ML20246N700
| ML20246N700 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/22/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8903280007 | |
| Download: ML20246N700 (2) | |
See also: IR 05000458/1988023
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In Reply Refer To:-
Docket: 50-458/88-23
Gulf States Utilities
ATTN: Mr. James C. Deddens
Senior Vice President (RBNG)
P.O. Box 220
St. Francisville Louisiana 70775
,
Gentlemen:
Thank you for your letter of January 6,1989,'.in response to our letter and
Notice of Violation dated December 7, 1988. 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 detennine that full compliance has been achieved and will be maintained.
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Sincerely.
Original Sb7ed Bp
A. B. BEACH
L. J. Callan, Director
Division of Reactor Projects
cc:
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Gulf States Utilities
ATTN:
J. E. Booker, Manager-
River Bend Oversight
P.O. Box 2951
Beaumont, Texas 77704
Gulf States Utilities
ATTN:
Les England Director
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Nuclear Licensing - RBNG
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P.O. Box 220
St. Francisville, Louisiana 70775
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Louisiana State University,
Government Documents Department
Louisiana Radiation Control Program Director
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GULF STATES
UTILITIES
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JAMES C. DEDDENS
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Senior Vice President
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River Bend Nudear Group
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(504)381 4796
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January
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RBG- 29740
File Nos. G9.5, G15.4.1~
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U. S. Nuclear Regulatory Ccmnission
Docunent Control Desk
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Washington, DC 20555
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Gentlenen:
RIVER BEIO STP2IN - EMIT 1
RITER 'IO: REGIN IV
DOCKET No. 50-458/REPORP 88-23
Pursuant to 10TR2.201, this letter provides Gulf States Utilities
q
Cmpany's (GSU) response to the Notice of Violation contained in NBC
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Inspection Report No. 50-458/88-23. The inspection was performed by
Messrs. E. J. Ford and W. B. Jones during the period Septaber 18 -
Novenber 5,1988 of activities authorized by NBC Operating License NPF-47
$
for River Bend Station - Unit 1.
GSU's response to the violation is
provided in the attachment. This ccrupletes GSU's response to this item.
Should you have any questions, please contact Mr. Rick J. King at (504)
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381-4146.
S'
e y,
. C. Deddens
Senior Vice President
River Bend Nuclear Group
JCD/JEB/IAE/RJK
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Attachnent
cc: U. S. Nuclear Regulatory Ccanission
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
NBC Resident Inspector
P.O. Box 1051
St. Francisville, IA 70775
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UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
STATE OF LOUISIANA
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PARISH OF WEST FELICIANA
)
Docket No. 50-458
In the Matter of
)
GULF STATES UTILITIES COMPANY
)
(River Bend Station - Unit 1)
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 company to sign and file
with the Nuclear Regulatory Commission the documents
attached
hereto;
and
that
all such documents are true and correct to
the best of his knowledge, information and belief.
/
/
e
J. O? Deddens
Subscribed and sworn to before me, a Notary Public in
and
for
the
State
and
Parish
above named, this /t
day of
b/]AutaAn,
1979
My Commission expires with Life.
,
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u
o
ffandiaA. Wut
cia'udia F. Hurst
Notary Public in and for
West Feliciana Parish, Louisiana
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Attachment
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Response to Notice of Violation 50-458/8823
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LEVEL IV
REFERENCE
Notice of Violation - Letter from L. J. Callan to
J.
C.
Deddens', dated
December 7, 1988.
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FAILURE TO FOLLOW MAINTENANCE WORK ORDER PROCEDURES
River Bend Station Technical Specifications, paragraph 6.8.1.a. requires
that procedures for activities identified in Appendix A of Regulatory Guide 1.33,
Revision
2,
February 1978, be established, implemented, and
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maintained.
Paragraph 9 to Regulatory Guide 1.33 requires that maintenance
that can affect the performance of safety-related equipment be performed in
accordance with written procedures.
Administrative Procedure, ADM-0023, " Conduct of Maintenance," paragraph
5.2.1, requires maintenance personnel to adhere to instructions of approved
work documents. Two examples of failure to adhere to instructions
in
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approved work documents are listed below:
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1.
Maintenance Work Order (MWO) R120318 required that maintenance workers
read and sign the MWO and notify a quality control inspector who will
verify that the correct lube oil has been selected for the job.
Contrary to the above, on October 30, 1988, mechanical maintenance
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workers failed to read and sign MWO R120318 as required.
The
individuals also failed to notify a quality control inspector to verify
that the correct lube oil
had been selected for addition to the
Division II diesel generator.
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2.
MWO R123136 required that maintenance workers read and sign the MWO
prior to beginning work.
Contrary to the above, on November 5, 1988, two of three individuals
observed performing work on MWO R123136 had not signed the MWO as
required. This MWO had been initiated to recharge the Division II
standby gas treatment system charcoal filter.
REASON FOR THE VIOLATION
The root cause of these incidents is attributed to Mechanical Maintenance
personnel not following established procedures, personnel error, and a lack
of written and verbal communications.
MWO R120318 was a standing MWO used by Maintenance to add lubricants / freon
to plant equipment as needed. The MWO was written and administrated within
the guidelines of procedure ADM-0028, " Maintenance Work Orders".
Contrary
to the requirements, the MWO job plan required by ADM-0028 was never
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comple'ted.
When Operations requested the oil addition, a mechanic, once
available, initiated the required documentation and delivered the oil
from
the warehouse to the security sally port entrance for inspection prior to
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entering the protected area. The lubricant (issued in 55 gallon drums)-was
left at the sally port for security to inspect.
Because of the delay, the
mechanic was assigned to perform a surveillance test on airlock doors.
After the security inspection, a different maintenance worker picked up the
lubricant by forklift and transported ~it to the diesel
generator (DG)
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building. Since no labels were provided on the exterior of the Division II
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DG bay area, the individual landed the lubricant on the loading dock of the
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middle DG room.
The River Bend Station DG building is designed with three
independent DGs such that redundant Divisions-I and II DGs are physically
separated in the DG building by the Division III DG (High Pressure Core
Spray DG). Therefore, the Division II DG lubricant was unloaded on the
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loading dock of the Division III DG located between Divisions I and II in
the DG building.
Once a maintenance crew became available to install
the lubricant, they
were dispatched to perform the task. However, the individuals were all
different than those previously involved in receiving the request from the
operations department, requesting the lubricant from the warehouse and
unloading it at the DG building.
The three maintenance individuals did not
review the MWO prior to adding the lubricant to the DG in accordance with
the MWO job plan.
Because of other required maintenance activities the Mechanical Maintenance
Foreman assumed the oil addition was a routine task and assigned personnel
accordingly.
Poor communications took place between the mechanics because the original
mechanic did not have the opportunity to turn over data to the subsequent
crew.
All communications were passed through the foremen and were
determined to be inadequate.
Each mechanic involved, as well as the foremen, failed to process the
standing MWO R120318 or assumed the other mechanics involved
were
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initiating the required documentation.
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In addition, the documentation required a quality control review to verify
the correct lubricant was being specified and added to the DG and this was
not performed.
As for MWO R123136, one individual had signed the MWO and the two others
failed to sign the MWO.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
The lubricating oil inadvertently added to the Division III
(HPCS) diesel
contained a zine additive.
This additive is required to ensure proper
lubrication of the Division I and II diesels.
The Division III diesel, however, contains bearings with silver cladding.
Zinc,
in quantities above 10 ppm, will degrade the silver components.
For
this reason, the Division III diesel was declared inoperable.
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Two ' il samples were drawn to determine zinc content and silver damage (if
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any).
The samples, taken shortly after the incident, showed 40 ppm and 36
ppm zinc, and O' ppm silver. The oil and the filters were then changed, and
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the strainers were cleaned.
After the oil
change, a second set of samples were taken from the sump
which determined the zine concentration to be between 5 and 6 ppm.
220
gallons of oil were then drained and replaced with new oil.
The
final
sampling of the Division III oil
concentration to be below 3 ppm, still with 0 ppm silver.
Based on. this
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data, it was determined that the engine could be operated as designed with
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no detrimental effects.
No further corrective actions for the DGs are
required.
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The failure to sign MWO R123136 was discussed with the individuals involved
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and they are aware of the significance involved with this event.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVO Q 91RTHER VIOLATIONS-
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The standing work order concept
for
unscheduled
lubrication
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Q-Applicable equipment is no longer in use.
GSU now requires a specific
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MWO for that lubrication which requires planning, routing through QC for
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establishment of any hold / witness points, a release for work signature
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prior to the job and return to service signature upon completion.
Also being investigated is the use of a specific PM task for unscheduled
lubrication.
This concept may be used but the use of a specific work
document for a specific scope of work with routing tnrough Operations and
QC as noted above will be maintained. The intent of having a work document
and job plan will be maintained whether a MWO or a PM is used.
Since this incident, several changes have been made to the maintenance
organization as part of the Maintenance Enhancement Program.
By this, the
planning effort is nu longer a responsibility of the discipline supervisor.
This effort has been shifted to a centralized
The discipline
supervisor, along with his administrative assistant (group.also an organizational
change as part of the Maintenance Enhancement Program), spend more of their
time scheduling activities on a weekly and day-to-day basis as well as
actual
field supervision. Better scheduling (updated twice each day with
interfacing departments) will allow continuity during each job.
This
organizational change also allows each discipline supervisor (as well as
their administrative assistant) to spend time in the field to assure the
technicians
assigned to him are in compliance with all
applicable
procedures as well as to assist when problems are identified.
A second organizational change has been made in the Mechanical Maintenance
department.
Each foreman has been assigned to a new crew and several
mechanics have been shifted from one crew to another.
This was done to
encourage better communications between the foreman and their crews as well
as between crew members.
In this way, each mechanic will communicate with
the others to determine job status. Assumptions which may have been made
in the past will no longer take place because the mechanic-to-mechanic long
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term relationship no longer exists.
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Each' door to each diesel generator bay has been marked with the appropriate
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nomenclature to identify which machine is behind which door. All commonly
known nomenclatures are listed on each door (Example: Division I Diesel
Generator, "A" Diesel Generator, 1EGS*EG1A). The doors identified include
the personnel
doors inside the Diesel Generator Building, as well as the
water-tight equipment doors on the other side of the building.
The dip
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stick on each diesel has also been tagged to identify the machine. Each
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tag also reminds the user to consult the General Maintenance Lubrication
Manual prior to adding lubricants.
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The concept of attention to detail'is constantly enforced by the Mechanical
Maintenance Supervisor. .This is done on a daily basis while scheduling
work and during work assignments to the mechanics.
This concept was also
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reinforced in a response to Quality . Assurance for surveillance number
05-88-11-08, which required reading by all Maintenance personnel.
The programmatic corrective steps stated above pertain to the signature
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deficiencies associated with MWO R123136.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance has been achieved and all
corrective actions have been
completed.
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