ML20053C806

Responds to NRC 820204,08 & 0304 Ltrs Re Violations Noted in IE Insp Repts 50-458/81-10,50-458/81-11 & 50-458/82-01. Corrective Actions:Time Period for Performing Reportability Reviews Reduced from 8 Working Days to 3 Working Days

ML20053C806
Person / Time
Site:	River Bend
Issue date:	03/18/1982
From:	William Cahill GULF STATES UTILITIES CO.
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20053C799	List: ML20053C803 ML20053C806
References
RBG-12310, NUDOCS 8206020578
Download: ML20053C806 (6)

Text

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J GULF STATES UTILITIES COMPANY @

POST OFFICE BOX 2951 *DEAUMONT, TEXAS 77704 AREA CODE 713 838 6631 March 18, 1982 RBG-12310 File G9.5, G15.4.1 i

Mr. John T. Collins, Regional administrator U. S. Nuclear Regulatory' Commission Region IV, Office of Inspection & Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Dear Mr. Collins:

River Bend Station-Unit 1 Refer To: Docket 50-458/81-10 Docket 50-458/81-11 Docket 50-458/82-01 Gulf States Utilities (GSU) is providing this letter and its attachments in response to Mr. G. L. Madsen's letters of February 4, 1982, February 8, 1982, and March 4, 1982.

Attachment i responds to the February 4 and 8 letters that requested additional information concerning Inspection Reports 81-10 and 81-11. This Attachment addresses the overall River Bend program for notifying the Region IV Office of potentially reportable and 10CFR50.55(e) reportable deficiencies.

Attachment 2 responds to the Notice of Violation transmitted to GSU in the March 4 letter.

Sincerely,

^

W. J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group Attachments

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA 1 PARIS 110F WEST FELICIANA I In the Matter of I Docket.Nos. 50-458 50-459

, GULF STATES UTILITIES COMPANY I (River Bend Station, Units 1 & 2)

AFFIDAVIT W. J. Cahill, Jr., 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 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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W. J # 1hill, Jr.

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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /8 ay of 19_ M in2hNL!Elab otary Public'in dhd for West Feliciana Parish, Louisiana hy Commission is for Life.

ATTACHMENT I

REFERENCE:

A. Request for Additional Information - Madsen letter dated February 4, 1982 Reis,  : Docket 50-458/81-11 B. Request for Additional Information - Madsen letter dated February 8, 1982 Refer To: Docket 50-458/81-10

RESPONSE

Gulf States Utilities' (GSU) program for review of deficiencies for reportability is embodied in River Bend Project Procedure (RBPP) 1.7 Revision 3 dated February 10, 1981. Employee orientation to this procedure is included in the GSU training program and each GSU River Bend Nuclear Group (RBNG) employee must attend. Additional training sessions are held as needed, as was the case for the RBNG sito personnel on February 9, 1982.

RBPP 1.7 Revision 3 was written to take into account the reporting requirements of Title 10 Code of Federal Regulations Paragraph 50.55(e) (10CFR50.55(e)) and the NRC Region IV Office of Inspection and Enforcement desires for early notification as was discussed by GSU (Cahill) and the NRC (Madsen) on February 8, 1982. This procedure places time ccnstraints on the GSU review for reportability. These time constraints are as follows:

a) for reviews of reportability that have been initiated by GSU, GSU will take no longer than three working days to disposition, or b) for reviews of reportability that have completed the Stone and Webster (S&W) or General Electric (GE) procedures, GSU will take no longer than one working day to disposition.

The " disposition" referred to above means that GSU will take one of the following three actions within the time frame indicated: 1) notify the Region IV Office of a reportable deficiency, 2) notify the Region IV Office of a potentially reportable deficiency, or 3) determine the deficiency is not reportable.

If at any time during the review of potentially reportable deficiencies GSU determines that the deficiency meets the reporting requirements of 10CFR50.55(e), GSU will notify the NRC Region IV Office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> por 10CFR50.55(e)(2).

As was indicated above, S&W and GE have procedures that they follow for reviewing deficiencies for reportability. Their review processes may require extended engineering evaluations and may take several weeks or months to complete. On River Bend Project, S&W uses Quality Standard 16.2 Revision A and River Bend Procedure 10.5 Revision 1 for initiating reviews for reportability and prompt notification to GSU. For its reportability review, GE utilizes Nuclear Energy Business Group Procedure (NEEG) 70-42. GE discussed

its reporting procedure with Mr. Sniezek (NRC) in a meeting on December 10, 1981. GE has indicated to GSU that from this meeting, the NRC fools that the GE reportability procedure is sufficient for the construction permit holder's needs and that an IE Information Notice will be forthcoming from the NRC.

GSU believes the procedures established above are responsive to both the 10CFR50.55(e) reporting requirements and the NRC Region IV Of fice's desires to be informed of potentially reportable deficiencies.

A'ITACHMENT 2

REFERENCE:

Notice of Violation - Madsen letter dated March 4, 1982 Refer To: Docket 50-458/82-01

" Failure to Provide Timely Notification of a Construction Deficiency"

RESPONSE

Title 10 Code of Federal Regulations Paragraph 50.55(e) places the responsibility on the holder of the construction permit to notify the NRC Regional Office of each deficiency in the constructior. and design phase of the project, which the holder determines meets the reporting requirements of this paragraph. In addition to these requirements GSU committed to inform the Region IV Office of deficiences that are potentially reportable under Paragraph 50.55(e).

At the end of the initial review period specified in the Gulf States Utilities' procedure, no determination had been made that the item was reportable. However, Gulf States Utilities believed that sufficient information existed at that time to classify the matter as "potentially reporteble" and the NRC was so informed. As is discussed in more detail in the Chronology, GSU followed its applicable procedures. The relevant procedure, RBPP 1.7 Rev. 2, had been previously discussed with officials of Region IV in mid-November of 1981 as part of the Systematic Assessment of Licensee Performance

("SALP") program.

GSU respectfully points out that its intentions have been, and currently are, responsive to our commitments and to the regulations.

We think the Chronology shows this. To avoid any misinterpretations, GSU has modified its procedures as we continue to work with Region IV.

For these reasons, GSU feels the severity level assigned to this violation is not warranted and we request that you reconsider the classification.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A meeting was held on February 8, 1982, between Mr. G. L. Madsen (NRC Region IV) and Mr. William J. Cahill (GSU-Sr. V. P.) to discuss earlier notificat i on to Region IV of potentially reportable deficiencies. As a result of this meeting, GSU issued Revision 3 to RBPP 1.7. The time period for performing the reportability reviews was reduced from a maximum of 8 working days from the first level concurrence to 3 working days from the initiation of the reporting form. The level of management approval for notifying the Region IV office of potentially reportable deficiencies was changed to the Director-Nuclear Licensing. Meetings were held with S&W and GE to clarify their roles in notifying GSU of deficiencies that are under review for reportability. S&W revised its River Bend Procedure 10.5 to indicate early notification and GE implements its program through its NEBG Procedure 70-42.

,o . .

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NONCOMPLIANCE Corrective steps have been implemented as outlined above in the revision of procedure RBPP 1.7, Rev. 3.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Not applicable - in compliance. Procedure RBPP 1.7, Rev. 3, was effective February 10, 1982 to be more responsive to early notification to the NRC Regional Office of potentially reportable deficiencies.

CHRONOLOGY Wednecday, January 20, 1982 GSU Licensing begins reivew for reportability.

Thursday, January 21, 1982 GSU Licensing interviews the GSU Site Engineering reporting person and the S&W Site Engineering person involved in dispositioning Nonconformance and Disposition Report (N&D) 2071.

From the interview it became evident that 1) had this deficiency gone undetected it could have resulted in the failure of the pipe whip restraint brackets to perform their intended function under the conservative design loadings, and 2) it was not clear whether the deficiency resulted from an Engineering problem, or other problem.

Monday, January 25, 1982 In an attempt to define the cause of the problem, GSU Licensing requests GSU QA to evaluate the deficiency and advise whether a QA program problem existed. GSU QA is to provide a response by Wednesday, January 27.

Friday, January 29 GSU QA responds to GSU Licensing that the review of the QA implications had not been completed but that a previous stop work had been issued on the vendor. A complete review of the vendor's program would require an extended period of time.

Based on the information gathered, GSU Licensing recommends to the Manager-Engineering & Licensing that a potentially reportable deficiency exists.

The Manager directs GSU Licensing to notify the NRC Region IV office of a potentially reportable deficiency. At 4:10 p.m. GSU calls the Region IV but the Office is closed for the day.

Monday, February 1, 1982 7:30 a.m. conmumication is made with the Region IV Office concerning a potentially reportable deficiency.