IR 05000458/1988008

Ack Receipt of 890306 Supplemental Ltr Responding to Violations Noted in Insp Rept 50-458/88-08

ML20247K337
Person / Time
Site:	River Bend
Issue date:	03/24/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8904050228
Download: ML20247K337 (2)

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In Reply Refer To:

Docket: 50-458/88-08 gyg Gulf States Utilities ATTN: Mr. Janes C. Deddens Senior Vice President (RBNG)

P.O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:

Thank you for your letter of March 6,1989, which revised your letter of June 1,1988, in response to our letter and Notice of Violation dated May 2, 1988. 'Je have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions durir.g a future inspection to determine that full compliance has been achieved and vill be maintaine

Sincerely, Drlgfnal sgrd ny E E / d e S Ye nr7 & 1 L. J. Callan, Director Division of Reactor Projects cc:

Gulf StatesJ Itilities ATTN: J. E. Bc,oker, Manager-River Bend Oversight P.O. Box 2951 Beaumont, Texas 77704 Gulf States Utilities ATTN: Les England, Director Nuclear Licensing - RBNG P.O. Box 220 St. Fra,1cisville, Louisiana 70775 Louisiana State University, Government Documents Department Louisiana Radiation Control Program Director J g

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8904050228 890324

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PDR ADOCK 05000458 Q PDC

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i DRP RRI R. D. Martin, RA SectionChief(DRP/C) !

I Lisa Shee, RM/ALF MIS System RPD-DRSS RSTS Operator }

Project Engineer, DRP/C RIV File W. Paulson, NRR Project Manager (MS: 13-D-18) DRS I  ;

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GULF STATES UTELITIES COMPANY

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March 6,1989 RBG- 30250 File Nos. G9.5, G15. $$55$YYlc '

U. S. Nuclear Regulatory Commission ,, ,

Document Control Desk Washington, D.C. 20555

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MAR I 3198 i)-[

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Gentlemen: l River Bend Station - Unit 1 Refer to.: Region IV Docket No. 50-458/ Report 88-08 This letter revises Gulf States Utilities Company's (GSU)

response to the Notice of Violation-contained in NRC -Inspection Report No. 50-458/88-0 The inspection was performed by Messr Chamberlain and Jones during the period of February 16 - March 31, 1988 of activities authorized by Operating License NPF-47 for River Bend Station - Unit GSU's revised response to Notice of Violation 8808-01,

" Inadequate Alarm Response Procedure", is provided in the enclosed attachment pursuant to 10CFR2.20 Changes to the '

original response are noted with sidebars in the right margi This completes GSU's response to this ite .

I Sincerel ,

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J. C. Deddens Senior Vice President

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g River Bend Nuclear Group i JCD/ /t / K/ ch cc: U. S. Nuclear Regulatory Commission Region IV

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611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Senior Resident Inspector P. O. Box 1051 St. Francisville-, LA 70775 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA )

PARISH OF WEST FELICIANA )

Docket No. 50-458

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In the Matter of )

GULF STATES UTILITIES COMPANY )

(River Bend Station - Unit 1)

AFFIDAVIT Deddens, being 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 hereto; and that all such documents are true and correct to the best of his knowledge, information and belie I J. C.vU6ddens Subscribed and sworn to before me, a Notary Public in and I

for the State and Parish above named, this 6 Y( - day of 7M da;}l , 19 $ Y . My Commission expires with Lif GL +,

Claudia F. Hurst l$ W Notary Public in and for West Feliciana Parish, Louisiana

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ATTACMENT Response to Notice of Violation 50-458/8808-01 REFERENCE:

Notice of Violation - Letter from L. J. Callan to J. C. Deddens, dated May 2, 198 INADEQUATE ALARM RESPONSE PROCEDURE:

River Bend Station Technical Specifications, paragraph 6.8.1.a. requires that procedures for activities identified in Appendix A of Regulatory Guide 1.33 Revision 2, February 1987 be established, implemented and maintaine Pa ragraph 5 to Regulatory Guide 1.33 requires that alarm annunciator procedures "contain: (1) the meaning of the annunciator, (2) the source of the signal, (3) the immediate action that is to occur automatically, (4) the immediate operator action and (5) the long-range actions."

Contrary to the abcVe, it was discovered on March 10, 1988, that the source of the signals defir.ed in alarm response procedure ARP-601-19, "P601-19 Alarm Responses," Revision 2, were incorrect in that the alarm setpoints were incorrectly stated for alarm numbers 2403 and 240 These alarms are for main steam tunnel ambient temperature high and main steam tunnel ventilation differential temperature hig In addition, the immediate and long range actions were inadequate in that actions for alarm 2403 defined the temperature at which the main steam tunnel temperature should be maintained below 180 degrees F rather than the correct value of '130 degrees F. If cooling systems cannot prevent the temperature from approaching the main steam valve isolation setpoints, no additional operator actions were specified to prevent a full main steam line isolation at high reactor power level REASON FOR VIOLATION:

The alarms in question are initiated by non-safety related recorders, and thus are not classified as safety related. However, the alarms are designed to alert the operator to high temperature conditions in an area protected by high temperature isolation logic, and are operational aids for that reaso Setpoints are included in the River Bend Station (RBS) alarm response procedures (ARPs) in excess of RG 1.33, " Quality Assurance Program Requirements (0perations)", guidelines as a supplementary source of information for the operator. Thus, the errors cited in the potential violation are considered to have no safety significance as related to the procedur Review of the procedural error, undertaken as immediate corrective action and as discussed with the NRC Senior Resident Inspector, revealed that in the-past the ARP was correct but the setpoint information was changed to incorrect values during one of the revision cycles. Both of the alarms had been actuated for an extended period due to unreasonably low setpoint selection. At the time the ARP errors were discovered, modification request (MRs)85-1154and86-1035 were in process of being worked to raise the Page 1 of 3 e__ . _ _ _ - - - _ _ _ .

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setpoints of the alarms in question to values within two degrees of the erroneous value Corrective action for the specific errors has been completed and TCNs were issued correcting the inaccurate ARP The root cause of the error is determined to be lack of understanding of the system alarm design details during procedure development. As designed, each

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leak detection thermowell contains two thermocouple, each identified with i the same mark numbe One thermocouple provided input to the Riley j tempera ture switch, which in turn supplies a trip signal at the isolation setpoint to the trip logic, the isolation alarm, and the meter modul The other thermocouple inputs to the temperature recorder, which actuates the l pre-isolation alarm at a lower setpoint. The ARPs in question listed as the l

initiating device both the temperature switch and the temperature recorder l that are fed by the thermocouple with identical mark numbers. The isolation setpoint, rather than the correct pre-isolation setpoint, was listed in the AR Contributing factors to the lack of understanding of the system design details during procedure development is the method of identifying two thermocouple with the identical mark numbe CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

i A 100% review of thirty-one high temperature leak detection alarms was performe Errors similar to those cited were identified and correcte Thirteen ARPs contained errors based on the same confusion between the temperature switch / temperature recorder as the alarm initiating device. For pre-isolation alarms, when the temperature switch was erroneously included as an initiating device, the temperature switch's setpoint was invariably listed  !

as the alarm setpoin In some of the thirteen ARPs, pre-isolation alarms erroneously included the automatic, operator, and long term actions appropriate to the isolation alarm In addition, two ARPs were found to

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contain random setpoint errors. Corrective action for the above deficiencies is complete, and consisted of portions of TCNs 88-0296, 88-0298, 88-0303, and l 88-030 Nine additional alarm deficiencies were detected during the corrective action review that are attributed to design documentation errors. Four alarm windows, for Divisions 1, 2, 3, and 4 turbine shield wall high temperature, l had been installed without the installation of the alarms themselves.

Corrective action to remove the four alarm windows is work complete via MR j 88-013 Five alarms contained incorrect wording. Three of the five describe the isolation as originating in a specific division, rather~than the correct I origination in either divisio The remaining two incorrectly list the area experiencing the high tempera ture. Corrective action for the five alarm wording deficiencies is included as a portion of MR 88-014 The ARP deficiencies, and the design documentation errors described above, are considered to have no safety significanc Automatic plant responses would have occurred as require Furthermore, the availability of actual area temperature data, and other diverse indications of plant system operations continued to provide the operator with a comprehensive plant statu Page 2 of 3

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l Information for both elements of each dual element thermocouple originally discovered has been combined into a single loop calibration report (LCR).

The instrument loop for each thermocouple was originally addressed by three different LCR The consolidation into a single LCR provides clear identification of the mark numbers, setpoints and trip functions of each ,

bi-stable device using the thermocouple as sensors. When operating or  !

maintenance personnel use the LCR, they will have all of this information summarized in one convenient documen Furthermore, the LCRs are used extensively as reference documents in the preparation of Alarm Response Procedures (ARPs). This consolidation of LCRs will help minimize the possibility of confusion during the preparation of ARPs. It will be obvious in the LCR which alarm is energized by a particular bi-stable devic CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

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Corrective action to prevent reoccurrence will consist of training and required reading for all licensed personnel. The training will consist of a review of leak detection system design drawings and loop calibration report The required reading will consist of the TCNs that corrected the ARP error This corrective action will be complete in September 1988. The two ARPs with random setpoint errors are considered to be isolated human errors, thus no specific corrective action to prevent reoccurrence is addresse Additional corrective action shall consist of a 100% review of ARPs for main control room alarms. The review will be performed in accordance with plant procedure OSP-005, " Operations' Procedure Review and Revision", and will include verification of alarm name, initiating device, setpoint, automatic actions, operator actions, long term actions, possible causes, and references. This review will be complete in March 1989.

l Each of the other ARPs containing errors based on the same confusion between the temperature switch / temperature recorder as the alarm initiating device will have its associated LCRs incorporated into a single LCR by September 1, 198 I J

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Corrective action will be completed by September 1, 198 l

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