ML20203L599
| ML20203L599 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/22/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8608290006 | |
| Download: ML20203L599 (2) | |
See also: IR 05000458/1986006
Text
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In Reply Refer To:
Docket: 50-458/86-06
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Gulf States Utilities
ATTN: Willia:n J. Cahill, Jr.
Senior Vice President
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River Bend Nuclear Group
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P. O. Box 220
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St. Francisville, Louisiana 70775
Gentlemen:
Thank you for your letter of July 29, 1936, in response to our letter and
Notice of Violation dated June 24, 1986. We have reviewed your reply and find
it responsive.to the concerns raised in our Notice of Violation. We will review
the implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and will be maintained.
Sincerely,
.,
Origina! Signed Dy
'
J. E. Gagliardo
.
J. E. Gagliardo, Chief
,
Reactor-Projects Branch
CC:
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' Gulf States Utilities
ATTN:~
J. E. Booker, Manager-
Engineering, Nuclear
Fuels & Licensing
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P. O. Box 2951
Beaumont, Texas 77704
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Louisiana Radiation Control Program Director
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GULF STATES
UTILITIES COMPANY
RIVf R BEND STAftON
POST OFFICE BOX 220
ST FRANCISVILLE. sOUISIANA 70775
ARE A CODE t>O4
635 6094
346 8651
July 29, 1986
RBG- 24110
File Nos. G9.5,
G15.4.1
Mr. Robert D. Martin, Regional Administrator
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U.
S. Nuclear Regulatory Commission
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Region IV
611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas
76011
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Dear Mr. Martin:
Ed
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River Bend Station-Unit 1
Refer to: Region IV
Docket No. 50-458/ Report 86-06
This
letter responds to the Notice of Violation, "NRC Inspection
Report No. 50-458/86-06", transmitted to
Gulf
States
Utilities
Company
(GSU)
in
a
letter
dated
June 24, 1986.
That letter
refers to an inspection performed by Mr. J.
R.
Boardman
during
the
periods
February
3-7
and
March
3-7,
1986 of activities
authorized
by
NRC
Operating
License
for
River
Bend
Station.
GSU's
response
to
Notice
of Violation 86-06, "Failur'e to have
Certain Maintenance Procedures",
is
provided
in
the
enclosed
attachment.
This
ccmpletes
GSU's
response
to
the Notice of
Violation.
,
,
Sincerely,
t ,,
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8608080143 860729
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J. Cahill,
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Senior Vice President
River Bend Nuclear Group
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cc:D. D. Chamberlain
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U. S. Nuclear Regulatory Commission
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Region IV Senior Resident Inspector
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UNITED STATES OF AMERICA
NUCLEAR REGUIATORT ColetISSION
.
STATE OF IAUISIAEA
5
PARISE OF WEST FELICIANA
5
.
In the Matter of
5
Docket Nos. 50-458
GULF STATES UTILITIES CGIFANY
l
(River Bend Station,
Unit 1)
.
W.
J.
Cahill,
Jr.,
being duly sworn, stated 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
conssission the documents attached heretos and that all such documents
are true and correct to the best of his knowledge, information and belief.
/
W g Cahill, Jr W
.
Subscribed and sworn to before me, a Notary Public in and for the
State and Parish above named, this M 7 day of h e
f
, 19f4
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(
.
D
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Joan W. Middlebrook)
Notary Public in and for
West Feliciana Parish,
My Connaission is for Life.
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ATTACHMENT
Response to Notice of Violation 50-458/8606-01
Level IV
FAILURE TO HAVE CERTAIN MAINTENANCE PROCEDURES
REFERENCE:
Notice of Violation - Letter to W.
J.
Cahill, Jr.
from J.
E.
Gagliardo dated June 24, 1986.
Item 1
REASON FOR THE VIOLATION
The NRC inspector identified a
failure
to
have
administrative
procedures
requiring
the
incorporation
of
Vendor
Technical
Information
(VTI)
in
maintenance
procedures
and
the
latest
available revision of VTI.
Specifically
identified
during , the
inspection
was
vendor
specified maintenance for
the
Reactor
Core
Isolation
Cooling
(RCIC)
turbine,
safety-related
Rosemount
transmitters,
and
containment cooling fan motors that
had
not
been
incorporated
into maintenance procedures.
GSU
determined
the
cause
of
the
subject violation to be not
having procedures in place that required the
evaluation,
review
and dissemination of pertinent VTI by a single department.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
Programs
existed
separately for receipt, review, evaluation and
dissemination
of
VTI.
To
ensure
one
central
department
coordinates
this
activity,
River
Bend
Nuclear
Procedure
(RBNP)-0032, " Processing of Vendor
Technical
Information",
was
issued
on April 28, 1986.
This upper tier procedure establishes
responsibilities and controls to ensure that
the
incoming
VTI,
including
changes, receive the appropriate engineering / technical
review,
evaluation,
distribution
and
incorporation
into
the
appropriate
plant
procedures.
According
to
this
procedure,
Nuclear
Plant
Engineering
(NuPE)
is
responsible
to
perform
evaluation,
disposition
and dissemination of VTI which includes
General
Electric's
(GE)
Service
Information
Letters
(SILs),
Service
Advice Letters (SALs), and Technical Information Letters
(TILs).
Subsection procedures,
NuPE-AA-65,
" Review of
Vendor
Technical
Information",
NuPE-AA-66,
"GE-NSSS
Modification
Interface", and NuPE-AA-70, " Processing Vendor Information", have
been issued to accomplish the above objective.
,. '
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Page 2
ATTACHMENT (Cont'd.)
The
vendor
manual
for
the
turbine,
when
compared
to
maintenance procedures by the NRC inspection team, produced three
(3)
discrepancies:
1)
yearly
overspeed testing, for which no
maintenance procedure was identified, 2) linkages to be
cleaned,
lubricated,
and
inspected
quarterly, yet maintenance was doing
this yearly, and 3) weekly
and
monthly
preventive
maintenance
(PM)
requirements
for which
no
procedure
was
identified.
Condition Report 86-1109 was issued identifying that there is
no
evidence
of
a procedure for performing a yearly overspeed test.
The Condition
Report
requests
an
engineering
review
of
the
descrepancy
by
3/29/86.
Preventive maintenance tash ME3074 has
been initiated requesting the linkages to be cleaned,
lubricated
.
and
inspected on a quarterly frequency.
tasks revealed that selected vendor
maintenance
recommendations
are
being
performed.
Those
activities
that
have
not
been
incorporated
into
the
Program
have
been
identified
to
engineering (CR 86-1109) for evaluation.
This evaluation will be
completed by 8/29/86.
Vendor
specified
maintenance
for
safety-related
Rosemount
transmitters,
that
had
not
been incorporated into procedures,
concerned
replacement
of
end
cover
"O"
rings.
To
ensure
Equipment
Qualification
(EQ)
requirements
on
safety-related
Rosemount 1153 and 1154 transmitters were met,
Maintenance
Work
Request
(MWR)
22768
was
initiated.
This
MWR called for the
replacement of the "O"
rings.
The work initiated
by
MWR
22768
was
completed
on
April
7,
1986.
With
the
exception
of
STP-203-4207,
"ECCS/HPCS-Suppression
Pool
Water
Level-High
Monthly
CHFUNCT,
18
month
CHCAL,
18
month
LSFT (E22-N055C,
E22-N655C)",
STP-203-4208,
"ECCS/HPCS-Suppression
Pool
Water
Level-High
Monthly
CHFUNCT,
18
month
CHCAL,
18
month LSFT,
(E22-N055G,
E22-N6556)",
and
STP-508-4810,
" Isolation
Actuation-Drywell Pressure High 18 month Response Time (C71-N050,
C71-N650) Channels B and
C",
Instrumentation
and
Control
(I&C)
procedures
have
been
revised
to
clarify the instructions for
replacing the "O"
ring when the
end
covers
are
removed.
The
excepted STP's are scheduled for revision by July 31, 1986.
Equipment
Qualification
Maintenance
Surveillance
Requirement
(EQMSR)
B-003F-01E
has
been
approved
for
indentifying
the
electrical
maintenance
requirements
necessary
to maintain the
qualified life of containment unit cooler motors.
Environmental
Qualification
tasks,
having
a frequency of qne (1) year or
less, have been established in accordance with EQMSR
B-003F-ole.
Tasks
having
a
frequency
of greater than one (1) year will be
incorporated into the EQ system prior to the task due dates.
The
task
group
is
incorporating
the
backlog of EQ tasks with
priorities being dictated by due dates to ensure
due
dates
are
not missed.
,
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.
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Page 3
ATTACHMENT (Cont'd.)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
The
above
corrective
actions
have
been taken to preclude the
occurance of further violations.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
MWR No. 22768 was completed on
April
7,
1986.
RBNP-0032
was
issued
on April 28, 1986.
NuPE-AA-65, NuPE-AA-66 and NuPE-AA-70
were issued on June 6, 1986.
The excepted
STP's
are
scheduled
for
revision
by
July
31,
1986.
The engineering evaluations
concerning the PM task for the RCIC turbine will be completed
by
August
29,
1986,
and
any required actions as a result of that
review will
be
completed
and
full
compliance
achieved
by
September 30, 1986.
Item 2
REASON FOR THE VIOLATION
The
NRC inspector identified a failure of procedures to properly
prescribe PM intervals.
The cause of the subject
violation was
determined
to
be
Maintenance procedures not providing adequate
instructions
when
establishing
" LATE
DATES"
for
Equipment
Qualification
(EQ)
maintenance
activities.
This
condition
resulted from the periodicity tolerances for PM activities
being
generically
adapted
to
maintenance
activities
during the
initial implementation of the plant EQ program.
THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
The periodicity tolerances for EQ activities have
been
revised.
The
due
dates
for
scheduled
activities
are
derived
by
subtracting twenty-five (25) percent from the qualified
life
of
components
having
a qualified life of less than five (5) years,
or by subtracting ten (10) percent from
the
qualified
life
of
components
having
a
qualified
life
of
greater than five (5)
years.
The " LATE
DATE"
for
scheduled
activities
is
the
qualified
life
expiration
date
as
indicated by the Equipment
Qualification Maintenance and Surveillance Requirements (EQMSR's)
issued by Engineering.
Missed EQ maintenance activities are required to be identified on
Condition Reports and require
an
Engineering
evaluation
(Ref.
Administrative
Procedure
(ADM)-0019, " Initiating and Processing
of
Condition
Reports",
and
Maintenance
Section
Procedure
(MSP)-0003,
" Preventative
Maintenance".
An
engineering
evaulation has been performed on missed EQ Preventive Maintenance
.
, .
<
- '. *
Page 4
ATTACHMENT (Cont'd.)
tasks
and
no equipment degradations were identified as a result
of late or missed EQ maintenance activities.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS
The
revised
requirements
for
establishing
and
scheduling
periodicity
tolerances
for
EQ maintenance activities have been
incorporated into MSP-0003.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
MSP-0003, Revision 4, was issued on 3/6/86
properly
prescribing
EQ maintenance intervals.
Full compliance with the requirements
of MSP-0003, Revision 4, is being achieved.
Item 3
REASON FOR THE VIOLATION
The NRC inspector identified that GSU failed to
have
a
program
that
adequately
met ANSI N18.7, Section 5.2.7.1 requirements at
the
time
of
the
inspection.
GSU
committed
to
establish
administrative
controls
to ensure active participation in NPRDS
prior to 100% power operations as referenced by letter under item
2.C.15 in the River Bend Station (RBS) Facility Operation License
During the NRC inspections (February 3-7 and March
3-7,
1986),
RBS's
program
for
implementing
root cause analysis of
equipment failures was
in
it's
final
stages
of
development.
Therefore,
the
cause of the subject violation was determined to
be GSU's interpretation of the requirements for establishing
its
administrative
procedures
for
the root cause analysis program.
Because the NPRDS root cause
analysis
was
not
required
until
achieving
100%
power
operation, the requirements of ANSI N10.7
for
root
cause
analysis
were
incorrectly
deemed
to
become
effective 100% power operation.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
Root
cause
analysis
of equipment failures is now covered under
two separate processes at RBS:
1)
" Initiating and Processing of Condition Reports"
(CRs),
ADM-0019
2)
" Nuclear
Plant
Reliability Data System (NPRDS) Storage
and Retrieval," PEP-0004
-
-
A
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'
,
. . . .
Page 5
ATTACHMENT (Cont'd.)
'
At the time of the NRC inspections, root cause analysis was
only
required
on
Nonconformance
Reports
(NRs)
in
accordance with
ADM-0030, " Reporting and Processing Nonconformances".
The NPRDS Program was fully implemented on April 29, 1986.
Under
the
Program Maintenance Work Requests (,MWR) generated on
NPRDS, reportable systems are reviewed for equipment failures.
A
reportable
component
or
system
is
one
that
hes been
designated reportable by guidelines established for NPRDS by INPO
(Institute
of
Nuclear
Power
Operations).
Safety-related
equipment and other equipment that could cause
the
shutdown
or
prevent
the safe shutdown of the plant are considered reportable
under NPRDS guidelines established
by
INPO.
PEP-0004
is
the
controlling
document
for
Reportable
MWR's are
routed
to
the
responsible
Technical
Staff
System
Engineer
for
further
investigation
of cause of failure.
This
information is then placed on the NPRDS
Component
Failure
Form
and
submitted
to INPO for trending.
General trend reports will
be submitted back to GSU for
review
and
additional
action
as
appropriate.
ADM-0019 was revised (Rev.
4, Eff. Date 5-16-86) to
incorporate the NR program into the CR program.
This
revision
broadened
the
scope
of
root
cause
analysis
to
include
safety-related, QA program applicable, reportable (10 CFR 50.72
and
to the NRC, or degraded safety CR's.
Also,
CR's issued since issuance of the operating license
(August
29,
1985)
were
reviewed
and,
where
applicable,
a root cause was
established for each.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
The CR
Program,
as
governed
by
ADM-0019,
ensures
that
all
safety-related,
QA applicable, etc., component failures reported
on CR's will receive root cause analysis.
The NPRDS Program,
as
governed
by
PEP-0004,
will
ensure
that
Reportable
Components will be reviewed for root cause and
trended
by
for GSU review of equipment failures.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED
GSU
is
currently
in
compliance with ANSI N18.7, 1976, Section
5.2.7.1.
ADM-0019 became effective on May 16, 1986.
The
program was implemented via PEP-0004 on April 29, 1986.
.