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{{Adams | |||
| number = ML20246H733 | |||
| issue date = 05/04/1989 | |||
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/88-26 | |||
| author name = Callan L | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = Deddens J | |||
| addressee affiliation = GULF STATES UTILITIES CO. | |||
| docket = 05000458 | |||
| license number = | |||
| contact person = | |||
| document report number = NUDOCS 8905160179 | |||
| title reference date = 04-17-1989 | |||
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE | |||
| page count = 2 | |||
}} | |||
See also: [[see also::IR 05000458/1988026]] | |||
=Text= | |||
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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 maintained. | |||
Sincerely. | |||
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 | |||
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GULF STATES UTILITIES COMPANY | |||
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RIVER DEND STATION POST OFFICE 80x 220 ST FRANCISVILLE. LOUISIANA 70776 | |||
ARE A CODE 604 636 6094 346 8661 | |||
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April 17, 1989 N I | |||
RBG-30552 jj | |||
File Nos. G9.5, G15.4.1 | |||
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- . . | |||
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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 1. | |||
GSU's response to the violations are provided in the attachments. | |||
This completes GSU's response to these items. | |||
Should you have any questions, please contact Mr. L. A. England | |||
at(504)381-4145. | |||
S ncerely | |||
/ / 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 ; | |||
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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; that. | |||
.he is authorized on. the part of said company to sign and | |||
file with the Nuclear Regulatory Commission the documents | |||
attached hereto; and that all such documents are true and | |||
correct to the best of' his knowledge, information' and | |||
belief. | |||
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 N. | |||
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/J otary Public in and for | |||
West Feliciana Parish, | |||
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Louisiana | |||
My Commission is for Life. | |||
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ATTACHMENT 1 | |||
Response to Notice of Violation 50-458/8826-01 | |||
t | |||
Level IV Violation | |||
REFERENCE: | |||
1. Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated | |||
March 17, 1989. | |||
2. Licensee Event Report No. 88-027 - to NRC from J. E. Booker, dated January | |||
18, 1989 | |||
FAILURE TO ENSURE RCIC SYSTEM OPERABILITY: | |||
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 psig. | |||
Contrary to the above, RBS was operated in Operational Conditions 1, 2, and 3 | |||
during the period November 1985 to December 19, 1988, with the RCIC system | |||
inoperable. .The RCIC system was considered inoperable because the turbine | |||
configuration was not in accordance with the seismically tested-design | |||
configuration. | |||
REASON FOR VIOLATION: | |||
During a review by the Design Engineering group to prioritize outstanding | |||
modification packages it was noted that the installation of the RCIC system | |||
turbine was not completed per design. Contrary to its seismic qualification | |||
requirements, an oil piping support addition had not been completed, the | |||
coupling pedestal bolting had not been lockwired, and the pedestal dowel pins | |||
were not in place. | |||
Investigation of historical documents shows that the portion of the original | |||
modification to install the lock wire and dowel pins was completed. However, | |||
in a subsequent realignment of the turbine, the dowel pins would no longer | |||
fit. A new modification using new dowel pin locations .was initiated to | |||
complete the original modification. This MR was found not to be worked. | |||
The scope of the management effort to reduce the backlog level of | |||
unprioritized MRs was established in response to two primary actions: | |||
(1) corrective action to NRC Inspection Report 88-01, to review all MRs | |||
generated as a result of corrective actions identified on condition reports | |||
and provide recommendations for prioritization (schedule) by 12/31/88, and (2) | |||
a commitment to.the Institute of Nuclear Power Operations (INP0) to have the | |||
. backlog of unprioritized MRs reduced to a manageable level by the end of 1988. | |||
The subject MR was not initiated as a result of the condition report program; ; | |||
it was a construction modification which was included in the balance of the i | |||
reduction effort. All modifications as a result of condition report | |||
corrective actions have been reviewed and prioritized. 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^.y. | |||
Page 1 of 3 | |||
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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 quickly. | |||
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED: | |||
The RCIC system was declared inoperable at 1700 on December 19, 1988. A | |||
condition report was written and the proper installation was completed on | |||
December 24, 1988. After satisfactory retest, the RCIC system was restored to | |||
operable status at 1245 on December 24, 1988. | |||
As identified above, the inadequate installation was initially identified as a | |||
direct result of an internal audit of incomplete construction modifications. | |||
All open MRs which have not been prioritized have been screened by Design | |||
Engineering and none have been determined to have an impact on operability. | |||
The identification of this deficiency and subsequent corrective action is | |||
indicative of GSU's improvement in the MR document control and administrative | |||
control areas. This review also confirmed that the operability oversight for | |||
incomplete construction modifications which had been tracked on system punch | |||
lists was isolated. | |||
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 HPCS. | |||
No operability or functional problems related to this incomplete modification | |||
have been identified. Operation of the RCIC turbine and pump for quarterly | |||
surveillance test procedures, both before and after completion of the | |||
modification, has been acceptable. Additionally, the RCIC system has | |||
experienced two automatic initiations and in each case the RCIC system | |||
performed as designed. Therefore, the operability of the RCIC system under | |||
normal plant conditions without a seismic event is not questionable. | |||
l | |||
l Seismic qualification tests were conducted on the prototype test turbine at | |||
much higher accelerations than those assumed for RBS for either an operata.g | |||
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 event. Therefore, | |||
the safe operation of the plant and the health and safety of the public were | |||
not adversely affected as a result of this event. (For additional details of | |||
assessment of safety implications, refer to Reference 2.) | |||
Page 2 of 3 | |||
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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 accordingly. | |||
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: | |||
RBS is currently in full compliance. | |||
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Page 3 of 3 | |||
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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 J. C. Deddens, dated | |||
March 17, 1989. | |||
-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 supervisor. , | |||
Doors shall remain locked, except during periods of access under an approved : | |||
radiation work procedure (RWP) that specifies the dose rate levels in the | |||
' | |||
immediate work area and the maximum allowable stay time for individuals in | |||
that area. | |||
Radiation Protection Procedure RPP-0005, " Posting of Radiologically Controlled | |||
Areas," Revision 5, paragraph 7.4, requires that very high radiation area | |||
(VHRA). entrances be locked and remain locked, except during periods of access | |||
under an approved RWP. Doors must be locked or attended at all times. | |||
Contrary to the above, on December 3,1988, from approximately 7:45 a.m. to | |||
4:30 p.m. (CST), turbine building door TB 123-20, which provided access to a | |||
VHRA around the moisture separator reheater tank, was not properly secured. | |||
TB 123-20 was not attended during the period the door was left unsecured. | |||
Seven cdditional examples of events where VHRA access doors were previously | |||
left unsecured are identified in NRC Inspection Report 50-458/88-26. | |||
REASON FOR VIOLATION: | |||
During normal full power operations, fifty-six (56) doors must be controlled | |||
as VHRAs. Locks for all VHRA doors may be opened by one of a limited number | |||
of identical keys. The Shift Supervisor and the 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 exit. | |||
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 | |||
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED: | |||
All VHRA doors were locked upon discovery. | |||
Numerous programmatic controls and corrective actions have been implemented | |||
since initial plant operation to ensure that these doors are secured upon | |||
exit. Increasingly stringent controls failed to produce the desired result. | |||
On December 7, 1988, the Plant Manager issued memorandum TFP-251-88 to | |||
supervisors emphasizing the serious nature regarding VHRA doors and | |||
establishing more stringent administrative guidelines for routine access to | |||
VHRAs. On December 9, 1988, procedure RPP-005, " Posting Radiologically | |||
Controlled Areas", was revised by TCN 88-0782 to incorporate the Plant | |||
Manager's guidelines. The 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 monthly. | |||
In addition to the above, Security also physically verifies twice daily that | |||
accessible VHRA doors are locked. | |||
CORRECTIVE, STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS: | |||
No VHRA doors have been discovered unsecured and unattended since the | |||
implementation of the present program. | |||
The improved, more stringent administrative controls established for routine | |||
access to VHRA should prevent any future violations. | |||
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: | |||
RBS is currently in full compliance. | |||
Page 2 of 2 | |||
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ATTACMENT 3 | |||
Response to Notice of Violation 50-458/8826 | |||
Level IV Violation | |||
REFERENCE: | |||
Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated | |||
March 17, 1989. | |||
VIOLATION C: | |||
10CFR 50.73 requires licensees to submit licensee event reports (LERs) to NRC | |||
within 30 days of the discovery of events which are described in this | |||
regulation. Among the events licensees are required to report is "Any | |||
operation or condition prohibited by the plant's Technical Specifications ..." | |||
RBS TS 6.12.2, "High Radiation Area," states that, " areas with radiation | |||
levels such that a major portion of the body could receive in 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 events. | |||
REASON FOR THE VIOLATION: | |||
GSU has previously interpreted NUREG-1022, " Licensee Event Reporting System", | |||
such that violation of this administrative section of the TSs need not be | |||
reported since the condition does not affect plant operation. | |||
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED: | |||
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 doors. | |||
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: | |||
1 | |||
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The appropriate RBS supervisors as identified above will be informed by May | |||
15, 1989 of the deportability of these events. | |||
Page 1 of 1 | |||
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}} |
Latest revision as of 21:55, 31 January 2022
ML20246H733 | |
Person / Time | |
---|---|
Site: | River Bend ![]() |
Issue date: | 05/04/1989 |
From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | Deddens J GULF STATES UTILITIES CO. |
References | |
NUDOCS 8905160179 | |
Download: ML20246H733 (2) | |
See also: IR 05000458/1988026
Text
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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 maintained.
Sincerely.
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
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i
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_ _ - _ - _ - - _ _ _ - _ - _ _ - _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ . _ - _ - _ . _
- , .
.
- -
- -
.:
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, G15.4.1
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 1.
GSU's response to the violations are provided in the attachments.
This completes GSU's response to these items.
Should you have any questions, please contact Mr. L. A. England
at(504)381-4145.
S ncerely
/ / tv
/ . C. Deddens
Senior Vice President
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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 ;
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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)
J. C. Deddens, being duly sworn, states that he'is a
Senior Vice President of Gulf States Utilities Company; that.
.he is authorized on. the part of said company to sign and
file with the Nuclear Regulatory Commission the documents
attached hereto; and that all such documents are true and
correct to the best of' his knowledge, information' and
belief.
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 N.
,
l ,e y
bW an W.
-
Middlebrooks
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W .
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/J otary Public in and for
West Feliciana Parish,
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My Commission is for Life.
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ATTACHMENT 1
Response to Notice of Violation 50-458/8826-01
t
Level IV Violation
REFERENCE:
1. Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated
March 17, 1989.
2. Licensee Event Report No.88-027 - to NRC from J. E. Booker, dated January
18, 1989
FAILURE TO ENSURE RCIC SYSTEM OPERABILITY:
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RBS Technical Specifications (TS) Limiting Condition for Operation (LCO)
3.4.7.3 requires that the reactor core isolation cooling -(RCIC) system be
operable in Operational Conditions 1, 2, and 3 with reactor steam dome
pressure greater than 150 psig.
Contrary to the above, RBS was operated in Operational Conditions 1, 2, and 3
during the period November 1985 to December 19, 1988, with the RCIC system
inoperable. .The RCIC system was considered inoperable because the turbine
configuration was not in accordance with the seismically tested-design
configuration.
REASON FOR VIOLATION:
During a review by the Design Engineering group to prioritize outstanding
modification packages it was noted that the installation of the RCIC system
turbine was not completed per design. Contrary to its seismic qualification
requirements, an oil piping support addition had not been completed, the
coupling pedestal bolting had not been lockwired, and the pedestal dowel pins
were not in place.
Investigation of historical documents shows that the portion of the original
modification to install the lock wire and dowel pins was completed. However,
in a subsequent realignment of the turbine, the dowel pins would no longer
fit. A new modification using new dowel pin locations .was initiated to
complete the original modification. This MR was found not to be worked.
The scope of the management effort to reduce the backlog level of
unprioritized MRs was established in response to two primary actions:
(1) corrective action to NRC Inspection Report 88-01, to review all MRs
generated as a result of corrective actions identified on condition reports
and provide recommendations for prioritization (schedule) by 12/31/88, and (2)
a commitment to.the Institute of Nuclear Power Operations (INP0) to have the
. backlog of unprioritized MRs reduced to a manageable level by the end of 1988.
The subject MR was not initiated as a result of the condition report program; ;
it was a construction modification which was included in the balance of the i
reduction effort. All modifications as a result of condition report
corrective actions have been reviewed and prioritized. 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^.y.
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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 quickly.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
The RCIC system was declared inoperable at 1700 on December 19, 1988. A
condition report was written and the proper installation was completed on
December 24, 1988. After satisfactory retest, the RCIC system was restored to
operable status at 1245 on December 24, 1988.
As identified above, the inadequate installation was initially identified as a
direct result of an internal audit of incomplete construction modifications.
All open MRs which have not been prioritized have been screened by Design
Engineering and none have been determined to have an impact on operability.
The identification of this deficiency and subsequent corrective action is
indicative of GSU's improvement in the MR document control and administrative
control areas. This review also confirmed that the operability oversight for
incomplete construction modifications which had been tracked on system punch
lists was isolated.
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 HPCS.
No operability or functional problems related to this incomplete modification
have been identified. Operation of the RCIC turbine and pump for quarterly
surveillance test procedures, both before and after completion of the
modification, has been acceptable. Additionally, the RCIC system has
experienced two automatic initiations and in each case the RCIC system
performed as designed. Therefore, the operability of the RCIC system under
normal plant conditions without a seismic event is not questionable.
l
l Seismic qualification tests were conducted on the prototype test turbine at
much higher accelerations than those assumed for RBS for either an operata.g
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
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conditions without a seismic event. Additionally, an evaluation comparing the
as-found installation with the original seismic qualification tests indicates
that the RCIC system would not have failed during a seismic event. Therefore,
the safe operation of the plant and the health and safety of the public were
not adversely affected as a result of this event. (For additional details of
assessment of safety implications, refer to Reference 2.)
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
' A 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 accordingly.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
RBS is currently in full compliance.
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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 J. C. Deddens, dated
March 17, 1989.
-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 supervisor. ,
Doors shall remain locked, except during periods of access under an approved :
radiation work procedure (RWP) that specifies the dose rate levels in the
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immediate work area and the maximum allowable stay time for individuals in
that area.
Radiation Protection Procedure RPP-0005, " Posting of Radiologically Controlled
Areas," Revision 5, paragraph 7.4, requires that very high radiation area
(VHRA). entrances be locked and remain locked, except during periods of access
under an approved RWP. Doors must be locked or attended at all times.
Contrary to the above, on December 3,1988, from approximately 7:45 a.m. to
4:30 p.m. (CST), turbine building door TB 123-20, which provided access to a
VHRA around the moisture separator reheater tank, was not properly secured.
TB 123-20 was not attended during the period the door was left unsecured.
Seven cdditional examples of events where VHRA access doors were previously
left unsecured are identified in NRC Inspection Report 50-458/88-26.
REASON FOR VIOLATION:
During normal full power operations, fifty-six (56) doors must be controlled
as VHRAs. Locks for all VHRA doors may be opened by one of a limited number
of identical keys. The Shift Supervisor and the 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 exit.
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.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
All VHRA doors were locked upon discovery.
Numerous programmatic controls and corrective actions have been implemented
since initial plant operation to ensure that these doors are secured upon
exit. Increasingly stringent controls failed to produce the desired result.
On December 7, 1988, the Plant Manager issued memorandum TFP-251-88 to
supervisors emphasizing the serious nature regarding VHRA doors and
establishing more stringent administrative guidelines for routine access to
VHRAs. On December 9, 1988, procedure RPP-005, " Posting Radiologically
Controlled Areas", was revised by TCN 88-0782 to incorporate the Plant
Manager's guidelines. The 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 monthly.
In addition to the above, Security also physically verifies twice daily that
accessible VHRA doors are locked.
CORRECTIVE, STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No VHRA doors have been discovered unsecured and unattended since the
implementation of the present program.
The improved, more stringent administrative controls established for routine
access to VHRA should prevent any future violations.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
RBS is currently in full compliance.
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ATTACMENT 3
Response to Notice of Violation 50-458/8826
Level IV Violation
REFERENCE:
Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated
March 17, 1989.
VIOLATION C:
10CFR 50.73 requires licensees to submit licensee event reports (LERs) to NRC
within 30 days of the discovery of events which are described in this
regulation. Among the events licensees are required to report is "Any
operation or condition prohibited by the plant's Technical Specifications ..."
RBS TS 6.12.2, "High Radiation Area," states that, " areas with radiation
levels such that a major portion of the body could receive in 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 events.
REASON FOR THE VIOLATION:
GSU has previously interpreted NUREG-1022, " Licensee Event Reporting System",
such that violation of this administrative section of the TSs need not be
reported since the condition does not affect plant operation.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
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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.
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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 doors.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
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The appropriate RBS supervisors as identified above will be informed by May
15, 1989 of the deportability of these events.
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