ML20236G917

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/98-05

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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g>n Tacut UNITED STATES

1. 1 I% NUCLEAR REGULATORY COMMISSION

g HEGION IV

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$ 0'8

611 RYAN PLAZA DRIVE, SUITE 400

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 jf

Chief Operating Officer I i

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Entergy Operations, Inc.

P.O. Box 31995 f

Jackson, Mississippi 39286-1995

Vice President

Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

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9807070019 990630

PDR ADOCK 05000458

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Entergy Operations, Inc. ' 2-

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i . General Manager j

l Plant Operations i

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.

l P.O. Box 220

St. Francisville, Louisiana 70775

Wise, Carter, Child & Caraway l

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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

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

Police Jury

[ P.O. Box 1921

St. Francisville, Louisiana 70775

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Entergy Operations, Inc. -3-

! Wdliam H. Spell, Administrator

L Louisiana Radiation Protection Division

P.O. Box 82135

Baton Rouge, Louisiana 70884 2135

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DOCUMENT NAME: R:\_RB\RB805AK2.GDR

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June 18,1998

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U.S. Nuclear Regulatory Commission i

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ATTENTION: Document Control Desk, OP-17 l

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 l

my staff at (504) 381-4157.

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Reply to Notice of Violation in 50458/98-05

June 18,1998

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RBG 44548

RBF198-0167

Page 2

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

l St. Francisville, LA 70775

David Wigginton

NRR Project Managei

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U.S. Nuclear Regulatory Commission

WS OWFN 13-H-3'

Washington, D9 20555

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Reply to Notice of Violation in S0-458/98-05

June 18,1998

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RBG-44548

RBF198-0167

Page 3

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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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RBG-44548

RSF198-0167

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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.)

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and 1/2 in. W.G.

l 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 j

applied only to initial system balancing done at startup and did not constitute '

design requirements for the system. River Bond Station should have

recognized the need to reconcile the nonconformances with design and i

licensing bases documentation at this time. Additionally, the relationship  !

' between recirculation line alignment, Auxiliary Building pressure, and filter train l

flow requirements was not recognized; although, the individual requirements  ;

were known, i

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

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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

June 18,1998

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feet per minute each (cfm). Following an emergency,2,500 cfm is exhausted

from the annulus to maintain a 1/4"-1/2" W.G. negative pressure relative to the ,

Auxiliary Building and 10,000 cfm is exhausted from the Auxiliary Building to l

l maintain it at 1/4"-1/2" W.G. negative pressure relative to the outside  !

l 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 i

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

fan with associated ductwork, backdraft dampers (GTS-DMP4A/B), manual i

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

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facilitate flow balancing of the air.

Discussion j

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.

! 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

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running train of SGTS, access to the Auxiliary Building would still be more '

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difficult than desired.

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 i

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

June S8,1998

,- RBG-44548

t RBF196-0167

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l Subsequently, a root cause evaluation (CR 98-0230) was performed to address

L 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

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signal. However, this resulted in filter train flows of 15,360 cfm exceeding the

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 l

l 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  !

' 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.

l The specification states, "The (SGTS) bypass loop dampers,

l 1GTS*AOD 22A, 228, must be closed.' The inlet damper is then

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adjusted for a flow rate of 12,500 cfm and suction paths established to l

the SGTS from the Auxiliary Building and Annulus via Annulus Mixing. l

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. i

e Previous history of accepting high negative pressure in the Annulus and

Auxiliary Sunng with a primary focus of action toward achieving draw down

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timesAfttration fancinon.

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

June 18,199s

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RBG 44548

R8F 1-98-0187

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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

e As a result of the high negative pressure condition in the Annulus and

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

trains were declared inoperable. An evaluation and inspection of the effects of

higher flows on systems, structures and components was performed. It was ,

determined that no adverse effects on equipment or structures did or would be l

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

June 18,1998

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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

e River Bond will perform a review of the design and licensing bases of the

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

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 i

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

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promising solutions to the access condition is the modification of Auxiliary Building

I 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

June 18,1996

- RBG-44548

RBF1-96-0167

Pege 9

Bend is in the process of acquiring these devices. These devices may provide a

possible solution to the secondary containment access conditions.

! 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

June 18,1998

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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 X i

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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 X

modes of operation without use of temporary devices.

Brief Design and System Engineering personnel on the specific X

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 X

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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