ML20134P458
| ML20134P458 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 11/22/1996 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mcgaha J ENTERGY OPERATIONS, INC. |
| References | |
| EA-96-175, NUDOCS 9611290094 | |
| Download: ML20134P458 (5) | |
Text
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AR LINGToN. T ExAS 76011-8064 NOV 2 21996 -
EA 96-175 John R. McGaha, Vice President - Operations River Bend Station Entergy Operations, Inc.
P.O. Box 220 St. Francisville, Louisiana 70775
SUBJECT:
NRC INSPECTION REPORT 50-458/96-12 Thank you for your letter of November 11,1996,in response to our report dated June 12,1996, and Notice of Violation dated October 11,1996. 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 corrective actions during a future inspection to
determine that full compliance has been achieved and will be maintained.
Sincerely,
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j J.' E.
yer, Director Division of Reactor Projects Docket No.: 50-458 License No.: NPF-47 cc:
Executive Vice President and Chief Operating Officer 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 9611290094 961122 PDR ADOCK 05000458 G
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i, Entergy Operations, Inc.~
2-1 General Manager i
Plant Operations
. River Bend Station Entergy_ Operations, Inc.
T P.O. Box 220 St. Francisville, Louisiana 70775 4
Director - Nuclear Safety River Bend Station Entergy Operations, Inc.
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. P.O. Box 220 j'
St. Francisville, Louisiana -70775 l
Wise, Carter, Child & Caraway j
P.O. Box 651 j
Jackson, Mississippi 39205 l
r Mark J. Wetterbahn, Esq.
j Winston & Strawn
.1401 L Street, N.W.
Washington, D.C. 20005-3502 i
Manager - Licensing River Bend Station l
Entergy Operations, Inc.
j P.O. Box 220 St. Francisville, Louisiana 70775 The Honorable Richard P. leyoub 3
i Attorney General I
P.O. Box 94095
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Baton Rouge, Louisiana 70804-9095 s
H. Anne Plettinger I
3456 Villa Rose Drive Baton Rouge, Louisiana 70806 5
j President of West Feliciana Police Jury P.O. Box 1921
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St. Francisville, Louisiana 70775 a
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Larry G. Johnson, Director..
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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
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Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
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5485 U S Highway 61 PO. Box 220 y
St. Francisv>He LA 70775 Tel 504 336 6225 Fax 504 635 5068 Rick J. King Osectcr
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>.._. a November 11,1996 il0Vl5 U.S. Nuclear Regulatory Commission
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Attn: Document Control Desk
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Subject:
River Bend Station - Unit 1 License No. NPF-47 Docket No. 50-458 Replies to Notices of Violation 9612-01 and 9612-02 File Nos.:
G9.5, G15.4.1 RBF1-96-0410 RBG-43339 -
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i Gentlemen:
On June 12, 1996, the NRC issued Inspection Report 50-458/96-12. Included in the report were three apparent violations, being considered for escalated enforcement. After a predecisional enforcement conference on June 26,1996, to discuss the apparent violations, i
Supplement I to Inspection Report 50-458/96-12 was issued on October 11, IC96, containing s
two Level IV violations. Entergy Operations, Inc., hereby submits its replies to Notices of Violation 9612-01 and 9612-02 (Attachments A and B, respectively).
Should you have any questions, please contact Mr. David N. Lorfing at (504) 381-4157.
Sincerely, i
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O Replies to Notices of Violation 9612-01 and 9612-02 November 11,1996 l
RBF1-96-0410 RBG-43339 l
Page 2 of 2 j
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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 U.S. Nuclear Regulatory Commission M/S OWFN 13-H-15 Washington, DC 20555 i
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J ATTACHMENT A REPLY TO NOTICE OF VIOLATION 50-458/%12-01 VIOLATION Technical Specification 5.4.1.a mtes, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33.
" Quality Assurance Program Requirements (Operations)," Revision 2, Febmary 1978.
Appendix A of Regulatory Guide 1.33, Item 4.a. states, in part, that procedures should cover operation of the nuclear steam supply system (vessel and recirculating system).
Technical Specification 3.3.5.1 requires that the emergency core cooling system instrumentation for each Function in Table 3.3.5.1-1, " Emergency Core Cooling System Instmmentation," shall be OPERABLE. Table 3.3.5.1-1 Function 1.b, "Iow Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS) Subsystems" requires for Modes 1, 2, and 3 two operable Drywell Pressure - High instmments.
Procedure SOP-0001, " Nuclear Boiler Instrumentation," Revision 5, Attachment 2 (Instrument and Valve Lineup), requires Valve A4-B21*N094E, Drywell Pressure Transmitter 1B21 *PTN094E isolation, to be open for the Drywell Pressure Transmitter IB21*ETN094E to be operable.
Contrary to the above, on Febmary 14,1996, while in Mode 1, instrument and control technicians found Valve A4-B21*N094E closed when it should have been open! This rendered Drywell Pressure Transmitter IB21 *PTN094E inoperable in Mode I when Technical Specifications required the instmment channel to be operable.
REASONS FOR THE VIOLATION Entergy Operations, Inc., (EOI) admits this violation. Supplement I to LER 96-008 was issued on April 10,1996 (RBG 12782), and documents the investigation, root cause, and corrective actions for this event. The investigation per LER 96-008 reflects instrument failure identification by an operator at 1303 on February 14, 1996. A Limiting Condition for Operation (LCO) was entered, a Maintenance Action Item was initiated, valve A4-B21*N094E was identified as being in the closed position, the valve was opened and the LCO was cleared by 2103 on February 14, 1996. On Febmary 15,1996, a Significant Event Response Team j
(SERT) was fonned to investigate this event. After their investigation, the SERT concluded that the cause of this event was indeterminate. However, the most probable cause was the valve being intentionally closed by someone who was directed by procedure to close another valve. LER 96-008 also identifies that this event was determined not to have a significant impact on safe plant operation.
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Attachment A to RBG-43339 Page 2 of 2 i
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVFE LER 96-008 identifies immediate corrective actions which included restoring the transmitter to service, verifying the Nuclear Boiler Instmmentation line-up, performing a High Pressure Core Spray instrumentation valve line-up, performing a verification of approximately 2,650 accessible safety-related instrumentation valves, and performing a verification of selected non-instrument valve and electrical line-ups.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS In addition to other ongoing program enhancements which are a palt of River Bend's corrective action program, LER 96-008 also identifies the use of a natural work team to review mispositioning events and line-ups for improvement areas.
DATE WHEN FULL COMPLIANCE WILL BE ACIYIEVED Full compliance was achieved at 2103 on Febmary 14,1996, after valve A4-B21*N094E had been re-opened and the LCO cleared.
4 ATTACHMENT B REPLY TO A NOTICE OF VIOLATION 50-458/9612-02 VIOLATION 10 CFR Part 50, Appendix B, Criterion III, " Design Control," states, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews or the performance of suitable checking processes.
Contrary to the above, following a valid start failure of the Division II Emergency Diesel Generator (EDG) on May 8,1994, the licensee installed an inadequately designed EDG modification. The modification consisted of a K-1 relay pilot light on the EDG exciter cabinet and the design of the modification was inadequate because the modification permitted sufficient current to be passed through the K-1 relay pilot light to cause heat to build up in the exciter cabinet. As a result of this heat buildup over time, the EDG field flash relay failed on February 14,1996, which rendered the EDG inoperable.
REASON FOR THE VIOLATION Entergy Operations, Inc., (EOI) admits this violation. LER 96-009 was issued on March 14, 1996 (RBG-42620), and documents the investigation, root cause, and corrective actions for this issue. After the investigation by a multi-discipline team, two root causes were identified in LER 96-009. The first root cause was an incorrect engineering assumption for the maximum temperature reached during an excitation cabinet overheating avent which resulted in less-than-adequate corrective actions. The second root cause was technical errors in the surveillance procedures which resulted in simultaneous latch and reset signals to the K-1 relay.
Contributing factors included less-than-adequate technical reviews of design analysis / change implementation and untimely completion of a previous corrective action. In addition, this event was complicated by the overspeed trip that resulted from less-than-adequate guidance on setting the diesel's mechanical governor. LER 96-009 contains substantially more disctission of the investigation and causes for this event and also notes that, since the other two diesel generators were available,01is event was of minimum safety significance.
CORRECTIVE STEPS TAKEN AND RESULTS ACIHEVED LER 96-009 corrective actions include replacement of the failed field flash relay, replacement of the K-1 relay, and readjustment of the mechanical governor speed setting on the Division II diesel. An in-depth evaluation was also performed on the effects of maximum temperature in the cabinet during the January 29th event.
A Attachment B to RBG-43339 Page 2 of 2 CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS j
The corrective actions identified in LER 96-009 include the performance of a detailed review of surveillance procedures and preventive maintenance tasks associated with the diesel generator control circuitry to identify conditions which may simultaneously energize both the latch and reset coils. LER 96-009 also notes that the field flash ready light will be changed j
out to one that has a higher resistive value and that engineering will receive " case study" training on this event to highlight lessons learned. A review of the process for granting corrective action extensions reviewed for possible improvements is also included in the LER 96-009 corrective actions.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED EOI is in full compliance.
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