ML20011E674

Responds to Violation Noted in Insp Rept 50-458/89-41 on 891101-15.Corrective Actions:Procedure Which Would Provide Guidelines for Future Troubleshooting of Recirculation Flow Control Valve Sys Being Developed

ML20011E674
Person / Time
Site:	River Bend
Issue date:	02/09/1990
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-32284, NUDOCS 9002220151
Download: ML20011E674 (7)

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O i i / GULF STATES

^ UTILITIES COMPANY .

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' ~ mvtamemnon . ost omct con no r,t runasw.a.towsiasa 70776  !

AREA CODf BCa4 635 C094 346 B6St

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~J ' February 9, 1990 RBG- 32284 s File Nos. G9.5, G15.4.1

• lU.n S. Nuclear. Regulatory Commission -

e -Document Control Desk LWashington, D.C.- 20555 s

-Gentlemen:

River Bend St$ tion .- Unit 1 .,

Refer-to: Region'IV.

t Doc ke t ' No .'- 50-458/89-41 J.

V Pursuant <Lto 10CFR2.201,:thisLletter providis Gulf States Utilities Company's i

'(GSU). response to"the Notice of Violation for NRC Inspection . Report No.

'50-458/89 41.: The inspection was conducted by Messrs. Gagliardo and Jones  ;

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'during"the' period lof November 1,- 15, 1989 of activities authorized by NRC.

0perating:, License NPF-47 for River Bend. Station - Unit 1. GSU.'s response to .

.the violations is.provided in the: attachment.

.. i P Should youhave any questions,- pleasd contact Mr. L. -A.; England' at -

1(504)381-4145.'

h ~Sincerel

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.J.-C..Deddens Senior Vice President River Bend Nuclear Group v rJCD/TFP/ /DNL/JWC/PDG/RGW/ch Attachment a ;cc: U. S. Nuclear Regulatory Commission f Region IVd i611 Ryan, Plaza Drive, Suite-1000'-

' Arlington, TX ' 76011 Senior Resident Inspector Post Office Box'1051

.St.'Francisv111e, LA 70775 1

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W UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA )

PARISH OF WEST FELICIANA )

Docket No. 50-458 ,

In the Matter of )

GULF STATES UTILITIES COMPANY )

(River Bend Station - Unit 1)

AFFIDAVIT- .

J.- C. Deddens, being duly sworn, states that he is a Senior Vice President of Gulf States. Utilities Company; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

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J.=C. Ee3 dens Subscribed and sworn to before me, a-Notary Public in and ,

for the State and Parish above named, this 9 # day of h>lhM/ tau, , 19 90 . My Commission expires with Life.

0 f flUfl av 0 Jhb1A W Claudia F. Hurst Notary Public in and for West Feliciana Parish, Louisiana

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.ATTACMENT f

RESPONSE TO NOTICE.0F VIOLATION 50-458/8941-01-(SEVERITYLEVELIV). 4 AND 458/8941-02 (SEVERITY LEVEL IV) i REFERENCES Notice of Violation -

Letter from S. J. Collins to J. C. Deddens, dated.

January 9, 1990.

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

[ l Inspection Report - Letter from S. J. Collins to J. C. Deddens, dated December 4,1989.

VIOLATIONS j A. Failure to Provide Sufficient Maintenance Work Instructions

River Bend Station Technical Specifications, paragraph .6.8.1.a. requires j i that procedures for activities identified in Appendix A of Regulatory l guide 1.33, Revision 2, February 1978, be established, implemented and maintained. Regulatory Guide 1.33, paragraph 9.c., requires that ,

procedures for the repair or replacement of equipment be prepared prior l y tn beginning work.

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Administrative procedure ADM-0028, " Maintenance Work Order," Revision 10, i attachment 2, step 3 requires that the following items be included in the maintenance work order traveler if appropriate. These items are 1) major steps in the job plan, 2) applicable procedures, and 3) applicable engineering drawings.

Contrary to the above, prompt maintenance work order (MW0) R056226, to troubleshoot the "B" recirculation flow initiated on control January)18, valve 1989, (FCV circuitry, did not include any references to diagrams, vendor manuals, 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, B338-LC1B and gain adjustments on

.the FCV position and velocity controllers. The MWO was subsequently revised on January 20, 1989, to- include references to diagrams, loop calibration reports, a- vendor manual and related procedures to perform additional troubleshooting activities on the "B" recirculation FCV

-circuitry.-

B. Failure'to Perform Post Maintenance Testing Criterion XI of Appendix B to 10CFR50 requires that "A test program shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the i

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requirements and acceptance limits contained in- applicable des 1gn i 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 plant operation, of structures, systen, and components. 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 1 performed under suitable environmental conditions. Test results shall be i documented and evaluated to assure that test requirements have been satisfied."

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 components that have been reworked, repaired, replaced or modified.

Contrary to the above, a prompt maintenance work order (MWO) R056226 which authorized replacement a " Modicon" card in the "B" recirculation flow control l valve circuitry on January 18, 1989, did not require a specific post maintenance test. In addition, MWO R118514, which authorized replacement of the solenoid valve on the "B" recirculation hydraulic power unit on the same I day, did not require specific post maintenance test.

REASON FOR THE VIOLATIONS A. Failure to provide svfficient maintenance work instructions MWO R056226 was planned, reviewed and approved by Maintenance and Quality Control on January 18, 1989 to troubleshoot and repair the "B" l recirculation FCV circuitry and repair as necessary. The Shift Supervisor approved the MWO following an in-depth evaluation with the System Engineer. Additionally, the Assistant- Plant Manager-0perations was briefed on the MWO and the information shown on the scram prevention form or " Red Sheet".

- 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 Supervisor was l rebriefed by the engineer on what work had been done and the expected  !

results. Operations personnel maintained complete control of the HPU l during all modes. Reactor power and rodline was conservatively reduced  !

during all troubleshooting activities. Although all specific and l necessary work documents were not identified in the MWO package on l January 18, 1989, replacement of the Modicon Unit in panel 1H13-P614, B33B-LC1B, was performed utilizing the proper drawings, vendor manuals and Loop Calibration Reports (LCRs). All gain adjustments were made in i accordance with the LCRs which are issued and maintained by engineering l and provide design guidance to I&C for setpoints. The LCR and the design setpoint data sheet indicate these settings are to be performed in the field and provide " initial settings only". The System Engineer and Design Engineering LCR Group had previously worked together on the methodology for these circuits and this methodology has been used during i other such tuning. For these reasons, this methodology does not l constitute a change to the facility as described in 10CFR50.59. I l

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B; Failure to Perform Post Maintenance Testing After each gain adjustment and/or replacement of any components, the Shift- Supervisor and Operations Control.-Room crew were rebriefed by the a System Engineer on what work had been performed and the expected results 1 prior to Operation's personnel resetting the FCV lockup. The engineer  !

then monitored responses from 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 I to reset, mo.nitor, and lockup the FCV. Although not documented in the MWO package on1 January 18, 1989, the " Modicon' card was functionally tested with the 'B' FCV maintained in the locked-up mode. .The functional L . test for the servo valve, following a successful preliminary test, was l first to place it into service, then to observe the valve's response to .,'

operator commands. Additionally, the post-maintenance test of the servo valve required' the dynamics of an operating loop. All troubleshooting and testing except the final post-maintenance test on the servo valve, -

was performed with the 'B' FCV in lockup. Reactor power was previously l reduced to 60%, applicable motion inhibit trips were operational and the j operator was carefully briefed with his finger on the lockup push button j prior to the test evolution.

i STP-053-0601, " Recirculation Flow Control Valve Operability Test", was l performed satisfactorily and documented on MWO R056226 prior to declaring  !

'B' Loop operable on January 21, 1989.

CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND,THE RESULTS ACHIEVED RBS management personnel performed a complete evaluation which included the following summaries:

-A detailed review of the sequence of events as they occurred by the timeclock from the initial FCV malfunction and troubleshooting activities until entry into Single Loop Operation.

A safety significance evaluation was performed utilizing the Updated Safety Analysis Report (USAR) reactivity and core flow limits. This evaluation' included a FCV transient analysis, core flow analysis, loss of coolant accident analysis, and a reactor stability analysis which included a comparison to the LaSalle Nuclear Power Plant stability event. This evaluation also showed that adequate precautions were taken throughout the event to preclude or-mitigate any potential reactivity changes.

Each NRC potential violation and concern identified in the December 4, 1989 letter was evaluated. Although no major programmatic deficiencies were identifiedc RBS management personnel did recognize several areas for

_ improvements. These areas of improvement are outlined below.

CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

-1. Since the recirculation system periodically requires troubleshooting / tuning to be performed on line and may have a direct impact on reactivity control, GSU is currently developing a procedure which would provide guidelines for future troubleshooting of the Page 3 of 5 E

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recirculation: FCV system. While these guidelines would provide a. l reference to all applicable drawings, loop calibration reports, vendor.

manuals, and generic troubleshooting activities it would not be possible to provide step-by-step specific instructions for every perceived

a troubleshooting / system tuning activity which could be performed.

However,. implementation of these guidelines would enhance the ,

. documentation of -applicable reference material and post-mainterance testing requirements associated with FCV troubleshooting type MW0s. ,

Troubleshooting for all other systems will be performed in accordance with existing procedures except for the increased management attention as described in #3 below. .

2. Training on this event will be provided to the following responsible personnel: Operations, Instrumentation and Control (I&C), Shift Technical Advisors (STAS), Facility Review Committee (FRC), Field Engineering'and Operations-Quality Assurance (0QA).

3. The scram prevention form or " Red Sheet" will be 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 cou~1d affect reactor core flow would also require Plant Manager / designee approval. This revision will increase management attention to any maintenance activities which have a potential to affect reactivity.

The following corrective. actions are not directly related to the deficiencies 1

identified in the notice of violation; however, these improvements were identified during the review and evaluation of the entire event. "

1. Administrative Procedure, ADM-0019, was revised to add a requirement for .

the Condition Report Oversight Group to include in its -oversight screening condition reports which may constitute a potential hazard to nuclear s,fety a for consideration of the Facility Review Committee (FRC) review of CRs.

2. An operating experience review of condition reports will be performed to ensure that the "RBS Training Department" include applicable CRs in appropriate lesson plans.

3. . GSU has increased Quality Assurance surveillances associated with 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, until these components demonstrate improved performance. ,

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5. Both recirculation FCV actuators, refurbished during the last refuel i

) outage, will be refurbished in alternating future refueling outages.

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6. Following resolution of recommendations by operations management  !

personnel, all Independent Safety Engineering Group reports containing l recommendations to Operations will be reviewed by the Shift Supervisors. l

7. Recirculation FCV LVT/LVOT connectors will be covered with heat shrink tubing during the upcoming mid-cycle outage.

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0 DATE-WHEN FULL COMPLIANCE WILL BE ACHIEVED

- GSU ' is nowlin full' compliance and except for'_ items 4 and. 5 above, corrective-l- s : actions will be completed by June I', 1990, t .,

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