IR 05000458/1988026

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/88-26

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)

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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 maintaine Sincerel Onginal Signed Bp t 3: CALLAN L. J. Callan, Director Division of Reactor Projects cc:

Gulf States Utilities ATTN: J. E. Booker, Manager-River Bend Oversight P.O. Box 2951 Beaumont, Texas 77704 Gulf States Utilities ATTN: Les England, Director ,

Nuclear Licensing - RBNG  !

P.O. Box 220 St. Francisville, Louisiana 70775 Louisiana State University, Government Documents Department Louisiana Radiation Control Program Director bec to DMB (IE01)

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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

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April 17, 1989 N I RBG-30552 jj File Nos. G9.5, G15. I

- . . U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 88-26 Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation for NRC Inspection Report No. 50-458/88-26. The inspection was performed by Messrs. E. J. Ford and W. B. Jones during the period of December 1 - 31, 1988 of activities authorized by NRC Operating Licensing NPF-47 for River Bend Station - Upit GSU's response to the violations are provided in the attachment This completes GSU's response to these item Should you have any questions, please contact Mr. England at(504)381-414 S ncerely

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/ . 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

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GULF STATES UTILITIES COMPANY )

(River Bend Station, Unit 1)

AFFIDAVIT J. C. Deddens, being duly sworn, states that he'is a Senior Vice President of Gulf States Utilities Company; tha .he is authorized on. the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of' his knowledge, information' and belie D * * > --

J.#C. Deddens Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this [7Ybdayof ddClr 0 h , 19 ,

l ,e y bW an Middlebrooks

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/J otary Public in and for West Feliciana Parish, I

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: Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated March 17, 198 . Licensee Event Report No.88-027 - to NRC from J. E. Booker, dated January 18, 1989 FAILURE TO ENSURE RCIC SYSTEM OPERABILITY:

l RBS Technical Specifications (TS) Limiting Condition for Operation (LCO)

3.4.7.3 requires that the reactor core isolation cooling -(RCIC) system be operable in Operational Conditions 1, 2, and 3 with reactor steam dome pressure greater than 150 psi Contrary to the above, RBS was operated in Operational Conditions 1, 2, and 3 during the period November 1985 to December 19, 1988, with the RCIC system inoperable. .The RCIC system was considered inoperable because the turbine configuration was not in accordance with the seismically tested-design configuratio REASON FOR VIOLATION:

During a review by the Design Engineering group to prioritize outstanding modification packages it was noted that the installation of the RCIC system turbine was not completed per desig Contrary to its seismic qualification requirements, an oil piping support addition had not been completed, the coupling pedestal bolting had not been lockwired, and the pedestal dowel pins were not in plac Investigation of historical documents shows that the portion of the original modification to install the lock wire and dowel pins was complete However, in a subsequent realignment of the turbine, the dowel pins would no longer fit. A new modification using new dowel pin locations .was initiated to complete the original modification. This MR was found not to be worke The scope of the management effort to reduce the backlog level of unprioritized MRs was established in response to two primary actions:

(1) corrective action to NRC Inspection Report 88-01, to review all MRs generated as a result of corrective actions identified on condition reports and provide recommendations for prioritization (schedule) by 12/31/88, and (2)

a commitment to.the Institute of Nuclear Power Operations (INP0) to have the

. backlog of unprioritized MRs reduced to a manageable level by the end of 198 The subject MR was not initiated as a result of the condition report program;  ;

it was a construction modification which was included in the balance of the i reduction effor All modifications as a result of condition report corrective actions have been reviewed and prioritize Less than 75 modification requests remain in the balance of the program. These 75 MRs have been screened by Design Engineering and none have been determined to have an impact on operabili^. Page 1 of 3

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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 quickl CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

The RCIC system was declared inoperable at 1700 on December 19, 1988. A condition report was written and the proper installation was completed on December 24, 1988. After satisfactory retest, the RCIC system was restored to operable status at 1245 on December 24, 198 As identified above, the inadequate installation was initially identified as a direct result of an internal audit of incomplete construction modification All open MRs which have not been prioritized have been screened by Design Engineering and none have been determined to have an impact on operabilit The identification of this deficiency and subsequent corrective action is indicative of GSU's improvement in the MR document control and administrative control areas. This review also confirmed that the operability oversight for incomplete construction modifications which had been tracked on system punch lists was isolate An assessment of the safety implications have shown the effects of the incomplete construction modification to be minimal. The RCIC system provides redundancy to ttle high pressure core spray system (HPCS) for long term core cooling following a postulated control rod drop accident (CRDA). The RCIC system is not required to function ir, this emergency safety feature (ESF)

capacity since the RBS design includes an automatic depressurization system (ADS). ADS provides the required redundancy to HPC No operability or functional problems related to this incomplete modification have been identified. Operation of the RCIC turbine and pump for quarterly surveillance test procedures, both before and after completion of the modification, has been acceptable. Additionally, the RCIC system has experienced two automatic initiations and in each case the RCIC system performed as designed. Therefore, the operability of the RCIC system under normal plant conditions without a seismic event is not questionable.

l l Seismic qualification tests were conducted on the prototype test turbine at much higher accelerations than those assumed for RBS for either an operat basis earthquake (0BE) or safe shutdown earthquake (SSE). Also, part of these tests was conducted with smaller dowel pins and without bolt locking and oil piping supports. The satisfactory performance of the prototype test turbine in this configuration indicates that the RBS installation would r.ot have failed in an OBE or SSE. The probability of simultaneous occurrence of a seismic event and a CRDA with off-site power unavailable and HPCS inoperable is approximately 10(-7) per reactor year, i The RCIC system has demonstrated its ability to perform under normal plant

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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 even Therefore, the safe operation of the plant and the health and safety of the public were not adversely affected as a result of this even (For additional details of assessment of safety implications, refer to Reference 2.)

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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 accordingl 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 Deddens, dated March 17, 198 FAILURE TO SECURE A VHRA ACCESS DOOR:

RBS TS 6.12.2 requires that accessible areas with radiation levels, such that a major portion of the body could receive in I hour a dose greater than 1000 mrem, shall be provided with locked doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the control operating foreman (C0F) on duty and/or the radiation protection superviso ,

Doors shall remain locked, except during periods of access under an approved  :

radiation work procedure (RWP) that specifies the dose rate levels in the

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immediate work area and the maximum allowable stay time for individuals in that are Radiation Protection Procedure RPP-0005, " Posting of Radiologically Controlled Areas," Revision 5, paragraph 7.4, requires that very high radiation area (VHRA). entrances be locked and remain locked, except during periods of access under an approved RWP. Doors must be locked or attended at all time Contrary to the above, on December 3,1988, from approximately 7:45 a.m. to 4:30 p.m. (CST), turbine building door TB 123-20, which provided access to a VHRA around the moisture separator reheater tank, was not properly secure TB 123-20 was not attended during the period the door was left unsecure Seven cdditional examples of events where VHRA access doors were previously left unsecured are identified in NRC Inspection Report 50-458/88-2 REASON FOR VIOLATION:

During normal full power operations, fifty-six (56) doors must be controlled as VHRAs. Locks for all VHRA doors may be opened by one of a limited number of identical key The Shift Supervisor and the COF are issued a key for emergencies only, and radiation protection (RP) personnel maintain control of seven keys for their use. The key checkout method only identified who checked out these keys -- not which doors were opened. However, persons checking out these keys were required to read a statement of their responsibilities with the use of VHRA keys which includes ensuring that the door must be left locked and secured upon exi Investigation was inconclusive as to who failed to ensure that these doors were secured upon exiting. The root causes of this problen are the failure on the part of the individual to verify that the doors were secured and ineffective controls to prevent recurrence.

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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

All VHRA doors were locked upon discover Numerous programmatic controls and corrective actions have been implemented since initial plant operation to ensure that these doors are secured upon exi Increasingly stringent controls failed to produce the desired resul On December 7, 1988, the Plant Manager issued memorandum TFP-251-88 to supervisors emphasizing the serious nature regarding VHRA doors and establishing more stringent administrative guidelines for routine access to VHRA On December 9, 1988, procedure RPP-005, " Posting Radiologically Controlled Areas", was revised by TCN 88-0782 to incorporate the Plant Manager's guidelines. The changes that were implemented require that 1) only radiation protection personnel will be issued keys to VHRA doors for routine access, 2) RP personnel will log the opening and locking of VHRA doors and is responsible for verification of locked doors, 3) for those entries without constant RP coverage, a double verification is required upon exit to assure that the door is locked, 4) RP personnel will daily physically check and verify that all VHRA doors are locked and 5) an operability verification of accessible VHRA doors will be performed monthl In addition to the above, Security also physically verifies twice daily that accessible VHRA doors are locke CORRECTIVE, STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

No VHRA doors have been discovered unsecured and unattended since the implementation of the present progra The improved, more stringent administrative controls established for routine access to VHRA should prevent any future violation DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

RBS is currently in full complianc Page 2 of 2

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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, 198 VIOLATION C:

10CFR 50.73 requires licensees to submit licensee event reports (LERs) to NRC within 30 days of the discovery of events which are described in this regulation. Among the events licensees are required to report is "Any operation or condition prohibited by the plant's Technical Specifications ..."

RBS TS 6.12.2, "High Radiation Area," states that, " areas with radiation levels such that a major portion of the body could receive in I hour a dose greater than 1000 mrem shall be provided with locked doors ..." and that the,

" doors shall remain locked except during periods of access under an approved RWP ..."

Contrary .to the above, on at least seven occasions between June 1987 and December 1988, doors to VHRAs were found unlocked, a condition prohibited by the plant's TS, and LERs were not submitted to NRC within 30 days of.the discovery of these event REASON FOR THE VIOLATION:

GSU has previously interpreted NUREG-1022, " Licensee Event Reporting System",

such that violation of this administrative section of the TSs need not be reported since the condition does not affect plant operatio CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

I Condition reports will continue to be utilized to identify these events, and RP management will now ensure that events related to TS section 6.12.2 are reported under 10 CFR 50.73 requirements.

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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 door 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 event Page 1 of 1

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