RBG-25462, Responds to NRC Re Violations Noted in Insp Rept 50-458/86-39 on 861208-12 & 870112-16.Corrective Actions: Temporary Change Notice Issued for Rev 6 to Surveillance Test Procedure STP-051-4234

Responds to NRC Re Violations Noted in Insp Rept 50-458/86-39 on 861208-12 & 870112-16.Corrective Actions: Temporary Change Notice Issued for Rev 6 to Surveillance Test Procedure STP-051-4234

ML20207R405
Person / Time
Site:	River Bend
Issue date:	03/11/1987
From:	William Cahill GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-25462, NUDOCS 8703170198
Download: ML20207R405 (6)

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GULF STATES UTILITIES COMPANY Rive R BENO STAf)ON POST OFFICE 80x 220 St FRANCisnLt. Louisiana 70776 An,A CODE 604 635 6094 344 e661 March 11, 1987 RBG- 25462 File Nos. G9.5, G15.4.1 Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlement River Bond Station - Unit 1 Refor to: Region IV Docket No. 50-458/ Report 86-39 This letter responds to the Notico of Violation contained in NRC Inspection Report No. 50-458/86-39. The inspection was performed by Mossro. W. R. Bonnott, M. E. Skow and R. D. Vickory during the period December 8-12, 1986, and January 12-16, 1987 of activition authorized by NRC Operating License NPF-47 for River Bond Station.

Gulf Staton Utilition Company'n (GSU) responuo to Notice of Violation 8639-01, " Failure to Follow Surveillance Tost Proceduron", and 8639-02, " Failure to Utilizo Proper Revision of Survoillanco Tout Proceduro", in provided in the onclosed attachment purnuant to 10CFR2.201 and 10CFR50.4. This completon GSU's responno to the Notico of Violation.

Sincoroly, Af '/ /

. J. Cahill, Jr.

Senior Vice President Gulf Staton Utilition Company WJC/ /1 J f /jo Attachmont cci Mr. Robert D. Martin, Regionni Administrator U.S. Nucionr Rogulatory Comminnion Rogion IV 611 Ryan Plaza Drivo, Suito 1000 Arlington, TX 76011 River Bond Runident Inspector Ol !

P.O. Box 1051 St. Francinvillo, lA 70775 jl6 '

0703170190 070311 Ilt EDH ADUCK 03000450

UNITED STATES OF AMEICA NUCLEAR RECULATORT C(ESEISSION STATE OF IABISIAEA 5 PARISE OF WEST FELICIANA 5 In the Matter of I Docket Noe. 50-458 GULF STATES UTILITIES CONFANT I (River Bend Station, Unit 1) .

AFFIDAVIT W. J. Cahill, Jr., being duly sworn, states that he is a Senior Vice President of Gulf States Utilities Company that he is authorised ,

on the part of said Company to sign and file with the Nuclear Rggulatory Coissission the documents attached hereto and that all such documents l are true and correct to the best of his knowledge, information and belief.

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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this // d ayd of Mb e d[ ,19 ('/.

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l o r, Joan W. Middlebrooks

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Notary Public in and for West Feliciana Parish, toutstana My Commsteston is for IAfa.

ATTACHMENT 1 RESPONSE TO NOTICE OF VIOLATION 50-458/8639-01 4 LEVEL IV REFERENCE Notice of Violation - J.E. Gagliardo letter to J.C. Doddens, dated February 11 , 1987, i

FAILURE TO FOLLOW SURVEILLANCE TEST PROCEDURES

Technical Specification, paragraph 6.8.1.d requires that written procedures shall be established, implemented, and maintained for survoillance and test activities of safety-related equipment.

Surveillance Test Procedure STP-505-4506, "RPS/ Control Rod Block-APRM Wookly Cl!FUNCT, Wookly C il C A L , and 18-Month LSFT (CSI*K605F) , " Revision 6, stop 7.1.47, requires that the operator"... install a jumpor from pin 2 to pin 50."

Surveillance Test Proceduro STP-051-4234, "ECCS/HPCS-Roactor Vossol Water Level-Low Low-Levol 2 and High Lovel 8 Monthly CilFUNCT, 18 Month Cl! CAL, 18 Month LSFT (321-N073L; B21-N673L; B21-N674L) ," Revision 5, stop 7.1.33.3, and Revision 6, stop 7.1.28.3, requires that the operator " verify 'llPCS liigh Water

- Lovel 8 Resot' (Ill 3-P 601-16 B-C- 2 2A-5 6 ) status light is on."

1 Contrary to the above, in stop 7.1.47 of STP-505-4506, performed on November 16, 1986, the operator installed a jumper at a different location than that specified in the proceduro; in stop i 7.1.33.3 of STP 051-4234, Revision 5 performed on May 6 and June 4, 1986, the operator designated thoso stops as not applicable i when in fact, the procedure required thoso stops to be performed; i and in stop 7.1.28.3 of STP-051-4234, Revision 6, performed on September 5, 1986, the operator signed off the stop as

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satinfactory ovon though plant conditions precluded satisfactory performance of this stop.

i This in a Soverity Lovel IV violation. (Supplomont I .D. ) (4 5 8/ 86 3 9-01) i REASON FOR VIOLATION The causo for thin violation in procedural inadequacy and personnel error. The Inntrumontation and Controla (I&C) technician failed to identify the alternato location of jumpor pincoment via a tout exception or Temporary Chango Notico (TCN).

. Accessibility of the location specified by the proceduro wan very rontricted. The technician had rocontly completed installation of terminal blocks por approved modification request. Thono terminal blocks wuro installed to provido an altornato location j to facilitato tonting. Boing awaro of the rovinion which wan l

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ATTACHMENT (cont'd) being processed and being knowledgeable with the system, the technician decided to use the alternate location.

In Surveillance Test Procedure (STP)-051-4234 Revision 5, step 7.1.33.3 and Revision 6, step 7.1.28.3 required the verification of a lighted status light, which under conditions other than having an actual indication of high reactor water level would not be lighted. The procedure was misleading by requiring something which can not normally be done. The technician erred when he did not stop and change the STP when step 7.1.33.3 could not be performed. A TCN is required under these circumstances by Administrative Procedure, ADM-0003, " Development, Control and Use of Procedures" and ADM-0015, " Station Surveillance Test Program".

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND Tile RESULTS ACHIEVED A TCN has been issued to STP-051-4234 Revision 6, wording it similarly to other sister procedures. Either initialing or N/A being placed in the block is acceptable.

CORRECTIVE STEPS TAKEN TO AVOID FURTilER VIOLATIONS Memorandum PIC-M-87-007 dated January 8, 1987 and PIC-M-87-033 dated March 10, 1987 have been issued to reiterate the requirements of administrative procedures: ADM-0003,

" Development, Control and Use of Procedures" and ADM-0015,

" Station Surveillance Test Program". I&C personnel were

instructed via memorandum (PIC-M-87-007) on the use of Comment Control Forms as a means of procedure improvement.

As a result of this violation, the I&C section is conducting a review and revising STP's as needed. Sister procedures are being reviewed for uniformity and are being revised as applicable.

DATE TilAT FULL COMPLIANCE WILL BE ACllIEVED:

River Bond Station is currently in full compliance.

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ATTACHMENT 2 RESPONSE TO NOTICE OF VIOLATION 50-458/8639-02 LEVEL IV REFERENCE Notice of Violation -

J.E. Gagliardo letter to J.C. Doddens, dated February 11 , 1987.

FAILURE TO UTILIZE PROPER REVISION OF SURVEILLANCE TEST PROCEDURE Technical Specification, paragraph 6.8.1.d requires that written procedures shall be established, implemented, and maintained for surveillance and test activities of safety-related equipment.

Administrative procedure ADM-0005, " Station Document Control,"

Revision 5, dated February 17, 1986, states, in paragraph 3.3, that the user of procedures is"... responsible to assure that they have the most current revision prior to performing safety-related activities."

Contrary to the above, STP-051-4234, "ECCS/flPCS-Reactor Vessel Water Level-Low Low-Level 2 and liigh Level 8 Monthly CilFUNCT, 18-Month Ci! CAL, 18-Month LSFT (D21-N073L; B21-N673L; B21-N674L),"

Revision 5, was performed on August 6, 1986. Revision 6 to STP-051-4234 was issued and in effect on August 4, 1986.

This is a Severity Level IV violation. (Supplement I .D. ) (4 58/ 8639-02)

REASON FOR Tile VIOLATION Personnel error caused an incorrect revision of STP-051-4234, "ECCS/11PCS Reactor Vessel Water Level-Low Low-Level 2 and liigh Level 8 Monthly CliFUNCT , 18-Month C llc A L , 18-Month LSFT (B21-N673L; B21-N674L)", to be used. On July 27, 1986, the technician withdrew Revision 5 of SrP-051-4234 from Station Document Control. Eight days later, Revision 6 of STP-051-4234 was issued. August 6, 1986, ten days after receiving Revision 5 and two days after Revision 6 became effective, the STP was performed. The technician did not check to see if the STP had been revised.

CORI<ECTIVE STEPS TAKEN AND RESULTS ACilIEVED A review of Revisions 5 and 6 indicated that Revision 6 incorporated the TCN's previously attached to Revision 5.

Because Revision 6 contains no significant technical differences from Revision 5 and the attached TCN's, there was no adverse impact on plant process systems or equipment.

ATTACHMENT 2 (cont'd)

CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION Administrative Procedure, ADM-0015, " Station Surveillance Test Program", requires the user to verify that the procedure that is to be used in the plant is the latest revision. This requirement has been clarified to assure a check of revision status. prior to use (TCN 87-0124).

Instructions concerning the importance of and methods used to ensure that the correct procedure revision is used in the plant will be provided.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED TCN-87-0124 has been issued to ADM-0015 to re-enforce the necessity for ensuring that the procedure used in the plant is current.

Training of Maintenance personnel will be complete by March 16, 1987, t