|
---|
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:INCOMING CORRESPONDENCE
MONTHYEARRBG-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 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 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 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 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 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-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 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 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 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 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 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 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 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 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 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 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 05000458/LER-1999-010, Forwards LER 99-010-00 for River Bend Station,Unit 1 IAW 10CFR50.73.Commitments Identified in Rept,Encl1999-05-28028 May 1999 Forwards LER 99-010-00 for River Bend Station,Unit 1 IAW 10CFR50.73.Commitments Identified in Rept,Encl RBG-45021, Informs That Cycle 9 Operation Will Remain within MCPR Safety Limits Approved in Amend 105 to TS Issued by NRC in1999-05-26026 May 1999 Informs That Cycle 9 Operation Will Remain within MCPR Safety Limits Approved in Amend 105 to TS Issued by NRC in 05000458/LER-1999-009, Forwards LER 99-009-00 IAW 10CFR50.73.Commitments Contained in Ltr Are Identified on Commitment Identification Form1999-05-24024 May 1999 Forwards LER 99-009-00 IAW 10CFR50.73.Commitments Contained in Ltr Are Identified on Commitment Identification Form RBG-45017, Informs NRC of Addition of ASME Boiler & Pressure Vessel Code,Section Xi,Code Case N-496-1 to RBS Inservice Insp Program.Commitment Made by Util,Encl1999-05-14014 May 1999 Informs NRC of Addition of ASME Boiler & Pressure Vessel Code,Section Xi,Code Case N-496-1 to RBS Inservice Insp Program.Commitment Made by Util,Encl ML20206N1921999-05-10010 May 1999 Provides Revised Attachment 2 for Alternative Request IWE-02,originally Submitted 990429 Re Bolt Torque or Tension Testing of Class Mc pressure-retaining Bolting as Specified in Item 8.20 of Article IWE-2500,Table IWE-2500-1 05000458/LER-1999-007, Forwards LER 99-007-00 IAW 10CFR50.73.Commitments Identified in LER Are Noted in Attachment 11999-05-10010 May 1999 Forwards LER 99-007-00 IAW 10CFR50.73.Commitments Identified in LER Are Noted in Attachment 1 05000458/LER-1999-006, Forwards LER 99-006-00 Re Unplanned Automatic Standby Svc Water Initiation,Due to Procedure Inadequacy.Commitments Identified in Rept Noted in Attachment 11999-05-0606 May 1999 Forwards LER 99-006-00 Re Unplanned Automatic Standby Svc Water Initiation,Due to Procedure Inadequacy.Commitments Identified in Rept Noted in Attachment 1 05000458/LER-1999-005, Forwards LER 99-005-00 IAW 10CFR50.73(a)(2)(i).Commitments Identified in LER Are Noted in Attachment 11999-05-0303 May 1999 Forwards LER 99-005-00 IAW 10CFR50.73(a)(2)(i).Commitments Identified in LER Are Noted in Attachment 1 RBG-44993, Forwards RBS Annual Individual Monitoring Rept for Jan-Dec 1998,per Requirements of 10CFR20.2206(b).File Info Listed. Without Encl1999-04-30030 April 1999 Forwards RBS Annual Individual Monitoring Rept for Jan-Dec 1998,per Requirements of 10CFR20.2206(b).File Info Listed. Without Encl RBG-44998, Informs of Missing Documentation Re Examination Results Reported in RBS Owners Activity Report Forms Submitted to NRC on 9802241999-04-30030 April 1999 Informs of Missing Documentation Re Examination Results Reported in RBS Owners Activity Report Forms Submitted to NRC on 980224 ML20206E7811999-04-29029 April 1999 Proposes Alternatives to Requirements of ASME B&PV Code Section XI,1992 Edition,1992 Addenda,As Listed.Approval of Alternative Request on or Before 990915,requested 05000458/LER-1999-003, Forwards LER 99-003-00,per 10CFR50.73.Commitments Identified in Rept Are Noted in Attachment 11999-04-23023 April 1999 Forwards LER 99-003-00,per 10CFR50.73.Commitments Identified in Rept Are Noted in Attachment 1 RBG-44968, Submits Addl Info Re 981008 LAR 1998-02 Re Implementation of Bwrog/Ge Enhanced Option I-A (EI-A) Reactor Stability long- Term Solution.Clarifies Certain Aspects of Proposed Ts,Per 990406 Telcon with NRC1999-04-15015 April 1999 Submits Addl Info Re 981008 LAR 1998-02 Re Implementation of Bwrog/Ge Enhanced Option I-A (EI-A) Reactor Stability long- Term Solution.Clarifies Certain Aspects of Proposed Ts,Per 990406 Telcon with NRC RBG-44965, Responds to 990324 Telcon RAI Re SLMCPR Calculation Method for RBS Cycle 9 Slmcpr,Per LAR 1998-15 Re Change to TS 2.1.1.2, Reactor Core Safety Limits. Proposed TS Pages, Encl1999-04-0808 April 1999 Responds to 990324 Telcon RAI Re SLMCPR Calculation Method for RBS Cycle 9 Slmcpr,Per LAR 1998-15 Re Change to TS 2.1.1.2, Reactor Core Safety Limits. Proposed TS Pages, Encl RBG-44959, Withdraws 981120 LAR 1998-20,allowing Adjusting Control Pattern for Plant Startup If Outage Had Occurred Before Planned Refueling Outage.No Plant Outage Was Conducted & Plant Is Now in Eighth Refueling Outage1999-04-0808 April 1999 Withdraws 981120 LAR 1998-20,allowing Adjusting Control Pattern for Plant Startup If Outage Had Occurred Before Planned Refueling Outage.No Plant Outage Was Conducted & Plant Is Now in Eighth Refueling Outage ML20205F1781999-03-31031 March 1999 Forwards Consolidated Entergy Submittal to Document Primary & Excess Property Damage Insurance Coverage for Nuclear Sites of Entergy Operations,Inc,Per 10CFR50.54(w)(3) RBG-44939, Forwards Rbs,Unit 1 Annual Occupational Radiation Exposure Rept for 1998, Per TS 5.6.1.Rept Consists of Tabulation of Exposure for Personnel Receiving Exposures Greater than 100 Mrem Per Yr1999-03-31031 March 1999 Forwards Rbs,Unit 1 Annual Occupational Radiation Exposure Rept for 1998, Per TS 5.6.1.Rept Consists of Tabulation of Exposure for Personnel Receiving Exposures Greater than 100 Mrem Per Yr ML20196K7101999-03-26026 March 1999 Submits Reporting & Recordkeeping for Decommissioning Planning,Per 10CFR50.75(f)(1) RBG-44899, Provides Notification of Termination of Licensed Operator, AA Rouchon,License OP-42416-1,due to Resignation.Reactor Operator License Data,Listed1999-03-25025 March 1999 Provides Notification of Termination of Licensed Operator, AA Rouchon,License OP-42416-1,due to Resignation.Reactor Operator License Data,Listed ML20204G8701999-03-15015 March 1999 Responds to NOV Described in NRC Correspondance to Util ,expressing Disappointment in NRC Determination That AD Wells Deliberately Provided Incomplete & Inaccurate Info to NRC During Meeting on 971015 RBG-44925, Responds to NRC Re Violations Noted in Investigation Rept 4-97-059.Corrective Actions: Mgt Expectations for Communicating with NRC Issued to Site Personnel on 980212,by RBS Vice President,Operations1999-03-15015 March 1999 Responds to NRC Re Violations Noted in Investigation Rept 4-97-059.Corrective Actions: Mgt Expectations for Communicating with NRC Issued to Site Personnel on 980212,by RBS Vice President,Operations RBG-44924, Informs That Util Response to NOV Re Investigation Rept 4-97-059,will Be Issued by 990315,as Extended by NRC Ltr .Encl Check for $55,000 Is for Payment of Civil Penalty IAW Instructions in .Without Check1999-03-0505 March 1999 Informs That Util Response to NOV Re Investigation Rept 4-97-059,will Be Issued by 990315,as Extended by NRC Ltr .Encl Check for $55,000 Is for Payment of Civil Penalty IAW Instructions in .Without Check RBG-44912, Responds to Violations Noted in Insp Rept 50-458/98-13. Corrective Actions:Matls & Training Were Provided to Expedite Implementation of Existing Procedural Guidance to Supply Compressed Air1999-03-0303 March 1999 Responds to Violations Noted in Insp Rept 50-458/98-13. Corrective Actions:Matls & Training Were Provided to Expedite Implementation of Existing Procedural Guidance to Supply Compressed Air RBG-44904, Informs NRC of Date Change Re Commitment Made in Response to NOV 50-458/98-05-01.New Commitment Date 9912161999-02-25025 February 1999 Informs NRC of Date Change Re Commitment Made in Response to NOV 50-458/98-05-01.New Commitment Date 991216 RBG-44384, Submits Response to Fuel Cladding Defect Issues Raised in 10CFR2.206 Petition.Clear Technical Basis Exists in Info Provided by River Bend Station to Deny Petition1999-02-11011 February 1999 Submits Response to Fuel Cladding Defect Issues Raised in 10CFR2.206 Petition.Clear Technical Basis Exists in Info Provided by River Bend Station to Deny Petition ML20203C4201999-01-25025 January 1999 Submits Denial of NRC Request for Advance Info Re Concerns Raised by Ucs in 10CFR2.206 Petitions on River Bend & Perry Plants.Petitioners Were Not Required to Provide NRC with Info in Advance of Informal Public Hearings 1999-09-09
[Table view] |
Text
,
EntIrgy Operations, Inc.
N River Bend Station
' ({/' 5485 U.S. Highway 61
', i* D* P. O. Box 220 ,
St. Francsville. LA 70775 I Tuf 225 336 6225 Fax 225 6'15 5068 f j
Rick J. King )
September 7,1999 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Response to Apparent Violations in IR 50-458/99-07 EA 99-158 River Bend Station License No. NPF-47 Docket No. 50-458 File Nos.: G9.5, G15.4.1 RBG-45095 RBF1-99-0257 Ladies and Gentlemen:
Entergy Operations, Inc. (EOl) appreciates this opportunity to respond to the apparent violations described in NRC Inspection Report (IR) 99-07 as requested in NRC's letter dated August 23,1999. This letter gave EOl the choice of either !
responding in writing to the apparent violations, or attending a pre-decisional !
enforcement conference. EOl b61ieves that this method of addressing issues is l appropriate for situations in which the facts of the issue are well understood by both EOl and NRC.
A response to the apparent violations as requested in your letter is provided in 1 Attachment A. The apparent violations were a result of a period in which the l Division I emergency diesel generator was inoperable for a time in excess of that allowed by the River Bend Station (RBS) Technical Specifications (TS). The first apparent violation deals with inadequate work instructions related to maintenance performed on the diesel generator. This was determined by our root cause analysis to be one of the causes of the second violation, a violation of the Technical Specification for the effected equipment. Because of the close relationship between the two violations, one response is being provided to address both violations. Commitments contained in this letter are summarized in Enclosure 1.
-gj 9909140163 990907 PDR
/> j G ADOCK 05000458 /
pg
r y _ R:sponse to Apparent Violations in IR 50-458/99-07
, y River Bend Station
' License No. NPF-47 Docket No. 50-458 1 Page2 of 3
' RBS management understands the significance of the issues described in the IR.
Attachment B provides our evaluation of the safety significance of the event.
While the condition resulted in a reduction in the defense-in-depth of safety systems provided in the design of RBS, our risk analysis found the condition to be non-risk significant.
We believe, based on the facts surrounding the event and our review of the Enforcement Policy (NUREG-1600), that no civil penalty is warranted. EOl should be given credit for identification of the issue and for prompt and thorough corrective actions following discovery of the problem. Our regulatory perspective addressing enforcement factors described in NUREG-1600 is provided in
~ Attachment C. This perspective addresses safety significance, credit for identification, and credit for corrective actions. However, in this case, we are concerned that the docketed NRC correspondence on the subject does not clearly describe, in detail, the causes determined or corrective actions taken by EOI. Therefore, we request that NRC consider holding a pre-decisional enforcement conference if there is a disagreement with the facts or conclusions presented in thir, letter, which show that no civil penalty is warranted.
RBS management recognizes the importance'of diesel generator performance to the safe operation of the station, and are taking aggressive actions to address issues which impact the performance of this equipment. A multi-discipline team i led by Engineering has been formed to directly oversee and correct problems identified in our assessment. This effort is focused on improving the reliability of the diesel generators. We request a separate meeting this fall to discuss our focused efforts and results of the diesel generator improvements. !
l Should you have any questions regarding the attached information, please I contact Mr. David Lorfing of my staff at (225) 381-4157. I Sincerely, RJK/dhw Affirmation '
Enclosure 1 Attachments - i h
R:sponse to App r nt Violations in IR 50-458/99-07 Rivsr B3nd St: tion License No. NPF-47 Docket No. 50-458 Page.3 of 3 cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 )
Arlington, TX 76011 NRC Sr. Resident inspector P. O. Box 1050 St. Francisville, LA 70775 NRR Project Manager, Robert Fretz U.S. Nuclear Regulatory Commission M/S OWFN 04DO3 i Washington, D.C. 20555 i i
- Director, Office of Enf arcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 0'
9,
BEFORE THE s
. UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-47 DOCKET NO. 50-458 IN THE MATTER OF ENTERGY GULF STATES, INC. AND ENTERGY OPERATIONS, INC.
AFFIRMATION 1, Rick J. King, state that I am Director - Nuclear Safety Assurance of Entergy Operations, Inc., at River Bend Station; that on behalf of Entergy Operations, Inc., I am authorized by Entergy Operations, Inc., to sign and file with the Nuclear Regulatory Commission, this response to Apparent Violations 50-458/99-07-01 and 02; that I signed this letter as Director - Nuclear Safety Assurance at River Bend Station of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information, and belief.
ls .
/ Rick J g'
{
STATE OF LOUISIANA PARISH OF WEST FELICIANA SUBSCRIBED AND SWORN TO before me, a Notary Public, commissioned in and for the Parish and State above named, thbs 1A day of kahh ,
1999.
(SEAL)
OJLcuutio J. /4uto t
- Claudia F. Hurst Notary Public My commission expires with life
^
. . 1
. Encigsure 1 Commitment identification Form
Subject:
Response to Apparent Vioations 50-458/99-07-01 and 02 RBF1-99-0257 RBG-45095 Date: September 7,1999 ;
l 3 COMMITMENT ' ONE-TIME CONTINUING ACTION COMPLIANCE An evaluation of past work on the Division I and ll x DGs will be conducted to assess compliance with SiMs. This review is scheduled to be completed by September 30,1999. '
An evaluation of Division lli DG will be performed to x confirm the adequacy of vendor documentation.
A sampling of vendor documents on other systems x and equipment has been initiated to determine whether this type of condition exists elsewhere.
Training on taper pin staking techniques will be x incorporated into continuing maintenance na.ning.
An effectiveness review of the corrective actions x taken to address the conditica of the Division I and 11 DGs, as we!! as training related to this event, will be performed.
4
(
1 1
Attachment A
+
i l Respanse to Apparent Violations in IR No. 50-408/99-07 APPARENT VIOLATIONS
- 1. An apparent violation of 10 CFR Part 50, App. B, Criterion V, was identified regarding failure to provide adequate work instructions for maintenance of the Division I emergency diesel generator.
- 2. An apparent violation of Technical Specifications 3.8.1.1b and c was identified regarding Divisions I and 11 emergency diesel generator inoperability. As a result of improper maintenance on the Division I emergency diesel generator j fuel oil pump coupling, the Division i emergency diesel generator was inoperable for approximately 30 days and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. During this period, the Division ll emergency diesel generator was removed from service for approximately 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />. l River Bend admits to the apparent violations.
REASON FOR VIOLATIONS i
On February 24,1999, during a scheduled maintenance outage of the Division I diesel generator (DG), repairs were performed to replace a leaking mechanical seal on the overspeed drive shaft. The scope of this task required removal and reinstallation of the fuel pump drive coupling.
The work was completed without apparent incident. The next day, the DG was operated per the applicable surveillance test procedure to satisfy post-maintenance retest requirements, and to restore the DG to an operable status. The surveillance was completed successfully.
On March 23,1999, the DG was operated for a scheduled surveillance test. Fifty-five minutes into the one-hour run, the operator tripped the DG when a " Generator Output High" alarm was received in the Main Control Room, and the electrical load on the generator became erratic.
Subsequent investigation revealed that a taper pin had come out of the fuel pump drive coupling, allowing the coupling to become loose and move on its shaft. This resulted in decreased fuel pump output. When interviewed, the mechanic that installed the pin stated that he did not countersink the taper pin any noticeable amount, but thought that sufficient metal was disturbed by the staking to hold it in place.
4 Further investigation showed that the DG vendor manual states that the fuel pump coupling should be assembled using Loctite 680 compound, in addition to the staking. The Loctite was not used during assembly on February 24. On March 25,1999, the fuel pump coupling was reworked
.'using Loctite in accordance with the vendor recommendations The DG .
- was then successfully operated using the applicable surveillance test procedure.
'The DG_ vendor, Cooper Energy Services (CES), was contacted during the investigation, and provided the follow lng pertinent information:
. . .The purpose of using Loctite in the assembly of the accessory
' drive, overspeed, and fuel booster pump drive couplings to their respective shafts is to fill any clearance that may exist between the shaft and bores. If the hubs assemble to the shafts with an interference fit, then the Loctite provides a small measure of increased protection against loosening. Use of the Loctite on the taper pin in addition to the staking is a " belt and suspenders" measure for added assembly security.
. Service information Memo (SIM) 363 was issued, including the Loctite application on the fuel booster pump drive coupling and staking the pin in two places, on January 23,1984.
b e The vender was not aware of any similar applications in which the taper pin had come loose.
.. The maintenance planner was unaware that the Loctite was recommended on this coupling when the work instructions were prepared.
- The use of Loctite is specified in SIM-363, located in the vendor manual. j There were no indicators or cross-references in the vendor parts !
' list / drawings used to prepare work instructions that referred to the SIM or ;
the need to use Loctite. Consequently, maintenance was performed on l this component without the use of Loctite. The same written work ;
- instructions have been used by CES and by River Bend personnel to l assemble this component on multiple occasions. When the maintenance l was performed on two occasions by CES, Loctite was used during j assembly and documented in the work documentation sheets. When it was rerformed by River Bend personnel, Loctite was not used.
The taper pin staking is the primary means of retaining the pin in place. If the staking fails, the security of the pin is lost without Loctite.
q
l Two causes of this event were identified: l
. The staking of the coupling taper pin was inadequately l performed. The taper pin was not sufficiently countersunk prior l to staking the surrounding metal.
. The maintenance work instructions did not specify the use of Loctite.
The primary document used for planning the work (i.e., the parts list /
drawings) did not specify the use of Loctite, or refer to the applicable SIM.
A contributing factor in this event is the lack of specific training in taper pin staking techniques in the maintenance training program.
1 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED l The following corrective actions I ave been completed:
. The fuel pump coupling was reworked using Loctite and the division l l diesel generator was returned to an operable status. l
. The Division 11 DG was evaluated for possible common mode failure due to inadequate taper pin staking. The fuel pump coupling was examined, and the taper pin was found to be adequately staked and operable without the Loctite.
. The Division 111 Electro-Motive Division DG was evaluated and, based on the use of a different type of coupling by a different manufacturer, it is not susceptible to this type of failure.
. A safety significance / risk assessment of the DG was performed. This assessment is documented in the RBS corrective action program. l Attachment B of this letter provides a summary of that assessment. )
. A standard job plan has been developed for this task to include the use 1 of Loctite. j
. Maintenance planners and mechanics have been briefed on the root cause analysis of this event.
. ECl has updated the DG vendor technical information to improve the :
correlation with the SIMs. l
. A maintenance training module has been developed to specifically address staking techniques on taper pins.
4 I
CORRECTIVE ACTIONS TO PREVENT RECURRENCE I The following actions will be completed:
. An evaluation of past work on the Division I and ll DGs is being conducted to assess compliance with SIMs. This review is scheduled to be completed by September 30,1999.
. An evaluation of Division lli DG will be performed to confirm the adequacy of vendor documentation.
. A sampling of vendor document types on other systems and l equipment has been initiated to determine whether this type of condition exists elsewhere.
. Training on taper pin staking techniques will be incorporated into )
continuing maintenance training.
1
. An effectiveness review of the corrective actions taken to address the condition of the Division I and 11 DGs, as well as training related to this event, will be performed. j DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
~ Compliance was achieved on March 25,1999, when the Division i diesel generator was restored to an operable condition.
Attachment B Safety Significance in order to assess the safety significance of this event, a review of concurrent equipment outages in redundant safety systems was perfonned for the period February 24 to March 24,1999. Four equipment outages in this period, in addition to the Division I DG, were evaluated. The components that were out of service at some time during the period in question were:
. Division ll diesel generator (25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> 54 minutes total over two outages),
e Reactor core isolation cooling system (11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> 21 minutes) and,
. Service water pump P2C, supplying Division 3 diesel generator, (6 days 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />).
At no time did these four outages coincide with each other.
A common mode failure analysis for the Division ll DG was performed immediately following the event. The recent maintenance history of the fuel pump was reviewed, and the fuel pump drive coupling was closely examined. The coupling had last been assembled on July 2,1996, and the maintenance work instructions did not specify the use of Loctite. Upon examination, however, the taper pin was found to be adequately restrained, such that it was not susceptible to becoming loose.
Additionally, the Division lll DG has a different type of drive coupling on its main fuel pump. It is not susceptible to the failure experienced on the Division I DG.
While the Division I DG was inoperable, it was capable of operation with an alternate fuel supply. The DG is equipped with an electrically driven fuel booster pump powered from the station's non-safety 125 volt DC system. Based on actual test data, the pump will start on an emergency start signal, and can run to support diesel operation as long as DC power is available. The non-safety station batteries are designed for a two-hour capacity following isolation of the battery charger from the DC bus by a loss of coolant accident signal.
The significance of this condition was the reduction of defense-in-depth of systems used to mitigate accidents analyzed in the River Bend USAR. One specific example is that the River Bend ECCS analysis assumes that two of three emergency Diesel Generators operate in response to plant transients, but there was a limited period of time (i.e., less than 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />) in which only Division lli DG was operable. To further evaluate this significance, a probabilistic safety assessment for the condition was performed.
V I-c ,
The instantaneous risk associated with each of these instances of concurrent
,' equipment outage was calculated and determined to be acceptable, based on a l . quantitative evaluation of the Equipment Out-of-Service Monitor. Also, the
!- incremental risk was evaluated using the methodology for temporary changes in the EPRI Probabilistic Safety Assessment Applications Guide (EPRI TR-105396).
The calculated incremental risk values were found to be non-risk significant.
l l
l l
i j
e
o .
Attachment C Regulatory Perspective in response to the inspection report, we have reviewed the identified issues against the criteria provided in NUREG-1600, " General Statement of Policy and Procedures for NRC Enforcement Actions." The apparent violations as described in IR 99-07 involved a failure to comply with the action statement for a Technical Specification Limiting Condition for Operation. NUREG-1600 includes this as an '
example of a severity level 111 violation. In this specific case, the Division I DG was inoperable for a period of time that exceeded the action statement time period. However, the NRC should consider risk as a basis to deviate from the j NUREG-1600 examples. In this case, the results of our risk significance {
evaluation, as discussed in Attachment B, indicates that a severity level IV I violation is warranted based on the condition being non-risk significant. )
l If NRC decides that a severity level ill violation is warranted, we conclude that no !
civil penalty should be assessed. This is based on 1) credit for identification,2) l immediate and comprehensive corrective actions, 3) minimal actual safety significance, and 4) absence of willfulness.
Credit for Identification Following the re-assembly of the fuel pump drive coupling on February 24, the appropriate post-maintenance test procedure was successfully performed to demonstrate the operability of the diesel generator. This test included a one hour surveillance run of the DG. As the pump coupling is not an item visually inspected by an operator during routine on-shift equipment monitoring, the next regularly scheduled surveillance test was the earliest possible opportunity to discover the discrepancy. The time of failure on March 23,1999, was the first opportunity to discover the condition after completion of the original maintenance work on the equipment.
Our review of NUREG-1600 indicates that this issue should be treated as
" revealed through an event." Credit for identification should be given as the condition was discovered through a "!icensee self-monitoring effort" which is intended to discover conditions such as this. In this case, the condition was discovered by a planned surveillance test. NUREG-1600 identifies a surveillance test as an example of a licensee self-monitoring effort. It further states that identification credit should normally be given when the condition occurred as a result of conducting a surveillance. In addition, based on review of the circumstances, there were no reasonable previous opportunities to discover the condition. A post-maintenance test is specified to reveal any performance
o ,
deficiencies following a maintenance activity, and no problems were identified.
. The first reasonable opportunity to discover this condition was during the March 23,1999, scheduled surveillance test on the Division 1 DG. The vendor SIM 363 document was issued more than two years ago, and does not represent a current reasonable opportunity to identify this condition.
Immediate and Comprehensive Corrective Actions immediately upon discovery of the condition, actions were taken to restore operability of the Division l DG. The coupling was reworked and the availability of the DG was restored. A common mode failure analysis for the Division ll DG was performed. This analysis found the Division ll DG to be operable in the as-found condition. An extensive root cause analysis was performed and reviewed by plant management as part of the River Bend Station (RBS) corrective action program. This analysis not only identified concerns with adequacy of staking, but also discovered contributing factors related to adequacy of vendor technical information. Details concerning the root cause analysis and corrective action plan are documented in the RBS corrective action program and described in Attachment A to this letter.
Our review of NUREG-1600 indicates that credit for prompt and comprehensive corrective action should be given for the subject condition. The problem with the Division I DG was immediately corrected. Additional actions are being implemented to prevent recurrence of similar conditions with not only the DGs.
Also, a sampling of vendor document types on other systems and components has been initiated. We believe these actions address the underlying root cause, and are sufficient to prevent recurrence of similar violations.
Actual Safety Significance The significance of this condition was the reduction of defense-in-depth of systems used to mitigate accidents analyzed in the River Bend USAR.
An evaluation of other equipment outages during the period that the Division I DG was inoperable was performed to assess the safety significance of this event.
The instantaneous risk associated with each instance of concurrent equipment outage were calculated and determined to be acceptable, per the RBS Equipment Out-of-Service Monitor. Also, the incremental risk was evaluated !
using the methodology for temporary changes in the EPRI Probabilistic Safety Assessment Applications Guide (EPRI TR-105396). The calculated incremental risk values were found to be non-risk significant. ;
Absence of Willfulness The root cause analysis found no instance of intentional noncompliance with or disregard of station procedures. The mechanic made a legitimate effort to ]
l
.4- )
.,.g+< q perform the task of installing the pump coupling taper pin per the work ;
instructions. The maintenance planners made a good-faith effort to provide ;
appropriate work instructions for the task. '
l i
i I
)