ML20214N993

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FOIA Request for Documents Concerning Tech Specs Changes, Operating Procedures,Personnel Training & Physical Plant Changes
ML20214N993
Person / Time
Site: River Bend Entergy icon.png
Issue date: 09/11/1986
From: Guste W
LOUISIANA, STATE OF
To:
NRC
References
FOIA-86-687 NUDOCS 8612040040
Download: ML20214N993 (3)
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. Spfate of Tauisiana DEPARTMENT OF JUSTICE

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Ptw FLoon Witu Au J. Guste.Ja.

ATTOe**ET Ogestaat 3-3 4 LOYOL A SUILDING September 11, 1986 FREEDOM OF INFORMATON ACT REQUEST forJ-26-u 7

Admiral Lando Zech, Chairman Nuclear Regulatory Commission Cf 9~/7-((

U.S.

Washington, D.C. 20555 This letter contains a Freedom of Information Act Request -

5 U.S.C. Sec. 532 et seq. -

Dear Admiral Zech:

I have been startled to read documents obtained from a Louisiana citizen in response to a Freedom of Information Act request in which an NRC official expressed the belief that Gulf States Utilities Company had apparently concealed knowledge of serious aad pervasive errors and misstatements in the River Bend Technical Specifications.

The NRC official, Mr. Dean Houston, has expressed his misgivings, not only about the concealment, and the prevalence of errors in the technical specifications, but also about what he evidently considered to be an unwise policy decision by NRC to accelerate its review of the technical specifications.

Mr. Houston's memo of May 1st refers to the fiasco to which, in his view, a similar policy led with respect to Grand Gulf.

I am not sure of the extent of the fiasco over Grand Gulf to which Mr. Houston refers; I am painfully aware, however, that only days after that plant had been declared in commercial service, and therefore, Middle South Energy's customers had become responsible for its capitol costs, the plant was shut down for an extended period, to accomplish by l retrofit compliance with NRC requirements which had been deferred until that time.

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Quite apart from the safety implications of Mr.

I Houston's revelations, which, I trust, you will examine l .

i 8612040040 FOIA 860911 PDR l Pbgo sTE86-687

A Admiral Lando Zech, Chairman U.S. Nuclear Regulatory Commission September 11, 1986

- Page Two thoroughly, I am concerned about their significance for economic regulation of Gulf States Utilities Company by the Louisiana Public Service Commission. The Louisiana Commission, like its counterpart in Texas, has before it the

, question of whether River Bend has "gone commercial" and, if so, when.

The company has suggested that River Bend was placed in commercial service on June 16, 1986.

I should be grateful if you would cause'your staff ~to send me whatever.information NRC may have that may be relevant to that determination, including, but not' limited to, any

~ documents containing any information concerning changes made in the technical specifications, the operating procedures, the training of personnel, and the physical plant itself, 1 - subsequent to June 16, 1986; whether decisions to make those changes have been made or are under contemplation, and whether

- such changes will cause or extend any shutdown of the plant, or any operation at reduced power.

I should further like to ask you, Admiral, in a spirit of comity, and apart from the specific requirements of j the Freedom of Information Act, to advise me of any NRC requirements, or contemplated requirements, or indeed to advise me of anything of which your agency has knowledge, (apart from normal fuel consumption) which may affect the capacity factor performance of River Bend.

I trust that you will direct your staff to respond to this request in keeping with the spirit as well as the letter of the Freedom of Information Act.

Inasmuch as this information is sought for use by a state government -- actually two state governments, since we will share it with our Texas counterparts -- in the economic regulation of a public utility company, a use which primarily benefits the general public, I request that you direct your 4

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Admiral Lando Zech, Chairman U.S. Nuclear Regulatory Commission September 11, 1986 Page Three agency to waive or substantially reduce the fees it is authorized to charge for compliance 'th this request.

Very truly ou ,

WILLIAM . USTE, .

Attorn eneral WJG,JR./vpf Enclosures cc: Members, U.S. Nuclear Regulatory C6mmission FOIA. Office, U.S. Nuclear Regulatory Commission Members, Louisiana Public Service Commission Louis S. Quinn, Secretary, Louisiana Public Service Commission Secretary, Public Utilities Commission of Texas James Boyle, Office of Public Utility Counsel r

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May 1,1985 i

Note To: E. Butcher, Group Leader TSRG, DL From: D. Houston, TSRG, DL

Subject:

Concerns About River Bend Technical Specification Development l l

Initial feedback from Region IV auditors and NRR reviewers in regard to River Bend Tech Spec review would indicate that: (1) this draft of Tech Specs has I some serious problems to be resolved. (2) numerous deficiencies in plant pro-cedures exist in about all areas wher. compared against this draft and (3) the plant itself will not be ready for licensing before September,1985. It would appear that our accelerated review schedule is inappropriate and our " Final Draft" questionable. Therefore. I feel that the future development of RBTS should be reassessed upon the conclusion of the current review, on or about May 15,1985, and see if a normal schedule (enclosed) would not be the better way to proceed. .

The licensing process for River Bend follows that for Grand Gulf during the last year of review. Grand Gulf was always to be ready for licensing in the next month or two from November 1981 to June 1982. Due to this anticipated action, technical reviews and Tech Spec development could not be performed under ideal conditions.

We are all aware of the problems that surfaced afterwards on GGTS but yet it appears to me that we have ignored some of the lessons learned from the GG case by accelerating the RSTS development, thus giving reviewers less time to perform their review and eitminating some logical steps in our established procedure.

On River Bend, the basic problem with the review is that the utility has failed to pursu[ solution of numerous issues in a timely manner. When confronted with the restr' citons on containment purge, their licensing contact said they were pre-paring a submittal for next week to address the problem that has been known to exist for months. Currently, the LPM carries 67 open items for resolution in the i SER and SSERs. This resolution in many cases depends upon future FSAR amendments, not just the ones in the past few weeks which have yet to be reviewed. As of now, ASB.CSB.EQB.ICSB,PSB andRSB branches are looking at or are awaiting information, all of which might affect RB Tech Specs. Compare this to Perry which expects a license in June-July,1985, only a total of 21 items remain open.

From the Regiyal Audit viewpoint, we have turned the Audit Team loose with a cet m m MJech Specs right off the press. On a normal schedule, they would have had the TS for 5 weeks to review, comment and resolve outstanding items prior to their audit function. The utility would also have had 5 weeks to review their procedures before the audit. By accelerating the schedule, both the Region and the utility a're poorly prepared for this important step in the TS process.

The same can be said for our consultant review and for the utility certification.

All of these functions were again an aftemath of the Grand Gulf fiasco and we have lessened the review. ~~

Due to the uncertainties associated with the current safety review, I would rec-omend that the TS situation be reassessed in the near future and a realistic schedule be set. If many problems exist or are still to be resolved, a nomal schedule ending in August should be adopted. Obviously, with current and future TSRG resources available, my participation in the realistic schedule should not -

be required and a near-future depar.ture to ACRS can be arranged. Please inform me of a ' suitable transfer date. t

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D. Houston, TSRG' DL

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                                            ?                                                                          UNITED STATES

[8 I 'l NUCLEAR REGULATORY COMMISSION 

                                "                                                                              W ASHINGTON,0. C. 20555 l        3                          ,    j May 17, 1985
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1 MEMORANDUM.FOR: Edward J. Butcher, Group Leader Technical Specification Review Group Division of Licensing FROM: M. Dean Houston, Reactor Engineer Technical Specification Review Group Division of Licensing

SUBJECT:

DEFICIENCIES IN REGARD TO GSU CERTIFICATION OF RIVER BEND . TECHNICAL SPECIFICATIONS (FINAL DRAFT) By letter dated May 2,1985. Gulf States Utilities (GSU) was requested to review the final draft of River Bend Technical Specifications and submit by May 13, 1985, a certification under oath and affinnation that .the final draft accurately reflects the FSAR, SER and as-built configuration of the plant. By letter dated May 6,1985 GSU submitted their certification, under oath and affirmation, of the final draft of River Bend Tech Specs. Included in their submittal were: (1) identified editorial changes (173 items), (2) proposed changes to the Tech Specs (38 items), (3) proposed revisions to the SER (7 items) and (4) identification of FSAR sections to be revised with some proposed FSAR revisions (55 areas). In my review of their submittal, numerous deficiencies, acts of emission and conynission, have been identified. Examples of editorial errors that were not identified by GSU are presented in Enclosure 1. The attached pages are from the GSU submittal, some with their markup, and the errors that were not detected are circled. These errors take many forms - typos, missed l headings, non-existent trip signals, nomenclature, etc. While misspelled

  • words can be properly interpreted, many of the other unidentified errors f

' would have contributed to operator confusion. The enclosure is not intended to be a complete compilation of overlooked errors but does establish that the GSU review process was less than thorough. Approximately 20% of the ! errors in the final draf t were not detected during their review. This is an unacceptable level by any standard and their review process for certi-fication at licensing must be improved. Examples of deficiencies by acts of comission are presented in Enclosure 2. Two of these are editorial errors and one is based on a possible false statement regarding their as-built plant. (1) GSU proposed changes to page 3/4 8-5 of the River Bend , Tech Specs as shown. As proposed, the change was to be inserted between 10 and seconds. On page 3/4 8-6 of the I 11 <  %

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Edward J. Butcher May 17, 1985 

         ,             same submittal, GSU properly proposed an identical change with the clause to be inserted after 10 seconds. As pr.oposed on 3/4 8-5, the revision makes no sense and would confuse the operator.

{2) In Attachment B of the GSU submittal of May 6, 1985, Item 29 reouests a deletion of a surveillance requirement because - 

                       "There are no valves in the flow path of any PGCC subsystem."

In past discussions, GSU has resisted this requirement on the basis that the valves did not have a position indicator although, in fact, the valves do have a trip indicator. A copy of FSAR Figure 9.5-13 is enclosed which shows numerous solenoid operated valves as well as a cou;1e of check valves 

   , ,                 in the flow path. Therefore, the GSU statement of "no valves in the flow path" appears to be a false representation.

(3) Also, in Attachment B, item 30 refers to adding a footnote to TS 3/4.7.6.4, Table 3.7.6.4-1. This is in error as the proposed footnote,was identified with TS 3/4.7.6.5 Table 3.7.6.5-1. - In' addition to the deficiencies noted above, I would like to comment briefly on other uncertainties associated with the River Bend Tech Spec review. GSU has submitted a listing of 55 areas in the FSAR that need revision to support Tech Spec. sections. Amendment 19 to the FSAR was delivered on May 14, 1985 and only 12 of these areas were addressed. Therefore, in the other 43 areas, the NRR Technical Reviewer has not seen the necessary documentation to support the current Tech Spec section or a proposed revision to a section. There is also the potential for additional FSAR revisions resulting from the reviewer's evaluation. This lack of timely information will impact the accelerated schedule for issuance of the Tech l Specs with the River Bend license in June,1985. There seem to be some values in the FSAR and Tech Specs that are constantly being changed. For example, the DBA activity release to the environment following a LOCA (used for containment Tech Spec review) were revised in Amendment 18 to the FSAR dated April 1985 and revised again (increased) in Amendment 19 on May 13, 1985. In the Tech Specs, GSU has proposed that the water level for r4 Ultimate Heat Sink be 112'4" (2nd Draft),108"6" (Final Draft) and 111'10" (current revision). Changes of this frequency would indicate that the utilities review process has not settled down. All of the above matters should be given due considerations when discussing comitments and completion schedules for the River Bend Tech Specs. 

                     .                           h A-                  @Lb M. Dean Houston, Reactor Engineer Technical Specification Review Group Division of Licensing                 -

cc: D. Crutchfield R. Benedict S. Stern l l

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a Edward J. Butcher May 17,1985
 '                                                               same submittal, GSU properly proposed an identical change with the clause to be inserted after 10 seconds. As proposed on 3/4 8-5, the revision makes no sense and would confuse the operator.

(2) In Attachment B of the GSU submittal of May 6,1985, Item 29 requests a deletion of a surveillance requirement because - 

                                                                "There are no valves in the flow path of any PGCC subsystem."

In past discussions, GSU has resisted this requirement on the basis that the valves did not have a position indicator although, in fact, the valves do have a trip indicator. A copy of FSAR Figure 9.5-13 is enclosed which shows numerous solenoid operated valves as well as a couple of check valves in the flow path. Therefore, the GSU statement of "no valves _- , in the flow path" appears to be a false representation. (3) Also, in Attachment B. Item 30, refers to adding a footnote to TS 3/4.7.6.4, Tab.le 3.7.6.4-1. This is.in error as the proposed footnote was' identified with TS 3/4.7.6.5, Table 3.7.6.5-1. In addition to the deficiencies noted above, I would like to comment briefly ! on other uncertainties associated with the River Bend Tech Spec review. GSU has submitted a listing of 55 areas in the FSAR that need revision to I support Tech Spec sections. Amendment 19 to the FSAF was delivered on May 14, 1985 and only 12 of these areas were addressed. Therefore, in the other 43 areas, the NRR Technical Reviewer has not seen the necessary documentation to support the current Tech Spec section or a proposed 

                            ,                   revision to a section. There is also the potential for additional FSAR revisions resulting from the reviewer's evaluation. This lack of timely information will impact the accelerated schedule for issuance of the Tech Specs with the River Bend license in June, 1985.

There seem to be some values in the FSAR and Tech Specs that are constantly being changed. For example, the DBA activity release to the environment following a LOCA (used for containment Tech Spec review) were revised in Amendment 18 to the FSAR dated April 1985 and revised again (increased) in A.mendment 19 on May 13, 1985. In the Tech Specs, GSU has proposed that the water level for the Ultimate Heat Sink be 112'4" (2nd Draft),108"6" l (Final Draft) and 111'10" (current revision). Changes of this frequency would indicate that the utilities review process has not settled down. - All of the above matters should be given due considerations when discussing i commitments and completion schedules for the River Bend Tech Specs. i Original signed by M. Dean Houston, Reactor Engineer Technical Specification Review Grooi Division of Licensing cc: D. Crutchfield TSRG:DL Distribution - R. Benedict DHouston:jc Docket File *TSRG File S. Stern 5//p/85 e 

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                  -                                        May 21, 1985 Mr.MORANDUM FOR:         Edward J. Butcher, Group Leader Technical Specification Review Group, DL FROM:                    R. A. Benedict, Reactor Engineer Technical Specification Review Group, DL SU3 JECT:               MORE DEFICIENCIES IN REGARD TO GSU CERTIFICATION OF RIVER BEND TECHNICAL SPECIFICATIONS (FINAL DRAFT)          ,

Further to Dean Hous' ton's May 17, 1985 memorandum to you on this same subject, there are an additional 38 pages in which editorial errors were not identified by GSU. The missed errors are circled on the enclosed pages. All told, 79 pages .out of 509 had editorial errors that GSU missed. R. A.. Benedict, Reactor Engineer Technical Specification Review Group, DL

Enclosure:

As stated cc: D. Crutchfield D. Houston S. Stern 5 f 

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          %      s., ,/                                       July 9, 1985 Docket No. 50-458 l

NOTE TO FILE:

SUBJECT:

RIVER BEND TECHNICAL SPECIFICATIONS 

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On July 8,1985, a highly reliable source with professional ties to Gulf States Utilities remarked in the presence of another TSRG member and myself that the River Bend staff was aware of many errors, discrepancies and problems in the current River Bend Technical Specifications. He further said that GSil management had apparently instructed their staff to not pursue resolution of these items at this time since Jt would be time consuming and hold up the issuance of a license. They have detemined that the plant can live by the current Tech Specs and changes will be pursued after licensing. This philosophy is identical to that of MP&L or Grand Gulf and we are all too aware of the disastrous results of that case. Ancther reason that GSU.would not want to pursue resolution at this time is that changes to Tech Specs will result in changes to operating procedures. With some 900 procedures to re-review and modify, if necessary, more time will be lost toward licensing. If the above is true, CAUTION should be the mode for TSRG, technical reviewers, Region IV and EG&G in the final audit and review of Appendix "A" to the license. GSU has already demonstrated their inability to identify all errors in the certification of the 

                  " Final Draft." I would expect that their final certification will be perfomed in the same haste and will definitely not identify all problems if the above instructions are true.

S 2$ ~ Dean Houston, Reactor Engineer Technical Specification Review Group Division of Licensing - cc: R. Benedict t M. Virgilio D. Crutchfield e 

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July 15, 1985 ' Docket No. 50-458 i NOTE TO: File 7 FROM: Dean Houston, TSRG:DL SU8 JECT: RIVER JULY BEND TECHNICAL SPECIFICATION NOTE OF 9, 1985 In my note of July 9,1985, I made reference to errors, discrepancies and were time constraints. known to GSU staff members but were not pursue asked about details no specific examples were furnished. concerning these areas p and the questio 

                                                                                 .The basis for my concern is that GSU has the Final already          demonstrated a weakness. in their certification (under oath) of Draft.

Following that certification, Bob Benedict and I issued memorandums, dated May 17 and 21, 1985, respectfully, in which we identified numerous errors that were not uncovered in their review (Enclosu To the best of my knowledge, I am unaware of specific details that would indicate errors, deficiencies, or problem areas in the curren't Technical Specifications. However, it would not surprise me if there were. For example, in Amendment 20 to the FSAR, that has been the basis of our review dated identified latefor June 1985, the first time. eight new ventilation systems and one new building w While it may be true that these systems did not truly not affectreflected the Technical the as-built Specifications, plant. it is an indication that the FSAR has safety systems, the Technical Specificatiens could be in error.If similar discrepa i Technical Specifications, note the differences between

certified (Enclosures copy dated 3 and 4). April 26, 1985, and a markup dated June 28, 1985

' Three key instru:nentation setpoints for the HPCS system were before?changed, hopefully the last set is correct but why wasn't the matter ca One Fuel Handling. area that has previously been discussed and w As written, all primary containment penetrations required to be closed during accident conditions are closed by some mechanism. GSU had i informally status ratherrequested than closed.that some of these penetrations be put into operable i some time to review and approve, that we should forget it.Their reques Since pytting valves into other than a closed category would have reopened the review of this area, we did not grant the change or pursue it further. There is some principle, but may not work in the real world. indication n that the should be pursuing now. This may be an area that GSU i .

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File July 15, 1985 The extent of errors and discrepancies is not known other than noted above. 

                                                     & af & ,. r;a Dean Houston Technical Specification Review Group, OL Er. closure:

As stated cc: D Crutchfield M. Virgilio um B e 1 . l l I

753, -2 July 15, 1985 Tre extent of errors and discrepancies is not known other than noted above. Original signed by Dean Houston Technical Specification Review Group, DL Er:losure: As stated cc: D. Crutchfield M. Virgilio DISTRIBUTION T5R5 Rdg _ DEcuston N * 'th .hJ () , 3.( , hc C < ,: % / F,% 4,

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  • W A SHING T ON, 0. C. 20555 h . ,',. . July 18, 1985 MEMORANDUM FOR: Robert D. Martin, Regional Administrator Region IV FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation

SUBJECT:

REQUEST FOR AN INVESTIGATION The purpose of this memo is to request your assistance in investigating an allegation of wrongdoing by Gulf States Utilities, the applicant for River Bend. By memo dated July 9,1985, Mr. Dean Houston, a Reactor Engineer in the Division 1 of Licensing, NRR, informed us of an allegation regarding the quality of certain licensing documents. In Mr. Houston's presence, an individual with professional ties to the applicant stated that the applicant's staff is aware of many errors, l discrepancies and problems in the River Bend Technical Specifications. He further stated that Gulf States Utilities' management had instructed their staff not to pursue corrections at this time since it would hold up issuance of a license. As Enclosure 1. I am providing a copy of Mr. Houston's July 9,1985 memo. i Mr. Houston believes the alleged activities likely occurred. This is based _ on his assessment of the applicant's perfomance throughout the Technical Specification development process. As Enclosure 2. I am providing a second memo on this subject from Mr. Houston dated July 15, 1985. This memo was written at our request to document relevant background infomation. Mr. Martin Virgilio of the Technical Specification Review Group DL, has been j designated as office contact for this action. Mr. Virgilio can be reached at  ! 492-8947. H o d R. Denton ir to O e of Nuclea Rea to regulation

Enclosures:

As stated cc: J. Taylor - ,

8. Hayes OM + x M ,

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