ML20059H785

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-458/93-27 on 930925-1106.Corrective Actions:Will Incorporate Necessary Changes Into Retest Program by 940415

ML20059H785
Person / Time
Site:	River Bend
Issue date:	01/18/1994
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9401310155
Download: ML20059H785 (12)

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9ENTERGY l"'feTJ"J" "*' '""

PO Box 220 i

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l January 18,1994 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i

Subject:

Response to NRC Notices of Violation IR 93-27

Reference:

River Bend Station - Unit 1/ Docket 50-458/93-27

( File Nos.: G9.5, G15.4.1 RBG-39921 Gentlemen:

Pursuant 10CFR2.201, please find attached Entergy Operation's respons to notices of violation described in NRC inspection Report (IR) 93-27. The inspection was performed by Mr. Ward Smith and other Region IV inspection personnel during September 25 through November 6,1993, of activities authorized by NRC Operating License NPF-47 for River Bend Station - Unit 1 (RBS).

Should you have any questions, please contact Mr. D. N. Lorfing at (504) 381-4157.

Sincerely, gmw  %

James J. Fisicato Manager, SA&QV 4

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JJF/jr enclosures cc: U. S. Nuclear Regulatory Commission, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Resident inspector

P. O. Box 1051 St. Francisville, LA 70775 1

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9401310155 940118-PDR ADOCK 05000458 f ,

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9 ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-458/9327-02 BEFERE E F, Notice of Violation - Letter from A. B. Beach to John R. McGaha dated December 17,1993 YLQLA_TIOR Failure to Condufet Post Maintenan_co Testirig 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," states, in part, that a test program shall be established to assure that all e ting required to demonstrate the structures, systems, and components will perform satisfactorily if service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design document.

Contrary to the above, on October 27,1993, the licenseo performed maintenance on the power supply breaker for Residual Heat Removal (RHR) B shutdown cooling suction Valve 1E12*F006B by adjusting the instantaneous overcurrent trip setting under Maintenance Work Order R172573; however, no post maintenance test was specified to verify and document that the breaker would trip within design tolerances.

REASON FOR THE VIOLATION On 10/27/93 at approximately 1600, Operations was attempting to open valvo 1E12*MOVF0068, (RHR "B" shutdown cooling suction valve) per Surveillance Test Procedure (STP)-204-6304 " Loop B RHR Valve Operability Test" when the supply breaker (1EHS*MCC2FF BRK 3A) tripped. Maintenance Work Order (MWO) R172573 was issued by Operations to investigate and repair or rework the valve as required.

When an MWO package is generated for troubleshocting a condition or problem, the maintenance planner incorporates the applicable documents and procedures into the work package. involved in this process are the post maintenance test requirements which are the specific test procedures performed as required by Operations, Maintenance, System Engineering and other groups such as the motre operated valva (MOV), in-service test (IST) and local leak rate test (LLRT) groupt When planning is completed, the MWO package is routed to the applicable departments for their review. Each department reviews their specific section of

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i the MWO package for accuracy, completeness, and determination of proper rotest requirements.

The work package for the residual heat removal 'B' shutdown cooling suction valve 1E12*F0068 provided the instructions to the technicians to adjust the trip coil setting por Drawing BE200A. The drawing allows for an increase of the trip coil setting to prevent " Nuisance" breaker trips and does not require a retest of the coil for adjustments made within the specifications listed. The reason for the ,

violation is past maintenance practice did not require a retest as long as the adjustment was within the set specifications. This was a failure to recognize the need for a retest in the job plan for an adjustment of the setting.  ;

Retests included in the MWO package addressed operability of the valve via the in-service test (IST) STP and Corrective Maintenance Procedure (CMP) 1253, "Limitorque Motor Operated Valves" which requires a stroke and time test. The package contained a retest for the replacement of the trip coils which would have tested them por Preventive Maintenance Procedure (PMP)-1020 had the coils been ,

replaced. No rotest was specified nor performed for an adjustment of a trip coil within the allowable range set forth in Drawing BE200A.

In order to address the NRC's concern expressed in the transmittal letter of IR 93- '

27 on the corrective action taken in response to a similar event which took place February 24,1993 (see response to Notice of Violation IR 9305-01 dated June 16,1993), a comparison of the two events was made. The 9305-01 event deals with the failure to perform the proper rotest after the replacement of solenoid operated valve (SOV) lAS*SOV36A. The MWO listed STP-122-6301 " Instrument  ;

Air Valvo Operability Test" as the retest for the SOV. This was determined using the maintenance planning guide and the in-service inspection (ISI) pump and valve index. The STP contained both a stroke time test and a local stroke verification.

.The system engineer, during his review for IST applicability, determined that only a stroke time test was required for retest. Thus, retest requirements were changed from those specified in the plan.

This violation (9327-02) deals with the failure to specify retest requirements for an adjustment of a trip coil on an RHR breaker. Past practices had been not to perform a retest as long as the adjustments performed were within predetermined specifications. This past practice resulted in personnel failure to recognize a need for a retest.

In summary, in 9305-01, STP-122-6301 was originally listed in the job plan but was later incorrectly Jeleted by the systems engineer when he determined a stroke test only was required. In the 9327-02 event, an adequate retest (PMP-1020) for trip coil adjustment was not specified. The corrective action for violation 9305-01 was to review any procedures that supplied rotest instructions that could be '

applied as post maintenance retests and list those rotests in maintenance planning.-

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The corrective action for NOV 9305-01 would not have prevented the omission of a retest that occurred in Violation 9327-02, although both violations address the failure to perform an adequate retest.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A successful retest was performed on 1E12*MOVF006B (RHR "B" shutdown cooling suction valve) using PMP-1020 after the retest requirement was identified.

This retest was accomplished during the performance of MWO R155357 which was written to perform additional maintenance checks for determining the cause of the breaker trip.

The maintenance planning supervisor, during the regular planning staff meeting, instructed the electrical planners to ensure the use of PMP-1020 for retest on any breaker work which involved the changing of a trip coil setting.

. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLA.T_ IONS A review of the maintenance retest program is being conducted comparing it to INPO good practices, NMAC guidelines, and processes in use at other nuclear plants. This review will be completed by February 18,1994. Once this review is complete, River Bend will incorporate the necessary changes into the retest program. Changes will be incorporated by April 15,1994.

CMP-1026 " Corrective Maintenance of MCC Starters and Circuit Breakers" will be revised to list the proper retest within the body of the procedure instead of using PMP-1020 " Preventive Maintenance of Thermal Overload Relays, Unitized and Molded Case Circuit Breakers". The procedure revision will be completed by '

February 28,1994.

A document change notice (DCN) will be issued to add a statement to Drawing BE200A specifying that after adjusting the trip coil, the breaker shall be tested to '

verify performance as specified. The DCN will be issued by January 24,1994.

An evaluation will be performed to determine impact on other breakers which have ')

, been adjusted and not rotested. Should any additional action be required, a supplement to this report will be provided. The evaluation will be completed by February 28,1994. I DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.

Full compliance was achieved upon rotest of the RHR valve. Additional actions will be completed as listed above.

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ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION 50-458/9327-03 LEVELIV REFERENCE Notice of Violation - Letter from A.B. Beach to J.R. McGaha dated 12/17/93 ,

VIOLATION Technical Specification 6.8.1.d requires, in part, that written procedures shall be implemented covering surveillance and test activities of safety-related equipment.

Licensee Administrative Procedure ADM-0015, Station Surveillance Test Program, Section 8.1, Revision 14, requires surveillance test procedure steps to be performed in sequential order unless specifically stated otherwise in the surveillance test procedure.

Contrary to the above, the following are two examples of where procedures were not followed in the prescribed sequential order.

Examole 1  :

On October 20,1993, during surveillance testing in accordance with Surveillance Test Procedure STP-309-0203, " Division ill Diesel Generator Operability Test," ,

Revision 9A, the operator skipped from Step 7.3.2.13 to Step 7.3.7 without first completing Steps 7.3.2.14 through 7.3.6.5.

g_xample R On October 27,1993, during surveillance testing of the Division ll low pressure '

core spray line fill pump in accordance with Surveillance Test Procedure STP-204- -

6302, " Division ll LPCI (RHR) Pump and Valve Operability Test," Revision 4, the i operator went out of sequence while placing test gauges into service, failing to properly check an equalizer valve open and to properly elevate the differential pressure gauge as required by Section 7.5 of the procedure.

[N RESPONSE TO EXAMPLE 1: -

i fLEASON FOR THE VIOLATION A procedural non-compliance occurred in the performance of Surveillance Test Procedure (STP)-309-0203. The diesel had been placed into maintenance mode at Step 7.3.5.12 to perform prestart filter inspection and remained in maintenance mode until Step 7.3.7.6 at the completion of the barring evolution. Steps 7.3.5.14 and 7.3.7.1 were not performed in order to maintain the diesel in

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' maintenance mode for both evolutions, instead of performing them independently as prescribed by the STP. Total time in maintenance mode was 17 minutes (1420 until 1437) as documented in the short term LCO log and main control room log.

STP-309-0203, Rev 9A was approved on 01/27/93. This revision required the placement of the diesel into maintenance mode on two separate occasions in the i diesel prestart preparation section of the procedure. These steps were not performed "as written" in accordance with ADM-0015, " Station Surveillance Test Program," Section 8.0. '

The operator performing these steps believed he had the option to modify the  ;

sequence of prerequisite steps in an STP. These steps were in the body of the '

procedure, entitled "Prestart Preparation"; therefore, both assumptions were incorrect. In addition, the operator failed to discuss this decision with the on-duty -

shift supervisor (SS) or control operating foreman (COF). Upon completion of the  ;

STP, the operator discovered while transferring initials from a field copy of the STP +

he could not sign off the omitted steps. At this point, he questioned his previous  !

decision and brought it to the attention of the SS/COF.

1 The steps omitted did not impact the STP acceptance criteria or Division 111 diesel operability. '

Root cause of this violation was attributed to poor work practice. Contributing i factors included training deficiencies related to operator's knowledge of ADM- ,

0015 requirements and format deficiencies in STP-309-0203 requiring maintenance mode to be entered twice during prestart preparation.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED I Condition Report 93-0632 was generated by the operator to address the procedural non-compliance. I i

STP.309-0203 has been revised to provide better " Human Factoring." The j prestart checks, requiring the mode switch to be placed in the maintenance mode,  :

are now accomplished within a single mode switch change. j An OSP-0018, " Operations Accountability Review," meeting was conducted to determine corrective actions needed to prevent recurrence.

Disciplinary action was administered by Operations management.

A training request form (93-052) was completed by Operations and submitted to the Training Department to provide training on CR 93-0632 and the applicable

_ requirements of ADM-0015, " Station Surveillance Test Program," to the current requalification training module. Training was completed on January 03,1994.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER FINDINGS All corrective steps to avoid further findings have benn completed as described above.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.

IN RESPONSE TO EXAMPLE 2:

[LEASON FOR THE VIOLATION During the performance of STP-204-6302, Rev. 4C, the STP performer failed to close the manifold equalizing valve as required in the note prior to Step 7.5.11, causing incorrect data to be entered. Original data taken with the manifold equalizing valve open was 7.0" H2 0. When this procedure violation was brought to the performer's attention, the STP performer re-performed the step correctly, obtained a reading of 21" H2 O and corrected the data to read 21" H2 0.

The note prior to Step 7.5.11 in STP-204-6302, Rev. 4C stated:

NOTE 4-way Instrument Manifold valve should have equalizing valve in the full closed position prior to taking measurements.

The performer failed to read the note preceding Step 7.5.11. The original reading recorded appeared to be too low to the performer. The performer investigated and found the equalizing valve to be open. He closed the valve and corrected the previous entry. The correction was accomplished prior to moving on to the next stop.

Step 7.5.3 requires the performer to open the equalizing valve when installing the test gauge. No other step requires the performer to close the equalizing valve.

The use of a note to ensure that the valve is closed is unsatisfactory and not in accordance with Operations Station Procedure OSP-0005, " Operations Procedure Review and Revision," and ADM-0003, " Development, Control and Use of Procedures."

OSP-0005, Attachment 5, "STP Procedure Review Checklist," provides the following guidelines:

Item 10 - Are NOTES, CAUTIONS and WARNINGS free of action steps?

River Bond Nuclear Procedure (RBNP)-0001, Attachment 6, " Procedure Review Checklist", provides the following guidelines:

Items 11,12 - Are NOTES, CAUTIONS and WARNINGS free of action  ;

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The failure to set the test rig at the proper elevation was due to the performer's lack of experience and attention to detail. The procedure directed where the test gauge should be locateJ, but the performer failed to road the step carefully, thus causing confusion on gauge location. Operator inexperience contributed to the cause of this event.

The instrument test kit did not specify what hoses were to be used with each instrument. The two hoses used with the differential pressure (d/p) instrument were too short to fulfill the installation height requirement (i.e., install test instrument at same height as permanent instrument). The performer was

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attempting to compensate for this by trying the instrument in different positions.

After trying several different heights and positions, the performer determined that the height requirement was not applicable for this type of instrument. During this process the performer had made several entries with different readings on this I step. The correct reading was finally entered prior to moving on to the next step.

The procedure was inadequate in that it did not provide specific instructions on test rig installation, venting and valve alignm'ent required to obtain correct data.

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.l The root causes for this incident are: '

1. Installed plant gauges are not calibrated. The performer has to connect j temporary calibrated test instruments instead of using the installed  ;

instruments. The installed instruments are not kept calibrated and their 1 instrument ranges are not acceptable for IST testing. I

2. No formal training is conducted for the IST/ OPS test group on installing test instruments and breaching contaminated systems.

3. Procedures are inadequate. Test procedures do not provide sufficient detail for a first time user to perform correctly. Test performers rely on basic

" Tool-box skills" during gauge installation and removal.

C_OjlRE_CTIVE STEPS THAT HAVli BEEN TAKEN AND RESULTS ACHIEVED l

Although System Engineering and Operations walk down IST/STPs prior to performing the test, there has been a lack of consistency in the methods used in the walkdown. To correct this inconsistency, a checklist has been developed to 1 guide future IST/STP procedure walkdowns. The checklist requires the individual i to answer many questions, one of which concerns whether there is sufficient detail to allow efficient performance of the procedure. Also:

1. STP-204-6302, " Division ll LPCI (RHR) Pump and Valve Operability Test",

has been revised to incorporate the findings of the violation event:

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a) Detailed instructions have been provided on installation, venting and valve manipulations of the test equipment.

b) The calculations required in performance of Section 7.5 have been arranged in succeeding steps.

r c) The note concerning the equalizing valve position has been made into a procedure step with a sign-off.

2. Operations has provided a list of gauges that need calibrating to the I&C-Department. This will eliminate approximately 90% of the test instrument installations currently required by the procedures.

3. The I&C Department has provided interim awareness training in the form of shop demonstrations to the IST/STP performers on the installation, venting and removal of test instruments.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS .

The Training Department has been requested to provide training to IST/STP performers on the proper methods of breaching contaminated systems and installing test instruments. The training will be completed by April 30,1994.

The I&C Department will maintain the list of gauges, provided by Operations, calibrated in support of IST/STP testing. The list will be completed by April 6, 1994.

A modification request will be developed by Engineering and reviewed by the Change Review Board to determine the need for revising instrument range requirements for IST/STP testing. The review will be completed during the first quarter of 1994.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved. Additional corrective action is scheduled as stated above.

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': l ATTACHMENT 3 REPLY TO NOTICE OF VIOLATION 50-458/9327-04 LEVELIV REFERENCE Notice of Violation - Letter from A.B. Beach to J.R. McGaha dated 12/17/93 VIOLATION Technical Specification 6.8.1.d requires, in part, that written procedures shall be -

implemented covering surveillance and test activities of safety-related equipment.

Contrary to the above, on October 27,1993, Surveillance Test Procedure STP- l 204-6302, " Division 11 LPCI (RHR) Pump and Valve Operability Test," Revision 4,  !

was found to be inadequately maintained, in that Step 7.5 did not provide instructions for venting of test gauges, and restoration of independent verification Step 7.5.32 failed to restore Valves 1RHS*V53 and *S4 to the locked condition.

BEASON FOR THE VIOLATION During the performance of STP-204-6302, Rev. 4C, procedure inadequacies were observed. Step 7.5.32 provides incorrect instructions for pressurizing the test differential pressure (d/p) instrumentation which may affect calibration of the test equipment.' The installed plant gauges are not calibrated, therefore the performer has to install temporary calibrated test instruments instead of using the installed equipment. The test procedure was inadequate in that it did not provide sufficient detail to install and properly vent the test rig. The performer relied on basic skills during installation, testing and removal.

Step 7.5.14 and 7.5.15 require suction and discharge pressure to be recorded; however, nineteen steps further into the STP Step 7.5.34 requires a calculation of the difference of these pressures to determine compliance with acceptance criteria. The performer chose to calculate the d/p to be acceptable prior to continuing the test. This was out of sequence with the procedure. Verification of the d/p was not required for the nineteen subsequent steps. The performer compensated for the inadequacies of the procedure in an effort to reduce radiation exposure.

1 Section 4.0, " Required Equipment," does not provide a specific list of equipment, tools and consumables required to satisfactorily complete the testing. The I procedure was deficient in not providing a list of specific equipment to allow testing. The root cause of this deficiency can be attributed to not having a l checklist specifically designed to aid in the procedure walkdown process that  !

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would cause the performer to consider the equipment necessary to support test performance.

CORREC_T_IVE STEPS TAKEN AND RESULTS ACHIEVED Management expectations for strict adherence to procedures have been continually reinforced during the last quarter of 1993. The number of procedure changes (162) processed since September 1,1993 provides evidence that the majority of Operations Department employees understand the significance of this '

commitment. In addition, the Operations Department /IST Group is reviewing / revising proceW es to improve the quality of the procedures. As a result, sixty-eight (68) p ocvure revisions have been completed, with 107 change notice revisions completed The management observation program currently in place will aid the Operations Department in identifying those individuals who have not fully accepted their individual responsibility for procedure compliance. OSP-0018, " Operations Accountability Review," meetings will be conducted for those incidents identified and appropriate actions taken accordingly.  ;

This event pointed out several areas requiring upgrade and improvement. STP-204-6302, " Division 11 LPCl (RHR) Pump and Valve Operability Test," was revised to incorporate the findings identified by this report. Precise instructions are i provided for installing and venting the test gauges. The locked valves (1RHS*V53 and 54) require verification and initiating of the locked condition. A checklist has been developed specifically to guide the procedure walkdown process that will cause the performer to address all areas of the procedure.

l The calculation of pump d/p and recording of the data is in succeeding procedure steps. Section 4.0, " Required Equipment," has been enhanced to provide a full list i of equipment requirements for performing the test.

Operations has provided a iist of gau;;es for calibation to the I&C Dencrtment.

This will eliminate approximately 90% of the test instrument installations currently l required by the procedures.  ;

in the interim until the IST/STP performers have been properly trained, the Instrumentation and Control (l&C) Department is providing shop demonstration training on how to install and remove all temporary calibrated test instruments.

The operators working in the IST/STP program have received this training.

The results of these immediate corrective actions have brought an added awareness to IST/STP testing. Emphasis has been placed on procedures being completo and workable.

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CQBRECTIVEE_EPS WHICH WILL BE TAKEN TO AVOlD FURTHER VIOLATIONS The l&C Department will provide shop demonstration training as required and as requested by Operations on how to install and remove all temporary calibrated test instruments to personnel performing IST tests. The I&C Department will maintain the identified gauges calibrated per MSP-0003, to be completed by April 6,1994.

A modification request will be developed by Systems Engineering ~and reviewed by the Change Review Board to determine the need for revising instrument range requirements for IST/STP testing. The review will be completed during the first quarter of 1994, i The Training Department will provide training to IST/STP performers on the proper methods of breaching contaminated systems and installing test instruments. The training will be completed by April 30,1994.

Testing has boon modified to incorporate a three way valve to permit venting after the test gauge is installed. This item is completed.

DATE WF.EN FULL COMP _LIANQ_E WILL BE A_CHIEVED Full ccmpliance has been achieved. Additional corrective action will be completed as stated above.

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