ML20044H357

LER 93-008-00:on 930429,investigation Determined That Relief Request for Inservice Testing of Pumps & Valves in Conflict W/Msiv Testing Requirements.Caused by Personnel Error.Relief Request 40 revised.W/930601 Ltr

ML20044H357
Person / Time
Site:	River Bend
Issue date:	06/01/1993
From:	Booker J, England L GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-008, LER-93-8, RBG-38583, NUDOCS 9306080233
Download: ML20044H357 (7)

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AHLA CliDE bO4 036-4=:r34 346 8651 June 1, 1993  !

RBG- 38583 File Nos. G9.5, G9.25.1.3 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

• Gentlemen:

River Bend Station - Unit 1 Docket No. 50-458 Please find enclosed Licensee Event Repon No.93-008 for River Bend Station -Unit 1. This report is submitted pursuant to 10CFR50.73.

Sincerely,

.lt2447tV)

J. E. Booker Manager - Safety Assessment and Quality Verification River Bend Nuclear Group M8 LAE/JPS/FRC/ CH/GMD/kvm

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cc: U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Resident Inspector >

P.O. Box 1051 St. Francisville, LA 70775 INPO Records Center 700 Galleria Parkway Atlanta, GA 30339-5957 Mr. C.R. Oberg Public Utility Commission of Texas 7800 Shoal Creek Blvd., Suite 400 Nor1h 4 Austin, TX 78757 Department of Environmental Quality Radiation Protection Division ,

P.O. Box 82135 Baton Rouge, LA 70884-2135 ATTN: Administrator i

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(See reverse for required number of digits / characters for each block) M ANAGEMENT AND BUDGET, WASH!NGTON, DC 20503, r f ACILITV NAME (1) DOCKET NUMBER (2) PAGE (3)

RIVER BEND STATION 05000 458 OF 4

= ") IMPROPERLY PREPARED RELIEF REQUEST FOR IN-SERVICE TESTING PROGRAM RESULTS IN NON-COMPLIANCE WITH MAIN STEAM ISOLATION VALVE TESTING REQUIREMENT EVENT DATE (5) LER NUMBER (6 -

REPORT NUMBER (7) OTHER FACILITIES INVOLVED (0)

SE QUE NilAL REV6104 F ACluTY NAME DOCKk i NUMdLit MONTH DAY YEAR YE AR MONTH DAY YEAR ggggg ggg 05000 F ACIUTf NAVE DOCKET NUMBER

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04 29 93 93 008 00 06 01 93 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF to CFR i: (Check one or more) (11)

MODE (9) 4 20 402(bl 20.405(c) 50 73(a)(2)(iv) 73.71(b)

POWER 7 20 405(a)(1Hi) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c)

LEVEL (10) 0l 20 405(al(1)(n) 50.36(c)(2) 50.73(a)(2)(vii) OTHER ,

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20 405(a)ll)(v) 50.73ta)(2)(iii) 50.73(a)(2)(x)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELLPMONE NLJVBLH pncht:1e 4ea Code)

L.A. ENGLAND, DIRECTOR - NUCLEAR LICENSING (504) 381-4145 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIDED IN THIS REPORT (13)

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" SUBMISSION pf ps, cow se i FECTED SLBMGSON DATE) X DATE (15) i ABSTRACT (Lnt to 1400 spaces, i.e, approximately 15 single-spaced typewri* ten knes) (16) l On April 29,1993, with the plant in Operational Condition 4 (Cold Shutdown), an investigation was initiated due to an apparent conflict between GSU's Safety Evaluation Repon (SER) ,

concerning the in-service testing (IST) program for pumps and valves and the River Bend IST l Program Plan. Pan of the SER, relief request (RR) #40, is worded such that it requires MSIV testing every cold shutdown. This is in conflict with the IST Program Plan. However, since i it is part of the SER, it is required pursuant to Technical Specification 4.0.5. During a cold shutdown in December 1992, the MSIV testing requirement was not met. Therefore, GSU has concluded that this event is reponable pursuant to 10CFR50.73(a)(2)(i)(b) as a condition prohibited by the Technical Specifications.

The root cause has been detennined to be personnel error when testing frequency changes were processed on relief request #40 including the word "every." Relief request #40 has been revised to address the error and to add the new requirements for additional MSIV exercising. This will prevent recurrence. Until this revision of the relief request is reviewed and approved by the l

NRC, RBS will perform a fast full stroke exercise test every cold shutdown, Nn: rmM u c5 %

REQUIRED NUMBER OF DIGITS / CHARACTERS ~

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SEGvE NTAL F4y@ON NUMBER NUMBER 05000 OF RIVER BEND STATION 458 - -

93 008 00 2 4 re m ,~,. n.e..,.e,. o ,.. m m ...a we w x s on REPORTED CONDITION On April 29,1993, with the plant in Operational Condition 4 (Cold Shutdown), an investigation was initiated due to an apparent conflict between GSU's Safety Evaluation Repon (SER) concerning the in-service testing (IST) program for pumps and valves and the River Bend IST Progmm Plan. Part of the SER, relief request (RR) #40, is worded such that it requires MSIV

(*ISV*) testing every cold shutdown. This is in conflict with the IST Program Plan. However, -

since it is part of the SER, it is required pursuant to Technical Specification 4.0.5. During a cold shutdown in December 1992, the MSIV (*ISV*) testing requirement was not met.

Therefore, GSU has concluded that this event is reponable pursuant to 10CFR50.73(a)(2)(i)(b) as a condition prohibited by the Technical Specifications.

INVESTIGATION On April 23,1993, at the request of NRC inspectors, GSU provided information concerning the RBS Safety Evaluation Report (SER) on the IST program for pumps and valves. The NRC expressed panicular interest in RR #40, which is the cold shutdown justification for testing the main steam isolation valves (MSIVs). The NRC inspectors raised the following questions:

1. Why was this cold shutdown justification worded differently than the rest of the cold shutdown justifications?

2. Was RR #40, cold shutdown justification, reviewed and approved by the NRC?

Due to the concerns raised by the NRC inspectors a condition repon (CR) was initiated on May 29,1993 to investigate these issues.

GSU began an extensive search into the history of how this relief request was developed. Our investigation into the history of RR .#40 revealed that it was originally written for relief from quarterly full stroke testing by requesting that alternate testing be performed during refuel outages. This philosophy was later changed due to industry experience with MSIV testing. In 1987, General Electric issued GE service infonnation letter (SIL) 21 to address MSIV failures due to a loss of air. In 1988, an addendum was issued to this document. In addition, the NRC had issued Inspection and Enforcement (I&E) Notice #85-84 concerning MSIV failures. A

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FACILITV NAME (1) DOCKET NUMBER (2) LER NUMBER 18) PAGE (3)

SEQJENTiAL RGsON NUVBER NUMBER 000 RIVER BEND STATION 458 - -

93 008 00 3 4 TLXT (!! rnore space es rectuored, use estvtronal comes of NHC form 3sM) (17) meeting was held at River Bend on December 15 and 16,1987 between the NRC, their consultants (EG&G Idaho Inc.), and GSU. The meeting was to discuss the questions raised by the review of the IST pump and valve program. The question on the MSIVs was to provide more specific technical justification for not perfonning full stroke exercising, fail safe testing, and stroke timing these valves on a quanerly basis. As a result of this meeting, it was agreed ,

that a conservative approach would be to revise RR #40 which required full stroke testing every refueling outage. The revision would require the full stroke testing, under certain conditions, during cold shutdowns. The original relief request was worded as follows:

"A full stroke exercise test for each valve during every refuel outage."

When it was revised the words " refuel outage" were removed and " cold shutdown" added, and the word "every" was inadvertently left in place. Subsequently, RR #40 was reviewed and approved by the NRC.

The revision should have incorporated wording identical to the other cold sht.tdown justifications. The IST Program Plan has specific guidance as what the cold shutdown frequency is, and how cold shutdown testing is to be implemented. The program states that the valves shall be tested during cold shutdowns but not less than every 92 days. Testing shall commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after achieving cold shutdown, but shall not prevent plant stan-up. Completion of cold shutdown testing is not a prerequisite for commercial generation of power. Tests not completed prior to stanup will be rescheduled for the next cold shutdown staning with the last test perfonned. Cold shutdown testing is not mquired if testing was performed in the last 92 days.

ROOT CAUSE The root cause has been detennined to be personnel error when testing frequency changes were processed on relief request #40 leaving in the word "every." This implied that we would perfonn this testing every cold shutdown contrary to the direction given in our IST Program Plan. Because of this error, the relief request required perfonnance every cold shutdown and caused a failure to comply in December 1992.

A review of previous LERs revealed no similar events.

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CORRECTIVE ACTION Relief request #40 has been revised to address the error and to add the new requirements _for additional MSIV exercising. This will prevent recurrence. Until this revision of the relief request is reviewed and approved by the NRC, RBS will perform a fast full stroke exercise test every cold shutdown.

Surveillance test procedure (STP)-109-6302 is being revised to incorporate the new testing prescribed in the RR #40. An additional step in our test schedule will incorporate the requirement for testing the MSIVs every cold shutdown until the new relief request is' approved by the NRC.

All other cold shutdown justifications were reviewed. The intent of these justifications was verified to require testing diri_ns n cold shutdowns. ,

SAFETY ASSESSMENT An Engineering review and analysis have shown that the condition indicated would not have placed the plant in a configuration beyond the safety analysis due to the missed perfonnance of MSIV cold shutdown testing. The acceptable monthly perfonnance of STP-051-0201 and previous perfonnance of STP-109-6302 during refueling outage 4 indicate the valves had acceptable perfonnance until February 27,1993. Recent review of the results of STP-051-0201 performed on that date and MSIV testing during an outage (April - May 1993) revealed that MSIV IB21 *AOVF022B had stuck in the open position. However, based on acceptable monthly perfonnances of STP-051-0201 until Febniary 27, 1992, there is no evidence of prior valve failure.

Note: Energy industry identification codes are indicated in the text as (*XX*).

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