IR 05000458/1999007
| ML20212L973 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/05/1999 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Edington R ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20212L975 | List: |
| References | |
| 50-458-99-07, EA-99-158, NUDOCS 9910080064 | |
| Download: ML20212L973 (5) | |
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SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-458/99-07)
Dear Mr. Edington:
This refers to Entergy Operations Inc.'s letter dated September 7,1999, regarding apparent violations described in the subject inspection report, issued August 4,1999. The inspection report described two apparent violations related to the River Bend Station Division i Emergency Diesel Generator (EDG) and stated that the NRC was considering escalated enforcement action. In a letter to Entergy dated August 23,1999, the NRC asked Entergy to indicate whether it would respond in writing to the apparent violations or opt for a predecisional enforcemeret conference. Entergy chose to provide a written response.
The apparent violations involved improper installation of a fuel booster pump coupling pin which resulted in the diesel failing after 55 minutes of operation during a surveillance test on March 24,1999. This failure was traced to improper staking of the coupling pin, including the failure to use an adhesive, Loctite, that was recommended in a Service Information Memo issued by the EDG vendor. This recommendation was not incorporated into diesel
- naintenance procedures at River Bend Station. The failure after 55 minutes of operation
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meant that the Division i EDG was not capable of fulfilling its intended safety function in the event of an accident that required electrical power from the diesels. The safety function of the EDG is to provide an alternate safety-related electrical power source in response to an event involving the loss of off-site power, for the duration of the event.
In its September 7,1999 response, Entergy admitted the apparent violations, described its corrective ac; ions, and provided its perspective on the safety significance and enforcement policy implications of the violations. In a supplemental response dated September 24,1999, Entergy provided a summary of its EDG reliability self assessment, provided additional completion dates for long-term corrective actions, and described the status of the EDGs within the scope of 10 CFR 50.65, the maintenance rule.
Entergy's assessment of the safety significance of this incident concluded that it resulted in a g
reduction of defense-in depth in terms of the systems available to mitigate accidents, noting
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' that for a period of about 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />, only the Division ill EDG was available to respond to an accident because of planned maintenance on the Division 11 diesel while the Division I diesel was inoperable.
A Corrective actions which have already been completed include: immediately restoring the operability of he EDG; evaluating the poters for the coupling pin problem to affect the 9910000064 991C M
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PDR ADOCK 05000458 G
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Entergy Operations, Inc. _
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Division !! and Ill'EDGs; modifying maintenance procedures to include the use of Loctite, an adhesive, on the fuel pump coupling pin; briefing maintenance planners and mechanico ori the root cause analysis of this event; including training on taper pin staking techniques inb the l'
continuing maintenance training module; and updating the diesel vendor technical information.
Corrective actions which have not yet been completed include: evaluating past EDG work to '
assess compliance with vendor servico information memos, due October 22,1999; evaluating
> the Division ill diesel to confirm the adequacy of vendor documentation, due December 31, 1999; sampling vendor documents on other systems and equipment, due December 31,1999; Jand performing an effectiveness review of the corrective actioris taken to address the condition of the Division I and 11 EDGs, due March 31,2000.
Based on NRC review of the information developed during the inspection and the information
- that you provided in your response to the inspection report, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice). Based on their close relationship, they have been combined to form a single Severity Level 111 problem. The severity level of the violations in this case is based on their resulting in the emergency EDG being inoperable for a period of 29 days, well in excess of the allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for one EDG. This severity Icvel determination is in accordance with Supplement I of the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.-
In accordance with the Enforcement Policy, a civil penalty with a base value of $55,000 is considered for a Severity Level 111 problem. Because your facility has been the subject of.
escalated enforcement actions within the last 2 years,' the NRC considered whether credit was
- due for identification and Corrective Action (relative to the curront violations) in accordanc9 with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. As En trgy noted in its September 7,1999 letter, Entergy personnel discovered the fuel booster pump L
coupl_ing pin problem while conducting a' surveillance test of the EDG. In light of the
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' circumstances which resulted in the discovery of this problem, and Entergy's corrective actions,
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which are described above, Entergy is given credit for both identification and corrective action,
-which results in no civil penalty being assessed for the current violations. Therefore, in recognition of Entergy's identification and correction of this issue, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil pencity in this case.
- However, significant violations in the future could result in a civil penalty.
The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to cor_ rect the violations and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in inspection Report 50-458/99-07, and in Entergy's September 7 and September 24,1999, letters.
- Therefore, you are not required to respor d to this lette: unless the description therein does not
- accurately reflect your corrective actions or your position. In that case, or if you choose to
' provide additional information, you should follow the instructions specified in the enclosed
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- Notice..
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'A Notice of Violation and Proposed imposition of Civil Penalty ($55,000) was issued on (
February 1,1999, consisting of two Severity Level lil violations related to the Division I and 11
. emergency diesel generators (EA 98-478).
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s Entergy Operations, Inc.
-3-In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and any response you choose to submit will be placed in the NRC Public Document Room.
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Sincerely,
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Ellis W. Mersch Regional Admin' trator cc w/ Enclosure:
Executive Vice President and Chief Operating Officar 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 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, DC 20005-3502
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I Entergy Operations, Inc.
-4-Manager'- Licensing
- River Bend Station Entergy Operations, Inc.
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P.O. Box 220
- St. Francisville, Louisiana 70775
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- The Honorable Richard P. leyoub 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
- Prer.ident -
. Wee Feliciana Parish Police Jury P.O. Oox 1921 St. Francisville, Louisiana 70775
' Ronald Wascom, Administrator and State Liaison Officer Department of Environmental Quality
- P.O. Box 82135 i
Baton Rouge, Louisiana j
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. Entergy Operations, Inc.
-5-bec w/ enclosure:
POR RA READING FILE NUDOCS.
GSANBORN-EAFILE SECY (0-16 C1)
RWISE lE 14 RIV FILES CA WJOHNSON, DRP OPA (0-2 A13)
EDO (0-16 E15)
OlG (T-5 D28)
DEDE (0-16 E15)
DEDR (0-16 E15)
DIRECTOR, OE (0-14E1)
OE:EAFILE (0-14E1)
Ol (0-3 F1)
D. DAMBLY, OGC (O-4 F20)
J. ZWOLIN3Kl, NRR '
S. RICHARDS, NRR EC'S: RI, Rll, Rl!!
E-MAIL DISTRIBUTION:
OEMAIL REIS (TXR)
MERSCHOFF (EWM)
GWYNN (TPG)
SANBORN (GFS)
SMITH (KDS1)
HENDERSON (BWH)
HACKNEY (CAH)
BROCKMAN (KEB):
COLLINS (EEC)
JOHNSON (WDJ)
PRUETT (TWP)
AHOWELL (ATH)
POWERS (DAP)
VASQUEZ (GMV)
FREEMAN i
DOCUMENT NAME: S:\\ RAS \\ ACES \\EA\\Casee - Open\\RB-EDGfuelpump\\ea99158rbsdiesel.wpd To receive copy of doeurnent, indicate in box: "C' = Copy without cnclo,sures *E' = Copy with enclosures 'N' = No copy D: ACES Aff
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RC
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