ML20236G917
| ML20236G917 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 06/30/1998 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mcgaha J ENTERGY OPERATIONS, INC. |
| References | |
| 50-458-98-05, 50-458-98-5, NUDOCS 9807070019 | |
| Download: ML20236G917 (5) | |
See also: IR 05000458/1998005
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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HEGION IV
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611 RYAN PLAZA DRIVE, SUITE 400
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ARLINGTON, TEXAS 76011-8064
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JUN 301998
John R. McGaha, Vice President - Operations
River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
SUBJECT: NRC INSPECTION REPORT 50-458/98-05
Dear Mr. McGaha:
Thank you for your supplemental letter of June 18,1998, in response to our letter and
Notice of Violation dated April 17,1998, concerning deficiencies with the Environmental Design
Criteria of the standby gas treatment system. 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.
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Thomas P. Gwynn, irecto
Division of Reactor rojec
Docket No.: 50-458
License No.: NPF-47
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Executive Vice President and
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Chief Operating Officer
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Entergy Operations, Inc.
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P.O. Box 31995
Jackson, Mississippi 39286-1995
Vice President
Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
9807070019 990630
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ADOCK 05000458
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Entergy Operations, Inc.
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. General Manager
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Plant Operations
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River Bend Station
Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
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Director- Nuclear Safety
River Bend Station
Entergy Operations, Inc.
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P.O. Box 220
St. Francisville, Louisiana 70775
Wise, Carter, Child & Caraway
P.O. Box 651
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Jackson, Mississippi 39205
Mark J. Wetterhahn, Esq.
Winston & Strawn
1401 L Street, N.W.
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. leyoub
Attorney General
Department of Justice
State of Louisiana -
P.O. Box 94005 -
Baton Rouge, Louisiana 70804-9005
-H. Anne Plettinger
3456 Villa Rose Drive
Baton Rouge, Louisiana 70806
President of West Feliciana
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Police Jury
P.O. Box 1921
St. Francisville, Louisiana 70775
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Entergy Operations, Inc.
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Wdliam H. Spell, Administrator
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P.O. Box 82135
Baton Rouge, Louisiana 70884 2135
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June 18,1998
AN 2 2
U.S. Nuclear Regulatory Commission
ATTENTION: Document Control Desk, OP-17
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Washington, D.C. 20555
Subject:
Reply to Notice of Violation in inspection Repoit 50-458/98 05
River Bend Station - Unit i
License No. NPF-47
Docket No. 50-458
File Nos.:
G9.5, G15.4.1
RBG-44548
RBF1-98-0167
Ladies and Gentlemen:
Pursuant to the provisions of 10CFR2.201, Entergy Operations, Inc. (EOI) is
submitting as Attachment i to this letter the response to the Notice of Violation
described in NRC Inspection Report (IR) 50-458/98-05. This inspection was
conducted February 22 through April 4,1998.
We value the insights that we have gained from the subject inspection and believe it
has resulted in an increased knowledge of the Standby Gas Treatment System. The
insights and perspectives acquired from interface with the Commission, research and
testing, and modification feasibility evaluations will allow us to further improve our
system's performance. The commitments contained in this document are identified on
Attachment 2. Should you have any questions, please contact Mr. David Lorfing of
my staff at (504) 381-4157.
Sin
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Reply to Notice of Violation in 50458/98-05
June 18,1998
RBG 44548
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RBF198-0167
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cc:
Regional Administrator
U.S. Nuclear Regulatory Cnmmission
Region IV
611 Ryr : Plaza Drive, Suite 400
Arlington, TX 76011
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NRC Sr. Resident Irispector
P.O. Box 1050
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St. Francisville, LA 70775
David Wigginton
NRR Project Managei
U.S. Nuclear Regulatory Commission
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Washington, D9 20555
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Reply to Notice of Violation in S0-458/98-05
June 18,1998
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ATTACHMENT 1
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REPLY TO NOTICE OF VIOLATION 50-458/9805-01
Violation
During a routine NRC Resident inspection conducted FebnJary 22 through Apri! 4,
1998, a violation of NRC requirements was identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-
1600, the violation is listed below:
10 CFR Part 50, Appendix B, Criterion 111 (Design Control), requires that measures be
established to assure that applicable regulatory requirements and the design basis,
as defined in 10 CFR 50.2 and as specified in the license application, are correctly
translated into specifications, drawings, procedures, and instructions. These
measures are required to include provisions to assure that appropriate quality
standards are specified and included in design documents and that deviations from
such standards are controlled.
The Updated Safety Analysis Report, Section 3.11.1.2, states 'The indoor
environmental design basis conditions which have been used to establish the design
basis for RBS [ River Bend Station) are specified for normal, abnorinai, and accident
conditions. The environmental data for temperature, pressure, humidity, and radiation
are defined for each building zone."
" Environmental Design Criteria, Document Number 215.150, for River Bond Station -
Unit I," Revision 4, specifies, in part, that auxiliary building pressure is between -1/4
and -1/2 inch water gauge (W.G.) under accident conditions.
Contrary to the above, established measures did not assure that deviation from the
Environmental Design Criteria was controlled, in that, since initial construction,
excessive standby gas treatment system induced pressure would have resulted,
under accident conditions, in auxiliary builoing pressure less than -1/2 W.G. (-4.0"
W.G. as currently configured).
Reason for the Violation
The primary root cause of this violation was River Bend Station personnel did
not exhibit a comprehensive level of sensitivity to the complex design and
licensing requirements for the Standby Gas Treatment System and Auxiliary
Building pressures.
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Reply to Notice cf Violation in 50-458/9605
June 18,1998
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System and Design engineers were constrained by their assumption that the
original design of the Standby Gas Treatment system was capable of meeting
the diverse requirements placed on it. In fact, later review and balardng
attempted during Forced Outage 98-01 demonstrated that the design
configuration simplicity of the system compounded by a very leak-tight
secondary containment will not allow it to meet all system requirements; such
as: drawdown requirements, maintain a flow rate of 12,500 cfm in both the
containment purge and the Loss of Coolant Accident snode, and result in long
term Auxiliary Building negative pressures between 1/4 in. Water Gage (W.G.)
and 1/2 in. W.G.
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River Bond Station personnel were focused on the safety functions of the
Secondary Containment and the Standby Gas Treatment System (SGTS) to -
contain, dilute, and hold up fission ;;oducts that may leak from the primary
containment following a Design Basis Accident. It was understood the SGTS
must meet the Technical Specification drawdown times to assure the
performance is within the assumptions of the offsite dose calculations.
Personnel developed the assumption that a higher long term negative pressure
would only help to assure that air exhausted from the Annulus and Auxiliary
Building was filtered and adsorbed by the SGTS. Although Specification
216.300, " Air Conditioning and Ventilation Systems - Hydronic Balancing, was
referred to in the investigation and disposition of Condition Report (CR' 97-
0526A, it was believed the pressure criteria contained in the specification
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applied only to initial system balancing done at startup and did not constitute
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design requirements for the system. River Bond Station should have
recognized the need to reconcile the nonconformances with design and
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licensing bases documentation at this time. Additionally, the relationship
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flow requirements was not recognized; although, the individual requirements
were known,
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Background
The Standby Gas Treatment System (SGTS) is designed to ensure all
radioactivity leaking from the primary containment and Auxiliary Building is
collected and filtered prior to discherge to the atmosphere following an
- accident. The SGTS consists of two identical 100% capacity redundant,
parallel, physically separated charcoal filtration assemblies (GTS-FLT1 A and
B), related ductwork, dampers, controls, and centrifugal fans of 12,500 cubic
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Reply to Notice of Violation in 50-458/98-05
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feet per minute each (cfm). Following an emergency,2,500 cfm is exhausted
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from the annulus to maintain a 1/4"-1/2" W.G. negative pressure relative to the
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Auxiliary Building and 10,000 cfm is exhausted from the Auxiliary Building to
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maintain it at 1/4"-1/2" W.G. negative pressure relative to the outside
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atmosphere. The system is also used (manually) to purge the containment and
drywell. Upon a receipt of a Loss of Coolant Alarm, high annulus radiation
signal or loss of Annulus Pressure Control flow, the SGTS is automatically
started and annulus air and exhaust air from the shielded compartments in the
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Auxiliary Building is divertad through the filter trains. A recirculation flow path is
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provided between the suchon of each filter train and discharge of each exhaust
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fan with associated ductwork, backdraft dampers (GTS-DMP4A/B), manual
balancing dampers (GTS-DMP5A/B), automatic air operated dampers (GTS-
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AOD22A/B) and their associated instrumentation and controls to recirculate and
facilitate flow balancing of the air.
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Discussion
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During the period of April 1986 through May 1997, SGTS operated with various
recirculation duct da nper (GTS-AOD22A/B and GTS-DMP5A/B) configurations.
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These configurations resulted in the recirculation line being unable to reduce
pressure in the Auxiliary Building during post accident system operation. The
Standby Gas Treatment System was more than able to perform its safety
function; however, access to the Auxiliary Building was difficult. In May of
1997, the recirculation duct was restored to a functional status by placing GTS-
AOD22A/B in automatic and by throttling open GTS-DMP5A/B. This action
restored the as <lesigned system lineup. Testing demonstrated that for a single
running train of SGTS, access to the Auxiliary Building would still be more
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difficult than desired.
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An engineering evaluation was performed and concluded that the higher
pressures experienced did not/would not adve sely impact equipment,
components or structures. Soon thereafter,it was recognized that access to
the Auxiliary Building would be necessary with two trains of SGTS sunr667 A
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temporary device was designed and installed on Auxiliary Building Door PW-
95-02. The device would ensure a operator access through the door.
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In March 1998, the need to update the Environmental Design Criteria was
rewgnized. A condition report (CR 98-0230) was written to address this issue.
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Reply to Notice Cf VElation in 50458/96 05
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Subsequently, a root cause evaluation (CR 98-0230) was performed to address
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the high negative pressures in the Annulus and the Auxiliary Building. It was
discovered that restoring the damper lineup to the design configuration in May
of 1997, produced SGTS Filter Train flows in excess of design values. This
restoration lineup required the filter train recirculation dampers, GTS-AOD 22A
and B to be placed in automatic so that they would open upon an initiation
signal. However, this resulted in filter train flows of 15,360 cfm exceeding the
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12,500 cfm * 10% Technical Specification reference flow. This higher flow also
exceeded the filter unit design flow of 12,500 cfm and charcoal maximum face
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velocity of 40 fpm given in Specification 225.220, " Standby Gas Treatment
Units.' High GTS filter train flows were evaluated as part of the interim
disposition for CR 98-0437 and the suppoding operability evaluation. The filter
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train individual components, the fans, the dampers and the associated
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' ductwork were found to be undamaged by the high flows and capable of
performing their safety functions with these high flows.
Contributing Factors:
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The balancing instruction,s containedin Spect6 cation 216.300 lead to a
system alignment where Riter flow may exceed system design tiow rate of
12,500 cim.
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The specification states, "The (SGTS) bypass loop dampers,
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1GTS*AOD 22A, 228, must be closed.' The inlet damper is then
adjusted for a flow rate of 12,500 cfm and suction paths established to
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the SGTS from the Auxiliary Building and Annulus via Annulus Mixing.
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Then, the specification directs the user to, "Open (SGTS) filter train
bypass loop damper 1GTS*AOD22A or 22B, and adjust and set the
pressure for the Auxiliary Building with manual dampers 1GTS*DMP5A
or 58." This results in filter train flows substantially different frem, and
higher then, the 12,500 cfm obteined during the prerequisite balancing.
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Previous history of accepting high negative pressure in the Annulus and
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Auxiliary Sunng with a primary focus of action toward achieving draw down
timesAfttration fancinon.
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Pre-operational test 1-PT 400-2, completed on September 7,1985,
recorded Annulus pressure of -4.2 ' W.G. and Auxilis:y Building
pressure of -0.91" W.G. after one hour of operation. Mceptance
criterion in section 10.12.1 was given as, "The annulus and auxilisty
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Reply to Notice cf Viriation in 50-458/98-05
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RBG 44548
R8F 1-98-0187
Pa0e 7
building pressure is maintained at a minimum -112 inches W.G. and -1/4
inches W.G. respectively (relative to outside atmosphere) during a Loss
of Coolant Accident."
Condition Reports 88-0101, 93-0403, and 94-1109 documented high
negative pressure and or difficulty in accessing the Auxiliary Building
when SGTS is in operation. In each case, no nonconformance with
Specification 216.300 or Environmental Design Criteria Specification
215.150 was recognized or identified.
The disposition and review of CR 97-0526A became nanowly focused on
the goal of reducing Auxiliary Building negative pressure while still meeting
the drawdown times containedin the Technical SpectMcations.
The disposition of CR 97-0526A focused efforts at the resolution of the
access problem created by excess negative pressures in the Auxiliary
Building. Given the system design, a solution was to open the
recirculation dampers and throttle the manual dampers as necessary to
achieve drawdown times. With this accomplished, the goal appeared to
have been met without sufficient consideration given to the effects of this
alignment on other system requirements such as flow rate and peak
positive pressure period.
Corrective Actions That Have Been Taken
As a result of the high negative pressure condition in the Annulus and
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Auxiliary Building, design change documents implemented after May 11,
1997, were reviewed to identify any modifications that may not have been
evaluated for high negative pressure in the Annulus and Auxiliary Building.
None were found.
In response to the flows in excess of Technical Specification values, both SGTS
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trains were declared inoperable. An evaluation and inspection of the effects of
higher flows on systems, structures and components was performed. It was
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determined that no adverse effects on equipment or structures did or would be
expected to exist. The trains were rebalanced to obtain flows within Technical
Specification limits and surveillance tests were performed to assure compliance
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with drawdown times. The final system configuration resulted in lower flows from
the Auxiliary Building than assumed in the original positive pressure period
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Reply to Notice of VI:lation in 50458/9605
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analysis. This in turn affected the Loss of Coolant Accident dose analysis.
River Bond performed a dose analysis (Interim Disposition to CR 98-0437)
using the existing filter train flows, containment leak rate data from 10CFR50,
Appendix J leak rate testing and historical filter efficiency test data. The results
of this analysis were acceptable and determined conservative relative to
historical test data. Additionally, the charcoal beds were analyzed to evaluate
the effects of increased flow. The analysis results on the charcoal indicated no
adverse effects.
Corrective Actione That Will Be Taken to Avoid Further Violationa
River Bond will perform a review of the design and licensing bases of the
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Standby Gas Treatment system and secondary containment prior to plant startup
following Refueling Outage 8.
Complete the System Design Criteria review for Standby Gas Treatment and
update licensing bases documentation prior to plant startup following Refueling
Outage 8.
Evaluate the options, design, and implement modification (s) that will allow
Auxiliary Building access under all modes of SGTS operation without the use of
temporary devices. Actions will be completed by November 30,1998.
Update Specification 216.300 and c'larify Environmental Design Criteria 215.150
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to reflect maximum negative pressures and correct the inaccuracies in the
balancing instructions that contributed to the high flow situ.ation prior to plant
startup following Refueling Outage 8.
Brief Engineering Department personnel on the specific lessons learned from
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this issue including recognizing the importance of both high and low limits for
design ranges; and the proper use of configuration control change mechanisms,
interim Statue
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River Bend Station Engineering has conducted feasibility evaluations to determine the
most 6ppropriate solution to Auxiliary Building access difficulties. One of the most
promising solutions to the access condition is the modification of Auxiliary Building
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doors to enable the installation of a mechanical assist device. The device being
considered, has been used by others in alleviate similar problems with doors. River
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Reply to Notice of Violation in 50-458/88-05
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Pege 9
Bend is in the process of acquiring these devices. These devices may provide a
possible solution to the secondary containment access conditions.
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River Bend Station is continuing to evaluate solutions to system performance
requirements (such as drawdown), system configuration and permanent access
solution alternatives.
Date When Full Compliance Will Be Achieved
Full compliance will be achieved prior to startup from Refueling Outage Eight.
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Reply to Notice of Violation in 50458/98 05
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ATTACHMENT 2
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Commitment identification Fonn
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COMMITMENT
ONE-TIME
CONTINUING
ACTION
COMPLIANCE
Review the design and licensing bases of the Standby Gas Treatment
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System and Secondary Containment. Additionally, RSS will complete
the Standby Gas Treatment System Design Cdteria review and update
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the 1.icensino and Desen Bases documentation
implement modification (s) that will allow Auxiliary Building accesa in all
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modes of operation without use of temporary devices.
Brief Design and System Engineering personnel on the specific
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lessons loamed from this issue including recognizing the importance of
both high and low limits for design ranges and the proper use of
configuration control chenge mechanirms.
Update Specification 216.300, ' Air Conditioning and Ventilation
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Systems - Hydronic Balancing * and clarify Environmental Design
Criteria 215.150 to reflect maximum negative pressures and correct
the inaccuracies in the balanc!ng instructions that contributed to the
high flow situation.
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