ML20066K449
| ML20066K449 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/28/1991 |
| From: | Odell W GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RGB-34386, NUDOCS 9102050314 | |
| Download: ML20066K449 (7) | |
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Jantary 28, 1991 RBG-3 4 3 86 File Nos. G9.5, G15.4.1 U.S. Nuclear Regulatory Ccrreission Docurrent Control Desk Washington, D. C.
20555 Genticmen:
River Bend Station - Unit 1 Refer to : Region IV Docket No. 50-458/90-29 Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Cortpany's (GSU) response to the tbtice of Violations for NRC Inspection Report No. 50-458/90-29. The inspection was conducted October 17 to November 27, 1990, of activities authorized by NRC Operating License NPF-47 for River Bend Station
- Unit 1 (RBS). GSU's reply to the violations are provided in the attachments.
GSU is concerned with these events and is aggressively pursuing corrective actions.
Should you have any questions or care to discuss these matters, please contact Mr. L. A. England at (504) 381-4145.
Sincerely,
. 1.
e.1 Manager-Oversight River Bond Nuclear Croup 1AE/PDG/FTC/DNL/DC/GSY/JhC/pg Attachents cc: U. S. Nuclear Regulatory Conmission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Senior Resident Inspector Ibst Office Box 1051 St. Francisville, IA 70775 9102050314 910128 E,
PDR ADOCK 05000458 if O
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA
)
PARISH OF WEST FELICIANA
)
Docket No. 50-458 In the Matter of
)
GULF STATES UTILITIES COMPANY
)
(River Dend Station
- Unit 1)
AFFIDAVIT W.
H. Odell, being duly sworn, states that he is a Manager-Oversight for Gulf States Utilities Company; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.
i N. H. Ode 1T
(
Subscribed and sworn to before me, a Notary Public in and for the State and Parish above
- named, this df F day of o n,uu m 19 q l.
My Commission expires with Life.
V U
('.00_.4 u000 d /4vu>C Claudia F.
Hurst Notary Public in and for West Feliciana Parish, Louisiana
ATTA0NENT 1 I@LY 70 tKTr1CE OP VIOIATICN 50-458/9029-02 IEVFL IV REFERE1K'E Notice of Violation - Letter fIun S. J. Collins to J.
C.
Deddens, dated December 27, 1990.
VIDIATION Technical Specification 6.12.2 states, in part, that, "For accessible areas that are located within large areas, such as the contairumnt.
and within which radiation levels are such that a major portion of the body could receive in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose in excess of 1000 mrem, then that area shall be roped off and conspicuously posted, and a flashing light shall be activated as a warning device."
Contrary to the above, on Noventer 14, 1990, a barrier was found to be down at the entrance to an accessible area on the 85-foot elevation of the dryw11 witht which radiation levels were such that a major portion of the body could receive, in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, a dose in excess of 1000 mrem. This resulted in a failure b/ the licensee to maintain the area roped off and conspicuously posted.
REASON FDR THE VIOIATION Personnel error was determined to be the cause in that the unknown Jndividual who entered / exited the area failed to properly restore the rope boundary.
CORRECTIVE STEPS MIICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
'Ihe radiation protection technician (RPT) inmediately restored the rope boundary upon notification. The RPT also verified that all individuals in the area were authorized and met 7bchnical Specification requirements for entry. No discrepancies were found. RPTs verified that all high radiation postings ir. the drywell were properly restored and that-all red flashing lights were operable.
CORRECTIVE STEPS MIICH WIIL BE TAKEN 7D A\\DID PURTHER VIOIATIONS To address the concern of an apparent lack of regard to radiation barriers at RBS, GSU has perfomed the following:
(1) On December 7,1990, the Plant Manager issued a Immo to all River Bend Station personnel highlighting high radiation problems.
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' (2)
On D2cember 17, 1990, a task force was established to nake further reccnnendations to the Plant Manager with regard to the causal factors.
(3)
Padiation Protection nanagenent toured the plant to review all high radiction and very high radiation zones and inspected them for the effect_iveness of posting.
(4)
A daily check of high radiation postings has been initiated.
(5) A none was issued to RPTs requiring inproved professionalism in postings.
(6)
Radiation Protection nunagenent wil] inspect and approve all new high radiation postings.
(7) On Jantary 9,1991, task force recczmendations were given to the Plant Manager:
a.
All personnel requiring access to high radiation and very high radiation areas will be retrained and will complete a written exantination.
(Target Date February 15, 1991) b.
All personnel requiring unrestricted access to the radiologically controlled area will be retrained and will ccrnplete a written examination.
(Target Date March 1,1991) c.
General Dnployee Training classes conducted after March 1,1991 will require specific written examinations addressing high radiation boundaries.
(8)
On an interim basis, Radiation Protection in checking high radiation areas during the last two hours of each shift to attempt to determine which shift any to responsible for not restoring ropes.
(9) On January 14,1991, the Plant Manager issued a meno to all nanagers and supervisors highlighting supervisory role in resolving this problem.
(10) A monthly operability check will be conducted on high radiation docra.
(11) Additional actions to be implemented include the following:
a.
RBS will change its philosophy with regard to radiation barriers in that personnel will not be allcmed to cross under or over radiation barriers.
Only approved entrances / exits set up by Radiation Protection nuy be used, b.
Radiation Protection is evaluating new stanchion designs and fasteners for posting high radiation areas.
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c.
Those high -radiation. areas whose boundaries can be slightly
~
expanded to pernanent structures will be reposted and locked.
d.
High radiation areas caused by hot spots in_ drains / piping htlich can be hydrolazed will be deconned to reduce the high radiation
-levels, c.
Signs resembling S'10P signs indicating that Technical Specification nonitoring is -required will be posted at high radiation and very high radiation area entrances.
f.
Evaluate the use of temporary barricades and pernanent structures to replace ropes.
DATE MIEN FULL COMPLIANCE WILL BE AGIEVED Fbil ccxnpliance was achieved upon the inmediate restoration of the rope boundary by the RPT.
Further corrective actions will be camplettd as
- indicated above.
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ATT10P'INr 2 MTLY 70 FUPICE OF VIOIATION 50-458/9029-04 LEVEL IV P m :RT2 C E Notice of Violation - Letter from S. J. Collins to J. C. Doddens, dated D2cember 27, 1990.
VIotATIo.N Technical Specification 6.8,1.c states, in part, that " Written procedures shall be established, inplenented, and maintained covering refueling opera tions. "
REP-0010, "Special Nuclear bbterial (SNM) bbvement Control and Accounting,"
Revision 7,
dated July 20, 1990, was implemented to provide instructions for reactor engineering activities during refueling operations. Attaclment 8 of REP-0010 required that each fuel bundle that has been transferred be placed in the specified location and with the specified orientation.
Contrary to the above, licensee personnel failure to implennnt the requirements of REP-0010 in that five bundles (LYP408, LYV206, LYV283, LYV281, and LY9685), transferred to the specified location, kure discovered by the licensee to be misoriented.
REASON FOR '118 VIOIATION Five fuel assemblies were misrotated as a direct result of refueling floor personnel error. The misrotation errors occurred during perfonTance of fuel novment plans SMP-CoR-4-02 and SMP-CDR-4-03.
These plans were developed as Attachnent 8 of procedure REP-0010 and specify the order, location and orientation requirenents for each fuel assembly noved. 7ko signatures are required to document performnce capletion of each step of these fuel movment plans.
An independent review and verification of correct fuel loadir' is thoroughly perforned by remote underwater TV canera equiplent upon completion of core loading during the final core verification process as governed by REP-0010.
VCR tapes of the core loading verification are obtained in accordance with the provisions of REP-0010.
Additional instructions included with the fuel novcment plans provided guidelines and requirenents for actions to be taken should any fuel novement errors be discovered by refueling personnel during implenentatio.
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' of the respective fuel novenunt plans. One of these instructions stated
/
that misrotated bundles were not considered fuel loading errors and that should any minrotated bundle be discovered it could be corrected - at-.the discretion of the SRO and Reactor Engineer. This rule was not intended and was not utilized to allow misrotated bundles to renain uncorrected when discovered by refueling floor personnel. The potential for a mislocated bundle to affect shutdown nargin (SDM) was recognized by GSU and was a najor ~ concern in the developtent of the fuel nevnent plans and rules. The novenent plans wore fannulated and designed to minimize the potential for a mislocated bundle to affect SDM.
Orientation cf fuel bundles in a uniform lattice reactor such as River Dend has no impact on SDM during refueling.
As a result, major emphasis is placed on shutdown margin and mislocation of bundles while discretion is allowed for correction of misrotated bundles when discovered.
The misrotation discretion rule was not clear in its 4
intent. A misrotated bundle was not clearly required to be docununted and corrected prior to initiation of the independent core loading verification 1
process. This cmission could have allowed direct. challenges to the independent reviewers.
- CORRECTIVE STEPS WHIO! HAVE BEEN TAKEN AND THE RESULTS AOIIEVED The microtated bundles identified during the core verification were repositioned and verified cor. met by novenent plan SMP-COR-4-04, as well-as the final core verification utilizing undervater television cancra/VCR equignent.
(DRRDNIVE STEPS WHICH WIIL BE TAKEN 'IO AVOID FURTHER VIOIATIONS REP-0010 will be revised to clarify and reduce - any potential for direct challenges - to the core loading verification independent review process. A fuel reovannt discrepancy form will be added such that any misrotated bundle discovered during fuel novement in the reactor core must be documented and corrected-prior to beginning the independent core verification process.
Training of refueling personnel will stress aanpliance with all fuel novenent instructions and requirements of REP-0010. These corrective actions will be cmpleted prior to the start of fuel novennnt 'in the reactor vessel during refueling outage No. 4.
Installation of a mast mounted cancra. to visually aid ' refuel floor personnel is-being. evaluated on a cost benefit basis along with other refueling equipnent upgrades.
BTE WHEN FULL COMPIJANCE WIIL BE ' ACHIEVED Pull-canpliance was achieved upon cmpletion of the core verification procees prior to startup after refueling outage No. 3.
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