ML19325D874

Forwards Supplemental Response to Violation 8924-01 Noted in Insp Rept 50-458/89-24,per 890824 & 0912 Discussions. Corrective Actions:Supply & Return Standby Svc Water Isolation Valves for Stated Cooler Repaired

ML19325D874
Person / Time
Site:	River Bend
Issue date:	10/17/1989
From:	Booker J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-31633, NUDOCS 8910270095
Download: ML19325D874 (8)

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October 17, 1989

. RBG- 31633 '

. File Nos. G9.5, G15.4.1

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..M,s ~y .U~ 5 S.. Nuclear Regulatory Comission .

! Document Control Desk. ~

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h1 Gentlemen:

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1 J' , River. Bend; Station - Unit 1.

s- Refer to: . Region IV '

Docket No. 50-458/ Report 89-24 1 Gulf States' Utilities Company (GSU) is providing our supplemental response to f, Notice of Violation 8924-01,x" Failure' to. Provide: Adequate Proceduresa for .

l Control, of . a Special s Process," ,. as : discussed with Messrs. W. Paulson, D.

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'l Nottley and G. Constable of your staff._on August 24 and September 12.- 1969. '

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. . Sho'uld 'you have any. questions,'please" contact Mr..'L - A. England at (504) 381-

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,, Sincerely, lf ' .c f }

i J. E. Booker  ;

l- Manager-River Bend Oversight River Bend Nuclear Group 7 .

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V.' S. Nuclear Regulatory Commission 1 Region IV  !

611 Ryan Plaza Drive, Suite 1000  :

Arlington, TX 76011 , j

HRC Senior Resident Inspector g.; -P. O. Box 1051 L, it

' St. Francisv111e, LA 70775 L

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v 1 L. UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION j y '

1 STATE OF LOUISIANA $

P' PARISH OF' WEST FELICIANA $ l In the Matter of-

$ Docket No. 50-458 5

i GULF STATES UTILITIES COMPANY 5 5 ,

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( , (River Bend Station' 5 Unit'l). $

AFFIDAVIT 6 s

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J. E. Booker, being duly sworn, states that he is Manager-River Bend Oversight for Gulf States Utilities Company; that he is authorized on the '

p-part of said Company to sign and file with the Nuclear Regulatory i

Commission the documents attached hereto; that he has read all of the i statements' contained in such documents attached thereto and made a part thereof;,and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.

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f3. E. Booker Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /7 b , day of hold 19t .

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s' O.LL8 0 YM Notary Public in and for West Feliciana Parish, Louisiana My Commission is For Life.

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f, ATTACHMENT Response to Notice of Violation 50-458/8924-01 L

L Level IV t-j REFERENCES L

i. Notice of Violation - letter from J. L. Milhoan to J. C. Deddens, dated June

'30, 1989.

L Licensee Event Report 89-020 from J. E. Booker to Document Control Desk, L dated May 19, 1989.

L i Augmented Inspection Team - Inspection Report No. 50-458/89-20 from L. J.

i, Callan to J. C. Deddens, dated May 16, 1989.

\ FAILURE TO PROVIDE ADEQUATE PROCEDURES FOR CONTROL OF A SPECIAL PROCESS:

River Bend Station Technical Specification 6.8.1.a requires that procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A of Regulatory Guide 1.33. Revision 2, February 1978, Paragraph 9 j requires that maintenance activities that can affect the performance of i

safety - related equipment and that require skills not normally possessed by qualified maintenance personnel be properly preplanned and performed in accordance with detailed procedures.

Contrary to the above, Corrective Maintenance Procedure (CMP)-9186, Revision  !

4, " Freeze Seal," did not require the use of a temperature detecting device in the sleeve of the freeze seal chamber to monitor the integrity of the freeze seal, and the procedure did not prohibit supplying more than one freeze seal from the same nitrogen bottle. These procedural inadequacies contributed to the loss of freeze seal event on a 6-inch service water line on April 19, 1989.

I REASON FOR THE VIOLATION: )

Gulf States Utilities Company (GSU) has reviewed Inspection Report No. 50- .

458/89-20 concerning the NRC Augmented Inspection conducted April 21-24,

.1989, and has found the facts contained therein to be factual and accurate.  :

Licensee Event Report (LER)89-020 was submitted May 19, 1989 and discussed this event as well. GSU believes that there were several contributing factors which led to the occurrence of this event:

1. An insufficient supply of liquid nitrogen coolant to the freeze plug

-resulted in a failure of the freeze plug.

2. Both freeze plugs were fed from the same nitrogen supply line. This system did not provide for independent control of liquid nitrogen flow to each of the two plug.

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3. Inadequate monitoring of the freeze plug resulted in the failure of the personnel involved to detect the onset and continuation of thawing of I' the freeze plug. The lack of freeze plug temperature monitoring was the major weakness identified.

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4. Corrective Maintenance Procedure (CMP)-9186, Rev. 4 was ambiguous with respect to the. temperature monitoring requirements for freeze plugs.

Also, this procedure did not prohibit the use of a single coolant supply to feed multiple freeze plugs, r

5.- Maintenance personnel had limited experience applying freeze plugs and {

a lack of formal training on freeze plugs may also be contributory factors to the incident, j

6. There was a lack of pertinent information as to the. exact location of l the freeze plug activity in progress and the lack of contingency plans to mitigate consequences of freeze plug failure hampered the Control Room (s) ability to respond to the failure. However, given the circumstances surrounding the incident, Plant Staff personnel responded  ;

as expected.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED: )

Immediate corrective actions taken included securing the Division II standby service water system to isolate the leak, reactor protection system power was transferred to its alternate power supply and the shutdown cooling mode of l the residual heat removal system was restored within approximately 17 minutes  !

with an insignificant increase in reactor coolant temperature.

'The supply and return standby service water isolation valves (ISWP*VF0524 and  !

ISWP*VF0525) for unit cooler lHVR*UCllB were successfully repaired under"a revised maintenance work order (MWO) using another pair of freeze plugs installed and maintained by a contractor (Freeze Technologies, Inc.)  !

specializing in this service. CMP-9186 has been formally cancelled ensuring  !

that RBS personnel will not perfnem freeze sealing until a proper procedure l 1s developed and training come M. Freeze 'Iechnologies , Inc. performed l subsequent freeze seals duriq .- cond refueling outage, i t

An existing Engineering Evaluatiot. and Assistance Request (EEAR) 86-R0093 for water proofing of all non-safety related switchgear equipment in the auxiliary building was dispositioned to initiate Modification Request (MR) 89-0135 to address the floor electrical penetrations and to prevent future  !

electrical failures due to flooding.

The Equipment Qualification and Specification Group of Design Engineering performed a walkdown of the affected areas of the auxiliary building to identify those equipment items susceptible to moisture ingress. All Class iE switchgear inspected was dry internally, and there were no water lines noted on the structures. MW0s were written to perform internal inspections of the equipment in other areas where it was suspected that moisture ingress was q The devices located within the equipment was cleaned, dried, and possible.

returned to its qualified condition where moisture was found internally. The documentation action of this inspection is contained in Equipment l Qualification Impact Summary (EQIS) No. X-388.

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The Independent Safety. Engineering Group (ISEG) prepared Operating Exrerience Report (GER)89-008, dated June 13, 1989. This report reviewed the freeze  !

• g plug failure ' event and the corrective actions taken. Based on those corrective actions taken, no additional ISEG recommendations were made. ,

Quality Assurance performed six surveillances as a result of-this event t

i 1. OS-89-04-49, " Conduct of Operations After Freeze Seal Transient", 1 b 12 . OS-89-04-48, " Loss of Freeze Plug Incident",

3. OS-89-05-35, " Follow-up on OS-89-04-48" ,

F i 4. OS-89-05-18. " Freeze Seal", and ,

5.- OS-89-04-61, " Unscheduled Surveillance on Freeze Technology Inttinational, Inc."

6. ES-89-04-64, " Moisture Intrusion in Electrical Equipment"

' Condition Reports (CR) 89-0492 and 89-0493 were issued to document the recommendations of these surveillances. CR 89-0492 describes the procedural

. deficiencies and CR 89-0493 discusses the training deficiencies previously identified.

Gulf States Utilities has reviewed the effects of discharging the fire water spray system on the 141' elevation of the auxiliary building. This study considered the effect of ponding water on the protected elevation as well as all elevations below. Also included was the effect of water, in the form of sprinkler discharge or floor runoff, on safe shutdown equipment. The basis for this investigation was the original design criteria established for the fire hazards analysis (FRA) and the moderate energy line crack (MELC) analysis.

Neither analysis took credit for the floor drain system, assuming water discharging underneath stairwell doors and down the elevator shaft. The latest study showed that the depth of water on the 141' elevation due to fire water flow is less than 0.75". Therefore, no safe shutdown equipment is affected by . flooding due to fire water discharge since all safety-related equipment is elevated at least 1.375".

, Water spray effects on the safe shutdown equipment were also reviewed, using the MELC guidance. Two potential targets were identified on the fringe of the sprinkled area, panel ISCV*PNL2Cl and transformer ISCV*XD2C. The MELC analysis required the conduit entering this equipment to be sealed for water entry and notes shielding is provided by adjacent equipment. Due to the i small amount of spray, protected conduit entry and shielding, this equipment will not be damaged by sprinkler discharge. Below the 141' elevation, water depths are bounded by the MELC analysis, due to the much larger flows typically found. Therefore, no safe shutdown equipment is affected by either fire water discharge spray or fire water sprinkler runoff to a lower elevation. ,

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' CORRECTIVE STEPS' WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS: l l

b Freeze plug training requirements were added to Maintenance Section Procedure ,

" (MSP)-0009,' " Qualification of Maintenance Personnel," requiring maintenance '

personnel to be trained in freeze plug installation techniques in order to insta11' freeze plugs at River Bend Station (RBS).

4, ' Corrective Maintenance. Procedure '(CMP)-9186, " Freeze Seal," was revised on -

May 3, 1989 via Temporary Change Notice (TCN) 89-0462 to emphasize the L requirement of temperature monitoring during freeze plugging. This TCN also

g. , prohibited the.secting of multiple freeze plugs using one coolant system.

, Operations issued Standing Order #76 on April 23, 1989, which requires contingency plans to be provided to the main control room for all future freeze plugs. These contingency plans include pertinent details -about the F freeze plugs and the actions to be taken in the event of a freeze plug failure in order to mitigate the consequences of the failure.

Floor electrical penetrations will be sealed to prevent future electrical failures due to flooding in accordance with MR 89-0135.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:' ,

GSU 'will perform training to maintenance personnel required to install and maintain freeze plugs prior to GSU performing any freeze plug activities in the future.

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o L ATTACHMENT 2 b ' ,

S Response to Notice Violation 50-458/8924-02 Level IV I -

REFERENCES:

L I Notice of Violation - Letter from L. J. Callan to J. C. Deddens, dated June

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30, 1989 Licensee Event Report 89-020 from J. E. Booker to Document Control Desk, i dated May 19, 1989.

Augmented Inspection Team - Inspection Report No. 50-458/89-20 from L. J.

Callan to J. C. Deddens, dated May 16, 1989.

FATLURE TO PROVIDE ADEQAUTE TRAINING TO CONTROL SPECIAL PROCESS:

, 10CFR50, Appendix B, Criterion IV, " Control of Special Process," requires, in part, that measures be established to ensure that special processes are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements. l The licensee's Quality Assurance Directive (QAD)-9, " Control of- Special Processes," Revision 4, paragraph 4.4, requires that special processes be performed by personnel, equipment, and procedures that have been qualified and certified in.accordance with applicable codes, standards, specifications, approved QA programs, or other special requirements.

Contrary to the above, the individuals performing the freeze seal on April 19, 1989, to isolate Service Water Valves ISWP*524 and ISWP*525, had not been certified to perform the activity through any special requirement other than observation of previous freeze seal activities.

REASON FOR VIOLATION:

The reason for this violation is discussed in Attachment 1 of this letter,

" Response to Notice of Violation 8924-01."

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The corrective actions noted in Attachment 1 of this letter are sufficient to address the concerns here. To reiterate, freeze plug training requirements have been added to MSP-0009, " Qualification of Maintenance Personnel."

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

Maintenance personnel will not install freeze plugs at River Bend Station until they have been adequately trained on freeze plug installation and maintenance. CMP-9186 has been cancelled for use until a proper procedure has been developed and adequate training has been completed.

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-DATE WHEN' FULL' COMPLIANCE WILL BE ACHIEVED: 1 1 m.. .

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.In u accordancewith Attachment.1 of this letter.'GSU will' perform training to' t

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imaintenance. personnel required .to perform'. freeze.: plugs prior .to. 'GSU.

performing any: freeze plug activities in the future.-

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