IR 05000458/1988022
| ML20235P767 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/23/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| EA-88-249, NUDOCS 8903020360 | |
| Download: ML20235P767 (2) | |
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FEB 23 5W In Reply Refer To:
Docket:
50-458/88-22 EA 88-249 Gulf States Utilities ATTN: Mr. James C. Deddens Senior Vice President (RBNG)
P.O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:
Thank you for your letter of December 15, 1988, in response to our letter dated November 15, 1988. We have no further questions at this time and will review your corrective action during a future inspection.
Sincerely, 0:ight R?nx! Bb L J. 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 w/ enclosure to DMB (IE01)
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GULF STATES UTILITIES COMPANY
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JAN 261989 y j L
December 15, 1988
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File Nos. G9.5, G15.4.1 U. S. Nuclear Regulatory Comission Document Control Desk Washington, DC 20555 Gentlemen:
RIVER BEND STATION - UNIT 1 l
REFER TO:
REGION IV
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DOCKET NO. 50-458/ REPORT 88-22 Pursuant to 10CFR2.201.,
this letter provides Gulf States Utilities l
Company's (GSU) response to the Notice of Violation contained in NRC l
Inspection Report No.
50-458/88-22.
The inspection was performed by Messrs. E. J. Ford and W. B. Jones during the period August 29 - September l
15, 1988 of activities authorized by NRC Operating License NPF-47 for River
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Bend Station - Unit 1.
GSU's response to the violations are provided in the attachments.
This completes GSU's response to these items.
Should you have any questions, please contact Mr. Rick J. King at (504)
l 381-4146.
Sincerely,
. f. C S m
. E. Booker Manager, River Bend Oversight J
River Bend Nuclear Group l
I JCD/JEB/LAE/RJr,/JWC/ns Attachment cc: U. S. Nuclear Regulatory Comission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051 l
St. Francisville, LA 70775
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UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA
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PARISH OF WEST FELICIANA
5 In the Matter of
Docket No. 50-458
GULF STATES UTILITIES COMPANY
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i Unit 1)
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Booker, being duly sworn, stateis that he is Manager-River Bend Oversight for Gulf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear F.egulatory j
l Commission the documents attached hereto; that he has read all of the
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l statements contained in such documents attached thereto and made a part f
thereof; and that all such statements usde and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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fJ. E. Booker Subscribed and sworn to before me, a Notary Public in and for the State l
M and Parish above named, this _/S day of f)St s nSp A.
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R jdoan W. Middlebrooks
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Notary Public in and for j
West Feliciana Parish, Louisiana i
My Con: mission is For Life:
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Attachment 1 Response to Notice of Violation 50-458/8822 Violation A REFERENCE Notice of Violation - Letter from R. D. Martin to J.
C.
Deddens, dated November 15, 1988.
VIOLATION A River Bend Station Technical Specification (TS) Limiting Condition for Operation (LCO)
3.6.5.6 requires that two independent fuel building ventilation charcoal filtration subsystems be operable in OPERATIONAL Conditions 1, 2 and 3.
Contrary to the above, River Bend Station was operated in Operational Conditions 1-- 2 and 3 from August 27, 1988 to 7:50 p.m. (CDT) on August 29, 1988, with both divisions of the fuel building ventilation charcoal fil tration subsystems inoperable as a result of their associated heater breakers having been de-energized.
REASON FOR THE VIOLATION On August 29, 1988 with the unit in Mode 1 operation at 100% power, the Unit Operator (U0), while preparing for the performance of STP-406-0201,
" Fuel Building HVAC Charcoal Filter Monthly Operability Test" noticed the control switch for both the Division I and Division II filtration heaters to be in the de-energized position.
With these heaters in the de-energized position, both divisions of the fuel building ventilation system were considered inoperable.
It appears that from Saturday, August 27th, when the control board lineup was verified for the ensuing startup, and Monday, August 29th at 1950 hours0.0226 days <br />0.542 hours <br />0.00322 weeks <br />7.41975e-4 months <br />, these breakers were open.
During this time the plant changed from Mode 3,
" Hot Shutdown", to Mode 2, "Startup", to Mode 1, "Run".
Since it cannot be substantiated that the breakers were closed during this time, it i
is assumed they were opened after the Saturday verification.
I GSU's investigation did not identify a single root cause but instead l
identified a combination of factors which collectively contributed to the l
subject violation. The contributing causes are identified as follows:
i shift turnover implementation inadequacies l
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- shift turnover procedure deficiencies
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operational startup communications deficiencies
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED i
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The shift supervisor, upon notification frem the U0, immediately entered the LC0 action statement for both divisions being inoperable.
This requires the plant to enter Technical Specification 3.0.3 for a short time.
Immediate action was taken to return both fuel building ventilation systems to operable status by closing the supply breakers.
Verification of all sa fety-rela ted control board lineups per procedure
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GOP-0001,." Master Startup Checklist," was completed with no other discrepancies identified.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Operations has implemented a control board walkdown checklist for the U0 to use as a guide when performing shift turnover to help ensure himself of the status of safety related equipment per procedure OSP-0002, " Shift Relief and Turnover." This change includes further detail on system (s) condition including in-service /out-of-service equipment and LCOs in effect.
The shift supervisor reviews the U0's checklist shortly after shift briefing to verify his understanding of board status.
A memo has been issued to all operators which described this event and emphasizing the importance of control board awareness.
The Assistant Plant Manager-0perations has begun conducting interviews with each operator, discussing management's philosophy of operator performance.
Additionally, the Assistant Plant Manager-0perations has personally discussed this event with each shift crew to emphasize the following:
safety significance of the discovered mispositioning
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panel awareness
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- inportance of turnover necessity for complete and adequate board walkdowns
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use of the new U0 checklist
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shift supervisor's review of the checklist
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" Daily Log Report", has been revised to include local verification of charcoal filter heater disconnect switch.
Operations section equipment-related procedures were reviewed for deletions of safety systems equipment monitoring.
No additional items were found.
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Procedure ADM-0022,
" Conduct of Operations," has been revised to require the Plant Manager's approval for deletion of safety system equipment monitoring from the Operations section procedures.
The activities of other plant staff departments were reviewed for the procedural deletion of safety-related equipment monitoring.
None were found.
Procedure OSP-0005,
" Operations Procedure Review and Revision," has been revised to include a checklist item for OSPs deleting safety-related observations, actions. or lineups.
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" Simulator training has been incorporated to increase control board
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awareness exercises.
Procedure OSP-0017,
" Normal Control Board Lineups for Safety-Related Systems," has been developed to facilitate verification of system control switch positions during startups.
Switch covers were added to heater control switches for fuel building, control building, and standby gas treatment charcoal filter systems heater control switches.
A proposed enhancement to the control board to designate system standby lineup is being evaluated for a selected system on the plant simulator.
If this evaluation indicates that the operators will benefit from this enhancement, it will be incorporated on the main control boards for the safety-related systems.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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The evaluation of control board enhancements will be completed by February 15, 1989 and interviews with individual operators will be completed by March 15, 1989.
All other enrrective actions have been completed.
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Attachment 2
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Response to Notice of Violation 50-458/8822 Violation B
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I REFERENCE Notice of Violation Letter from R. D. Martin to J. C. Deddens, dated
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November 15, 1988.
VIOLATION 8 10CFR50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," states in Criteria XVI, " Corrective Action,"
that " Measures shall be established to assure that conditions adverse to l
quality, such as failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected."
i GSU Ouality Assurance Directive. 0AD-16
" Corrective Action," which describes the measures and delineates the requirements for identifying, documenting, reporting and correcting conditions adverse to quality (nuclear safety), states, in part, that " Procedures shall require that corrective action be promptly initiated and adequately documented by the
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I responsible department to correct the condition and to determine if action is necessary to preclude its recurrence."
Contrary to the above, River Bend Station Condition Report (CR) 86-0875, i
written on July 1,1986, identified a deficiency in the design of the fuel building ventilation charcoal filtration system in that the system did not provide operators adequate indication of situations in which the system heaters may be deenergized and unavailable if needed, a deficiency for which corrective action was not taken as of August 29, 1988, when the
licensee discovered the heaters had been deenergized for a two day period.
l Although Modification Request (MR) 86-1214, written in September 1986, l
would have resulted in alarms being added to the system to alert operators
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to situations when the heaters may be deenergized, MR 86-1214 was cancelled l
on April 23, 1988, and no other suitable corrective actions were taken.
l REASON FOR THE VIOLATION MRs 86-1213 and 86-1214 were initiated as corrective action for CR 86-0875.
At the time the two MRs were recommended for cancellation, the modification request procedure contained no restrictions on cancelling MRs associated with corrective action documents.
After MR 86-1213 was cancelled, a coincidental procedure change was made to procedure ENG-3-006, "RBS Design and Modification Request Control Plan",
requiring additional review for corrective action MRs. As a result of this change, MR 86-1214 was reviewed
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by the Quality Assurance (QA) department prior to final cancellation.
QA returned the MR to engineering for further evaluation.
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The root cause for this violation has been determined to involve a
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procedural deficiency which allowed incompletion of a corrective action to
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a self-identified design deficiency.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED MR 88-0300, which provides for a local heater operability indicator light for the control building ventilation system was issued to replace cancelled MR 86-1213.
The request to cancel MR 86-1214 has been rescinded and the MR was processed as a field work MR. MR 86-1214 provides a local heater operability indicator light and an improved breaker status alarm in the control room for the fuel building ventilation system.
The field work associated with both MRs has been completed.
A review was conducted to identify cancelled MRs written against safety-related CRs, restricted to those MRs processed before implementation of the procedure revision which identified MR 86-1214. These MRs have been
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identified, and are being reviewed to ensure that documentation clearly I
shows corrective action is either being accomplished by another mechanism or justifies why corrective action is no longer required.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS ENG-3-006 has been further revised to require the completion of a cancellation checklist if an individual wishes to cancel an MR.
This checklist requires documentation of other mechanisms for implementation of
corrective actions or justification as to why the corrective action is no longer required. The supervisor's and the responsible engineer's approval are required for this new checklist.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The review of identified safety-related MPs action will be completed by February 28, 1989.
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