ML20205L023
| ML20205L023 | |
| Person / Time | |
|---|---|
| Site: | River Bend |
| Issue date: | 03/27/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8704020098 | |
| Download: ML20205L023 (1) | |
See also: IR 05000458/1986039
Text
. -
.
-
i -. A
NAR 2 71987
l
In Reply Refer To:
Docket: 50-458/86-39
Gulf States Utilities
ATTN: Mr. James C. Deddens
Senior Vice President, (RBNG)
Nuclear Licensing
P. O. Box 220
St. Francisville, Louisiana
70775
Gentlemen:
,
Th~ank you for your letter of March 11, 1987, in response to our letter and
Notice of Violation dated February 11, 1987. 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,
Ors;tml S!,;ned ef
J. E, o c gya73 ,
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Gulf States Utilities
ATTN:
J. E. Bcoker, Parager-
River Bend.0versight-
P. O. Box 2951
Ceaumont, Texas
77704
Louisiana State University,
Government Documents Department
Louisiana Radiation Control Program Director
bec to DMB (IE01)
8704020098 870327
ADOCK 05000458
bcc distrib. by RIV:
RPB
DRSP
Resident. Inspector
R. D. Martin, RA
SectionChief(RPB/A)
J
RSTS Operator
RIV File
MIS System
RSB-
Project Inspector
R&SPB
R. 11al'1
[A.
y
JPJhu/
C:RPB,
\\
C:RP
/y(0 [t
WRBennett:cs
on
JEGaglirdo
3/A//87
3/@/87
3/fl / 7J
,
i
. . _ _ _
e
.4
. . .
.
O
GULF STATES
UTELITIES COMPANY
river BEND STATION
POST OFFICE 804 220
$f FRANCISvtLLE.LOUIStANA 70775
-
AREA CODE 504
635-6094
346 6651
4
March 11, 1987
RBG- 25462
File Nos. G9.5, G15.4.1
- - m --
Nuclear Regulatory Commission
' I' h _ O, L _ ' JM,_
j]
m-
..
_
Document Control Desk
'I t
v
Washington, D.C.
20555
'l
!
1
MAR I 91987
l!_J
U
Gentlemen:
t
River Bend Station - Unit 1
Refer to:
Region IV
Docket No. 50-458/ Report 86-39
'
-
letter responds to the Notice of Violation contained in NRC
This
Inspection Report No. 50-458/86-39.
The inspection was performed
by Messrs. W. R. Bennett, M. E. Skow and R. B. Vickery during the
O
verioa oece der 8-12, 1986, and January 12-16, 1987 of activities
authorized
by
NRC
Operating
License
for
River
Bend
Station.
3
Gulf States Utilities
Company's
(GSU)
response
to
Notice
of
f
Violation
8639-01,
" Failure
to
Follow
Surveillance
Test
Procedures", and 8639-02, " Failure to Utilize Proper Revision
of
Surveillance
Test
Procedure",
is
provided
in
the
enclosed
j
This
completes
'
attachment pursuant to 10CFR2.201 and 10CFR50.4.
-
GSU's response to the Notice of Violation.
I
Sincerely,
.
d
)
J. Cahill,
r.
.Senior Vice President
Gulf States Utilities Company
WJC
/J /
/je
.
Attachment
Mr. Robert D. Martin, Regional Administrator
cc:
U.S. Nuclear Regulatory Commission
.
Region IV
{
611 Ryan Plaza Drive, Suite 1000
Arlington, TX
76011
River Bend Resident Inspector
A.T
. ,3
g _ p f g { p
P.O. Box 1051
, _ , , . _ ,
St. Francisville, LA
70775
-
c ( v p ( (v r/C
C
,
__
. - _ _ . . . .
..
,
.
V
t'.
~
..
.
.
.
UNITED STATES OF AMERICA
EUCLEAR REGULATORY CIEWISSION
-
.
5
STATE OF LOUISIANA
I
PARISE OF WEST FELICIAEA
5
Docket Bos. 50-458
In the Matter of
CULF STATES UTILITIES C(EEFANY
l
(River Bend Station,
.
Unit 1)
.
W.
J.
Cahill,
Jr., being duly sworn, states that he is a Senior
i
Vice President of Gulf States Utilities Company; that he is authorised
.
-
of said Company to sign and file with the Nuclear Eggulatory
on the part
Commission the documents attached heretos and that all such ' documents
G
are true and correct to the best of his knowledge, information and belief.
1
A
." . Cahill,/dr[
-
.
I
.-
Subscribed and sworn to before me, a Notary Public in and for the
d ay of M ag d , 19ff_.
State and Parish above named, this //
d
T
.
l
I
Y'
./ , i
.
. i ,i
.. ..
. . . , ,
.
Joan W. Middlebrooks
,' Notary Public in and for
-
West Feliciana Parish,
-
My Conunission is for Life.
.
-
-
.
-.
- -.
.-.
-
- -
.
. - . - . . - .
-
.
.'
s-
,.
..
.
- -
ATTACHMENT 1
50-458/8639-01
RESPONSE TO NOTICE OF VIOLATION
-
LEVEL IV
REFERENCE
J.E.
Gagliardo letter to J.C. Deddens,
Notice
of
Violation
-
dated February 11 , 1987.
FAILURE TO FOLLOW SURVEILLANCE TEST PROCEDURES
written
Technical Specification, paragraph 6.8.1.d requires thatshall be es
proceduressurveillance and test activities of safety-related equipment.
,
i
.
Surveillance
Test
Procedure
STP-505-4506,
"RPS/ Control
Rod
,
!
Block-APRM Weekly
CHFUNCT,
Weekly
CECAL,
and
18-Month
(CSI*K605F),"
Revision
6,
step
7.1.47,
requires
that
the
.
operator"... install a jumper from pin 2 to pin 50."
-
-
Surveillance
Test
Procedure
STP-051-4234,
"ECCS/HPCS-Reactor
2
and
High
Level
8
Monthly
-
Vessel Water Level-Low Low-Level
CHFUNCT,
18
Month
CHCAL,
18 Month LSFT (B21-N073L; B21-N673L;
7.1.33.3,
and
Revision
6,
step
O..
B21-N674L)," Revision 5, step
operator " verify 'HPCS High Water
7.1.28.3,
requires
that
the
Level 8 Reset' (H13-P601-16B-C-22A-56) status light is on."
in step 7.1.47 of STP-505-4506,
performed
Contrary to the above,
on November
16,
1986,
the
operator
installed
a jumper at a
in
step
different location than that specified in the procedure; Revision 5 performed
of STP 051-4234,
as
not
applicable
7.1.33.3
4,-1986, the operator designated these stepsthe procedure required these
Revision
6,
performed
on
when in fact,
g
and in step 7.1.28.3 of STP-051-4234,
5,
1986,
the
operator
signed
off
the
step
as
-
satisfactory
September
satisfactory even though plant conditions precluded
performance of this step.
This
is
a
Severity
Level
IV
violation.
(Supplement
I .D . ) (458 / 8639-01)
REASON FOR VIOLATION
The
cause
for
this
violation
is
procedural
inadequacy
and
error.
The
Instrumentation
and
Controls
(I&C)
location
of
jumper
personnel
technician failed to identify the alternate
(TCN).
viaa$~estexdWptioy;orTemporaryChangeNotice
Accessibility of the location specified by the procedure was veryt
.
placement
per
approved
modification
request.
These
restricted.
The
(
of terminal blockswere installed to provide an alternate location
to facilitate testing.
Being aware of
the
revision which was
terminal
blocks
- .-.
..
..
.
.
-
'i
s.
,,
r
,
,
,
ATTACHMENT (cont'd)
[
}k rts kT3 yJV
-
being
processed
and
being
knowledgeable
with the-system, the
technician decided to use the alternate location.
(STP)-051-4234
Revision
5,
step
In Surveillance Test Procedure
and Revision 6, step 7.1.28.3 required the verification
7.1.33.3
of a lighted status light,
which
under
conditions
other
than
having an actual indication of high reactor water level would not
something
be lighted.
The procedure was misleading by requiring
The technician erred when he did
which can not normally be done.
not stop and change the STP
when
step
7.1.33.3
could
not
be
i
performed.
A TCN
is
required
under
these
circumstances by
" Development, Control and Use
Administrative Procedure, ADM-0003," Station Surveillance Test Program".
of Procedures" and ADM-0015,
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEV
,
A TCN
has
been
issued
to STP-051-4234 Revision 6, wording it
.
Either initialing
or
N/A
-
similarly to other sister procedures.
,
h
being placed in the block is acceptable.
4
,
5
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS
'eG
Memorandum
PIC-M-87-007
dated
January 8, 1987 and PIC-M-87-033
dated
March
10,
1987
have
been
issued
to
reiterate
the
requirements
of
administrative
procedures:
ADM-0003,
,
" Development,
Control
and
Use
of
Procedures"
and ADM-0015,
" Station
Surveillance
Test
Program".
IEC
personnel
were
on the
use
of
Comment
instructed via memorandum (PIC-M-87-007)
Control Forms as a means of procedure improvement.
of this violation, the Isc section is conducting a
.
As
a
result
review and revising STP's as needed.
Sister procedures are being
-
l
I
reviewed for uniformity and are being revised as applicable.
DATE THAT FULL COMPLIANCE WILL BE ACHIEVED:
<
River Bend Station is currently in full compliance.
1
\\.
-
.
i
1
. , . .
_ . _ , . . - . _ _ , , . - . . _
.._.._,_.,m.__,,._.m..
._,,,,,__m._
,..,..,m._.
_ _ _ . .
_.-m_,
m.m
_ e
yo.,,.-_m.~.
, _ - _ , - _ ,
_
-_
_ - _ _
_ _ - - - - -
,
'
t
f, , ' '* -
'*
..
.
e
.
i
t
ATTACFMENT 2
l
f
RESPONSE TO NOTICE OF VIOLATION 50-458/8639-02
i
LEVEL IV
-
,
'
,
1
.
REFERENCE
'
J.E.
Gagliardo letter to J.C. Deddens,
Notice
of
Violation
-
dated February 11
1987.
,
FAILURE TO UTILIZE PROPER REVISION OF SURVEILLANCE TEST PROC
written
Technical Specification, paragraph 6.8.1.d requires that
shall be established, implemented, and maintained for
[
proceduressurveillance and test activities of safety-related equipment.
iii
l
Administrative procedure ADM-0005,
" Station
Document
Control,"
t
Revision
5,
dated
February 17, 1986, states, in paragraph 3.3,
j
that the user of procedures
is"...
responsible
to
assure
that
l
!
they
have
the
most
current
revision
prior
to
performing
i
safety-related activities."
~
Contrary to the above,
STP-051-4234,
"ECCS/HPCS-Reactor
Vessel
-
Water
Level-Low
Low-Level
2
and High Level 8 Monthly CHFUNCT,
(])
18-Month CHCAL, 18-Month LSFT (B21-N073L; B21-N673L; B21-N674L) ,"
on
August
6, 1986.
Revision 6 to
was
performed
Revision
5,
STP-051-4234 was issued and in effect on August 4, 1986.
-
This
is
a
Severity
Level
IV
violation.
(Supplement
.
I.D.) (458 / 8639-02)
1
REASON FOR THE VIOLATION
incorrect revision of STP-051-4234,
Personnel
error
caused
an
2
and
High
"ECCS/HPCS Reactor Vessel Water Level-Low Low-Level
i
Level
8
Monthly
CHFUNCT,
18-Month
CHCAL,
18-Month
(B21-N673L; B21-N674L)", to be
used.
On
July
27,
1986,
the
Revision
5
of
STP-051-4234
from Station
'
technician
withdrewEight days later,-Revision- 6- of- STP -051-4.234___
Document Control.
August 6, 1986, ten days after receiving Revision 5
was
issued.
and two days after Revision
6
became
effective,
the
was
performed.
The
technician
did not check to see if the STP had
been revised.
>
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
.
)
A
review
of
Revisions
5
and
6
indicated
that
Revision
6
incorporated
the
TCN's
previously
attached
to
Revision
5.
differences
j
Because Revision 6 contains no significant technical
from
Revision
5
and
the
attached TCN's, there was no adverse
,
{
impact on plant process systems or equipment.
1
_
. .
.
, _ _ _
,
- - _ .
__
_ _ _ _ , _ _ _
_
. . _ - __ __ --
..
. - .
._
q . .. .
'
-
.
i'
f.
f
I
ATTACHMENT 2 (cont'd)
'
s
.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION
" Station
Surveillance
Test
Administrative Procedure, ADM-0015, requires the user to verify that the pro
This requirement
Program",
to be used in the plant is the latest revision.
been clarified to assure a check of revision status prior to
has
use (TCN 87-0124).
and
methods
used
to
Instructions concerning the importance ofthe correct procedure revision is use
t
j
ensure
that
will be provided.
i
1
]
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
issued
to
ADM-0015
to
re-enforce
the
U
- f
TCN-87-0124
has
been
that the procedure used in the plant is
4
necessity
for
ensuring
current.
j
-
March
16,
Training of Maintenance personnel will be complete by
4
1987.
.
- O
,
'
i
.k
i"
,
15
I
L
'
.
i
i
e
(
,
-
_ _ . . _ , . _ . _ ,
_ . . . - . . . - , _ , .
. _ . .
.,
- . .
_ _ _ _
_ _
, _ . _
_m..
- _ _ . _ _ , - . _ , . ,
. _ _ . _ ~ _ _ -
_ _ _ _ . _ _