IR 05000458/1989018: Difference between revisions

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{{Adams
{{Adams
| number = ML20247E750
| number = ML20247H332
| issue date = 07/21/1989
| issue date = 09/11/1989
| title = Discusses Insp Rept 50-458/89-18 on 890501-05 & 15-19 & Forwards Notice of Violation
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/89-18
| author name = Martin R
| author name = Milhoan J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Deddens J
| addressee name = Deddens J
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = EA-89-122, NUDOCS 8907260303
| document report number = NUDOCS 8909190296
| package number = ML20247E757
| title reference date = 08-21-1989
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 4
| page count = 2
}}
}}


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c[ %g UNITEo STATES
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   .f 611 RYAN PLAZA ORIVE. SU'TE 1000
~    SEP ! l~ 1989
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In Reply Refer To:
b , Docket: 50-458/89-18 9  .,,
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Gulf States Utilities
 
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  ~ ATTN: Mr. James C. Deddens SeniorVicePresident(RBNG)
  , P.O. Box 220 St.,Francisville, Louisiana 70775 Gentlemen:
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Thank you for your letter of August 21, 1989, in response to our letter and Notice of Violation dated July 21, 1989. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine
 
Sincerely, Original Soned By:
Thomas P. Gwynn
    ' James L. M11hoan, Director Division of Reactor Projects o  cc:
Gulf States Utilities ATTN: J. E. Booker, Manager-
  .
River Bend Oversight P.O. Box 2951 7  Beaumont, Texas 77704 Gulf States Utilities
#
ATTN: Les England, Director -
Nuclear Licensing - RBNG e ~ P.O. Box'220:
  ,J8 . St. Francisv111e, Louisiana 70775
  . ~ o Louisiana State University, Government Documents Department  7 f r$$
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ARLINGTON, TEXAS 76011  ,
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Gulf. States Utilities
Docket No. 50-458 License No. NPF-47      {
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EA 89-122 Gulf States Utilities ATTN: Mr. James C. Deddens SeniorVicePresident(RBNG)
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Post Office Box 220 St. Francisville, Louisiana 70775    i Gentlemen:
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SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT N0. 50-458/89-18)
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This is in reference to the NRC inspection conducted during the period May 1-5 and May 15-19, 1989, at the River Bend Station (RBS), located in St. Francisville, and to NRC's~ discussion of the inspection findings with Gulf States Louisiana,(GSU) officials at an enforcement conference in Arlington, Texas, on Utilities June 9, 198 As you know, NRC's concerns stenning from this inspection focused on the failure to establish a test program which would have assured the operability of the safety-related ventilation systems associated with the fuel building and the main control room. The results of the inspection were documented in NRC
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' Inspection Repcrt No. 89-18, dated June 6,198 During the June 9 enforcement conference, two apparent violations resulting from this inspection were discussed. The violation in the enclosed Notice of Violation (Notice) involves an apparent failure to assure, through the establishment of a test program, the operability of two independent fuel building ventilation subsystems and two subsystems associated with the main stem in accordance with the requirements of control room airSpecifications plant Technical conditioning sy(T.S.) 3.6.5.6 and 3.7.2. As a result of River Bend Station's self-initiated Safety System Functional Inspection (SSFI) of the Instrument Air System (IAS) and SSFI followup actions, GSU discovered design and installation flaws that would have prevented these required subsystems from performing their intended function under certain condition NRC has concluded that GSU's failure to have developed an adequate test program resulted in a significant violation of RBS's T.S. in that GSU failed to assure operability of fuel building ventilation and main control room air conditioning subsystems. These subsystems are important for ensuring the maintenance of a negative pressure within the fuel building and limiting any release of radio-activity within 10 CFR Part 100 limits following a design basis or fuel handling accident, and ensuring that the control room will remain habitable for operations personnel during and following all design basis accident ADOCK 05000458 (Q l PDR Q  PDC  g I
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August 21, 1989 RBG- 31384 File Nos. G9.5, G15. ~ . .
        . ;.. ;_
U. S. Nuclear Regulatory Commission    S [$ !; L _
Document Control Desk    o Washington, D.C. 20555    i
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gggg4jggg Gentlemen:    , Ih River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/89-18
  - Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation for NRC Inspection Report No. 50-458/89-18. The inspection was performed by Messrs. C. Stewart, L. E. Ellershaw and W. B. Jones during the periods of Mt .t 1-5 and 15-19, 1989 of activities authorized by NRC Operating License NPF-47 for River Bend Station -
Unit GSU's response to the violation is provided in Attachment 1. GSU's response to the concerns addressed in the body of the letter is provided in Attachment GSU's response to the rotice of violation is complet Should you have any questions, please contact Mr. L. A. England at (504) 381-414
 
Sincerely,
, p J. E. Booker Manager-River Bend Oversight River Bend Nuclear Group JEB/LAE/RJK/MSF/RGW/AJK/ch Attachments cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Senior Resident Inspector P.O. Box 1051 St. Francisville, LA 70775
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     -2-  DOL 211989 Gulf States Utilities Had GSU established an adequate testing and surveillance program to evaluate IAS design and operation, it would have been determined that the subsystem associated with the fuel building ventilation was inoperable from initial fuel load in August 1985 and that the subsystem associated with the main control room air conditioning was inoperable for an indeterminate tim Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment," alerted licensees to potential IAS problems and required a response verifying that IAS quality, functional characteristics, and design were 1 as intended. A response was required by February 8, 1989, or if operations were affected, the next refueling or scheduled outage in order to avoid adverse j system interactions. GSU determined through a self-initiated SSFI conducted during the period November 17 to December 21, 1988, and through SSFI followup actions that solenoid operated valves, check valves, and accumulator tanks would not function as designed for the subsystems associated with the main control room air conditioning and fuel building ventilation systems. These conditions were corrected promptly upon discover The NRC has classified the violation in the enclosed Notice at Severity Level III in accordance with Supplement I of the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy), as published in the Federal Register on October 13, 1988. While the NRC could consider imposing a monetary civil penalty for a Severity Level III violation, I have determined in this case after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards and Operations Support, that no penalty will be assesse I base this decision on discretionary provisions in Section V.G. of the Enforcement Policy. The NRC encourages and supports licensee efforts for self-initiated identification and correction of problems and intends on applying enforcement discretion in cases such as this one in which the problems were identified by a GSU self-initiated SSFI and were promptly corrected. However, the NRC is concerned that upon discovery GSU did not consider the deportability j
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of the problems. Prompt evaluation fnr deportability and timely reporting are significant issues. Had the problems discovered not been of a highly technical nature, requiring extensive evaluation and review before determining a possible operability problem existed, your failure to promptly repot c them could have resulted in additional enforcement action being take You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA      )
PARISH OF WEST FELICIANA     )
Docket No. 50--458 In the Matter of      )
                  '
GULF STATES UTILITIES COMPANY      )
  (River Bend Station - Unit 1)
AFFIDAVIT
, E. Booker, being duly  sworn,    states that he is Manager-River Bend  Oversight for Gulf         States Utilities Company; that he is  authorized on the part of said company to l
sign and file with  the Nuclear Regulatory Commission the documents attached  hereto; that he has read all of the statements contained  in such documents attached thereto and i  made a part thereof;  and that all such statements made and j'  matters set forth therein are true and correct to the best          of his knowledge, information and belief.
 
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      [J . Booker Subscribed  and sworn to before me, a Notary Public in and for the State and Parish above named, this          J/ day of h>l d , .< 6(  , 1929 . My Commission expires with Lif [
0}Clu dALS NtAME Notary Public in and for West Feliciana Parish, Louisiana
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ATTACMENT 1 RESPONSE TO NOTICE OF VIOLATION 50-458/8918-01 LEVEL III
- REFERENCES-Inspection _ Report 89-18 - Letter from J. L. Milhoan to J. Deddens, dated June 6, 198 Meeting Summary of Enforcement Conference held June 6, 1989 - Letter from L. Milhoan to J. C. Deddens, dated June 22, 198 Notice of Violation - Letter from J. D. Martin to J. C. Deddens, dated July 21, 198 FAILURE TO ESTABLISH A TEST PROGRAM Criterion VI of Appendix B to 10CFR50 requires, in part, that a test program shall be established to assure that all testing required to demonstrate .that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design document Contrary to the above, in November 1988 it was identified that Gulf $tates Utilities (G5U) had failed to establish a test program at River Bend Station to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performe Specifically, GSU failed to establish a test program    to demor. strate that two independent fuel building ventilation charcoal filtration subsystems and two independent main control room air handling unit / filter train subsystems would perform satisfactorily in service. As a result, GSU failed to discover design and installation flaws that would. have prevented these subsystems from operating as intended under certain design condition REASON FOR THE VIOLATION Gulf States Utilities Company's (GSU) performed a detailed review to determine the cause 01 the subject violation. During the start-up test program each system or subsystem was considered to be a separate entit This cause was determined to be GSU's failure to adequately test the interface between the instrument air and HVAC systems which is considered to be an isolated inciden GSU considered interconnected instrument ' air systems operable based on each system or subsystem test and did not realize the need for simultaneous testin The control building and auxiliary building heating, venting and air conditioning (HVAC) systems were released for start-up testing prior to the release of the instrument air system. The need for pressure decay testing of the auxiliary, control atid fuel building's instrument air accumulators was Page 1 of 4 L  . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
 
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actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
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not recognized during initial plant start-up. The ASKE Section XI valve testing program was thought to provide an adequate indication of system operabilit Neither Technical Specifications nor the ASME XI code requires simultaneous interacting system performance start-up testing. GSU did not interpret Criteria XI of Appendix B to 10CFR Part 50 to require testing of interacting systtms in addition to performance testing of structures, systems and component The initial design was inadequate and testing of the instrument air system would have discovered the problem as GSU discovered in subsequent testin However, the RBS current design modification process requires functional tests such that operability of a system can be assured prior to its return to servic GSU initiated a self assessment of the River Bend Station instrument air system by performing a Safety System Functional Inspection (SSFI) during the fall of 1988. During the inspection a question was raised on the instrument air system accumulator supply capacity for post-accident condition Subseque.a testing was performed during refueling outage 2 which showed that the accumulator air supply was not sufficient for the areas identifie Further investigation identified that solenoid valves had been installed in reverse which did not allow the valves to seal in the correct positio RBS submitted Licensee Event Report (LER) No. 89-022. Other aspects relating to the instrument air system were addressed in the LER and GSU's response to Generic Letter 88-14. GSU's response to the notice of violation will  focus on the area of testin CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Design Engineering conducted a review of loads which are dependent upon the safety-related headers within the control, auxiliary, and fuel buildings. This study consisted of a review of the two safety related headers within each of these three buildings. As a result of this study: The control building chilled water pressure differential control valves were modified as described in Section C.I.a belo . Five nonsafety-related loads have been removed from the two instrument air headers within the control buildin . Two standby gas treatment and two auxiliary building HVAC outlet air operated dampers within the auxiliary building will be modifie The first design verification testing included the testing of one of the two instrument air headers within the control building to verify that each header would stay pressurized for the calculated two days upc1 loss of the instrument air compressor The results of the first control building header pressure retertion test revealed the volume of the associated accumulator to be significantly undersized and the following design changes and repairs were then implemented:
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  ~ Control Building: The major instrument air users, the control building chilled water pressure differential control valves, were modified to remain mechanically secured in a throttled position instead of remaining as air operated control valves, The pressure retention time of each of the two safety-related headers was increased through the 180 degree realignment of the inlet header solenoid operated valves (50V) to an orientation which seated the valves in the correct position to keep air in
Gulf States Utilities  -3-       JUL 211989 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The response directed by this letter and the enclosed Hotice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51 Sincerel.y,       !
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the accumulato , The inlet check valve of each of the two safety-related headers received seat relapping and spring change-ou . Auxiliary Building: The pressure retention time of each of the two safety-related headers was increased through the 180 degree realignment of the inlet header S0Vs to an orientation which seated the valves in the correct position to keep air in the accumulato . Fuel Building: The pressure retention time of each of the two safety-related headers was increased through the 180 degree realignment of the inlet header 50Vs to an orientation which seated the valves in the correct position to keep air in the accumulato The damper fail positions of four dampers were changed to " fail open" from " fail closed", thereby resulting in instrument air not being required within the fuel building to mitigate the release of radioactivity after an acciden D. The final design verification testing included the testing of the two safety related headers of the control building and the two safety related headers of the auxiliary building to verify that each header remained pressurized to assure the respective HVAC systems would perform their design basis functions following an acciden . Control Building: Each of the two safety related accumulators, along with its associated header, was tested for pressure retention time upon the failure of the instrument air compressor Each safety related header was found to remain pressurized for an adequate time period to assure the control building atmosphere would remain habitable after an accident only when an auxiliary compressed air source is also connected to each heade Page 3 of 4
    '(. bb e ^G l q<}$      3 Robert D. Martin Regional Administrator Enclosure: Notice of Violation cc:
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Louisiana Radiation Control Program Director        >
NRC Public Document Room Local Public Document Room l
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~ '' Auxiliary Building: Ecch of the two safety related accumulators, alcng with its  i associated header, were tested for pressure retention time upon the failure of the instrument air compressors. Each header was found to remain pressur4 zed for an adequate time period to assure the auxiliary, containment, and drywell building HVAC systems would perform their design basis functions following an accident only when an auxiliary compressed air source is connected to each heade The control bailding and auxiliary building safety related accumulator pressure retention times were then increased through the following design modifications: Control Building:
Each of the two accumulators' capacities van ir.creas?d through the installation of two banks of high pre:sure air bottles at each accumulator inle . Auxiliary Building:
Each of the two accumulators' capacities was increased through the installation of two banks of high pressure air bottles at each accumulator inlet. These bottles are subject to removal upon the installation of the backdraft damper CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A-. The two standby gas treatment and two auxiliary butiding HVAC outlet air operated dampers wili be replaced by self-actuating back draft dampers thereby eliminating the need for safety related instrument ai Field Engineering is establishing a control building safety-related accumulator air retention test to be performed every refueling outag C.. In addition, GSU will review the testing methods, the bases for ASME categorization and the leak rate criterion for check valve DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The River Bend Station instrument air system is currently in full complianc The current system configuration is adequate and the follcwing are enhancements to increase system performance and reliabilit The back draft dampers will be installed in the standby gas treatment and HVAC system prior to start-up fcllowing the third refueling outag The control building accumulator air retention test procedure will be developed by November 15, 198 The review of testing methods, the bases for ASME categorization and the leak rate criterion for check v61ves will be completed prior to start-up following the third refueling outag Page 4 of 4
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ATTACIMENT 2 As discussed in your letter dated July 21, 1989 transmitting Notice of Violation 8918-01, GSU is providing its response concerning your questions about deportability and operability of the instrument air system at River Bend Station. The reporting requirements contained in 10CFR Parts 50.72 a .73 and GSU's reporting evaluation process via the condition report procedure (ADM-0019), will be emphasized in required training for engineering department personnel. Operability of systems or components with questionable characteristics, as identified on condition reports, will be documented in greater detail in the disposition of the condition report justifying continued operatio Determination of the extent of the nonconforming conditions will be an important element in resolution of the reported conditio Page 1 of I
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P    JUL 211989 -
Gulf State Utilities i DISTRIBUTION:
SECY-CA
  'JMTaylor, DEDR HThompson, DEDS TMurley, NR J..Partlow, NRR    i JLieberman, OE
  :JGoldberg, 0GC Enforcement Coordinators RI, RII, RIII, RIV, RV F. Ingram, GPA/PA EJordan, AEOD    i MHalsch, 0lG BHayes, 01 OE:ES
  .0E:EA File OE:Chron M $-
RIV DISTRIBUTION:
RMartin JMontgomery LJCallan-JLMilhoan JPJaudon
  .IBarnes RStewart LE11ershaw W. B. Jones, RI, RB JG11111and(1trhd)
CHackney WBrown RWise E0 Files RIV Files DRS Division Files DRP Division Files RSTS Operator MIS Coordinator G \"
OE y :n RIV D:0E DEDS HThompson k I\
JLaphman RDMJrtin JLieberman 7/iq/89 7/h/89 7/9()/89 7SO/89  ,
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Latest revision as of 23:14, 30 January 2022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/89-18
ML20247H332
Person / Time
Site: River Bend Entergy icon.png
Issue date: 09/11/1989
From: Milhoan J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Deddens J
GULF STATES UTILITIES CO.
References
NUDOCS 8909190296
Download: ML20247H332 (2)
v • d • e


Text

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~ SEP ! l~ 1989

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In Reply Refer To:

b , Docket: 50-458/89-18 9 .,,

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Gulf States Utilities

,

'

~ ATTN: Mr. James C. Deddens SeniorVicePresident(RBNG)

, P.O. Box 220 St.,Francisville, Louisiana 70775 Gentlemen:

-

Thank you for your letter of August 21, 1989, in response to our letter and Notice of Violation dated July 21, 1989. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, Original Soned By:

Thomas P. Gwynn

' James L. M11hoan, Director Division of Reactor Projects o cc:

Gulf States Utilities ATTN: J. E. Booker, Manager-

.

River Bend Oversight P.O. Box 2951 7 Beaumont, Texas 77704 Gulf States Utilities

ATTN: Les England, Director -

Nuclear Licensing - RBNG e ~ P.O. Box'220:

,J8 . St. Francisv111e, Louisiana 70775

. ~ o Louisiana State University, Government Documents Department 7 f r$$

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Td LouisianaRediationCcntrolProgramDirecto[ j

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August 21, 1989 RBG- 31384 File Nos. G9.5, G15. ~ . .

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U. S. Nuclear Regulatory Commission S [$ !; L _

Document Control Desk o Washington, D.C. 20555 i

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gggg4jggg Gentlemen: , Ih River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/89-18

- Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation for NRC Inspection Report No. 50-458/89-18. The inspection was performed by Messrs. C. Stewart, L. E. Ellershaw and W. B. Jones during the periods of Mt .t 1-5 and 15-19, 1989 of activities authorized by NRC Operating License NPF-47 for River Bend Station -

Unit GSU's response to the violation is provided in Attachment 1. GSU's response to the concerns addressed in the body of the letter is provided in Attachment GSU's response to the rotice of violation is complet Should you have any questions, please contact Mr. L. A. England at (504) 381-414

Sincerely,

, p J. E. Booker Manager-River Bend Oversight River Bend Nuclear Group JEB/LAE/RJK/MSF/RGW/AJK/ch Attachments cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Senior Resident Inspector P.O. Box 1051 St. Francisville, LA 70775

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA )

PARISH OF WEST FELICIANA )

Docket No. 50--458 In the Matter of )

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GULF STATES UTILITIES COMPANY )

(River Bend Station - Unit 1)

AFFIDAVIT

, E. Booker, being duly sworn, states that he is Manager-River Bend Oversight for Gulf States Utilities Company; that he is authorized on the part of said company to l

sign and file with the Nuclear Regulatory Commission the documents attached hereto; that he has read all of the statements contained in such documents attached thereto and i made a part thereof; and that all such statements made and j' matters set forth therein are true and correct to the best of his knowledge, information and belief.

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[J . Booker Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this J/ day of h>l d , .< 6( , 1929 . My Commission expires with Lif [

0}Clu dALS NtAME Notary Public in and for West Feliciana Parish, Louisiana

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ATTACMENT 1 RESPONSE TO NOTICE OF VIOLATION 50-458/8918-01 LEVEL III

- REFERENCES-Inspection _ Report 89-18 - Letter from J. L. Milhoan to J. Deddens, dated June 6, 198 Meeting Summary of Enforcement Conference held June 6, 1989 - Letter from L. Milhoan to J. C. Deddens, dated June 22, 198 Notice of Violation - Letter from J. D. Martin to J. C. Deddens, dated July 21, 198 FAILURE TO ESTABLISH A TEST PROGRAM Criterion VI of Appendix B to 10CFR50 requires, in part, that a test program shall be established to assure that all testing required to demonstrate .that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design document Contrary to the above, in November 1988 it was identified that Gulf $tates Utilities (G5U) had failed to establish a test program at River Bend Station to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performe Specifically, GSU failed to establish a test program to demor. strate that two independent fuel building ventilation charcoal filtration subsystems and two independent main control room air handling unit / filter train subsystems would perform satisfactorily in service. As a result, GSU failed to discover design and installation flaws that would. have prevented these subsystems from operating as intended under certain design condition REASON FOR THE VIOLATION Gulf States Utilities Company's (GSU) performed a detailed review to determine the cause 01 the subject violation. During the start-up test program each system or subsystem was considered to be a separate entit This cause was determined to be GSU's failure to adequately test the interface between the instrument air and HVAC systems which is considered to be an isolated inciden GSU considered interconnected instrument ' air systems operable based on each system or subsystem test and did not realize the need for simultaneous testin The control building and auxiliary building heating, venting and air conditioning (HVAC) systems were released for start-up testing prior to the release of the instrument air system. The need for pressure decay testing of the auxiliary, control atid fuel building's instrument air accumulators was Page 1 of 4 L . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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not recognized during initial plant start-up. The ASKE Section XI valve testing program was thought to provide an adequate indication of system operabilit Neither Technical Specifications nor the ASME XI code requires simultaneous interacting system performance start-up testing. GSU did not interpret Criteria XI of Appendix B to 10CFR Part 50 to require testing of interacting systtms in addition to performance testing of structures, systems and component The initial design was inadequate and testing of the instrument air system would have discovered the problem as GSU discovered in subsequent testin However, the RBS current design modification process requires functional tests such that operability of a system can be assured prior to its return to servic GSU initiated a self assessment of the River Bend Station instrument air system by performing a Safety System Functional Inspection (SSFI) during the fall of 1988. During the inspection a question was raised on the instrument air system accumulator supply capacity for post-accident condition Subseque.a testing was performed during refueling outage 2 which showed that the accumulator air supply was not sufficient for the areas identifie Further investigation identified that solenoid valves had been installed in reverse which did not allow the valves to seal in the correct positio RBS submitted Licensee Event Report (LER) No.89-022. Other aspects relating to the instrument air system were addressed in the LER and GSU's response to Generic Letter 88-14. GSU's response to the notice of violation will focus on the area of testin CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Design Engineering conducted a review of loads which are dependent upon the safety-related headers within the control, auxiliary, and fuel buildings. This study consisted of a review of the two safety related headers within each of these three buildings. As a result of this study: The control building chilled water pressure differential control valves were modified as described in Section C.I.a belo . Five nonsafety-related loads have been removed from the two instrument air headers within the control buildin . Two standby gas treatment and two auxiliary building HVAC outlet air operated dampers within the auxiliary building will be modifie The first design verification testing included the testing of one of the two instrument air headers within the control building to verify that each header would stay pressurized for the calculated two days upc1 loss of the instrument air compressor The results of the first control building header pressure retertion test revealed the volume of the associated accumulator to be significantly undersized and the following design changes and repairs were then implemented:

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~ Control Building: The major instrument air users, the control building chilled water pressure differential control valves, were modified to remain mechanically secured in a throttled position instead of remaining as air operated control valves, The pressure retention time of each of the two safety-related headers was increased through the 180 degree realignment of the inlet header solenoid operated valves (50V) to an orientation which seated the valves in the correct position to keep air in

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the accumulato , The inlet check valve of each of the two safety-related headers received seat relapping and spring change-ou . Auxiliary Building: The pressure retention time of each of the two safety-related headers was increased through the 180 degree realignment of the inlet header S0Vs to an orientation which seated the valves in the correct position to keep air in the accumulato . Fuel Building: The pressure retention time of each of the two safety-related headers was increased through the 180 degree realignment of the inlet header 50Vs to an orientation which seated the valves in the correct position to keep air in the accumulato The damper fail positions of four dampers were changed to " fail open" from " fail closed", thereby resulting in instrument air not being required within the fuel building to mitigate the release of radioactivity after an acciden D. The final design verification testing included the testing of the two safety related headers of the control building and the two safety related headers of the auxiliary building to verify that each header remained pressurized to assure the respective HVAC systems would perform their design basis functions following an acciden . Control Building: Each of the two safety related accumulators, along with its associated header, was tested for pressure retention time upon the failure of the instrument air compressor Each safety related header was found to remain pressurized for an adequate time period to assure the control building atmosphere would remain habitable after an accident only when an auxiliary compressed air source is also connected to each heade Page 3 of 4

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~ Auxiliary Building: Ecch of the two safety related accumulators, alcng with its i associated header, were tested for pressure retention time upon the failure of the instrument air compressors. Each header was found to remain pressur4 zed for an adequate time period to assure the auxiliary, containment, and drywell building HVAC systems would perform their design basis functions following an accident only when an auxiliary compressed air source is connected to each heade The control bailding and auxiliary building safety related accumulator pressure retention times were then increased through the following design modifications: Control Building:

Each of the two accumulators' capacities van ir.creas?d through the installation of two banks of high pre:sure air bottles at each accumulator inle . Auxiliary Building:

Each of the two accumulators' capacities was increased through the installation of two banks of high pressure air bottles at each accumulator inlet. These bottles are subject to removal upon the installation of the backdraft damper CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A-. The two standby gas treatment and two auxiliary butiding HVAC outlet air operated dampers wili be replaced by self-actuating back draft dampers thereby eliminating the need for safety related instrument ai Field Engineering is establishing a control building safety-related accumulator air retention test to be performed every refueling outag C.. In addition, GSU will review the testing methods, the bases for ASME categorization and the leak rate criterion for check valve DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The River Bend Station instrument air system is currently in full complianc The current system configuration is adequate and the follcwing are enhancements to increase system performance and reliabilit The back draft dampers will be installed in the standby gas treatment and HVAC system prior to start-up fcllowing the third refueling outag The control building accumulator air retention test procedure will be developed by November 15, 198 The review of testing methods, the bases for ASME categorization and the leak rate criterion for check v61ves will be completed prior to start-up following the third refueling outag Page 4 of 4

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ATTACIMENT 2 As discussed in your letter dated July 21, 1989 transmitting Notice of Violation 8918-01, GSU is providing its response concerning your questions about deportability and operability of the instrument air system at River Bend Station. The reporting requirements contained in 10CFR Parts 50.72 a .73 and GSU's reporting evaluation process via the condition report procedure (ADM-0019), will be emphasized in required training for engineering department personnel. Operability of systems or components with questionable characteristics, as identified on condition reports, will be documented in greater detail in the disposition of the condition report justifying continued operatio Determination of the extent of the nonconforming conditions will be an important element in resolution of the reported conditio Page 1 of I

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