IR 05000458/1997019

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/97-19. Implementation of CAs Will Be Reviewed During Future Insp to Determine That Full Compliance Has Been Achieved

ML20217D659
Person / Time
Site:	River Bend
Issue date:	03/25/1998
From:	Collins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mcgaha J ENTERGY OPERATIONS, INC.
References
50-458-97-19, NUDOCS 9803300131
Download: ML20217D659 (5)

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• "8009 UNITED STATES

.7 A+t NUCLEAR REGULATORY COMMISSION

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611 RYAN PLAZA DRIVE, SUITE 400 0[ AR LlNGTON, TEXAS 760118064

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MAR 2 51998 John R. McGaha, Vice President - Operations River Bend Station Entergy Operations, Inc.

P.O. Box 220 St. Francisville, Louisiana 70775 l l'

SUBJECT: NRC INSPECTION REPORT 50-458/97-19

Dear Mr. McGaha:

j Thank you for your letter of March 9,1998, in response to our letter and Notice of Violation dated December 24,1997. We have reviewed your reply and find it responsive to the issues raised in our Notice of Violation: a failure of plant workers to maintain appropriate separation criteria l between a safety-related cable tray and a temporary cable; the failure to maintain the postaccident sample system to ensure the capability to take gaseous and liquid samples following an accident; and ineffective corrective actions to address air entrapment in reactor core isolation system instrument lines.

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, (( 0

.O L Elmo E. Collins, Chief Project Branch C f Division of Reactor Projects I Docket No.: 50-458 License No.: NPF-47 f i cc: I Executive Vice President and Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 -

Jackson, Mississippi 39286-1995 9903300131 980325 PDR ADOCK 05000458 G PDR I

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Entergy Operations, Inc. -2-Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 General Manager Plant Operations River Bend Station Entergy Operations, Inc.

P.O. Box 220 St. Francisville, Louisiana 70775 Director- Nuclear Safety River Bend Station Entergy Operations, Inc.

P.O. Box 220 St. Francisville, Louisiana 70775 Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 Mark J. Wetterhahn, Esq.

Winston & Strawn 1401 L Street, N.W.

Washington, D.C. 20005-3502 Manager- Licensing River Bend Station Entergy Operations, Inc.

P.O. Box 220 St. Francisville, Louisiana 70775 The Honorable Richard P. leyoub Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005

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Entergy Operations, Inc. -3-H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, Louisiana 70806 President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135

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Entergy Operations, Inc. -4- MAR 2 51998

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Entergy Operations, Inc. -4- WF . 5 i998 bec distrib. by RIV:

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i DOCUMENT NAME: R:\_RB\RB719AK.GDR To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:DRP/C , C:DRP/Q),

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.!9 Washington DC 20555 i MiR 16,nm :y l " i Subject: Reply to Notices of Violation in IR 97-019 -- River Bend Station Unit I -~ ~ License No. NPF-47 i

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Docket No. 50-458 ' File Nos.: G9.5.G15.4.1 RBG-44415 RBF1 98-0068

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Ladies and Gentlemen: Pursuant to the provisions of 10CFR2.201, Attachments A, B and C provide the Entergy Operations. Inc. responses to the Notices of Violation (NOV) described in NRC inspection Report (IR) 50-458/97-019.

We have aggressively reviewed the subject violatiorts with a self-critical perspective to improve Riser Bend Station perfonnance. The lessons teamed are being addressed and integrated into our practices and programs as described in the attachments.

' Should you have any questions regarding the attached information, please contact Mr. David Lorfing of my staff at (504) 381-4157.

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a Reply to Notice of Violation in 50-458/97-019 March 9,1998 RBG-44415

' RBF1-98 0068 Page 2 of 2 cc: Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011
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NRC Sr. Resident Inspector

- P.O. Box 1050 St. Francisville, LA 70775 David Wigginton NRR Project Manager U.S. Nuclear Regulatory Commission M/S OWFN 13-H-3 Washington, DC 20555 l

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e . ATTACHMENT A Reply To A Notice of Violation IR 50-458/9719-01 Page 1 of 2 Violation: 10 CFR Part 50, Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings . . ." Updated Final Safety Analysis Report Section 8.3.1.4.2 requires that safety-related cables from different divisions and nonsafety-related cables be separated per the minimum allowable separation distances in Table 8.3.9, " Separation Criteria Allowable Versus Tested." Table 8.3-9 requires one foot of separation between a horizontal tray and a cable.

Procedure ADM-0073, " Temporary Installation Guidelines," Revision 2, Step 5.2, requires that temporary installations adhere to the design separation from divisional cable and that plant personnel be cognizant of the separation requirements of a temporary installation to divisional cabling as specified on Drawing EE-34ZE.

Drawing EE-34ZE, " Standard Details for Separation Requirements," Revision 7, identifies the separation requirements for free air cables to trays as one foot.

~ Contrary to the above, on December 4,1997, an extension cord was draped across safety-related cable Tray ITX817B, with free-air cables, and the required one-foot separation was not maintained.

Reasons for the Violation: , A root cause analysis was performed which determined the root causes to be:

* Corrective actions from a previous condition report (CR) for a similar event were not ' '

yet fully implemented. As corrective action from the previous event, procedural changes to ADM-0073," Temporary Installation Guidelines," were made, but l

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Revision 3 of the procedure was not issued and available for plant personnel to use on December 4,1997. Additional means to prevent recurrence (such as temporary power cord tagging) had not been finalized at the time ofinstallation of the cable identified in the subject violation.  ;

* Training on the proper installation of temporary electrical cords for the personnel involved had not been completed.

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Corrective Actions Which Have Been Taken and the Results Achieved:

* The subject extension cord was removed.

. ADM-0073, Revision 3 was issued on December 15,1997.

. Potential users of extension cords were notified of the changes to ADM-0073 to ensure that additional emphasis was being provided in Maintenance, Chemistry, l Radiation Protection and Operations. { e Operations crews performed a walkdown of the plant to identify if other separation discrepancies were present. Items found were corrected.  ;

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Corrective Actions That Will Be Taken To Avoid Further Violations: l e A briefing sheet will be prepared to provide Operations department personnel with information regarding the changes to ADM-0073.

. The Operations Superintendent will discuss the requirements of ADM-0073 with Operations crews.

e Tags will be procured which provide the separation criteria of ADM-0073. These ; tags will be placed on extension cords in the tool room and distributed to other j departments with guidance for their use. j

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e Training covering ADM-0073 will be developed and implemented for plant l personnel.

e ADM-0073 requirements will be added to the outage handbook.

• The process for handling temporary power cables will be changed to ensure that these cables are issued by the tool room.

Date When Full Compliance Will Be Achieved: Full compliance was achieved on December 4,1997 when the subject extension cord was removed. Subsequent plant walkdowns were completed by January 31,1998 to ensure , that other discrepancies were identified and corrected.

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ATTACHMENT B Reply To A Notice Of Violation I IR 50-458/9719-03 Page 1 of 2 Violation: 1

Technical Specification 5.5 states, in part, "the following programs and manuals shall be established, implemented, and maintained ... 5.5.3 Post Accident Sampling... This program provides controls that ensure the capability to obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions. The program shall include the following... Provisions for maintenance of sampling and analysis { equipment."

Contrary to the above, between March 3 and December 12,1997, provisions for maintenance of sampling and analysis equipment were inadequate to effectively ensure the capability to obtain and analyze reactor coolant, radioactive gases, and particulates in plant gaseous effluents and containment atmosphere samples under accident conditions.

The post accident sampling system was out of service for approximately 50 percent of the time during the subject period.

Reason For The Violation: A root cause determination provided the following primary causes: j i e Monitoring and ownership of the post accident monitoring system (PASS) were ineffective. Some personnel involved in monitoring of the system did not fully understand the scope of their responsibilities or have proper understanding of the impact ofissues on the system. Responsibility for ensuring prompt performance of corrective maintenance was not clearly understood. .,

* The design configuration allowed water intrusion into the dry nitrogen portion of the _

system. Some valves were found to be incorrectly installed. This led to equipment j degradation and system malfunction.

) Corrective Actions That Have Been Taken and the Results Achieved: j

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* A system engineer was assigned responsibility for PASS.

• A modification was installed to provide separation between the dry and wet sides of i

the nitrogen supply to PASS.

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, e The PASS has been thoroughly inspected for degradation caused by the water intrusion.

e The incorrectly installed valves in the PASS sample station have been correctly installed.

• Other potential sources of water intrusion were researched and determined not to be {

valid sources of water intrusion.

• A walkdown was performed to ensure that plant configuration and design configuration match.

• Chemistry PASS sampling procedure, COP-1001, has been revised to include information related to pressurization of the system water tank. This will minimize the potential for water intrusion.

Corrective Action That Will Be Taken To Avoid Further Violations:

* Operations shift superintendents, control room supervisors, maintenance supervisors and work week managers will review Operations Policy 6," Active Limiting Conditions of Operation," to reinforce management expectations with respect to the use oflimiting conditions of operation.

l e An evaluation will be performed to determine if a process to review the accumulated effects of repeated entry into tracking LCOs (Limiting Conditions of Operation) is needed. l

e Other maintenance rule scoped systems will be evaluated to ensure proper assignment j of system ownership.

• Responsibilities for personnel outside system engineering who "own" systems will be !

clarified. Personnel outside system engineering who "own" a system will be informed of their responsibilities.

* A procedure will be developed describing how PASS satisfies Technical Specification 5.5.3 including the expectations and responsibilities of the various departments involved, o Engineering will evaluate and take appropriate action to ensure proper  -

implementation of other similar programs identified in Technical Specification 5.5.

Date When Full Compliance Will Be Achieved: Full compliance was achieved on March 7,1998 when the limiting condition on operation was removed.

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a ATTACHMENT C Reply To A Notice of Violation IR 50-458/9719-05 Violation

"10 CFR Part 50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as . . malfunctions ... are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective
. actions taken to preclude repetition . . ."

Contrary to the above, on January 23,1997, a significant amount of air was found in reactor core isolation cooling flow instrument sensing lines (a significant condition adverse to quality) but established measures did not assure the cause of the air entrapment was identified, and actions were not taken to preclude repetition. Consequently, the following problems were observed due to air entrapment in other system flow instrument lines: (1) on November 11,1997, the high pressure core spray minimum flow valve malfunctioned; (2) on December 11,1997, the residual heat removal Train C minimum flow valve malfunctioned; and (3) on December 12,1997, the residual heat removal Train B minimum flow valve malfunctioned."

Reasons for the Violation:

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Spurious gross failure nuisance alarms had been received in the RCIC (Reactor Core Isolation Cooling) flow transmitter circuit while running the HPCS (High Pressure Core Spray) system and were identified on a condition report in 1993. The condition report was dispositioned with the cause not determined. During the course of a follow-up review of the spurious gross failure alarms including the documented reports, an engineer was led to suspect air in the instrument sensing lines. A maintenance action item was generated on January 23,1997, and RCIC flow instrument sensing line high point vents were vented as part of the investigation into the above' mentioned long standing problem

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involving the receipt of spurious gross failure alarms. Air was found in the high point vent. The system engineer realized that other ECCS (Emergency Core Cooling Systems) systems could have a simila problem and investigated further by reviewing the ADM-0064 log (Spurious Instrument Trip Log), walking down ECCS systems, checking system l

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indications and discussing the situation with other engineers and operations personnel.

. Based on this investigation, he concluded that other systems were not exhibiting symptoms of this problem and that a Condition Report (CR) was not warranted.

A root cause team was assigned to investigate the cause of the Criterion XVI violation.

The root cause was determined to be less than adequate communication and enforcement

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e of the condition report initiation threshold. The definition of when to initiate a condition report versus a maintenance work document while troubleshooting equipment is not clear.

The root cause team also evaluated previous similar conditions. Causes for these conditions were identified and are being addressed as part of the River Bend Station (RBS) corrective action program.

Corrective Actions That Have Been Taken and the Results Achieved: As an interim action, a memorandum was issued by the General Manager Plant Operations to RBS personnel addressing management expectations conceming condition report initiation threshold.

^ Corrective actions involving the presence of air in transmitter sensing lines was discussed in LER 97-010 as submitted on December 11,1997 and supplemented on February 26, l 1998. The completed actions to resolve this issue included:

 . Maintenance and System Engineering personnel conducted troubleshooting to j determine the cause of the minimum flow valve failure.

e The sensing lines from the HPCS pipe to the flow transmitter were vented at the high point vents to remove air indicated by troubleshooting.

. The HPCS pump was run and no abnormalities were noted.

. Following the discovery of air in Residual Heat Removal (RHR) B and C transmitter sensing lines, a team of engineering, operations, and maintenance personnel reviewed safety related instrumentation to determine other susceptible transmitters. As a result, six additional locations were vented.

• An Operations Department Standing Order was issued to direct the venting of instrument lines with the high point vents when necessary.

• Instrumentation technicians and planners were made aware of the effects of entrapped air on instrumentation, and the need to vent instrumentation high point vents.

, Corrective Actions That Will Be Taken To Avoid Further Violations: The short term actions to address the Criteria XVI violation include:

* The guideline delineating when a condition report should be written will be clarified.

• Reinforcement of the expectation that a CR should be generated if a condition investigation or operability determination of a safety related component identifies the potential to affect safety related system operation, indication, or identifies an unexpected response will be provided.

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. , , . r e Training will be provided to RBS personnel to emphasize: 1. Expectations with regard to when CRs should be initiated and actions to be taken when the scope of the CR expands.

2. Consideration of broader, generic implications of conditions, including investigation and identification of previous occurrences.

. The trending process will be improved to routinely review maintenance action items, condhion reports and tracking Limiting Conditions of Operation (LCOs) to identify repetitive failures in safety-related equipment and to provide for timely trend CR initiation.

• ADM-0064 will be revised to clarify when a CR should be initiated during the evaluation ofissues.

The long term corrective actions involving the presence of air in transmitter sensing lines included:

 * System configuration will be reviewed to identify other instrumentation with high point vents.

• Final procedural guidance will be developed specifying the appropriate venting requirements for instrument line high point vents. This will include a plan for periodic venting.

• Training on this issue will be provided to appropriate operation's and maintenance personnel.  !

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Date When Full Compliance Will Be Achieved: Full compliance will be achieved by June 30,1998 upon the completion of the short term i corrective actions. ( i I

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