ML20217Q883

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/98-04 on 980319

ML20217Q883
Person / Time
Site:	River Bend
Issue date:	04/09/1998
From:	Collins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mcgaha J ENTERGY OPERATIONS, INC.
References
50-458-98-04, 50-458-98-4, NUDOCS 9804130216
Download: ML20217Q883 (5)

See also: IR 05000458/1998004

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

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REGION IV

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611 RYAN PLAZA DRIVE, SUITE 400

AR UNGTON, TEXAS 760114064

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John R. McGaha, Vice President - Operations

River Bend Station

Entergy Operations, Inc.

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P.O. Box 220

St. Francisville, Louisiana 70775

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SUBJECT: NRC INSPECTION REPORT 50-458/98-04

Dear Mr. McGaha:

Thank you for your letter of April 3,1998, in response to our letter and Notice of Violation

dated March 19,1998. We have reviewed your reply and find it responsive to the concerns

raised in our Notice of Violation involving inadequate procedural guidance to maintain control of

the position of a maintenance Jacking device on a primary containment purge isolation valve.

We will review the implementation of your corrective actions during a future inspection to

determine that full compliance has been achieved and will be maintained.

Sincerely.

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Elmo E. Collins, Chief

Project Branch C

Division of Reactor Projects

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Docket No.: 50-458

' ' License No.: NPF-47

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cc:

Executive Vice President and

Chief Operating Officer

Entergy Operations, Inc.

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' P.O. Box 31995 -

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Jackson, Mississippi 39286-1995

9804130216 900409

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ADOCK 05000458

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' Entergy Operations, Inc.

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Vice President

Operations Support

Entergy Operations, Inc.

~ P.O. Box 31995

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Jackson, Mississippi 39286-1995

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General Manager

' Plant Operations -

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

Director- Nuclear Safety

. River Bend Station

Entergy Operations, Inc.-

P.O. Box 220

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St. Francisville, Louisiana 70775

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Wise, Carter, Child & Caraway

P.O. Box 651

Jackson, Mississippi 39205

- Mark J. Wetterhahn, Esq.-

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Winston & Strawn

1401 L Street, N.W.

Washington, D.C. 20005-3502 -

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Manager - Licensing -

! River Bend Station -

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- Entergy Operations, Inc.

P.O. Box 220 :-

St. Francisville Louisiana 70775

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. The Honorable Richard P. leyoub-

Attorney General .

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. Department of Justice

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' State of Louisiana

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P.O. Box 94005

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Baton Rouge, Louisiana .70804-9005

H.~ Anne Plettinger

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3456 Villa Rose Drive

.. Baton Rouge, Louisiana 70806

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Entergy. Operations, Inc.

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President of West Feliciana

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- P.O. Box 1921

' St. Francisville, Louisiana 70775

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William H. Spell, Administrator

Louisiana Radiation Protection Division

P.O. Box 82135

Baton Rouge, Louisiana 70884-2135

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DOCUMENT NAME: R:\\_RB\\RB804AK.GDR

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DOCUMENT NAME: R:\\_RB\\RB804AK.GDR

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April 3,1998

U.S. Nuclear Regulatory Commission

Document Control Desk, OPI-17

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Washington, DC 20555

Subject:

Reply to Notice of Violation in IR 98-004

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River Bend Station - Unit I

License No. NPF-47

Docket No. 50-458

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File Nos.:

G9.5,G15.4.1

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RBG-44445

RBF1-98-0072

Gentlemen:

Pursuant to the provisions of 10CFR2.201, Attachment A provides the Entergy

Operations, Inc. response to the Notice of Violation (NOV) described in NRC Inspection

Report (IR) 50-458/98-004.

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The subject violation,50-458/98004-02, involves inadequate procedural guidance to

maintain control of the position of an attached maintenance jacking device on a primary

containment purge valve.

Should you have any questions regarding the attached information, please contact Mr.

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David Lorfing of my staff at (504) 381-4157.

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Reply to Notice of Violation in 50-458/98-004

April 3,1998

RBG-44445

RBF1-98-0072

Page 2 0f 2

cc:

U.S. Nuclear Regulatory Commission

Region IV

611 Ryan Plaza Drive, Suite 400

Arlington,TX 76011

NRC Sr. Resident Inspector

P.O. Box 1050

St. Francisville, LA 70775

David Wigginton

' NRR Project Manager

U.S. Nuclear Regulatory Commission

M/S OWFN 13-H-3

- Washington, DC 20555

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ATTACHMENT A

REPLY TO NOTICE OF VIOLATION 50-458/98004-02

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Page1of2

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Violation:

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. During an NRC inspection conducted on January 11 through February 21,1998, one

violation of NRC requirements was identified. In accordance with the " General

Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the

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' violation is listed below:

10 CFR Part 50, Appendix B, Criterion V, states, in part, " Activities affectir's

quality shall be prescribed by documented instructions, procedures, or drawings of

a type appropriate to the circumstances and shall be accomplished in accordance

with these instructions, procedures, or drawings . . ."

Matryx Company Drawing Number 410318, dated October 10,1980, required

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that the pump release screws (petcock valves) be positioned one tum

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counterclockwise (open) when operating containment ventilation and purge

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Dampers HVR-AOV-128, HVR-AOV-165, and HVR-AOV-166 in the pneumatic

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mode (safety-related mode). This drawing was the only document that specified

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' the position of the petcock valves.

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Contrary to the above, on January 8,1998, the petcock valves for Dampers HVR-

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. AOV-128, HVR-AOV-165, and HVR-AOV-166 were found full closed, but the

dampers had been operated in the pneumatic mode. Controls to ensure that the

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valves were correctly positioned were inadequate.

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This is a Severity Level IV violation (Supplement 1)(50-458/9804-02).

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Reasons for the Violation:

River Bend Station has four containment purge dampers, functioning as primary

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containment isolation barriers, which are fitted with attached hydraulic jacking devices.

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These devices can be used to open the dampers during maintenance or abnormal

operating conditions. The petcock valves, when closed, allow hydraulic pressure to be

- developed for operation of these jacking devices. The petcocks are opened to disable

thesejacks thereby allowing normal pneumatic operation of the dampers.

A root cause investigaticu was conducted, with two primary causes identified.

The first primary cause was related to the area of configuration conul in that there were

inadequate administrative controls established to ensure that the attacned hydraulic

jacking assembly would not interfere with pneumatic operation of the damper. The

correct restoration position of the petcocks (i.e., one turn open) should have been

identified and controlled. If the position had been controlled, the petcocks would have

been restored to the correct position upon completion of maintenance activities.

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ATTACHMENT A

REPLY TO NOTICE OF VIOLATION 50-458/98004-02

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The second primary cause was related to the area of work organization and planning in

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that work package preparation was inadequate as related to this event. . The last

documented maintenance involving steps during which personnel may have manipulated

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the petcocks was performed in June of 1994. There was no step in the job plans directing

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the workers to return the petcocks to the open position upon completion of the work.

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Corrective Actions That Have Been Taken:

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To maintain administrative control over the open position, as depicted on Matryx

Company Drawing Number 410318, dated October 10,1980:

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the petcocks on'all four purge dampers were lockwired one turn open;

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the four lockwired petcocks were fitted with conspicuous labels to direct personnel to

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maintain that position; and1

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the applicable Work Management Screens for the purge dampers were updated with a

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reference note to direct that future job plans contain instructions for the petcocks to be

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lockwired one tum open prior to returning the dampers to service.

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.To address the generic implications:

regarding other pneumatic opetated valves that serve as primary containment isolation

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valves and are included in the Local Leak Rate Testing Program, a review was

conducted finding no other valves fitted with similarly uncontrolled subcomponents

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that could affect operation;

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regarding other plant components, maintenance personnel and system engmeers were

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briefed on this event, stressing the need to identify configurations that could result m

similar events; and

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regarding other plants, the details of this event were distributed through the Institute

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for Nuclear Power Operation (INPO) Nuclear Network for review by other plants,

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Corrective Actions That Will Be Taken to Avoid Further Violations:

The applicable operating procedure will be revised to invoke procedural control over

. retuming the locked open petcock valves to their proper condition after operation.

Preventive maintenance tasks and other standardized maintenance job plans will be

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revised to include a specific restoration step for the petcocks where applicable.

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Date When Full Compliance Will Be Aebieved:

Ad, equate control was achieved upon lockwiring the petcocks open and conspicuously

labeling their correct position. Full compliance will be achieved by June 30,1998.

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