ML20148D936
| ML20148D936 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/19/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8801250516 | |
| Download: ML20148D936 (2) | |
See also: IR 05000458/1987027
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In Reply Refer To:
JM I 9 N
Docket: 50-458/87-27
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Gulf States' Utilities
ATTN: Mr. James C. Deddens
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Senior Vice President, (RBNG)
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Nuclear Licensing
P.O. Box 220
St. Francisv111e, Louisiana
70775
Gentlemen:
Thank you for your letter of December 18, 1987, in response to our letter
and Notice of Violation dated November 17,1987. 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 corrpliance has been achieved and will be
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maintained.
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O fginal Signed 11y
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L. J. Callan
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L. J. Callan, Director
Division of Reactor Projects
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Gulf States Utilities
ATTN:
J. E. Booker, Manager-
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River Bend Oversight
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P.O. Box 2951
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Beaumont, Texas
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Louisiana State University,
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Government Documents Department
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Louisiana Radiation Control Program Director
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DEC 2 81987
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December 18, 1987
RBG - 27174
File Nos. G9.5, G15.4.1
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U. S. Nuclear Regulatory Comission
Document Control Desk
Washington, D.C.
20555
Gentlemen:
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River Bend Station - Unit 1
Refer to: Region IV
Docket No. 50-458/ Report 87-27
This letter responds to the Notice of Violations contained in NRC
Inspection Report No. 50-458/87-27. The inspection was performed by
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Messrs. Chamberlain and Jones during the period of October 1-31, 1987 on
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activities authorized by NRC Operating License NPF-47 for River Bend
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Station Unit No. 1.
Gulf States Utilities Company's (GSU) response to
Notice of Violations 458/8727-01, "Failure to Obtain Required Procedure
Approval", and 458/8727-02, "Failure to Initiate Hot Work Pemit for
Grinding Activity", is provided in the enclosed attachment pursuant to
10CFR2.201. This completes GSU's response to these items.
Sincerely,
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J. C. Deddens
Senior Vice President
River Bend Nuclear Group
JCD/DRD/JWL/sN/ ERG JHM/tl
cc:
U.S. Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
NRC Resident Inspector
P. O. 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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In the Matter of
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Docket No. 50-458
50-459
GULF STATES UTILITIES COMPANY
)
(River Bend Station,
Unit 1)
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
belief.
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J. C. beddens
Subscribed
and
sworn
to before me, a Notary Public in
and for the St.ste and Parish above named, this
/8Yb day of
h0PfY1hPr
, 19 S 0 .
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-
/Joan W. Middlebrooks
M otary Public in and for
West Feliciana Parish,
My Commission is for Life.
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ATTACMENT
Response To Notice of Violation 50-458/8727-01
Level V
REFERENCE:
Notice of Violation - letter from L. J. Callan to J. C. Deddens, dated
November 17, 1987.
VIOLATION - Failure to Obtain Required Procedure Approval
River Bend Station Technical Specifications, Section 6.5.2.1, require
that each procedure and program of Specification 6.8, which includes
surveillance and test activities of safety-related equipment, shall be
approved, prior to implementation, by the Plant Manager or one of the
Assistant Plant Managers or the Supervisor-Radiological Programs.
Contrary to the above, on October 6,1987, during observation of a
maintenance activity, the senior resident inspector found that Station
Operating Procedure No. TP-87-29, "RCIC Signature Testing", was being
implemented to test safety-related motor operated valves in response to
NRC Bulletin 85-03. This procedure had been approved by the Director of
Field Engineering, and not by the Plant Manager or one of the Assistant
Plant Managers.
REASON FOR THE VIOLATION:
The Engineering Department was reorganized in September of 1986. A new
group within the engineering department was formed from several existing
Technical Staff Groups combined with Nuclear Plant Engineering's
Mechanical Engineering group to fom the Field Engineering Group. The
functions of the Technical Staff Groups were also assigned to the Field
Engineering Group, along with the procedures necessary for
implementation. Control of those procedures was transferred to the
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Director-Field Engineering by a change to ADM-0003, "Development
Control and Use of Procedures", which controls the issuance and
modification of procedures in the Station Operating Manual. However,
Technical Specification (TS) Section 6.5.2.1 was not changed to reflect
that the Director - Field Engineering has assumed signature authority
for procedures in the Field Engineering area of responsibility.
It was
felt that Plant Manager approval of the change to ADM-0003 constituted
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adequate control. Therefore, the root cause was a result of the
reorganization of engineering, and a misunderstanding of the changes
required to allow transfer of procedural responsibility to the Field
Engineering Group.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The reorganization of the Engineering Department is now complete.
Procedures which had been signed solely by the Director-Field
Engineering were reviewed and signed as required by T.S. 6.5.2.1.
Thus,
the Field Engineering related procedures now have the required
approvals.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Corrective measures have been taken to assure STPs in use are properly
approved. The Director-Field Engineering now initials applicable Field
Engineering procedure changes and forwarde them for approval in
accordance with T.S. 6.5.2.1.
ADM-0003, Figure 1, has been changed to
eliminate signature authority for the Director-Field Engineering and has
been replaced with the Plant Manager or Assistant Plant Manager. This
assures that none of the applicable procedures will be issued without
the approvals as required by T.S. 6.5.2.1.
An initial review of other
available procedures controlling signature authority under T.S. 6.8.1
was performed and determined that adequate signatures were controlled.
To ensure that the appropriate procedures are identified and controlled
in accordance with T.S. Sections 6.5.2.1 and 6.8.1, a Quality Assurance
review will be performed. This review is expected to be completed
during January 1988.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The Technical Specifications applicable procedures in active use are
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signed by the PM or APH. The revisions or changes will be signed by the
PM or APM as they are written.
Quality Assurance evaluations will be
completed during January 1988. Any recommendations will be reviewed for
further corrective action.
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ATTACMENT
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Response To Notice of Violation 50-458/8727-02
Level V
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REFERENCE:
Notice of Violation - letter from L. J. Callan to J. C. Deddens, dated
November 17, 1987.
VIOLATION - Failure to Initiate Hot Work Permit for Grinding Activity
Technical Specification 6.8.1.g requires that written procedures be
established, implemented, and maintained for activities implementing the
Fire Protection Procedure (EPP)-0060, "Hot work Pemit." states that, "A
Hot Work Pemit shall be required whenever an ignition source is to be
used in any area of the plant, except those areas designated as Hot Work
Area." An ignition source is defined as an open flame apparatus,
welding, abrasive cutting and grinding, brazing, and other devices whose
temperature exceeds the heat of ignition of materials in contact or
close proximity to the device.
Contrary to the above, on October 24, 1987, at approximately 2 a.m.
(CDT), the resident inspector observed grinding operations on the
inboard main steam isolation valve 1821*A0V022C for the removal of a
bolt stud without a Hot Work Permit having been obtained.
The area had
not been designated as a Hot Work Area, nor had a firewatch been
established.
Combustible materials were located within close proximity
of the grinding activity.
REASON FOR THE VIOLATION:
Procedure FPP-0060 defines the use of a Hot Work Permit during operation
and outage work and requires a pemit whenever an ignition source is
used in any area of the plant, except those areas designated as
permanent Hot Work Areas.
During the rework of main steam isolation
valves on MWO #105963, two repairmen violated procedure FPP-0060. After
attempting unsuccessfully to remove a seized body-to-bonnet nut on
1821*A0VF022B using nomal means, the person in charge of the field work
elected to "crack" the nut off.
This process involved grinding a notch
in the nut and then using a cold chisel to crack the nut in half. The
grinding process created sparks in the area. This was a procedure
violation because there was not a designated fire watch nor did the
repairmen have a valid Hot Work Permit.
The event occurred at about 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> (eight hours into a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
shift).
Dress out requirements included double PC's and a respirator.
The person in charge of the field work decided to continue the job
instead of leaving the work area to ensure a valid Hot Work Permit was
in effect (a loss of time on the job estimated at two hours).
Therefore
the root cause of the incident is determined human error. The mechanics
assumed that a Hot Work Pemit existed rather than one of them leaving
the work area to check,
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The person in charge of the field work was given disciplinary action
(verbal reprimand) by the Mechanical Maintenance Supervisor. Both
repaimen also received disciplinary action and personal instructions on
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the requirements for use of Hot Work Permits.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
On November 3, 1987, D. R. Derbonne (Assistant Plant Manager -
Maintenance) issued memo number APM-M-87-342 which states the
circumstances of the event and promulgates Maintenance Management's
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position on adherence to procedures.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Gulf States Utilities Company is currently in full compliance.
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