IR 05000458/1986020: Difference between revisions

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{{Adams
{{Adams
| number = ML20203H770
| number = ML20213E539
| issue date = 07/24/1986
| issue date = 11/05/1986
| title = Insp Rept 50-458/86-20 on 860501-0615.Violation Noted: Failure to Follow Administrative Procedures for Issue of Temporary Change Notices & Failure to Implement Procedures to Maintain Safety Sys Drawing Configuration
| title = Ack Receipt of 860829 & 1017 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-20
| author name = Chamberlain D, Jaudon J, Jones W
| author name = Gagliardo J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Cahill W
| addressee affiliation =  
| addressee affiliation = GULF STATES UTILITIES CO.
| docket = 05000458
| docket = 05000458
| license number =  
| license number =  
| contact person =  
| contact person =  
| case reference number = TASK-1.G.1, TASK-TM
| document report number = NUDOCS 8611130209
| document report number = 50-458-86-20, NUDOCS 8608050087
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| package number = ML20203H757
| page count = 2
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 15
}}
}}


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NOV 5 1986 In Reply Refer To:
Docket: 50-458/86-20 Gulf States Utilities
. ATTN: William J. Cahill, Jr.
 
Senior Vice President River Bend Nuclear Group P.-0. Box 220 St. Francisville, Louisiana 70775 Gentlemen:
Thank you for your letters, dateo August 29, 1986, and October 17, 1986, in response to our letters, dated July 30, 1986, and September 16, 1986. We have no further questions at this time and will review your corrective action during a future inspectio'n.
 
Sincerely,
-cornai nma dy:
    # 1. r_ H A t. L*
J. E. Gagliardo, Chief Reactor Projects Branch cc:
Gulf States Utilities ATTN: J. E. Booker, Manager-Engineering, Nuclear Fuels & Licensing P. O. Box 2951 Beaumont, Texas 77704
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Louisiana State University, Government Documents Department Louisiana Radiation Control Program Director bcc: (see next page)
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C /( C RPB JPJpu on:cs /kJEGagliardo  g 11/g/86 Wil/ /86    D\
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8611130209 861105 PDR ADOCK 05000458 G  PDR
 
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Gulf States Utilities -2-bec to DMB (IE01)
bcc distrib. by RIV:
RPB  DRSP Resident Inspector R. D. Martin, RA Section Chief (RPB/A) D. Weiss, LFMB (AR-2015)
MIS System RSB RSTS Operator R&SPB RIV File
 
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GULF STATES  UTELETIES COMPANY ,
river BEND STATION Post OFFICE BOX 220 $7 FR ANCISVlLLE. louts 4ANA 70775 AREA CODE 504 635 6094 346 8651 August 29, 1986 RBG- 24275 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Adntinistrator U.S. Nuclear Regulatory Commission Region IV        t
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611 Ryan Plaza Drive, Suite 1000    j 1:, y tf. t :
Arlington, TX 76011
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==Dear Mr. Martin:==
SEP - 41986 ', _
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dO; River Bend Station - Unit 1  -
Refer to: Regicn IV    -
Docket No. 50-458/ Report 86-20 This letter is in response to the Notice of Violation contained in NRC Inspection Report No. 50-458/86-20. The inspection was performed by Messrs. D. D. Chamberlain and W. B.
 
Jones during the period May 1 through June 15, 1986, of activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No. 1.
 
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Gulf States Utilities Company's (GSU) response to the Notice of Violation 8620-01 and  8620-02 is provided in the enclosed attachment. This completes  GSU's response to the Notice of Violation.
 
Sincerely,
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W. J. Cahill, Jr.
 
Senior Vice President River Bend Nuclear Group GP 6?S WJC/ ERG /RRS/kn Attachment
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UNITED STATES OF AMERICA BUCIAAR REGUIATORY Ct3 MISSION
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STATE OF IRISIAEA 5 FARISE OF UEST FELICIANA  l  .
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In the Matter of  $ Docket Boe. 50-458 CULF STATES UTILITIES CtBIFARY I (River Bend Station,
APPENDIX B
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  ,  U. S. NUCLEAR REGULATORY COMMISSION
Unit 1)    .
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AFFID&VIT W. J. Cahill, Jr., beins 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 heretos and that all such documents are true and correct to the best of his knowledge, information and belief.
 
W. Cahill, Jr. //
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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /7 day of dead ,19&. l l r tt o /%
anW.Middlebloops  I otary Public in and for West Feliciana Parish, Louisiana   l l
My Conunission is for Life. l
 
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ATTACHMENT
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Response to Notice of Violation 50-458/8620-01
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Level IV FAILURE TO FOLLOW ADMINISTRATIVE PROCEDURES FOR ISSUANCE OF TEMPORARY CHANGE NOTICES (TCN's)
REFERENCE:
Notice of Violation -
Letter to W. J. Cahill, Jr. from J. E.
 
Gagliardo dated July 30, 1986.


==REGION IV==
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NRC Inspection Report: 50-458/86-20  License: NPF-47
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Docket: 50-458 Licensee: Gulf States Utilities Company (GSU)
P. O. Box 2951 Beaumont, Texas 77704 Facility Name: River Bend Station (RBS)
Inspection At: River Bend Station, St. Francisville, Louisiana Inspection Conducted: May 1 through June 15, 1986 Inspectors: {
D. D. diamberlain, Senior Resident Inspector
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Date (pars. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11 and 12)
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W. B.FJones, Resident inspector l b'h$b Date (pars. 1,2,3,4,5  6,7,8 9, and 11)
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Approved: _ _ /w MYl  72 Y/[
REASON FOR THE VIOLATION l  During an NRC inspection conducted on May 1 through June 15, 1986, the inspectors identified a failure to follow
J./.Jfudon,Ghiel,ProjectSectionA   Dafe  /
:   Administrative procedures. As a result of personnel oversight,
Eeactor Proj& cts Branch 8608050087 860730
I&C Maintenance Technicians failed to comply with the procedural requirements of Administrative Procedure (ADM)-0003,
, PDR ADOCK 05000458 G  PDR
;  " Development, Control and Use of Procedures" when initiating i  Temporary Change Notice No. 86-0581 for procedure STP-051-4210.
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This resulted in an official work copy of the procedure
  -2-Inspection Summary Inspection Conducted Iby 1 through June 15, 1986 (Report 50-458/86-20)
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Areas Inspected: Routine, unannouncad inspection of licensee action on previous inspection findings, status of operating license conditions, Nuclear Review Board activities, startup test witness, safety system walkdown, operational safety verification, maintenance witness, surveillance witness, licensee plans for coping with strikes and status of IMI action ite Results: Within the ten areas inspected, two violations were idantified (failure to follow administrative procedures for issue of temporary change notices, paragraph 9, and failure to implement procedures to maintain safety system drawing configuration, paragraph 6).
containing duplicate page numbers with different Temporary Change
:   Notice (TCN) Numbers on each page.


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)   CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS' ACHIEVED
o-3-DETAILS P_ersons Contacted Principal Licensee Employees M. Arant, Technician, Ir.strumentation and Control (I&C)
;  On April 10, 1986, prior to the NRC inspection, Memorandum No.
* J. Backen, Supervisor (Acting), Operations Quality
:  PAS-86-141 was issued identifying procedures with two or more TCN's having duplicate pages with different changes.
' Assurance (QA)
W. J. Beck, Supervisor, Reactor Engineering
*W.E H. Cahill, Jr. , Senior Vice President, River Bend Nuclear Group
*E. M. Cargill, Supervisor, Radiation Programs
*T. C. Crouse, Manager, QA
*J. R. Cummings, Procedure Coordinator,
* E. Freehill, Superintendent, Startup and Test A. O. Fredieu, Assistant Operations Superviser P. F. Gillespie, Senior Compliance Analyst D. R. Gipson, Assistant Plant Manager, Operations
*E. R. Grant, Supervisor, Nuclear Licensing
*B. R. Hall, Supervisor, Plant Services,
*R. W. Helmick, Director, Projects,
*G. K. Henry, Supervisor, Electrical Engineering  i K. C. Hodges, Supervisor, Quality Systems
*R. J. King, Licensing Engineer
*A. D. Kowalczuk, Assistant Plant Manager, Maintenance
*W. H. Odell. Manager, Administration
*T. F. Plunkett, Plant Manager
*S. R. Radebaugh, Assistant Plant Manager, Services W. J. Reed, Director, Nuclear Licensing D. Reynerson, Director, Nuclear Plant Engineering (NUPE)
N. Simpson, Technician I&C
* H. Small, Acting Supervisor, Operations Quality Control (QC)
R. B. Stafford, Director, Operations QA
*K. E. Suhrke, Manager, Projects
^ P. c. Tomlinson, Director, Quality Services D. Williamson, Operations Supervisor The NRC senior resident inspector (SRI) and resident inspector (RI) also interviewed additional licensee personnel during the inspection perio * Denotes those persons that attended the exit interview conducted on June 19, 1986. NRC Region IV Section Chief, J. P. Jaudon, NRC resident inspector (RI), W. B. Jones and Nuclear Reactor Regulation (NRR)
licensing Project Manager, S. Stern also attended the exit intervie .
    -4- Licensee Action on Previous Inspection Findings (Closed) Violation (458/8569-01): Failure of design document control program.


i    s This violation was a failure to post approved design changes against the effected design documents and a failure to distribute design change documents to document control stations. NUPE revised procedures NUPE-AA-54 and 59 to provide more control for the posting and routing of design change documents. A 100 percent audit of s  design change files was conducted, and all noted discrepancies were
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  ?' corrected. Training was conducted on the revised procedural requirements, and-subsequent quality assurance surveillances revealed no recurrence of.the problem. The SRI reviewed the revised
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procedu'res and,the"other corrective action This, viol'ation is_ close ~
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_ (Closed) Violation (458/8569-02): Improper use of a field change
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NUPE issued procedure NUPE-AA-64, " Control and Approval of Field Change Notices (FCN's)" which provides detailed instructions and
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restrictions for the use of FCNs. The licensee had conducted an audit of the design change files and the discrepancies noted had been corrected. Training of NUPE personnel responsible for completing FCN's had been complete This violation is closed.
The
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memorandum identified the deficiencies with STP-051-4210 and j  requested that the faulty TCN's be corrected.
 
i  In response to Memorandum No. PAS-86-141, Procedure STP-051-4210,  .
l  Revision 2, was submitted for revision on April 20, 1986 to    !
l  incorporate the outstanding TCN's and eliminate the duplicate pages. Revision 3 of STP-051-4210 was approved and issued on July 30, 1986.


i (Closed) Violation (458/8604-01): Failure to control temporary circuit alterations administrativel .
CORRECTIVE STEPS WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The I&C Procedure Coordinator reviewed the TCN deficiencies with i
The licensee actions in response to this violation included: a complete inspection of control room panels for unauthorized lifted leads or jumpers; QC hold points included in electrical maintenance work requests to inspect for proper restoration; implementation of a main control room cabinet access and work monitoring program; the change of control room panel locks; a maintenance procedure revision serialized tagging of any lifted lead or jumper for accountability and the temporary alterations program was suspended and replaced by design modification request procedures. The SRI has monitored licensee actions relative to temporary alterations, and the additional controls appear to be effective.
the. responsible individuals and instrucLad the individuals to
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comply with the requirements of ADM-0003 when initiating future TCN's.


!   Ihis violation is close (Closed) Violation (458/8581-01): Failure to maintain a controlled copy of a temporary change notice (TCN) in front of the affected
Memorandum No. PIC-M-86-116 was issued on July 9, 1986 requesting that TCN's issued by the I&C Maintenance Department be routed l   through the I&C Procedure Coordinator prior to obtaining the
. controlled procedure in the control room Station Operating Manual (50M)
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Shift Supervisor's signature. The IEC Procedure Coordinator is i  responsible for reviewing TCN's being issued to assure compliance l  with ADM-0003 and evaluates the necessity of the TCN. The
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ATTACHMENT (Cont'd)
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routing of the TCN through the I&C Procedure coordinator will be discontinued when the number of   TCN's being  issued is significantly reduced.
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] To prevent recurrence of similar violations, ADM-0003 was revised
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  <The licensee :took immediate corrective actions by performing a
on 8/6/86 to clarify procedural instructions for issuing a TCN to a page that has been previously changed by a TCN.
  ~ departmental review of all station operating procedures (SOPS),
 
  , , abnormal' operating procedures (A0Ps), and emergency operating
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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procedures (EOPs). . During the review,.the licensee identified several SOP's with duplicate copies of the same TCN and a few TCN's filed with the wrong S0P. These conditions were immediately corrected.'
STP-051-4210 was reviied on July 30, 1986 to incorporate the
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outstanding TCN's and eliminate the duplicate pages.
 
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River Bend Station is currently in compliance.
 
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m Responsibility for maintaining and ensuring that updates to the Main
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  ' Control- Room procedure manual are properly filed has been reassigned to Station Document Control (SDC). Periodic reviews of the Main Control Room SOMs are being conducted by the SDC in accordance with administration procedure ADM-005, " Station Document Control,"
e Page 3 ATTACHMENT (Cont'd)
Section '
Response to Notice of Violation 50-458/9620-02 Level.IV
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This violation is close . Status of Operating License Conditions Facility Operating License NPF-47 for River Bend Station was issued on November 20, 1985, and Attachment 1 to this license contains items which must be completed to the satisfaction of NRC Region IV. The following status is provided for the Attachment 1 license conditions: (Closed) License Condition 1.a.: Verify the station electric distribution voltage analyses are in accordance with the guidelines of Branch Technical Position PBS-1, Position 4, prior to completion of the initial test progra GSU has completed special situation test 1-SST-6, ." Bus Load Test,"
FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY REASON FOR THE VIOLATION A walkdown of the "C" Residual Heat Removal (RHR) system by NRC inspectors identified the following differences between actual
and the results were provided to Stone and Webster (S&W) for comparison to analytical model results. Memorandum S-CRB-9031 dated June 4, 1986, summarizes the results of that comparison and indicates that the test versus analytical results are acceptable with no test voltage drops more than 3 percent lower than the analytical values as recommended by Branch Technical Position PSB- This license condition is close (Closed) License Condition 1.b: Evaluate and complete modifications on battery powered lighting systems used in areas of the plant outside the main control room required for safe shutdown and personnel evacuation prior to completion of the initial test progra The RI reviewed the licensee's emergency lighting plan as detailed on Stone and Webster Lighting Plan drawings 12210-EE-65 thru 7 Emergency lighting stations were selected from the drawings and verified to be installed and operational for areas identified in Final Safety Analysis Report (FSAR) Table 9.5-2, " Illumination Level and Type of Fixtures used in Plant Areas Necessary for Safe Shutdown and Evacuation of Personnel." In addition, areas previously
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system configurations and controlling instructions, procedures, and drawings: 1) five pipe caps, shown as installed on Engineering, Piping and Instrument Drawing PID-27-C were not.
 
installed, 2) valve E12*MOVF064C, which was shown closed on Engineering, Piping and Instrument Drawing PID-27-7C was open, 3)
valve E12*VF063C was not locked, although Engineering, Piping and Instrument Drawing PID-4-3C showed this valve to be locked, 4)
differences were found between Engineering, Piping and Instrument Drawing PID-27-7C and System Operating Procedure, SOP-0031, as to which valves were locked in position.
 
Item 1 Investigaticns to determine the reason that the pipe caps are missing, although shown installed on Engineering, Piping and Instrument Drawing, PID-27-7C, are indeterminate.
 
Item 2 The minimum flow valve E12*VF064C was placed in the open position, per the SOP-0031, however, PID-27-7C showed this valve to be closed.
 
Item 3 Operations personnel had previour,1y performed an audit of locked valves on the RHR system and determined valve E12*VF063C was verified to be closed, but no lock was installed on the valve because it was approximately twenty feet above the floor and considered inaccessible.
 
Item 4 Operations was aware of the differences between the two existing system drawing types and the SOP's and was in the process of correcting this situation by revisions to the PID's and the SOP's. The cause of these discrepancies was determined to be the lack of configuration management programs to ensure procedure updates on the issuance of changes to drawings and drawing updates to reflect commitments to lock specific valves.


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CORRECTIVE STEP WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The five missing pipe caps that are shown on PID-27-C have been replaced.
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identified as being deficient in illumination were selectively observed to meet the requirements of Table 9.5-2. As a result of this walkdown, one area was identified which did not meet the minimum illumination requirements. The area identified was an egress stairwell located on the east side of the turbine building between the elevation 95'0" and 123'6". The licensee initiated modification request (MR) 86-162 and maintenance work request (MWR) 41124 to install the emergency light. This work was completed on June 15, 198 This license condition is close . Nuclear Review Board Activities The RI reviewed the Nuclear Review Board (NRB) minutes for the period February 1985 thru December 1985, to assess the overall effectiveness of the licensee's implementation of the off-site review committee. These minutes were evaluated against the NRB responsibilities outlined in Section 6.5.3 of the Technical Specifications (TS) and the NRB Manua The RI noted during the above review, that the NRB has chartered four subcommittees to assist the NRB in fulfilling their responsibilitie These subcommittees are:
Since valve E12*MOVF064C was in the proper position in accordance with SOP-0031 it will be left in this position (i.e., open to allow minimum flow).
o "Unreviewed Safety Questions Committee" (USQC);
 
o " Quality Assurance Program Audit Committee" (QAPAC);
i Valve E12*VF063C has been locked as shown on PID-4-3C.
o " Quality Concern Subcommittee;" and o "NRB/FRC Committee" The USQC was established to assist the NRB in meeting its responsibilities for reviewing proposed changes to the plant and its documentation to ensure that changes are not made which constitute an unreviewed safety question. Specifically, the USQC will review:
o all safety evaluations for changes to procedures, equipment, systems or experiments which were determined not to involve unreviewed safety questions; o selected procedures, equipment, systems, tests and experiments which did not receive an evaluation to verify that they were properly classified and did not require a safety evaluation; o changes which were determined to be unreviewed safety questions and the associated changes to licensing documents; proposed changes to the Operating License or TS; and o violations of codes, regulations, orders, TS license requirements, procedures and instructions having nuclear safety significanc .
  -7-The QAPAC was chartered to advise the NRB on the effectiveness of the
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Quality Assurance Program. This is accomplished thru the QAPAC's participation in and review of audits performed by the QA audit group for the areas required by 6.5.3.8 of the TS. The requirement of the QAPAC to audit the Operational Quality Assurance Program every 24 months for compliance with 10 CFR part 50, Appendix B, is being fulfilled thru the Joint Utility Audit Group (JUAG).


The Quality Concern Subcommittee receives and coordinates quality concern inquiries dealing with the operation of the quality assurance department and management of the River Bend Nuclear Grou This committee insures that proper action is taken by all departments to allegations or inquiries which are receive The NRB established the NRB/FRC Committee to monitor the FRC's activitie This Committee assesses the FRC's fulfillment of its responsibilities by:
Operations has revised the RHR SOP to agree with existing FID's.
o reading all FRC minutes and other reports issued by the FRC; o occasional attendance at FRC meetings; o occasional verification of an FRC review item; and o semi-annual meetings to discuss FRC activitie The above subcommittees chartered by the NRB appear to be adequate to meet the function and responsibilities established in the Technical Specifications for the licensee's off-site review committe The NRB meeting' minutes reviewed by the RI for the period February 1985 thru December 1985 demonstrate that the NRB members are cognizant of their responsibilities and have established programs to fulfill these responsibilities. The NRC inspectors will evaluate the effectiveness of the NRB during future inspection No violations or deviations were identified in this area of the inspectio . Startup Test Witness During this inspection period, the SRI and RI witnessed startup testing conducted under the startup testing program. The NRC inspectors observed that: personnel conducting the test were cognizant of the test acceptance criteria, precautions and prerequisites prior to beginning the test; the test was conducted in accordance with an approved procedure; the test procedure was being used and signed off by the personnel conducting the test; and data were being collected and recorded as required. The NRC inspectors witnessed the following startup tests:


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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
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Nuclear Equipment Operators on rounds will take notice of missing
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  -8-o 1-ST-27 Turbine Trip and Generator Load Reject o 1-ST-28 Shutdown from Outside the Control Room o 1-ST-25B Main Steam Isolation Valve (MSIV) Full Closure o 1-ST-19 Core Performance The following observations were made during the performance of the above startup tests:
pipe cape and r? place them. A supply of caps has been placed in l  the Control Room for this purpose. Additionally, Local Leak Rate
o Test 1-ST-27 Turbine Trip and Generator Load Reject:
!  Testing (LLRT) Procedures will include a step to ensure i  replacement of caps which are removed for LLRT. Nuclear Plant-l  Engineering (NuPE), along with Stone & Webster (S&W) is in the process of determining which valve caps are required for a system j
The SRI and RI observed the performance of Section 6.3, "High Power Generator Load Rejection" to startup test 1-ST-27, " Turbine Trip and Generator Load Rejection" on May 29, 1986. The reactor was at approximately 96 percent thermal power when a generator load rejection was initiated by tripping a generator differential rela This caused both generator output breakers to open and a turbine control valve fast closure (TCVFC) to occur. The reactor scrammed, as expected, when the TCVFC signal was initiated. The peak reactor pressure reached during the transient was 1106 psig. The NRC inspectors noted that the bypass valves opened along with nine safety relief valves (SRV) to reduce and control reactor pressur Following the initial SRV blowdown, only 1 SRV was observed to reopen, which is consistent with the test acceptance criteri The licensee is presently evaluating SRVs B21*F041D and B21*F041F which apparently opened briefly in their safety mode. The results of this evaluatior, will be reviewed by the NRC inspectors during their review of 1-ST-27 test results. The licensee has collected test data to evaluate for conformance to acceptance criteri No violations or deviations were identified in this area of inspectio o 1-ST-28 Shutdown from Outside the Control Room:
to meet its intended design.
The SRI and RI observed the performance of Section 6.3, " Cold Shutdown from Outside the Control Roem", on May 30, 1986. Following the reactor scram initiated during 1-ST-27, reactor pressure was reduced to 120 psig from the main control room (MCR). The licensee had previously demonstrated the ability to scram and maintain the reactor in hot shutdown from outside the control room on February 15, 1986. With reactor pressure at 120 psig, control of the Division I residual heat removal (RHR) system was transferred from the MCR to the remote shutdown panel (RSP). When the nucleer control operators (NCO) began to realign the RHR system from the low pressure coolant injection (LPCI) mode to the RHR mode, the suppression pool suction valve 1E12*F004A indication failed in the intermediate positio _
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PID's will be revised to indicate valve position for a normal mode of operation, and Station Operation Manual (SOM) procedures
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; will govern actual valve position.
        -9-l After verifying locally that 1E12*F004A was closed, the NCO attempted to open 1E12*F006A valve as required to establish shut down coolin This attempt failed however because of the interlock that prevents 4    -the F006A valve from opening if the F004A is not in the closed
 
.   (indicated) position. Control of the division II RHR system was then transferred to the division II RSP and the system aligned to the shut    -r down cooling mode without inciden The NCO established a cooldown rate of approximately 80 F per hour with the heat transfer path to the' standby, service water system. The licensee has collected the test data to evaluate for conformance to acceptance criteri ,
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A new procedure,  Operation Section Procedure OSP-0014, which directly addresses the control of locked valves has been issued i  by the River Bend Operations Department.
    % violation or deviations were observed in this area of inspectio *    '
 
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A review of all PID's versus SOPS has been conducted. Changes to i
the procedures have been issued to- agree with the PID's. A review of the PID's is being performed by NuPE to determine which
!  valves should be locked and which should be left unlocked. NuPE l^  will also develop a procedure which will delineate the locked valve regulation requirements. Included in this review will be
the necessary changes of PID's to match these requirements. Upon completion, it is expected this will decrease the number of valves required to be locked.
 
j  Adequate configuration management control procedures are
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currently in place. All changes to locked valve status will be-followed by updates to the SOP's via these controls, i
i  DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l  The additional procedural controls ensuring replacement of pipe t
caps in Local Leak Rate Testing Procedures will be completed by
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October 30, 1986.
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o ATTACHMENT (Cont'd)
Valve E12*VF063C has been verified to be locked at the time of this response.
Procedures being devel5 ped by NuPE for determining locked valve regulation requirements will be completed by November 30, 1986.
, The;PID changes brought about by NuPE's reviews will be completed iby December 31, 1986.
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    .T,est 1-ST-25B Main Steam Isolation Valve (MSIV) Full Closure:
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GULF STATES  UTILETIES COMPANY eg RIVER BEND STAYtON POST OFFICE 80x 220 St FRANCISvtLLE. LOutslANA 70776 ARE A CODE 604 635 6094 346-8651 October 17, 1986 RBG- 24583 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011
==Dear Mr. Martin:==
River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 86-20 This letter is in supplemental response to the Notice of Violation contained in NRC Inspection Report No. 50-458/86-20.
The inspection was performed by Messrs. D. D. Chamberlain and W.
B. Jones during the period May 1 through June 15, 1986, of activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No. 1.
'
Gulf States Utilities Company's (GSU) supplemental response to  the Notice of Violation 8620-02,  " Failure to Control Activities Affecting Quality", is provided in the enclosed attachment. This completes GSU's response to the Notice of Violation.
Sincerely,
,
W. J. Cahill, Jr.
Senior Vice President River Bend Nuclear Group
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Attachment    .
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OCT 231986 Mc -,;  -
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Th'e RI witnessed the pefformance of startup test 1-ST-25B, "MSIV Full Closure", on-June 8,1986 with reactor power at 100 percent and rated
*    UNITED STATES OF AMERICA BUCLEAR EEGULATORY CCESEISSION
., . core f, low at 96 percent. The licensee initiated the test at 1733 hours.by simulating a loss of condenser vacuum which results in the MSIVs closing when in the run mode. Upon initiation of the MSIV full closure, the reactor tripped and the SRVs opened momentarily to control pressure. Following the initial opening of the SRVs, only
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,   1 SRV was observed to reopen. The high pressure core spray (HPCS)
STATE OF IAUISIAEA  5 FARISE OF WEST FELICIAEA  5 In the Matter of   I  Docket Bos. 50-458 GULF STATES UTILITIES C(EEFANY  $
and reactor core isolation cooling (RCIC) systems initiated on reactor vessel water level reaching the level 2 setpoint. The reactor vessel water level recovered quickly because of the subsequent swell of vessel water and the continuous feed from the reactor feed water pump The NC0 secured the HPCS injection valve prior to the system injecting based on the rising vessel water leve ,
  (River Bend Station, Unit 1)        .
Approximately 3 minutes into the transmit, the reactor feed pumps tripped on vessel high level. The reactor feed water B pump was subsequently restarted and vessel level maintained within the normal band. Control room conduct during the test was observed to be well coordinated and efficient. The licensee has collected the test data to evaluate for conformance to acceptance criteria.
AFFID&VIT W. J. Cahill, Jr., being duly sworn, states that he is a Senior Vice President of Gulf States U' 111 ties Company: that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission the documents attached heretos and that all such documents are true and correct to the best of his knowledge, information and belief.
 
W. J Cahill, Jr.
 
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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /8 ,
day of #MM , 19ffe,.
Q 9//] L U L L /,
          -
L L.,. ,
Joan W. Middlebrooks Notary Public in and for West Feliciana Parish, Louisiana My Commission is for Life.
 
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ATTACHMENT Response to Notice of Violation 50-458/8620-02 Level IV FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY REFERENCE Notice of Violation - Letter to W. J. Cahill, Jr. from J. E.
 
Gagliardo dated July 30, 1986.
 
Request for supplemental information - Letter to W. J. Cahill, Jr. from J. E. Gagliardo dated September 16, 1986.
 
REASON FOR THE VIOLATION A walkdown of the "C" Residual Heat Removal (RHR) system by NRC inspectors identified the following differences between actual system configurations and controlling instructions, procedures, i
and drawings: 1) five pipe caps,  shown as installed on
: Engineering, Piping and Instrument Drawing (PID)-27-C were not installed,  2) valve E12*MOVF064C, which was shown closed on PID-27-7C was open, 3) valve E12*VF063C was not locked, although PID-4-3C showed this valve to be locked, 4) differences were found between PID-27-7C  and System  Operating Procedure, (SOP)-0031, as to which valves were locked in position.


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Item 1 Investigations to determine the reason that the pipe caps are missing, although shown installed on PID-27-7C are indeterminate.
No violations or deviations were identified in this area of inspection, i
!  o Test 1-ST-19 Core Performance The SRI witnessed the running of traversing incore probe (TIP) traces in preparation for computer calculation of reactor power / thermal limit The required data was extracted and inserted into startup
;    test procedure 1-ST-19, " Core Performance" by the licensee for test
;    condition (TC) 6 verification of core thermal limits and core thermal i    power. A preliminary review of the test data by the SRI revealed i-that core thermal limits were well within the TS limits and core thermal power was approximately 99.3 percent of rated thermal power.


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Item 2 The minimum flow valve E12*VF064C was placed in the open position, per the SOP-0031, however, PID-27-7C showed this valve to be closed.
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Item 3 Operations personnel had previously performed an audit of locked valves on the RHR system and determined valve E12*VF063C was verified to be closed, but no lock was installed on the valve because it was approximately twenty feet above the floor and      *
considered inaccessible.
 
Item 4 Operations was aware of the differences between the two existing system drawing types and the SOP's and was in the process of correcting this situation by revisions to the PID's and the SOP's. The cause of these discrepancies was determined to be the
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No violations or deviations were identified in this area of
  . inspectio ,
6., Safety System Walkdow l'Duringthisinspebtionperiod,theSRIandRIperformedawalkdownofthe
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  "C",RHR system to verify proper system alignment for operability as required by TS for Operational Conditions 1, 2, 3, 4, and 5. It was observed that:
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o sy' stem valves were properly aligned; o abnormal control-room instrumentation readings or alarms were
t ATTACHMENT (cont'd.) Page 2 lack of configuration management programs to ensure procedure updates on the issuance of changes to drawings and drawing updates to reflect commitments to lock specific valves.
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present; o no leakage from major components was present; o the "C" RHR pump upper and lower bearing oil reservoirs were properly filled; and o accessible hangers and supports were intac No anomalies were noted that would have affected "C" RHR system operability for low pressure coolant injection (LPCI). However, certain discrepancies were noted when comparing the system condition / lineup with the engineering piping and instrument diagrams (PIDs). It was noted that pipe caps were missing from five vent and drain locations where PID-27-7C indicated caps were installed; valve E12*MOVF064C which was open showed closed on PID-27-7C; and valve E12*VF063C was not locked as shown on PID-4-3C. Also, several valves were locked closed although the drawings did not indicate locks installed. The failure to implement procedures to maintain a safety system condition / lineup as shown on design output drawings or to modify the design output drawings to reflect the required system condition was identified by the SRI as an apparent violation (458/8620-02). Subsequent discussions with licensee management revealed that minimum flow valve E12*MOVF064C is open for standby operation and condensate fill and flush valve E12*VF063C (not a major flow path valve)
had been identified as unlocked during an operations review of all valves on the locked valve list. It had been noted that the valve was unlocked and inaccessible without a scaffold or ladder. No action had been taken to gain access to the valve to install a lock. The licensee took immediate action to obtain ladders, and the valve was locked as shown on PID-4-3C when the SRI identified that the valve was not locked. It was also noted that the system operating procedure valve lineup did not indicate that valve E12*VF063C was to be locked closed as show on the PI In response to the identified violation, the licensee should address how they will assure that PID drawing, Stone and Webster flow diagrams, system operating procedure valve lineups, locked valve lists and actual system configuration are consistent for an identified system operational condition and they should identify procedural controls which allow deviation from drawing requirements. For example, procedures may allow


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CORRECTIVE STEP WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
    -11-the locking of more valves than shown on the drawings at the discretion of the operations staff. This issue should also be addressed for other drawings / documents used routinely by operations and/or maintenance for performance of work activitie . Operational Safety Verification The SRI and RI observed operational activities throughout the inspection period and closely monitored operational events. Control room activities and conduct were observed to be well controlled and efficient. Proper control room staffing was maintained and access to the control room operational area was controlled. The licensee was adhering to limiting conditions for operation (LCO) as they occurred. Operators were questioned regarding lit annunciators and they understood why the annunciators were lit in all cases. Selected shift turnover meetings were observed, and all necessary information concerning plant status was apparently being covered in these meetings. A walkdown of the "C" RHR system was conducted, and the valves were observed to be in the proper position for standby operation. Several plant tours were conducted and overall plant cleanliness was good. During these plant tours, radiation protection area postings were observed to be accurat During this inspection period the licensee completed a 100 hour verification run at full power operation, and all planned startup testing was complete No violations or deviations were identified in this area of inspectio . Maintenance Witness During this inspection period, the RI observed portions of selected corrective maintenance activities to verify that maintenance activities are being conducted in accordance with approved procedures, TS and appropriate industrial codes and standards. The RI verified through direct observation and review of records that:
 
o maintenance activities did not violate LCOs; o redundant components were available; o required administrative approvals and tagouts were obtained before initiating work; o procedures were adequate to control the work; o radiological controls were properly implemented where applicable; o QC hold points were established and observed; and o replacement parts and materials used were properly certifie , o-12-The_following two corrective maintenance activities were observed:
The five missing pipe' caps that are shown on PID-27-C  have  been replaced.
o Control Rod Drive (CRO) Cooling Water Check Valve:
 
On May 7, 1986, the licensee experienced a failure of control rod 24-33 to insert or withdraw during control rod manipulation Trouble shooting of the hydraulic control unit (HCU) revealed that CRD cooling water check valve C11-V138 was not reseating when drive water was applied to HCU 24-33. This condition allowed the drive water to flow back thru the cooling water line and thus the necessary lift was not being provided to the CRD drive piston to insert the rod or retract the collet finger to allow withdraw of the control ro This condition would not have prevented the control rod from inserting during a reactor scra ~The. licensee initiated prompt maintenance work request (MWR) 39099 to clean', inspect and replace if necessary the ball checks to CRD cooling water check valve C11-V138 on HCU 24-33. The RI verified prior to initiating work that the MWR had been properly initiated; QC notification points were established, the job plan was appropriate to control the work; and a job briefing had been performed as evidenced by maintenance personnel signatures on the job briefing sheet. In addition, the RI verified the requirements of T.S. 3.1.3.1 for an inoperable control = rod were being complied wit Prior to in'itiating work, the nuclear equipment operator (NE0)
Since valve E12*MOVF064C was in the proper position in accordance with SOP-0031 it will be left in this position (i.e., open to allow minimum flow).
obtained the shift supervisors permission to isolate HCU 24-33. The
 
, ' HCU was then isolated and tagged out using clearance number 86-192, and.the ball was removed from the check valve. Inspection of the ball revealed surface scratches and abrasions. Subsequent flushings of the cooling water line produced a 1/2" x 1/16" round metal slive '
I Valve E12*VF063C has been locked as shown on PID-4-3C.
A new ball was then installed in the check valve and the system
. verified operable using surveillance test procedure STP-052-0101,
" Control Rod Movement Operability Check." LC0 86-394, which was initiated to track the action requirements of T.S. 3.1.3.1 was closed based on the acceptable performance of STP-052-010 No violations or deviations were identified in this area of inspection, o Division II Emergency Diesel Generator:
During the performance of surveillance test STP-309-0202," Diesel Generator Division II Operability Test," on June 5,1986, the " ready to load" light did not illuminate after the diesel generator achieved rated frequency and voltage. The licensee noted this condition and immediately shut down the diesel. The failure of the " ready to load light" to illuminate indicates that the standby generator breaker 1 ENS *ACB27 would not have closed onto standby buss IENS*SW61 Prompt MWR 41549 was then initiated to trouble shoot and restore the ready to load circuit to operable statu The RI reviewed the MWR


. *
Operations has revised the RHR SOP to agree with existing PID's.
  .
  -13-prior to the initiation of work and verified that a deficiency tag had been placed and the applicable LC0 initiated. The appropriate hold points were placed in the procedure and a quality control representative was present during the performance of this MWR. The RI verified that the lifted leads were identified in the Lifted Lead and Jumper Log as tag, numbers 86-3101-001 thru 006 and that the
, restored leads were independently verifie The licensee identified-that relays EGS*UVRA-UVRB needed the pick up voltages adjusted to within the setpoint limits. This work was subsequently performed under MWR 41549, and the diesel restored to operable statuu at 2041 hrs after the successful completion of surveillance STP-309-020 LC0 86-472 was then cancelled at 2045 hour No violations'or deviations were identified in this area of inspectio . Surveillance Witness The SRI and RI witnessed surveillance testing conducted by the licensee during this inspection period and the following observations were made:
o Surveillance Test STP-051-4210:
The SRI witnessed a portion of the instrumentation surveillance STP-051-4210, "RPS/RHR Reactor Vessel Steam Dome Pressure - High, Monthly Chfunct, 18 Month Chcal, and 18 Month LSFT (821-N078B,B21-6798)" conducted on May 28, 1986. The portion of the test observed was known to cause a half scram signal and the technicians were cautious in verifying the other division was not tripped prior to test performance. They also limited the time that the half scram was allowed to be in by close coordination with the operations staff. During the performance of this test it was noted that there were more than one copy of certain pages of the procedure in the official work cop This created some confusion during test performanc The SRI discussed this with instrumentation maintenance supervision and it was discovered that there were seven open TCNs against this procedure and the preparer of the last TCN (No. 86-0581)
had failed to use copies of previous permanent TCN pages to markup for the new TCN as required by administrative procedure. This resulted in the official work copy of the procedure containing three page eights and three page elevens with a different TCN number on each pag This failure to follow administrative procedures for issue of TCNs was identified by the SRI as an apparent violation (458/8620-01).


The SRI also discussed the status of incorporation of TCNs in procedure revisions in response to a previous NRC violation and it was found that there are a total of 38 procedures with more than three open TCNs out of a total procedure population of
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Nuclear Equipment Operators on rounds will take notice of missing pipe caps and replace them. A supply of caps has been placed in the Control Room for this purpose. Local Leak Rate Testing (LLRT) Procedures include a step to ensure replacement of caps which are removed for LLRT. GSU Design Engineering, along with Stone & Webster (S&W) is in the process of determining which pipe caps are required for a system to meet its intended design.


  . - - .. - .-- - .
A new procedure, Operation Section Procedure (OSP) -0014, " Control of Locked Valves and Devices", which directly controls locked valves and other devices required to be locked has been issued by
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    -14-approximately 3500. The SRI requested a date from licensee management for revision of these 38 procedures to incorporate the
  'open TCNs and management stated that these procedures would be issued
*
by September 1, 198 o Surveillance Test STP-309-0202:
The RI observed the performance of surveillance STP-309-0202, " Diesel Generator Division II Operability Test," Revision 5 on June 5, 1986,
  .with the plant in operational condition 1. This surveillance is
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  . designed to demonstrate the operability of the Division II diesel
the Operations Department.
 
GSU Design Engineering has initiated two Modification Requests (MR's), Nos. 86-1587 and 86-1588, to add notes to the PID's concerning valve position and pipe caps. A note will be added to PID's stating that valve positions shown on the PID's are for the l
normal mode of operation and are for information only. The valve positions indicated by the PID's are not to be used for actual valve lineups. Station Operation Manual (SOM) procedures will govern actual valve position. Another note on the PID's will state that pipe caps are not required for system operability.
 
Any exceptions to this note will be identified on the PID.    .
I A review of PID's against Flow Diagrams (FSK's) and Loop Diagrams by S&W began in January  1986. This review identified
; discrepancies in these drawings. MR's were initiated to resolve
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generator and satisfie's T.S. Sections 4.8.1.1.2.a.1 through i  4.8.1.-l.2.a.7;and 4.8.1.1.2.c.1 and .
these discrepancies in accordance with existing design control
  -
: procedures. This initial review has been completed, however, all l MR's have not been closed. Ninety-Five (95) MR's were identified
) Prior to' initiating the test, communications were established between
 
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the NE0 at the remote diesel panel and the NC0 in the Main Control i  Roo LC0 86-472 had previously been initiated in accordance with
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!  T.S. 3.8.1.1.b because of the preplanned preventive maintenance (PM)
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which had been performed on this diesel generator prior to beginning
  'STP-309-0202. Upon initiation of the STP, the diesel generator was observed to attain rated frequency and voltage within the required 10 seconds, however the " ready to load" light did not illuminate at either the remote panel or in the main control room. The diesel generator was shutdown within 30 seconds of its starting and prompt MWR 41549 initiate The failure of the " ready to load" light to illuminate indicates that the standby generator breaker IENS*ACB27 would not have closed onto standby bus IENS*SW61 After verifying the diesel generator had failed its surveillance test, the licensee initiated the actions required by T.S. 3.8.1.1.b for an inoperable diesel generator, because of any cause other than the performance of preplanned preventive maintenanc MWR 41549 was completed at 2015 hours on June 5, 1986, and STP-309-0202 was satisfactorily performed. LC0 86-472 was then
:  closed based on the diesel generator satisfying the operability tes No violations or deviations were identified in area of the inspection.


i 10. Licensee Plans for Coping With Strikes
    .- - - . _. -_ -
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The SRI reviewed licensee plans for coping with strikes during this inspection period. It was found that the licensee had addressed such issues as personnel / training requirements, security support requirements,
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offsite support, et This area will be reviewed further during future NRC inspections as require No violations or deviations were identified in this area of inspectio :
!    ATTACHMENT (cont'd.)  Page 3 f
that affect PID's. Design Engineering will conduct a survey of a 10% sample of safety related PID's to verify the effectiveness of the S&W review. If additional discrepancies are identified, an MR is processed in accordance with NuPE-AA-0054, " Guidelines and Instructions for Processing Modification Requests".
 
PID's will be reviewed and revised to include locked open and i  locked closed designations for those valves which must be locked because of regulatory requirements. A list of locked valves will be generated and a Design Engineering procedure developed to
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control this list and to delineate the requirements for locking
"
valves. Upon completion, this procedure will be forwarded to
;  Operations for implementation under OSP-0014.


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The criteria will divide locked valves into two groups:
regulatory required locked valves and administrative required locked valves. Regulatory required locked valves are those valves that must be locked in accordance with  regulatory requirements. Administrative required locked valves are those
;  which, at the discretion of the River Bend Operations Department, must be locked for safety considerations or other administrative reasons.
:  Overall, it is anticipated that this review process and the establishment of the locked valve criteria will reduce the number of required locked valves.
 
i A review of PID's versus SOP's has been conducted. Changes to
;  the procedure have been issued to agree with the PID's. Adequate
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configuration management control procedures are currently in
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place, and changes to locked valve status will be followed by
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updates to the SOP's via these controls.
 
;  DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The procedural controls ensuring replacement of pipe caps in l i
Local Leak Rate Testing Procedures are in place.
 
Valve E12*VF063C has been verified to be locked at the time of this response.
 
MR's issued to correct discrepancies between PID's and FSK's l  Loop Diagrams will be completed by December 31, 1986. andl I  The review of PID's with respect to locked valve criteria and the
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procedures controlling these locked valves will be completed by
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November 30, 1986.
 
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ATTACHMENT (cont'd.) Page 4 MR 86-1587 concerning pipe caps on PID's and MR 86-1588 concerning valve position will be completed by December 31, 1986.
 
The Design Engineering survey of safety related PID's will be completed by December 1, 1986.


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>
    -15-1 Status of TMI Action Item (Closed) NUREG-0737, Item I.G.1: Trair;ing during initial startup test
l
. phas The licensee has completed the initial startup test program training requirements as described in NUREG-0737, Item I.G.1 and FSAR Section 14.2.3 Training During Initial Startup Test Phase. The startup test training program was established to assure that personnel from each of the six operating shift crews:
!,
o observed a reactor scram; o observed a pressure regulator transient; o observed a water level setpoint transient; o operated the operation of RCIC system; and o observed a turbine trip or load rejectio The startup test program was balanced, as much as practical, between the six shif ts to assure that each shift was exposed to the above, off-normal event This has resulted in each shift having at least four individuals who have observed actual plant responses for each of these event Based on the shift experience that now exists for each shift crew, no further licensee action regarding NUREG-0737, Item I.G.1 is necessar This TMI action item is close . Exit and Inspection Interview An exit interview was conducted on June 19, 1986, with licensee representatives (identified in paragraph 1). During this interview, the SRI reviewed the scope and findings of the inspection.
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Revision as of 03:49, 20 January 2021

Ack Receipt of 860829 & 1017 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-20
ML20213E539
Person / Time
Site: River Bend Entergy icon.png
Issue date: 11/05/1986
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: William Cahill
GULF STATES UTILITIES CO.
References
NUDOCS 8611130209
Download: ML20213E539 (2)


Text

, .

NOV 5 1986 In Reply Refer To:

Docket: 50-458/86-20 Gulf States Utilities

. ATTN: William J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group P.-0. Box 220 St. Francisville, Louisiana 70775 Gentlemen:

Thank you for your letters, dateo August 29, 1986, and October 17, 1986, in response to our letters, dated July 30, 1986, and September 16, 1986. We have no further questions at this time and will review your corrective action during a future inspectio'n.

Sincerely,

-cornai nma dy:

  1. 1. r_ H A t. L*

J. E. Gagliardo, Chief Reactor Projects Branch cc:

Gulf States Utilities ATTN: J. E. Booker, Manager-Engineering, Nuclear Fuels & Licensing P. O. Box 2951 Beaumont, Texas 77704

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Louisiana State University, Government Documents Department Louisiana Radiation Control Program Director bcc: (see next page)

' iV

C /( C RPB JPJpu on:cs /kJEGagliardo g 11/g/86 Wil/ /86 D\

4 y s \

8611130209 861105 PDR ADOCK 05000458 G PDR

, .

Gulf States Utilities -2-bec to DMB (IE01)

bcc distrib. by RIV:

RPB DRSP Resident Inspector R. D. Martin, RA Section Chief (RPB/A) D. Weiss, LFMB (AR-2015)

MIS System RSB RSTS Operator R&SPB RIV File

' '

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s.

GULF STATES UTELETIES COMPANY ,

river BEND STATION Post OFFICE BOX 220 $7 FR ANCISVlLLE. louts 4ANA 70775 AREA CODE 504 635 6094 346 8651 August 29, 1986 RBG- 24275 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Adntinistrator U.S. Nuclear Regulatory Commission Region IV t

_.

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611 Ryan Plaza Drive, Suite 1000 j 1:, y tf. t :

Arlington, TX 76011

,

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Dear Mr. Martin:

SEP - 41986 ', _

"

dO; River Bend Station - Unit 1 -

Refer to: Regicn IV -

Docket No. 50-458/ Report 86-20 This letter is in response to the Notice of Violation contained in NRC Inspection Report No. 50-458/86-20. The inspection was performed by Messrs. D. D. Chamberlain and W. B.

Jones during the period May 1 through June 15, 1986, of activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No. 1.

.

Gulf States Utilities Company's (GSU) response to the Notice of Violation 8620-01 and 8620-02 is provided in the enclosed attachment. This completes GSU's response to the Notice of Violation.

Sincerely,

.

W. J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group GP 6?S WJC/ ERG /RRS/kn Attachment

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UNITED STATES OF AMERICA BUCIAAR REGUIATORY Ct3 MISSION

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STATE OF IRISIAEA 5 FARISE OF UEST FELICIANA l .

In the Matter of $ Docket Boe. 50-458 CULF STATES UTILITIES CtBIFARY I (River Bend Station,

Unit 1) .

AFFID&VIT W. J. Cahill, Jr., beins 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 heretos and that all such documents are true and correct to the best of his knowledge, information and belief.

W. Cahill, Jr. //

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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /7 day of dead ,19&. l l r tt o /%

anW.Middlebloops I otary Public in and for West Feliciana Parish, Louisiana l l

My Conunission is for Life. l

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ATTACHMENT

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Response to Notice of Violation 50-458/8620-01

{

Level IV FAILURE TO FOLLOW ADMINISTRATIVE PROCEDURES FOR ISSUANCE OF TEMPORARY CHANGE NOTICES (TCN's)

REFERENCE:

Notice of Violation -

Letter to W. J. Cahill, Jr. from J. E.

Gagliardo dated July 30, 1986.

'

REASON FOR THE VIOLATION l During an NRC inspection conducted on May 1 through June 15, 1986, the inspectors identified a failure to follow

Administrative procedures. As a result of personnel oversight,

, I&C Maintenance Technicians failed to comply with the procedural requirements of Administrative Procedure (ADM)-0003,

" Development, Control and Use of Procedures" when initiating i Temporary Change Notice No. 86-0581 for procedure STP-051-4210.

This resulted in an official work copy of the procedure

,

containing duplicate page numbers with different Temporary Change

Notice (TCN) Numbers on each page.

i

) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS' ACHIEVED

On April 10, 1986, prior to the NRC inspection, Memorandum No.
PAS-86-141 was issued identifying procedures with two or more TCN's having duplicate pages with different changes.

'

The

memorandum identified the deficiencies with STP-051-4210 and j requested that the faulty TCN's be corrected.

i In response to Memorandum No. PAS-86-141, Procedure STP-051-4210, .

l Revision 2, was submitted for revision on April 20, 1986 to  !

l incorporate the outstanding TCN's and eliminate the duplicate pages. Revision 3 of STP-051-4210 was approved and issued on July 30, 1986.

CORRECTIVE STEPS WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The I&C Procedure Coordinator reviewed the TCN deficiencies with i

the. responsible individuals and instrucLad the individuals to

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comply with the requirements of ADM-0003 when initiating future TCN's.

Memorandum No. PIC-M-86-116 was issued on July 9, 1986 requesting that TCN's issued by the I&C Maintenance Department be routed l through the I&C Procedure Coordinator prior to obtaining the

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Shift Supervisor's signature. The IEC Procedure Coordinator is i responsible for reviewing TCN's being issued to assure compliance l with ADM-0003 and evaluates the necessity of the TCN. The

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ATTACHMENT (Cont'd)

routing of the TCN through the I&C Procedure coordinator will be discontinued when the number of TCN's being issued is significantly reduced.

] To prevent recurrence of similar violations, ADM-0003 was revised

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on 8/6/86 to clarify procedural instructions for issuing a TCN to a page that has been previously changed by a TCN.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

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STP-051-4210 was reviied on July 30, 1986 to incorporate the

outstanding TCN's and eliminate the duplicate pages.

River Bend Station is currently in compliance.

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Response to Notice of Violation 50-458/9620-02 Level.IV

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FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY REASON FOR THE VIOLATION A walkdown of the "C" Residual Heat Removal (RHR) system by NRC inspectors identified the following differences between actual

system configurations and controlling instructions, procedures, and drawings: 1) five pipe caps, shown as installed on Engineering, Piping and Instrument Drawing PID-27-C were not.

installed, 2) valve E12*MOVF064C, which was shown closed on Engineering, Piping and Instrument Drawing PID-27-7C was open, 3)

valve E12*VF063C was not locked, although Engineering, Piping and Instrument Drawing PID-4-3C showed this valve to be locked, 4)

differences were found between Engineering, Piping and Instrument Drawing PID-27-7C and System Operating Procedure, SOP-0031, as to which valves were locked in position.

Item 1 Investigaticns to determine the reason that the pipe caps are missing, although shown installed on Engineering, Piping and Instrument Drawing, PID-27-7C, are indeterminate.

Item 2 The minimum flow valve E12*VF064C was placed in the open position, per the SOP-0031, however, PID-27-7C showed this valve to be closed.

Item 3 Operations personnel had previour,1y performed an audit of locked valves on the RHR system and determined valve E12*VF063C was verified to be closed, but no lock was installed on the valve because it was approximately twenty feet above the floor and considered inaccessible.

Item 4 Operations was aware of the differences between the two existing system drawing types and the SOP's and was in the process of correcting this situation by revisions to the PID's and the SOP's. The cause of these discrepancies was determined to be the lack of configuration management programs to ensure procedure updates on the issuance of changes to drawings and drawing updates to reflect commitments to lock specific valves.

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CORRECTIVE STEP WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The five missing pipe caps that are shown on PID-27-C have been replaced.

Since valve E12*MOVF064C was in the proper position in accordance with SOP-0031 it will be left in this position (i.e., open to allow minimum flow).

i Valve E12*VF063C has been locked as shown on PID-4-3C.

Operations has revised the RHR SOP to agree with existing FID's.

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

Nuclear Equipment Operators on rounds will take notice of missing

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pipe cape and r? place them. A supply of caps has been placed in l the Control Room for this purpose. Additionally, Local Leak Rate

! Testing (LLRT) Procedures will include a step to ensure i replacement of caps which are removed for LLRT. Nuclear Plant-l Engineering (NuPE), along with Stone & Webster (S&W) is in the process of determining which valve caps are required for a system j

to meet its intended design.

PID's will be revised to indicate valve position for a normal mode of operation, and Station Operation Manual (SOM) procedures

will govern actual valve position.

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A new procedure, Operation Section Procedure OSP-0014, which directly addresses the control of locked valves has been issued i by the River Bend Operations Department.

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A review of all PID's versus SOPS has been conducted. Changes to i

the procedures have been issued to- agree with the PID's. A review of the PID's is being performed by NuPE to determine which

! valves should be locked and which should be left unlocked. NuPE l^ will also develop a procedure which will delineate the locked valve regulation requirements. Included in this review will be

, the necessary changes of PID's to match these requirements. Upon completion, it is expected this will decrease the number of valves required to be locked.

j Adequate configuration management control procedures are

currently in place. All changes to locked valve status will be-followed by updates to the SOP's via these controls, i

i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l The additional procedural controls ensuring replacement of pipe t

caps in Local Leak Rate Testing Procedures will be completed by

October 30, 1986.

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Valve E12*VF063C has been verified to be locked at the time of this response.

Procedures being devel5 ped by NuPE for determining locked valve regulation requirements will be completed by November 30, 1986.

, The;PID changes brought about by NuPE's reviews will be completed iby December 31, 1986.

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GULF STATES UTILETIES COMPANY eg RIVER BEND STAYtON POST OFFICE 80x 220 St FRANCISvtLLE. LOutslANA 70776 ARE A CODE 604 635 6094 346-8651 October 17, 1986 RBG- 24583 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

Dear Mr. Martin:

River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 86-20 This letter is in supplemental response to the Notice of Violation contained in NRC Inspection Report No. 50-458/86-20.

The inspection was performed by Messrs. D. D. Chamberlain and W.

B. Jones during the period May 1 through June 15, 1986, of activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No. 1.

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Gulf States Utilities Company's (GSU) supplemental response to the Notice of Violation 8620-02, " Failure to Control Activities Affecting Quality", is provided in the enclosed attachment. This completes GSU's response to the Notice of Violation.

Sincerely,

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W. J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group

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Attachment .

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OCT 231986 Mc -,; -

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  • UNITED STATES OF AMERICA BUCLEAR EEGULATORY CCESEISSION

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STATE OF IAUISIAEA 5 FARISE OF WEST FELICIAEA 5 In the Matter of I Docket Bos. 50-458 GULF STATES UTILITIES C(EEFANY $

(River Bend Station, Unit 1) .

AFFID&VIT W. J. Cahill, Jr., being duly sworn, states that he is a Senior Vice President of Gulf States U' 111 ties Company: that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission the documents attached heretos and that all such documents are true and correct to the best of his knowledge, information and belief.

W. J Cahill, Jr.

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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /8 ,

day of #MM , 19ffe,.

Q 9//] L U L L /,

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Joan W. Middlebrooks Notary Public in and for West Feliciana Parish, Louisiana My Commission is for Life.

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ATTACHMENT Response to Notice of Violation 50-458/8620-02 Level IV FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY REFERENCE Notice of Violation - Letter to W. J. Cahill, Jr. from J. E.

Gagliardo dated July 30, 1986.

Request for supplemental information - Letter to W. J. Cahill, Jr. from J. E. Gagliardo dated September 16, 1986.

REASON FOR THE VIOLATION A walkdown of the "C" Residual Heat Removal (RHR) system by NRC inspectors identified the following differences between actual system configurations and controlling instructions, procedures, i

and drawings: 1) five pipe caps, shown as installed on

Engineering, Piping and Instrument Drawing (PID)-27-C were not installed, 2) valve E12*MOVF064C, which was shown closed on PID-27-7C was open, 3) valve E12*VF063C was not locked, although PID-4-3C showed this valve to be locked, 4) differences were found between PID-27-7C and System Operating Procedure, (SOP)-0031, as to which valves were locked in position.

Item 1 Investigations to determine the reason that the pipe caps are missing, although shown installed on PID-27-7C are indeterminate.

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Item 2 The minimum flow valve E12*VF064C was placed in the open position, per the SOP-0031, however, PID-27-7C showed this valve to be closed.

Item 3 Operations personnel had previously performed an audit of locked valves on the RHR system and determined valve E12*VF063C was verified to be closed, but no lock was installed on the valve because it was approximately twenty feet above the floor and *

considered inaccessible.

Item 4 Operations was aware of the differences between the two existing system drawing types and the SOP's and was in the process of correcting this situation by revisions to the PID's and the SOP's. The cause of these discrepancies was determined to be the

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t ATTACHMENT (cont'd.) Page 2 lack of configuration management programs to ensure procedure updates on the issuance of changes to drawings and drawing updates to reflect commitments to lock specific valves.

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CORRECTIVE STEP WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

The five missing pipe' caps that are shown on PID-27-C have been replaced.

Since valve E12*MOVF064C was in the proper position in accordance with SOP-0031 it will be left in this position (i.e., open to allow minimum flow).

I Valve E12*VF063C has been locked as shown on PID-4-3C.

Operations has revised the RHR SOP to agree with existing PID's.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Nuclear Equipment Operators on rounds will take notice of missing pipe caps and replace them. A supply of caps has been placed in the Control Room for this purpose. Local Leak Rate Testing (LLRT) Procedures include a step to ensure replacement of caps which are removed for LLRT. GSU Design Engineering, along with Stone & Webster (S&W) is in the process of determining which pipe caps are required for a system to meet its intended design.

A new procedure, Operation Section Procedure (OSP) -0014, " Control of Locked Valves and Devices", which directly controls locked valves and other devices required to be locked has been issued by

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the Operations Department.

GSU Design Engineering has initiated two Modification Requests (MR's), Nos. 86-1587 and 86-1588, to add notes to the PID's concerning valve position and pipe caps. A note will be added to PID's stating that valve positions shown on the PID's are for the l

normal mode of operation and are for information only. The valve positions indicated by the PID's are not to be used for actual valve lineups. Station Operation Manual (SOM) procedures will govern actual valve position. Another note on the PID's will state that pipe caps are not required for system operability.

Any exceptions to this note will be identified on the PID. .

I A review of PID's against Flow Diagrams (FSK's) and Loop Diagrams by S&W began in January 1986. This review identified

discrepancies in these drawings. MR's were initiated to resolve

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these discrepancies in accordance with existing design control

procedures. This initial review has been completed, however, all l MR's have not been closed. Ninety-Five (95) MR's were identified

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that affect PID's. Design Engineering will conduct a survey of a 10% sample of safety related PID's to verify the effectiveness of the S&W review. If additional discrepancies are identified, an MR is processed in accordance with NuPE-AA-0054, " Guidelines and Instructions for Processing Modification Requests".

PID's will be reviewed and revised to include locked open and i locked closed designations for those valves which must be locked because of regulatory requirements. A list of locked valves will be generated and a Design Engineering procedure developed to

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control this list and to delineate the requirements for locking

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valves. Upon completion, this procedure will be forwarded to

Operations for implementation under OSP-0014.

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The criteria will divide locked valves into two groups:

regulatory required locked valves and administrative required locked valves. Regulatory required locked valves are those valves that must be locked in accordance with regulatory requirements. Administrative required locked valves are those

which, at the discretion of the River Bend Operations Department, must be locked for safety considerations or other administrative reasons.
Overall, it is anticipated that this review process and the establishment of the locked valve criteria will reduce the number of required locked valves.

i A review of PID's versus SOP's has been conducted. Changes to

the procedure have been issued to agree with the PID's. Adequate

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configuration management control procedures are currently in

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place, and changes to locked valve status will be followed by

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updates to the SOP's via these controls.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The procedural controls ensuring replacement of pipe caps in l i

Local Leak Rate Testing Procedures are in place.

Valve E12*VF063C has been verified to be locked at the time of this response.

MR's issued to correct discrepancies between PID's and FSK's l Loop Diagrams will be completed by December 31, 1986. andl I The review of PID's with respect to locked valve criteria and the

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procedures controlling these locked valves will be completed by

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November 30, 1986.

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ATTACHMENT (cont'd.) Page 4 MR 86-1587 concerning pipe caps on PID's and MR 86-1588 concerning valve position will be completed by December 31, 1986.

The Design Engineering survey of safety related PID's will be completed by December 1, 1986.

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