IR 05000458/1985066

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Ack Receipt of 851213 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/85-66
ML20205P178
Person / Time
Site: River Bend Entergy icon.png
Issue date: 05/15/1986
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: William Cahill
GULF STATES UTILITIES CO.
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ML20205P181 List:
References
NUDOCS 8605210222
Download: ML20205P178 (1)
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In Reply Refer To: MAY 151996 Docket: 50-458/85-66 Gulf States Utilities ATTN: William J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group P. O. Box 2951 Beaumont, Texas _77704 Gentlemen:

Thank you for your letters, dated December 13,1985, and March 5, 1986, in response to our . letters, dated November 14, 1985, and January 27, 1986. We have no further questions at this time and will review your c'orrective action during a future inspection.

Sincerely, Origiral Signed By Ramon E. Ha 1 James E. Gagliardo, Chief Reactor Project Branch cc:

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

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e GULF STATES UTILITIES COMPANY RIVER BEND STAT'ON POST OFFICE BOX 220 ST FRANCISVILLE LOUISIANA 70775 ARE A CODE 504 635 6094 346 8651 December 13, 1985 RBG- 22,814 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator g U.S. Nuclear Regulatory Commission }gg a Region IV  : !j 611 Ryan Plaza Drive, Suite 1000 '

Arlington, Texas 76011 DEC231985 1 i

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Dear Mr. Martin:

. . I'$I River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 85-66 This letter is in response to the Notice of Violation contained in NRC I&E Inspection Report No. 50-458/85-66. The inspection was performed by Mr. W. R. Bennett during the period September 30 through October 4, 1985, of activities authorized by NRC Operating License NPF-40 for River Bend Station Unit No. 1.

Gulf States Utilities Company's (GSU) response to the Notice of Violation 85-66-01, is provided in the enclosed attachment.

. This completes GSU's response to the Notice of Violation.

Sincerel ,

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. C. Deddens

Vice President

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River Bend Nuclear Group i

JCD/TCC/PDG/RJK/amg I

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UNITED STATES OF ABERICA NUCLEAR REGUIATORY C(BetISSION STATE OF IAUISIANA $

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FARISH OF WEST FELICIANA $

In the Matter of I Docket Bos. 50-458

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CULF STATES UTILITIES C(BIPANY l (River Bend Station, Unit 1)

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AFFIDAVIT

J. C. Deddens, being duly sworn, states that he is a 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 Consnission

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the documents attached heretos and that all such documents are true and correct to the best of his knowledge, information and belief.

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J. M. Deddens

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Subscribed and sworn to before me, a Notary Public in and for the

State and Parish above named, this day of 60#/VI

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s tw 1 4 Y an W. Middlebrookh otary Public in and for West Feliciana Parish, Louisiana My Commission is for Life.

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ATTACHMENT December 13, 1985 RBG- 22,814 Response to Notice of Violations Severity Level IV Reference '

Notice of Violation -

L. to W. J. Cahill, Jr. dated November 14, 1985.

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Refer to Docket No. 50-458/85-66.

A. Failure to Update Procedures After Issuance of Three TCN's Reason for Violation Eight system operating procedures (SOP-2, -16, -18, ~41, -42,

-48, -53 & -90) had more than three TCNs, which required a permanent procedure change, outstanding.

Corrective Steps Taken and Results Achieved As a result of extensive testing and operations activities during the startup and power ascension program, certain procedures required more than three Temporary Change Notice (TCN's) in order to successfully implement the procedure.

Procedural compliance was stressed during this period, therefore, management encouraged the use of TCN's to make the i procedure correct prior to implementation. Realizing that the quantity of TCN's outstanding against a procedure may be greater than the administrative limit of 3, Revision 7 to t

ADM-0003 was processed 09/10/85 to allow more than 3 TCN's

! A during the first implementation phase of the procedure. The l number of TCN's written however, precluded timely l incorporation.

During the first week of October, 1985, the Operations l

Supervisor assigned additional personnel the task of

incorporating TCN's into permanent revisions of Operations I procedures when the number of TCN's reached three. TCN's l have been incorporated into permanent SOP revisions as shown below

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Page 2 December 13, 1985 RBG- 22,814 SOP-0002 Revision 2 issued 11/25/85 SOP-0016 Revision 1 issued 10/21/85 SOP-0018 Revision 1 in review cycle; expect approval by 12/14/8C SOP-0041 Revision 1 issued 10/08/85 ,

SOP-0042 Revision 1 issued 10/08/85 SOP-0048 Revision 1 issued 11/12/85

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SOP-0053 Revision 3 issued 10/29/85 SOP-0090 Revision 2 issued 10/14/85 Corrective Steps Taken to Avoid Further Violations

'The Operations department is performing independent TCN status checks and marking up file copies of procedures as TCF's are issued. Operations previously relied upon a memo (from the Plant Services Department) which indicated that three TCN's were initiated against a specific procedure. GSU is currently incorporating outstanding TCN's into all proce6"tes and plant management has placed emphasis on TCN

, incorposciton Operations currently has all operating procedures with three or more TCN's outstanding in review for their incorporation. Other operations support procedures are also being reviewed for incorporation of TCN's.

Date When Full Compliance Will Be Achieved

All procedures with more than three TCN's against them will

be revised to incorporate thora, JNs by January 31, 1986.

B. Failure to Properly Prepare TCN Reason for Violation TCN's were issued to SOP-35,-42,-48 and -49 which did not incorporate previously approved TCN's to those procedures.

This resulted in two different approved changes to the same pages.

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Page 3 December 13, 1985 RBG- 22,814 Corrective Steps Taken and Results Achieved The inspector has noted ADM-0003 requirements concerning the preparation of TCN's to require that TCN's be made to the latest approved change to the affected procedure. River Bend Staff personnel interpret the statement from ADM-0003 (Development, Control, and Use of Procedures), Revision 7 (...that TCN's be made to the latest approved change to the affected procedure...), to mean that the marked up pages of the TCN must originate from the affected procedure of the most current revision on file in the Central Information

, Center (CIRC). The above process parallels the design change process regarding the use of E&DCR's against the latest approved drawing revision.

As a result of the NRC Inspection, the effectiveness of the current TCN program is being evaluated by Plant Staff and ADM-0003 will be revised as necessary.

' Corrective Steps Taken to Avoid Further Violations See above.

Date When Full Compliance Will Be Achieved

Any revisions to ADM-0003 determined to be necessary will be completed by January 31, 1986.

C. Change and Issuance of TCN after Final Approval Reason for Violation A

TCN 85-1550 to SOP-0035 was changed and issued after final approval of the TCN.

Corrective Steps Taken and Results Acnieved Investigation into this matter revealed that on 8/15/85, TCN 85-1550 was routinely transmitted without two pages of the original "as-apprcved" TCN. This resulted from a clerical error. The two pages deleted from the distribution were written on Comment Control Forms (CCF's). The clerk thought this to be a mistake and directed the CCF's to the appropriate procedure file. This error went unnoticed until the TCN was to be incorporated into the proposed procedure revision (SOP-0035). At that time (10/04/85), the CCF's were added to the original TCN and the TCN was retransmitted to bring the document back to its originally approved status.

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. December 13, 1985 RBG- 22,814 The document handling clerks have been instructed by their supervisors to perform closer checks of all TCN's which they handle. Specifically, the Operations Shift Clerks verify that the TCN is made to the latest revision of the applicable procedure and that all pages are attached and identified correctly. If any changes are necessary, then they are performed prior to the TCN working copy being issued to the individual.

Corrective Steps Taken to Avoid Further Violations

. In addition to the above corrective action, ADM-0003 will be reviewed and revised as necessary to clarify the TCN process.

Date When Full Compliance Will Be Achieved Full compliance (for the transmittal error) was achieved on 10/04/85. Any revisions determined to be necessary to ADM-0003 will be completed by January 31, 1986.

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