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EA-99-158 - River Bend 1 (Entergy Operations, Inc.)October 5, 1999 EA 99-158 Randal K. Edington, Vice President - Operations SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-458/99-07) Dear Mr. Edington: This refers to Entergy Operations Inc.'s letter dated September 7, 1999, regarding apparent violations described in the subject inspection report, issued August 4, 1999. The inspection report described two apparent violations related to the River Bend Station Division I Emergency Diesel Generator (EDG) and stated that the NRC was considering escalated enforcement action. In a letter to Entergy dated August 23, 1999, the NRC asked Entergy to indicate whether it would respond in writing to the apparent violations or opt for a predecisional enforcement conference. Entergy chose to provide a written response. The apparent violations involved improper installation of a fuel booster pump coupling pin which resulted in the diesel failing after 55 minutes of operation during a surveillance test on March 24, 1999. This failure was traced to improper staking of the coupling pin, including the failure to use an adhesive, Loctite, that was recommended in a Service Information Memo issued by the EDG vendor. This recommendation was not incorporated into diesel maintenance procedures at River Bend Station. The failure after 55 minutes of operation meant that the Division I EDG was not capable of fulfilling its intended safety function in the event of an accident that required electrical power from the diesels. The safety function of the EDG is to provide an alternate safety-related electrical power source in response to an event involving the loss of off-site power, for the duration of the event. In its September 7, 1999 response, Entergy admitted the apparent violations, described its corrective actions, and provided its perspective on the safety significance and enforcement policy implications of the violations. In a supplemental response dated September 24, 1999, Entergy provided a summary of its EDG reliability self-assessment, provided additional completion dates for long-term corrective actions, and described the status of the EDGs within the scope of 10 CFR 50.65, the maintenance rule. Entergy's assessment of the safety significance of this incident concluded that it resulted in a reduction of defense-in-depth in terms of the systems available to mitigate accidents, noting that for a period of about 26 hours, only the Division III EDG was available to respond to an accident because of planned maintenance on the Division II diesel while the Division I diesel was inoperable. Corrective actions which have already been completed include: immediately restoring the operability of the EDG; evaluating the potential for the coupling pin problem to affect the Division II and III EDGs; modifying maintenance procedures to include the use of Loctite, an adhesive, on the fuel pump coupling pin; briefing maintenance planners and mechanics on the root cause analysis of this event; including training on taper pin staking techniques into the continuing maintenance training module; and updating the diesel vendor technical information. Corrective actions which have not yet been completed include: evaluating past EDG work to assess compliance with vendor service information memos, due October 22, 1999; evaluating the Division III diesel to confirm the adequacy of vendor documentation, due December 31, 1999; sampling vendor documents on other systems and equipment, due December 31, 1999; and performing an effectiveness review of the corrective actions taken to address the condition of the Division I and II EDGs, due March 31, 2000. Based on NRC review of the information developed during the inspection and the information that you provided in your response to the inspection report, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice). Based on their close relationship, they have been combined to form a single Severity Level III problem. The severity level of the violations in this case is based on their resulting in the emergency EDG being inoperable for a period of 29 days, well in excess of the allowed outage time of 72 hours for one EDG. This severity level determination is in accordance with Supplement I of the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. In accordance with the Enforcement Policy, a civil penalty with a base value of $55,000 is considered for a Severity Level III problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years,(1) the NRC considered whether credit was due for Identification and Corrective Action (relative to the current violations) in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. As Entergy noted in its September 7, 1999 letter, Entergy personnel discovered the fuel booster pump coupling pin problem while conducting a surveillance test of the EDG. In light of the circumstances which resulted in the discovery of this problem, and Entergy's corrective actions, which are described above, Entergy is given credit for both identification and corrective action, which results in no civil penalty being assessed for the current violations. Therefore, in recognition of Entergy's identification and correction of this issue, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty. The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report 50-458/99-07, and in Entergy's September 7 and September 24, 1999, letters. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and any response you choose to submit will be placed in the NRC Public Document Room.
cc w/Enclosure: Executive Vice President and Chief Operating Officer Vice President General Manager Director - Nuclear Safety River Bend Station Wise, Carter, Child & Caraway Mark J. Wetterhahn, Esq. Manager - Licensing River Bend Station The Honorable Richard P. Ieyoub H. Anne Plettinger President Ronald Wascom, Administrator and State Liaison Officer
During an NRC inspection completed July 10, 1999, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below: River Bend Station Technical Specification 3.8.1.b requires that three diesel generators be operable in Modes 1, 2 and 3. Technical Specification 1.1 defines OPERABLE as follows: "A system . . . shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) . . ." The emergency diesel generator's safety function is to provide an alternate safety-related electrical power source in response to an event involving the loss of off-site power, for the duration of the event. 10 CFR Part 50, Appendix B, Criterion V requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances. The River Bend Station "Maintenance Planning Guideline," Revision 6, Section 6.5.9.5 states, in part, "Reference all procedures, vendor procedures, and design documents required to perform the work instruction and to return the . . . system . . . to operational or desired status." Contrary to the above:
These violations represent a Severity Level III problem (Supplement I). The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report 50-458/99-07, and in Entergy Operations, Inc.'s September 7 and September 24,1999, letters. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at River Bend Station facility within 30 days of the date of the letter transmitting this Notice of Violation (Notice). If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21. Dated this 5th day of October 1999
1. A Notice of Violation and Proposed Imposition of Civil Penalty ($55,000) was issued on February 1, 1999, consisting of two Severity Level III violations related to the Division I and II emergency diesel generators (EA 98-478). |
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