ML20247E750

Discusses Insp Rept 50-458/89-18 on 890501-05 & 15-19 & Forwards Notice of Violation

ML20247E750
Person / Time
Site:	River Bend
Issue date:	07/21/1989
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
Shared Package
ML20247E757	List: ML20247E750 ML20247E761
References
EA-89-122, NUDOCS 8907260303
Download: ML20247E750 (4)

See also: IR 05000458/1989018

Text

- _ _ - -

• ' *

c[ %g UNITEo STATES

$ [T k NUCLEAR REGULATORY COMMISSION

$3

S

f REGloN IV

.f 611 RYAN PLAZA ORIVE. SU'TE 1000

,

\. ,

ARLINGTON, TEXAS 76011 ,

I l

L JUL 211989 {

Docket No. 50-458

License No. NPF-47 {

EA 89-122

Gulf States Utilities

ATTN: Mr. James C. Deddens

SeniorVicePresident(RBNG)

Post Office Box 220

St. Francisville, Louisiana 70775 i

Gentlemen:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT N0. 50-458/89-18)

4

This is in reference to the NRC inspection conducted during the period May 1-5

and May 15-19, 1989, at the River Bend Station (RBS), located in St. Francisville,

and to NRC's~ discussion of the inspection findings with Gulf States

Louisiana,(GSU) officials at an enforcement conference in Arlington, Texas, on

Utilities

June 9, 1989.

As you know, NRC's concerns stenning from this inspection focused on the

failure to establish a test program which would have assured the operability of

the safety-related ventilation systems associated with the fuel building and

the main control room. The results of the inspection were documented in NRC

' Inspection Repcrt No. 89-18, dated June 6,1989.

During the June 9 enforcement conference, two apparent violations resulting

from this inspection were discussed. The violation in the enclosed Notice of

Violation (Notice) involves an apparent failure to assure, through the

establishment of a test program, the operability of two independent fuel

building ventilation subsystems and two subsystems associated with the main

stem in accordance with the requirements of

control room airSpecifications

plant Technical conditioning sy(T.S.) 3.6.5.6 and 3.7.2. As a result of River

Bend Station's self-initiated Safety System Functional Inspection (SSFI) of the

Instrument Air System (IAS) and SSFI followup actions, GSU discovered design

and installation flaws that would have prevented these required subsystems

from performing their intended function under certain conditions.

NRC has concluded that GSU's failure to have developed an adequate test program

resulted in a significant violation of RBS's T.S. in that GSU failed to assure

operability of fuel building ventilation and main control room air conditioning

subsystems. These subsystems are important for ensuring the maintenance of a

negative pressure within the fuel building and limiting any release of radio-

activity within 10 CFR Part 100 limits following a design basis or fuel handling

accident, and ensuring that the control room will remain habitable for operations

personnel during and following all design basis accidents.

8907260303 890721

ADOCK 05000458

(Q l

PDR

Q PDC g

I

- _ -

,

l

. ..

'

. .

-2- DOL 211989

Gulf States Utilities

Had GSU established an adequate testing and surveillance program to evaluate

IAS design and operation, it would have been determined that the subsystem

associated with the fuel building ventilation was inoperable from initial fuel

load in August 1985 and that the subsystem associated with the main control

room air conditioning was inoperable for an indeterminate time. 1

Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-

Related Equipment," alerted licensees to potential IAS problems and required a

response verifying that IAS quality, functional characteristics, and design were 1

as intended. A response was required by February 8, 1989, or if operations were

affected, the next refueling or scheduled outage in order to avoid adverse j

system interactions. GSU determined through a self-initiated SSFI conducted

during the period November 17 to December 21, 1988, and through SSFI followup

actions that solenoid operated valves, check valves, and accumulator tanks would

not function as designed for the subsystems associated with the main control

room air conditioning and fuel building ventilation systems. These conditions

were corrected promptly upon discovery.

The NRC has classified the violation in the enclosed Notice at Severity Level

III in accordance with Supplement I of the " General Statement of Policy and

Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement

Policy), as published in the Federal Register on October 13, 1988. While the

NRC could consider imposing a monetary civil penalty for a Severity Level III

violation, I have determined in this case after consultation with the Director,

Office of Enforcement, and the Deputy Executive Director for Nuclear Materials

Safety, Safeguards and Operations Support, that no penalty will be assessed.

I base this decision on discretionary provisions in Section V.G. of the

Enforcement Policy. The NRC encourages and supports licensee efforts for

self-initiated identification and correction of problems and intends on applying

enforcement discretion in cases such as this one in which the problems were

identified by a GSU self-initiated SSFI and were promptly corrected. However,

the NRC is concerned that upon discovery GSU did not consider the deportability

j

of the problems. Prompt evaluation fnr deportability and timely reporting are

significant issues. Had the problems discovered not been of a highly technical

nature, requiring extensive evaluation and review before determining a possible

operability problem existed, your failure to promptly repot c them could have

resulted in additional enforcement action being taken.

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 determine whether further NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

i

. - - - . - . _

~, .

.

'.

Gulf States Utilities -3- JUL 211989

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC Public Document Room.

The response directed by this letter and the enclosed Hotice are not subject to

the clearance procedures of the Office of Management and Budget as required by

the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

Sincerel.y,  !

/. J , \ ~ 1]

'(. bb e ^G l q<}$ 3

Robert D. Martin

Regional Administrator

Enclosure: Notice of Violation

cc:

Louisiana Radiation Control Program Director >

NRC Public Document Room

Local Public Document Room

l

!

i

'

!

i

i

i

!

1

- . _ _ _ - _ . . _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _

,. , _

______ _ ,

a. _, -ff '

y

,

.; .

,

'

P JUL 211989 -

Gulf State Utilities

i DISTRIBUTION:

SECY-

CA

'JMTaylor, DEDR

HThompson, DEDS

TMurley, NRR.

J..Partlow, NRR i

JLieberman, OE

JGoldberg, 0GC

Enforcement Coordinators

RI, RII, RIII, RIV, RV

F. Ingram, GPA/PA

EJordan, AEOD i

MHalsch, 0lG

BHayes, 01

OE:ES

.0E:EA File

OE:Chron

M $-

RIV DISTRIBUTION:

RMartin

JMontgomery

LJCallan

-JLMilhoan

JPJaudon

.IBarnes

RStewart

LE11ershaw

W. B. Jones, RI, RBS.

JG11111and(1trhd)

CHackney

WBrown

RWise

E0 Files

RIV Files

DRS Division Files

DRP Division Files

RSTS Operator

MIS Coordinator

G \"

OE

y :n RIV D:0E DEDS

HThompson

k I\

JLaphman RDMJrtin JLieberman

7/iq/89 7/h/89 7/9()/89 7SO/89 ,

l