ML20210C329
| ML20210C329 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/16/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8609180311 | |
| Download: ML20210C329 (2) | |
See also: IR 05000458/1986020
Text
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In-Reply Refer To:
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Docket: 50-458/86-20
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Gulf States Utilities
ATTN: William J. Cahill, Jr.
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Senior Vice President-
River Bend Nuclear Group
P. O. Box 220
St. Francisville, Louisiana 70775
Gentlemen:
Thank you for your letter of August 29, 1986 , in response to our letter
and the attached Notice of Violation dated July 30, 1986'
As a result
.
of our review, we find that additional information, as discussed with your
Mr. E. Grant during a telephone call on September 11, 1986, is needed.
Specifically, we need more information on the review of piping and instrument
drawings that we understand you are conducting.
Please provide the supplemental information within 30 days of the
date of this letter..
Sincerely,
Original signed By
J. E. Gagliardo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
. Gulf States Utilities
ATTN:
~J. E. Booker, Manager-
Engineering, Nuclear
Fuels & Licensing
P. O. Box 2951
Beaumont, Texas 77704
Louisiana State University,
Government Documents Department
{
Louisiana Radiation Control Program Director
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Resident Inspector
R. D. Martin, RA
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GULF STATES
UTELETIES COMPANY .
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river SEND STATION
POST OFFICE 80x 220
ST FR ANCISvtLLE. LOUISIANA 70775
AREA CODE 504
635 6094
346 8651
August 29, 1986
RBG-
24275
File Nos. G9.5, G15.4.1
Mr. Robert D. Martin, Regional Administrator
U.S. Nuclear Regulatory Commission
Region IV
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Arlington, TX 76011
, yI5 O, .s
611 Ryan Plaza Drive, Suite 1000
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Dear Mr. Martin:
SEP - 41986 "; j
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River Bend Station - Unit 1
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Refer to:
Region IV
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Docket No. 50-458/ Report 86-20Y
This
letter
is
in
response
to
the
Notice
of Violation
contained
in
NRC
Inspection
Report
No.
50-458/86-20.
The
inspection
was
performed by Messrs. D. D. Chamberlain and W. B.
Jones
during
the
period
May
1
through
June
15,
1986,
of
activities
authorized
by NRC Operating License NPF-47 for River
Bend Station Unit No. 1.
Gulf States Utilities Company's (GSU) response to the
Notice
of
Violation
8620-01
and
8620-02
is provided in the enclosed
attachment.
This completes
GSU's
response
to
the
Notice
of
Violation.
Sincerely,
f
.
W. J. Cahill, Jr.
Senior Vice President
River Bend Nuclear Group
ca? #As
WJC/ ERG /RRS/ks
Attachment
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UNITED STATES OF AMERICA
EUCLEAR REGUIATORT CGAESSION
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STATE OF UMTISIAEA
5
FARISn OF WEST FILICIANA
5
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In the Matter of
I
Docket Bos. 50-458
OULF STATES UTILITIES CGIFANY
l
(River Bend Station,
Unit 1)
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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 Rggulatory
Coussis sion the documents attached hereto
and that all such documents
are true and correct to the best of his knowledge, information and belief.
W.
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 /7 day of duud ,198
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anW.Middlebloops
otary Public in and for
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West Feliciana Parish,
My Commission is for Life.
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ATTACHMENT
Response to Notice of Violation 50-458/8620-01
Level IV
FAILURE TO FOLLOW ADMINISTRATIVE PROCEDURES FOR ISSUANCE OF
TEMPORARY CHANGE NOTICES (TCN's)
REFERENCE:
Notice
of
Violation
Letter
to W. J. Cahill, Jr. from J. E.
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Gagliardo dated July 30, 1986.
REASON FOR ,THE VIOLATION
During an NRC inspection conducted on
May
1
through
June
15,
1986,
the
inspectors
identified
a
failure
to
follow
Administrative procedures.
As a result of
personnel
oversight,
Maintenance Technicians failed to comply with the procedural
requirements
of
Administrative
Procedure
.
(ADM)-0003,
" Development,
Control
and
Use
of
Procedures" when initiating
Temporary Change Notice No. 86-0581 for
procedure
STP-051-4210.
This
resulted
in .an
official
work
copy
of- the
procedure
containing duplicate page numbers with different Temporary Change
Notice (TCN) Numbers on each page.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
On
April
10,
1986,.orior to the NRC inspection, Memorandum No.
PAS-86-141 was issued identifying procedures
with
two
or 'more
TCN's
having
duplicate
pages
with
different
changes.
The
memorandum identified
the
deficiencies
with
STP-051-4210
and
requested that the faulty TCN's be corrected.
l
In response to Memorandum No. PAS-86-141, Procedure STP-051-4210,
Revision 2, was submitted for
revision
on
April
20,
1986
to
incorporate
the
outstanding
TCN's
and eliminate the duplicate
pages.
Revision 3 of STP-051-4210 was
approved
and
issued
on
July 30, 1986.
CORRECTIVE STEPS WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
The
I&C Procedure Coordinator reviewed the TCN deficiencies with
.
the responsible individuals and
instructed
the
individuals
to
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comply with
the requirements of ADM-0003 when initiating future
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TCN's.
Memorandum No. PIC-M-86-116 was issued on July 9, 1986 requesting
that
TCN's
issued
by
the I&C Maintenance Department be routed
through the I&C Procedure
Coordinator
prior
to
obtaining
the
Shift
Supervisor's
signature.
The I&C Procedure Coordinator is
responsible for reviewing TCN's being issued to assure compliance
with ADM-0003 and evaluates the necessity of the TCN.
The
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ATTACHMENT (Cont'd)
routing
of the TCN through the I&C Procedure Coordinator will be
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discontinued
when
the
number
of
TCN's
being
issued
is-
significantly reduced.
To prevent recurrence of similar violations, ADM-0003 was revised
on 8/6/86 to clarify procedural instructions for issuing a TCN to
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a page that has been previously changed by a TCN.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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STP-051-4210
was
revised
on
July
30, 1986 to incorporate the
outstanding TCN's and eliminate the duplicate pages.
River Bend Station is currently in compliance.
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ATTACHMENT (Cont'd)
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Response to Notice of Violation 50-458/8620-02
Level IV
FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY-
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REASON FOR THE VIOLATION
A walkdown of the
"C" Residual Heat Removal (RHR) system by
NRC
inspectors
identified
the
following differences between actual
system configurations and controlling
instructions,
procedures,
and
drawings:
1)
five
pipe
caps,
shown~ as
installed
on
Engineering, Piping _and
Instrument
Drawing
PID-27-C were
not
installed,
2)
valve
E12*MOVF064C,
which
was
shown closed on
Engineering, Piping and Instrument Drawing PID-27-7C was open, 3)
valve E12*VF063C was not locked, although Engineering, Piping and
Instrument Drawing PID-4-3C showed this valve to
be
locked,
4)
differences were found between Engineering, Piping and Instrument
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Drawing PID-27-7C and System Operating Procedure, SOP-0031, as to
which valves were locked in position.
Item 1
Investigations
to
determine
the
reason that the pipe caps are
missing, although shown
installed
on
Engineering,
Piping
and
Instrument Drawing, PID-27-7C, are indeterminate.
Item 2
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The
minimum
flow valve
E12*VF064C
was
placed
in
the
open
position, per the SOP-0031, however, PID-27-7C showed this
valve
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to be closed.
I
Item 3
Operations
personnel had previously performed an audit of locked
valves on the RHR system
and
determined
valve
E12*VF063C was
verified
to
be
closed,
but no lock was installed on the valve
because it was approximately twenty
feet
above
the
floor
and
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considered inaccessible.
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Item 4
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Operations
was aware of the differences between the two existing
system drawing types and the SOP's and
was
in
the
process
of
correcting
this
situation
by
revisions
to
the PID's and the
SOP's.
.The cause of these discrepancies was determined to be the
,
lack
of
configuration
management
programs to ensure procedure
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updates on the
issuance
of
changes
to
drawings
and
drawing
updates to reflect commitments to lock specific valves.
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CORRECTIVE STEP WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
The
five
missing pipe caps that are shown on PID-27-C have been
replaced.
Since valve E12*MOVF064C was in the proper position in accordance
with
SOP-0031
it
will
be left in this position (i.e., open to
allow minimum flow).
Valve E12*VF063C has been locked as shown on PID-4-3C.
Operations has revised the RHR SOP to agree with existing PID's.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
Nuclear Equipment Operators on rounds will take notice of missing
pipe
caps and replace them.
A supply of caps has been placed in
the Contrcl Room for this purpose.
Additionally, Local Leak Rate
Testing
(LLRT)
Procedures
will
include
a
step
to
ensure
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replacement of caps which are removed for
LLRT.
Nuclear
Plant
,
Engineering
(NuPE),
along
with Stone & Webster (S&W) is in the
process of determining which valve caps are required for a system
to meet its intended design.
,
PID's
will
be
revised
to indicate valve position for a normal
mode of operation, and Station Operation Manual (SOM)
procedures
will govern actual valve position.
A new
procedure,
Operation
Section
Procedure OSP-0014, which
directly addresses the control of locked valves has
been
issued
by the River 3end Operations Department.
A review of all PID's versus SOPS has been conducted.
Changes to
,
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the procedures have been issued
to
agree
with
the
PID's.
A
review of the PID's is being performed by NuPE to determine which
,
valves should be locked and which should be left unlocked.
NuPE
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will
also
develop
a'
procedure which will delineate the locked
valve regulation requirements.
Included in this review will
be
the necessary changes of PID?s to match these requirements.
Upon
,
completion, it is expected
this
will
decrease
the
number
of
l
l
valves required to be locked.
'
Adequate
configuration
management
control
procedures
are
currently in place.
All changes to locked valve status
will
be
followed by updates to the SOP's via these controls.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
The
additional
procedural controls ensuring replacement of pipe
caps in Local Leak Rate Testing Procedures will be
completed
by
October 30, 1986.
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ATTACHMENT (Cont'd)
Valve
E12*VF063C
has
been verified to be locked at the time of
this response.
Procedures being developed by NuPE for determining
locked
valve
regulation
requirements
will be completed by November 30, 1986.
The PID changes brought about by NuPE's reviews will be completed
by December ~31, 1986.
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