IR 05000458/1990041

Ack Receipt of 900614 & 0209 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/90-41

ML20055E197
Person / Time
Site:	River Bend
Issue date:	07/05/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 9007110132
Download: ML20055E197 (3)

Text

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@o Thank-youifor your letters of June 14, 1990, and February 9,:1990, inl , O.,;;: " response'to our-letters and, Notice of Violation dated Hay'9, 1990 -and

1 ? [7, December 4, 1989. We.have reviewed your reply and find it' responsive to the-concerns raised in our Notice of-Violation. We will review the implementation v.

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of your corrective actions during a future inspection to de'termine that full-

compliance has been achieved and will be maintained.

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Sincerely, - ' Original Signed By: , Samuot J. Coilins q l ' Samuel'J. Coll. ins, Director j Division'of Reactor Projects.

, CC - . . W Gulf' States-Utilities; ' 'ATTH: J. E.. Booker, Manager-L ' *; Nuclear Industry Relations a ' ' .P.O.. Box 2951

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s 1. Department ^ofcEnvironmentalQuality '! , \\ ATTN:7tWilliam H. Spell, Administrator? l

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,r - , ^ . T 'U'.S. Nuclear Rsgulatory Commission ATTH;y Resident Inspector

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June 14,1990 -- , RBG - 33066 , .. File Nos. G9.5, G15.4.1 x , U.S. Nuclear, Regulatory -Camission - Doctment Control Desk - Washington, D. C.

20555 Gentimen River Bend Station - Unit 1 Refer to.

Region IV Docket No. 50-458/89-41 '3

As requested in your May 9,1990 letter, Gulf States Utilities campany (GSU) is providing additional information to supplement our-February 9,.

1990 response to NRC Inspection Report , 50-458/89-41. Dctensions to the subnittal date for this letter and for the.cmpletion date for corrective action have been-discussed with your Messrs. Constable and Azua.

This canpletes-GSU's response. to Notice - of l Violation. 8941-01, " Failure to-Provide Sufficient Maintenance Work Instructions" and.8941-02, " Failure to Perform Post Maintenance Testing".

Should 'you have any questions, please contact Mr. L. A. England at (504) 381-4145.

Sincerely, T. F. Plunkett General Manager Business Systems and Oversight River Bend Nuclear Group & MA d ' $ WH0/ /PDG/DRD/pg ' Attachment ccr U. S. Nuclear Regulatory Ccmnission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 ., NRC Resident Inspector Post Office Box 1051 St. Francisville, LA 70775 q.

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=, .g - ATDOseptT l y' J RESFGEE 'to IG'IG CF VIGATICN 50-458/8941-01_(SIM!RITY IJMIL IV) ' .

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Ale 458/8941-02 (SIMRITY IJMtb IVF c , NO c Notice of Violation Letter from S. J. Collins to J. C.

Deddens, dated j - Januarv 9,_1990.

Notice of Enforcement Conference - Dated December 5, 1989.-

Inspection Report

Letter frm S. J. Collins to J. C.'Deddens, dated- - -December 4, 1989. ( F . Request for Additional Information - letter from S. J.. Collins to J. C. _ Deddens, dated May 9, 1990, t VIOLATIONS - A ' Failure to Provide Sufficient Maintenance Work Instructions . ' River Bend Station Technical Specifications, paragraph 6.8.1.a, ' requires that procedures-for activities identified in Appendix A of - Regulatory guide 1.33, Revision 2, February 1978, be established,

irp1mented _- and maintained. Regulatory Guide 1.33, paragraph 9.c., s requires that procedures for the repair or replacement of equipnent be , prepared prior to beginning work. l Administrative procedure ADM- 0028, " Maintenance Work Order," Revision ~ 10, attachrent 2, step 3 requires that the following itms be included - in the maintenance work order traveler if appropriate. These items are o 1) major' steps-in the job plan,- 2) applicable procedures, and 3) applicable engineering drawings. ' Contrary to ; the 'above,.prmpt maintenance work order (MWO) R056226, l initiated.on January'18, 1989, to troubleshoot the "B" recirculation , l flow control valve (FtV) circuitry, did not~ include any references to t L diagrams, loop calibration reports, or procedures other than' general

maintenance procedure GMP-0042, " Circuit Testing and Lifted Leads and , Jumpers." The troubleshooting activities included replacement of a. '" Modicon unit in panel,1H13-P614, B33B-IC1B and gain adjustments on the - ' FCV position :and velocity controllers. The' NHO= was subsequently

L revised on' January : 20, 1989, to include references'to diagrams, loop -g calibration reports, a vendor manual and related procedures to perfom additional troubleshooting activities on the "B" recirculation Irv circuitry. ' l !' % , Page 1 of 6 l I i4 . - - - - - -

. .w- $ 6l, Q, ' 'l '., < > - B._ Failu_re to Perform Post Maintenance Testing ' Ilh ' Criterion XI of Appendix B to 10CTR50 requires, that: ' ' . "A= test _ program 'shall be established to assure that all testing. b' .' required to denonstrate that' structures, systems and emponents-will perform satisfactorily. in service is identified and' perfomed in accordance with written test' procedures' which incorporate the requirements 'and acceptance = limits contained -in applicable design < S documents. The test program shall include,_as appropriate, proof tests prior to -installation, preoperational tests,' and operational tests during nuclear power plant or fuel reprocessing plants operation, of structures, systems, ard ccrqponents. Test procedures shall include provisions for assuring that all prerequisites for the given test have been met,: that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. ' -Test results shall-be documented and evaluated to assure that test requirements have been satisfied." , , N Administrative Procedure ADM-0028, " Maintenance Work Order," Revision 10, paragraph '5.12.26) implements these requirements and directs that appropriate post maintenance testing be specified for all cmponents that' have been reworked, repaired, replaced or modified. . J Contrary to the above, a prmpt maintenance work order (MO) R056226 which - authorized replacment of a " Modicon" card in the "B" recirculation -flow L control. valve circuitrv on January 18, 1989, did not require a specific . post maintenance test. In addition, MO R118514, which authorized replacemnt of the -solenoid valve on the "B" recirculation hydraulic power

unit on the same day, did not require specific post maintenance test. j ! REASON FDR THE VIOLATIONS

l .A. Failure to provide sufficient maintenance work instructions y~ MO R056226 was planned, reviewed and, approved by Maintenance and-

Quality Control on January 18, 1989 to troubleshoot and repair as ) necessary the "B" ~ recirculation FCV circuitry. The Shift Supervisor ' approved the MO following an in-depth evaluation : with the-System. ' .. . Engineer. Additionally, the Assistant Plant Manager-Operations was briefed on the MO and the infomation shown on the scram prevention ! form or " Red Sheet". q I All troubleshooting was performed under the direct supervision of the - System ~ Engineer while the hydraulic power unit (HPU) was locked up. - _ Each time operations personnel reset the FCV _ lockup, the Shift j 1 Supervisor was rebriefed by the engineer on what work had been done and .! the expected results.. Operations personnel maintained emplete control /j of the. 'HPU during all nodes. Reactor power and rodline was j . conservatively reduced during all troubleshooting activities. Although

' all specific _ and necessary work documents were not identified in the M O package on January 18, 1989, replacment of the Modicon Unit in Page 2 of 6 h . .

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. . , .Nz, e panel'_ 1H13-P614, 'B33B-IC1B, was_ performed utilizing the proper

( drawings, vendor manuals and Loop Calibration Reports '(ICRs).- All gain' '_ ' i adjustments' were made in accordance with the ICRs which are issued and l = maintained by engineering 1 and provide design guidance to II.C' for ,setpoints.- The 'IfR and the design setpoint data sheet indicate these settinga are to be performed in the field:and provide " initial settingsi ', only". The Syste Engineer and Design Engineering IfR Group had ' .previously worked together on tho' methodology for these ' circuits and this methodology has been used during other such tuning. -For these g reasons,.this methodology does not constitute a change to the facility. ! as described in 10CPR50.59. '" p i Administrative Procedure ADM-0028 section 6.0 and Attachment 2 " Work ' Traveler / Inspection Record" Step 3 states that a job plan for a prmpt, [ MWO should be written and that it contain the following items as ' appropriate; major steps-in the job plan, applicable procedures, e.nd ' , ' applicable engineering drawings. A prmpt MHO was written because the, problem with the recirculation flow control valve did not allow ' ~ timely i __ processing of a MWO through normal channels. At the time the MWO was !- written, the troubleshooting and repair were to be performed under the , direction of the system engineer and it was not deemed necessary by the i foreman who planned the m o to include references to drawings and- c- vendor-manuals. All activities were performed at the direction of the , System Engineer and controlled documents were used in the performance of the work even though not specifically addressed in the MWo job plan. ' B. Failure to Perform Post Maintenance Testing ' O. ~After each gain adjustment and/or replac ment of any cmponents,- the Shift Supervisor and Operationa Control Room crew were rebriefed by the System Engineer on what work had been. performed' and 'the expected results prior to operation's personnel resetting the M lockup. The engineer then monitored responses frm step changes to the valve as ,; retest. . Reactivity excursions were guarded against by operable > position and velocity trips. and position limiter, and a stationed , operator instructed to reset, monitor, and lockup the M. Although:

.not documented in the MWO package on January'18, 1989, the " Modicon"

o I card was functionally tested with the 'B' FCV -maintained _in the

!! locked-up mode. The functional test for the servo' valve, following a ! successful preliminary test, was first to place it into service, then l , " to observe the valve's response to operator cmmands. Additionally,' ' , the post-maintenance test of the servo valve required the dynamics.of an operating loop. All troubleshooting and testing except the' final r post-maintenance test on the servo valve, was performed with theB' i FCV in lockup. Reactor power was previously reduced to 60%, applicable i ! motion inhibit trips were operational and the operator was carefully ! briefed with his finger on the lockup push button prior to the test oml m vn. ' i L 'STP-053-0601, " Recirculation Flow Control Valve Operability Test," was U performed satisfactorily and documented on MWO R056226 prior to i I declaring 'B' Icop operable on January 21, 1989. j Page 3 of 6 l- i l - - - - - - - - - - .

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n . T. - " CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND 'INE RESULTS ACHIEVIO ,. . . . j " r., RBS managment personnel perfomect 't ccatplete evaluation which included the;

ifollowing simnaries: i 'A detailed review of the sequence of events as they occurred by the ' < - "timeclock frm the initial M malfuction and troubleshooting _ . activities until entry into Single Icop Opecation.

A safety significance evaluation was performed utilizing the Updated - ' Analysis Report (USAR) reactivity and core flow limits. -This c evaluation included a M transient analysis, core flow-analysis, loss

of coolant accident analysis, and a reactor stObility analysis.Lich- J

included a ccriparison ' to the LaSalle Nuclear Power Plant Gtability l - ' event..This evaluation also showed that adequate precautions were - taken 'throughout the event to preclude or mitigate any potential , , reactivity changes, n - Each NHC potential' violation and concern identified in the Deceber 4,

1989 letter was evaluated. Although no major programatic deficiencies were identified, RBS management personnel did recognize several areas' , of improvements. These areas of improvement are outlined below.

GSU considered' detuning of the FCV system such that maximum allowed - average velocity is 1 percent per second open and 4 percent per second. ) closed instead of less than 11 percent per second open and closed. In -t , order to justify slowing down the M respcense, an evaluation' would need to be performed to insure that the M would run-back fast enough . to avoid a low level scram on a loss of feed pump event. This has been- -i discussed with General Electric-San Jose. Due to the unlikelihood'of

the event and the marginal benefits to be obtained,:this detuning will > not be pursued. ! The scram prevention form or " Red Sheet" has been revised to require Plant

Manager / designee approval of maintenance activities. associated with the

,! , feedwater or main steam systems which have the. potential to affect reactivity. Additionally, any work which could affect -reactor core. flow , I would also require Plant Manager / designee approval. This revision will- L increase management attention to any maintenance activities which have. a

potential to affect reactivity. o p- A memo has been issued to maintenance supervisors, foremen, and planners on , the importance of including a job plan in prompt Maintenance Work Orders i twhich _ includes references to applicable drawings and vendor manuals and-

which specifies any applicable post maintenance testing. n . CORRIETIVE ACTIONS WHICH WIIL BE TAKEN 'ID AVOID FURTHER VIOIATIONS l7 - qi

1. Since the recirculation system periodically requires - troubleshooting / tuning to be perfomed on line and may have a direct

o impact on reactivity control, GSU is currently developing a procedure which would provide guidelines for future troubleshooting of the recirculation U system. While these guidelines would provide a Page 4 of 6 1~ appropriate lesson plans. 3. GSU has increased Quality Assurance surveillances associated with c - recirculation system activities. 4.. A visual inspection of the recirculation FCV actuator instrumentation > will be.added to every cold' shutdown' with a drywell entry with a = duration greater than 72 hours, until these cmponents demonstrate improved performance. ( - , 5. - Both recirculation FCV actuators, refurbished-during the.last refuel Loutage, will'be refurbished in alternating future refueling outages. '

6. -Following. resolution of reccrimendations by operations

management -personnel, all Independent Safety Engineering Group reports containing- reemmendations to operations will be reviewed by the Shift- Supervisors.

7. ' ' Recirculation FCV LVT/LVryr connectors will be covered with heat shrink

tubing during the upcming mid-cycle outage. Page 5 of 6 ,

t % '4/{ n m- . # -: . , "o- ' A . f ] , ' > DATE WHEN FUIL COMPLIANCR WILL BE ACHIFNED The gprocedure -for ~providing' guidelines -for troubleshooting of the ' , ' recirculation IW system will be empleted by August -1,1990. , e ' if The. majority of the following people have reviewed this event as required: " reading,: however the Training Department will provide additional training.

' on this event according to the following schedules.

, ,. Licensed operations personnel during licensed operator requalification= - program by August'3, 1990 -STAS'during STA requalification training by June 29, 1990' - g . . 'ITC and applicable engineering personnel will receive training during . ' - the fourth quarter 1990 i (OA personnel'will emplete review of this event as required reading by [ - July 1, 1990 i I&C technicians will receive training by July 31, 1990 --

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