RBG-46213, Reply to a Notice of Violation in Inspection Report 05000458/02-07, River Bend Station, Unit 1
| ML040340418 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/28/2004 |
| From: | King R Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IR-02-007, RBF1-04-0009, RBG-46213 | |
| Download: ML040340418 (6) | |
Text
Entergy Operations, Inc.
~E n y tergy River Bend Station 5485 U. S. Highway 61N St. Francisville. LA 70775 Fax 225 635 5068 January 28, 2004 U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, D.C. 20555
Subject:
Reply to a Notice of Violation in Inspection Report 50-458/02-07 River Bend Station - Unit 1 License No. NPF47 Docket No. 50-458 File Nos.: G9.5, G15.4.1 RBG - 46213 RBF1-04-0009 Ladies and Gentlemen:
Pursuant to the provisions of IOCFR2.201, Attachment 1 provides Entergy Operations Incorporated's (EOI) River Bend Station response to the Notice of Violation 50458/0207-01.
Commitments contained in this document are identified on Attachment 2.
Entergy Operations Incorporated does not contest the violation or the significance as determined by the Nuclear Regulatory Commission (NRC). However, we intend to pursue clarification of the methodology to be used in the future by industry and NRC to evaluate the impact of external events on findings identified in the Significance Determination Process (SDP). Specifically, Entergy desires that NRC provide a more prescribed and scrutable means to utilize Individual Plant Examination of External Events (IPEEE) results to support risk determinations within the SDP. To this end, Entergy will be working with industry and NRC to pursue this issue.
Should you have any questions regarding the attached information, please contact me at (225) 336-6225.
Sincerely, Rick J. King Director-Nuclear Safety Assurance RJK/RLB attachments
Reply to Notice of Violation in 50-458/0207-01 January 28, 2004 RBG- 46213 RBFI-04-0009 Page 2 of 2 cc: Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Sr. Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 Mr. Michael K. Webb U. S. Nuclear Regulatory Commission M/S OWFN 0-7 DI 11555 Rockville Pike Rockville, MD 20852-2738 Director, Office of Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
ATTACHMENT I REPLY TO NOTICE OF VIOLATION 50-458/0207-01 Page 1 of3 Violation Technical Specification 5.4.1 .a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A4, "Procedures for Startup, Operation, and Shutdown of Safety-Related BWR Systems," Item n., lists "Condensate System (hotwell to feedwater pumps, including demineralizers and resin regeneration)."
System Operating Procedures SOP-0007, "Condensate System," Revision 21, required Condensate Pre-filter Vessel Bypass Flow Control Valve CNM-FCV200 to be locked open.
Contrary to the above, on September 18, 2002, Valve CNM-FCV200 failed closed as a result of not having been properly locked open, as required by System Operating Procedures SOP-0007, "Condensate System." As a result, the feedwater flow transient resulting from a reactor scram on September 18, 2002, caused Valve CNM-FCV200 to close unexpectedly, causing a complete loss of feedwater flow to the reactor pressure vessel.
Reason for the Violation Following installation of a plant modification, condensate full flow filtration bypass valve, Flow Control Valve 200 (CNM-FCV200) was improperly locked open without the hand wheel being properly engaged. Subsequently, an Automatic Reactor Scram occurred on September 18, 2002 due to high neutron flux in response to an increase in reactor pressure. This increase in reactor pressure was the result of a main turbine electro-hydraulic control system transient.
Main Feedwater and Condensate system flow changes in response to the scram caused the improperly locked open CNM-FCV200 valve to close. Closure of CNM-FCV200 isolated the condensate supply to the feedwater pump suctions.
The feedwater pumps tripped on low suction pressure.
ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-458/0207-01 Page 2 of 3 Root Cause RBS failed to properly lock open Condensate Full Flow Bypass Valve CNM-FCV200 following installation subsequent to a plant modification. This cause of the violation was further divided into two cause categories as follows:
- 1. River Bend Station did not ensure responsible individuals had sufficient knowledge to enable them to position, lock and control CNM-FCV200 correctly.
- 2. Some station personnel were aware that valve CNM-FCV200 was different than what operations personnel were accustomed to and that training and additional procedure detail may be needed. These needs were not adequately followed-up in a timely manner.
Corrective Actions Taken The following corrective actions were developed to address the flow control valve issue:
- The flow control valve, CNM-FCV200, was placed in the open position using the hand wheel. The hand wheel was engaged and both the hand wheel and engaging lever were chained to prevent operation.
- Using ADM-0076 (Verification Program), Operations provided coaching and reinforcement regarding valve positioning to qualified personnel.
- The Training Department trained the Operators on handwheel operation of valve CNM-FCV200.
- Operations Training provided lessons learned and Operating Experience on this event to Operations personnel to address failure to follow through on identified problems and reinforced expectations for positioning new valves.
- The Training Department provided training for engineers to review Operating Experience and to reinforce engineering expectations for ownership and follow through.
ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-458/0207-01 Page 3 of 3 Corrective Actions to Prevent Recurrence Additional corrective actions were developed to prevent recurrence. These corrective actions include:
- The Design Engineering staff revised the modification process to clearly specify the need for distinct evaluations for each phase of modification implementation and to expand requirements for operational considerations to include evaluation of new equipment/components to identify differences from existing equipment/components.
- Engineering revised the engineering desk guide to ensure consideration of contingencies for modifications that result in late arrival of equipment/components and associated technical information (drawings, vendor manuals). The contingencies addressed the means for ensuring appropriate training and procedure changes are performed in a timely manner for modification installation/turnover to Operations.
- The Training Department established a Training Department Review Guideline to aid in determination of training needs. This guidance also emphasizes the need for a review of the operational aspects and man/machine interface of new systems/
components vs. generic features to ensure training needs are adequately addressed.
Date Compliance was Achieved Compliance was achieved upon restoration of the Flow Control Valve to the correct position on September 19, 2002.
ATTACHMENT 2 COMMITMENT IDENTIFICATION FORM Page 1 of 1 Violation 50-458/0207-01 COMMITMENT ONE-TIME CONTINUING ACTION COMPLIANCE Revised modification process to clearly specify the X need for distinct evaluations for each phase of modification implementation. (Complete)
Revised modification process to expand requirements X for operational considerations to include evaluation of new equipment/components to identify differences from existing equipment/components. (Complete)
Revised Engineering Request Database (ERD) X Operations impact screening questions to consider differences in new equipment/component from existing plant equipment/components. (Complete)
Trained Operators on operation of valve CNM- X FCV200. (Complete)
Provided lessons learned on this event to Operations X Personnel to address to reinforce expectations for positioning new valves or components. (Complete)
Provided training for engineers on this CR and X reinforced engineering expectations for ownership and follow through. (Complete)