View source for RBG-30552, Responds to NRC Ltr Re Violations Noted in Insp Rept 50-458/88-26.Corrective Actions Taken:Condition Repts Will Continue to Be Utilized & Mgt Will Ensure That Events Re Tech Spec 6.12.2 Reported Under 10CFR50.73 Requirements

{{Adams
| number = ML20245A533
| issue date = 04/17/1989
| title = Responds to NRC Ltr Re Violations Noted in Insp Rept 50-458/88-26.Corrective Actions Taken:Condition Repts Will Continue to Be Utilized & Mgt Will Ensure That Events Re Tech Spec 6.12.2 Reported Under 10CFR50.73 Requirements
| author name = Deddens J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000458
| license number = 
| contact person = 
| case reference number = RTR-NUREG-1022
| document report number = RBG-30552, NUDOCS 8904250256
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 8
}}

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     . q GULF ' STATES                           UTILITIES                         COMPANY RIVER tlEND STATION     POST OFFICE BOX 220    ST. I RANCISVILLE, LOUISIANA 70775 AREA CODE SO4     636 0094       346-8651-April 17, 1989 RBG-30552 File Nos. G9.5, G15.4.1 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
River Bend Station - Unit 1 Refer to: Region IV                                                        ,,
Docket No. 50-458/Rerart 88-26 Pursuant       to       10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response'to the Notice of Violation for NRC Inspection Report No. 50-458/88-26.                                      The inspection was performed by Messrs. E. J. Ford and W. B. Jones during the period of December 1             -    31, 1988 of activities authorized by NRC Operating Licensing NPF-47 for River Bend Station                                           -
Upit 1.
GSU's response to the violations are provided in the attachments.
This completes GSU's response to these items.
Should you have any questions, please contact Mr. L.                                        A. England' at (504) 381-4145.
S ncerely lA                  v
                                                                                                             / lC. Deddens Senior Vice President River Bend Nuclear Group JEB/LAE/RJK/JWC/ch I
cc:    U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 l                                                                Arlington, TX 76011 NRC Senior Resident Inspector P. O. Box 1051 St. Francisville, LA 70775 h4MOjcnosooo4gg 56 890437                                                                                               \
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA                                                            )
j,                                    PARISH OF WEST FELICIANA                                                      )
In the Matter of                                                             )               Docket No. 50-458 "
50-459 l                                     GULF STATES UTILITIES COMPANY                                                 )
l                                              (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.
J/          w J.#C. Deddens Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /7Ybdayof dd Q V O h                               , 19 /N.
f        G      -
Middlebrooks bg- J
                                                                                                         /J West an otaryW. Public in and for Feliciana Parish, Louisiana My Commission is for Life.

ATTACIMENT.1.
                      .                                                                      Response to Notice of Violation 50-458/8826-01 Level IV Violation

==REFERENCE:==
: 1.                                     Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated March 17, 1989..
: 2.                                      Licensee Event Report No. 88-027 - to NRC from J. E. Booker, dated January 18, 1989 FAILURE TO ENSURE RCIC SYSTEM OPERABILITY:
RBS Technical                                            Specifications (TS) Limiting Condition for Operation (LCO) 3.4.7.3 requires that the reactor core isolation cooling (RCIC) _ system be operable in Operational Conditions 1, 2, and 3 with reactor steam dome pressure greater than 150 psig.
Contrary to the above, RBS was operated in Operational Conditions 1, 2, and 3 during the period November 1985 to December 19, 1988, with the RCIC system inoperable. The RCIC system was considered inoperable because the turbine configuration. was not in accordance with the seismically tested design configuration.
REASON FOR VIOLATION:
During a review by the Design Engineering group to prioritize outstanding modification packages it was noted that the installation of the RCIC system
                             ' turbine was not completed per design.                                                 Contrary to its seismic qualification requirements, an oil piping support addition had not been' completed, the coupling pedestal bolting had not been lockwired, and the pedestal dowel                                            pins were not in place.
Investigation of historical documents shows that the portion of the original modification to install the lock wire and dowel pins was completed. However, in a subsequent realignment of the turbine, the dowel pins would no longer fit. A new modification using new dowel pin locations was initiated to complete the original modification.                                           This MR was found not to be worked.
The                                              scope  of the management effort to reduce the backlog level of unprioritized MRs was established in response to two primary actions:
(1) corrective action to NRC Inspection Report 88-01, to review all MRs generated as a result of corrective actions identified on condition reports and provide recommendations for prioritization (schedule) by 12/31/88, and (2) a commitment to the Institute of Nuclear Power Operations (INP0) to have the l                                   backlog of unprioritized MRs reduced to a manageable level by the end of 1988.
The subject MR was not initiated as a result of the condition report program; it was a construction modification which was included in the balance of the reduction effort.                                            All modifications as a result of condition           report corrective                                            acticns nave been reviewed and prioritized.         Less than 75 modification requats remain in the balance of the program. These 75 MRs have been screened by Drsign Engineering and none have been determined to have an impact on operability.
Page 1 of 3

The root cause of this event appears to have been an oversight in identifying the , operability impact of not performing this modification. Due to the large
          ,       backlog of incomplete construction modifications that existed at the time, the potential significance of this MR did not surface quickly.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
The RCIC system was declared inoperable at 1700 on December 19, 1988. A condition report was written and the proper installation was completed on December 24, 1988. After satisfactory retest, the RCIC system was restored to
               . operable status at 1245 on December 24, 1988.
As identified above, the inadequate installation was initially identified as a direct result of an internal audit of incomplete construction modifications.
All open MRs which have not been prioritized have been screened by. Design Engineering and none have been determined to have an impact on operability.
The identification of this deficiency and subsequent corrective action is indicative of GSU's improvement in the MR document control and administrative control areas. This review also confirmed that the operability oversight for incomplete construction modifications which had been tracked on system punch lists was isolated.
t An assessment of the safety implications have shown the effects of the incomplete construction modification to be minimal. The RCIC system provides redundancy to-the high pressure core spray system (HPCS) for long term core cooling following a postulated control rod drop accident (CRDA). The RCIC system is not required to function in this emergency safety feature (ESF) capacity since the RBS design includes an automatic depressurization system (ADS). ADS provides the required redundancy to HPCS.
No operability or functional problems related to this incomplete modification have been identified. Operation of the RCIC turbine and pump for quarterly surveillance test procedures, both before and after completion of the modification,     has been acceptable.           Additionally, the RCIC system has experienced two automatic initiations and in each case the RCIC system performed as designed.             Therefore, the operability of the RCIC system under normal plant conditions without a seismic event is not questionable.
Seismic qualification tests were conducted on the prototype test turbine at much higher accelerations than those assumed for RBS for either an operating basis earthquake (0BE) or safe shutdown earthquake (SSE). Also, part of these tests was conducted with smaller dowel pins and without bolt locking and oil piping supports. The satisfactory performance of the prototype test turbine in this configuration indicates that the RBS installation would not have failed in an OBE or SSE. The probability of simultaneous occurrence of a seismic event and a CRDA with off-site power unavailable and HPCS inoperable is approximately 10(-7) per reactor year.
The RCIC system has demonstrated its ability to perform under normal plant conditions without a seismic event. Additionally, an evaluation comparing the as-found installation with the original seismic qualification tests indicates that the RCIC system would not have failed during a seismic event. Therefore, the safe operation of the plant and the health and safety of the public were not adversely affected as a result of this event.             (For additional details of assessment of safety implications, refer to Reference 2.)
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                               . . CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
                                           . A co'mprehensive review of the configuration management program - at- RBS has shown that it is now thorough and effective. - The current process for review
                                                .and'. prioritizing. MRs is designed to                      assure                                         that plant operability considerations are factored into the final schedule decisions and that the MRs
                                                  .are prioritizod for-implementation accordingly.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:.
RBS is currently. in full compliance.
1 Page 3 of 3

ATTACMENT 2
                     ~
Response to Notice of Violation 50-458/8826-02.
Level IV Violation

==REFERENCE:==

Notice of Violation - Letter from R. D. Martin. to to          J. C. Deddens, dated March 17, 1989.
FAILURE.TO SECURE A VHRA ACCESS D0OR:
RBS TS 6,12.2 requires that accessible areas with radiation levels, such that a major portion of the body could receive in 1 hour a dose greater .than 1000 mrem, shall be provided with locked doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the control operating foreman (C0F) on duty and/or the radiation protection supervisor.
Doors shall remain locked, except during periods of access under an approved radiation work procedure (RWP) that specifies the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in
              ' that area.
Radiation Protection Procedure'RPP-0005, " Posting of Radiologically Controlled Areas," Revision 5, paragraph 7.4, requires that very high radiation area (VHRA) entrances be locked and remain locked, except during periods of access under an approved RWP. Doors must be locked or attended at all times.
Contrary to the above, on December 3, 1988, from approximately 7:45 a.m. to 4:30 p.m. (CST), turbine building door TB 123-20, which provided access to a VHRA around the moisture separator reheater tank, was not properly secured.
TB 123-20 was not attended during the period the door was left unsecured.
Seven additional examples of events where VHRA access doors were previously left unsecured are identified in NRC Inspection Report 50-458/88-26.
REASON FOR VIOLATION:
During normal full power operations, fifty-six (56) doors must be controlled as VHRAs. Locks for all VHRA doors may be opened by one of a limited number of identical        keys. The Shift Supervisor and the C0F are issued a key for emergencies only, and radiation protection (RP) personnel maintain control of seven keys for their use. The key checkout method only identified who checked out these keys -- not which doors were opened. However, persons checking out these keys were required to read a statement of their responsibilities with the use of VHRA keys which includes ensuring that the door must be left locked and secured upon exit.
Investigation was inconclusive as to who failed to ensure that these doors were secured upon exiting. The root causes of this problem are the failure on the part of the individual          to verify that the doors were secured and ineffective controls to prevent recurrence.
Page 1 of 2 i

                   ~
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
                     , All 'VHRA doors were locked upon discovery.
Numerous programmatic controls and corrective actions have been implemented since initial    plant operation to ensure that these doors are secured upon exit. Increasingly stringent controls failed to produce the desired result.
On December 7,   1988, the Plant Manager issued memorandum TFP-251-88 to supervisors    emphasizing   the    serious nature regarding VHRA doors and establishing more stringent administrative guidelines for routine access to VHRAs. On December 9, 1988, procedure RPP-005, " Posting Radiologically Controlled Areas", was revised by TCN 88-0782 to incorporate the Plant Manager's guidelines. The charges that were implemented require that 1) only radiation protectio., personnel vill be issued keys to VHRA doors for routine access, 2) RP personnel will los the opening and locking of VHRA doors and is responsible for verification of lo ked doors, 3) for those entries without constant RP coverage, a double verification is required upon exit to assure that the door is locked, 4) RP personnel will daily physically check and verify that all VHRA doors are locked and 5) an operability verification of accessible VHRA' doors will be performed monthly.
In addition to the above, Security also physically verifies twice daily that accessible VHRA doors are locked.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No VHRA doors have been discovered unsecured and unattended since the implementation of the present program.
The improved, more stringent administrative controls established for routine access to VHRA should prevent any future violations.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
RBS is currently in full compliance.
Page 2 of 2

w
_ g, ATTACMENT' 3 Response to Notice of Violation 50-458/8826 Level IV Violation

==REFERENCE:==

Notice .of Violation - Letter from R. D. Martin to to J. C. Deddens, dated March 17, 1989.
VIOLATION C:
10CFR 50.73 requires licensees to. submit licensee event reports (LERs) to NRC within 30 days of the discovery of. events which are described in this regulation. Among the events ' licensees are required to report is "Any operation or condition prohibited by the plant's _ Technical Specifications ..."
RBS TS 6.12.2,     "High Radiation Area," states that, " areas with radiation levels such that a major portion of the body could receive in 1 hour a dose greater than 1000 mrem shall be provided with locked doors ..." and that the,
                                   " doors shall remain locked except during periods of access under an approved RWP ..."
Contrary to the above, on at least seven occasions between June 1987 and December 1988, doors to VHRAs were found unlocked, a condition prohibited by the plant's TS, and LERs were not submitted to NRC within 30 days of the discovery of these events.
REASON FOR THE VIOLATION:
GSU has previously interpreted NUREG-1022, " Licensee Event Reporting System",
such that violation of this administrative section of the TSs need not be reported since the condition does not affect plant operation.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
Condition reports will continue to be utilized to identify these events, and
                                                                                       ~
RP management will now ensure that events related to TS section 6.12.2 are reported under 10 CFR 50.73 requirements.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
A copy of this violation including the response will       be routed to Shift Supervisors, Radiation Protection, licensing, QA, ISEG, and Compliance group supervisors to inform these individuals of the reporting            requirements regarding discovery of unlocked VHRA doors.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The appropriate RBS supervisors as identified above will be informed by May l                                  15, 1989 of the deportability of these events.
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