ML20043G221

Responds to 900509 Request for Addl Info Re 900209 Response to Violations Noted in Insp Rept 50-458/89-41.Procedure Being Developed to Provide Guidelines for Future Troubleshooting of Recirculation Flow Control Valve Sys

ML20043G221
Person / Time
Site:	River Bend
Issue date:	06/14/1990
From:	Plunkett T GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-33066, NUDOCS 9006200058
Download: ML20043G221 (7)

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t' GULF STATES UTILET1ES COMPANY a m m .a s m a cost omce ena m u mesnu touseca art A COOrf bO4 tDS 6094 346 tl651 June 14 ,1990 RBG - 33066 File Nos. G9.5, G15.4.1 U.S. Nuclear Regulatory Cmmission Document Control Desk Washington, D. C. 20555 Gentlemen:

River Bend Station - Unit 1 Refer to : Region IV Docket No. 50-458/89-41 As requested in your May 9, 1990 letter, Gulf States Utilities Company (GSU) is providing additional information to supplement our February 9, 1990 response to NRC Inspection Report 50-458/89-41. Extensions to .the subnittal date for this letter and .for the empletion date for corrective action have been discussed.with your Messrs. Constable and Azua. This cmpletes GSU's response to Notice of Violation 8941-01',. " Failure to-Provide Sufficient Maintenance Work Instructions" and 8941-02,

" Failure to Perfonn Post Maintenance 'Ibsting".

Should you have any-questions, please contact Mr. L. A. England at -(504) 381-4145.

Sincerely, r 'i _

T. F. Plunkett i General Manager Business Systems and Oversight-River Bend Nuclear Group

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Attachment cct U. S. Nuclear Regulatory Cmmission

-Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector Post Office Box 1051 $ .l St. Francisville, LA 70775 i l

9006200058 900614 PDR ADOCK 05000459 lIl Q PDC t

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.. .a RFSPG4SE '10 ICI' ICE OF VIO[ATION 50-458/8941-01 (SPNERITY IEVEL IV)

AIO 458/8941-02 (SEVERITY IPNEL IV)

JemulCES - l 1

Notice of Violation -

Letter frm S. J. Collins to J. C. Deddens, dated  !

January 9, 1990.  !

Notice of Enforcement Conference - Dated Decmber 5,1989. q i

Inspection Report -

Letter frm S. J. Collins to J. C. Doddens, dated ,

December 4, 1989.  !

Request for Additional Infonmtion - Intter from S. J. Collins to J. C.

Deddens, dated May 9, 1990.

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VIOIATIONS i

A. Failure to Provide Sufficient Maintenance Work Instructions -j River Bend Station 'Inchnical Specifications, paragraph 6.8.1.a, j requires that procedures for activities identified in Appendix A of Regulatory guide 1.33, Revision 2, February 1978, be established, implemented and maintained. Regulatory Guide 1.33, paragraph 9.c., ,

requires that procedures for the repair or replacment of equipmnt ' be 1 prepared prior to beginning work.

Administrative procedure ADM-0028, " Maintenance Work Order," Revision 10, attachment 2, step 3 requires that the following itms be included in the naintenance work order traveler if appropriate. These items are  ;

1)' major steps in the job plan, 2) applicable procedures, and 3) '

applicable engineering drawings. l 4

' Contrary to the above, prmpt maintenance work order (b50) R056226, j initiated on January 18,'1989, to troubleshoot- the "B" recirculation .i flow _ control valve (KV) circuitry, did not include any references to diagrams, loop calibration reports, or procedures other than general maintenance procedure GMP-0042, " Circuit Testing and Lifted Inads and Jumpers." The troubleshooting activities included replac ment of a "bbdicon unit in panel lH13-P614, B33B-IrlB and gain adjustments on the K.V position and velocity controllers. The b50 was subsequently revised on January 20, 1989, to include references to diagrams, loop calibration reports, a_ vendor manual and related procedures to perform additional troubleshooting activities on the "B" recirculation FCV

. circuitry.

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-B. Failure to Perform Post Maintenance Testing b Criterion XI of Appendix B to 10CPR50 requires that:

"A test program shall be established to assure that all testing required to demonstrate that structures, systisns and canponents will perform satisfactorily in service is identified and perfonned in accordance with written test procedures which- incorporate the

- rquirements and acceptance ' lindts contained in applicable design.

documents. .The test program shall include, as appropriate, proof tests prior to installation, preoperational tests, and operational tests during nuclear power plant or fuel reprocessing plant operation, of structures, systas,. and cmponents. Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrunentation is available and used, and that the test is performed under suitable enviromental conditions.

Test results shall be documented and evaluated to assure that test requirements have been satisfied."

Administrative Procedure ADM-0028, " Maintenance Work Order," Revision 10, paragraph 5.12.26, implements these requirennnts and directs that appropriate post maintenance testing he specified for all canponents that have been reworked, repaired, replaced or modified.

Contrary to the above, a pranpt maintenance work order IW R056226 which authorized replacanent of a " Modicon" card in the ""7 recirculetion flow control valve circuitry on January 18, 1989, did not require a specific post maintenance test. In addition, MO R118514, which at thorized replacment of the solenoid valve on the "B" recirculation hydraulic power unit on the.same day, did not require specific post maintenance test.

REASON FOR THE VIOIATIONS

. A. Failure to provide sufficient maintenance work instructions f40 R056226 was planned, reviewed and approved by Maintenance and Quality Control on January 18, 1989 to troubleshoot and repair as necessary the "B" recirculation FCV circuitly. The Shift Supervisor approved the MO following an in-depth evaluation with the Systm Engineer. Mditionally, the Assistant Plant Manager-Operations was briefed on the MO and the information shown on the scram prevention form or " Red Sheet".

All troubleshooting was performed under the direct supervision of the System Engineer while the hydraulic powr unit DIPU) was locked up.

Each time operations personnel . reset the FCV lockup, the Shift Supervisor was rebriefed by the engineer on what work had been done and l the expected results. Operations personnel maintained canplete control of tne HPU during all modes. Reactor powr and rodline was ,

conservatively reduced during all troubleshooting activities. Although I all. specific 'and necessary work docunents were not identified in the M O package on January 18, 1989, replacment of the Modicon Unit in Page 2 of 6 I

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panel lH13-P614, B338-LC1B, wan performd utilizing the proper drawings, vendor manuals and Icop Calibration Reports (IfRs) . All gain .

adjustmnts were made in accordance with the IfRs which are issued and  !

maintained by engineering and provide design guidance to I&C for setpoints. The ICR and the design setpoint data sheet indicate these settings are to be performd in the field and provide " initial settings only". The System Engineer and Design Engineering. ICR Group had previously worked together on the :aethodology for these circuits and this methodology has been used during other such tuning. For these  ;

reasons, this methodology does not constitute a change to the facility {

as described in 10CFR50.59. )

i Administrative Procedure ADM-0028 Section 6.0 and Attachment 2 " Work i Traveler / Inspection Record" Step 3 states that a job plan for a prcnpt .!

MO should be written and that it cont 2.in the following items as i appropriate; major steps in the-job plan, applicable procedures, .and i applicable engineering drawings. A prmpt 30 was written because the problem with the recirculation flow control valve did not allow timely  :

processing of a MO through normal channela. At the time the MO was written, the troubleshooting and repair were to be performd under the direction of the system engineer and it was not deemed necessary by the j foreman who planned the MO to include references to drawings and i vendor manuals. All activities were perfor.ned at the direction of the i System Engineer and controlled documents were used in the performance of the work even though not specifically addressed in the MO job plan.

l B. Failure to Perform Post Maintenance 'Ibstina ,

After each gain adjustment and/or replacment of any cmponents, the i Shift Supervisor and Operations Control Room crew were rebriefed by the l System Engineer on what work had been performed and the expected J results prior to Operation's personnel resetting the FCV lockup. The j engineer then monitored responses from step changes to the valve as-rutest. Reactivity excursions were guarded against by operable 1 position and velocity trips and position limiter, and a stationed cperator instructed to reset, monitor, and lockup the FCV. Although not documented in the MO package on January 18, 1989, the " Modicon" card was functionally tested with the 'B' FCV maintained in the i locked-up rrode. The functional test for the servo valve, following a f successful preliminary test, was first to place it into service, then to observe the valve's response to operator ccumands. Additionally,  ;

the-. post-maintenance test of the servo valve required the dynamics of an operating loop. All troubleshooting and testing except the final  !

post-maintenance test on the servo valve, was performed with the 'B' FCV in lockup. Reactor power was previously reduced to 60%, applicable '

motion inhibit trips were operational and the operator was carefully briefed'with his finger on the lockup push button prior to the test i evolution.

STP-053-0601, " Recirculation Flow Control Valve Operability Test," was performed satisfactorily and docume".ed oa MO R056226 prior to declaring 'B' Icop operable on January 21, 1989.

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CORidLnVE ACTIONS WHICH HAVE BEEN TAKTN AND THE RESULTS ACHIEVFD RBS managment personnel perforned a couplete evaluation which included the

= following sumaries:.

A -detailed review of the sequence of events as they occurred by the timeclock frm the initial M malfunction and troubleshooting t ectivities until entry into Single Icop Operation.

A safety significance evaluation was performed utilizing the Updated Analysis Report '(USAR) reactivity and core flow limits. This evaluation- included a FCV transient analysis, core flow analysis, loss of coolant accident analysis, and a reactor stability analysis which included a cmparison to the LaSalle Nuclear Power Plant stability event. This evaluation also showed that adequate precautions were taken throughout the event to preclude or mitigate any potential reactivity changes.

Each NRC potential violation and concern identified in the Decmber 4, 1989 Ictter was evaluated. Although no major progranmatic deficiencies were identified, RBS management personnel did recognize several areas of improvements. These areas of improvement are outlined below.

GSU considered detuning of the U system such that maximum allowed average velocity is 1 percent per second open and 4 percent per second closed instead of less than 11 percent per second open and closed. In order to justify slowing down the FCV response, an evaluation would need to be perforned to insure that the M would run-back fast enough to avoid a low level scram on a loss of feed pump event. This has been discussed with General Electric-San Jose. Due to the unlikelihood of the event and the marginal benefits to be obtained, this detuning will not be pursued.

The scram prevention form or "Rdd Sheet" has been revised to require Plant Manager / designee approval of maintenance activities associated with the feedwater or main steam systes which have the potential to affect reactivity. Additionally, any work which could affect reactor core flow ,

would also require Plant Manager / designee approval. This revision will increase management attention to any maintenance activities which have a potential to affect reactivity.

A meno has been issued to maintenance supervisors, foremen, and planners on the _importance of including a job plan in prmpt Maintenance Work orders which includes references to applicable drawings and vendor manuals and which specifies any applicable post maintenance testing.

CORRECTIVE ACTIONS WHICH WILL BE TAKEN 'IO AVOID FURTHER VIOLATIONS

1. Since the recirculation system periodically requires troubleshooting / tuning to be performed on line and may have a direct inpact on reactivity control, GSU is currently developing a procedure which would provide guidelines for futur9 troubleshooting of the recirculation M system. While these guiaolines would provide a Page 4 of 6 o

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reference to all app.11 cable drawings, loop calibration reports, vendor i manuals, and generic troubleshooting activities it would not be possible~ to pInvide step-by-step specific - instructions for every perceived troubleshooting / system _ tuning activity which could- be performed. However, impl m entation of these guidelines would enhance the documentation of applicable reference material and post-maintenance testing requircments associated with KV troubleshooting type MWos.

Troubleshooting for all other systems will be perfonnM in accordance with existing procedures except for the increased managacent attention as described above. l_

2. Training on this event will be provided to the following responsible

-personnel: Operations, Instruttentation and Control (ILC) , Shift Technical Advisors (STAS), Facility Review Conmittee (FRC), Field Engineering and Operations-Quality Assurance (OM) .

I The following corrective actions are not directly related to the deficiencies identifie6 in the notice of violation; however, these improvments were identified during the review and evaluation of the entire event.

1. Administrative Procedure, ADM-0019, was revised to add a requirement for the Condition Report Oversight Group to include in its oversight screening, condition reports which may constitute a potential hazard to nuclear safety for consideration of the Facility Review Cmmittee (FRC) review of CRs.

2. An operating experience review of condition reports will be performed to ensure that the "RBS" Training Department" include applicable CRs'in appropriate lesson plans.

3. GSU has increased Quality Assurance surveillances associated with recirculation system activities.

4. A visual inspection of the recirculation FCV actuator instrumentation will be 'added to every cold shutdown with a drywell entry with a duration greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, until these cmponents demonstrate improved performance.

-5. Both recirculation FCV actuators,. refurbished during the last refuel outage, will be refurbished in alternating future refueling outages.

6. Following resolution of recamendations by operations management personnel, all Ndependent Safety Engineering Group reports containing recmmendations te operations will be reviewed by the Shift Supervisors. ,

7. Recirculation FCV INT /LVEfr connectors will be covered with heat shrink tubing during the upcming mid-cycle outage.

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DATE MIEN FULL COfEIANCE WILL BE ACHIEVFD The procedure for providing guidelines for troubleshooting of the recirculation FLV system will be completed by August 1,1990.

'Ihe majority of the following people have reviewed this event as required reading, however the Training Department will provide additional training on this event according to the following schedule:

Licensed operations personnel during licensed operator requalification program by August 3, 1990 i STAS during STA requalification training by June 29, 1990 FRC and applicable engineering personnel will receive training during the fourth quarter 1990 COA personnel will canplete review of this event as required reading by July 1, 1990 I&C technicians will receive training by July 31, 1990 Page 6 of 6

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