IR 05000458/1993015

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/93-15 on 930510-14
ML20046D251
Person / Time
Site: River Bend Entergy icon.png
Issue date: 08/09/1993
From: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Graham P
GULF STATES UTILITIES CO.
References
NUDOCS 9308170118
Download: ML20046D251 (4)


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Docket:

50-458 License: NPF-47 Gulf States Utilities ATTH:

P. D. Graham Vice President (RBNG)

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

RESPONSE TO NRC INSPECTION REPORT 50-458/93-15 Thank you for your letter dated June 25, 1993, in response to the emergency preparedness findings identified in NRC Inspection Report 50-458/93-15 dated May 28, 1993.

Inspection Followup Item 458/9315-01 concerned your recent organizational changes affecting the Quality Assurance and Emergency

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Preparedness organizations. This issue is currently being reviewed by the Office of Nuclear Reactor Regulation.

We will provide you with the results of this review when it is completed.

With respect to Emergency Preparedness Weakness 458/9315-02. we have examined your reply and find it responsive to the concerns raised in our inspection report. We will review the implementation of your corrective actions during a future inspection.

Should you have any questions concerning this letter, please contact Dr. D. Blair Spitzberg of my staff at (817) 860-8191.

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jg L. J Callan, Director

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i Gulf States Utilities ATTN:

J. E. Booker, Manager-Safety Assessment /0uality Verification P.O. Box 2951 Beaumont, Texas 77704 i

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'.i ATTN:. Mark J.'Wetterhahn, Esq.

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ATTN:

Les England, Direc' tor t

Nuclear Licensing

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P.O.' Box 220

St. Francisville, Louisiana 70775 j

l Mr. J. David McNeill, III

.3 William G. Davis, Esq.

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Department of Justice

Attorney General's Office

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P.O. Box 94095

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Baton Rouge, Louisiana 70804-9095

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H. Anne Plettinger

3456 Villa Rose Drive

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Cajun Electric Power Coop. Inc.

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Philip G. Harris 10719 Airline Highway

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Chief, Technological Hazards Branch

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RBEXEC-93-306 Regional Administrator U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Gentlemen:

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River Bend Statica - Unit 1 Docket No. 50-458/ inspection Reoort 93-15 This letter provides Gulf States Utilities Company's (GSU) response to inspection follow-up item 9315-01 concerning independent audits of the emergency preparedness program and weakness 9315-02 concerning the execution of messages using. the emergency, state and parish notification system.

The attachments describe GSU's corrective actions regarding the inspection follow-up item and weakness observed _duriog the inspection conducted by Dr. D.B. Spitzberg and Mr. Jack M. Keeton en May 10-14,1993.

Should you have any questions, please contact Mr. David N. Lorfing at 504/381-4157.

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Sincerely, P49st

P. D, Graham cc:

NRC Resident Inspector

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P.O. Box 1051

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St. Francisville, La 700775 i

U.S. Nuclear Regulatory Commission n o n c~ A l i E

Document Control Desk hv b~t # J U l O d Washingtop, D.C. 20555

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Attachment 1 I

Response to Inspection Follow up Item 458/9315-01 River Bend Station Gulf States Ut'.!!tles Company

. REFERENCE letter from LJ. Callan to P.D. Graham dated May 28,1993 INSPECTION FOLLOW UP ITEM About a month prior to the inspection, an upper-level reorganization was implemented in l

the licensee's organization. Among the changes made to the facility organization were two changes effecting emergency preparedness. The emergency planning organization was placed under a newly titled Manager of Safety Assessment and Quality Verification. This manager reported to the vice president. Previously, emergency planning reported to the General Manager, a position which was eliminated with the reorganization. The second change effecting emergency preparedness involved the Ouality Assurance organization which is responsible for performing independent audits of emergency preparedness as required by 10 CFR 50.54(t). With the reorganization, the Quality Assurance organization was placed under the Manager of Safety Assessment and Quality Verification. The inspectors expressed concern to licensee representatives as to whether the Quality Assurance organization under the new organization struaure would have sufficient independence in conducting audits of emergency preparedness to meet the requirements of 10 CFR 50.54(t). Since no audits of emergency preparedness had been conducted since the reorgamzation, the inspectors found no information with which to evaluate this concern. This issue will be reviewed during a future inspection as Inspection Follow-up Item (458/9315-01).

_ GULF STATES UTILITIES COMPANY'S RESPONSE

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The GSU Quality Assurance (OA) Department is sufficiently removed from the Emergency Planning (EP) Department by organization and practice to ensure independent performance of QA audits. The OA Department is headed by the Director - OA, who reports to the Manager, Safety Assessment and Quality Verification (SA/OV). The Director - QA also has direct access, as needed, to the Vice President - RBNG on matters of quality. The QA audit process is organized and conducted by the QA organization. A lead auditor is assigned by the QA Supervisor to organize and plan each audit including audit scope, checklists, scheduling, etc. The OA Supervisor is responsibk for reviewing / approving individual audit pans, prepared audit checklists, audit reports, completed audited checklist, and audit findings. An audit team, which usually includes an outside, independent technical expert, is organized by the lead auditor with input from his supervisor. The audit is then conducted by the audit team. Audit results are presented by the lead auditor and team members at an exit meeting. The Manager - SA/OV attends this exit meeting. This is the first time in the audit process that the Manager - SA/OV is involved. The audit report and any audit findings (quality condition reports) are then prepared by the lead auditor and approved bf the OA Supervisor. The Director - OA reviews the audit report and any

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findings, and signs the audit report cover sheet, While the Director - QA does report to the Manager - SA/QV, the audit process itself is independent of th Manager - SA/OV. The Manager - SA/QV is not involved in the organintion, planning, conduct, or reporting of QA audits. Thus, the requirement to audit the emergency preparedness program by an independent group is met.

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' Attachment 2 Response te Weakness 4$8/9315 02 River Bend Station Gulf States Utilities Company REFERENCE Letter from LJ. Callan to P.D. Graham dated May 28,1993 WEAKNESS The inspectors conducted a series oi~ emergency response walkthroughs with the operating crews to evaluate tne adequacy and retention of skills obtained from the emergency response training program. A single walkthrough scenario was developed by the inspectors and administered to the crews to determine whether control room personnel were proficient in their duties and responsibilities during a simulated accident scenario. During the walkthroughs, notificadens were made promptly. However, in observing the Emergency, State, and Parish System notification process, certain weaknesses were noted.

Short form notification messages transmitted of the General Emergency did not indicate the Protective Actfon Recommendations issued by the recovery

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manager.

The inspectors observed that Protective Action Recommendatiorn and been properly entered into the message as it appeared on t'ie Emergency, State, and Parish System monitor, but this information wa s r

'f 'he message transmitted.

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When one crew's u.~.acdo. sntered the Emergency, State, and Parish System computer command to gain control of the Emergency, State, and Parish System notification system for the purpose of making the Notification of Unusual Event (Notification of Unusual Event) notification, control was electronically denied by the computer system with the message

"TSC denied control access." Because of this, the communicator was unable to use the Emergency, State, and Parish System notification system to make the initial Notification of Unusual Event notifications.

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e During one ALERT notification, a communicator entered the required information into the Emergency, State, and Parish System on the short notification form for transmittal. When the transmit command was executed, the Emergency, State, and Parish System transmitted the long form message instead of the intended short form message. The long form

had not appeared on the Emergency, State, and Parish System monitor nor had the communicator worked with the long form during the ALERT notification sequence. In addition, the long form transmitted indicated conflicting information regarding whether the reactor was shut down.

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The Emergency, State, and Parish System notification system demonstrated an internal'elock problem which prompted a "next message due in 6 minutes" message on the monitor 24 minutes before the next message was actually due.

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i GULF STATES UTILITIES COMPANY'S RF5tPONSE

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Condition Report (CR) 93-0270 was written to document and investigate the identified weakness. Corrective actions taken are described below.

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The weakness - concerning the Protective Action Recommendations

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(scenario number) not printing on the notification message form after i

being correctly entered on the input form has been corrected with a software modification. This change has been installed in the production

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system and tested.

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111e problem encountered when a station was denied transmission control

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has been thoroughly researched and software modifications to correct it are being designed. During the investigation, logical sequences other than that i

documented in the response to CR 93-0270 that could also cause this problem were identified in the program. The final solution will address all

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identified software problems. A subset of these changes which correct the

"most likely to occur" situations (including the specific problem experienced

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production system. Final solutions are scheduled for installation and

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integration testing on the production system by July 31,1993.

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i The error that caused a wrong format form print (long format when short j

was requested) has been identified and a software change eliminating the l

problem has been designed. A partial solution, specifically addressing :he

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problem that occurred on May 12,1993 has been installed and functionally

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tested. The final solution will be installed by July 31,1993.

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Software changes to eliminate clock / timer problems that were experienced

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have been functionally tested and installed in the production system.

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The production system as currently installed is functional. Until Snal corrective actions for

the identified problems can be completed, the notification system is being maintained in a known state which minimizes the chance of a serious operational problem during the nor sequence of emergency facility activation.

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