reactor Projects Docket No.- 50-458 License No.. NPF 47 cc:
Executive Vice President and Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 Vice President Operations Support Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 9610160170 961009 PDR ADOCK 05000458 G
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Entergy Operations, Inc.
-2-General Manager Plant Operations River Bend Station Entergy Operations, Inc.
P.O. Box 220 St. Francisville, Louisiana 70775 Director - Nuclear Safety River Bend Station Entergy Operations, Inc.
P.O. Box 220 St. Francisville, Louisiana 70775 Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 Mark J. Wetterhahn, Esq.
Winston & Strawn 1401 L Street, N.W.
Washington, D.C. 20005-3502
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Manager - Licensing River Bend Station Entergy Operations, Inc.
P.O. Dox 22C St. Francisville, Louisiana 70775 The Honorable Richard P. leyoub Attorney General P.O. Box 94095 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
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Entergy Operations, Inc.
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Larry G. Johnson, Director Systems Engineering Cajun Electric Power Coop. Inc.
10719 Airline Highway P.O. Dox 15540 Baton Rouge, Louisiana 70895 l
William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135
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OCT 9 1996
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Entergy Operations, Inc.
-4-ficc~i$UMb (IE01)
bec distrib. by RIV:
L. J. Callan Senior Resident Inspector (Grand Gulf)
DRP Director Senior Resident inspector (Cooper)
Branch Chief (DRP/D)
DRS-PSB Project Engineer (DRP/D)
MIS System Branch Chief (DRP/TSS)
RIV File Resident Inspector Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
DOCUMENT NAME: R:\\_RB\\RB613 AK.WFS To receive copy of document, indicate in box: "C" = Copy w.thout enclosures
"E" = Copy with enclosures "N" = No copy PE:DRP/b C:DRP/D l, d D:DRP @
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PHHa@ g JEDye P 10/ V> /96 10/ M/96 10/ 7 /96 OFFICIAL RECORD COPY 1600y
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OCT g 1996
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Entergy Operations, Inc.
-4-bec to DMB (IE01)
bec distrib. by RIV:
L. J. Callan Senior Resident inspector (Grand Gulf)
DRP Director Senior Resident inspector (Cooper)
Branch Chief (DRP/D)
DRS-PSB Project Engineer (DRP/D)
MIS System Branch Chief (DRP/TSS)
RIV File Resident inspector Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
DOCUMENT NAME: R:\\_RB\\RB613AK.WFS To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enchsures "N" = No copy
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PHHagy K JEDyePR 10/ 'fy /96 10/ M/36 10/ 7 /96 OFFICIAL RECORD COPY
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nt:rgy oper tions,Inc.
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O Box 220 c, soa eas sace a
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l Rick J. King
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September 23,1996
~d6 U S. Nuclear Regulatory Commission ATTN: Document Control Desk M/S PI-37 Washington, DC 20555-0001 Subject Reply to a Notices of Violation 50-458/96-13 River Bend Station - IJnit I License No NPF-47 Docket No 50-458 File Nos.:
G9.5, G15 41 RBG-43252 RBF1 96-0357 Gentlemen:
Pursuant to the provisions of 10CFR2.201, attached is the Entergy Operations Inc.
response to the notice of violations described in NRC Inspection Report (IR) 96-13. The subject violations address a problem with the implementation of an Inservice Testing Program (IST) procedure and an instance where a high radiation area was not posted as required.
The IST issue that is the subject of this violation is one of several issues identified that involve various aspects of the IST p agram. A comprehensive evaluation of these issues has been conducted by RBS management. An action plan has also been issued to facilitate rapid improvements within the program. Some of the enhancements and program adjustments identified by this action plan are as follows:
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Reply to Notices of Violation 50-458/96-13 September 23,1996 R BG-43252 RBF 1-96-0357 Page 2 of 2 More experienced engineers and operators assigned to IST
IST Test Director present in field during testing
Hands-on gauge installation training
Pre-test and post-test briefings
Procedure review to ensure appropriate level of detail
IST procedure validation not performed by an IST expert e
Note added to pump test procedures to allow stoppage for troubleshooting
Engineering Programs to perform a one-time validation of pump test procedures by
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observing successful performance Increased management observations in the area ofIST
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Should you have any questions regarding the attached information, please contact Mr.
- David Lorfing of my staff at (504) 381-4157.
Sincerely, b
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i RECRM/
attachments cc:
U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Sr. Resident inspector i
P. O. Box 1050 St. Francisville, LA 70775 i
David Wigginton NRR Project Manager U. S. Nuclear Regulatory Commission M/S OWFN 13-H-15 Washington, DC 20555
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a ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-458/9613-01 Violation:
Technical Specification 5.4.1.a states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 133, " Quality Assurance Program Requirements (Operations),"
Revision 2, Febmary 1978.
Appendix A of Regulatory Guide 1.33, Item 8 b.(2)(j) states, in part, that specific procedures for emergency core cooling system tests are applicable. Step 7.10.3 of Surveillance Test Procedure STP-204-6304, " Division 11 RHR Quarterly Valve Operability Test," Revision 10, stated, " Connect a 0-100 psig test gauge to the air actuator pressure regulator for IE12* AOVF098."
Contrary to the above, on July 29,1996 Procedure STP-204-6304 was not properly implemented in that an operator disconnected air tubing between the air actuator and the solenoid air control valve in preparation for connecting a test gauge, instead of connecting the test gauge to the air actuator pressure regulator for Valve IE12* AOVFO98.
Reasons for the Violation:
The reason for this violation was misinterpretation of procedural guidance. During the performance of a quarterly valve operability test, the operators were unsure of where to install a pressure gauge due in part, to their knowledge level of the test, and the level of detail provided in the procedure for the installation of the test gauge. Instead of stopping work, the operators made an assumption concerning gauge placement and disconnected an air line down stream of the regulator in preparation for installing the test rig when it arrived at the test beation. The actual test connection was the pressure port on the regulator itself. The operators did not involve the IST Coordinator, the Operations Shift Superintendent (OSS) or the Control Room Supervisor (CRS). Station procedures are clear that the OSS/CRS are to be consulted if there are questions concerning the performance of surveillance procedures.
Corrective Actions That Have Been Taken:
The operator was instructed to reconnect the air supply line and connect the pressure gauge to the pressure regulator. Retest requirements, due to this air supply line being disconnected, were verified. Once the air supply line was reconnected and the gauge properly installed, the test was completed satisfactorily including a leak test of the air supply line with the line pressurize ___
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Attachment A Page 2 of 2
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Operations department personnel have been instructed to notify the OSS / CRS when they have questions concerning the performance of surveillance tests. The operators performing the procedure were counseled on the importance of the OSS/CRS's role in the interpretation of procedural steps.
Corrective Actions That Will Be Taken to Avoid Further Violations:
Further management level accountability sessions will be held for the operators involved with this event. This action will be completed by September 24,1996.
The procedure step in question states that th ; gauge was to be installed at the pressure regulator. The procedure did not specify where on the pressure regulator to install the gauge or that an existing gauge had to be removed to allow installation. This is the only inservice test that uses the pressure sensing port on a pressure regulator as a test connection The procedure step will be clarified prior to the riext performance of the test.
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Date When Full Compliance Will Be Achieved:
Full compliance was achieved on July 29,1996, when the air supply line was connected and the test was completed satisfactorily.
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ATTACHMENT B REPLY TO A NOTICE OF VIOLATION 50-458/9613-02 i
i Violation:
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Technical Specification 5.7.1 states, in part, that each high radiation area in which the j
intensity of radiation is greater than 100 mR/hr but less than 1000 mR/hr shall be barricaded and conspicuously posted as a high radiation area.
Section 6.3 of Radiation Protection Procedure RPP-0005, " Posting of Radiological Controlled Areas," Revision 10, required, in part, that areas accessible to individt.als in
j which radiation levels could result in an individual receiving a deep dose equivalent in
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excess of 100 mR in I hour at 12 inches shall be conspicuously posted as a high radiation
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area, shall have radiological barriers and boundaries established, and shall have a sign posted resembling a stop sign that states, " TECH SPEC MONITORING REQUIRED S
BEYOND THIS POINT."
Contrary to the above, on May 21,1996, an area in which radiation levels exceeded 100 mR/hr was not posted as a high radiation area in that a filter assembly was loaded on a flat
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bed trailer in the radwaste building truck bay, allowing personnel access, to a high
radiation area that was not posted and barricaded until May 27.
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Reasons for the Violation:
l The reason for this violation was that the Radiation Protection technician did not follow basic radiation protection work practices for surveying and posting high radiation areas.
l Initial survey information obtained on the empty flatbed truc'.: by a Radiation Protection
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technician did not reveal a high radiation area. The technician did not climb up on the
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filter after it was loaded on the flatbed truck and conduct a survey. He estimated that the l
workers would not be exposed to a radiation field of 100 mrem /hr or greater based on his
initial survey.
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The technician did not discover the high radiation area while the workers were on the filter assembly disconnecting the rigging from the crane. The high radiation area was found by I
a different Radiation Protection technician on May 27,1996. It was then realized that the workers that disconnected the rigging most likely had their heads in a high radiation area for a short period of time.
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Attachment B Page 2 of 2 Corrective Actions That Have Been Taken:
Upon discovery, RP personnel posted the tmck bay as a "high radiaticn area." The condition report response and related issues were discussed with RP personnel during an RP department information meeting on June 18,1996. A dose assessment was performed for the workers exposed during the incident (highest dose for this event was estimated to be 50 mR). The RP technician was counseled on expectations and the actions he should have taken. A talking paper was developed for RP supervisors / foremen to use in reinforcing posting requirements and expectations. An employee newsletter was issued, discussing posting requirements and expectations. Continuing training is scheduled for RP personnel on observation techniques and the detrimental impacts of complacency during job performance.
The expectations for posting equipment in the truck bay located adjacent to the resin liner shield wall were reiterated to the RP technicians. The importance ofimplementing this policy was also stressed.
Corrective Actions That Will Be Taken to Avoid Further Violations:
Corrective actions associated with this violation have been completed.
l Date When Full Compliance Will Be Achieved:
Full compliance was achieved when the tmck bay area wrs properly surveyed and posted.
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