ML20045A426

LER 93-002-02:on 930212,discovered That TS SRs Not Properly Implemented in Logic Sys Functional Tests Due to Inattention to Detail While Preparing Revs of Relevant Surveillance Test Procedures (Stp).Relevant STPs revised.W/930601 Ltr

ML20045A426
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-93-002, LER-93-2, RBG-38584, NUDOCS 9306100240
Download: ML20045A426 (13)

Text

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GULF ' -STATES ' ' UTILITIES - COMPANY MVE R flEhD STAMON POST OrtfCE BGX 220 ST FF4ANCISVILLE todt$1ANA 70775 ARE A COD 6 %d 6 38J 6094 346 66f1 June 1, 1993 RBG- 38584 File Nos. G9.5, G9.25.1.3 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

River Bend Station - Unst 1 Docket No. 50-458 Please find enclosed Supplement 2 to Licensee Event Report No.93-002 for River Bend Station - Unit 1. This supplement provides details of additional investigation concerning logic system functional tests that did not fulfill the Technical Specification Surveillance Requirements.

Sincerely,

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J. E. Booker i Manager - Safety Assessment and Quality Verification River Bend Nuclear Group i LAE/ S / C /ML5/kvm (l"('0 Q G })

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cc: U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 >

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NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 '

INPO Records Center f 1100 Circle 75 Parkway Atlanta, GA 30339-3064 i Mr. C.R. Oberg Public Utility Commission of Texas I 7800 Shoal Creek Blvd., Suite 400 Nonh +

Austin, TX 78757

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Department of Envimnmental Quality Radiation Protection Division ,

P.O. Box 82135 Baton Rouge, LA 70884-2135 l ATrN: Administrator [

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i NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED DY OMB NO. 3150-0104

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EXPIRES 5/31/95

' l'ST! MATED BURDEN PER RESPONSE TO COMPLY WrTH THIS INrORMATION COi.LE CTION REQUEST. 50 0 HR3. FORWARD LICENSEE EVENT REPORT (LER) cOMMms ntGAnOm BuRotN csTwTE TO TnE ivoneroN AND RECORDS MANAGEMENT BRANCH (VNBS 7714), U $ NUCLEAR HrGULATORY COMMISS!ON, WASH:NGTON, DC 20555-0001, AND TO THE FAPERWORK HCDUCTION P5tGJECT 13150 otc4 OF FICE Or (See reverse for required number of d3gits/ characters for each block) uANAGEMENT AND BUDGET, WASH:NGTON, DC 20$03 f ACIUTY NAME (1) DOCKET NUMBER (2) PAGE (3)

RIVER BEND STATION 1 OF 05000 458 10

= a) TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS NOT PROPERLY IMPLEMENTED IN LOGIC l SYSTEM FUNCTIONAL TESTS EVENT DATE (5) LER NUMBER (6l REPORT NUMBER (7) OTHER FACILITIES INVOLVED (8) ,

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OPERATING THIS REPORT IS SUBMITTED PUHSUANT TO THE REQUIREMENTS OF 10 CFR 1: (Check one or morel (11)

MODE (9) 1 20.402(b) 20 405(c) 50 73(a)(2} 0v) 73.71(b) ,

POWEH 20 405;ain10) 50.36(c)(1) 50.73(a)(2Hv) 73 71(c)

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I LICENSEE CONTACT FOR THIS LER (12)

NayE 4d&+K,JNE NUMdd Mcluce Area Corie} l L.A. ENGLAND - DIRECTOR.. NUCLEAR LICENSING (504) 381-4145 ,

COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

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ABSTRACT (Limtt to 1400 spaces, i e., approdmately 15 sing le-spaced typewntten knes) (16) l i

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On February 12,1993 with the plant at 100 percent power (Operational Condition 1), a deficiency  :

in plant suneillance test procedures (STPs) was identified. During a safety system functional assessment (SSFA) perfonned by Quality Assurance, it was discovered that the logic system

. functional test (LSFT) that verifies the isolation of reactor core isolation cooling system (RCIC) [

valve E51-F045 on a reactor water level 8 signa: was not being completely satisfied.  !

Technical SpeciGcations (TS) require that an LSFT and simulated automatic operation of all channels be performed at least once per 18 months. A combination of three suneillance test procedures was intended to meet the TS suncillance requirements; however, the SSFA revealed that j these procedures do not provide proper overlap. ,

GSU's ongoing review of all STPs which perfonn LSFTs has revealed several conditions in addition i to the original one described above. As conditions are identiGed, GSU is verifying the operability  ;

of the affected circuitry and initiating the necessary changes to the applicable surveillance test procedures.

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4 UP TO 76 TITLE 6 TOTAL DATE 2 PER BLOCK  ;

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NUMBEA NUMBER RIVER BEND STATION 05000 4 5 8 93 - 002 -

02 2 10

,w w n.w.c.v.u a ..m m .~ m m on RF. PORTED CONDITION On February 12,1993 with the plant at 100 percent power (Operational Condition 1), a deficiency in plant surveillance test procedures (STPs) was identified. During a safety system functional 1

assessment (SSFA) performed by Quality Assurance, it was discovered that the logic system functional test (LSFT) that verifies the isolation of reactor core isolation cooling system (RCIC)

(*BN*) valve (*V*) E51-F045 on a reactor water level 8 signal was not being completely satisfied.

Technical Specification (TS) Table 4.3.5.1-1-1.b and TS 4.3.5.2 requires that a logic system ,

functional test and simulated automatic operation of all channels be performed at least once per 18 months. The combinations of STP-209-0601, STP-051-4226, and STP-051-4227 were intended to meet the TS surveillance requirements; however, the SSFA revealed that thti procedures do not provide proper overlap. The last performance of these STPs such that the TS requirements were met was on November 13, 1985. This report is submitted pursuant to 10CFR50.73(a)(2)(i)(b) as operation prohibited by the Technical Specifications.

The supplemental repon dated April 2,1993 documented two additional missed overlap points. One l ,

of these was the low pressure core spray (*BM*) / low pressure coolant injection (*BO*) ' l (LPCS/LPCI) injection valves (*V*) E21-F005 and E12-F042A permissive actuation instrumentation channels / circuitry for reactor vessel pressure - low. The other condition is the LSFT requirement to verify that Division II balance of plant (BOP) isolation valves (*V*) will isolate on a high drywell  ;

pressure signal.

This report documents additional conditions identified during the period from March 26,1993 to May 11,1993. These conditions are described in detail in the investigation section below.

INVESTIGATION The logic system functional test (LSFT) requirement to verify that RCIC valve E51-F045 (*V*) will 1 isolate on a reactor water level 8 signal is implemented by the combination of STP-051-4226, STP- .l 051-4227 and STP-209-0601. Review of these procedures has shown that proper overlap between them is not provided.

The logic for this circuit requires that two level transmitters (*LT*) both sense that a level 8 condition exists for the isolation to occur. Each of the level transmitters (*LT*) sends a signal to a trip unit. When the trip unit receives a level 8 signal from the transmitter, it trips, causing a contact to close. The contacts from the two trip units are in series. When both of these contacts close,  ;

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NRC FORM 366A u.S. NUCLEAR REGULATORY COMMISSION APPROVED BY oMB NO. 3150-0104 cs-ag EXPIRES $/31/95 ESTruA'ED BJRDEN PER RESPONSE TO COMPLY W'TM TMS LICENSEE EVENT REPORT (LER) C$ $ 3 E f 8 E RiE! $ $ JE OOMR72 TEXT CONTINUATION @MS yMEN',$"fo"TS*M,*EIS c

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002 - 02 3 10 Tw m. ,o.:. w.w.a .. .mm., e Nw m <m relay (*RLY*) B21-K92 is energized, which causes the E51-F045 valve (*V*) to close.

Surveillance test procedure STP-051-4226 verifies that if there is a high level signal at transmitter

(*LT*) B21-N095A, contact MI/Tl of relay B21-K62 closes. This is one of the two contacts needed to energize relay B21-K92. Surveillance test procedure STP-051-4227 verifies that a level 8 condition at the other reactor vessel level transmitter (*LT*), B21-N095B, will cause contact Ml/Tl of relay (*RLY*) B21-K14 to close. This is the second contact needed to energize relay (*RLY*)

B21-K92. Surveillance test procedure STP-209-0601 jumpers a lead from terminal TB0004-1 and terminal TB0004-03 which supplies 125VDC to relay (*RLY') B21-K92. Valve (*V*) E51-F045 is then checked to see if it closed when the jumper was installed. The combination of these three STPs are designed to check all of the circuitry from the transmitters to the valve. However, ponions of wiring between each of the relays are not checked by the STPs as written. Therefore, proper overlap between the STPs did not exist.

Based on a review of the STPs, TS Table 4.3.5.1-1-1.b, and TS 4.3.5.2 it is apparent that the surveillance requirements were not met. A search through previous performance of these STPs showed that the last time that the surveillance was met was on November 13, 1985. At that time, STP-051-4226 checked the circuitry beyond relay (*RLY*) K62 and actually cycled valve (*V*)

E51-F045. During revision 3 of this procedure it was changed to the method of testing currently used. Based on the correct performance of the nirveillance on November 13, 1985, the surveillance became overdue on October 2,1987. Continuity checks performed by Prompt MWO 059403, on the wiring that was not checked by the STPs, showed that there was no problem with the wiring.

This check also completed the overlap between the STPs. The combination of this MWO and the STPs meets the surveillance requirements of TS Table 4.3.5.1-1-1.b, and TS 4.3.5.2.

Funher reviews of STPs were performed by the SSFA team and by System Engineering. In these reviews two additional missed overlap points were found. One of these was the LPCS/LPCI injection valves E21-F005 and E12-F042 permissive actuation instrumentation channels / circuitry for reactor vessel pressure - low. The other condition is the LSFT requirement to verify that Division II balance of plant (BOP) isolation valves (*V*) will isolate on a high drywell pressure signal.

The investigation of the LPCS/LPCI (*BM*) (*BO*) injection valve (*V*) permissive overlap condition revealed that STP-051-4247 was changed during revision from rev. 6 to rev. 7. This revision deleted the check of relay (*RLY*) E21 A-K108 terminals M1-Tl and M4-T4. The reason for the change called out on the procedure change review form was to " Incorporate Administrative requirements, technical comments, and TCN-88-0094". This failed to indicate that the procedure intent had been changed. Also, the question "Does this revision change the intent of the procedure" was marked "NO". STP-051-4249 was also changed in the same manner and the same reason for 440 FORM M6A (S 92,

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E.E QvENTiAL HENON YEAR NUMBER NUMBER 05000 OF RIVER BEND STATION 458 93 002 02 4 10 rw w n, w.c. ,, ,v.w. .mn m , mc w us o n change was given. No specific n:ason was given for deleting the checks of (*RLY*) E21 A-K108.

Analysis of the available documents indicates that the deletion of these steps was due to an oversight by the personnel preparing the new revision. This revision was not intended to change the purpose of the procedure. The steps were deleted in error. Further analysis shows that the review of the procedure by the independent reviewer should have detected the change in intent, but failed to do so.

Both STPs were corrected to include checks of (*RLY*) E21 A-K108 at the appropriate points in the procedure via change notice (CN)-93-0098 and CN-93-0099. After incorporation of these CNs, STPs 051-4247 and 051-4249 were performed (panially) to demonstrate the operability of (*RLY*)

E21A-K108. Both STPs were completed successfully. This would indicate that these contacts have been operable since the last correct perfonnance of these STPs (STP-051-4247 last done correctly 3-28-89 and STP-051-4249 last done correctly on 10-8-87). Together with previous performances of STP-051-4247,051-4249, and 309-0601, this satis 0es the ponion of the LSFT required by Technical Specification 4.3.3.2 relating to LPCS/LPCI (*BM*) (*BO*) injection valve (*V*) E21-F005 and E12F042A permissive.

The logic system functional test (LSFT) requirement to verify that the Division II BOP isolation valves will isolate on a high drywell pressure signal is panially implemented by STP-508-4202 and verified by the time response surveillance in STP-508-4810. Note that this testing is required by Technical Specifications 4.3.1.2 and 4.3.2.2. The channel B logic circuit for high drywell pressure de-energizes relay C71 A*K4B, opening contacts M4-T4. If a similar signal is provided in channel C, the Division II BOP isolation valves will close.

Revision 9 to STP-508-4202 omitted testing contacts M4-T4 of relay C71 A*K4B. The time response surveillance in STP-508-4810 was also not performed during the last outage because it is scheduled for every other outage. Therefore, the Division II BOP isolation function on high drywell pressure was not tested during the last outage.

A review of previous revisions of STP-508-4202 shows that the point in question was tested before, but it was eliminated from revision 9. The last correct performance of the LSFT was on October 1, 1990. The procedure writer used another STP for the same function in a different channel as an example and eliminated t'~ relay from the test due to a different relay number used in this channel.

In addition, the independent review was inadequate.

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02 5 10 mTm oc..,. - .. .c .e m , m on The STP was corrected to test relay C71 A*K4B at the appropriate points in the procedure via change notices CN-93-0122 and CN-93-0123. After incorporation of these CNs, a panial performance of the STP verified the operability of relay C71 A*K4B.

A ponion of the safety relief valve (SRV) 10-10 set function of the reactor vessel pressure instnamentation was not properly tested as required by TS 4.4.2.2.1.b. This circuit changes the pressure setpoints of several SRVs once the Hrst SRV has lifted, and keeps these setpoints at this lower value until a manual reset button is pressed. These lower setpoints prevent excessive cycling of SRVs. The ponion of the circuit that maintains these lower setpoints until the manual reset is pressed was not tested. The LSFT requirement to verify that the safety relief valve (SRV) IsLo set setpoints remain in effect is implemented by STP-051-4247,051-4248,051-4249, and 051-4250.

A review of past revisions of these procedures revealed that this deficiency has existed since the l implementation of the STP program at RBS.

A portion of the reactor core isolation cooling (RCIC) high differential pressure or line break isolation circuitry was not tested as required by TS 4.3.2.2. This circuit monitors RCIC flow (differential pressure) and will close the RCIC system isolation valves (*ISV*) if a high flow condition exists (indicating a line break). The portion of wire which connects the isolation logic relay contacts to the valve operation relays was nat tested. The LSFT requirement to verify that the RCIC high differential pressure isolation logic is properly tested is implemented in STP-207-5250, 207-5251, and 202-0602. A review of past revisions of these procedures revealed that this deficiency has existed since the implementation of the STP program at RBS.

A ponion of the RCIC low supply pressure isolation circuitry was not tested as required by TS 4.3.2.2. This circuit monitors the supply pressure to the RCIC system and will isolate the RCIC system on low pressure to prevent operation under these plant conditions. The isolation relay contacts M2-T2 of relays (*RLY*) E31 A-K66 and E31 A-K86 and the wire connecting the isolation

( relay contacts to the valve operation relays was not tested. The LSFT requirement to verify that the l RCIC low supply pressure isolation logic is properly tested is implemented in STP-209-5201,209-l 5202, and 209-0603. A review of past revisions of these procedures revealed that this deficiency has existed since the implementation of the STP progam at RBS.

' A ponion of the main steam line tunnel high temperature RCIC isolation circuitry was not tested as required by TS 4.3.2.2. This circuit monitors the main steam tunnel temperature and on a high temperature signal, indicating a leak in the main steam tunnel, closes the isolation valves for RCIC and other systems. The wire connecting the isolation relays to the valve operation relays was not tested. The LSFr requirement to verify that the RCIC portion of the main steam line tunnel high l

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temperature isolation logic is properly tested is implemented in STP-207-4201,207-4202,207-4238, 207-4239, and 209-0603. A review of past revisions of these procedures revealed that this deficiency l has existed since the implementation of the STP program at RBS.

I A portion of the RCIC turbine exhaust diaphmgm high pressure isolation circuitry was not tested as required by TS 4.3.2.2. This circuit monitors the RCIC turbine exhaust pressure and closes the isolation valves for the RCIC system to prevent operation of the turbine under adverse conditions.

The wire between terminal board 0036 terminal I and terminal 2 which connects the isolation relays to the valve operating relays was not tested. The LSFT requirement to verify that the RCIC turbine exhaust diaphmgm high pressure isolation logic is properly tested is implemented in STP-209-4201, 209-4202,209-5201,209-5202 and 209-0603. A review of past revisions of these procedures revealed that this deficiency has existed since the implementation of the STP program at RBS. I A portion of the circuitry which load sheds the emergency standby buses when a degraded voltage i occurs for 3 seconds concurrently with a LOCA was not tested as required by TS 4.3.2.2, Table 4.3.3.1-1.D.l.b and Table 4.3.3.1-1.D.2.b. One contact and a small section of wiring was not tested on Division I, one contact was not tested on Division II, and two contacts were not tested on l Division III. If any of these contacts would not have worked, it would not have prevented load shedding of the buses on a sustained undervoltage for 3 seconds or a degraded undervoltage for 60 seconds. The LSFT requirement to verify that the degraded undervoltage (short time) standby diesel generator start and load shedding logic is properly tested is implemented in STP-309-0601,309-0602, and 309-0603. A review of past revisions of these procedures revealed that this deficiency has existed since the implementation of the STP program at RBS.

l A portion of the sustained undervoltage trip circuitry of service water pump (*P*) ISWP*P2C was not tested as required by TS 4.3.3.2. This circuit monitors the Division III bus voltage and trips the Division III service water pump so that the Division III (HPCS) diesel will not be overloaded on its subsequent startup. A contact in the service water pump switchgear which performs this function was not tested. The 13FT requirement to verify that the sustained undervoltage trip logic for service water pump ISWP*P2C is properly tested is implemented in STP-309-0603. A review of past revisions of this procedure revealed that this deficiency has existed since the implementation of the STP program at RBS.

A portion of the HPCS level control circuitry was not tested as required by TS 4.3.3.2. This circuit l will close the high pressure core spray (HPCS) injection valve on receipt of a reactor vessel high level 8 signal and open it on receipt of a reactor vessel low level 2 signal, thereby controlling reactor vessel level during HPCS operations. Two contacts on IE22A-K13, which prevent manual

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02 7 10 1LXT (U rnore spece ss reowrea, use enterw topees of NHG larrn 3664) (11) or automatic opening (due to other HPCS initiation signals) of the HPCS injection valve prior to a level 2 signal or manual reset of the logic, were not tested. If the untested contacts had failed, the HPCS system would still have been capable of performing its intended safety function. The reactor vessel low level 2 contact in this same circuit was verified to open but was not verified to close.

The wire connecting this circuit to the valve operation relays was not tested. The LSFT requirement to verify that the HPCS reactor vessel level control logic is properly tested is implemented in STP-309-0603. A review of past revisions of this procedure revealed that this deficiency has existed since the implementation of the STP progam at RBS.

A podion of the circuitry that closes the test return valves (*20*) IE22*MOVF0010 and IE22*MOVF011 on a HPCS initiation signal was not tested as required by TS 4.3.3.2. This circuit closes these test return valves to prevent diverting pan of the HPCS flow to the condensate storage tank. Also the valves themselves were not verified to close as required by an LSFT. The LSFT requirement to verify that the test return to suppression pool valve logic is properly tested is implemented in STP-309-0603. A review of past revisions of this procedure revealed that this deficiency has existed since the implementation of the STP program at RBS.

A portion of the HPCS backup battery charger supply breaker trip circuitry was not tested as required by TS 4.3.3.2. This breaker (*BKR*) is required to open on receipt of a HPCS initiation signal so that HPCS power is isolated from the normal bus. The contact that initiates this trip in the switchgear was not tested. The LSFT requirement to verify that the HPCS backup battery charger supply breaker trip logic is properly tested is implemented in STP-309-0603. A review of past revisions of this procedure revealed that this deficiency has existed since the implementation of the STP progmm at RBS.

A portion of the reactor vessel high level 8 trip circuitry for the main turbine was not tested as required by TS 4.3.9.2. This circuit will close the stop and control valves on the main turbine in the event of high water level in the reactor. This is to prevent turbine damage due to water impingement on the turbine blades. This circuit requires 2 channels out of 3 monitoring reactor vessel level to indicate a high level 8 condition before initiating a trip. The wire connecting channels A, B, and C to each other and the wire connecting this 2 out of 3 logic to the main turbine trip relay was not tested. Also there was no test to check that the main turbine stop and control valves went closed.

The LSFT requirement to verify that the main turbine trip logic for reactor vessel high level 8 is properly tested is implemented in STP-501-4201,501-4202,501-4203, and 509-4801. A review of past revisions of these procedures revealed that this deficiency has existed since the implementation of the STP program at RBS.

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THE PAPERWORK REDUCTON PAGJECT [3153-0104;. OFFICE OF MANAGEMENT AND BUDGET, WASWNGTON DC 70$03.

FACILITY NAME (1) DOCFET NUMBER (2) LER NUMBER (4) PAGE (3) ,

ygg sEoA%At HEwsoN NUMBER NUMBER i 05000 l RIVER BEND STATION 458 93 - 002 _ 02 8 10 mT w. . ,, ,,,,w, -- -C - % cm i A portion of the reactor vessel high level 8 trip circuitry for the mactor feed pumps (*P*) was not tested as required by TS 4.3.9.2. These circuits will stop all three reactor feed pumps in the event of high water level in the reactor. This is to prevent overfilling the reactor in the event of failure of the feedwater flow control circuits. These circuits require 2 channels out of 3 monitoring reactor vessel level to indicate a high level 8 condition before initiating a trip. The wire connecting channels '

A, B, and C to each other and several contacts in these circuits was not tested. Also there is no test  :

to verify that the reactor feed pump breakers would open. The LSFT requirement to verify that the ,

reactor feedwater pump trip logic for reactor vessel high level 8 is properly tested is implemented in STP-501-4201,501-4202,501-4203, and 509-4801. A review of past revisions of these procedures l revealed that this deGeiency has existed since the implementation of the STP program at RBS. 1 ROOT CAUSE A change analysis was performed which revealed two causal factors. The primary causal factor was  !

identified as inattention to detail while preparing previous revisions of the relevant STPs. A -!

secondary causal factor was the inadequate review of the procedure by the independent myiewer.

A contributing factor to this event is that there is currently no cross reference matrix that provides association between STPs and their cormsponding overlap point. This makes the current process for

- LSFT verification difGcult during STP revisions.

t Similarities were identified in LERs91-020 and 92-014. LER 91-020 reported an event in which l hydrogen igniters were declared inoperable due to discrepancies between the TS and an STP. The root cause included denciences in the procedure review and revision process. Limited similarity between LER 91-020 and LER 93-002 exists due to these past practices of procedure review and revision. As part of the corrective action for LER 91-020, GSU made significant changes to the  !

procedure review / revision process as described below in the corrective action section. LER 92-014 ,

reported an event in which LSFT overlap for ECCS logic system functional testing (LSFT) STPs did not have adequate overlap. In this event, a similar pattern emerged in that the LSFT had been '

properly performed during preoperational testing and later the STPs wem revised such that proper 4 overlap was no longer provided. ,

CORRECTIVE ACTIONS

1. STP-051-4226 and STP-051-4227 have been revised such that they also check all the wiring ,

and will meet the surveillance mquirements of TS Table 4.3.5.1-1-1.b and TS 4.3.5.2. In addition, STP-051-4247, STP-051-4249, and STP-508-4202 have all been revised to address I

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NRC FDRM 36CA (5 9a f

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NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSloN APPROVED BY OMB NO. 3150-0104 gen EXPIRES 5/31/95 FSDMA4D BURDEN PER RESPONSE TO COMPLY W"N TH4 LICENSEE EVENT REPORT (LER) El#MTE:Lc'3$'EaTmE2 E S OU Nr501s TEXT CONTINUATION Ev"S'5 Cc E "'w"$ E1 7 *S 7S'd $ " $ ^$

THE PAPERWORK REDUCTION PROJECT (3160 0104). OFFICE 08 MANAOf MENT AND BJDGET. WASHINGTON, DC 20503.

DOCFET NUMBER (2) LIR NUMBER (S) PAGE l3)

F ACILITY NAME (1) t4QUENTA. Rf u SON NUMBER NUMBER 05000 OF RIVER BEND STATION 458 93 - 002 -

02 9 10 TEXT (Ir vnwe spece os rowea use *004rore cones of NC form 35A (17>

the LSFT deficiencies concerning the LPCS/LPCI %' injection valve permissive and the Division II BOP isolation function.

2. STPs 051-4247, 051-4248, 051-4249, 051-4250, 207-5250, 207-5251, 209-5201, 207-4201, 209-4202,501-4201,501-4202,501-4203, and 509-4801 were revised to include the ponions of the circuitry that were identified as not having been tested. These procedures were then panially perfonned and operability of their respective circuits was verified.

3. Maintenance work orders (MWOs) R059433, R059435, R059438, R059442, and R059448 verined the logic circuitry that should have been tested under STPs 309-0601,309-0602, and 309-0603 and demonstrated that these circuits are operable. These tests were performed under these MWOs since revision of these STPs is already in progress; however, it is not expected to be completed until later this year. These revisions will include proper testing of all required circuits.

4. A review of all STPs which perform LSFTs which was initially scheduled to start in May 1993 was started in February-March 1993. This review is to verify that the overlap exists between all STPs that perform a portion of an LSFr. It will also generate a cmss reference matrix between the TS, STPs, and procedures for every LSFT overlap point.

5. As of August 31, 1992, per ADM-0003 " Development, Control, and Use of Pmcedures" paragraph 4.6, all persons performing an independent review of new revisions to STPs shall have completed classroom training and on-the-job training (OJT) on the proper method of 10CFR50.59 review. Also a detailed checklist is now required which includes items for verifying that Technical Specifications requirements are met. The required training includes the process to verify TS and USAR requirements. This procedure revision and personnel training was completed subsequent to the inadequate changes made to the referenced STPs and prior to the discovery of the LSFT inadequacies reported in this LER.

6. GSU's accelerated review schedule for STPs which perfonn LSFTs now has an estimated completion date of December 31,1993. A final supplement to this LER will be issued following completion of this review.

NC FORv 366A (5 9h

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 n ear EXPIRES 5/31/95 EST1 MATED BJRDEN PER RESPONSE TO COMPLY WITH TH'S INFORMATON COU.ECTON REOUE ST; 50 0 HRS. FORWA.C LICENSEE EVENT REFORT (LER) COMMEuTS REGARDiNG BURDEN EST,uATE To THE N ORMiTcN AND RE^mS MANAGEMENT BRANCH (MNBB 7714L U.S. NUCLEAR TEXT CONTINUATION REGUOTORY COWSSCN, WASMMTON, DC 20555-D001. AND TO THE PAPERWORK REDUCTON PRO. LECT (31$04104L OFFICE OF MANAGEMENT AND BJDGET, WASHtNGTON. DC 20503.

FACIUTY NAME (1) DOCF ET NUMBER (2) LER NUMBER (6) P AGE (3)

LEiGUEN hAs HEv$ON

, NUMBER NUMBER 05000 OF RIVER BEND STATION 458 93 002 -

02 10 10 1E.XT (If Move Space is requered, use esa*Dorser cop *es of NHC Forrn 3bbA) (11}

SAFETY ASSESSMENT The TS surveillance requirements for LSFT overlap were not satisfied for the following STPs:

051-4226, 051-4227, 051-4247, 051-4248, 051-4249, 051-4250 l 207-4201, 207-5250, 207-5251 ,

209-0601, 209-5201, 209-5202, 209-4202 309-0601, 309-0602, 309-0603

. 501-4201, 501-4202, 501-4203

. 508-4202

. 509-4801 The portions of circuitry that were not tested have since been verified to be functioning properly.

This provides confidence that the portions of the circuitry that have not received the proper surveillance tests have in fact been operable since the expiration of the last surveillances. ,

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