ML20213E539
| 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) | |
See also: IR 05000458/1986020
Text
,
.
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
bcc:
(see next page)
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bec to DMB (IE01)
bcc distrib. by RIV:
RPB
DRSP
Resident Inspector
R. D. Martin, RA
Section Chief (RPB/A)
D. Weiss, LFMB (AR-2015)
MIS System
RSB
RSTS Operator
R&SPB
RIV File
'
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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
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,
611 Ryan Plaza Drive, Suite 1000
,
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Arlington, TX 76011
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Dear Mr. Martin:
SEP - 41986
', _
River Bend Station - Unit 1
-
dO;
"
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. //
.-
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
otary Public in and for
West Feliciana Parish,
l
My Conunission is for Life.
1
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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.
-
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
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
the. responsible individuals and
instrucLad
the
individuals
to
i
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
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
'
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
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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Page 4
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.
i
Operations has revised the RHR SOP to agree with existing FID's.
!
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
'
A review of all PID's versus SOPS has been conducted.
Changes to
the procedures have been issued
to- agree
with
the
PID's.
A
i
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^
valve regulation requirements.
Included in this review will
be
will
also
develop
a
procedure which will delineate the locked
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
t
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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eg
GULF STATES
UTILETIES COMPANY
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
-
,
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
-
L
L.,. , 9//] L U L L /,
Joan W. Middlebrooks
Notary Public in and for
West Feliciana Parish,
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,
and
drawings:
1)
five
pipe
caps,
shown
as
installed
on
i
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
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.
(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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ATTACHMENT (cont'd.)
Page 3
f
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
control
this
list and to delineate the requirements for locking
,
valves.
Upon completion, this procedure
will
be
forwarded
to
"
Operations for implementation under OSP-0014.
!
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
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
Local Leak Rate Testing Procedures are in place.
i
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
andl
l
Loop Diagrams will be completed by December 31, 1986.
I
The review of PID's with respect to locked valve criteria and the
.
procedures controlling these locked valves will be
completed
by
!
November 30, 1986.
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ATTACHMENT (cont'd.)
Page 4
86-1587
concerning
pipe
caps
on
PID's
and
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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