IR 05000458/1988026

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

ML20247G365
Person / Time
Site:	River Bend
Issue date:	03/17/1989
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
Shared Package
ML20247G371	List: IR 05000458/1988026 ML20247G373
References
EA-89-010, EA-89-10, NUDOCS 8904040205
Download: ML20247G365 (3)

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\ NUCLEAR REGULATORY COMMISSION f8 Rt040N IV 4 Sit RYAN PLAaA DRIVE. SulTE 1000 ARLINGTON, TEXAS 75011

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uan I T 19m Docket No. 50-458/88-26 Lic:nse No. NPF-47 -

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Culf States Utilities ATTN: Mr. James C. Deddens Senior Vice President (R8NG),

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

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-458/88-26)

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

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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 .

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-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, ,

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 '

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.- 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-

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Sincerely,

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Robert D. Martin Regional Administrator Rtc-le9 3- -

i: 'P;'!! Enclosure:

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Radiation Control Program Director _