RBG-22866, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-69.Corrective Actions:Nuclear Plant Engineering Procedure NuPE-AA-64 Issued to Provide Detailed Instructions & Restriction for Use of Field Change Notices

Responds to NRC Re Violations Noted in Insp Rept 50-458/85-69.Corrective Actions:Nuclear Plant Engineering Procedure NuPE-AA-64 Issued to Provide Detailed Instructions & Restriction for Use of Field Change Notices

ML20140D634
Person / Time
Site:	River Bend
Issue date:	12/19/1985
From:	Deddens J GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20140D611	List: ML20140D607 RBG-22866, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-69.Corrective Actions:Nuclear Plant Engineering Procedure NuPE-AA-64 Issued to Provide Detailed Instructions & Restriction for Use of Field Change Notices
References
RBG-22866, NUDOCS 8602030086
Download: ML20140D634 (6)

Text

. . - - .

GULF STATES UTELETIES COMPANY river BENO STATION POST OFFICE BOit 220 ST FRANO5VILLE. LOU 4SLANA 70776 ARE A CODE 604 635 6094 348 8651 December 19, 1985 REG- 22866 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Dear Mr. Martin:

River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 85-69 This letter responds to the Notice of Violation contained in NRC IEE Inspection Report No. 50-458/85-69. The inspection was performed by Messrs. D. D. Chamberlain, W. B. Jones and R. P.

Mullikin during the period September 16 through October 31, 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 85-69-01A, " Failure of Document Control Program" and 85-69-01B, " Improper Use of a Field Change Notice (FCN) , " are provided in the enclosed attachment. This completes GSU's response to the Notice of Violation.

Sincerely, t- gg aw 06020300060601h50 /. C. Deddens PDR ADDCK 0500 PDR Vice President 0 River Bend Nuclear Group JCD/R amg - --

'v 3 7.] ;, j; i' f /!

3 h)y

~

Attachment l

PIC 7 7 085

+ t

UNITED STATES OF AMERICA NUCLEAR EECULATORY CODMISSION STATE OF LOUISIANA 5 PARISH OF WEST FELICIANA 5 In the Matter of I Docket Nos. 50-458

~

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

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

/ ~

/ W '

J. C. D4ddens Subscribed and sworn to before me, a Notary Public in and for the 5.

State and Parish above named, this [ day of b'I' r Wd y r' ge , 19 u, 2 d h RL 'J v/oanW.MidlebrookNotary Public in and for West Feliciana Parish, Louisiana My Commission is for Life.

ATTACHMENT December 19, 1985 RBG- 22866 Response to Notice of Violation Severity Level IV Reference Notice of Violation - L. E. Martin letter to W. J. Cahill, Jr.

dated November 19, 1985.

Refer to Docket No. 50-458/85-69.

A. Reason for Violations on October 18, 1985, it was discovered that approved modification request (MR) design packages and approved field change notices (FCN) had not been posted against affected design documents and they had not been distributed to document control stations. For example, FCN 85-0397-19 was not posted against drawing 12210-ESK-5 ENS 06 and it was not available at the document control stations. Several other examples of the failure to post and distribute MRs and FCNs were noted.

The Corrective Steps Which Have Been Taken & Results Achieved Procedure NPE-3-006 (River Bend Station Design and Modification Request Control Plan) was supplemented by issuance of an Interim Procedure Change IPC-3-006-2-2 on December 12, 1985. A revision to the Nuclear Plant Engineering (NuPE) procedure NuPE-AA-54 (Guidelines and Instructions for Processing Modification Requests) was issued December 4, 1985. This procedure controls River Bend Station's (RBS) engineering activities for handling MR's and, in conjunction with NuPE-AA-59, is used to ensure that the holder of the design data base is notified of design modifications and that RBS's Change Control Document Reporting System (IS-217 Report) is updated to list these changes against the affected documents. NuPE-AA-59 (Updating and Distributing Design Documents) was revised and issued November 22, 1985. The revision to NuPE-AA-54 includes more detailed instructions for completing the MR and routing of same. In addition, this revision has a mandatory requirement that a computer data input form be completed and included as a numbered page of all MR's. This data input form contains spaces which correspond to the input fields in the IS-217 Report referenced above. The location of this input form within the MR is identified on the MR Cover Sheet; it in

normally the second sheet in the MR document. All documents affected by the MR are consolidated and listed on this input form. A similar practice has also been adopted for FCN's.

Upon approval of an MR or FCN by NuPE, the following occurs:

1 - A copy is forwarded to the field for implementation.

2 - A copy if formally transmitted to the holder of the design data base for updating the IS-217 Report and for making distribution to document control stations.

3 - A copy is now forwarded to the control room document station for immediate posting via " redlining" the IS-217 Report.

Prior to transmitting the change documents to the holder of the design data base an internal review ig performed by the NuPE Design Control Coordinator to ensure that procedural requirements (including completion of the IS-217 data input form) are adhered to.

In addition to redlining the IS-217 Report, a verification is performed by the control room document station clerical supervisor to ensure that MR's or FCN's are included in subsequent issues of the report. This practice will continue until it has been demonstrated that change documents are posted in the appropriate manner.

A condensed IS-217 Report is now being issued which lists only the change documents which are required to be incorporated into a given a f fected document (i.e.,

information only changes are not included). This report in intended to reduce the information which must be considered to only those changes which have impact on the documents.

Administrative changes have been implemented by NuPE and the holder of the design data base to reduce the time between design change approval and posting against the affected documents. For example, the staff responsible for updating the IS-217 Report has been relocated to an area immediately adjacent to the group responsible for design control interface between GSU and the design data base holder.

Initial surveillance indicates that the time lag between approval of the design modification and posting against the affected documents has reduced significantly.

A 100% audit of the MR files, which includes FCNs, has been conducted to determine if similar cases exist. Some additional discrepancies were discovered and steps have been taken to resolve them. However, all of these deficiencies occurred prior to issuance of the revised procedure, indicating that the above actions have precluded the recurrence of similar events.

Corrective Action to Prevent Recurrence In addition to the actions implemented above, training of all Nuclear Plant Engineering Personnel responsible for completing or handling MR's and FCN's began December 9, 1985 and will continue with retraining as procedures are reviewed.

Also, verbal instructions have been provided as necessary by cognizant individuals on a continuing basis since such activities began.

An interim Quality Assurance (OA) audit has been scheduled for January, 1986 to ascertain the effectiveness of these actions. The specific case (i.e., MR-85-0397 FCN 19) was rectified at the time of discovery, and subsequently FCN 19 was incorporated into FCN 23.

Date of Full Compliance The training mentioned above and the correction of other deficiencies identified as a result of the audit of the MR files are scheduled for completion by December 31, 1985.

B. Reason for Violation On October 18, 1985, it was discoverd that FCN 85-0397-19 was approved and implemented to modify the function / control logic of the diesel generator output breaker to allow remote shutdown operation frem the diesel generator panel in either the normal or emergency mode.

The Corrective Steps Which Have Been Taken_& Results Achieved Nuclear Plant Engineering Procedure NuPE-AA-64 (Control and Approval of Field Change Noticos (FCNs)) was developed and issued November 18, 1985. This procedure provides detailed instructions and restrictions for the use of FCN's and in certain cases requires additional reviews. The limited use of FCN's for making changes to previously approved MR's is strensed throughout the procedure. A parallel surveillance of FCN's during implementation is conducted by Quality Assurance to ensure compliance to the procedure.

Corrective Action to Prevent Recurrence In addition to the actions implercented above, training of all Nuclear Plant Engineering Personnel responsible for completing or handling MR's and FCN's began December 9, 1985 and will continue with retraining as procedures are revised.

Also, verbal instructions have been provided as necessary by cognizant individuals on a continuing basis since such activities began.

1

<b An interim Quality Assurance (QA) audit has been scheduled for January, 1986 to ascertain the effectiveness of these actions. The specific case (i.e., MR-85-0397 FCN 19) was rectified at the time of discovery, and subsequently FCN 19 was incorporated into FCN 23.

Date of Full Compliance NuPE-AA-64 was approved and issued on November 18, 1985. The training mentioned above and the correction of other deficiencies identified as a result of the audit of the MR files is scheduled for completion by December 31, 1985.

.