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#REDIRECT [[RBG-27648, Responds to Violations Noted in Insp Rept 50-458/87-28. Corrective Action:Administrative Procedure ADM-0003 Revised to Require Initial Sign Off for Actions Performed & Verification Step]]
| number = ML20151B850
| issue date = 04/04/1988
| title = Responds to Violations Noted in Insp Rept 50-458/87-28. Corrective Action:Administrative Procedure ADM-0003 Revised to Require Initial Sign Off for Actions Performed & Verification Step
| author name = Booker J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name =
| addressee affiliation = NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
| docket = 05000458
| license number =
| contact person =
| document report number = RBG-27648, NUDOCS 8804110304
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
}}
 
=Text=
{{#Wiki_filter:. _ _ _ _  _                              _ _                      _          ._        _. _    _    _
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* STATES                              UTXLITIES COMPANY Frd P BE ND fiMI A    FC3T 08H f eGX 2D      $f F R ANC'L"d f. WOS: AN & ? }775 A9E A CCRE 504    635 F94      346P651 April 4, !988 RBG- 27648 File. Nos. G9.5, G15.4.1 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 87-28 This letter responds to the Notice of Violation contained in NRC Inspection Report No. 50-458/87-28.                          The inspection was performed                        by Messrs.
Chamberlain and Jones during the period of November 1-21, 1987 on activities authorized by NRC Operating License NPF-47 for River Bend .
Station Unit 1.
Gulf States Utilities Company's                                (GSU) responses to Notices of Violation l
6728-01, "Failure to Maintain Required High Drywell Pressure Instruments Operable", 8728-02, "Failure to Follow a Temporary Test Procedure", and 8728-03, "Failure to Obtain Approved Cancellation Extensions for PMRs" are provided          in the enclosed attachments pursuant to 10CFR2.201.                                        This completes GSU's responses to these items.                                                                                            >
;                                                                                      Sincerely, e      f.            WLi~2_
                                                                                    'J.      E. Booker Manager, River Bend Oversight River Bend Nuclear Group JE0/LAE/J C/ch cc:  U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drira, Suite 1000 Arlington, TX 76011 I
NRC Resident Insper:ter P.O. Box 1051                                                                                                g St. Francisv111e, LA 70775 8804110334 880404
.          PDR  ADOCK 05000450 0                        MD
 
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA                  $
PARISH OF WEST FELICIANA            $
In the Matter of                    I                  Docket No. 50-458 GULF STATES UTILITIES COMPANY        $
(River Bend Station                i Unit 1)                          $
AFFIDAVIT J. E. Booker, being duly sworn, states that he is Manager-River Bend Oversight for Gulf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission the docume-ts attached hereto; that he has read all of the statements contained in such documents attached thereto and made a part thereof; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.
h, f      hW                    "
37J. E. Br oker Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this      4A          day of      f/ /'/P / t_      ,
.          19 F S .
                                                        &v                      (    l& V'
                                                    ',Joan f      W. Middlebrooks Notary Public in and for West Feliciana Parish, Louisiana My Commission is For Life:
}
 
    ,. e ATTACEMENT 1 Response To Notice'of Violation 50-458/8728-ul Level III
 
==REFERENCE:==
 
Notice of Violation - letter from R. D. Martin to          J. C. Deddens, dated March 4, 1988.
            ' Enforcement Conference Meeting Summary - letter from L. J. Callan to J. C.
Deddens, dated January 29, 1988.
Inspection Report - letter from L._        J. Callan to  J. C. Deddens, dated December 7, 1987.
            ' Licensee Event Report      No. 87-027 - letter from J. E. Booker to Nuclear Regulatory Commission, dated December 11, 1987 FAILURE TO MAINTAIN REQUIRED HIGH PRYWELL PRESSURE INSTRUMENTS OPERABLE:
Technical Specifications Limiting Conditions for Operations        (LCO) 3.3.1,
: 3. 3. 2, . and 3.3.3 require that the following minimum channels of Drywell Pressure-High remain operable: two channels per trip system for reactor-protection system (RPS) initiation (operational conditions 1 and 2); two channels per trip system for primary and secondary containment and residual heat removal      (RHR) system isolation (operational conditions 1, 2, and 3);
and four channels for high pressure core spray system (HPCS)          initiation (operational conditions 1,2, and 3). With less than the minimum number of channels operable, the associated LCO action statement requirements include placing the inoperable channel (RPS or isolation actuation) and/or the trip system in the tripped condition within one hour and declaring the HPCS system inoperable.
Contrary _ to the above, from August 1985 to November 17, 1987 while the plant was operating in conditions 1, 2 or 3, one of two channels in one trip      system  for RPS initiation, primary and secondary containment isolation, and RHR system isolation were inoperable, and two of four l            channels for HPCS initiation were inoperable. The channels were inoperable when an instrument root valve (IRCS-V122) for a drywell pressure sensing line was closed, thereby isolating three pressure transmitters, and actions were not taken to meet the action statement requirements.
l REASON FOR THE VIOLAT!ON:
Prior to receiving River Bend Station's low power operating license, system valve lineups were being performed to align the plant systems for startup and operation.      On July 5, 1985, Maintenance Work Request (MWR)    04128 was written on valve RCS*V122 identifying missing valve packing bolts. On
            . August 13, 1985 Station Operating Procedure (SOP)-0001, "Nuclear Boiler Page 1 of 7 l
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Instrumentar on", valve line-up was performed. On the lineup sheets valve RCS*V122 was not initia11ed as being checked in position, but a note was added to identify the valve needed repair. The lineup sheet also had many Temporary Change Notice (TCN) notations in the margin _which may have caused the Shift Supervisor to miss the MWR notation for valve RCS*V122. On August 15, 1985 the Shift Supervisor reviewed the lineup, but overlooked the failure to complete valve RCS*V122.      On September 6, 1985 MWR 04128 was released for work, and on October 26, 1985 it was signed as complete.        No work instructions were included in the package to check valve position.
Since it was a process isolation root valve with the process being drywell ambient air' pressure, there was no safety clearance associated with the valve. Therefore, the mispositioned valve went undetected.          The drywell pressure instruments are unique in that the process provides a zero, or nearly zero, reading at all times, same as an isolated instrument.
Therefore,    channel checks throughout the first cycle did not identify this condition.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Valve RCS*V122 was immediately positioned to the open position. A complete review of this situation was performed, including a determination of the safety significance. The results of this effort were presented to the NRC at an Enforcement Conference on December 14, 1987. Specific corrective action included the following: 1)      100% of safety related system valve lineups were performed prior to startup following Refueling Outage No. 1.
This included independent verification of proper valve position, review by the Shift Supers 4sor, review by the Operations Supervisor, and review by l-        Quality Assurance; 2) process root valves supplying ins t rument s which normally read zero were sealed open; and 3) all four drywell pressure instruments were verified operable during the drywell pressure bypass test.
In addition, the probabilistic consideration analysis of effects of valve
,        IRCS*V122 closure substantiated that the redundancy and diversity provided by the safety systems results in a very low probability of core damage.
t Plant Staif Operations personnel involved in the identification and reporting of the mispositioned valve received commendations from senior management for their alertr.ess and attention to details.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
l l          The Tracking LCO program which was implemented September 12, 1985 has been l          very effective in tracking problems of this nature. This program will be l
continued. Additionally, the following corrective action is planned:        1) l          MWO job plans for work on manual valves require an Opetatio:a "Hold Point" for valve positioning; 2) All safety related systems lineups will be performed each refueling outage; and 3) Operations management will perform
(          a review of complettd safety related lineups to assure the adequacy of noted problem disposition.
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O DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
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  .          s                                                                                          l ATTACEMENT 2 Response To Notice of Violation 50-458/8728-02 Level IV
 
==REFERENCE:==
 
Notice of Violation            -
letter from R. D. Martin to J. C. Deddens. dated March 4, 1988.
                .nspection Report - letter from L.              J. Callan to    J. C. Deddens, dated December 7, 1987.
FAILURE TO FOLLOW A TEMPORARY TEST PROCEDURE:
Technical Specification 6.8.1.d requires that written procedures shall be established,          implemented and maintained for          surveillance    and  test activities of safety-related equipment.
;              Step 7.7.4 of Temporary Procedure (TP) 87-25, "RPV Inservice Leakage Test,"
l              Revision 0, which provides instructions for the inservice leakage test on the reactor pressure vessel, requires that the operator secure shutdown cooling by stopping both RHR pumps and closing shutdown cooling isolation l              valves E12*F053A, E12*F053B, E12*F008 and E12*F009.
Contrary to the above, on November 19, 1987, step 7.7.4 of TP 87-25 was l              improperly signed off by the responsible shift supervisor due to confusion in the procedures, although the required valve manipulations for valves E12*F008 and E12*F009, described among other items in step 7.7.4,                had not been performed.
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!              REASON FOR THE VIOLATION:
l l              In removing the Residual Heat Removal                  (RHR)  system from the shutdown I              cooling mode, the RHR pump was secured and valves E12*F053A and E12*F053B l              were closed. However, valves E12*F008 and E12*F009 vere left open to allow l              torquing of valve E12*F009. The decision was made on the day tha'c shutdown cooling was secured,              to torque valve E12*F009 after securing shutdown cooling, but prior to pressurizing the vessel.                This required that step 7.7.4 be performed in parts. Consequently, before pressurizing the vessel i
the next day, step 7.7.4 was initialed prior to closing valves E12*F008 and E12*F009.        Several factors contributed to the above violation including:
: 1. Step  7.7.4    having too many activities listed, requiring one step to be performed in parts for only one set of initials.
l                              2. No documentation was avialable to demonstrate that the performars had previously read and understood the TP prior to performance.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Upon identification, the Shift Supervisor was notified and the misaligned valves were immediately closed.
Administrative Procedure (ADM)-0003 was revised on March 18, 1988 to require for each special test procedure:                                                1) an initial /signoff for each action performed, and 2) a verification step that all performers have read                                                                                          ,
and understood the procedure prior to performance.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The TP will be revised and changed into a permanent plant procedure.                                                                The ster 7.7.4 will be broken down to require initialing by each activity. Any                                                                                          i persons initialing or signing in the procedure will sign a required reading record or equivalent that he or she has read and understands all the steps.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The TP shall be revised by May 15, 1988.
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  .  . s ATTACHMENT 3 Response To Notice of Violation 50-458/8728-03 Level IV
 
==REFERENCE:==
 
Notice of Violation      -  letter from R. D. Martin to J. C. Deddenr, dated March 4, 1988.
Inspection Report - letter from L. J. Callan to                                    J.                          C. Deddens, dated December 7, 1987.
FAILURE TO OBTAIN APPROVED CANCELLATION EXTENSIONS FOR PMR'S:
Technical    Specification,    6.8.1.a requires that procedures shall be established, implemented, and maintained for activities recommended in Appendix A to Regulatory Guide 1.33, Revision 2, February 1978.                                                              Paragraph 9 of Appendix A to Regulatory Guide 1.33 delineates procedures for control of modification work.
Pursuant to Regulatory Guide 1.33, Procedure ENG-3-006, "River Bend Station Design and Modification Request Control Plan," requires that if a prompt modification request (PMR) cannot be cancelled (i.e.                                                                    converted to a modification request or system returned to original configuration) by the date indicated in block 23, a memorandum explaining the need for an extension and the new cancellation date must be prepared, approved and forwarded to document control for permanent retention.
Contrary to the above, on November 17, 1987, it was found during a review of the PMR status log that extension memoranda had not been approved for 16 PMRs that were not cancelled by the due date.            Examples include, PMR 86-98 l          (due September 15,1987); PMR 86-128 (due October 7,1987) and PMR 87-35 (due October 23, 1987).
REASON FOR THE VIOLATION:
4          In addition to the three overdue safety-related PMRs, 14 other non-safety related PMRs identified by GSU were found to be delinquent. The finding is the result of procedure violation, with several root causes. These causes are:
: 1. Inadequate management attention and lack of emphasis on monitoring of cancellation dates.
: 2. Engineera who determine initial PMR cancellation due dates often have no control over the actual date of work performed oy other departments.
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: 3. In some cases, dates were based on existing outage schedules. As the outage schedule slipped, the PMR cancellation dates were not extended.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
All PMRs have been reviewed for due date status,'and have been either cancelled or extended by memorandum as required by ENG-3-006.                                                  As of December 10, 1Q87, no overdue PMRs have been identified.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Engineering        has initiated a look-ahead program for PMRs and other "due-date" documents, which will keep. abreast of upcoming PMRs due. for cancellation.          The Engineering Administration section will review the PMR log o.4 a weekly basis and advise engineers of PMRs coming due.                                                    In addition, engineering supervisors wiil receive copies of the PMR log on a weekly basis, listing all open PMRs and due dates, thus providing increased supervisory awareness.              Any PMRs which become overdue will be brought to the attention of the. appropriate engineering director for action.                                                To minimize the numbers of extensions, engineers have been advised to consult with other responsible departments prior to extending the PMR cancellation                                            ;
date.        Also, where the cancellation of a PMR is tied to a milestone (such as end of Refueling Outage No. 1), enginears have been instructed to use the milestone as the cancellation date instead of calendar date.
1 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
All corrective action has been completed as of this date.
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