IR 05000458/1997017

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/97-17 on 971224.Finds Reply Responsive to Concerns Raised Re Failure to Meet TS Limiting Condition for Operation

ML20199L298
Person / Time
Site:	River Bend
Issue date:	02/04/1998
From:	Collins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mcgaha J ENTERGY OPERATIONS, INC.
References
50-458-97-17, NUDOCS 9802090171
Download: ML20199L298 (5)

Text

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p. t NUCLEAR REGULATORY COMMISSION g i nEoioN iv 411 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 760114064

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

P.0, Box 220 St. Francisville, Loulslana 70775

. SUBJECT: NRC INSPECTION REPORT 50-458/97-017

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Dear Mr. McGaha:

Thank you for your letter of January 23,1998, in response to our letter and Notice of Violation dated December 24,1997, We have reviewed your reply and find it responsive to the

concerns about a failure to meet a Technical Specification Limiting Condition for Operation i

associated with one of the primary containment air locks raised in our Notice of Violation. We will review the imp:ementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

c(

Elmo E. Collins, Chief Project Branch C Division of Reactor Projects Docket No.: 50-458 License No.: NPF-47

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Executive Vice President and

. Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 9902090171 990204 PDR ADOCK 05000458 G PDR ll,1,Illl)I1,1RI

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Entergy Operations, Inc. -2-Vice President

- Operations Support Entergy Operations, Inc.

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P.O. Box 31905 Jackson, Mississippl 39286 1995 1 General Manager Plant Operations River Bend Station '

Entergy Operations, Inc.

P.O. Box 220 -

St. Francisville, Loulslana 70775 Director - Nuclear Safety River Bend Station Entergy Operations, Inc. .

P.O. Box 220 St. Francisville, Loulslana 70775 Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippl 3g205 Mark J. Wetterhahn, Esq.

Winston & Strawn

- 1401 L Street, N.W.

Washington, D.C. 20005 3502 Manager- Licensing River Bend Station Entergy Operations, Inc, P.O. Box 220 St. Francisville, Loulslana 70775 The Honorable Richard P. leyoub -

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Attorney General'

Department of Justice State of Louisiana P.O. Box 94005 -

Baton Rouge, Louisiana 70804 9005 H. Anne Plettinger

3456 Villa Rose Drive Baton Rouge, Louisiana 70806 .

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Entergy Operations, Inc. 3

- President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 William H. Spell, Administrator Louisiana Radiation Protection Division

- P.O. Box 82135 Baton Rouge, Loulslana 70884 2135

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Entergy Operations, Inc. -4 FEB - 4 1998 MADDtlAMtt bec distrib. by RIV:

Regional Administrator Senior Resident inspector (Grand Gulf)

DRP Director DRS PSB Branch Chief (DRP/C) MIS System Project Engineer (DRP/C) RIV File Branch Chief (DRP/TSS) Resident inspector i

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DOCUMENT NAME: R:\_RB\RB717AK.GDR To receive copy of document. Indicate in box: *C" a Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/C; C:GPBP/C PJAlter;df /dL E@7ollins 2/4 /98 l) 2/W/98 - - --

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- Project Engineer (DRP/C) RIV File Branch Chief (DRP/TSS) Resident inspector

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.1 DOCUMENT NAME: R:\_RB\RB717AK.GDR To recolve copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" s No copy RIV:PE:DRP/C f C:pBP/C PJAlter;df r$L EIK:ollins 2/4 /98 () 2/T/98 1 OFFICIAL RECORD COPY

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January 23,1998

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U.S. Nuclear Regulatory Comminion c . I . d "> b i'

Document Control Desk. OPI 17 ')

Wuhinston, DC 20555 JAN28 7 i

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Subject: Reply to Notice of Violation in IR 97 017 BEC'N ./

River Bend Station Unit ! - - - - - -I License No. NPF-47 Docket No. 50-458 i

File Nos.: 09.5,015.4.1

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RBO-44354

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RBF198 0007 Gentlemen:

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Pursuant to the provisions of 10CFR2.201, Attachment A provides the Entergy

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Operations, Inc. response to the Notice of Violation (NOV) described in NRC Inspection Report (IR) 50-458/97-017.

i The subject violation,50-458/97017-04, involves a failure to meet a Technical Specification Limiting Condition for Ope ation Action associated with one of the primary containment airlocks.

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

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

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Reply to Notice of Violation in 50-458/97 017 January 23,1998 RBO 44354 RBF198 0007 Page 2 of 2 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 David Wigginton NRR Project Manager U.S. Nuclear Regulatoiy Commission M/S OWFN 13 H 3 Washington, DC 20555 -

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ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-453/97017 04 Page 1 of 3 Violation:

During an NRC inspection conducted on October 12 through November 29,1997, one violation of NRC requirements was identified. In accordance with the "Ceneral Statement of Policy and Procedure for NRC Enforcement Actions," NUREO 1600, the violation is listed below:

Technical Specification Surveillance Requirement 3.0.1 states, in part, " failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or t re.a.. performances of the Surveillance, rhall be friture to meet the LCO."

Technical Specification Surveillance Requirement 3.6.1.2.1 states, in part,

" Perform required primary containment alt lock leakage rate testing in accordance with the Primary Containment Leakage Rate Testing Program."

Technical Specification 3.6.1.2 Condition A, applies to containment air locks with one door inoperable. Technical Specification 3.6 's .2, Condition B, applies to containment air locks with the primary containment air lock interlock mechanism inoperable.

Technical Specification 3.6.1.2, Condition C, requires, in part, with one or more primary containment air locks inoperable for reasons other than Technical Specification 3.6.1.2, Conditions A or B, immediately initiate action to evaluate primary containment overall leakage rate per Technical Specification 3.6.1.1, using cunent air lock test results.

Contrary to the above, on October 30,1997, at 8 a.m., the lower primary containment air lock failed during the performance of Technical Specification Surveillance Requirement 3.6.1.2.1, thus rendering the air lock inoperable for reasons other than Technical Specification 3.6.1.2, Conditlens A or B, and action to evaluate, primary containment overall leakage ate per Technical Specification 3.6.1.1, using current air lock test results, was not completed.

This is a Severity Level IV violation (Supplement 1) (50 458/97017-04)

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)* ATTACHMENT A l REPLY TO NOTICE OF VIOLATION 50-45g/97017 04 l

Page 2 of 3

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Reasons for the V6 elations

, The primary cause of this violation was related to human performance, in that a complex

knowledge based decision wu required, but was made using inappropriate assumptions.

l The Operations Shift Superintendent (OSS), who was vrsponsible for evaluating the condition, made an incorrect assumption regarding the applicable Technical Specifications. The OSS used the Technical Specification Bases discussion for SR 3.6.1.2.1 which discusses a method for quantifying the maximum leakage through the air lock. This method states that the actuc.1 air lock leakage (from inside containment to outside containment) is the lesser of the two barriers (alt lock doors). The OSS assumed '

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that the only leakage paths, through the air lock doors, were through the door seals or the

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equalization valves. There was no indication of a seal problem, since the seals were ',

acceptable at the time of the surveillance performance. The OSS had been informed that the equalization valves on the outer door of the air lock were leaking. Focusing on the l valve leakage, he neglected other possible paths for leakage, such as tubing, fittings, etc.

1 It should be noted that the inner door equalization valves tested satisfactorily.

A contributing cause was related to work practices, regarding not obtaining one or more -

peer checks while making complex knowledge based decisions. The OSS discussed the Technical Specification 0:?rmination with several other Senior Reactor Operators, and other Operations manager at personnel, but he did so in an informative manner rather

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than as a consultation for a peer check. Th OSS may have inadvertently impressed his own conclusions upon those individuals, instead of allowing them to independently review and advise him. .

Correettve Aetless That Have Been Taken:

At 1330 on October 30,1997 Technical Specification 3.6.1.2 Condition "C" Actions =

were entered. The OSS contacted the system engineer to verify that action was being taken to evaluate primary contalmnent overall leakage in acccriuce with Required

Action C.I. Upop,repir of the leaking equalization valves, Tesanical Specification i SR 3.6.1.2.1 was completed on the air lock satisfactorily. Technical Specification Limiting Condition for Operation 3.6.1.2 was met and Condition "C" Actions were exited -

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at 0745 on October 31,1997.

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The 03S involved in this event has been counseled by management. This event was addressed, includiag a more thorough review of applicable Technical Specifications and -

ensuring that a proper peer check is conducted. -

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l ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-458/97017-04 page 3 of 3 Corrective Actions That Will Be Taken to Avoid Further Violations:

Distribution of this event in a shift briefing; will be performed to inform other Operations personnel of the need to ensure: thoroughness in the review of applicable Technical Specifications; proper peer checking methods are utilized; and that decisions can be substantiated through appropriate documentation.

Additionally, a discussion of this event, focusing on implementation of Technical

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Specification actions upon failing surveillances, will be included in the next licened operator requalification training module.

Date When Full Compliamee Will Be Achieved:

River Bend Station is currently in full compliance.

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