ML20209C023
| ML20209C023 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/22/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8704280568 | |
| Download: ML20209C023 (2) | |
See also: IR 05000458/1986040
Text
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APR 2 21337
In Reply Refer To:
Docket: 50-458/86-40
Gulf States Utilities
ATTN: Mr. James C. Deddens
Senior Vice President, (RBNG)
Nuclear Licensing
P. O. Box 220
St. Francisville, Louisiana
70775
Gentlemen:
Thar,k you for your letter of February 23, 1987, in response to our letter
and Notice of Violation dated January 23, 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,
ottend sWned By
-
.
J. E. G63!!ardo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Gulf States Utilities
ATTN:
J. E. Booker, Manager-
River Bend Oversight
P. O. Box 2951
Beaumont, Texas
77704
Louisiana State University,.
Government Documents Department
Louisiana Radiation Control Program Director
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February 23, 1987
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File Nos. G9.5, G15.4.1
Nuclear Regulatory Commission
Document Control Desk
Washington, D.C.
20555
Gentlemen:
River Bend Station - Unit 1
Refer to:
Region IV
Docket No. 50-458/ Report 86-40
This
supplemental
letter
responds
to
contained
in
NRC
Inspection
Report
No.
50-458/86-40
The
inspection
was
performed by Messrs. D. D. Chamberlain and W. B.
O
Jones
during
the
period
December
1-31,
1986
of
activities
authorized
by
NRC
Operating
License
for
River
Bend
Station.
Gulf States Utilities
Company's
(GSU)
response
to
Notice
of
Violation
8640-01,
" Failure
to
Follow
Surveillance
Test
Procqdure", i:s pro.vided.in the enclosed
attachment
pursuant
to
10CF-R'2.201
and
, Notice of Violatien.
This completes GSU's response to the
.
Sincerely,
/
J. C. Deddens
Senior Vice President
River Bend Nuclear Group
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
P.O. Box 1051
h
St. Francisville, LA
70775
-> J . s 1. - -
M_e.
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FROM U?NRC RIVER BEND
04/17/87 10:50
P.
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turIED IWW!lS OF AMERICA
NOCIERR MKKHA50RY G30ESSICN
Im dE T IDUISIANA
PARISH T NEST PELICIANE
In the Matter of
Dodoet Mos. 50-458
GIF SDGElS tFTILITIES (X3@ANY
(River Bend Station,
Unit 1)
AITIDAVIT
J. C. Deddens, being duly sworn, states that he is a Senior Vice
President of Gulf States Utilities Cmpany; that he is authorized on the
part of said Campany to sign and file with the Nuclear Regulatory
Ctamission 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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--
J. 4. Doddens
Subscribed and sworn to before me, a Notary Prblic in and for the
State and and Parish above named, this
day of bru6% 1h.
J
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[foanW.Middlebrooks
Notary Public in and for
West Feliciana Parish,
My Comnission is for Life.
FR0f1 USHRC RIVER BEND
04/17/87 10:50
P.
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ATTACHMENT
RESPONSE TO NOTICE OF VIOLATION 50-45_8/8640-01
LEVEL IV
REFERENCE
Notice of Violation letter from J.
E.
Gagliardo to J. C.
Deddens
dated January 23, 1987.
REASON FOR THE VIOLATION
The
root
cause
was
determined
to
be
personnel
error.
The
procedure, Surveillance Test Procedure (STP)-209-0302, was
being
performed
to test the Reactor Core Isolation Cooling (RCIC) main
I
pump for operability in accordance with
Technical
Specification
l
4.7.3.b
and
4.0.5.
The
portion
of
the
procedure where the
violation
occurred
realigns
the
system
from
the
Condensate
Storage
Tank
(CST)
test
return
path to the minimum flow path
after completion of the pump flow test.
The test return
valves,
lE51*MOVF059
and
F022,
are
installed
in series and both were
required to be closed by step 7.4.29.
Step 7.4.30 verified
that
the
minimum
flow
valve
1E51*MOVF019
auto
opened
as
a
i
precautionary step to ensure the pump was not
operating
without
minimum flow.
l
The
next. step,
7.4.32,
(7.4.31
had been deleted by Temporary
Change Notice (TCN)) required
the
pump
suppression
pool
suction valve,
lE51*MOVF031,
to be opened in preparation for a
check valve test.
The valve did not open as expected.
It was at
this
point
that- the
operator
at
the
controls
and the test
engineer realized that test return
valve
lE51*MOVF022
had
not
been
closed
as
required
by
Step
7.4.29.
1E51*MOVF031
is
interlocked not to open unless both IB61*MOVF059 and 1E51*MOVF022
are
closed.
This
ensures
there is no chance that suppression
pool water will be pumped to the CST even though the
closure
of
one of the valves will prevent it.
The
test
engineer
failed
to fully complete step 7.4.29 before
signing it off.
Possible
contributing
factors
are
discussed
below:
,
1
This
was
the
first
time
the test engineer performed this
-
particular STP.
This
engineer
was
certified
to
perform
In-Service
Tes.ing
(IST) pump and valve STPs and had in the
past performed numerous other pump
and
valve
STPS
without
incident.
Because
he had not performed this particular STP
before, he was briefed by the Process Systems Supervisor as a
precaution
prior
to
performing
the STP.
Because the test
A
methods and STP's for pump and
valve
In-Service
Inspection
1
(ISI)
testing
are
very
similar
and consistent, it is not
required to assign an engineer who has
previously
performed
the
STP.
Per
2300,
ANSI /ASME
N45.2.6-1978,
FROM USNRC RIVER BEND
04/17/87 10:51
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ATTACHMENT (cont'd)
ANSI /ANS/ANS 3.1-1978, Reg Guide 1.8,
Reg
Guide
1.58,
and
Tech
Staff
Procedure
(TSP)-0001, the engineer was properly
qualified and certified to perform the STP.
It
is
believed
that
the
above
did
not
contribute
directly to the valve
error.
The communication techniques used by the
test
engineer
and
-
the
operator
at
the
controls
were
inadequate
to ensure
instructions given by the test engineer
were
fully
carried
out and confirmed step by step.
It is believed that the lack
of formal communications during the test contributed
to
and
led directly to the valve error.
It is the responsibility of
the test engineer to ensure proper communications
are
being
used during a test.'
The
was
in
the
revision
process
to incorporate the
-
existing
temporary
changes
when
the
violation
occurred.
There
were
no
existing temporary changes to Step 7.4.29 in
which the valve error occurred.
The STP instructed the performer to close
two
valves
in
a
-
single
step.
It is not uncommon to perform two aut ;;ns in a
single step if a)
the actions are closely related.
b)
the
failure
to
perform
one
action
will
not adversely impact
safety or give a test
result
which
appears
valid
but
is
actually
invalid
and
c)
the
step
is
not
a
double
verification restoration step.
The
failure
to
close one of the test return valves in Step
7.4.29 reaulted only in the inability
to
perform
the
next
action
step.
The closure of the valves can be performed in
parallel, and either one will shutoff flow in the line.
The
engineer
failed
to fully read the step and confirm that the
step was
fully
implemented
prior
to
signing- it
off
as
complete.
Although
there were two actions in the step, the
performance of any single or double action step can
fail
if
the
performer does not fully read it, follow it, and finally
confirm it.
CORRECTI_VE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
TCN #86-1947 was issued on 12/23/86 to change
Step
7.4.29
into
two separate steps.
Revision
2
of
STP-209-0302
was expedited and issued on 2/3/87
prior to the next performance on 2/5/87
[\\
Field Engineering personnel responsible for performing
pump
and
valve
attended
a
documented
departmental
training
session on
1/20/87.
The
major
subjects
covered
during
the
!
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FROM USHRC RIVER BEND
04/17/87 10:52
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ATTACHMENT (cont'd)
training
included
a
discussion
of
the
violation, corrective
actions, recent NRC questions on past
performances,
proper
completion
of .
the
survei1>ance
Test
Scheduling
Completion / Exception Forms, recent changes in the Pump and
Valve
Test
Plan, proper communication techniques to use during testing
activities, etc.
Departmental training sessions
have
been
and
will
continue
to be given on an as-needed basis to ensure Field
Engineering
personnel
are
knowledgeable
of
the
latest
developments in their areas of responsibility.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN TO AVOID F_URTHER VIOLATIONS
In
addition to the corrective steps already discussed above, the
following is being taken:
Field Engineering is presently undergoing
-
a
reorganization.
It
is
intended
that
a
new
organization within
Field
Engineering will
take
responsibility
of
performing
Field
Engineering surveillance testing activities, including ISI of
pumps
and
valves.
Rather
than
using
numerous
system
engineers
to
perform
the tests, a small group of qualified
engineers and technicians will
perform
the
testing.
This
effort
was in the planning stages prior to the violation and
is progressing on an independent schedule.
,
.
ADM-0003, " Development, Control and Use.of. Procedures",
Step
-
6.7.1,
requires
all
QA applicable procedures in continuous
.
.use to be reviewed no less than every two years.
It
is
the
policy
of Field Engineering to revise a procedure within two
years as part of this review if a significant TCN against the
procedure
exists
and/or
if
significant programmic changes
need to be made to it.
It is also
the
policy
that
if
an
extensive
TCN
exists that could adversely affect the proper
performance of the procedure, the procedure shall be
revised
as
soon
as
possible.
The
subject
procedure
was in the
process of being revised when
the
violation
occurred.
To
expedite
the
revision
of the remaining procedures, the new
organization discussed above will establish this task as
one
of
its
top
priorities.
It
is
planned
that a qualified
engineer will be assigned full time to accomplish this task.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Corrective actions, other than the procedural revisions on
other
similar
STPs, have been completed.
Revisions on other STPs will
be completed prior to the respective two year review
limit.
In
A
most
cases,
this
will occur by the end of 1987.
The procedure
I
revisions
will
be
prioritized
according
to
the
number
and
complexity of the TCNs and then by the required review dates.
BEND
04/17/87 10:52
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