ML20199C470
| ML20199C470 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 11/17/1997 |
| From: | Collins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mcgaha J ENTERGY OPERATIONS, INC. |
| References | |
| 50-458-97-13, NUDOCS 9711200026 | |
| Download: ML20199C470 (6) | |
See also: IR 05000458/1997013
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NOV I T 1997
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John R. McGaha, Vice President Operations
River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
SUBJECT: NRC INSPECTION REPORT 50-458/9713
Thank you for your letter of November 3,1997, in response to our letter and Notice
of Violation dated September 26,1997. We have reviewed your reply and find it
responsive to the concerns about tagging, post trip reviews, foreign material excluelon,
water tight doors, procedure compliance, and control of combustibles 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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E. Collins, Branch Chief C
Division of Reactor Projects
Docket No.: 50-458
License No.: NPF-47
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Executive Vice President and
Chief Operating Officer
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Director - Nuclear Safety .
River Bend Station
Entergy Operations, Inc.
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Wise, Carter, Child & Caraway
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Mark J. Wetterhahn, Esq.
Winston & Strawn
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Washington, D.C. 20005-3502
Manager Licensing
River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
The Honorable Richard P. layoub
Attorney General
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P.O. Box 94096
Baton Rouge, Louisiana 70804 9095
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H.- Anne Plettinger
3456 Villa Rose Drive
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P.O. Box 1921 '
St. Francisville. Louisiana 70775
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William H. Spell, Administrator
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P.O. Box 82135
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Subject:
Reply to Notice of Violation in IR 97 013
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River Bend Station - Unit I
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License No. NPF-47
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Docket No. 50-458
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File Nos.:
G9.5,O15.4.1
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RBG-44218
RDF197 0342
Gentlemen:
Pursuant to the provisions of 10CFR2.201, Attachments A through F provide the Entergy
Operations, Inc, responses to the Notices of Violation (NOV) described in NRC
Inspection Report (IR) 50-458/97 013. These responses are being submitted within the
one week extension as granted by Mr. Elmo Collins on October 27,1997.
The subject violations,50-458/97013-01,03,05,06,07(a), and 07(b) involve:
(1) breaker alignment during removal of protective tags; (2) an inadequate post trip
review prior to restart; (3) procedural control of temporary flexible material (i.e., a bag of
anti contamination clothing); (4) blocking open a water-tight door which was required to
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be closed by the UFSAR;(5) procedural non-compliance upon receiving unexpected data
while performing a fire pump surveillance; and (6) control of transient combustible
material, respectively.
River Bend Station is equally doncerned regarding the recent performance resulting in
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cach of the subject violations. While the attached responses address actions to correct
each of the violations individually, we are actively pursuing overall human performance
impmvements. Identification and ccrrection of human performance and supervisory
issues is a crucial step in River Bend Station's continuing improvement process. Only
through prompe identification of problems and self-critical resiews can sustained
improvement be accomplished.
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Reply to Notice of Violation in 50-458/97-013
November 3,1997
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RBO-44218
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RBF197 0342
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Should you have any questions regarding the attached information, please contact Mr.
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David I.orfing of my staff at (504) 381-4157.
Sincerely,
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attachments
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 Regulatory Commission
M/S OWFN 13 H 3
Washington, DC 20555
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ATTACHMENT A
REPLY TO NOTICE OF VIOLATION 50-458/97013-01
Page 1 of 2
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Violatles:
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During an NRC inspection conducted on July 20 through August 30,1997, six violations
of NRC requirements were identified. In accordance with the " General Statement of
Polley and Procedure for NRC Enforcement Actions," NUREO 1600, the first of the
violations is listed below:
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Technical Specification 5.4.1.a states, in part, that written procedures shall be
implemented covering the applicable procedures recommended in Apnendix A of
Regulatory Oulde 1.33, " Quality Assurance Program Requirements (Operation),"
Revision 2. February 1978.
Appendix A of Regulatory Guide 1.33, Section 1, recommends administrative
procedures for equipment control (e.g., locking and tagging).
Administrative Procedure ADM 0027," Protective Tagging," Revision 16, Section
7.10 requires, in part, that the operator designated to remove Danger Hold tags
shall be responsible to perform tag removal and component positioning in the
sequence shown on the Clearence Removal Sheet. In addition, Section 7.10
requires the independent verifier to verify restoration of the clearance and initial
each step.
Contrary to the above, on July 17,1997, the individuals responsible to perform
these functions failed to close and independently verify closed, Bwaker EOS-
ACBi l (Division I emergency diesel generator neutral breaker) as specified
during the removal of Protective Tagout 97-0725.
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This is a Severity Level IV violation (Supplement 1) (50-458/97013-01)
Reasons for the Violation:
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Three primary causes were determined. The operators failed to self-check during system
alignment and clearance restoration. The operators failed to follow procedural
requirements for clearance removal and independent verification. The Control Room
Supervisor (CRS) failed to ensure self checking methods were applied.
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ATTACHMENT A
REPLY TO NOTICE OF VIOLATION 50-458/97013-01
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Page 2 of 2
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Corrective Actions That Have Been Taken:
A control panel lineup (main control room and local panel in the diesel generator
building) was immediaMly performed for the division I diesel generator.
A shift briefing form was generated for this event and distributed to Operations crews.
The individuals ' .volved were counseled on procedural compliance and proper
independent verideation.
The operators involved have completed clearance requalification training; including an
interview with the Operations Superintendent before qualifications were restored.
Corrective Actions That Will Be Taken to Avoid Further Violations:
The above tag-out clearance remedial actions are considered appro,riate to prevent
teCurrence.
Date When Full Compliance Will Be Achieved:
River Bend Station is currently in full compliance.
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ATTACilMENT H
REPLY TO NOTICE OF VIOLATION 50-458/97013-03
Page1of3
Violation:
During an NRC inspection conducted on July 20 through August 30,1997, six victations
of NRC requirements were identified. In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the second of the
violations is listed below:
Technical Specification 5.4.1 a states, in part, tiiat written procedures shall be
implemented covering the applicable procedures recommended in Appendix A of
Regulatory Guide 1.33," Quality Assurance Program Requirements (Operation),"
Revision 2, Febr.sary 1978.
Appendix A of Regulatory Guide 1.33, Section 2.c, recommends a general
operating procedure on recovery from reactor trips.
General Operating Procedure GOP-0003, " Scram Recovery," Revision 11,
Enclosure 1, post trip review checklist Section 2.f, states, " Document any
observed premature (safety relief valve) lifts in the safety mode here and receive
an engineering evaluation of the event prior to restart."
Contrary to the above, on August 22,1997, during a reactor scrut event, safety
relief valves lifted in the safety mode; however, the licensee did not document the
safety mode lifts in the post trip review checklist or perfonn an engineering
evaluation of the event prior to restart.
This is a Severity Level IV violation (Supplement 1)(50-458/97013-03)
Reasons for the Violation:
The Safety Relief Valve (SRV) lift occuned due to the rapid pressure increase created by
the relatively fast closure of the Turbine Control Valves. Though system pressure never
reached the SRV set points, the momentum of the rapid pressure increase (i.e., pressure
wave) acting on the SRV's temporarily overcame the spring forces, and jostled some of
the SRV's off their seats. This pressure wave phenomenon is understood, and is of
minimal safety significance.
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A'ITACliMENT B
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REPLY TO NOTICE OF VIOLATION 50-458/97013-03
Page 2 of 3
Reasons forthe Violation (Continued):
Three canses were identified. The first was related to work practice, in that documents
were fallowed incorrectly due to the veong assumptions being made. The oncoming
Shift Technical Advisor (STA) incorrectly assumed that SRV opening corresponded to a
pressure of i123 psig (corresponding to relief pressures of the SRV's), even though the
highest recorded pressures were 1084 psig and 1080 psig by separate indicating systems,
and recorded in the post-trip review checklist. The oncoming STA incorrectly assumed
that the difference must have been due to calibration errors and that the computer sys'.,:ms
failed to record the actuations in the relief mode. Therefore, the step in the subject
procedure directing him to have an engineering evaluation of SRV's that had lifted in the
safety mode was detennined to not apply.
Verbal Communications were a second cause, in that the STA misunderstood verbal
communication during tumover. The oncoming STA did not recall a specific turnover on
the status of the SRV's in the Post Trip Review Checklist. The off-going STA
remembers providing the information verbally. The lack of placement in the formal
tumover tool (i.e., computerized turnover entries) normally used for STA tumovers could
have contributed to this miscommunication. In addition, an inaccurate message was
transmitted to the Facility Review Committee (FRC). The FRC was incorrectly told that
the cause of the difference between what the plant recorded and what the main control
room personnel saw, was within the allowable calibration error for reliefinstrumentation.
The actual cause (i.e., the lift due to the pressure wave phenomenon) was unknown at the
time.
Inadequate training on this phenomenon was a third cause, in that Operations' training
materials do not include the pressure wave phenomenon from a rapid closure of the
turbine control valves. In addition, simulator modeling does not reflect this type of pir.:'t
response.
Corrective Actions That Have Been Taken:
The responsible STA has been counseled conceming the need to follow procedures and
provide accurate data to others.
An engineering evaluation of the event was completed identifying the lift due to the
pressure wave phenomenon.
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ATTACHMENT B
REPLY TO NOTICE OF VIOLATION 50-458/97013-03
Page 3 of 3
Correctiverctions That Will Be Taken to Avoid Further Violations:
The need for the engineering evaluation of the pre mature SRV lifting will be evaluated
since the cause of the SRV lifts associated wi h the pressure wave phenomenor. is both
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expected and understood. As an interim corrective action, the Scram Recovery procedure
will be revised to include an engineering evaluation for any SRV operation concurrent
with a Senun.
The Scram Recovery procedure format will be reviewed to ensure that the scram review
methodology is appropriately human factored.
Operator training and simulator response modeling will be evaluated for the need to
include this pressure wave phenomenon.
Date When Full Comphance Will Be Achieved:
River Bend Station is currently in full compliance.
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ATTACHMENT C
REPLY TO NOTICE OF VIOLATION 50-458/97013-05
Page 1 of 2
Violation:
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During an NRC inspection conducted on July 20 through August 30,1997, six violations
of NRC requirements were identified. In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the third of the
violations is listed below:
Technical Specification 5.4.1.a states, 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 (Operation),"
Revision 2, February 1978,
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Appendix A of Regulatory Guide 1.33, Section 9.a recommends, in part, that
maintenance that can affect the performance of safety-related equipment should
be properly planned and performed in accordance with written procedures.
Administrative Procedure ADM-00s1," Cleanliness Control," Revision 4, Section
8.2.8.6 requires personnel to minimize the use of temporary flexible material such
as plastic sheeting, drop cloths and rags when in containment below the 141-foot
elevation and the reactor is at power.
Contrary to the above, on August 11,1997, while on the 95-foot elevation in
containment with the reactor at power, modification workers failed to minimize
the use of temporary flexible material, in that used protective anti-contamination
clothing was allowed to accumulate in a large open bag before it was removed
from the area.
This is a Severity Level IV violation (Supplement 1) (50-458/97013-05)
Reasons for the Violation:
Two plastic bags, one containing used protective anti-contamination clothing and one
empty, were located above the Suppression Pool. The location of the Contandnation
Zone is unique in that its location above the Suppression Pool prevents the use of a step
off pad and clothes hamper for the collection of protective anti-contamination clothing.
In this particular instance, when a worker removes protective anti-contamination clothing,
it is immediately placed in a yellow plastic bag held by a second worker outside the
Contamination Zone. The bag is taped closed and removed from the immediate work
area.
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NfTACHMENT C
REPLY TO NOTICE OF VIOLATION 50-458/97013-05
Page 2 of 2
Reasons fortfle Violation (Continued):
The two bags were on the catwalk next to the Drywell Wall and within immedicte reach
of three workers, who were aware of the contents of both bags. The bags were under
observation by the workers. This practice was observed by field and design engineers
that were present at the time and was considered acceptable. The workers considered the
bags to be under their control and thus satisfied % r-ouirements for Foreign Material
Exclusion control. Radiation Protection personnel had been contacted and actions to
remove the bag containing the used protective anti-contamination clothing were pending.
The primary cause of this condition is th:tt standards for work practices were less than
adequate. The workers were not instructed to remove foreign material immediately upon
generation.
Corrective Actions That Have Been Taken:
Work was suspended and workers left the area.
Work related material was removed so that the work area could be left unattended in
accordance with govcming procedures.
A me eting was held between all involved personnel to evaluate work compliance with
require.ments.
Standards were reinforced to the workers that no items are to be left unattended or
unsecured when working in and around the Suppression Pool and the swell influence
zone. When a worker exits the Contamination Zone, a second worker outside of the
Contamination Zone will leave the area and obtain a plastic bag. The first worker will
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then remove his protective anti-contamination clothing and place them in the plastic bag.
The bag is then closed and the bag is removed from the area.
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Corrective Actions That Will Be Taken to Avoid Further Violations:
The completed corrective actions should be adequate to prevent recurrence.
Date When Full Compliance Will De Achieved:
River Bend Station is currently in full compliance.
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A1TACHMENT D
REPLY TO NOTICE OF VIOLATION 50-458/97013-06
Page 1 of 2
Violation:
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During an NRC inspection conducted on July 20 through August 30,1997, six violations
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of NRC requirements were identified. In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the fourth of the
violations is listed below:
10 CFR Part 50, Apper. dix B, Criterion Ill, " Design Control," states, in part, that
measures shall be established to assure that the design basis is correctly translated
into procedures'and instructions. The Updated Final Safety Analysis Report
(UFSAR) Section 3.4.1.1.3 requires closure of the Residual Heat Removal (RHR)
Pump Room A water-tight door to prevent adverse effects from flooding.
Contrary to the above, plant staff failed to translate into any procedure the
UFSAR Section 3.4.1.1.3 requirement for closure of the RHR Pump Room A
water-tight door, with the result that from August 11 through August 19,1997, the
water tight door was blocked open for performance of heat exchanger
performance testing during the Seprmber 12 refueling outage and there was no
documented evidence that operatire 'he plant in this configuration was reviewed.
This is a Severity Level IV violation (Supplement 1)(50-458/97013-06).
Reasons for the Violation:
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Three primary causes were determined. Administrative controls were less than adequate
in that existing drawings available for use by Operations personnel did not readily
identify all necessary considerations. Adequate training was not performed in that the
requirement for allowing doors to be held open had only been recently identified as a
knowledge task for operators. The procedure was inadequate in that the procedure did
not contain sufficient direction to ensure equipment operability was considered
appropriately.
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ATTACHMENT D
REPLY TO NOTICE OF VIOLATION 50-454/97013-06
Page 2 of 2
Corrective *rtions That Have Been Taken:
The cables were removed from the door and the door closed immediately.
An engineering analysis of the effect of the open door on equipment was conducted and
determined that the equipment remained operable.
Other immediate actions included a review of other open doors and counseling personnel
involved.
Additional documentation has been provided to the work management center to assist in
the identification of door functions.
Training was provided to operations personnel concerning this event and door functions.
Process controls to control plant doors were developed and implemented.
Corrective Actions That Will Be Taken to Avoid Further Violations:
The required corrective actions have been taken.
Date When Full Compliance Will Be Achieved:
River Bend Station is currently in full compliance.
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ATTACHMENT E
REPLY TO NOTICE OF VIOLATION 50-458/97013-07(a)
Page 1 of 2
Violation:
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During an NRC inspection conducted on July 20 through August 30,1997, six violations
of NRC requirements were identified. In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the fifth and sixth
of the violations are listed below:
Technical Specification 5.4.1.a states, 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 (Operation),"
Revision 2, February 1978, and for the fire protection program.
Appendix A of Regulatory Guide 1.33,Section I recommends administrative
procedures controlling safety related activities carried out during the operational
phase of nuclear power plants.
Administrative Procedure ADM 0015," Station Surveillance Test Program,"
Revision 18, Section 8.9 states, in part, "If a problem occurs during a surveillance
procedure,IMMEDIATELY NOTIFY THE APPROPRIATE SECTION
SUPERINTENDENT OR DESIGNEE AND THE OSS/CRS (Operations Shift
Superintendent / Control Room Supervisor), THEN perform the following: (1)
Determine the cause and extent of the problem. (2) The OSS/CRS with the
guidance of the appropriate Section Superintendent or Designee, shall determine
whether the test should be continued or terminated . . ."
Contrary to the above, on August 21,1997, during the performance of
Surveillance Test Procedure STP-251-3602, " Fire Pump Functional Test,"
Revision 9, a problem developed during the performance of Step 7.2.15, (in that
the batteries did not switch during the sequential cranking test as expected;)
however, the test was resumed without notifying the OSS/CRS and obtaining his
concurrence to proceed.
This is a Severity Level IV violation (Supplement 1)(50-458/97013-07).
Reasons for the Violation:
nree primary causes were determined.
Expectations for the identification of a " problem" were not well understood by the
individual. The failure to follow the procedure requirements was due to the operator's
misjudgment that a problem did not exist requiring resolution by the Operations Shift
Supervisor or Control Room Supervisor, when in fact one did.
- Written communication was less than adequate in that the cross discipline review of the
procedure was not coaducted after the addition of changes.
Also, the procedure validation performed by operations personnel was insufficient.
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ATTACHMENT E
REPLY TO NOTICE OF VIOLATION 50-458/97013-07(a)
Page 2 of 2
CorrectiveMus That Have Been Taken:
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Plant management has counseled the responsible operator on the need to communicate
with the Control Room Supervisor when problems are encountered while performing
procedures.
Corrective Actions That WPI Be Taken to Avoid Further Violations:
Standards regarding Operations' personnel's responsibilities V, communicate with the
appropriate supervision when T.mblems are encountered while performing procedures will
be reinforced.
Standards for performing cross discipline reviews and procedure validations will be
reinforced.
The subject surveillance procedure will be revised to ensure its technical accuracy.
Date When Full Compliance Will Be Achieved:
River Bend Station is currently in full compliance.
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ATTACHMENT F
REPLY TO NOTICE OF VIOLATION 50-458/97013-07(b)
Page1of1
Violation:
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During an NRC impection conducted on July 20 through August 30,1997, six violations
of NRC requirements were identified. In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the fifth and sixth
of the violations are listed below:
Technical Specification 5.4.1.a states, 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 (Operation),"
Revision 2, February 1978, and for the fire protection program.
Appendix A of Regulatory Guide 1.33,Section I recommends administrative
procedures controlling safety-related activities carried out during the operational
phase of nuclear power plants.
Fire Protection Procedure FPP-0040, " Control of Transient Combustibles,"
Revision ?, Section 5.2.4, states, in part, that untreated packing materials shall not
be left unattended during lunch breaks, shift changes, or other similar periods.
Contrary to the above, procedure FPP-0040 was not implemented in that from
July 30 through August 7,1997, untreated packing materials (wooden boxes
containing new fuel channels) were left unattended during breaks and overnight.
This is a Severity Level IV violation (Supplement 1)(50-458/97013 07).
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Reasons for the Violation:
Individuals who were involved in the event demonstrated adequate fire protection safety
consciousness by reviewing the applicable procedure specifically on this topic. After
reviewing and questioning the applicable portion of the procedure, each came to an incorrect
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understanding of the specific requirements regarding control of the different types of
combustible materials which were present. The primary cause was that the applicable
procedure was not clear as to the requirement for handling untreated wooden boxes.
Corrective Actions That flave Been Taken:
The boxes containing fuel channels were attended throughout the shift and were moved to
an appropriate area at the end of the shift.
y
Corrective Actions That Will Be Taken to Avoid Further Violations:
The procedural requirements in the Control of Transient Combustibles procedure will be
clarified to remove any identified ambiguities.
Date When Full Compliance Will Be Achieved:
River Bend Station is currently in full compliance.
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