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Ack Receipt of 860829 & 1017 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-20
	ML20213E539
Person / Time
Site:	River Bend
Issue date:	11/05/1986
From:	Gagliardo J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill; GULF STATES UTILITIES CO.
References
	NUDOCS 8611130209
	Download: ML20213E539 (2)
	v • d • e

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NOV 5 1986

In Reply Refer To:

Docket: 50-458/86-20

Gulf States Utilities

. ATTN: William J. Cahill, Jr.

Senior Vice President

River Bend Nuclear Group

P.-0. Box 220

St. Francisville, Louisiana 70775

Gentlemen:

Thank you for your letters, dateo August 29, 1986, and October 17, 1986,

in response to our letters, dated July 30, 1986, and September 16, 1986. We

have no further questions at this time and will review your corrective action

during a future inspectio'n.

Sincerely,

-cornai nma dy:

1. r_ H A t. L*

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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GULF STATES UTELETIES COMPANY ,

river BEND STATION Post OFFICE BOX 220 $7 FR ANCISVlLLE. louts 4ANA 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 Adntinistrator

U.S. Nuclear Regulatory Commission

Region IV t

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611 Ryan Plaza Drive, Suite 1000 j 1:, y tf. t :

Arlington, TX 76011

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Dear Mr. Martin: SEP - 41986 ', _

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River Bend Station - Unit 1 -

Refer to: Regicn IV -

Docket No. 50-458/ Report 86-20

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,

.

W. J. Cahill, Jr.

Senior Vice President

River Bend Nuclear Group

GP 6?S

WJC/ ERG /RRS/kn

Attachment

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UNITED STATES OF AMERICA

BUCIAAR REGUIATORY Ct3 MISSION

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STATE OF IRISIAEA 5

FARISE OF UEST FELICIANA l .

In the Matter of $ Docket Boe. 50-458

CULF STATES UTILITIES CtBIFARY I

(River Bend Station,

Unit 1) .

AFFID&VIT

W. J. Cahill, Jr., beins 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 heretos 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 dead ,19&. l

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anW.Middlebloops I

otary Public in and for

West Feliciana Parish,

Louisiana l

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My Conunission is for Life. l

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ATTACHMENT

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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.

Gagliardo dated July 30, 1986.

'

REASON FOR THE VIOLATION

l 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,

, I&C Maintenance Technicians failed to comply with the procedural

requirements of Administrative Procedure (ADM)-0003,

" Development, Control and Use of Procedures" when initiating

i Temporary Change Notice No. 86-0581 for procedure STP-051-4210.

This resulted in an official work copy of the procedure

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containing duplicate page numbers with different Temporary Change

Notice (TCN) Numbers on each page.

i

) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS' ACHIEVED

On April 10, 1986, prior 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

j requested that the faulty TCN's be corrected.

i In response to Memorandum No. PAS-86-141, Procedure STP-051-4210, .

l Revision 2, was submitted for revision on April 20, 1986 to !

l 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

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the. responsible individuals and instrucLad the individuals to

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comply with the requirements of ADM-0003 when initiating future

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

l through the I&C Procedure Coordinator prior to obtaining the

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Shift Supervisor's signature. The IEC Procedure Coordinator is

i responsible for reviewing TCN's being issued to assure compliance

l 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

discontinued when the number of TCN's being issued is

significantly reduced.

] To prevent recurrence of similar violations, ADM-0003 was revised

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on 8/6/86 to clarify procedural instructions for issuing a TCN to

a page that has been previously changed by a TCN.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

'

STP-051-4210 was reviied 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)

Response to Notice of Violation 50-458/9620-02

Level.IV

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FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY

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

Drawing PID-27-7C and System Operating Procedure, SOP-0031, as to

which valves were locked in position.

Item 1

Investigaticns 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

The minimum flow valve E12*VF064C was placed in the open

position, per the SOP-0031, however, PID-27-7C showed this valve

to be closed.

Item 3

Operations personnel had previour,1y 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

considered inaccessible.

Item 4

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

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).

i

Valve E12*VF063C has been locked as shown on PID-4-3C.

Operations has revised the RHR SOP to agree with existing FID's.

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

Nuclear Equipment Operators on rounds will take notice of missing

.

pipe cape and r? place them. A supply of caps has been placed in

l the Control Room for this purpose. Additionally, Local Leak Rate

! Testing (LLRT) Procedures will include a step to ensure

i replacement of caps which are removed for LLRT. Nuclear Plant-

l Engineering (NuPE), along with Stone & Webster (S&W) is in the

process of determining which valve caps are required for a system

j

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.

1 .

A new procedure, Operation Section Procedure OSP-0014, which

directly addresses the control of locked valves has been issued

i by the River Bend Operations Department.

J

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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

l^ 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

valves required to be locked.

j 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,

i

i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

l The additional procedural controls ensuring replacement of pipe

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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 devel5 ped 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

iby December 31, 1986.

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GULF STATES UTILETIES COMPANY

eg

RIVER BEND STAYtON POST OFFICE 80x 220 St FRANCISvtLLE. LOutslANA 70776

ARE A CODE 604 635 6094 346-8651

October 17, 1986

RBG- 24583

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, TX 76011

Dear Mr. Martin:

River Bend Station - Unit 1

Refer to: Region IV

Docket No. 50-458/ Report 86-20

This letter is in supplemental 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) supplemental response

to the Notice of Violation 8620-02, " Failure to Control

Activities Affecting Quality", is provided in the enclosed

attachment. This completes GSU's response to the Notice of

Violation.

Sincerely,

,

W. J. Cahill, Jr.

Senior Vice President

River Bend Nuclear Group

.

Attachment .

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OCT 231986

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UNITED STATES OF AMERICA

BUCLEAR EEGULATORY CCESEISSION

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STATE OF IAUISIAEA 5

FARISE OF WEST FELICIAEA 5

In the Matter of I Docket Bos. 50-458

GULF STATES UTILITIES C(EEFANY $

(River Bend Station,

Unit 1) .

AFFID&VIT

W. J. Cahill, Jr., being duly sworn, states that he is a Senior

Vice President of Gulf States U' 111 ties 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 Cahill, Jr.

..

Subscribed and sworn to before me, a Notary Public in and for the

State and Parish above named, this /8 ,

day of #MM , 19ffe,.

Q 9//] L U L L /,

-

L L.,. ,

Joan W. Middlebrooks

Notary Public in and for

West Feliciana Parish,

Louisiana

My Commission is for Life.

_. . . -- - _ - - - - - . _ _ . .- . . - . _ . _ - _ _ . _ . - - . - . . _ - - _ _ _ _ . - . - _ _ .

. . .

,

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ATTACHMENT

Response to Notice of Violation 50-458/8620-02

Level IV

FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY

REFERENCE

Notice of Violation - Letter to W. J. Cahill, Jr. from J. E.

Gagliardo dated July 30, 1986.

Request for supplemental information - Letter to W. J. Cahill,

Jr. from J. E. Gagliardo dated September 16, 1986.

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,

i

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

PID-27-7C was open, 3) valve E12*VF063C was not locked, although

PID-4-3C showed this valve to be locked, 4) differences were

found between 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 PID-27-7C are indeterminate.

.

Item 2

The minimum flow valve E12*VF064C was placed in the open

position, per the SOP-0031, however, PID-27-7C showed this valve

to be closed.

4

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 *

considered inaccessible.

Item 4

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

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ATTACHMENT (cont'd.) Page 2

lack of configuration management programs to ensure procedure

updates on the issuance of changes to drawings and drawing

updates to reflect commitments to lock specific valves.

,

CORRECTIVE STEP WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

4

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).

I 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 Control Room for this purpose. Local Leak Rate Testing

(LLRT) Procedures include a step to ensure replacement of caps

which are removed for LLRT. GSU Design Engineering, along with

Stone & Webster (S&W) is in the process of determining which pipe

caps are required for a system to meet its intended design.

A new procedure, Operation Section Procedure (OSP) -0014, " Control

of Locked Valves and Devices", which directly controls locked

valves and other devices required to be locked has been issued by

'

the Operations Department.

GSU Design Engineering has initiated two Modification Requests

(MR's), Nos. 86-1587 and 86-1588, to add notes to the PID's

concerning valve position and pipe caps. A note will be added to

PID's stating that valve positions shown on the PID's are for the

l

normal mode of operation and are for information only. The valve

positions indicated by the PID's are not to be used for actual

valve lineups. Station Operation Manual (SOM) procedures will

govern actual valve position. Another note on the PID's will

state that pipe caps are not required for system operability.

Any exceptions to this note will be identified on the PID. .

I

A review of PID's against Flow Diagrams (FSK's) and Loop Diagrams

by S&W began in January 1986. This review identified

discrepancies in these drawings. MR's were initiated to resolve

,

these discrepancies in accordance with existing design control

procedures. This initial review has been completed, however, all

l MR's have not been closed. Ninety-Five (95) MR's were identified

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that affect PID's. Design Engineering will conduct a survey of a

10% sample of safety related PID's to verify the effectiveness of

the S&W review. If additional discrepancies are identified, an

MR is processed in accordance with NuPE-AA-0054, " Guidelines and

Instructions for Processing Modification Requests".

PID's will be reviewed and revised to include locked open and

i locked closed designations for those valves which must be locked

because of regulatory requirements. A list of locked valves will

be generated and a Design Engineering procedure developed to

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control this list and to delineate the requirements for locking

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valves. Upon completion, this procedure will be forwarded to

Operations for implementation under OSP-0014.

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The criteria will divide locked valves into two groups:

regulatory required locked valves and administrative required

locked valves. Regulatory required locked valves are those

valves that must be locked in accordance with regulatory

requirements. Administrative required locked valves are those

which, at the discretion of the River Bend Operations Department,

must be locked for safety considerations or other administrative

reasons.

Overall, it is anticipated that this review process and the

establishment of the locked valve criteria will reduce the number

of required locked valves.

i

A review of PID's versus SOP's has been conducted. Changes to

the procedure have been issued to agree with the PID's. Adequate

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configuration management control procedures are currently in

,

place, and 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 procedural controls ensuring replacement of pipe caps in l

i

Local Leak Rate Testing Procedures are in place.

Valve E12*VF063C has been verified to be locked at the time of

this response.

MR's issued to correct discrepancies between PID's and FSK's

l Loop Diagrams will be completed by December 31, 1986. andl

I The review of PID's with respect to locked valve criteria and the

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procedures controlling these locked valves will be completed by

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November 30, 1986.

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ATTACHMENT (cont'd.) Page 4

MR 86-1587 concerning pipe caps on PID's and MR 86-1588

concerning valve position will be completed by December 31, 1986.

The Design Engineering survey of safety related PID's will be

completed by December 1, 1986.

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ML20213E539

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