RBG-25392, Supplemental Response to NRC Re Violations Noted in Insp Rept 50-458/86-40.Corrective Actions:Temporary Change Notice 86-1947 Issued on 861223 to Change Step 7.4.29 Into Two Separate Steps & Rev 2 to STP-209-0302 Issued

Supplemental Response to NRC Re Violations Noted in Insp Rept 50-458/86-40.Corrective Actions:Temporary Change Notice 86-1947 Issued on 861223 to Change Step 7.4.29 Into Two Separate Steps & Rev 2 to STP-209-0302 Issued

ML20212E311
Person / Time
Site:	River Bend
Issue date:	02/23/1987
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-25392, NUDOCS 8703040322
Download: ML20212E311 (5)

Text

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GULF STATES UTELITIES COMPANY RfVER SEND STATION POST Or'#CE pox 220 $f FRANCISVILLE, LOUISIANA 70775 AAEA CODE bo4 635 6094 346-8651 ,

February 23, 1987 RBG- 25392 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 the Notice of Violation contained in NRC Inspection Report No. 50-458/86-40. The inspection was performed by itessrs. D. D. Chamberlain and W. B.

Jones during the period December 1-31, 1986 of activities authorized by NRC Operating License NPF-47 for River Bond Station.

Gulf States Utilities Company's (GSU) response to Notice of Violation 8640-01, " Failure to Follow Surveillance Test Procedure", is provided in the enclosed attachment pursuant to 10CFR2.201 and 10CFR50.4. This completes GSU's response to the Notice of Violation.

Sincerely, 0703040322 870223 PDR ADOCK 05000458 G PDR - J. C. Deddens Senior Vice President River Bend Nucicar 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 l St. Francisville, LA 70775

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IMI1ED Sm3ES & JMUtICA IR1CMAR IBGUEA50Rf C[BGESSI(M Sm3E OF IOUISIANK

• PARISH T W!ST FI!LICIANE

• In the MPtter of .

W Nos. 50-458 GUEF Sm3ES UTILITIES CCWANY *

(River Bend Station, Unit 1) .

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

J. 4. Deddens Subscribed and sworn to before me, a Notary Public in and for the 1

State and and Parish above named, this.43$3ay of hnrtmrth 19b.

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[JoanW.Middlecrooks Notary Public in and for West Feliciana Parish, Iouisiana My Cm mission is for , Life.

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION 50-458/8640-01 LEVEL IV REFERENCE Notice of Violation letter from J. E. Gagliardo to J. C. Doddens 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 pump for operability in accordance with Technical Specification 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, 1E51*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 valvo 1E51*MOVF019 auto opened as a precautionary step to ensure the pump was not operating without minimum flow.

The next step, 7.4.32, (7.4.31 had boon deleted by Temporary Change Notice (TCN)) required the RCIC pump suppression pool suction valve, 1E51*MOVF031, to be opened in preparation for a check valve test. The valvo 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 1E51*MOVF022 had not been closed as require'd by Step 7.4.29. 1E51*MOVF031 is interlocked not to open unless both IE51*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:

- This was the first time the test engineer performed this particular STP. This engineer was certified to perform In-Service Testing (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 methods and STP's for pump and valve In-Service Inspection (ISI) testing are very similar and consistent, it is not required to assign an engineer who has previously performed the STP. Per ASME IWA 2300, ANSI /ASME N45.2.6-1978,

=

o.

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 STP 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 valvo error occurred.

- The STP instructed the performer to close two valves in a It is not uncommon to perform two actions in a single stop.

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 resulted only in the inability to perform the next action step. The closure of the valves can be performed in The parallel, and either one will shutoff flow in the line.

engineer failed to fully read the step and confirm it that the off as step was fully implemented prior to signing complete. Although there were two actions in the step, the fail if performance of any single or double action stop can the performer does not fully read it, follow it, and finally confirm it.

CORRECTIVE 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.

ISI pump Field Engineering personnel responsibic for departmental performing training and STPs attended a documented valve major subjects covered during the session on 1/20/87. The

. e ATTACHMENT (cont'd) training included a discussion of the violation, corrective actions, recent NRC questions on past STP performances, proper completion of the Surveillance 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 FURTHER VIOLATIONS In addition to the correctivo 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 Engincoring surveillance testing activitics, 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 reviso a procedure within two years as part of this review if a significant TCN against the proceduro exists and/or if significant programmic changes need to be madeexists the policy that if an to it. that could adversely It is also extensive TCN affect the propor performance of the proceduro, the proceduro shall be revised as soon as possibic. The subject procedure was in the process of being revised when the violation occurred. To expedite the revision of the remaining proceduros, the new ,

one organization discussed above will establish this task as 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 DE ACHIEVED Corrective actions, other than the procedural revisions on other similar STPs, have boon completed.

Revisions on other STPs will limit. In be completed prior to the respective two year reviewThe procedure most casos, this will occur by the end of 1987.

according to the number and revisions will be prioritized complexity of the TCNs and then by the requireu review datos.

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