ML20203L599

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-06

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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l 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 l

River Bend Nuclear Group j

P. O. Box 220 i

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

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J. E. Gagliardo

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J. E. Gagliardo, Chief

, Reactor-Projects Branch

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' Gulf States Utilities

ATTN:~ J. E. Booker, Manager-

Engineering, Nuclear

Fuels & Licensing ,

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

U. S. Nuclear Regulatory Commission

Region IV

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611 Ryan Plaza Drive, Suite 1000 lj

Arlington, Texas 76011 5 M"jg ,

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 NPF-47 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

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Violation.

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Sincerely,

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ADOCK 0500 8 J. Cahill,

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Senior Vice President

River Bend Nuclear Group

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cc:D. D. Chamberlain f

U. S. Nuclear Regulatory Commission / g

Region IV Senior Resident Inspector i

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UNITED STATES OF AMERICA

NUCLEAR REGUIATORT ColetISSION

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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) .

AFFIDAVIT

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

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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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Joan W. Middlebrook)

Notary Public in and for

West Feliciana Parish,

Louisiana

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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ATTACHMENT (Cont'd.)

The vendor manual for the RCIC 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. A review of che RCIC PM

tasks revealed that selected vendor maintenance recommendations

are being performed. Those activities that have not been

incorporated into the PM 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 PM 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

EQ 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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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 EQ 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 EQ 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 EQ 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

.

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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

NPF-47. 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

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ATTACHMENT (Cont'd.)

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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 NPRDS Program Maintenance Work Requests (,MWR) generated on

NPRDS, reportable systems are reviewed for equipment failures. A

NPRDS 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 the NPRDS Program at RBS. 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 10 CFR 50.73) 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 NPRDS Reportable

Components will be reviewed for root cause and trended by INPO

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 NPRDS

program was implemented via PEP-0004 on April 29, 1986.

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