ML20210C041
| ML20210C041 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/05/1986 |
| From: | William Cahill GULF STATES UTILITIES CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| RBG-24325, NUDOCS 8609180221 | |
| Download: ML20210C041 (8) | |
Text
e s.s GULF STATES UTILITIES COMPANY R1VER BEND STATION POST OFFICE 80x 220 ST. FRANCISVILLE, LOUISIANA 70775 AREA CODE 504 636-6094 346-8651 September 5, 1986 RBG-24325 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission kh h Region IV 611 Ryan Plaza Drive, Suite 1000
!I Arlington, TX 76011 u o
Dear Mr. Martin:
River Bend Station - Unit 1 Refer to:
Region IV Docket No. 50-458/ Report 86-08
-This supplemental letter responds to the Notice of Violations contained in NRC I&E Inspection Report No.
50-458/86-08.
The inspection was performed by Messrs.
D.
D.
Chamberlain, R. E.
Farrell, and W. B. Jones during the period February 1
through March 15, 1986 of activities authorized by NRC Operating License NPF-47 for River Bend Station.
Gulf States Utilities Company's (GSU) supplemental response to Notice of Violation 86-08-01, " Improper Disposition of Startup Test Deficiency", and 86-08-02, " Failure to Schedule an. Audit Early in the Life of an Activity", are provided in the enclosed attachments.
This completes GSU's supplemental response to the Notice of Violations.
Sincerely,
/
r A
. J. Cahill, Jr.
Senior Vice Preside 1.t River Bend Nuclear Group s
M /A'S WJC/ ERG 7RRS/PFT/je Attachments 8609180221 860905 PDR ADOCK 05000458 G
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t UNITED STATES OF AMERICA NUCLEAR EEGULATORY C(BSEISSION STATE OF LOUISIANA 5
FAEISE OF WEST FELICIANA 5
In the Matter of I
Docket Nos. 50-458 GULF STATES UTILITIES C(BIFANT I
(River Bend Station, Unit 1)
AFFIDAVIT W.
J.
- Cahill, Jr.,
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 Coassission the documents attached heretos and that all such documents are true and correct to the best of his knowledge, information and belief.
/2 Wp.Cahill,Jr/'
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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this _ ay of
'Isy /n, 19 f6.
lb wA)
/Joan W. Middlebroots Notary Public in and for West Feliciana Parish, Louisiana My Conanission is for Life.
4
. o; e ATTACHMENT 1 Response To Notice Of Violation 458/8608-01 Level IV i
REFERENCE Notice' of Violation J.
E. Gagliardo letter to W. J. Cahill, Jr.
-dated May 1, 1986, Docket 50-458, License No. NPF-47.
A.
IMPROPER DISPOSITION OF STARTUP TEST DEFICIENCY i
REASON FOR VIOLATION
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Condition Report (CR) No. 85-0622 was written to' document a
test exception (TE-1) following performance of Start Up and Test l
Procedure ST-31.
The test exception was closed on 2/4/86 based on i
NuPE's disposition-to the noted CR.
The violation occurred when it was discovered that a telecopied design. evaluation from Stone &
i Webster Engineering Corporation (SWEC) to Gulf States Utilities Company (GSU) which formed part of the basis for the disposition l_
to the CR, did not contain signatures of approval or verification.
I The responsible GSU system engineer did not notice that signatures
[
were lacking and, therefore, proceeded to disposition the.CR based j.
on the unsigned telecopy which is not consistent-with normal' practice.
presented to the Facility Review Committee (FRC) for The CR was j
approval of Test Exception 1 to ST-31, " LOSS OF _OFFSITE POWER".
The FRC is responsible for reviewing and approving Startup Test Frogram Test Exceptions (TE).
TE-1 to ST-31 required Condition i
Report (CR) No. 85-0622 be dispositioned prior to closure of TE-1.
The CR was reviewed by NuPE and a
summary disposition was presented. to the FRC which stated that Modification Request (MR) l No. 86-0035 was initiated.
The MR was generated to assure that only ~one division of the control Building Chilled Water System l
would start following a loss of offsite power.
The FR review was t
j determined to be adequate for closure of the TE based on the l-disposition prepared by NuPE.
l CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED J
j SWEC was contacted via phone regarding the subject
- telecopy, at
+
l which time it was noted that a formal calculation would not-yield L
results different from those presented in the telecopy.
GSU requested SWEC to provide a formal calculation with appropriate reviews.
Calculation PB-364 was formally transmitted from SWEC to j
GSU to document these results.
The results from calculation p
i PB-364 did not differ from those presented in the unsigned j
telecopy.
Therefore, the disposition to CR NO. 85-0622 did not i
change.
It should be noted that neither the unsigned telecopy or calculation PB-364 were attached to the CR, rather, they are a i
i
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a ATTACHMENT 1 (cont'd.)
part of supporting documentation used to form a
basis for dispositioning the CR.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The FRC does not track approved MRs.
For this instance, CR No.
85-0622 was the source document for MR 86-0035.
Control of the implementation and maintenance of the design process rests with NuPE as specified in NPE-03-006,
" Design and Modification Control".
All MRs are processed internal to NuPE in accordance with NuPE procedure NuPE-AA-54,
" Nuclear Plant Engineering Guidelines and Instructions for Processing Modification Requests".
If MRs are cancelled, procedure NPE-3-006 requires the Design System Engineer (DSE) to write a
memorandum providing justification and requesting permission from the Plant Manager to cancel a MR.
Upon obtaining the Plant Manager approval to cancel a MR, the Design Control Coordinator (DCC) must provide a copy of the cancelled MR to the initiator, the DSE, and the Plant Manager.
MRs that require changes to the Final Safety Analysis Report (FSAR) require NuPE to generate a " Change to a Licensing Document Form" in accordance with NuPE-AA-54.
FSAR change request forms are submitted to Nuclear Licensing pursuant to RBNP-0027,
" Initiation of a Change to a Licensing Document".
NuPE procedure NuPE-AA-54 is being revised to require the DSE to ensure that any documentation used during developing the design input.for a
MR, which is received form a vendor or agent, be officially signed and dated.
In addition to this
- request, the Engineering Coordinator will be procedurally required to review all MR's and FCN's for compliance with the added review required in NuPE-AA-54.
NuPE has assigned a Mechanical Engineer to review a random sample of approved and processed MR's for the subject concern.
The review will be completed by June 15, 1986.
Should the review identify any reoccurrence of the aforementioned, appropriate corrective action will be implemented.
In
- addition, NuPE will take this opportunity to issue a memorandum which instructs its engineers to ensure that any documentation used during the design
)
process received from a
vendor or outside agent be officially signed and dated.
This memorandum will be issued by June 6, 1986.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1)
SWEC calculation PB-364 was received on April 2, 1986.
2)
NuPE-AA-54 will be revised by June 15, 1986.
3)
A sample review of MRs will be completed by June 15, 1986.
ATTACHMENT 1 (cont'd.)
4)
A memorandum instructing NuPE engineers will be issued by June 6, 1986.-
l l
- . s.
ATTACHMENT 2 Response To Notice Of Violation 458/6608-02 Level IV REFERENCE J.
E. Gagliardo le'tter to W. J. Cahill, Jr.
Notice of Violation dated May 1, 1986,' Docket 50-458, License No. NPF-47.
B.
FAILURE TO SCHEDULE AN AUDIT EARLY IN THE LIFE OF AN ACTIVITY REASON FOR THE VIOLATION The failure to schedule an audit of Facility Review Committee (FRC) review activities early in the life of this activity was due to a lack of programmatic controls associated with follow-up conditions related to Quality Assurance (OA) audits.
An audit addressing Startup and Test (SU&T) activities and FRC review was performed in
- February, 1985 (Audit No.
GSUS/SU&T-85/02).
However, FRC review activities at that time were predominantly review and approval of start-up procedures as the actual start-up phase had not yet commenced.
The audit checklist documented this fact and indicated that a subsequent audit would be scheduled to address these activities following commencement.
Until
- recently, a procedural mechanism had not existed to assure that activities, not covered in an audit
- scope, were brought forward for consideration in future audit conduct.
Revision 0 of the Master Audit Schedule included an audit o f.
Startup and Test activities.
However Revision 1 of this schedule deleted this audit.
The justification for this deletion was not properly communicated and objective evidence could not be found in support of this deletion.
Discussion with the past Audit Coordinator, who had recently terminated as a GSU employee, indicated his intent was to include PRC Review Activities in the scope (s) of related audit activity.
CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An evaluation of FRC Review of SU&T activities was included in the scope of Audit 86-03-I-STPG,
" Surveillance Test Program",
conducted in March, 1986.
The scope of this audit was increased to include the SU&T activities and FRC reviews performed during the subject period in February, 1985.
One deficiency was identified relative to administrative controls required by the RBS Startup Manual - the documentation of required
b ATTACHMENT 2 (cont'd.)
l reviews of the initial Startup Test Log.
This deficiency was documented as Quality Assurance Finding Report (QAFR)
No.
P-86-04-012 and is currently in the corrective action process.
As part of the
- scope, the audit addressed a follow-up to the i
j Operations QA Surveillance efforts.
A finding had been identified in January, 1986 addressing deficiencies in the area of FRC Review and Approval of Test Condition (TC) Heat-Up without taking proper exception to ST-11,~"LPRM Calibration", and ST-13, "NSSS Process Computer".
Results indicated the corrective actions taken to address QAFR No.
O-86-01-02-D have prevented recurrence of this problem during subsequent FRC review and apprcval of TC-1 and 3
TC-2.
Results of this audit effort indicated - that the overall performance of Plant Staff in the review and approval of initial startup test results is considered satisfactory.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIOl!S In March of 1986, QA Systems performed a
review of the GSU Internal QA Audit Program (QAI-2.1,
" Audit Performance and Reporting")
to assess adequacy and effectiveness.
Results indicated weak programmatic controls relative to several elements, one of which involved audit schedule / scope reviews.
Two QAFRs 4
(QAFR Nos.
P-86-03-015 and P-86-03-016) were issued to document i
these deficiencies and are currently in the corrective action j
process.
The actions to correct and prevent similar recurrence of problems include:
la.
Inctituting a
100% review of all 1985 audit files against a given checklist of tanks, such as:
i
-a determination of any outstanding audit checklist items l
identified as requiring attention during subsequent audits, and
- an indication of those unsatisfactory audit checklist items which do not appear to be supported properly (i.e.,
justified or referenced to QAFR number).
l lb.
Assuring 'that these deficient er questionable items are corrected and/or accounted for.
This review is projected to be complete by November 28, 1986.I Corrective action as applicable for those deficiencies identified J
by the review will be corrected by December 31, 1986.
2.
Revising procedure QAI-2.1 to include necessary programmatic centrols in sufficient detail to assure commitments /
requirements are implemented properly.
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ATTACHMENT 2 (copt'd.)
Procedure CAI-2.1 will be revised by July 15,, 198C.
t 3.
Provided training to the auditing 9ta f f (n1 the proper implementation of there requirements.
This is currently an ongoing ef fort and will ec.ntir3us folicwing the issuance of the revised QAI-2 1 Although QAI-2.1 has not yet been issued to addreas increased program
- controls, these controls have been invoked and are currently implemented.
Completed hudit files dating back-to
- January, 1986 have been properly reviewed and maintained.
Personnel have been instructed in required proce. dural guidelines and mechanisms are in place to assure accountability of each audit scope.
DATE W14N FUL'L COMPLIANCE WILL DE ACHIEVED la.
A con.plete review of 1995 internal audit files will be completed by November 28, 1986, Forty-four (44) audjts are being considered in this review of which thirty-threeL33) have been reviewed and eleven (11) remain to be reviewed, i
This date differs from the previously submitted completion date of t.ugust 31, 1986 because of the unanticipated scope of the task necessary to comprehensively complete this review.
Ib.
The applicable corrective action based on la wil2 he I
completed by December 31, 1986.
J 2.
A revision to QAI-2.1 will be cespleted by July 15, 1906.
3.
Training of auditors is cngoing, Training of auditors to revised QAl-2.1 will be ccmpleted by August 1, 1986 l