ML20198A319
| ML20198A319 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 12/23/1997 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mcgaha J ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20198A324 | List: |
| References | |
| 50-458-97-15, EA-97-497, NUDOCS 9801050346 | |
| Download: ML20198A319 (6) | |
See also: IR 05000458/1997015
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REGION IV
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611 RYAN PLAZA DRIVE.SUliE 400
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- ARLINGTON, TEXAS 76011 8064
-December 23.-1997
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EA 97497
- John R. McGaha, Vice President - Operations
River Bend Ststion
Entergy Operations, Inc.
P.O. Box 220
St; Francisville, Louisiana 70775
SUBJECT;
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY -
555,000
(NRC Inspection Report No. 50-458/97-15)
Dear Mr. McGaha:
This refers to the predecisional enforcement conference conducted in the NRC's Region IV
office in Arlington, Texas on December 2,1997. The conference was held to discuss the results
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of an NRC inspection conducted September 22 through October 17,1997, at the River Bend
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Station (RBS). The inspection reviewed the circumstances surrounding two instances where
shutdown cooling was not appropriately maintained. The first event, described in Licensee
Event Report (LER)97-006, occurred on September 13,1997, anf msulted in an unplanned
mode change.- The second event occurred on October 4,1S97, and involved the inadvertent
closing of a shutdown cooling suction isolation valve. Our inspection identified two apparent
violations, and these were discussed with you a d your staff during an exit briefing on
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October 17,1997,
Based on the information developed during the inspection and the information that you provided
during the conference, the NRC has determined that two violations of NRC requirements
occurred. These violations are cited in the enclosed Notice of Violation and Proposed
imposition of Civil Penalty and the circumstances surrounding them were described in detailin
the subject inspection report. The first violation involves a failure to meet technical specification
requirements that prohibit mode changes except when associated limiting conditions for
operation are met. Specifically, RBS inadvertently transitioned from Mode 4 to Mode 3 when the
average reactor coolant temperature increased to greater than 200*F. This violation occurred -
on September 13 when RBS was performing post-modification testing on a new system, the
alternate decay heat removal (ADHR) system. In developing the test plan and procedures, RBS
_ personnel failed to determine how long shutdown cooling systems could remain offline (a
. situation with no forced cooling in the core) before boiling would occur. As a result, after two
hours, unexpected boiling occurred. When RBS r*nonnel unbolted the reactor core isolation
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cooling flange connection to the reactor head, si .am was released on the refuel floor. This
steaming set off alarms and caused an evacuation of the refuel floor until airborne activity could
- be determined /
A review of the circumstances surrounding this event indicated that RBS staff and management
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relied _on a requirement in the test procedure to terminate the test and to restore shutdown
9901050346 971223
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cooling if indicated reactor ecolant temperature reached 160'F. This was intended to give RBS
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personnel sufficient time to restore shutdown cooling before the temperature reached 200'F.
However, with shutdown cooling secured and no forced circulation, the temperature indication
was not representative of average reactor coolant temperature because of temperature
stratification (coolant temperature near the core was much higher than coolant temperature at
RWCU inlet). As a consequence, the unit changed Technical Specification operating modes in
an uncontrolled mt.nner.
The second violation involves three examples of inadequate procedures for operation of
shutdown cooling. The first two E amples were identified after reviewing the circumstances of
the September 13 event. The third example was identified after reviewing the circumstances of
the inadvertent isolation of shutdown cooling on October 4. The October 4 event occurred when
operators closed an electrical breaker and unintentionally shut the shutdown cooling suction
valve. The plant was without shutdown cooling for approximately 17 niinutes while operators
worked to restore the appropriate systems. During this time, average coolant temperature
increased from 97* to 100'F.
These issues are of regulatory significance. In the first event, RBS staff did not recognize a
fundamentalissue (time-to boil) during its review process. Although average coolant
temperature exceeded 200'F for about 30 minutes, with a maximum average coolant
temperature calculated at about 205 *F, the lack of sensitivity to time-to-boil considerations
created the potential for safety consequences, especially in light of the fact that both primary and
smndary containment were open, establishing an unfiltered release path to the environment.
It, tLe second event, she 10wn cooling was not effectively protected from other plant activities.
Therefore, based on the importance of plant staff being sensitive to the need to maintain and
protect shutdown cooling, these violations are classified in the aggregate in accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement
Policy), NUREG 1600, as a Severity Level lli problem.
In accordance with the Enforcement Policy, a civil penalty with a base value of $55,000 is
considered for a Severity Levelill problem. Because your facility has been the subject of
escalated enforcement actions within the last 2 years', the NRC considered whether credit was
warranted for Identification and Corrective Action in accordance with the civil penalty
assessment process in Section VI.B.2 of the Enforcement Policy. The NRC has determined that
no credit is warranted for Identification, because the violations were revealed by events and
because there was industry experience and other information available to RBS staff (specifically
time-to-boil curves in the RBS Shutdown Operations Protection Plan) that should reasonably
have caused actions that would have prevented the violation. This information was not
considered by the engineers developing the test procedure nor by the operations department
reviewing the procedure, and of concern to the NRC, was not questioned by the Facility Review
Committee (FRC). However, the NRC has determined that Entergy is deserving of credit for
Corrective Action based on its prompt and comprehensive corrective actions. These actions
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' On November 7,1996, a Severity Level 111 Notice of Violation (EA 96-329) was issued
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for many licensee-identified examples of a failure to meet the surveillance test program.
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Entergy Operations, Inc.
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included tsking immediate actions to restore shutdown cooling after each event, immediately
forming a Significant Event Response Team, chartering a Quality Action Team to improve the
modification process, enhancing management oversight of complex processes, stressing
leadership of the Operations department, performing additional training on fundamental
knowledge and outage risk awareness, raising the standards and expectations of the FRC,
developing a ? bus coordinator" assignment for entire cycle, and formalizing shutdown cooling
procedure to greater degrees of detail.
Therefore, to emphasize the importance of protecting shutdown cooling from other plant
activities and in recognition of your previous escalated enforcement actior', I have been
authorized to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalty
(Notice) in the base amount of $55,000 for the Severity Level lli problem.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. In your response, you should document the
specific actions taken and any additional actions you plan to prevent recurrence. The NRC will
use your response, in part, to determine whether further enforcement action is necessary to
ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosure, and your response will be placed in the NRC Public Document Room.
Sincerely,
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Ellis W. Mersch
Regional Admi strator
Docket No. 50-458
License No. NPF-47
Enclosure: Notice of Violation and
Proposed imposition of Civil Penalty
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. Entergy Operations, Inc.
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Executive Vice President and.
Chief Operating Offmer
. Entergy Operations, Inc.-
P.O. Box 31995 -
Jackson, Mississippi 39286-1995-
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Vice' President
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- Operations Support
Entergy Operations, Inc.
P.O. Box 31995
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~ Jackson, Mississippi 39286-1995-
General Manager -
Plant Operations
River Bend Station
Entergy Operations, Inc.
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. P.O. Box 220 -
- St. Francisville, Louisiana - 70775
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Director.- Nuclear Safety
River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana' 70775
Wise, Carter, Child & Caraway
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P.O. Box 651
Jackson, Mississippi 39205
Mark J. Wetterhahn, Esq.
Winston & Strawn
1401 L Street, N.W.
Washington, D.C. 20005-3502
Manager- Licensing
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River Bend Station .
Entergy Operations, Inc.
P.O; Box 220
St. Francisville, Louisiana 70775 :
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"The Honorable Richard P. leyoub -
' : Attorney General
P.O. Box 94095
Baton Rouge, Louisis la 70804-9095
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Entergy Operations,lInc.-
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H. Anne Plottinger -
3456 Villa Rose Drive
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- Baton Rouge, Louisiana - 70806
President of West Feliciana -
Police Jury J
P.O. Box 1921
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. St. Francisville, Louisiana 70775 -
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- Joint ownership Manager
' Cajun Electric Power Coop. loc.
- P.O. Box 15540
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-. Baton Rouge, Louisiana 70895.
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-! William H. Spell, Administrator-
Louisiana Radiation Protection Division -
P.O. Box G2135-
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Baton Rouge, Louisiana 70884 2135
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