ML20247P495
| ML20247P495 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/19/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8909270187 | |
| Download: ML20247P495 (2) | |
See also: IR 05000458/1989028
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_ Docket:.'50-458/89-28
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T Gulf States Utilities
E ATTN:: :Mr. James C. Deddensi
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Senior Vice President (RBNG)'.
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P.O.' Box 220-
St'.'Francisville.. Louisiana 70775
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,
, Gentle' men:
'
Thank you'for your letter of. August 25, 1989, in response to our letter;and
. Notice of, Violation dated' July 28, -1989. '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,
,
James L.' Milhoan, Director
Division of, Reactor Projects
CC:'
Gulf States Utilities
ATTN:
J. E. Booker, Manager-
'
River Bend Oversight
'P.O. Box 2951
1
Beaumont, Texas 77704
' Gulf States Utilities
ATTN:
Les England, Director
Nuclear Licensing - RBNG
P.O.~ Box 220'
St. Francisv111e, Louisiana 70775
- Louisiana' State University,
Government Documents Department
Louisiana Radiation Control Program Director
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GULF STATES
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August 25, 1989
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File Nos. G9.5, G15.4.1
U. S. Nuclear Regulatory Commission
Document Control Desk
Washington, D.C.
20555
_
Gentlemen:
River Bend Station - Unit 1
Refer to: Region IV
___ Docket No. 50-458/89-28
Pursuant to 10CFR2.201,
this letter provides Gulf States Utilities
Company's (GSU) response to the Notice of Violation for NRC Inspection
Report No. 50-458/89-28.
The inspection was performed by Messrs. E.
J. Ford and
W.
B.
Jones during the period June
1-30,
1989 of
activities authorized by NRC Operating License NPF-47 for River Bend
Station - Unit 1.
GSU's response to the violation is provided in the
attachment.
GSU's response to this item is complete.
Should you have any questions, please contact Mr. L. A. England at
(504) 381-4145.
Sincerely,
,f. h /h
J. E. Booker
Manager-River Bend Oversight
River Bend Nuclear Group
JEB/LAE/
MSF/RGW/ch
Attachment
cc: U. S. Nuclear Regulatory Commission
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
Senior Resident Inspector
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P.O. Box 1051
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St. Francisville, LA 70775
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UNITED' STATES OF AMERICA
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' NUCLEAR REGUIJLTORY COMMISSION
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' STATE OF LOUISIANA
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PARISH OF NEST FELICIANA
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Docket No. 50-458
'In the-Matter of
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GULF. STATES UTILITIES COMPANY
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(River Bend Station - Unit 1)
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J.
.E.
Booker,: being ' duly
sworn,
states
that
he
is
Manager-River
Bend
Oversight .for
Gulf
States
Utilities
Company;
that he is authorized on the part of said company to-
-
sign'and file 'with
the
Nuclear
Regul' tory
Commission -the
a
documents' attached' hereto;
that
he
has
read
all
of the
statements contained in such documents
attached
thereto
and
made
.a
part
thereof;
and that all such statements made and
matters set forth therein are true and correct to the best
of
~his knowledge, information and belief.
/) . f. A$cdh
[. E. Booker
-Subscribed
and sworn to before me, a Notary Public in and
for the State and ' Parish above
named,
this
2. 5 *
day
of
[}11 cud
19 d .
My Commission expires with Life.
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Mr
Notary Public in and for
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West Feliciana Parish, Louisia[na
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ATTACMENT
RESPONSE TO NOTICE OF VIOLATION 50-458/8928-01
LEVEL IV
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REFERENCES
Notice of Violation - Letter from J. L. Milhoan to J. C. Deddens, dated Ju".y
28, 1989.
INADEQUATE SYSTEM CONFIGURATION CONTROL
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 maintained.
Paragraph 9 of Regulatory Guide 1.33 requires that maintenance activities
that can affect the performance of safety-related equipment be properly
preplanned and performed in accordance with written procedures, documented
instructions, or drawings appropriate to the circumstances.
Contrary to the above, Administrative Procedure ADM-0028, " Maintenance Work
>.
. Order,". Revision 10, was not appropriate in that it did not require the
maintenance work order (MWO) job plan to provide specific restoration steps
if valve manipulations are performed or that the system be restored in
accordance with the applicable procedure. As a result,18 control rod drive
hydraulic control units were not. verified as being properly aligned following
flush and vent activities authorized by MWO R126315. This condition existed
from June 2-17, 1989.
REASON FOR THE VIOLATION
At approximately 3 a.m. on June 17, 1989 during reactor startup following the
second refueling outage, a reactor operator was dispatched to vent a control
rod drive (CRD) at its respective hydraulic control unit (HCU). The reactor
operator arrived at the CRD location and discovered that a CRD cooling water
isolation valve (HCU 4821-V104) was closed. The Station Operating Procedure
(S0P)-0002,
" Control
Rod Drive Hydraulics", requires this valve to be open.
The last time this SOP was performed and completed was on May 22, 1989.
Further investigation revealed subsequent work on the CRDs after the 50P was
performed. MWO R126315 was work released on May 25, 1989 to flush and vent
various- HCUs including HCU 4821-V104.
The job plan step requiring that
operations verify the valve position per the S0P valve line-up sheet, prior
to returning the system to service was deemed not applicable by the planner
and the job plan did not address any other restoration steps.
The MWO was
completed and signed off on June 2,1989 without any other verification as to
the correct valve lineup.
In conclusion, Gulf States Utilities Company (GSU)
determined the root cause was attributed to two causal factors: personnel
error was made in determining the applicability of the job plan step, which
should have required valve lineup after completed work and a specific
restoration step did not exist at the end of the job plan.
Page 1 of 2
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CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
'
Immediately following- the discovery of the mispositioned
valve,
GSU
- management terminated the plant start-up and operations personnel performed
the S0P-0002 valve lineup. The performance of this lineup did not find any
other HCU valves closed or mispositioned. Operation's management personnel
determined the missing lock wires were also a direct result of the work
performed on MWO R126315. The operations department initiated a revision to
SOP-0002 to improve its format and content.
Based on the evaluation, GSU
decided to proceduralize the flushing of CRDs with required individual
sign-offs for each step.
Currently, each valve on the HCU is identified on
the lineup sheet and requires a first and second verification signature.
This revision eliminates the original generic lineup for CRDs by specifically
identifying valve numbers and providing more clarity'to the sign-offs.
7
CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
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ADM-0028,
" Maintenance Work Order", was revised to resolve the deficient e b
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manipulations
1) shall
delineate
plan to specify steps
requiring ) valve
steps or 2 be performed in_accordance with ADM-0027,
specific restoration
" Protective Tagging",
GMP-0042, " Circuit Testing and Lifted Leads and
- Jumpers" or the appropriate S0P valve lineup sheet.
A 100 percent verification of all- safety-related valves was conducted prior
to commencing the subsequent plant start-up.
This verification involved
approximately 11,700 valves and resulted in finding one additional valve
(LSV*PT21A) closed in the positive valve leakage control
system (PVLCS).
- This valve is required to be open per SOP-0041, " Penetration Valve Leakage
Control System". Since the finding was discovered during corrective action
for the CRD valve and the PVLCS system operability was not affected by the
valve being closed, no further corrective action was appropriate.
In
addition, the procedure revisions now in effect for 50P-0002 and ADM-0028
specifically address the root cause for the mispositioned valve.
.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
GSU is currently in full compliance and all
corrective actions have been
completed.
!
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