IR 05000458/1989037
| ML20006C109 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/30/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 9002060322 | |
| Download: ML20006C109 (2) | |
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In Reply Refer To:
t-Docket:
50-458/89-37-
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Gulf. States Utilities
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ATTNi James C.'Deddens:
SeniorVicePresident(RBNG)
P.O. Box 220 St. Francisville, Louisiana 70775
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Gentlenen:
.Thank you for your letter of January 12, 1990,- in response ~ to our letter-a and Notice of Violation dated December 1, 1989. We 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 during:a future-(
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inspection to-determine that' full compliance has been achieved and will be F
maintained.
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Sincerely,
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OriginalSigned By:
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Sarnuel J. Collins Samuel 'J.
Collins, Cirector
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l Division of Reactor Projects o
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Gulf States Utilities Company
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ATTN:
J. E. Booker, Manager-
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River Bend Oversight P.O. Box 2951
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Beaumont, TX 77704
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Conner and Wetterhahn ATTil:
Troy B. Conner, Jr., Esq.
1747 Pennsylvania Avenue, NW j
Washington, D.C.
20006
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Gulf States Utilities Company.
ATTN: Les England, Director Nuclear Licensing P.O. Box 220-
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St. Francisville, LA 70775
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PDR ADOCK 05000458 O
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Gulf-States' Utilities-2-
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It Richard M.. Troy, Jr., Esq.
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. Assistant Attorney General in Charge-
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. State of. Louisiana' Department of Justice.
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i 234 Loyola Avenue-(
New Orleans, Louisiana 70112
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Mr.
J.- David McNeill, III William G. Davis,-Esq.
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Department of Justice-Attorney General's Office P.O. Box 94095-
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l Baton Rouge, Louisiana 70804-9095 H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, Louisiana. 70806 President of West Feliciana Police Jury P.O. Box 1921
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St. Francisville, Louisiana 70775
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l Cajun Electric Power Coop. Inc.
ATTH:. Philip G. Harris 10719 Airline Highway -
P.O. Box 15540
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Baton' Rouge,-LA' 70895
Department of. Environmental Quality ATTN: -William H. Spell, Administrator-Nuclear Energy Division
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P.O. Box 14690
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Baton Rouge, Louisiana -70898 (
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U.S; Nuclear Regulatory Commission ATTN: - Resident Inspector P. 0.' Box 1051
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- St. Francisville, Louisiana 70775 U.S. Nuclear-Regulatory Commission
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ATTN:
Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 1000
- Arlington, Texas 76011 bec to DMB (IE01)
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bec distrib. by RIV:
R. D. Martin Resident Inspector
'DRP-Section Chief (DRP/C)
Lisa Shea, RM/ALF MIS System DRSS-FRPS RSTS Operator i
ProjectEngineer-(DRP/C)
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RIV File
.W. Paulson, NRR. Project. Manager (MS:
13-D-18)
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JAN 191990-t
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l January 12,' 1990
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l RBG-32101 File Nos. G9.5, G15.4.1 L
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U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.'C.
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Gentlemen:
River Bend Station - Unit 1-
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' Refer.to: Region IV
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Docket No.' 50-458/89-37
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Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation for NRC Inspection--Report: No,
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y 50-458/89-37.
The inspection was conducted by. Messrs. Ford, Azua, and Jones
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during the period of October 1 - 31, 1989 of' activities authorized -by -NRC-Operating License NPF-47 for River Bend Station Unit 1..
GSU's response to the violation is provided in the attachment and is being submitted. at -this time per agreement with Mr. L. Constable.
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Should you have any questions, please contact Mr.
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A. - England at (504)381-4145.
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Sincerely,
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'J. C. Deddens
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Senior Vice President
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/ C/DET/ch Enclosure cc:
U. S. Nuclear Regulatory Commission
Region IV 611 Ryan Plaza Drive, Suite 1000
- Arlington, TX 76011 Senior Resident Inspector Post Office Box 1051 St. Francisville, LA 70775
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UNITED STATES OF AMERICA NUCLEAR' REGULATORY COMMISSION STATE OF LOUISIANA
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PARISH OF WEST FELICIANA
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i Docxet No. 50-458 I
In the' Matter of'
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GULF STATES-UTILITIES COMPANY-
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(River Bend Station - Unit 1)
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AFFIDAVIT J.
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Deddens, - being duly ~ sworn, states that he is a
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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 belief.
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J. C //ITeddens~ '
Subscribed and sworn to before me, a. Notary Public in 'and t'or the State and. Parish above named', this
/2 day of
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My Commiss' ion expires with Li'fe.
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V 0).OJ. NuAat Claudia F.
Hurst i'
Notary Public in and for West Feliciana Parish, Louisiana
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ATTACMENT
RESPONSE TO NOTICE OF VIOLATION 50-458/8937-01
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LEVEL IV
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REFERENCE Notice of Violation - Letter from S. J. ' Collins to J.
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Deddens, dated December 1, 1989.
FAILURE TO FOLLOW PROCEDURE FOR MODIFICATION OF PERMANENT PLANT EQUIPMENT
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10. CFR. 50, Appendix B, Criterion III and the licensee's Quality Assurance l
Directive QAD-3, " Design Control," require that measures be: established for i
the identification and control of design interfaces and for coordination i
among participating design organizations. These measures shall ; include the
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establishment of procedures among participating design organizations for the j
review,= approval, release, distribution, and revision of documents ' involving
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design interfaces.
Engineering Procedure ENG-03-006, " River Bend Station Design &' Modification i
Request Control Plan," Revision 5, paragraph 6.12.5 requires that maintenance
use the transmitted copy of the prompt modification request (PMR) for i
generation of the maintenance work orders (MW0s) necessary to implement the PMR.
Contrary to the above, on September 16, 1989, modifications were made to Power Line Conditioner 1RPS*XRC10B1, which included rerouting conduit and the pull and termination of electrical cable prior to review and approval of PMR-89-0025.
PMR 89-0025 provided the instructions to reroute 120 VAC secondary conductors-~ from 1RBS*XRC1081 -to the-instrument panel previously supplied by failed power line condition 1SCM*XRC1481. The work activity was performed utilizing MWO R056460, which was originated for troubleshooting the
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failed power line conditioner. MWO R056460 was later utilized to. implement the PMR.
REASON FOR THE VIOLATION The events described in the violation occurred on a weekend under'the direction of the assigned Design Engineering Duty Supervisor.
The condition investigated through a debriefing with the Duty Supervisor the following was Monday.
The supervisor gave verbal authorization to reroute conduit and pull and terminate cable prior to the field work release of PMR 89-0025. The Duty Supervisor's decision was influenced by the urgency of the situation, i.e., a half isolation condition, 8-hour LCO, and risk of spurious main steam isolation involving a challenge to safety systems.
The authorization is
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contrary 'to the requirements of ENG-3-006, which describes a sequence of actions in which the.PMR is required to be ' field work released'
prior to generation of the Maintenance Work Order.
Thus, the Duty Supervisor authorized a deviation from the sequence of steps prescribed in the procedure, but did not authorize any procedure requirement to be omitted.
The work was performed under an MWO with Engineering and Maintenance Page 1 of 3
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su'pervisors and QC personnel present. The engineering supervisor was present
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when the decision to perform the work was made and was satisfied -that-no unreviewed_ safety question existed due to the nature of the work and the
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previous declaration of the component as inoperable.
Prior to the verbal authorization of field work, engineers knowledgeable in'.
cable and conduit routing, conduit support, electrical design, engineering
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analysis, and equipment qualification were summoned to the site, and developed the proposed design. The development included hands-on walkdowns
.i and eyes-on inspection of the proposed installation. An expedited parallel effort was initiated to complete the documentation, approval, and Facility Review Committee review of the modification prior to completion' of field work. The actions taken minimized the time period during which the plant was.
exposed to a spurious isolation and shutdown, and there was no effect on plant or public safety.
Based on additional review by management, it was determined that, while the-
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technical guidance given to Operations and Maintenance prior to issuance o f --
f the PMR was appropriate, ENG-3-006 did not provide adequate guidance for the
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situation and the use of verbal authorization. prior to issuance of the PMR was not appropriate.
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The root cause is therefore considered to be procedure violation.
The supervisors on duty for Maintenance, Operations, and Engineering failed. to recognize the bounds of the governing procedures.
Consequently, some work
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was performed which should have taken place under an approved modification l
request.
Additionally the existing procedural guidance was not considered'
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adequate to exercise proper controls to disallow modifications to the-plant under the MWO procedure, ADM-0028.
With regard to procedural compliance in general, a number of-instances of noncompliance have been identified by River Bend Station (RBS) personnel via the Condition Report program and other programs.
CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED After identification by a QA supervisor that the activities appeared to be outside the scope of procedures, work was voluntarily stopped =on' the modification.
Work resumed following the issuance of the PMR in accordance
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with existing procedures.
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In order to reduce procedural noncompliance, the Senior. Vice President _ has issued to all RBS managers a -memo instru'cting.them to're-review this.
Inspection Report, particularly noting the NRC comments in the cover letter pertaining to procedural compliance.
The managers were further instructed to hold meetings with management personnel down to the supervisor / foreman level, stressing the importance of procedural compliance and the necessity to' reduce
the incidence of noncompliance.
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CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS ADM-0028 was revised to specifically state l that field work intended for
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implementation of a modification may not occur until authorized by ENG-3-006.
ENG-3-006 was revised to provide a mechanism for Engineering to evaluate and authorize field work parallel-to the development of the modification request.
Personnel in Maintenance, Operations -and, Engineering, and QA who are
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involved in the review,-approval, and implementation of modifications will be
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trained to the changes in the procedures.
It will also be-emphasized in the-
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training sessions that personnel are required to follow procedural requirements without deviation.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i
i ENG-3-006 and ADM-0028 were revised December 20, 1989 and November 3,
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respectively. Training will be completed by February 15, 1990.
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The Senior Vice President issued the memo to the managers on January 9, 1990, l
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