ML20006B226
| ML20006B226 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/22/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 9002010124 | |
| Download: ML20006B226 (3) | |
See also: IR 05000458/1989011
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JAN 222-
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. In Reply Refer To:
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Docket:- 50-458/89-11
Gulf States Utilities
ATTN: James C. Deddens-
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Senior Vice President (RBNG).
P.O. Box 220
St. Francisville, Louisiana 70775
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Gentlemen:
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Thank you for your letter of December 15, 1989, supplementing your
previous response to our letter and Notice of Violation dated May 31, 1989. We
have reviewed your supplementary reply and find it responsive to the concerns
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raised in our Notice of Violation. We will review the implementation of your
corrective actions, described-in the July 7,1989, and December 15,.1989
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letters, during a future inspection to determine that full compliance has-been
achieved and will'be maintained.
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Sincerely,
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ORIGINAL SIGNED BY
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SAMUEL J. COLLINS
Samuel J. Collins, Director
Division of Reactor: Projects-
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Gulf States Utilities Company.
ATTN:
J. E. Booker, Manager-
,
River Bend Oversight
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P.O. Box 2951
Beaumont, TX- 77704
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Conner and Wetterhahn
ATTN: Troy B. Conner, Jr. .. Esq.
1747 Pennsylvania. Avenue, NW
Washington, D.C.
20006
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9002010124 900122
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ADOCK 05000458
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Gulf States Utilities
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Gulf States Utilities Company
ATTN:. Les England, Director
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Nuclear Licensing
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'P.O.-Box 220
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St. Francisville, LA 70775
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Richard M. Troy, Jr., Esq
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Assistant Attorney General in Charge
State of Louisiana. Department of Justice
234 Loyola Avenue-
New Orleans Louisiana 70112
Mr. J. David McNeill . III
William G. Davis, Esq.
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Department of Justice
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Attorney General's Office
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P.O. Box 94095
Baton Rouge, Louisiana- 70804-9095
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H. Anne P1ettinger
3456 Villa Rose Drive
Baton Rouge, Louisiana 70806
President of West Feliciana
Police' Jury
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P.O.-Box 1921
St. Francisv111e, Louisiana 70775
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Cajun Electric Power Coop. Inc.
ATTN:
Philip G. Harris
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10719 Airline Highway
P.O. Box 15540
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Baton Rouge, LA 70895
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Department of Environmental Quality
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ATTN: William H. Spell, Administrator
Nuclear Energy Division
P.O. Box 14690
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Baton Rouge, Louisiana 70898
U.S. Nuclear Regulatory Commission
ATTN:-- Resident Inspector
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P. O. Box 1051
St. Francisv111e, Louisiana 70775
U.S. Nuclear Regulatory Commission
. ATTN: Regional-Administrator, Region IV
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611 Ryan Plaza Drive, Suite 1000
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. Arlington Texas 76011
bectoDMB(IE01)
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Gulf-States Utilities'
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bcc distrib. by RIV:
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R. D. Martin
Resident Inspector .
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DRP-
SectionChief(DRP/C)
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Lisa Shea .RM/ALF
MIS System
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DRSS-FRPS-
RSTS Operator
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Project Engineer (DRP/C)
RIV File
W. Paulson, NRR Project Manager (MS:
13-D-18)
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GULF STATES
UTELETIES COMPANY
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DEC 1: 9 1989 1 (
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-December 15, 1989
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RBG- 31946
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File Nos. G9.5, G15.4.1
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U.S. Nuclear Regulatory Commission
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Document Control Desk
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Washington, D.C. 20555
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Gentlemen:
River Bend Station - Unit 1
Refer to:
Region IV
Docket No.-50-458/ Report 89-11
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Pursuant
to
10CFR2.201, this letter provides Gulf States
Utilities Company's -(GSU) supplemental response to the Notice of
Violation contained in NRC Inspection Report No. 50-458/89-11.
This inspection was conducted by Messrs. E. J.
Ford and
W.
B.
Jones during the period of March.15 through April 30, 1989 of
activities authorized by NRC Operating License NPF-47 for River
Bend Station - Unit 1.
GSU's response to the Notice of Violation
is attached.
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Should you have any questions, please contact Mr. L.
A.
England
at (504) 381-4145.
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Sincerely,
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J. C. Deddens
Senior Vice President-
River Bend Nuclear Group-
JEB/L4E/TFP/(
M W Q pg.
1GW/DNL/MSF/
Attachmen
cc-
.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
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STATE OF LOUISIANA-
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PARISH OF WEST FELICIANA
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In the Matter of
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Docket No. 50-458
50-459
GULF STATES UTILITIES COMPANY
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(River Bend Station,
Unit 1)
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J. C. 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
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belief.
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J. !. Deddens
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Subscribed
and
sworn
to before me, a Notary.Public in
and for the State and Parish above named,-this-
h b day of
be*0PfTO2r
, 19 h .
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A
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oan W. MiddieBrdoks
Notary Public in and for
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West Feliciana Parish,
My Commission is for Life.
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ATTAC K NT'
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Supplemental Response to Notice of Violation 50-458/8911-01A
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REFERENCE
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Notice of Violation - Letter from L.J. Callan to J.C. Deddens, dated May
31, 1989.
Response to Notice of Violation - Letter from
J.C.
Deddens to Document
Control Desk, dated July 7, 1989.
VIOLATION
Criterion XVI of Appendix B to 10CFR Part 50 requires that measures be
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established to assure that conditions adverse to . quality are promptly:
identified and corrected.
Quality Assurance Directive (QAD)-16,
" Corrective Action," Section 4.3,
states that procedures shall require that corrective- action be promptly
initiated and adequately documented by the responsible department to
correct the condition and to determine if action is necessary to preclude
its recurrence.
River Bend Nuclear Procedure (RBNP)-0047,
" Corrective Action Program,"
Section 5.4, requires that corrective action be promptly initiated and
adequately
documented by the responsible department to correct the
condition and to determine if action is necessary to preclude its
recurrence.
Contrary to the above,
adequate corrective actions were not.taken to
prevent repeat violations
of
Administrative
Procedure
(ADM)-0027,
" Protective Tagging."
During the period of March 18 through April 12,
1989, the licensee identified eleven procedural
violations of ADM-0027.
The . corrective actions taken did not determine the ' extent to which
protective tagging program violations existed.
REASON FOR VIOLATION
GSU has reviewed the associated protective tagging program condition
reports (CR) stated in
Inspection Report .89-11 'and other related CRs
initiated during the second refueling outage (RF2).
GSU has reviewed the
chronology presented in the Inspection. Report and finds it accurate. The
various problems identified from our review of CRs can be categorized. into
four major areas:
1.
Individuals working without a clearance or a wrong clearance,
2.
Tagging boundaries were vio!ated,
3.
Clearances were released without work being finished, or
4.
Crews began work on the wrong train.
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$e'vsral
root
causes have been identified from GSU's review.
The
. ' contributing causes were attributed to
poor
communication
between
contractor
work
crews
and
their
supervisors, contract personnel
unfamiliarity with RB3 plant design, and' failure of contract personnel
to
take adequate precautions to follow details in RBS procedure ADM-0027,
" Protective Tagging". GSU determined the primary cause was inadequate-
training of contract personnel to ADM-0027 requirements.
In addition, the
retraining provided as a corrective action was not adequate to preclude
future occurrences.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED
Numerous corrective act?ons were taken for each RF2 CR related to
protective tagging. GSU took additional
actions after recognizing that
previous corrective actions had not been adequate to prevent recurrence of
additional tagging violations.
Immediate corrective actions. included:
1) Contract personnel
responsible for the tagging
violations
were
retrained,
2) Tagging procedure (ADM-0027) was revised,
3) Additional " tool box" and formal classroom training was conducted,
4)
Individuals
involved in violations were removed from the " Authorized
Requestor" list,
5) GSU personnel were assigned to oversee and
co-sign
contractor
clearances,
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6) A 100% review of open supplemental clearances and partial releases was
completed,
7) GSU discontinued the use of supplemental clearances for RF2,
8) Operations Quality Assurance surveillances were increased for- safety
and non-safety related work activities for review of work-documentation
and tagging, and
9) Tagging officials were retrained and instructed to give
closer
attention to details prior to resuming duties.
The
root causes mainly focused' around contractor ~ personnel. events;
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therefore, GSU believes the program implemented -by GSU- personnel
is
satisfactory.
Supplemental clearances have been reinstituted, post outage,
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since the contractors involved are no longer performing work on site.
Contractors will
not be allowed as holders of clearances under ADM-0027
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pending completion of task force review activities.
CRs are sent to a wide distribution, including but not limited to-Quality
Assurance, Licensing, and the Independent Safety Engineering Group (ISEG).
CRs are now reviewed and trended daily in accordance with a new procedure,
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RBNP-0052,'! River Bend Station Trending Program", to determine adverse
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trends.
The recently developed and approved trending program is designed
to detect long term trends.
RBNP-0052 recommends that trend reports be
issued at six month frequencies.
Short term trends are
generally
discovered through the various CR reviews and periodic trend' reports issued
to RBS management (typically every month).
RBNP-0022, " Root Cause Analysis Program" was issued on September 19,
1989,
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to standardize root cause analysis based on INP0 Good Practice OE-907,
" Root Cause Analysis".
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A ' critique for lessons learned during RF2 was completed by Outage
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' Management and a task force was formed to identify particular problems with
the tagging program. A number of recommendations for the
improvement of
the tagging program were identified.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUTURE VIOLATIONS
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Training will
be provided to all licensee personnel required to provide
root cause analysis for responses to condition reports (CR).
QA personnel
will also receive this training as it is QA's responsibility to review CRs
and other nonconformance documents.
The following corrective actions were identified in the RF2 critique and by
the task force formed to review the existing tagging program:
1.
Revise ADM-0027 to:
a.
Follow the format of INP0 Good Practice OP-203, which logically-
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presents clearance requirements and necessary actions,
b.
Have consistent clearance program "tenns and definitions".
c.
Clarify responsibilities of
the
Assistant
Plant
Managers,
departmental
supervisors, authorized Tag Order Requestors, tagging
officials, Shift Supervisors, Control Operating Foremen, designated
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operators
and
Maintenance Training Coordinator as they are
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applicable to the tagging program.
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d.
Allow supplemental clearance release on a partial basis by signing
a partial release form.
2.
Allow only GSU employees trained on ADM-0027 to hold clearances during
RF3.
However, contract employees brought
on-site
who
receive
docenented
training.
including
on-the-job
experience with the
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protective tagging system under the supervision of a qualified Tag
Order Requestor, and demonstrate the necessary level
of skill to
successfully implement the tagging program may be allowed to hold
clearances.
This requirement will be re-evaluated for future outages.
3.
Computerize the clearance program to reduce the administrative burden
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on
operations
and
to
increase
productivity
of'
the
maintenance / contractor work force.
Operations, Computer Systems and
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Projects will coordinate the development of.the computerized system.
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These actions are currently being planned and implemented by GSU.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
1.
Root Cause Analysis training will be completed by May 1, 1990.
2.
ADM-0027, Revision 8, was submitted for review on November 9, 1989,
and will be approved by April 1,1990.
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Training on ADM-0027 Revision 8, will be completed within 30 days
of the issuance of the procedure.-
4.
Implementation of the new computerized tagging system will be
achieved by June 30, 1990,
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