RBG-21245, Responds to Violations Noted in Insp Rept 50-458/85-20. Corrective Actions:All Series Z E&Dcrs Implemented Identified & Associated Documents Revised to Previous Condition

Responds to Violations Noted in Insp Rept 50-458/85-20. Corrective Actions:All Series Z E&Dcrs Implemented Identified & Associated Documents Revised to Previous Condition

ML20129B684
Person / Time
Site:	River Bend
Issue date:	06/07/1985
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20129B666	List: IR 05000458/1985020 RBG-21245, Responds to Violations Noted in Insp Rept 50-458/85-20. Corrective Actions:All Series Z E&Dcrs Implemented Identified & Associated Documents Revised to Previous Condition
References
RBG-21245, NUDOCS 8507290233
Download: ML20129B684 (7)

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, f) l GULF STATES UTILITIES COMPANY 15)f RIVER BENO STATION POST OFFICE BOX 220 ST FRANOSVILLE. LOUISIANA 70775 AREA CODE 504 635-6094 346 8651 I

June 7, 1985 RBG-21245 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission g a nggg Region IV -

5UWLE 611 Ryan Plaza Drive, Suite 1000 s Arlington, Texas 76011 m 13m

Dear Mr. Martin:

_( p River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 85-20 This is in response to the Notice of Violations contained in NRC I&E Inspection Report No. 50-458/85-20. The inspection was performed by Messrs. W. R. Bennett, C. C. Harbuck, and Ms. K. A. Whittlesey during the period March 18-22, 1985, of activities authorized by NRC Construction Permit CPPR-145 for River Bend Station Unit No. 1.

Gulf States Utilities Company's-(GSU) response to the Notice of Violations 85-20-04, " Implementation of a "Z" Series E&DCR," 85-20-01, " Operating Procedures," and 85-20-05, " Performance of Time Delay Control Relay Set Point Verification Testing," is provided in the enclosed attachment. This complet'es GSU's response to the Notice of Violations.

Sincerely

/

. J. Cahill, .

Senior Vice President River Bend Nuclear Group WJC/PJD/PE TFP/ C/amg N

8507290233 850722 8 PDR ADOCK 0500 G

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A'ITACHMENT June 7, 1985

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RBG- 21245 Response to Notice of Violations Reference Notice of Violations - E. H. Johnson letter to W. J. Cahill, dated May 8, 1985.

Refer to Docket 50-458/85-20.

Response to 85-20-04 Implementation of a "Z" Series E&DCR Corrective Steps Which Have Been Taken and Results Achieved All "Z" series E&DCRs which had been implemented were identified and associated documents revised to their previous condition.

Corrective Steps Which Will Be Taken To Avoid Further Violations The lower level procedure was revised to control implementation of "Z" series E&DCRs and appropriate personnel were made aware of the revision.

As a result, "Z" series E&DCRs are not being implemented.

Date When Full Compliance Was Achieved Full compliance was achieved by May 23, 1985.

r Page 2 June 7, 1985 RBG- 21245 Response to 85-20-01 Operating Procedures Corrective Steps Which Have Been Taken and Results Achieved With regard to the examples involving procedure errors, corrective action has been initiated for all 11 examples. The cited procedural deficiencies are being corrected by procedure revision or the processing of temporary changes to the procedures. Explicit corrective action for the 11 examples is provided below:

a. This discrepancy was corrected during the Field Verification Performance of the procedure. Revision One of STP-051-4224 will include Step 7.3.2.8, requiring removal of the temporary jumper.

b. G0P-0003 " Shutdown From Low Power Alarm Point to Hot Standby" -

is in the Revision 1 Review Cycle with these changes incorporated.

c. TCN-85-309 - Has been issued to S0P-0018 Normal Service Water to correct the " Light" color error.

d. TCN-85-310 - Has been issued to SOP-0029 Automatic Depressurization System to incorporate dual sign off column.

c. GOP-0003 " Shutdown From Low Power Alarm Point to Hot Standby" is in the Revision 1 Review Cycle with these changes incorporated.

f. A Procedure Comment Control Form has been issued to revise Step 7.2.23 to Reference 7.2.24. This change will be incorporated into Revision One of STP-051-4224.

g. This error was identified and corrected during the Field Verification Performance of the procedure. Revision One of STP-051-4250 will call for equipment for Step 6.7.

h. The cause of this procedural inadequacy was evidently comment incorporation that changed procedure steps without changing the corresponding item number on Attachment 2. This inconsistency is being corrected in Rev. I to the identified STP. Please note that STP-057-7704 has changed to STP-057-3704. This procedure is currently in the Revision 1 approval cycle,

i. This procedural inadequacy resulted from the procedure specifying a Data Sheet I when, in fact, the data was on an Attachment. This Surveillance Test Procedure is currently in the Revision 1 approval cycle which will eliminate this procedural inconsistency.

J. This discrepancy was identified and corrected during the Field Verification Performance of this procedure. The Acceptance Criteria in Revision One of STP-203-1302 will indicate the

y Page 3 June 7, 1985 RBG-21245 correct limit, as required by the River Bend Technical Specification, for the Battery Average Specific Gravity.

k. This comment has been incorporated into the Revision One mark-up of the procedure. Revision One of STP-203-1302 will specify that the battery charger is in a float condition.

Corrective Steps Which Will Be Taken To Avoid Further Violations Extensive efforts are on going to "walkdown" procedures and identify and resolve deficiencies in preparation for fuel load. Also, procedure reviewers have been verbally cautioned concerning attention to detail and the need to eliminate procedural inconsistencies.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by June 19, 1985.

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Page 4 June 7;, 1985 RBG- 21245 Response to 85-20-05 Performance of Time Delay Control Relay Set Point Verification Testing Corrective Steps Which Have Been Taken and Results Achieved With regard to the reviewed and approved test data sheets for relays associated with the Loss of Coolant Acciden't/ Loss of Offsite Power sequenced loads, the following information is provided for the problems identified: _

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1. 1HVP*FN2A The correct set point time tolerance, in accordance with STT 1HVP.000.049, was placed on the test record.

The proper value (2%) was listed in accordance with STT 1HVP.000.049. s The proper voltage (DC) was listed in accordance with $rr 1HVP.000.049.

The Instruction Manual number blank, in accordance with STT 1HVP.000.049, was determined to be not applicable,because there is no existing manual for the relay. An approved setpoint, data sheet was used.

2. 1HVP*FN2B A retest was satisfactorily performed on STT HVP.000.049. All times were within two percent of the setpoint value.

3. 1HVR*0 CIA and 1HVR*UC1B The Resistance should have been written as greater than 20 mohms.

Correction was made on April 2, 1985.

4. 1GTS*FNIA STT-GTS-000-030 was written and retest was performed satisfactorily on March 25, 1985.

The Setpoint Data Sheet called for approximately a 1% tolerance which was the value used. The SPDS is the controlling document which provided for a more stringent requirement than the procedure.

5. 1HVR*FN11A The test record was changed to reflect approximately .43 sec.

(approximately 2%) on April 13, 1985. Test results were within this requirement.

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6. 1HVC*ACU1A, 1HVC*ACU2A, 1HVC*ACU1B, 1HVC*ACU2B STT-HVC-000-035 was written and retest was performed satisfactorily on

, March 27, 1985 in accordance with 1-G-EE-17.61.

Corrective Steps Which Will Be Taken To Avoid Further Violations The JTG review staff has been instructed by the JTG Chairman to provide a more stringent critique of completed generics and PT/AT test results to preclude recurrence of this problem.

The Plant Manager has issued a memorandum to test personnel, Plant Staff Personnel and Test Technicians that emphasizes the use of correct procedures, qualified personnel and documentation quality.

Date When Full Compliance Was Achieved Full Compliance was achieved by June 5, 1985.

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UNITED STATES OF AMERICA NUCLEAR REGULATORT C(BetISSION STATE OF IAUISIANA 5 PARISH OF WEST FELICIANA 5 In the Matter of 5 Docket Nos. 50-458 GULF STATES UTILITIES COMPANY 50-459 (River Bend Station, Unit 1)

AFFIDAVIT l

W. J. Cahill, Jr., being duly sworn, states that he is a 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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. Cahiff,' Tr.[F Subscribed and sworn to before 9e, a Notary Public in and for the k day of x \ fine State and Parish above named, tM' t

, 19 b O .

I w On i Li oan W. Middlebrooksl

[NotaryPublicinandfor West Feliciana Parish,

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Louisiana My Commission is for Life.

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