RBG-32249, NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment.

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NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment.
ML18018A012
Person / Time
Site: River Bend Entergy icon.png
Issue date: 02/02/1990
From: Deddens J
Gulf States Utilities, Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-89-013, RBG-32249 NUDOCS 9002150296
Download: ML18018A012 (7)


Text

, '

~. ' .

GULP STA'l'EJS U'l'l.£17'1.ES February 2, 1990 RBG-32249 File Nos. Gl.49.5, G9.5, 69.33.4 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

River Bend Station - Unit 1 Docket No. 50-458 NRC Generic Letter 89-13 This letter provides Gulf States Utilities Company's (GSU) initial response to Generic Letter 89-13, "Service Water System Problems Affecting. Safety-Related Equipment". This generic letter requested that licensees perform the actions specified below to ensure that their service water system is in compliance and will be maintained in compliance with applic~ble codes and criteria. This response is formatted according to the generic letter outline; in that each action item is stated followed by the GSU response.

I. For open-cycle service water systems, implement and maintain an ongoing program of surveillance and control techniques to significantly reduce the incidence of flow blockage problems as a result of biofouling.

As a facility with recognized potential for biofouling problems due to Corbicula sp., River Bend Station developed an Asiatic Clam Control Program (ACCP) which was implemented at the time of foitial . introduction of Mississippi River water to plant systems (November, 1985). The ACCP and revisions were approved by the.

NRC prior to implementation, as is required of any future changes~

  • The *ACCP incorporates* continuous, low-level .chlorination of

.nonnal. service water (NSW); monthly performance trending of safety-related heat exchangers supplied by NSW; sampling and/or inspection of each safety-related heat exchanger supplied by NSW at least *once per operating cycle; and biological monitoring. for . .

clams . *1n sourc.e wa*ter and pfarit {ysteins *. AlthouQ'h .. intended to specifically address Asiatic ~lams,**th.e ACCP provides for equally

.~ffective detection and . prevention* of macrofoul ing by other

  • .*potential agents ..

(e.g., ~ebra mussels)~

  • 9002150296 900~0~
  • 1 ,*
  • PDR . Ar)~V ~~=~-~~-

'"'C C,r, *1..1.:,1.11.104,_,:::::

  • )-'1.'
,* . P * *

..':*J.':',i.;:..{t*i*,*:-::,.:.. ,,:*...*:., ,,,,',, ,:* .. , **.';*

The fire protection system at River Bend Station* is s~pplied by well water, thus offering no potential for intrusion by macrofouling agents and no need fortreatmentwithbiocides. There is a remote possibility*for cross*

connection of service water with limited portions of the fire protection system, in which case the ACCP requires inspection of the affected sections and flushing with deminera,ized water to restore acceptable water quality.

Because of the ACCP requirement for continuous chlorination of* NSW, any \

service water cooling loop would automatically be filled with treated water when isolated for layup.

  • Inspections by divers of the outside of the makeup water intake screens can be* performed during normal operation at any time there is concern about possible blockage. Sediment accumulation in the immediate vicinity of the screens is monitored monthly by fathometry and complete surveys of the intake embayment are performed approximately annually as required and as limited hy river conditions.

Service water supply and return lines to the normally closed reactor ~lant component cooling water (CCP) and ventilation chilled water (HVN) systems are redundant and infrequently used cooling loops. Flow in these lines will be evaluated prior to startup from refueling outage 3 (RF-3) scheduled to begin September 15, 1990, by indirect methods (e.g., pressure drop calculations, partial flow tests) or by system flow testing.

II. Conduct a test program to verify the heat transfer capability of all safety-related heat exchangers ~ooled by service water. The total test program should consist of an initial test program and a periodic retest program. Both th~ initial test program and the periodic retest program should include heat exchang~r~ connected to or cooled by one or mor~ open-cycle systems.

GSU is developing a Heat Exchanger Performance Monitoring Test Program (PEP-046) prior to RF-3 which meets the recommended actions of this part of the generic letter. The following heat exchangers~will be tested per this program:

HEAT EXCHANGER SCHEDULE FOR INITIAL TEST Diesel/Generator Jacket Water Coolers RF-3 Control Building Chiller Condensers RF-3 Auxiliary Building Unit Coolers RF-3 RHR Heat Exchangers RF-3 PVLCS Compressor Aftercoolers RF-3 RHR Heat Exchangers Radiation Monitor Coolers RF-4 Periodic retesting rin a sampling basis will be performed at least one~ per fuel cycle with the frequency being evaluated after three tests to ensur~

that testing. is providing

  • assura.nces that* equipment is performing
  • its intended function, Portions of the following systems are considered safety-related:

closed..:cyc.le systems at River Bend:

Reactor Plant Component Cooling Water .. (CCP)*

Spent Fuel Pool Cooling and Cleanup (SFC)

. Turbine Building .Chilled Water (HVN) .

Control Building Chilled Water {HVK) . .

Diesel Ge~erator Jacket Cooling Water (EGT) 2 -

j' I.... ,!','
:, .. *'. '* ** ... ,**,. *.*.

Complete flushing and flow testing. of these nonnally closed loops is unnecessary, since plant chemistry records document acceptable water quality throughout most of the operating histo,ry. To further confirm this position, GSU will perform a one-time heat exchanger performance test on a contairiment ~nit cooler (cooled by HVN) and will clean the control building chiller evaporators (HVK) prior to startup from RF-3. £valuations of the results of this testing and cleaning wi.11 determine if further actions are required. These actions, combined with current improved water chemistry~

assure adequate closed cycle system performance.

  • III. Ensure, by establishing a routine inspection and maintenance

. program for open-cycle service water system piping and components; that corrosion, erosion, protective coating failure, silting, and biofouling cannot degrade the performance of the safety-related systems supplied by service water. The maintenance program should have at least thA following purposes:.

A. To remove excessive accumulations of biofouling agents, corrosion products, and silt; B. To repair defective protective coatings and corroded service water system piping and components that could adversely affect performance of their intended safety functions.

The ACCP described above includes requirements to inspect and take corrective action in the event of degradatfon of heat. exchanger performancP.

due to biofouling, corrosion products or silt.

Local leak rate testing, inservice inspections and* inservice testing of safety-related components as well as system surve1llance testing helps ensure that such components are capable of performing their intended function. Failures of such tests and inspections are i~vestigated and components are repaired. Noncestructive examinations of service water piping have been performed to establish baseline data. These examinations are repeated on a periodic basis to monitor specific piping sections for erosion/corrosion. Observations of the service water systems during daily rounds serve to identify leaks or other discrepancies. Any deficiencies identified would be investigated and reworked in accordance with existing site procedure5, GSU has developed inspection criteria and requirements which provide for scheduled inspections and specific instructions for maintenance of service water heat exchangers and unit coolers. The draft corrective maintenance procedure. which implements this program, is currently under review and will be in place prior to start up from RF-3.

IV. Confirm that the service water system will perform its intended.*

function in accordance with the licensing basis

  • for the plant.

This confirmation should*include a review of the ability to perform required safety functions in the event bf failure of a single active component. To ensure that the as-built system is in accordance with the appropriate licensing basis documentation,*

. this confirmation

  • sho1,1ld include recent system walkdown inspections.

G~lf States Utilities' confirmattci~ that the service water systefu, as defined in Generic

  • Letter 89-13, will be able to perform its function in

- 3 ...

  • .,.). ..

the event of the failure of a single active component will rely primarily on the analysis being performed for Generic Letter 88-20, Individual Plarit Examination (JPE) for Severe Accident Vulnerabilities. GSU s methodology j to perform the IPE is described in GSU's response to GL 88-20 dated October 27, 1989 (RBG-31692). The analysis performed for GL 89-13 will address those' service water systems, or portions thereof, that serve safety-related components and wfl 1 be performed in a manner consistent with that of the original design ba~is for those systems as described in the.USAR. This analysis will be completed prior to plant startup following RF-3. If any

  • single active failure is identified which could prevent the service water system from performing its intended function, evaluation of the potential safety impact will be performed as part of the IPE analysis in accordance with the IPE schedule as stat~d in RBG-31692.

To confirm the service water system licfmsing ~asis configuration and s,;*stem condition, GSU is performing a service water system walkdown to

. verify flow path and system status. This walkdown excludes pipe supports, electrical and electrical supports,* instrument supports and instrumentation. These portions of the service water system were verified at the end of the construction phase of River Bend Stationi and changes are tightly controlled by design control procedures. This walkdown will be completed prior to startup from RF-3.

V. Confirm that maintenance practices, operating and emergency procedures, and training that involves the. service water system are adequate to ensure that safety-related equipment cooled by the service water system will function as intended and that operators of this equipment will perform effectively. This confirmation should include recent reviews of practices, procedures, and training modules.

GSU has reviewed maintenance practices affecting the service water system.

Maintenance of*equipment at RBS is identified, controlled, and documented through the implementation of Maintenance Work Orders. The work package supplies job steps for perfonning the required work as well as identifying applicable procedures and plant documentation that sho~ld he adhered to during job performance. Material and spare parts needed to accomplish the task are identified and ASME Section XI repair/replacement plans are provided when required. MaintenancP. personnel perform the specified repairs or rework in accordance with the job plan and general or corrective maintenance procedures that may be applicable to that parti~ular piece of equipment. Quality Control hold points for wotk steps within the package require documented inspection to ensure that work is performed correctly and in accordance with.specified instructions and procedures. Functional testing ensures that the repaired component will perform its intended funcUon.

General and corrective maintenan~e procedures have been dev~loped to provide specific wo~k instructions for the repair and rework of gen~ric and specific equipment and components. The .use of th~se procedures, fn conjunction with vendor documentation as specified in the job plan, allows

.the maint~nan.ce p~rsonn.e.l to per,f.orm.* repai.r/rew.ork . 9f .. equJpmer:it in a reliable,. safe and efficient manner to ensu~e proper functioning of the equipment. Thes.e . procedures .are* periodically re 1ewed for . accuracy. 1*.

  • Mo.reover, revts*fqns are :made. any time a. discrepancy 1s found to ensure that .

they are current. correct and workable documents.

4 -

I *~' ::, , , ,,, *"

  • 1* t , , r: :t , ,),* ,I :*, . ,.,:r:,.: *.; ,: :,*.:.

Plant maintenance personnel are trained to ensure that they possess and maintain the skill~ and understanding required to perform, certain tasks.

The training involves classroom a~ well as on th~ job training. A qualification matrix is also maintained to ensure that maintenance personnel are qualified to perform the particular job to which they are assigned. *

  • GSU has reviewed Plant System Operating Procedures, . Abnor)llal Operating Procedures, Alann Response Procedures, and Emergency Operating Procedures.

Valve lineups in System Operating Procedures assure adequate cooling using normal means. In case of abnormal conditions, Alarm Response Procedures and Abnormal Operating Procedures delineate operator actions to either restore normal cooling cir verify* that standby systems have actuated properly. Emergency Operating Procedures provide guidance for mitigating plant emergencies as indicated by plant symptoms; Operations review of the emergency procedures indicat~d there are no specified operator actions which will have an adverse impact on the cooling of safety-related equipment. GSU design cnntrol procedures require review of system modifications by Maintenance and Operations to ensure that procedure revisions or additional training requirements are identified. Also, NUREG 1275 was reviewed against applicable operating procedures with no deficiencies identified.

GSU has reviewed all of the training materials assriciated with the service water system. Through this review, it was determined that the existing training modules are adequate to ensure that operators will perform effectively and that they will recognize when safety-related equipment cooled by service water is functioning as intended. Existing training procedures require that procedure changes and modifications are reviewed for incorporation into existing training modules.. This requirement will ensure that all service water related training material remains current.

GSU will provide a final response to this letter 30 days after completion of refueling outage 3 which is scheduled to begin September 15, 1990. At that time all initial tests or activities described above will have been completed and all continuing programs will have been establi~hed, If you have any questions concerning this respon~u please contact Mr. L. L.

Dietrich at (504) 381-4866. *.,

,}1ierely, y#,r//du-?

J. C. Deddens

~enior Vice President

  • . River Bend Nuclear Group

- 5 -

c;c: U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, .Suite 1000

. Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 Mr. Walt Paulson U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

      • .*,,1, ,.* *,'.\.'./.-*.:; .*
    • t: ..
  • ~

UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION STA~E OF LOUISIANA )

PARISH OF WEST FELICIANA )

  • Docket No. S()-458
  • In the Matter of )

GULF STATES UTILITIES COMPANY )

(River Bend Station - Unit 1)

AFFIDAVIT J. c. Deddens, being duly sworn, states that he is a Senior Vice President of Gulf States Utilities Company: that he is authorized on the *part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

Subscribed and sworn to before me, a Notary Public in and for the State

  • and Parish above named, this c:J, /\J._, day of j ~ ' ] , 19.9..Q_
  • My Commission expires. with Life *.

Claudia F. Hurst N0tary Public in and for West Feliciana Parish, Louisiana

,,,;,,,.*J,,",;,,r* .. ,,

Text

, '

~. ' .

GULP STA'l'EJS U'l'l.£17'1.ES February 2, 1990 RBG-32249 File Nos. Gl.49.5, G9.5, 69.33.4 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

River Bend Station - Unit 1 Docket No. 50-458 NRC Generic Letter 89-13 This letter provides Gulf States Utilities Company's (GSU) initial response to Generic Letter 89-13, "Service Water System Problems Affecting. Safety-Related Equipment". This generic letter requested that licensees perform the actions specified below to ensure that their service water system is in compliance and will be maintained in compliance with applic~ble codes and criteria. This response is formatted according to the generic letter outline; in that each action item is stated followed by the GSU response.

I. For open-cycle service water systems, implement and maintain an ongoing program of surveillance and control techniques to significantly reduce the incidence of flow blockage problems as a result of biofouling.

As a facility with recognized potential for biofouling problems due to Corbicula sp., River Bend Station developed an Asiatic Clam Control Program (ACCP) which was implemented at the time of foitial . introduction of Mississippi River water to plant systems (November, 1985). The ACCP and revisions were approved by the.

NRC prior to implementation, as is required of any future changes~

  • The *ACCP incorporates* continuous, low-level .chlorination of

.nonnal. service water (NSW); monthly performance trending of safety-related heat exchangers supplied by NSW; sampling and/or inspection of each safety-related heat exchanger supplied by NSW at least *once per operating cycle; and biological monitoring. for . .

clams . *1n sourc.e wa*ter and pfarit {ysteins *. AlthouQ'h .. intended to specifically address Asiatic ~lams,**th.e ACCP provides for equally

.~ffective detection and . prevention* of macrofoul ing by other

  • .*potential agents ..

(e.g., ~ebra mussels)~

  • 9002150296 900~0~
  • 1 ,*
  • PDR . Ar)~V ~~=~-~~-

'"'C C,r, *1..1.:,1.11.104,_,:::::

  • )-'1.'
,* . P * *

..':*J.':',i.;:..{t*i*,*:-::,.:.. ,,:*...*:., ,,,,',, ,:* .. , **.';*

The fire protection system at River Bend Station* is s~pplied by well water, thus offering no potential for intrusion by macrofouling agents and no need fortreatmentwithbiocides. There is a remote possibility*for cross*

connection of service water with limited portions of the fire protection system, in which case the ACCP requires inspection of the affected sections and flushing with deminera,ized water to restore acceptable water quality.

Because of the ACCP requirement for continuous chlorination of* NSW, any \

service water cooling loop would automatically be filled with treated water when isolated for layup.

  • Inspections by divers of the outside of the makeup water intake screens can be* performed during normal operation at any time there is concern about possible blockage. Sediment accumulation in the immediate vicinity of the screens is monitored monthly by fathometry and complete surveys of the intake embayment are performed approximately annually as required and as limited hy river conditions.

Service water supply and return lines to the normally closed reactor ~lant component cooling water (CCP) and ventilation chilled water (HVN) systems are redundant and infrequently used cooling loops. Flow in these lines will be evaluated prior to startup from refueling outage 3 (RF-3) scheduled to begin September 15, 1990, by indirect methods (e.g., pressure drop calculations, partial flow tests) or by system flow testing.

II. Conduct a test program to verify the heat transfer capability of all safety-related heat exchangers ~ooled by service water. The total test program should consist of an initial test program and a periodic retest program. Both th~ initial test program and the periodic retest program should include heat exchang~r~ connected to or cooled by one or mor~ open-cycle systems.

GSU is developing a Heat Exchanger Performance Monitoring Test Program (PEP-046) prior to RF-3 which meets the recommended actions of this part of the generic letter. The following heat exchangers~will be tested per this program:

HEAT EXCHANGER SCHEDULE FOR INITIAL TEST Diesel/Generator Jacket Water Coolers RF-3 Control Building Chiller Condensers RF-3 Auxiliary Building Unit Coolers RF-3 RHR Heat Exchangers RF-3 PVLCS Compressor Aftercoolers RF-3 RHR Heat Exchangers Radiation Monitor Coolers RF-4 Periodic retesting rin a sampling basis will be performed at least one~ per fuel cycle with the frequency being evaluated after three tests to ensur~

that testing. is providing

  • assura.nces that* equipment is performing
  • its intended function, Portions of the following systems are considered safety-related:

closed..:cyc.le systems at River Bend:

Reactor Plant Component Cooling Water .. (CCP)*

Spent Fuel Pool Cooling and Cleanup (SFC)

. Turbine Building .Chilled Water (HVN) .

Control Building Chilled Water {HVK) . .

Diesel Ge~erator Jacket Cooling Water (EGT) 2 -

j' I.... ,!','
:, .. *'. '* ** ... ,**,. *.*.

Complete flushing and flow testing. of these nonnally closed loops is unnecessary, since plant chemistry records document acceptable water quality throughout most of the operating histo,ry. To further confirm this position, GSU will perform a one-time heat exchanger performance test on a contairiment ~nit cooler (cooled by HVN) and will clean the control building chiller evaporators (HVK) prior to startup from RF-3. £valuations of the results of this testing and cleaning wi.11 determine if further actions are required. These actions, combined with current improved water chemistry~

assure adequate closed cycle system performance.

  • III. Ensure, by establishing a routine inspection and maintenance

. program for open-cycle service water system piping and components; that corrosion, erosion, protective coating failure, silting, and biofouling cannot degrade the performance of the safety-related systems supplied by service water. The maintenance program should have at least thA following purposes:.

A. To remove excessive accumulations of biofouling agents, corrosion products, and silt; B. To repair defective protective coatings and corroded service water system piping and components that could adversely affect performance of their intended safety functions.

The ACCP described above includes requirements to inspect and take corrective action in the event of degradatfon of heat. exchanger performancP.

due to biofouling, corrosion products or silt.

Local leak rate testing, inservice inspections and* inservice testing of safety-related components as well as system surve1llance testing helps ensure that such components are capable of performing their intended function. Failures of such tests and inspections are i~vestigated and components are repaired. Noncestructive examinations of service water piping have been performed to establish baseline data. These examinations are repeated on a periodic basis to monitor specific piping sections for erosion/corrosion. Observations of the service water systems during daily rounds serve to identify leaks or other discrepancies. Any deficiencies identified would be investigated and reworked in accordance with existing site procedure5, GSU has developed inspection criteria and requirements which provide for scheduled inspections and specific instructions for maintenance of service water heat exchangers and unit coolers. The draft corrective maintenance procedure. which implements this program, is currently under review and will be in place prior to start up from RF-3.

IV. Confirm that the service water system will perform its intended.*

function in accordance with the licensing basis

  • for the plant.

This confirmation should*include a review of the ability to perform required safety functions in the event bf failure of a single active component. To ensure that the as-built system is in accordance with the appropriate licensing basis documentation,*

. this confirmation

  • sho1,1ld include recent system walkdown inspections.

G~lf States Utilities' confirmattci~ that the service water systefu, as defined in Generic

  • Letter 89-13, will be able to perform its function in

- 3 ...

  • .,.). ..

the event of the failure of a single active component will rely primarily on the analysis being performed for Generic Letter 88-20, Individual Plarit Examination (JPE) for Severe Accident Vulnerabilities. GSU s methodology j to perform the IPE is described in GSU's response to GL 88-20 dated October 27, 1989 (RBG-31692). The analysis performed for GL 89-13 will address those' service water systems, or portions thereof, that serve safety-related components and wfl 1 be performed in a manner consistent with that of the original design ba~is for those systems as described in the.USAR. This analysis will be completed prior to plant startup following RF-3. If any

  • single active failure is identified which could prevent the service water system from performing its intended function, evaluation of the potential safety impact will be performed as part of the IPE analysis in accordance with the IPE schedule as stat~d in RBG-31692.

To confirm the service water system licfmsing ~asis configuration and s,;*stem condition, GSU is performing a service water system walkdown to

. verify flow path and system status. This walkdown excludes pipe supports, electrical and electrical supports,* instrument supports and instrumentation. These portions of the service water system were verified at the end of the construction phase of River Bend Stationi and changes are tightly controlled by design control procedures. This walkdown will be completed prior to startup from RF-3.

V. Confirm that maintenance practices, operating and emergency procedures, and training that involves the. service water system are adequate to ensure that safety-related equipment cooled by the service water system will function as intended and that operators of this equipment will perform effectively. This confirmation should include recent reviews of practices, procedures, and training modules.

GSU has reviewed maintenance practices affecting the service water system.

Maintenance of*equipment at RBS is identified, controlled, and documented through the implementation of Maintenance Work Orders. The work package supplies job steps for perfonning the required work as well as identifying applicable procedures and plant documentation that sho~ld he adhered to during job performance. Material and spare parts needed to accomplish the task are identified and ASME Section XI repair/replacement plans are provided when required. MaintenancP. personnel perform the specified repairs or rework in accordance with the job plan and general or corrective maintenance procedures that may be applicable to that parti~ular piece of equipment. Quality Control hold points for wotk steps within the package require documented inspection to ensure that work is performed correctly and in accordance with.specified instructions and procedures. Functional testing ensures that the repaired component will perform its intended funcUon.

General and corrective maintenan~e procedures have been dev~loped to provide specific wo~k instructions for the repair and rework of gen~ric and specific equipment and components. The .use of th~se procedures, fn conjunction with vendor documentation as specified in the job plan, allows

.the maint~nan.ce p~rsonn.e.l to per,f.orm.* repai.r/rew.ork . 9f .. equJpmer:it in a reliable,. safe and efficient manner to ensu~e proper functioning of the equipment. Thes.e . procedures .are* periodically re 1ewed for . accuracy. 1*.

  • Mo.reover, revts*fqns are :made. any time a. discrepancy 1s found to ensure that .

they are current. correct and workable documents.

4 -

I *~' ::, , , ,,, *"

  • 1* t , , r: :t , ,),* ,I :*, . ,.,:r:,.: *.; ,: :,*.:.

Plant maintenance personnel are trained to ensure that they possess and maintain the skill~ and understanding required to perform, certain tasks.

The training involves classroom a~ well as on th~ job training. A qualification matrix is also maintained to ensure that maintenance personnel are qualified to perform the particular job to which they are assigned. *

  • GSU has reviewed Plant System Operating Procedures, . Abnor)llal Operating Procedures, Alann Response Procedures, and Emergency Operating Procedures.

Valve lineups in System Operating Procedures assure adequate cooling using normal means. In case of abnormal conditions, Alarm Response Procedures and Abnormal Operating Procedures delineate operator actions to either restore normal cooling cir verify* that standby systems have actuated properly. Emergency Operating Procedures provide guidance for mitigating plant emergencies as indicated by plant symptoms; Operations review of the emergency procedures indicat~d there are no specified operator actions which will have an adverse impact on the cooling of safety-related equipment. GSU design cnntrol procedures require review of system modifications by Maintenance and Operations to ensure that procedure revisions or additional training requirements are identified. Also, NUREG 1275 was reviewed against applicable operating procedures with no deficiencies identified.

GSU has reviewed all of the training materials assriciated with the service water system. Through this review, it was determined that the existing training modules are adequate to ensure that operators will perform effectively and that they will recognize when safety-related equipment cooled by service water is functioning as intended. Existing training procedures require that procedure changes and modifications are reviewed for incorporation into existing training modules.. This requirement will ensure that all service water related training material remains current.

GSU will provide a final response to this letter 30 days after completion of refueling outage 3 which is scheduled to begin September 15, 1990. At that time all initial tests or activities described above will have been completed and all continuing programs will have been establi~hed, If you have any questions concerning this respon~u please contact Mr. L. L.

Dietrich at (504) 381-4866. *.,

,}1ierely, y#,r//du-?

J. C. Deddens

~enior Vice President

  • . River Bend Nuclear Group

- 5 -

c;c: U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, .Suite 1000

. Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 Mr. Walt Paulson U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

      • .*,,1, ,.* *,'.\.'./.-*.:; .*
    • t: ..
  • ~

UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION STA~E OF LOUISIANA )

PARISH OF WEST FELICIANA )

  • Docket No. S()-458
  • In the Matter of )

GULF STATES UTILITIES COMPANY )

(River Bend Station - Unit 1)

AFFIDAVIT J. c. Deddens, being duly sworn, states that he is a Senior Vice President of Gulf States Utilities Company: that he is authorized on the *part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

Subscribed and sworn to before me, a Notary Public in and for the State

  • and Parish above named, this c:J, /\J._, day of j ~ ' ] , 19.9..Q_
  • My Commission expires. with Life *.

Claudia F. Hurst N0tary Public in and for West Feliciana Parish, Louisiana

,,,;,,,.*J,,",;,,r* .. ,,