ML20205N950
| ML20205N950 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/16/1986 |
| From: | William Cahill GULF STATES UTILITIES CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20205N935 | List: |
| References | |
| RGB-23-535, NUDOCS 8605210021 | |
| Download: ML20205N950 (6) | |
Text
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GULF STATES UTILITIES COMPANY RIVER BEND STATION POST OFHCE BOX 220 ST FRANCISvitLt. LOUISLANA 70775 ARE A CODE 604 635 6094 346 8651 April 16, 1986 RBG-23,535 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission
'~
' - rpq Region IV 2_
611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 APR 211986 t
Dear Mr. Martin:
dUl J
.x a, M River Bend Station - Unit 1 Refer to:
Region IV Docket No. 50-458/ Report 85-77 Based on discussion with your staff, this letter supplements Gulf States Utilities Company's (GSU) February 26, 1986 response l
to the Notice of Violation contained in NRC I&E Inspection Report l
No. 50-458/85-77.
The inspection was conducted by Messrs.
D.
D.
l Chamberlain, W.
B. Jones, R. P. Mulliken, R.
E.
Farrell, and W.
R. Bennett during the period October 31 through November 30, 1985 of activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No.
1.
GSU's supplemental response to the Notice of Violation 85-77-01, " Failure of Design Control Program", is provided in the enclosed attachment.
This completes GSU's response to the Notice of Violation.
Sincerely,
. J.
Cahill, Jr.
Senior Vice President River Bend Nuclear Group WJC/R3K/RRS/je Attachment 8605210021 860508 PDR ADOCK 05000458 O
PDR fC# D J
n UNITED STATES OF AMERICA NUCLEAR RECUIATORY CGREISSION STATE OF IAUISIANA 5
PARISE OF WEST FELICIANA 5
In the Matter of Docket Nos. 50-458 CULF STATES UTILITIES COMPANY l
(River Bend Station, Unit 1)
AFFIDAVIT W.
J.
- Cahill, Jr.,
being duly sworn, states that he is a Senior Vice President of Culf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear Rggulatory Connais sion the documents attached heretos and that all such documents are true and correct to the best of his knowledge, information and belief.
J. Cahill, Jr /
Subscribed and sworn to before me, a Notary Public in and for the State and Parish abova named, this day of
/)r /
,19[
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/ /h l} -
/7 oan W. Middlebrc oks otary Public in'and for West Feliciana Parish, Louisiana My Commission is for Life.
ATTACHMENT RESPONSE TO NOTICE OF VIOLATION 50-458/8577-01 LEVEL IV REFERENCE Notice of Violation - J.
E.
Gagliardo to W.
J. Cahill, Jr. dated January 27, 1986.
REASON FOR VIOLATION Field Change Notice (FCN) #19 to design Modification Request (MR) 85-0397 was comprised of several individual change documents.
One of the change documents provided page 36 of the FCN which added the contacts 7/8 and 3/4 of switch 43B into the circuit.
Page 57 of the FCN was issued on a separate change documents and removed the contacts to reflect a change in the design to allow operation of the diesel from its local control panel during normal operation.
The' second change document issued was the third revision of that particular change.
The preparer of the first two revisions recognized that changes were being made to an existing change document and it was identified that the change removing the contacts
" supplemented" or replaced the original design which had.added them.
However, during the preparation of the third revision, a change in the philosophy of " supplementing" previous design changes was made and this change document did not replace the original design.
This was incorrect and was the apparent result of a failure by the preparer to recognize the contradicting information and the need to replace it.
In addition, at the time the third revision was prepared the base initial Modification Request for that revision had been cancelled.
As such the entire change should have been combined under a revision to the original change document.
The illegibility of several pages of FCN
- 19 due to poor reproductive quality was the result of a
need to continually supersede existing change documents to provide new design information.
This was necessary since the original design changes had not yet been incorporated into the base drawing.
The need to provide original design information capable of yielding legible results following multiple reproductions was not recognized.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED FCN #23 to MR 85-0397 was prepared to consolidate all outstanding design changes for this MR into a single FCN.
The contradicting information of FCN #19 has been corrected and is properly shown on page 170 of 208 of FCN
- 23.
This FCN eliminates all outstanding documents against the cancelled MR.
Attachment (cont'd.)
Page 2 RBG-23,535 On the generic
- basis, the Quality Assurance (QA)
Department performed a surveillance on all FCNs issued prior to November 8, 1985.
Seventy-four (74)
FCNs were reviewed for clarity and legibility.
This review (Surveillance ESOA-85-ll-05) identified an additional twenty-two (22)
FCNs as being deficient in legibility, understandability, acceptance criteria, and change of intent.
Twenty-one (21) of the FCNs were corrected and re-reviewed by the QA Department.
The one remaining FCN (MR 85-0577 FCN
- 1) was found to have an indeterminate field condition as the result of ambiguous markings on the FCN.
This deficiency was documented on NR 85-0557 and was subsequently closed on November 12, 1985.
To review the overall performance of the design modification process, the GSU QA Department rescheduled its audit of design modifications from December to November.
This audit (OM& M-8 5-11) was conducted during November 18-26, 1985 and resulted in the issuance of no Quality Assurance Finding Reports (QAFR's) which directly concerned the FCNs.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The personnel involved in the preparation of such MRs and FCNs have reviewed the discrepancies identified in FCN #19 to MR 85-0397 at the time FCN #23 was prepared.
In addition, specific information, including the preparation of preprinted forms for I
use in MRs and FCNs has been issued and discussed with each engineer (attached).
This has resulted in a noted increase in the clarity and legibility of the design information.
Ci a generic
- basis, NuPE Procedure NuPE-AA-64,
" Control and Approval of Field Change Notices (FCN's)", was developed and issued November 8, 1985 and provides detailed instructions for the use of FCNs and in certain cases requires additional reviews.
The limited use of FCNs for making changes to previously approved MRs is stressed throughout the procedure.
A parallel review of FCNs during implementation is conducted by Quality Assurance to ensure compliance to the procedure.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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Page 2 December 4, 1985 RBG-22,740 Affected setpoints have been verified to be within maximum allowable limits specified in technical specifications by reviewing test data or performing channel functional tests.
The technical specification nominal setpoint requirements have been clarified as a
result of meetings held among Plant Staff Management and members of the NRC Staff during the recent inspection in which the subject violation was identified.
The corrective actions discussed above have also been established to prevent further violation of technical specification requirements.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED All of the surveillance test procedures identified as allowing instruments to be calibrated outside of the technical spec.ification requirements shall be corrected by April 1, 1986.
e i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COIMISSION STATE OF IAUISIANA 5
PARISH OF WEST FELICIANA 5
In the Matter of I
Docket Nos. 50-458 50-459 CULF STATES UTILITIES COMPANY l
(River Bend Station, Unit 1)
AFFID&VIT 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 hereto and that all such documents are true and correct to the best of his knowledge, information and belief.
/
s W
J. C. Dd'ddens l
l Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this day of FM /me r,19 89.
1
/gtk fit W
l an W. Middlebrooks(
otary Public in and for l
West Feliciana Parish, Louisiana I
My Commission is for Life.
I
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