IR 05000458/1996016

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/96-16

ML20137J836
Person / Time
Site:	River Bend
Issue date:	04/01/1997
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mcgaha J ENTERGY OPERATIONS, INC.
References
NUDOCS 9704040151
Download: ML20137J836 (5)

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NUCLEAR REGULATORY COMMMSION f k,,M[8j [5

REGION IV

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611 RYAN PLAZA DRIVE, SulTE 400

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APR I1997 John R. McGaha, Vice President - Operations River Bend Station Entergy Operations, Inc.

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P.O. Box 220 St. Francisville, Louisiana 70775 SUBJECT: NRC INSPECTION REPORT 50-458/96-16 Thank you for your letter of February 6,1997, in response to our letter and Notice of Violation dated January 7,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation.

For Violation 50-458/9616-01, you indicated that the second example was not a procedure discrepancy. We agree that no discrepancy existed between the control board and electrical breaker lineups solely because the procedurally specified component positions differed; therefore, we withdraw this as an example of the violation.

We will review the implementation of your corrective actions during a future inspection to

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

Sincerely, J. E. Dyer, Deputy Regional Administrator Docket No.: 50-458 License No.: NPF-47 cc:

Executive Vice President and Chief Operating Officer Entergy Operations, Inc.

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P.O. Box 31995 Jackson, Mississippi 39286-1995 lEl,E%IEl$l$[gl[ll[ll

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Entergy Operations, Irc.

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Vice President

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I Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 General Manager Plant Operations River Bend Station Entergy Operations, Inc.

P.O. Box 220 St. Francisville, Louisiana 70775

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Director - Nuclear Safety River Bend Station

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Entergy Operations, Inc.

P.O. Box 220 St. Francisville, Louisiana 70775

Wise, Carter, Child & Caraway

P.O. Box 651 l

Jackson, Mississippi 39205 i

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Mark J. Wetterhahn, Esq.

Winston & Strawn

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1401 L Street, N.W.

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Washington, D.C. 20005-3502

Manager - Licensing River Bend Station

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Entergy Operations, Inc.

P.O. Box 220 i

St. Francisville, Louisiana 70775

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The Honorable Richard P. leyoub Attorney General

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i P.O. Box 94095

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Baton Rouge, Louisiana 70804-9095

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H. Anne Plettinger i

3456 Villa Rose Drive Baton Rouge, Louisiana 70806

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Entergy Operations, Inc.

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President of West Feliciana Police Jury P.O. Box 1921

St. Francisville, Louisiana 70775 Larry G. Johnson, Director Systems Engineering Cajun Electric Power Coop. Inc.

10719 Airline Highway

P.O. Box 15540 r

Baton Rouge, Louisiana 70895 I

William H. Spell, Administrator Louisiana Radiation Protection Division

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P.O. Box 82135 i

Baton Rouge, Louisiana 70884-2135

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APR I 1997

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Entergy Operations, Inc.

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Regional Administrator Senior Resident inspector (Grand Gulf)

DRP Director DRS-PSB L

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Branch Chief (DRP/TSS)

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Branch Chief (DRP/D)

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Entergy operatiore,Inc.

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R<ver Bend Staton

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5485 U. S Highway 61 J

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O PO Box 220 i

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a Tel 504 336 6225

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Fax 504 635 5068

I Rick J. King Owector Nuclear Safety & Regulatory Atfairs

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February 6,1997 3IO

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk

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M/S PI-37

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Washington, DC 20555-0001

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i Subject:

Reply to Notice of Violation IR 96-016

River Bend Station-Unit I

License No. NPF-47

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Docket No. 50-458 j

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File Nos.:

G9.5, G 15.4.1

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RBG-43713 i

RBF1-97-0043 l

Gentlemen:

Pursuant to the provisions of 10CFR2.201, attached is the Entergy Operations, Inc.

l response to the notice of violations described in NRC Inspection Report (IR)96-016.

Violation 50-458/9616-01 involving an inadequate system operating procedure for the j

hydrogen control system is addressed in Attachment A. Violation 50-458/9616-02

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involving proper implementation of the safety function determination program is

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addressed in Attachment B. Violation 50-458/9616-03 involving improper implementation of ASME Code,Section XI, is addressed in Attachment C.

I Based on information provided in Attachment A, we request that example 2 of violation 50-458/9616-01 be reconsidered. Clarifications are provided in each subject violation to

ensure the examples and information represent the results of our investigation.

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Reply to Notice of Violations in 50-458/96-016

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February 6,1997 RBG-43713 RBF1-97-0043 Page 2 of 2

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Should you have any questions regarding the attached information, please contact Mr.

l David Lorfing of my staff at (504) 381-4157.

Sincerely, b

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RJK/CRM

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attachments

cc:

U. S. Nuclear Regulatory Commission

Region IV 611 Ryan Plaza Drive, Suite 400 l

Arlington,TX 76011

NRC Sr. Resident Inspector

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P. O. Box 1050 St. Francisville, LA 70775 l

l David Wigginton

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NRR Project Manager i

U. S. Nuclear Regulatory Commission M/S OWFN 13-H-15 Washington, DC 20555 t

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ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-458/9616-01 Page 1 of 2 i

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Violation:

Technical Spe ification (TS) 5.4.1.a states, in part, that written procedures shall be

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maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operations),"

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Revision 2, February 1978. Item 4 of Appendix A to Regulatory Guide 1.33 recommends

procedures for the operation of safety-related systems.

Contrary to the above, listed below are examples where Procedure SOP-0040, " Hydrogen Mixing, Purge, Recombiners, and Igniters," Revision 9, was not properly maintained:

i 1. Each of the four igniter panels had a master breaker that was not identified on the

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Procedure SOP-0040 breaker lineup. Failure to verify these breakers closed could

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have resulted in groups of 5 igniter circuits being unable to perform their intended j

safety function.

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2. Procedure SOP-0040, Attachment 3C, " Electrical Lineup for the Hydrogen Recombiners," conflicted with the control board lineup Attachment 4C " Control

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Board Lineup - Hydrogen Recombiners," in that Attachment 3C required the breakers j

to be open while Attachment 4C required the breakers to be closed.

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3. Procedure SOP-0040, Attachment 1, " Valve Lineup for Hydrogen Purge," failed to specify the required status for Valves CPP-V3, -V4, and -V5 Valve CPP-V3 was

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specified open in lieu oflocked open, Valve CPP-V4 was specified locked / capped instead oflocked closed and capped, and Valve CPP-V5 was specified capped in lieu

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of closed and capped.

Reasons for the Violation:

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The cause for the first violation example is an inappropriate determination of which components to include in the System Operating Procedure (SOP) lineups. The hydrogen control system (HCS) panels differ from other 120/240 voltage alternating current (vac)

distribution panels in that, rather than supplying multiple functions with multiple indicators of failure, the hydrogen control system panel main breakers are part of a single function circuit with no direct indication of failure.

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ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-458/9616-01

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Page 2 of 2

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lineup witida Procedure SOP-0040 is implemented as designed. SOP lineups are l

structured such that valve, electrical, and instrument lineups place systems in a standby j

configuration and the control boa 1 %ups place these systems in a ready-for-service

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configuration. Valve, electrical, a. a 'nstrument lineups are generally designed to allow

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for concurrent performance, but tlw untrol board lineups cannot be performed without,

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electrical power to the affected components. The Procedure SOP-0040 electrical lineup positions the breakers for the hydrogen recombiners as "open" to allow remote closure of

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l the breakers via the performance of the control board lineup. This example cited in the

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violation is not considered to be a discrepancy.

I The cause of the third example was inadequate technical verification of the procedure

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within the Operations department. Revision 8 to Pincedure SOP-0040 showed these

valves in the correct positions, while revision 9 (issued September 4,1996) contained j

incomplete position descriptions. A line-for-line comparison of the two revisions should

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i have identified the discrepancies, but was not performed.

l Corrective Actions That Have Been Taken:

An editorial change was issued to revise Procedure SOP-0040 and update the Control i

e j-Room system lineups correcting the identified valve position discrepancies.

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e As an interim measure, administrative control of the four main HCS breakers was j

established using Procedure OSP-0014, " Administrative Control of Equipment and/or l

Services."

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Corrective Actions That Will Be Taken to Avoid Further Violations:

i Procedure SOP-0040 will be revised to show the four main HCS breakers in the "on" e

position.

The need for inclusion of other safety-related 120/240 vac main breakers into

appropriate procedures will be evaluated.

An evaluation will be performed of Operations' procedure verification and validation

processes.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on November 22,1996, when administrative control was established on the HCS main breaker _

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ATTACHMENT B

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i REPLY TO NOTICE OF VIOLATION 50-458/9616-02 l

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Violation:

j TS 3.0.6 specifies, in part, that when a supported system limiting condition for operation

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(LCO) is not solely met due to a support system LCO not being met, the conditions and I

i required actions associated with this supported system are not required to be entered.

Only the support system LCO actions are required to be entered. In this event, additional

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evaluations and limitations may be required in accordance with TS 5.5.10, " Safety l

Function Determination Program."

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TS 5.5.10 states, in pan, "...a loss of safety function may exist when a support system is

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inoperable, and: a. A required system redundant to system (s) supported by the j

inoperable support system is also inoperable..."

l TS 3.5.1 H requires, in part, that with both high pressure core spray (HPCS) and low i

pressure core spray (LPCS) inoperable enter LCO 3.0.3 immediately.

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Procedure OSP-0040, "LCO Tracking and Safety Function Determination Program,"

Revision 1, Step 3.4.1 specifies that a cross-divisional check must be performed to ensure that no loss of safety function goes undetected and Step 4.2.5, specified that if TS 3.0.6 is entered to prevent entering additional LCOs for supported systems, perform an i

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evaluation as required by TS 5.5.10 to ensure no loss of safety function exists.- Further, Procedure OSP-0040, Enclosure 1, " Support-Supported LCO Matrix," indicated upon entry into support LCO TS 3.7.1 (SSW), a review of supported LCO 3.5.1 (ECCS-Operating) was required.

Contrary to the above, on November 14,1996, operators removed the Division I standby service water system (a support system for LPCS) from service while the HPCS system was already inoperable because of a disabled room cooler without performing a loss of safety function determination as required by TS 5.5.10 and Procedure OSP-0040.

Reasons for the Violation:

On November 14,1996, authorized maintenance and testing activities resulted in conditions that could have caused a short duration entry into Technical Specification Limiting Condition for Operation (LCO) 3.0.3. The Control Room Supervisor (CRS) did not recognize that Division I and Division III Emergency Core Cooling Systems (ECCS)

were redundant. This led to a failure to identify the potential loss of safety function; making the use of LCO 3.0.6 to delay entry into required actions inappropriate. Had the Division 1 Standby Service Water (SSW) inoperability occurred concurrently with Auxiliary Building Unit Cooler #5 (HVR-UCS) not running, entry into LCO 3.0.3 would have been required by LCO 3.5.1, Condition H.

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ATTACHMENT B REPLY TO NOTICE OF VIOLATION 50-458/9616-02 Page 2 of 3

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Training content did not adequately address relation of task to overall plant operation.

e The Control Room Supervisor (CRS) was unaware of the relationship of Division III ECCS to Division I and II ECCS. Discussions within the Operations department indicated that most licensed operators were not aware of this relationship. The initial

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and requalification training content does not identify this condition. Furthermore, training content supponing Procedure OSP-0040, "LCO Tracking and Safety

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Function Determination Program," and the Safety Function Determination Program j

did not identify this redundant relationship.

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Omission of relevant information from the procedure. Procedure OSP-0040 did not

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contain information on the redundant condition. The Support / Supported System Matrix did not identify Condition H as the appropriate TS reference. Procedure OSP-0040 is not intended to be a stand alone document, however this significant information should have been included.

l Documents not used correctly. Despite the training material and procedure

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e shortcomings identified above, enough information was available for the on-shift

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Operations and Work Management Center personnel to determine the correct course of action. A more thorough review of the TS Bases could have identified this condition.

Corrective Actions That Have Been Taken:

All Senior Reactor Operators (SRO) were made aware of this event and of the

redundant nature of Division I and III equipment.

Procedure OSP-0040 has been reviseCo include a reference to Condition H in the.

• ECCS (3.5.1) Support / Supported block of the matrix. An additional note has been added to identify the fact that Division III ECCS is redundant to Divisions I and II.

Corrective Actions That Will Be Taken to Avoid Further Violations:

Initial and licensed operator training content will be revised to include a discussion of

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the redundant nature of Division III ECCS with Divisions I and I i

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ATTACHMENT B REPLY TO NOTICE OF VIOLATION 50-458/9616-02 Page 3 of 3 OSP-0040 will be reviewed to determine if conditions other than Condition H of TS

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3.5.1 should be added to the matrix for those systems supported by Standby Service Water (SSW).

Licensed operators will review this event during Licensed Operator Requalification.

• Emphasis will be placed on the need to carefully review all applicable TS sections when making a Safety Function Determination.

Date When Full Compliance Will Be Achieved:

EOI is in full compliance.

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L ATTACHMENT C REPLY TO NOTICE OF VIOLATION 50-458/9616-03 Page 1 of 2

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Violation:

10 CFR 50.55a(f) specifies the regulatory requirements to maintain an inservice test program for safety-related components.

Updated Final Safety Analysis Report, Section 9.1.3 specifies that the design basis of the spent fuel pool cooling system includes the ability of a single division to remove the required spent fuel pool heat load during accidents and specifies that the spent fuel pool cooling pumps will be tested in accordance with ASME Code Section XI. ASME Code Section XI, Subsection IWP-3230(c), " Corrective Action," specifies that correction shall

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be either replacement or repair per IWP-3111, or shall be an analysis to demonstrate that the condition does not impair pump operability and that the pump will still fulfill its function. A new set of reference values shall be established after such analysis.

Contrary to the above, on December 14,1996, inservice test personnel failed to establish a new set of reference values as required by ASME Code Section XI, Subsection IWP-

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3230 prior to placing the Train A spent fuel pool cooling pump in service to maintain pool temperatures, with Train B out of service periodically from August 18 to November 11.

Reasons for the Violation:

The cause for this violation is because there was no formal guidance for controlling the out-of-service time for this American Society of Mechanical Engineering (ASME)

equipment. Since the Spent Fuel Pool Cooling (SFC) pumps are not in TS, they are not controlled by a Limiting Condition for Operation (LCO). Also, sufficient importance (to warrant scheduling a test outside the system window) was not placed on restoring the system by the test scheduler. The management expectation to restore safety-related equipment following maintenance activities was not adequately emphasized.

Corrective Actions That Have Been Taken:

A review of other pumps tested in the inservice testing (IST) program revealed that the SFC pumps are the only case where the component had no associated LCO to define an outage duration. Operations Policy #006 was revised to require that a tracking LCO be initiated for SFC component inoperabilities and will not permit the equipment to be

"retumed to service" until the cause of the deviation has been determined and the condition corrected.

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ATTACHMENT C REPLY TO NOTICE OF VIOLATION 50-458/9616-03 Page 2 of 2

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Corrective Actions That Will Be Taken to Avoid Further Violations:

A review ofInservice Testing (IST) components, which have no associated LCO's

will be performed. TRM change requests will be evaluated for these components.

A method will be developed to ensure that components placed on the IST Exception

List due to test failure, or the inability to successfully complete the surveillance test for other reasons, are placed on the applicable LCO(s) or Tracking LCO(s) to ensure the components are not returned to service without successful performance of the IST surveillance test.

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A shift briefing will be provided for Licensed Operators on this event.

• Date When Full Compliance Will Be Achieved:

Full compliance was achieved on November 7,1996, when SFC-PI A satisfactorily passed the required operability surveillance test.

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