IR 05000458/1997006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/97-06 on 970202-0315

ML20148D705
Person / Time
Site:	River Bend
Issue date:	05/28/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mcgaha J ENTERGY OPERATIONS, INC.
References
50-458-97-06, 50-458-97-6, NUDOCS 9706020069
Download: ML20148D705 (5)

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611 RY AN PLAZA DRIVE, SulTE 400 k '"** ' AR LINGToN, T E XAS 76011 8064 MAY 2 81997 1 John R. McGaha, Vice President - Operations River Bend Station i Entergy Operations, Inc.

P.O.~ Box 220 St. Francisville, Louisiana 70775 SUBJECT: NRC INSPECTION REPORT 50 458/97-06

Dear Mr. McGaha:

' Thank you for your letter of May 12,1997, in response to our letter and Notice of Violation dated April 11,1997. 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 j corrective actions during a future inspection to determine that full compliance has been ! i achieved and will be maintained.

Sincerely, )

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o as P. wyr n, Di ector Division of Rea or P ojecte l Docket No.: 50-458 License No.: NPF-47 j cc w/ enclosure: Executive Vice President and Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 Vice President Operations Support

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Entergy Operations, Inc. /'~ P.O. Box 31995 Jackson, Mississippi 39286-1995 d i 9706020069 970528 umt ElEM PDR ADOCK 05000458 ' G PDR  %.$. LEllN*mlHi

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. . * j Entergy Operations, Inc. 2-I

! > l General Manager

Plant Operations s

River Bend Station Entergy Operations, Inc.

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' ' P.O.~ Box 220 j St. Francisville, Louisiana 70775 '

Director - Nuclear Safety .

l River Bend Station t i Entergy Operations, inc. .

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

Wise, Carter, Child & Caraway l' P.O. Box 651 Jackson, Mississippi 39205 f f r j Mark J. Wetterhahn, Esq. - i . Winston & Strawn 1401 L Street, N.W. Washington, D.C. 20006-3502

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Manager - Licensing River Bend Station Entergy Operations, Inc.

! P.O. Box 220 1 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 l Police Jury P.O. Box 1921 ~ St. Francisville, Louisiana .70775 i

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! Entergy Operations, Inc. -3- , Larry G. Johnson, Director Systems Engineering Cajun Electric Power Coop. Inc.

10719 Airline Highway P.O. Box 15540 , Baton Rouge, Louisiana 70895

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

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. . Entergy Operations, Inc. -4-MAY 2 81997 bec to DCD (IE01) bec distrib. by RIV: Regional Administrator Senior Resident inspector (Grand Gulf) DPP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) Resident inspector l I l l

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1 I l DOCUMENT NAME: R:\_RB\RB706AK.WFS To receive copy of document, indicate in box: "C" = Copy without enciqsures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/D jl C:DRP,/D ,[f D:DRP l_ S , GAPick;d@l PHH([fgG TPG,wynn G " [ ) 5/'lh97 Sr)T/$ M 5$[J97 i OFFICIAL RECORD COPY l l

Entergy Operations, Inc. -4-MAY 2 81997 bec to DCD (IE01) bec distrib. by RIV: Regional Administrator Senior Resident Inspector (Grand Gulf) DRP Director DRS-PSB Branch Chief (DRP/D) MIS System l Project Engineer (DRP/D) RIV File j Branch Chief (DRP/TSS) Resident Inspector

l DOCUMENT NAME: R:\_RB\RB706AK.WFS l To receive copy of document, indicate in box: "C" = Copy without encigsures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/D j C:DRP)p , [[/ D:DRP [$ l l ' GAPick;dyff,j' PHHj[f@Q TPG,wynn(j" [ 5/'p)97 Br),3/$ % S$b/97 OFFICIAL RECORD COPY l ! .

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3 . . . Enttrgy operitiana. Inc.

Rwer Benc Stat.on 5485 U S H<gnway 61

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"       PO Box 220 l
=.       St Franc: syme LA 70775 Te! 504 336 6225 Fax 504 635 5068 Rick J. King a     . . . Drector huC;ea. sagty & Regulestory ANars

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l May 12,1997 . neg;cd{J _

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) U.S. Nuclear Regulatory Commission i Document Control Desk, OPI-17

;  Washington, DC 20555 Subject: Reply to Notice of Violation in IR 97-006 River Bend Station - Unit I License No. NPF-47 Docket No. 50-458 File Nos.: G9.5, G 15.4.1 g  RBG-43928        !

RBF1-97-0126

 . Gentlemen:

i Pursuant to the provisions of 10CFR2.201, Attachments A, B, and C provide the Entergy Operations, Inc. responses to the Notices of Violation (NOV) described in NRC Inspection Report (IR) 50-458/97-006.  ! The subject violations,50-458/9706-01,04, and 05, involve: inadequate procedural implementation of overtime tracking as required by Technical Specification (TS) 5.2.2.e; inadequate procedural implementation for the Primary Containment Leakage Rate I Testing Program, as required by TS 5.4.1.a; and a radiological posting which was made  ; inconspicuous in violation of 10CFR20.1902(a), respectively. 1

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..       j Reply to Notice of Violation in 50-458/97-0%

May 05,1997 RBG-43928 j RBF1-97-0126 , i Page 2 of 2 i Should you have any questions regarding the attached information, please contact Mr. David Lorfing of my staff at (504) 381-4157.

Sincerely, C

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RJK/MGM attachments

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cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011  ; NRC Sr. Resident Inspector P. O. Box 1050 St. Francisville, LA 70775

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David Wigginton NRR Project Manager U. S. Nuclear Regulatory Commission M/S OWFN 13-H-3 Washington, DC 20555

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*O       j ATTACHMENT A

. REPLY TO NOTICE OF VIOLATION 50-458/9706-01 l Page1of1

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Violation:

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During an NRC inspection which was conducted February 2 through March 15,1997, a violation of NRC requirements was identified. In accordance with the " General l Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the i

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violation is listed below:  ! Technical Specification 5.2.2.e states, in part, that administrative procedures shall be developed and implemented to limit working hours of unit staff who perform l safety-related functions.

Contrary to the above, as of March 15,1997, administrative procedures were not developed in sufficient scope to implement the requirements of Technical Specification 5.2.2.e, in that licensee procedures did not include specific controls for plant manager approval of overtime extensions or monthly reviews of overtime usage for Maintenance, Radiation Protection, and Systems Engineering , ~ personnel, who were performing safety related functions. A numbc. of these individuals exceeded the established overtime limits.

Reasons for the Violation: The site policy on overtime control allowed a great deal of freedom for individual l departments to establish overtime control programs. This policy was implemented ! through either supervisory review programs, or a number oflower tier procedures. I Because of the latitude allowed for compliance with the policy, several different methods ! were used to document the control of overtime. These were not consistent in implementing the provisions of the Technical Specification. l Corrective Actions That Have Been Taken: This violation has been investigated and its causes determined. Corrective actions have been developed and approved for implementation.

An interim memorandum was issued by the General Manager of Plant Operations which provides a specific overtime approval process.

Corrective Actions That Will Be Taken to Avoid Further Violations: A comprehensive site-wide procedure to control overtime for personnel performing safety related work will replace the previous policy. This procedure will provide a uniform method for ovenime control, without the need for other independent processes.

Date When Full Compliance Will Be Achieved: Corrective actions will be completed by June 15,1997.

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ATTACHMENT B I REPLY TO NOTICE OF VIOLATION 50-458/9706-04 Page 1 of 2 . Violation: * During an NRC inspection which was conducted February 2 through March 15,1997, a i violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below: , Technical Specification 5.4.1.a states, in part, that written procedures shall be maintained covering the applicable procedures recommended in Appendix A of i Regulatory Guide 1.33," Quality Assurance Programs Requirements (Operations)," Revision 2, February 1978.

Appendix A of Regulatory Guide 1.33, Section 8.b.(2)(a) recommends written - procedures for containment leak rate and penetration leak rate tests.

Contrary to the above, on February 4,1997, Administrative Procedure ADM-0050, " Primary Containment Leakage Rate Testing Program," Revision 4, was not maintained, in that the criteria for extended local leak rate test intervals were inadequate and resulted in missed surveillance tests.

Reasons for the Violation: This violation involved personnel failing to follow the requirements specified for test interval selection in the procedure which implements the Local Leak-Rate Testing (LLRT) program. Three causes were established: (1) there was inadequate , documentation of the inputs used to evaluate each component against its performance ! based criteria: (2) EOI personnel were overly dependent on contractor knowledge of ' Appendix J, Option B testing for LLRT program development; and (3) the LLRT procedure was unnecessarily restrictive in its implementation of the performance based testing program.

Corrective Actions That Have Been Taken: . The four valves associated with this violation have all exhibited historically good LLRT performance. Though the original basis for placing these valves on an extended test

interval did not meet the LLRT procedural requirements, further review determined that i they do meet the requirements set forth in the RBS commitments for LLRT program implementation. The subject valves were tested to, and successfully passed, the , applicable LLRT requirements.

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. . ... ATTACHMENT B l REPLY TO NOTICE OF VIOLATION 50-458/9706-04 Page 2 of 2

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Corrective Actions That Will Be Taken to Avoid Further Violations: ) The LLRT program procedure will be revised prior to its next scheduled use during the refueling outage. This revision will clarify the step which specifies the test interval establishment based on the results of previous testing. The revision will also include examples of what constitutes maintenance which can effect a valves leak tightness.

) A detailed evaluation of each component within the LLRT program will be performed.

A qualification matrix will be established for the LLRT Coordinator position.

Date When Full Compliance Will Be Achieved: River Bend is in full compliance upon review of the LLRT commitments and completion of the LLRT confirmatory testing. Long-term corrective actions will be completed prior i to refueling outage seven, which is currently scheduled to begin during September of 1997.' i l

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- ATTACHMENT C REPLY TO NOTICE OF VIOLATION 50-458/9706-05

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Page1of2 Violation: * During an NRC inspection which was conducted February 2 through March 15,1997, a l violation of NRC requirements was identified. In accordance with the " General 1 Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below: i

10 CFR 20.1902(a) states, In part, that each radiation area shall be conspicuously posted with signs stating " CAUTION, RADIATION AREA."

Contrary to the above, on February 20 and 24, the entrance to the alternate decay l heat removal system room (a radiation area) was not conspicuously posted with signs stating " CAUTION, RADI ATION AREA," because unauthorized personnel , relocated the signs.

Reasons for the Violation:

The policy for conspicuously posting doors and doorways did not ensure that:

(1) the function of the doorway (i.e., to provide ingress and egress) is not disrupted; and (2) a single radiological posting for a door can not be rendered inconspicuous by a l process as fundamental as holding the door open.

An investigation was conducted to determine the root cause of the human performance aspect of the posting movement on February 24. Personnel interviews and work activity reviews were conducted. However, the individual who moved the posting could not be identified. Therefore, the specific reason for moving the posting could not be determined.

Corrective Actions That Have Been Taken: The area was posted in a functional and conspicuous manner.

All employees working in the affected area were counseled on the importance of postings being moved only by authorized personnel. Foreman and supervisor observation skills were reinforced to prevent reoccurrence.

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OO ATTACHMENT C REPLY TO NOTICE OF VIOLATION 50-458/9706-05 Page 2 of 2 Corrective Actiodt That Will Be Taken to Avoid Further Violations: A posting policy or procedure will be developed which reinforces the appropriate method of posting doors and doorways such that: the posting is not obscured by an action as fundamental as opening the door; and the function of the door (i.e., ingress and egress) is ' not disrupted by the presence of the posting (e.g., the rope across the doorway).

RP Technicians will receive enhanced training on the developed policy or procedure, ! including: proper posting methods; proper posting evaluations; and the importance of I ensuring that postings are as ergonomic as is possible without compromising their conspicuous nature.

Date When Full Compliance Will Be Achieved:

River Bend is in full compliance. Long-term corrective actions to prevent reoccurrence

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will be completed by August 31,1997.

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