|
|
| Line 1: |
Line 1: |
| {{Adams | | {{Adams |
| | number = ML20247G365 | | | number = ML20246H733 |
| | issue date = 03/17/1989 | | | issue date = 05/04/1989 |
| | title = Discusses Violations Noted in Insp Rept 50-458/88-26 & Forwards Notice of Violation.Requests Response Documenting Specific Actions Taken & Addl Actions Planned to Prevent Recurrence | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/88-26 |
| | author name = Martin R | | | author name = Callan L |
| | 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-89-010, EA-89-10, NUDOCS 8904040205 | | | document report number = NUDOCS 8905160179 |
| | package number = ML20247G371 | | | title reference date = 04-17-1989 |
| | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | page count = 3 | | | page count = 2 |
| }} | | }} |
|
| |
|
| Line 19: |
Line 19: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:~1 | | {{#Wiki_filter:_ __ - . - - _ - - _ _ _ - - - - - - _ _ - - |
| . _ . ,
| | , |
| ge[q, * , ' UNITED STATts
| | - |
| \ NUCLEAR REGULATORY COMMISSION f8 Rt040N IV 4 Sit RYAN PLAaA DRIVE. SulTE 1000 ARLINGTON, TEXAS 75011
| | i |
| %....+ | | . . , |
| uan I T 19m Docket No. 50-458/88-26 Lic:nse No. NPF-47 -
| | . |
| ~EA 89-10
| | HN AY In Reply Refer To: |
| .
| | Docket: 50-458/88-26 Gulf States Utilities ATTN: fir. James C. Deddens Senior Vice President (RBNG) |
| Culf States Utilities ATTN: Mr. James C. Deddens Senior Vice President (R8NG),
| | P.O. Box 220 St. Francisville, Louisiana 70775 Gentlemen: |
| Nuclear Licensing P.O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:-
| | Thank you for your letter of April 17, 1989, in response to our letter and Notice of Violation dated March 17, 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 Sincerel Onginal Signed Bp t 3: CALLAN L. J. Callan, Director Division of Reactor Projects cc: |
| SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-458/88-26)
| | Gulf States Utilities ATTN: J. E. Booker, Manager-River Bend Oversight P.O. Box 2951 Beaumont, Texas 77704 Gulf States Utilities ATTN: Les England, Director , |
| This refers to the inspection conducted December 1-31, 1988, by the NRC Resident Inspectors at River Bend Station (RBS). NRC's inspection report was issued on February 7,1989. This inspection focused on the circumstances surrounding Gulf States Utilities' (GSU) discovery on December 3,1988, that a very high radiation area (VHRA) access door was not secured and on GSU's declaration on December 19, 1988, that the reactor core isolation cooling (RCIC) system was in:perable. The inspection disclosed that several VHRA doors had been left unsecured during the previous 18 months'. It was also disclosed that the lic nsee's staff failed to identify prior to initial criticality and on at least three occasions following initial criticality that the RCIC system was potentially inoperable because a design change had not been completed. These matters were described in detail in the referenced inspection report and were discussed with you and other GSU officials at an enforcement conference in the NRC Region IV office on February 27, 198 The seven incidents involving VHRA access doors during the previous 18 months indicate that your corrective actions prior to December 1988 had not been completely effective in assuring that access to VHR areas was strictly controlled. Your subsequent cormctive actions, which you described during the enforcement conference, should ensure that all personnel are aware of their responsibilities for controlling VHRA access doors and that each door is secured after each exit to prevent an individual from entering a VHRA without proper authorizatio In detamining the overall significance of this matter, the staff considered the fact that there is no evidence that individuals actually entered these areas when the doors were unlocked, and the fact that the radiation levels in
| | Nuclear Licensing - RBNG ! |
| $$ N Oobk O . | | P.O. Box 220 St. Francisville, Louisiana 70775 Louisiana State University, Government Documents Department Louisiana Radiation Control Program Director bec to DMB (IE01) |
| CERTIFIED MAIL '
| | RIV:DRP/C C: d D:DR \\ |
| _ RETURN REGLIPT REQUESTED A | | GLMadsen;df GLC6nstable LJCa n g 5/.g/89 5/y/89 0 5/3 /89$1 / ./ |
| -
| | 8905160179 870504 N |
| h h
| | {DR ADOC1' 05000458 |
| y<h
| | _ |
| | PDC j |
| | |
| | _ _ - - - _ . . _ _ - _ - -- |
| | .. . |
| | ,.,,, |
| | j ^/ |
| | ~' |
| | '. |
| | . |
| | L* |
| | - |
| | ... - |
| | r, |
| | , |
| | , |
| | I . Gulf States Utili.tiies, -2- |
| | / |
| | bec.distrib by RIV:- |
| | l DRP RRI'. . . |
| | 'R. D. Martin, RA |
| | ' |
| | SectionChief-(DRP/C)- |
| | Lisa'Shea,RM/ALF ' MIS System RPB-DRSS' RSTS Operator Project Engineer (DRP/C)' RIV File W. Paulson, NRR Project Manager (MS: 13-D-18) DRS o |
| | i I |
| | _ _ - _ - _ - - _ _ _ - _ - _ _ - _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ . _ - _ - _ . _ |
| | |
| | :, . |
| | . |
| | - - |
| | - - |
| | .: |
| | GULF STATES UTILITIES COMPANY |
| | .g RIVER DEND STATION POST OFFICE 80x 220 ST FRANCISVILLE. LOUISIANA 70776 ARE A CODE 604 636 6094 346 8661 |
| | * R@ RDW/RV . . . - -- |
| | April 17, 1989 N I RBG-30552 jj File Nos. G9.5, G15. I |
| | - . . 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/ Report 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 GSU's response to the violations are provided in the attachment This completes GSU's response to these item Should you have any questions, please contact Mr. England at(504)381-414 S ncerely |
| | / / tv |
| | / . C. Deddens Senior Vice President |
| | , |
| | River Bend Nuclear Group JEB/LAE/RJK/JWC/ch cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Senior Resident Inspector P. O. Box 1051 i St. Francisville, LA 70775 ; |
| | __ $W _ _ _ _ _ _ _ _ _ _ _ _ . _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ - |
|
| |
|
| 1'
| | - - _ _ - - .. . _ _ - _ _ _ _ - - - _ _ - _ |
| . , | | _ _ - _ _ _ _ _ _ - _ _ - _ - - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ |
| , , | | .. |
| ___ j
| |
| . | | . |
| ., | | . . ,. |
| Gulf States Utilities -2 ' " '' I 7 *
| | d , .. - |
| these areas did not create a high potential for significant radiation exposure should someone have entered. Further, RSS's practices result in thrice-daily checks of these doors, minimizing the possibility of their being open for extended periods prior to discovery. Accordingly, this violation has been classified at Severity Level IV in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions (Enforcement Policy) in 10 CFR, Part 2 Appendix C. We have also incluued a Severity Level IV violation for G50's failure to submit Licensee Event Reports to the NRC within 30 days of the discovery of these doors having been found unlocked, a violation of the requirements of 10 CFR 50.7 .
| | UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA ) |
| -
| | PARISH OF WEST FELICIANA ) |
| -The NRC staff is also concerned that RBS was operated with the RCIC system potentially inoperable from November 1985 through December 19, 1989. The d; sign change to restore the RCIC system to an operable status was initiated prior to initial criticalit Reviews performed prior to initial criticality to identify design changes which could affect safety system operability were not effective in identifying that the RCIC turbine base alignment pins had not been installed. This concern is compounded by your staff's failure to identify that the alignment pins were not installed during subsequent opportunities following initial criticalit In determining the overall safety significance of the RCIC system problem, NRC considered GSU's analysis of the safety significance of RCIC alignment pins not being installed and recognizes that the RCIC system did perform as required during two events in August and September 1988. In addition, your evaluation, conducted after the alignment pins were discovered missing on December 19, 1988, ,
| | In the Matter of ) Docket No. 50-458 50-459 |
| has concluded that the alignment pins are not necessary to ensure the operability of the RCIC system, a conclusion,that the NRC accepts. This violation also has been classified at severity Level IV in accordance with NRC's enforcement policy. However, the importance NRC places on ensuring that plants are operated in compliance with requirements incorporated in the Tcchnical Specifications is not necessarily diminished even in situations when the actual impact on safety may later be found to be insignifican 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 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 determ.ine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement '
| | ^ |
| .
| | 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; tha .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 belie D * * > -- |
| | J.#C. Deddens Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this [7Ybdayof ddClr 0 h , 19 , |
| | l ,e y bW an Middlebrooks |
| | ' '' |
| | W . |
| | l |
| | /J otary Public in and for West Feliciana Parish, I |
| | Louisiana My Commission is for Life. |
|
| |
|
| e e O a
| | !. |
| | , |
| | _ _ . - . . _ _ _ _ _ _ - _ _ _ - _ - _ _ |
|
| |
|
| ~. . _ . . _ .
| | - ________ __ _ - _ __ |
| - . | | : ' , |
| j l ,( . . . ....m
| | . |
| .~ . . . . q ..: .,
| | . . ,. |
| :,,. ;& :%g; g _ .-
| | s ,, .- |
| .
| | ATTACHMENT 1 Response to Notice of Violation 50-458/8826-01 t |
| .
| | Level IV Violation REFERENCE: Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated March 17, 198 . Licensee Event Report No. 88-027 - to NRC from J. E. Booker, dated January 18, 1989 FAILURE TO ENSURE RCIC SYSTEM OPERABILITY: |
| .'
| | l RBS Technical Specifications (TS) Limiting Condition for Operation (LCO) |
| un I T '989
| | 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 psi 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 configuratio 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 desig 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 plac Investigation of historical documents shows that the portion of the original modification to install the lock wire and dowel pins was complete 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 worke 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 |
| | . backlog of unprioritized MRs reduced to a manageable level by the end of 198 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 i reduction effor All modifications as a result of condition report corrective actions have been reviewed and prioritize Less than 75 modification requests remain in the balance of the program. These 75 MRs have been screened by Design Engineering and none have been determined to have an impact on operabili^. Page 1 of 3 |
| . | | . |
| - | | _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . . _ _ _ _ _ _ _ _ _ _ _ . _ _ __ _ .__ __a |
| ' ' i. '' | | |
| -i: . 'p+ ..
| | _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - - |
| ,47. Gulf States Utilities i -3-
| | , . |
| - | | I- |
| | . . , |
| | ' |
| | Tfie 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 quickl 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, 198 As identified above, the inadequate installation was initially identified as a direct result of an internal audit of incomplete construction modification All open MRs which have not been prioritized have been screened by Design Engineering and none have been determined to have an impact on operabilit 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 isolate An assessment of the safety implications have shown the effects of the incomplete construction modification to be minimal. The RCIC system provides redundancy to ttle 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 ir, this emergency safety feature (ESF) |
| | capacity since the RBS design includes an automatic depressurization system (ADS). ADS provides the required redundancy to HPC 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. |
| | |
| | l l Seismic qualification tests were conducted on the prototype test turbine at much higher accelerations than those assumed for RBS for either an operat 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 r.ot 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, i 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 even Therefore, the safe operation of the plant and the health and safety of the public were not adversely affected as a result of this even (For additional details of assessment of safety implications, refer to Reference 2.) |
| | |
| | Page 2 of 3 U___ _ _ - __ _ ___ -__ -_ - ________---_-_ _______ .__ _ _ __ _ _ _ _ _ _ - _ - _ _ _ _ _ |
| | |
| | ___ _ |
| | .. |
| . | | . |
| ; ,. b/ ! , 4 g | | . - . |
| ' | | , |
| . | | -' |
| ' %I | | .. . |
| . | | ' |
| | CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS: |
| | ' A comprehensive 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 prioritized for implementation accordingl DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: |
| | RBS is currently in full compliance. |
| | |
| | I i |
| | { |
| | l |
| | ! |
| | Page 3 of 3 |
| | _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ |
| | |
| | __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ __ _ _ _ _ _ _ . _ _ - . _ _ - _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ - _ |
| | i j |
| | .- 1 ' |
| | ; - |
| | . |
| , | | , |
| l$
| | ATTACIMENT 2 Response to Notice of Violation 50-458/8826-02 Level IV Violation REFERENCE: |
| .- Th ! responses directed by this letter and the enclosed Notice are not subject j th..the cicerance procedures of the Office of Management and Budget as required i, the Papenvork Reduction Act of 1980, Pub. L. No. 96-51 F.ay;by W.:7t !i-
| | Notice of Violation - Letter from R. D. Martin to to Deddens, dated March 17, 198 FAILURE TO SECURE A VHRA ACCESS DOOR: |
| - J.y:7p '
| | RBS TS 6.12.2 requires that accessible areas with radiation levels, such that a major portion of the body could receive in I 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 superviso , |
| | 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 are 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 time 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 secure TB 123-20 was not attended during the period the door was left unsecure Seven cdditional examples of events where VHRA access doors were previously left unsecured are identified in NRC Inspection Report 50-458/88-2 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 key The Shift Supervisor and the COF 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 exi Investigation was inconclusive as to who failed to ensure that these doors were secured upon exiting. The root causes of this problen are the failure on the part of the individual to verify that the doors were secured and ineffective controls to prevent recurrence. |
|
| |
|
| Sincerely,
| | l Page 1 of 2 |
| :. Q9 .
| | . |
| ''
| | |
| g 5li . .'lj)Nbj' i ;- j h[
| | - ___ _ __-_-_ _ -______ . _ _ _ _ _ _ |
| >
| |
| '
| |
| ~~
| |
| :$l'lfhl3
| |
| . | | . |
| <t, H{'%':tP;[
| | . |
| * :l?*n,/.E l i .'
| | ' |
| Robert D. Martin Regional Administrator Rtc-le9 3- -
| | i , |
| i: 'P;'!! Enclosure:
| | . '.* |
| ';f1 Notice of violation y:% <m' .{ .
| | CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED: |
| # | | All VHRA doors were locked upon discover Numerous programmatic controls and corrective actions have been implemented since initial plant operation to ensure that these doors are secured upon exi Increasingly stringent controls failed to produce the desired resul 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 VHRA 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 changes that were implemented require that 1) only radiation protection personnel will be issued keys to VHRA doors for routine access, 2) RP personnel will log the opening and locking of VHRA doors and is responsible for verification of locked 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 monthl In addition to the above, Security also physically verifies twice daily that accessible VHRA doors are locke CORRECTIVE, STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS: |
| I*.dC:
| | No VHRA doors have been discovered unsecured and unattended since the implementation of the present progra The improved, more stringent administrative controls established for routine access to VHRA should prevent any future violation DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: |
| '
| | RBS is currently in full complianc Page 2 of 2 |
| | _ _ _ _ _ _ _ - - _ _ - _ - _ . _ _ - _ . _ - _ |
| | |
| | _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ - |
| | .. |
| | . |
| . | | . |
| .{j
| | .; , |
| ; .D,J... Louisiana . , | | ATTACMENT 3 Response to Notice of Violation 50-458/8826 Level IV Violation REFERENCE: |
| Radiation Control Program Director _ | | Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated March 17, 198 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 I 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 event 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 operatio CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED: |
| | I 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: l 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 door DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: |
| | |
| | ' |
| | The appropriate RBS supervisors as identified above will be informed by May 15, 1989 of the deportability of these event Page 1 of 1 |
| | , |
| | - - - - . - - - - . - - . . - . . _ _ - - - _ - _ _ _ - - _ - _ _ - _ _ |
| }} | | }} |
|
|---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L7681999-10-19019 October 1999
Forwards Insp Rept 50-458/99-12 on 990822-1002.Four Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy
RBG-45125, Forwards Voluntary Response to Administrative Ltr 99-03, Preparation & Scheduling of Operating Licensing Exams1999-10-18018 October 1999
Forwards Voluntary Response to Administrative Ltr 99-03, Preparation & Scheduling of Operating Licensing Exams
ML20217J3751999-10-15015 October 1999
Informs That Applicable Portions of NEDC-32778P, Safety Analysis Rept for River Bend 5% Power Uprate, Marked as Proprietary Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b)
IR 05000458/19990071999-10-0505 October 1999
Refers to Util Ltr Re Apparent Violations Described in Insp Rept 50-458/99-07 Issued on 990804 & Forwards Nov.Insp Described Two Apparent Violations Related to River Bend Station Division I EDG
RBG-45123, Informs That Error Reported to NRC by GE on 990630 Resulted from Changes to SAFER Code Models Counter Current Flow Limiting (Ccfl) in Upper Part of Fuel Bundle at Upper Tie Plate (Utp).No Changes in SAR or COLR Required1999-09-30030 September 1999
Informs That Error Reported to NRC by GE on 990630 Resulted from Changes to SAFER Code Models Counter Current Flow Limiting (Ccfl) in Upper Part of Fuel Bundle at Upper Tie Plate (Utp).No Changes in SAR or COLR Required
RBG-45124, Suppl to 990907 Response to Violations Noted in Insp Rept 50-458/99-07.Info to Address Specific Requests in 990920 Conference Call Re DG Assessment Completion Dates for Corrective Actions & DG Maint Rule (a)(1) Status,Encl1999-09-24024 September 1999
Suppl to 990907 Response to Violations Noted in Insp Rept 50-458/99-07.Info to Address Specific Requests in 990920 Conference Call Re DG Assessment Completion Dates for Corrective Actions & DG Maint Rule (a)(1) Status,Encl
RBG-45122, Forwards Rev 3 to RBS COLR for Ninth Fuel Cycle, IAW TS 5.6.5 of App a of FOL NPF-471999-09-23023 September 1999
Forwards Rev 3 to RBS COLR for Ninth Fuel Cycle, IAW TS 5.6.5 of App a of FOL NPF-47
RBG-45113, Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp1999-09-21021 September 1999
Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp
ML20212D8901999-09-16016 September 1999
Discusses 6 Month Review of Plant Midcycle Ppr.Advises of Plans for Future Insp Activities.Forwards Historical Listing of Plant Issues,Referred to as PIM
ML20216F7881999-09-15015 September 1999
Forwards Insp Rept 50-458/99-10 on 990830-990903.No Violations Noted.Insp Covered Licensed Operators Requalification Training Program & Observation of Requalification Activities
05000458/LER-1998-003, Forwards LER 98-003-02,revising Previous Rept Dtd 981005, Submitted to Clarify Reported Condition & to Incorporate Final Root Cause Analysis & Corrective Action Plan for Event.Complete Rev & No Change Bars Used in Documents1999-09-0909 September 1999
Forwards LER 98-003-02,revising Previous Rept Dtd 981005, Submitted to Clarify Reported Condition & to Incorporate Final Root Cause Analysis & Corrective Action Plan for Event.Complete Rev & No Change Bars Used in Documents
ML20211Q7721999-09-0909 September 1999
Expresses Appreciation for ,In Response to NRC 990702 Re Denial of Notice of Violation Cited in Concerning Insp Rept 50-458/98-16.Reply Found to Be Responsive to Concerns Raised in NOV
RBG-45109, Provides Comments on Reactor Vessel Integrity Database. Requests That Data Be Corrected as Noted1999-09-0808 September 1999
Provides Comments on Reactor Vessel Integrity Database. Requests That Data Be Corrected as Noted
ML20211Q3921999-09-0808 September 1999
Forwards Insp Rept 50-458/99-08 on 990711-0821.One Violation Being Treated as Noncited Violation
ML20211Q5541999-09-0808 September 1999
Discusses Meeting Conducted on 990830 in St Francisville,La Re Overall Performance Issues During 990403-0703 Refueling/ Maintenance Outage.Due to Proprietary Nature of Some Subject Matters,Meeting Closed to Public.Attendance List Encl
ML20211P4121999-09-0707 September 1999
Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d)
RBG-45095, Responds to NRC Re Violations Noted in Insp Rept 50-458/99-07.Corrective Actions:Fuel Pump Coupling Was Reworked Using Loctite & Division I DG Was Returned to Operable Status1999-09-0707 September 1999
Responds to NRC Re Violations Noted in Insp Rept 50-458/99-07.Corrective Actions:Fuel Pump Coupling Was Reworked Using Loctite & Division I DG Was Returned to Operable Status
RBG-45097, Requests Approval of Proposed Alternative to Second Interval Inservice Testing Program,Allowing One Time Extension of Test Interval for 20% of Full Set Main Steam Line Safety Relief Valves1999-08-31031 August 1999
Requests Approval of Proposed Alternative to Second Interval Inservice Testing Program,Allowing One Time Extension of Test Interval for 20% of Full Set Main Steam Line Safety Relief Valves
RBG-45094, Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation1999-08-25025 August 1999
Responds to NRC Re Violations Noted in Insp Rept 50-458/98-16 Between 990720 & 0807.Corrective Actions:River Bend Will Submit Changes Associated with Lcn 15.06-006 & Accompanying Evaluation
ML20211E2071999-08-23023 August 1999
Discusses Insp Rept 50-458/99-07 in Which 2 Violations Were Identified & Being Considered for Escalated Enforcement Action.Response Should Be Submitted Under Oath or Affirmation
ML20211C5101999-08-19019 August 1999
Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15
RBG-45093, Forwards FFD six-month Program Performance Data Rept for Rept Period 990101 Through 990630,containing Statistical Data & Trend Analysis Compiled by FFD Dept1999-08-17017 August 1999
Forwards FFD six-month Program Performance Data Rept for Rept Period 990101 Through 990630,containing Statistical Data & Trend Analysis Compiled by FFD Dept
ML20211A9291999-08-17017 August 1999
Forwards Insp Rept 50-458/99-11 on 990719-23.Areas Examined Included Portions of Licensee Physical Security Program. No Violations Noted
ML20210T8881999-08-16016 August 1999
Forwards Replacement Pages 9-18 for Insp Rept 50-458/99-09, Issued on 990730
IR 05000458/19980101999-08-13013 August 1999
Forwards Summary of 990805 Mgt Meeting with Licensee in Arlington,Tx Re Radiological Control Problems Noted in Insp Repts 50-458/98-10 & 50-458/99-04.With Attendance List & Licensee Presentation
ML20211A9501999-08-12012 August 1999
Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl
ML20210U3751999-08-12012 August 1999
Informs That Info Contained in Presentation, River Bend Station Fuel Recovery Project,Dtd 990622, Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act of 1954,as Amended
ML20210Q7691999-08-11011 August 1999
Forwards Request for Addl Info Re Licensee River Bend Individual Plant Exam External Events,Under GL 88-20,suppl 4,dtd 910628
ML20210R4591999-08-10010 August 1999
Ack Receipt of Which Transmitted Plant Emergency Plan,Rev 20 Under Provisions of 10CFR50,App E,Section V.Nrc Approval Not Required,Based on Determination That Changes Does Not Decrease Effectiveness of EP
ML20210N1641999-08-0404 August 1999
Forwards Insp Rept 50-458/99-07 on 990530-0710.One Violation of NRC Requirements Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy
ML20210K4641999-08-0303 August 1999
Forwards SE Accepting Licensee 180-day Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Power-Operated Gate Valves, Issued on 950817
ML20210L1461999-08-0303 August 1999
Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams
ML20210K1351999-07-30030 July 1999
Forwards Insp Rept 50-458/99-09 on 990510-28 with in-office Insp Until 990701.Three Violations Being Treated as Noncited Violations
ML20210J9691999-07-30030 July 1999
Discusses 990719 Meeting with Util in Arlington,Tx Re Region IV Staff Findings of Root Cause Investigation Into Fuel Cladding Failures That Occurred During Recent Cycle 8 Operation.List of Attendees & Organization Chart Encl
RBG-45072, Submits Final Response to GL 94-02, Long-Term Solution & Upgrade of Interim Operating Recommendations for Thermal- Hydraulic Instabilities in Bwrs. Ltr Documents Completion of Reporting Requirements Contained in Subject GL1999-07-23023 July 1999
Submits Final Response to GL 94-02, Long-Term Solution & Upgrade of Interim Operating Recommendations for Thermal- Hydraulic Instabilities in Bwrs. Ltr Documents Completion of Reporting Requirements Contained in Subject GL
ML20210E9001999-07-23023 July 1999
Informs That as Result of Staff Review of Licensee Responses to GL 92-01,rev 1,Suppl 1 & Suppl 1 Rai,Staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2
RBG-45073, Requests Withholding of Info Presented in 990719 Meeting of EOI & NRC Region IV Re Recent Anomalous Conditions Found During Insp of Fuel Bundles During 1999 RFO at Rbs.Affidavit Executed IAW Provisions of 10CFR2.790(b)(1),encl1999-07-20020 July 1999
Requests Withholding of Info Presented in 990719 Meeting of EOI & NRC Region IV Re Recent Anomalous Conditions Found During Insp of Fuel Bundles During 1999 RFO at Rbs.Affidavit Executed IAW Provisions of 10CFR2.790(b)(1),encl
RBG-45071, Forwards Rev 2 to River Bend COLR for Ninth Fuel Cycle,Iaw TS 5.6.5 of App A.Affected Pages of GE Suppl Reload Licensing Rept, May 1999 Submittal & List of Effective Pages,Encl1999-07-19019 July 1999
Forwards Rev 2 to River Bend COLR for Ninth Fuel Cycle,Iaw TS 5.6.5 of App A.Affected Pages of GE Suppl Reload Licensing Rept, May 1999 Submittal & List of Effective Pages,Encl
05000458/LER-1999-002, Forwards LER 99-002-01,IAW 10CFR50.73.Supplemental Rept Details Root Cause Analysis for Reported Condition. Commitments in Document Annotated on Commitment Identifier Form,Attachment 11999-07-15015 July 1999
Forwards LER 99-002-01,IAW 10CFR50.73.Supplemental Rept Details Root Cause Analysis for Reported Condition. Commitments in Document Annotated on Commitment Identifier Form,Attachment 1
ML20196L0501999-07-0606 July 1999
Informs That NRC Insp Rept 50-458/99-03 Issued on 990519 with Errors in Tracking Numbers Assigned to Seven Noncited Violations & Error Re Actual Location of SRO During Refueling Activities.Revised Pages 2 & 4 Encl
ML20209B6081999-06-30030 June 1999
Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl
ML20196K6851999-06-30030 June 1999
Ack Receipt of & Denial of NOV in Response to Transmitting NOV & Insp Rept 50-458/98-16.Listed Info Documents Results of Review of Response to Violation Re fire-induced Circuit Faults
ML20196K0671999-06-30030 June 1999
Forwards Insp Rept 50-458/99-04 on 990412-16 & 28-29.Five Violations of NRC Requirements Occurred & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy.Meeting Scheduled for 990726
RBG-45048, Forwards Rev 1 to Rbs,Cycle 9 COLR, IAW TS 5.6.5 of License NPF-47.GE Suppl Reload Licensing Rept,Dtd May 1999, Is Included.Without GE Rept1999-06-29029 June 1999
Forwards Rev 1 to Rbs,Cycle 9 COLR, IAW TS 5.6.5 of License NPF-47.GE Suppl Reload Licensing Rept,Dtd May 1999, Is Included.Without GE Rept
RBG-45047, Informs of Util Expectation to Complete Review of Final Rept Supporting Power Uprate & Submits TS Changes in Jul 1999,per Licensee to NRC Re Increasing Power Output1999-06-29029 June 1999
Informs of Util Expectation to Complete Review of Final Rept Supporting Power Uprate & Submits TS Changes in Jul 1999,per Licensee to NRC Re Increasing Power Output
ML20196H5171999-06-21021 June 1999
Requests Withholding of Info Being Presented in Meeting of Entergy,General Electric & NRC Staff.Licensee Requested Meeting with NRC to Present Info on Recent Anomalous Conditions Found During Insp of Fuel Bundles.W/Affidavit
05000458/LER-1999-012, Forwards LER 99-012-00,IAW 10CFR73.Commitments Contained in Document Identified on Commitment Identification Form1999-06-21021 June 1999
Forwards LER 99-012-00,IAW 10CFR73.Commitments Contained in Document Identified on Commitment Identification Form
RBG-45035, Requests That Encl RBS Fuel Recovery Info Be Withheld from Public Disclosure,Per Provisions of 10CFR2.790(a)(4).Info Is Being Presented at Meeting to Discuss Recent Anomalous Conditions Found.Proprietary Info Withheld1999-06-21021 June 1999
Requests That Encl RBS Fuel Recovery Info Be Withheld from Public Disclosure,Per Provisions of 10CFR2.790(a)(4).Info Is Being Presented at Meeting to Discuss Recent Anomalous Conditions Found.Proprietary Info Withheld
ML20196E0601999-06-18018 June 1999
Forwards Insp Rept 50-458/99-05 on 990418-29.Four Violations Identified & Being Treated as Noncited Violations
05000458/LER-1999-011, Forwards LER 99-011-00 for River Bend Station,Unit 1,IAW 10CFR50.73.Commitments Identified in Rept,Encl1999-06-0909 June 1999
Forwards LER 99-011-00 for River Bend Station,Unit 1,IAW 10CFR50.73.Commitments Identified in Rept,Encl
1999-09-09
[Table view]
Category:NRC TO UTILITY
MONTHYEARML20062G5771990-11-23023 November 1990
Forwards Insp Rept 50-458/90-31 on 901105-09.No Violations or Deviations Noted
IR 05000458/19900151990-11-21021 November 1990
Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/90-15
ML20062E4031990-11-15015 November 1990
Discusses Util Response to NRC Bulletin 88-010, Nonconforming Molded-Case Circuit Breakers
ML20058H5481990-11-14014 November 1990
Informs That Util 900529 Changes to Physical Security Plan Unacceptable Under Provisions of 10CFR50.54.Proposed Changes Decrease Effectiveness of Physical Security Plan
ML20217A3511990-11-0909 November 1990
Forwards Insp Rept 50-458/90-25 on 900924-28 & 1015-19. Violation Noted But Not Cited
ML20058D0401990-10-29029 October 1990
Forwards Physical Security Insp Rept 50-458/90-24 on 900910-14. Violations Not Cited Per 10CFR2
IR 05000458/19900161990-10-20020 October 1990
Ack Receipt of 900830 & 1011 Ltrs Responding to 900730 Notice of Deviation & 900907 & 22 Telcons,Per Insp Rept 50-458/90-16
ML20058B0131990-10-19019 October 1990
Forwards Insp Rept 50-458/90-28 on 901009-12.No Violations or Deviations Noted
ML20058D9531990-10-18018 October 1990
Forwards Ref Matl Requirements for Reactor/Senior Reactor Operator Licensing Exams Scheduled for 901114
ML20058A5421990-10-17017 October 1990
Forwards Insp Rept 50-458/90-23 on 900910-14.No Violations or Deviations Noted
ML20058A2191990-10-11011 October 1990
Forwards Summary of 900917 Mgt Meeting at Licensee Site Re Activities Conducted Under License NPF-47
IR 05000458/19900021990-10-0808 October 1990
Ack Receipt of Re Violations Noted in Insp Rept 50-458/90-02
ML20059N4721990-10-0303 October 1990
Forwards Insp Rept 50-458/90-22 on 900827-31.No Violations or Deviations Noted
ML20059D6411990-08-29029 August 1990
Forwards Insp Rept 50-458/90-15 on 900611-15.No Violations or Deviations Noted
ML20056B2461990-08-22022 August 1990
Forwards Insp Rept 50-458/90-20 on 900723-26.No Violations or Deviations Noted.However,Inability to Acquire & Retain Seasoned Instructors W/Substantial Operations Experience Apparently Affecting Quality of Operator Training
IR 05000458/19900061990-08-21021 August 1990
Ack Receipt of Informing NRC of Steps Taken to Correct Weaknesses Noted in Insp Rept 50-458/90-06
ML20056B2921990-08-14014 August 1990
Requests Submittal of Final Analysis of Combustible Gas Control Sys,Per 10CFR50.44,by 910301,addressing Key Elements in Encl SER
IR 05000458/19892001990-08-0909 August 1990
Discusses Insp Rept 50-458/89-200 on 891023-27 & 1113-17 & Forwards Notice of Violation
ML20056A7521990-08-0303 August 1990
Discusses Util 891220 Response to Generic Ltr 89-10 Re safety-related motor-operated Valve Testing & Surveillance. Util Schedule for Completing Phase I of motor-operated Valve Program in Four Refueling Outages Acceptable
ML20056A7681990-08-0202 August 1990
Ack Withdrawal of Proposed Amend to License NPF-47,allowing One Loop of RHR to Be Used for ECCS & for Shutdown Cooling. Util Resubmittal of Proposed Amend Following Completion of Generic Study Recommended
ML20058L5361990-08-0101 August 1990
Forwards Electrical Distribution Sys Functional Insp Rept 50-458/90-200 on 900521-0622 & Notice of Violation
ML20055G5241990-07-18018 July 1990
Forwards Fr Notice Re Util Withdrawal of 900202 Amend to License NPF-47,per .Amend Modifies Tech Specs Re Div I & II Diesel Generator Crankshaft Insp Scheduling & Surveillance Requirements
IR 05000458/19900411990-07-0505 July 1990
Ack Receipt of 900614 & 0209 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/90-41
ML20055D5211990-06-27027 June 1990
Forwards Insp Rept 50-458/90-14 on 900521-22.One self-identified Violation Noted But Not Cited
ML20055F1861990-06-27027 June 1990
Forwards Safety Evaluation Accepting Util Proposed Changes Re Scram Accumulator Check Valves
ML20055D0981990-06-25025 June 1990
Reviews Util 900406 Response to Violation Noted in Investigation Rept 50-458/90-43 Re Unescorted Access for Two Welding Svcs,Inc Employees to Plant Protected Area. Violation Properly Classified as Severity Level IV
ML20055D6581990-06-20020 June 1990
Ack Receipt of 900531 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/89-31
ML20059M9441990-06-13013 June 1990
Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl
ML20055D0021990-06-11011 June 1990
Discusses Util 900514 Application for Amend to License NPF-47,increasing Suppression Pool Temp from 95 F to 100 F. Requests That Util Demonstrate Applicability of Items Addressed in Encl Hatch Safety Evaluation to Facility
ML20055C3071990-02-23023 February 1990
Advises That 891027 Changes to Emergency Plan,Acceptable
ML20248A3051989-09-26026 September 1989
Forwards Insp Rept 50-458/89-33 on 890801-31.No Violations or Deviations Noted
ML20247Q7221989-09-22022 September 1989
Forwards FEMA Exercise Evaluation Rept of Plant Emergency Preparedness Exercise on 890301.No Deficiencies Observed During Exercise.W/O Encl
ML20248E5681989-09-21021 September 1989
Forwards Amend 3 to Indemnity Agreement B-104,reflecting Increase in Primary Layer of Nuclear Energy Liability Insurance
ML20247P4951989-09-19019 September 1989
Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/89-28
IR 05000458/19890181989-09-11011 September 1989
Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/89-18
ML20247D4661989-09-11011 September 1989
Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/89-27. Understands That Comparison of Expanded Unreviewed Safety Question Committee Data Base Will Be Reviewed by Committee
ML20247B0381989-09-0101 September 1989
Forwards Insp Rept 50-458/89-31 on 890701-31 & Notice of Violation
ML20247C3081989-09-0101 September 1989
Summarizes 890822 Meeting W/Util in Region IV Ofc to Discuss Results of INPO Evaluation of Facility.List of Attendees Encl
ML20247A1241989-08-30030 August 1989
Forwards Summary of Region Iv/Senior Util Executive Meeting on 890818.No plant-specific Issues Discussed at Meeting. Agenda & Attendees List Also Encl
ML20247A6751989-08-28028 August 1989
Advises That 890424 Rev 3 to ODCM Acceptable,Per Encl Eg&G Idaho,Inc Comments.Remaining Questions Re Rev 3 in Encl Should Be Considered in Next Rev
ML20246J0751989-08-21021 August 1989
Forwards Insp Rept 50-458/89-30 on 890619-23.Violation Noted
ML20245H6631989-08-0707 August 1989
Forwards Insp Rept 50-458/89-32 on 890717-21.No Violations or Deviations Noted
ML20245K0101989-08-0606 August 1989
Forwards Summary of 890727 Meeting W/Licensee in Region IV Ofc Re Plant Security Enhancement Program & Personnel Changes
ML20247N7601989-07-31031 July 1989
Informs That 890719 Request for Withdrawal of Proposed Tech Specs 3.5.2,3.7.1.1,3.7.1.2 & 3.9.11.1 Changes,Submitted by Ltr W/Other Proposed Changes,Approved.No Addl Work Will Be Performed by NRC
ML20247R2641989-07-28028 July 1989
Forwards Insp Rept 50-458/89-28 on 890601-30 & Notice of Violation.Notice of Violation Will Not Be Issued for Item Identified by Licensee
ML20247M2581989-07-27027 July 1989
Forwards Insp Rept 50-458/89-25 on 890710-14.No Violations or Deviations Noted
ML20247H4611989-07-26026 July 1989
Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-458/89-11
1990-08-09
[Table view]
Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217L7681999-10-19019 October 1999
Forwards Insp Rept 50-458/99-12 on 990822-1002.Four Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy
ML20217J3751999-10-15015 October 1999
Informs That Applicable Portions of NEDC-32778P, Safety Analysis Rept for River Bend 5% Power Uprate, Marked as Proprietary Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b)
IR 05000458/19990071999-10-0505 October 1999
Refers to Util Ltr Re Apparent Violations Described in Insp Rept 50-458/99-07 Issued on 990804 & Forwards Nov.Insp Described Two Apparent Violations Related to River Bend Station Division I EDG
ML20212D8901999-09-16016 September 1999
Discusses 6 Month Review of Plant Midcycle Ppr.Advises of Plans for Future Insp Activities.Forwards Historical Listing of Plant Issues,Referred to as PIM
ML20216F7881999-09-15015 September 1999
Forwards Insp Rept 50-458/99-10 on 990830-990903.No Violations Noted.Insp Covered Licensed Operators Requalification Training Program & Observation of Requalification Activities
ML20211Q7721999-09-0909 September 1999
Expresses Appreciation for ,In Response to NRC 990702 Re Denial of Notice of Violation Cited in Concerning Insp Rept 50-458/98-16.Reply Found to Be Responsive to Concerns Raised in NOV
ML20211Q3921999-09-0808 September 1999
Forwards Insp Rept 50-458/99-08 on 990711-0821.One Violation Being Treated as Noncited Violation
ML20211Q5541999-09-0808 September 1999
Discusses Meeting Conducted on 990830 in St Francisville,La Re Overall Performance Issues During 990403-0703 Refueling/ Maintenance Outage.Due to Proprietary Nature of Some Subject Matters,Meeting Closed to Public.Attendance List Encl
ML20211E2071999-08-23023 August 1999
Discusses Insp Rept 50-458/99-07 in Which 2 Violations Were Identified & Being Considered for Escalated Enforcement Action.Response Should Be Submitted Under Oath or Affirmation
ML20211A9291999-08-17017 August 1999
Forwards Insp Rept 50-458/99-11 on 990719-23.Areas Examined Included Portions of Licensee Physical Security Program. No Violations Noted
ML20210T8881999-08-16016 August 1999
Forwards Replacement Pages 9-18 for Insp Rept 50-458/99-09, Issued on 990730
IR 05000458/19980101999-08-13013 August 1999
Forwards Summary of 990805 Mgt Meeting with Licensee in Arlington,Tx Re Radiological Control Problems Noted in Insp Repts 50-458/98-10 & 50-458/99-04.With Attendance List & Licensee Presentation
ML20211A9501999-08-12012 August 1999
Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl
ML20210U3751999-08-12012 August 1999
Informs That Info Contained in Presentation, River Bend Station Fuel Recovery Project,Dtd 990622, Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act of 1954,as Amended
ML20210Q7691999-08-11011 August 1999
Forwards Request for Addl Info Re Licensee River Bend Individual Plant Exam External Events,Under GL 88-20,suppl 4,dtd 910628
ML20210R4591999-08-10010 August 1999
Ack Receipt of Which Transmitted Plant Emergency Plan,Rev 20 Under Provisions of 10CFR50,App E,Section V.Nrc Approval Not Required,Based on Determination That Changes Does Not Decrease Effectiveness of EP
ML20210N1641999-08-0404 August 1999
Forwards Insp Rept 50-458/99-07 on 990530-0710.One Violation of NRC Requirements Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy
ML20210K4641999-08-0303 August 1999
Forwards SE Accepting Licensee 180-day Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Power-Operated Gate Valves, Issued on 950817
ML20210L1461999-08-0303 August 1999
Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams
ML20210K1351999-07-30030 July 1999
Forwards Insp Rept 50-458/99-09 on 990510-28 with in-office Insp Until 990701.Three Violations Being Treated as Noncited Violations
ML20210J9691999-07-30030 July 1999
Discusses 990719 Meeting with Util in Arlington,Tx Re Region IV Staff Findings of Root Cause Investigation Into Fuel Cladding Failures That Occurred During Recent Cycle 8 Operation.List of Attendees & Organization Chart Encl
ML20210E9001999-07-23023 July 1999
Informs That as Result of Staff Review of Licensee Responses to GL 92-01,rev 1,Suppl 1 & Suppl 1 Rai,Staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2
ML20196L0501999-07-0606 July 1999
Informs That NRC Insp Rept 50-458/99-03 Issued on 990519 with Errors in Tracking Numbers Assigned to Seven Noncited Violations & Error Re Actual Location of SRO During Refueling Activities.Revised Pages 2 & 4 Encl
ML20196K6851999-06-30030 June 1999
Ack Receipt of & Denial of NOV in Response to Transmitting NOV & Insp Rept 50-458/98-16.Listed Info Documents Results of Review of Response to Violation Re fire-induced Circuit Faults
ML20196K0671999-06-30030 June 1999
Forwards Insp Rept 50-458/99-04 on 990412-16 & 28-29.Five Violations of NRC Requirements Occurred & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy.Meeting Scheduled for 990726
ML20196E0601999-06-18018 June 1999
Forwards Insp Rept 50-458/99-05 on 990418-29.Four Violations Identified & Being Treated as Noncited Violations
ML20195G3121999-06-0909 June 1999
Ack Receipt of Re Changes to River Bend Station Emergency Plan,Rev 19.No Violations of 10CFR50.47(b) Were Identified
ML20195G3671999-06-0909 June 1999
Ack Receipt of Ltr Dtd 981016,which Transmitted River Bend Station Emergency Plan,Rev 18 Under Provision of 10CFR50, App E,Section V.No Violations of 10CFR50.54(q) Identified During Review
ML20195D6041999-06-0303 June 1999
Discusses EOI Request That Attachment 4,NEDC-32549P, Safety Review for River Bend Station Cycle 7 Final Feedwater Temp Reduction, Rev 0,be Withheld from Public Disclosure. Determined Info Proprietary & Will Be Withheld
DD-99-08, Informs That to Extent That Union of Concerned Scientists Requests Commission Undertake Formal Review of DD-99-08 & Hold Meeting to Directly Receive View on Decision,Request Denied.With Certificate of Svc.Served on 9905211999-05-20020 May 1999
Informs That to Extent That Union of Concerned Scientists Requests Commission Undertake Formal Review of DD-99-08 & Hold Meeting to Directly Receive View on Decision,Request Denied.With Certificate of Svc.Served on 990521
ML20206U4321999-05-18018 May 1999
Forwards Notice of Withdrawal of Licensee 961106 Request for Approval of Deviation from Approved Fire Protection Program to Extent Program Incorporated Technical Requirements of Section III.G.2 of App R to 10CFR50
ML20206U6081999-05-18018 May 1999
Forwards Insp Rept 50-458/99-03 on 990307-0417.Eight Violations of NRC Requirements Identified & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy
ML20207A8051999-05-15015 May 1999
Forwards Insp Rept 50-458/99-06 on 990419-23.No Violations Noted.Inservice Insp Activities at River Bend Station Were Being Implemented in Accordance with ASME Code & Regulatory Requirements
ML20206N7081999-05-12012 May 1999
Informs That NRC Ofc of NRR Reorganized,Effective 990328. Reorganization Chart Encl
ML20206N8811999-05-12012 May 1999
Forwards Notice of Withdrawal of 981120 Amend Request for License NPF-47.Proposed Amend Would Have Established New TS 3.10.9, Control Rod Pattern - Cycle 8, Added to Section 3.10, Special Operations
ML20206H9191999-05-0707 May 1999
Informs That on 990407,NRC Administered Generic Fundamentals Exam Section of Written Operators Licensing Exam.Facility Did Not Participate in Exam,However Copy of Master Exam with Key Encl.Without Encl
NUREG-1434, Discusses Licensee 960418 Request for Amend for Plant That Would Permit Addl Method of Fuel Movement & Loading in Core Upon Removal of Control Rods from Defueled Core Cells.Nei TSs Task Force Process Will Be Used to Review TSTF-2261999-05-0505 May 1999
Discusses Licensee 960418 Request for Amend for Plant That Would Permit Addl Method of Fuel Movement & Loading in Core Upon Removal of Control Rods from Defueled Core Cells.Nei TSs Task Force Process Will Be Used to Review TSTF-226
ML20206J2291999-05-0303 May 1999
Discusses Responding to NOV Issued on 990105.NOV Was Based on NRC Conclusions That Licensee Provided NRC Inspector with Info Licensee Knew Was Inaccurate & Incomplete
ML20206E6381999-05-0303 May 1999
Ack Receipt of 990305,990315 & s Responding to NOV & Proposed Imposition of Civil Penalty, .EOI Paid Civil Penalty & Requested Withdrawal of NOV & Civil Penalty for Reasons Stated.Finds NOV & Civil Penalty Appropriate
ML20206E4531999-04-27027 April 1999
Discusses Request That Attachment 4, Final Calculation of RBS Cycle 9 SLMCPR (Safety Limit for Mcpr), Submitted with 981216 License Amend Request,Be Withheld from Public Disclosure.Determined Info Proprietary & Will Be Withheld
ML20206A2031999-04-21021 April 1999
Discusses EOI Second 10-year IST Program for River Bend Station Submitted on 980106 & 980910 Which Included One Pump Relief Request & Two Valve Relief Requests.Forwards SE Authorizing Pump Relief Request & One Valve Relief Request
ML20205N7251999-04-13013 April 1999
Forwards Summary of 990408 Meeting with EOI in Jackson, Mississippi Re EOI Annual Performance Assessment of Facilities & Other Issues of Mutual Interest.List of Meeting Attendees & Licensee Presentation Slides Encl
ML20205J5331999-04-0606 April 1999
Ack Receipt of Denying Request from NRC That Addl Info Be Provided Prior to Informal Public Hearing Held on 990222 Re River Bend Station & Perry Nuclear Power Plant 10CFR2.206 Petitions
ML20205K0681999-04-0505 April 1999
Submits Summary of 990325 Meeting Re Engineering Performance at Site & Assessment of Organization Strengths & Opportunities for Improvement.List of Attendees & Matl Used in Presentation Enclosed
ML20205A4531999-03-26026 March 1999
Forwards Insp Rept 50-458/98-10 on 990222-26.Violation Noted & Being Treated as Non-Cited Violation.Concludes That Radiation Work Permit Program Poorly Implemented Until July 1998 Because of Inadequate Program Implementing Procedures
ML20205D7691999-03-26026 March 1999
Forwards Insp Rept 50-458/99-02 on 990124-0306.One Violation Identified & Being Treated as non-cited Violation.Licensee Conduct of Activities During Insp Generally Characterized by safety-conscious Operations & Sound Engineering
ML20205D5361999-03-26026 March 1999
Forwards Ser,Accepting Util 980107 Request for Alternative to Augmented Reactor Pressure Vessel Exam Requirements for Plant,Unit 1 Pursuant to 10CFR50.55a(g)(6)(ii)(A) for First 10-year Insp Interval.Technical Ltr Rept Also Encl
ML20204G8081999-03-24024 March 1999
Refers to 990303 Reply to NRC NOV & Proposed Imposition of Civil Penalty .Since Licensee Paid Civil Penalty & C/A Found Responsive to NRC Concerns,Matter Considered Closed
ML20205A4021999-03-23023 March 1999
Forwards Insp Rept 50-458/99-301 on 990222-0303.No Violations Noted.Insp Included Evaluation of Three Applicants for Senior Operator Upgrade & for Senior Operator Instant & Eight Applicants for Reactor Operator License
ML20205F3131999-03-19019 March 1999
Advises of Planned Insp Effort Resulting from River Bend PPR Review,Which Was Completed on 990211.Performance of River Bend Staff During Assessment Period Was Acceptable
1999-09-09
[Table view] |
Text
_ __ - . - - _ - - _ _ _ - - - - - - _ _ - -
,
-
i
. . ,
.
HN AY In Reply Refer To:
Docket: 50-458/88-26 Gulf States Utilities ATTN: fir. James C. Deddens Senior Vice President (RBNG)
P.O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:
Thank you for your letter of April 17, 1989, in response to our letter and Notice of Violation dated March 17, 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 Sincerel Onginal Signed Bp t 3: CALLAN L. J. Callan, Director Division of Reactor Projects cc:
Gulf States Utilities ATTN: J. E. Booker, Manager-River Bend Oversight P.O. Box 2951 Beaumont, Texas 77704 Gulf States Utilities ATTN: Les England, Director ,
Nuclear Licensing - RBNG !
P.O. Box 220 St. Francisville, Louisiana 70775 Louisiana State University, Government Documents Department Louisiana Radiation Control Program Director bec to DMB (IE01)
RIV:DRP/C C: d D:DR \\
GLMadsen;df GLC6nstable LJCa n g 5/.g/89 5/y/89 0 5/3 /89$1 / ./
8905160179 870504 N
{DR ADOC1' 05000458
_
PDC j
_ _ - - - _ . . _ _ - _ - --
.. .
,.,,,
j ^/
~'
'.
.
L*
-
... -
r,
,
,
I . Gulf States Utili.tiies, -2-
/
bec.distrib by RIV:-
l DRP RRI'. . .
'R. D. Martin, RA
'
SectionChief-(DRP/C)-
Lisa'Shea,RM/ALF ' MIS System RPB-DRSS' RSTS Operator Project Engineer (DRP/C)' RIV File W. Paulson, NRR Project Manager (MS: 13-D-18) DRS o
i I
_ _ - _ - _ - - _ _ _ - _ - _ _ - _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ . _ - _ - _ . _
- , .
.
- -
- -
.:
GULF STATES UTILITIES COMPANY
.g RIVER DEND STATION POST OFFICE 80x 220 ST FRANCISVILLE. LOUISIANA 70776 ARE A CODE 604 636 6094 346 8661
April 17, 1989 N I RBG-30552 jj File Nos. G9.5, G15. I
- . . 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/ Report 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 GSU's response to the violations are provided in the attachment This completes GSU's response to these item Should you have any questions, please contact Mr. England at(504)381-414 S ncerely
/ / tv
/ . C. Deddens Senior Vice President
,
River Bend Nuclear Group JEB/LAE/RJK/JWC/ch cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Senior Resident Inspector P. O. Box 1051 i St. Francisville, LA 70775 ;
__ $W _ _ _ _ _ _ _ _ _ _ _ _ . _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ -
- - _ _ - - .. . _ _ - _ _ _ _ - - - _ _ - _
_ _ - _ _ _ _ _ _ - _ _ - _ - - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
..
.
. . ,.
d , .. -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA )
PARISH OF WEST FELICIANA )
In the Matter of ) Docket No. 50-458 50-459
^
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; tha .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 belie D * * > --
J.#C. Deddens Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this [7Ybdayof ddClr 0 h , 19 ,
l ,e y bW an Middlebrooks
'
W .
l
/J otary Public in and for West Feliciana Parish, I
Louisiana My Commission is for Life.
!.
,
_ _ . - . . _ _ _ _ _ _ - _ _ _ - _ - _ _
- ________ __ _ - _ __
- ' ,
.
. . ,.
s ,, .-
ATTACHMENT 1 Response to Notice of Violation 50-458/8826-01 t
Level IV Violation REFERENCE: Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated March 17, 198 . Licensee Event Report No.88-027 - to NRC from J. E. Booker, dated January 18, 1989 FAILURE TO ENSURE RCIC SYSTEM OPERABILITY:
l 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 psi 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 configuratio 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 desig 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 plac Investigation of historical documents shows that the portion of the original modification to install the lock wire and dowel pins was complete 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 worke 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
. backlog of unprioritized MRs reduced to a manageable level by the end of 198 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 i reduction effor All modifications as a result of condition report corrective actions have been reviewed and prioritize Less than 75 modification requests remain in the balance of the program. These 75 MRs have been screened by Design Engineering and none have been determined to have an impact on operabili^. Page 1 of 3
.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . . _ _ _ _ _ _ _ _ _ _ _ . _ _ __ _ .__ __a
_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - -
, .
I-
. . ,
'
Tfie 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 quickl 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, 198 As identified above, the inadequate installation was initially identified as a direct result of an internal audit of incomplete construction modification All open MRs which have not been prioritized have been screened by Design Engineering and none have been determined to have an impact on operabilit 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 isolate An assessment of the safety implications have shown the effects of the incomplete construction modification to be minimal. The RCIC system provides redundancy to ttle 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 ir, this emergency safety feature (ESF)
capacity since the RBS design includes an automatic depressurization system (ADS). ADS provides the required redundancy to HPC 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.
l l Seismic qualification tests were conducted on the prototype test turbine at much higher accelerations than those assumed for RBS for either an operat 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 r.ot 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, i 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 even Therefore, the safe operation of the plant and the health and safety of the public were not adversely affected as a result of this even (For additional details of assessment of safety implications, refer to Reference 2.)
Page 2 of 3 U___ _ _ - __ _ ___ -__ -_ - ________---_-_ _______ .__ _ _ __ _ _ _ _ _ _ - _ - _ _ _ _ _
___ _
..
.
. - .
,
-'
.. .
'
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
' A comprehensive 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 prioritized for implementation accordingl DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
RBS is currently in full compliance.
I i
{
l
!
Page 3 of 3
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ __ _ _ _ _ _ _ . _ _ - . _ _ - _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ - _
i j
.- 1 '
- -
.
,
ATTACIMENT 2 Response to Notice of Violation 50-458/8826-02 Level IV Violation REFERENCE:
Notice of Violation - Letter from R. D. Martin to to Deddens, dated March 17, 198 FAILURE TO SECURE A VHRA ACCESS DOOR:
RBS TS 6.12.2 requires that accessible areas with radiation levels, such that a major portion of the body could receive in I 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 superviso ,
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 are 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 time 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 secure TB 123-20 was not attended during the period the door was left unsecure Seven cdditional examples of events where VHRA access doors were previously left unsecured are identified in NRC Inspection Report 50-458/88-2 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 key The Shift Supervisor and the COF 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 exi Investigation was inconclusive as to who failed to ensure that these doors were secured upon exiting. The root causes of this problen are the failure on the part of the individual to verify that the doors were secured and ineffective controls to prevent recurrence.
l Page 1 of 2
.
- ___ _ __-_-_ _ -______ . _ _ _ _ _ _
.
.
'
i ,
. '.*
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
All VHRA doors were locked upon discover Numerous programmatic controls and corrective actions have been implemented since initial plant operation to ensure that these doors are secured upon exi Increasingly stringent controls failed to produce the desired resul 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 VHRA 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 changes that were implemented require that 1) only radiation protection personnel will be issued keys to VHRA doors for routine access, 2) RP personnel will log the opening and locking of VHRA doors and is responsible for verification of locked 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 monthl In addition to the above, Security also physically verifies twice daily that accessible VHRA doors are locke 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 progra The improved, more stringent administrative controls established for routine access to VHRA should prevent any future violation DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
RBS is currently in full complianc Page 2 of 2
_ _ _ _ _ _ _ - - _ _ - _ - _ . _ _ - _ . _ - _
_ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ -
..
.
.
.; ,
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, 198 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 I 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 event 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 operatio CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
I 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: l 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 door DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
'
The appropriate RBS supervisors as identified above will be informed by May 15, 1989 of the deportability of these event Page 1 of 1
,
- - - - . - - - - . - - . . - . . _ _ - - - _ - _ _ _ - - _ - _ _ - _ _
