RBG-25254, Forwards Supplemental Response to Notice of Violation 8627-02 Re Failure to Follow Surveillance Test Package Per Insp Rept 50-458/86-27 on 860801-0915.Temporary Change Notices Issued Against Listed Procedures

Forwards Supplemental Response to Notice of Violation 8627-02 Re Failure to Follow Surveillance Test Package Per Insp Rept 50-458/86-27 on 860801-0915.Temporary Change Notices Issued Against Listed Procedures

ML20207Q631
Person / Time
Site:	River Bend
Issue date:	01/21/1987
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-25254, NUDOCS 8701280405
Download: ML20207Q631 (5)

Text

I~

l 4

GULF STATES UTELETIES COMPANY RIVER BEND $IADON POST OFFICE BOX 220 $7 FRANCISVILLE. LOUISIANA 70775 ARIA CODE 604 635 6094 346 8651 January 21, 1987 RBG- 25254 File Nos. G9.5, G15.4.1 Nuclear Regulatory Commission

{

Document Control Desk Washington, DC 20555 Gentlemen:

River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 86-27 {-

This supplemental letter responds to the Notice of Violation contained in NRC Inspection Report No. 50-458/86-27. The. inspection was performed by Messrs. D. D. Chamberlain, W. B. Jones and W. R. Bennett during the period August 1 through September 15, 1986 of activities authorized by NRC Operating License NPF-47 for River Bend Station.

Gulf States Utilities Ccmpany's (GSU) supplemental response to Notice of Violation 8627-02, " Failure to Follow a Surveillance Test Package", is provided in the enclosed attachment pursuant to 10CFR2.201 and 10CFR50.4. This completer GSU's response to the Notice of Violation.

Sincerely,

. C. Deddens Senior Vice President

)

Attachment cc. Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 River Bend Resident Inspector 8701280405 870121 PDR ADOCK 05000458 G PDR I

IMPMD SUSES T NERICA IHTFAR perzRJdGN (DetISSICE SUSE T IOUISIANA

• PARISH T M!lST FE[JCIANA

• In the Matter of

• Docket Nos. 50-458 GUEF SDGES 17fILITIES CCB@ANY *

(River Bend Station, Unit 1)

AFFIDPLVIT J. C. Deddens, being duly sworn, states that he is a Senior Vice President of Gulf States Utilities Company; that he is authorized on the part of said Ompany to sign and file with the Nuclear Regulatory Cm mission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

AV J. C. Deddens Subscribed and sworn to before me, a Notary Public in and for the State and and Parish above named, this 5fby ofhDlif(V,19h

/

~ Evw / %t /V j aoan W. Middlebrooks Notary Public in and for West Feliciana Parish, Iouisiana My Cm mission is for Life.

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION 50-458/8627-02 LEVEL IV REFERENCE Notice of Violation - J. E. Gagliardo letter to W. J. Cahill, Jr. dated October 24, 1986.

Request for additional information - J. E. Gagliardo letter to W. J.

Cahill, Jr. dated December 22, 1986.

FAILURE TO FOLLOW A SURVEILLANCE TEST PACKAGE REASON FOR THE VIOLATION When performing Surveillance Test Procedure (STP)-203-1102, " Battery Weekly Surveillance Test for 1E22*S001 BAT", the procedure requires the technician to obtain and record the pilot cell numbers using the previous performance of STP-203-1302, "1E22*S001 BAT Quarterly l Surveillance Test". The pilot cells are defined as the cells having the loweit specific gravities. When obtaining the pilot cell numbers the performer is required to identify and select the lowest cell readings from a four (4) page tabulation of values. During the performance of the quarterly test on August 12, 1986, maintenance personnel inadvertently recorded the cell number having the lowest specific gravity (cell #37) and the cell with the third lowest specific gravity (cell #52). This personnel oversight resulted in a deviation from the procedural requirements of STP-203-1102.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Immediately upon discovering the error of identifying the incorrect pilot cell number, a conservative approach was taken, and the batteries were removed from service. STP-203-1102 was rerun on September 12, 1986 with satisfactory results.

Following the performance of STP-203-1102 on September 12, 1986, the data recorded by the procedure since the last performance of STP-203-1302 (Quarterly Test), was reviewed to ensure compliance with River Bend Technical Specifications and IEEE 450-1975. The review concluded that the data recorded met the intent of IEEE 450-1975 and was within the limits specified by the Technical Specifications.

While performing the history review of the data recorded during the performances of STP-203-1102, it was discovered that STP-203-1102 performed on August 18, 1986 also failed to identify the correct pilot cell numbers. This was caused by personnel not having available the latest performance of STP-203-1302 (Quarterly Test) when obtaining the pilot cell numbers.

.s ATTACHMEFT (Cont'd.)

To ensure these problems are not indicative of a generic problem, the Maintenance Department conducted a review of other Maintenance Surveillance Test Procedures that require data to be transferred from another sourco. The review identified some Radiation Monitoring Calibration Surveillance Procedures and Instrumentation Response Time Procedures as also requiring the transfer of data.

It has been concluded that the Radiation Monitoring Surveillance Procedures provide sufficient methods and controls to preclude the transfer of incorrect data. These procedures require Radiation Protection to provide Maintenance with background radiation readings and source count values. Unlike the Battery Surveillance Procedures, the Radiation Monitoring Procedures involve a separate discipline for the purpose of verifying the data, and the values being transferred are readily identifiable.

On November 7, 1986, CR 86-1708 was initiated identifying Instrumentation Response Time Procedures having incorrect data transferred during their initial performance. An Engineering inver.tigation of this condition revealed no response time was found to excead the Technical Specification response time acceptance criteria.

The CR identified programmatic problems in a number of areas which contributed to the incorrect data being transferred.

As documented on Condition Report (CR) 86-1809 during a review of leak rate data from STP-208-3600, " Main Steam Positive Leakage Control / Penetration Valve Leakage Control System Leakage Rate Test", it was discovered that the wrong value was used to compile Division 1 Main Steam Positive Leakage Control System Leakage Rate. Two tests were performed to determine inboard main steam isolation valve B21*A0VF022C inleakage rate. One test was performed on November 11, 1986 and indicated 174.45 standard cubic feet per hour (SCFH), while another test performed on November 12, 1986 indicated 201.4 SCFH. The value recorded on test dated November 11, 1986 was used to deternine total inleakage rate. However the test dated November 12, 1986 should have been used because it was the last test performed on this valve. Data transfer was determined to be the cause.

Leak rate data was analyzed by a number of different cethods. In each approach, leakage ot B21*A0VF022C satisfied Technical Specification criteria. New STP-208-3600 data is being compiled and will be completed by February 16, 1987.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Temporary Change Notices (TCNs) 86-1416, 86-1418 and 86-1419 have beend issued against procedures STP-305-1100 STP-305-1101 STP-203-1102 an PMP-1036, respectively, to require independent verification for ensuring that the cells with the lowest specific gravities are used as pilot cells.

. s ATTACHMENT (Cont'd.)

To ensure the latest Quarterly Battery Test is available when obtaining pilot cell numbers, the Electrical Maintenance Supervisor will maintain the latest Quarterly Battery Test on file until the next performance of the test. Upon completion of the next scheduled quarterly battery test of the results of the previous quarterly test will be transmitted to the Permanent Plant File (PPF).

Remaining STP's will be reviewed for possible transfer of data concerns.

These reviews will be documented, problems identified, corrections made and procedures revised by July 1, 1987, to prevent recurrence of data transfer errors.

DATE FULL COMPLIANCE WILL BE ACHIEVED The affected Battery Surveillance Test Procedures have been revised. l Remaining procedures will be reviewed and changes issued by July 1, l 1987.

The new STP-208-3600 data will be compiled by February 16, 1987. l L