ML20235T533

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/87-16

ML20235T533
Person / Time
Site:	River Bend
Issue date:	10/06/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8710130120
Download: ML20235T533 (2)

See also: IR 05000458/1987016

Text

- _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

J., 00T 6 - 1987

i

L.

In Reply Refer To:

Docket: 50-458/87-16

Gulf States Utilities

ATTN: Mr. James C. Deddens

Senior Vice President, (RBNG)

Nuclear Licensing

P. O. Box 220

St. Francisville, Louisiana 70775

Gentlemen:

Thank you for your letter of September 15, 1987, in response to our letter

and Notice of Violation dated August 13, 1987. We have reviewed your reply and

find it responsive to the concerns' raised in our Notice of Violation. We will

review the implementation of your corrective actions during a future inspection

to determine that full compliance has been achieved and'will be maintained.

Sincerely,

/s

J. E. Gagliardo, Chief

Reactor Projects Branch

cc:

Gulf States Utilities

ATTN: J. E. Booker, Manager-

River Bend Oversight

P. O. Box 2951

Beaumont, Texas 77704

Louisiana State University,

Government Documents Department

Louisiana Radiation Control Program Director

bec: (see next page)

i

f/

,

s

N .

PI g. .PB/k C:RPB

i

WRBenfieIt:cs JP audon JEGagli o

10/ / /87 10/1 /87 10/'L/ 7

8710130120 871006

PDR

G

ADDCK 05000458

PDR

i\

- _ _ _ _ _ _ _ - _

I

c i. . .s

l

,1

-2-

'

Gulf _ States Utilities

-i

bectoDMB(IE01) j

bec distrib. by RIV:

RPB DRSP i

Resident Inspector R. D. Martin, RA

SectionChief(RPB/A) D. Weiss, RM/ALF ]

MIS System RSB

RSTS Operator Project Inspector, RPB-

RPSB R. Hall

RIV File W. Paulson, NRR Project Manager

'

1

,

!

i

')

l

<

1

I

I

E_______-____-.___-___-_ _ _ _ _

i #

k'

GULF STATES UTILITIES COMPANY

RIVER DEND ST AflON POST OFFICE BOX 220 ST FRANCISVuf.LOUIStANA 70775

AR( A CODE 504 635 6094 346 8661

SEP 2 I ggy L

September 15, 1987 .

l l

RBG - 26628

File Nos. G9.5, G15.4.1

l

y

U.S. Nuclear Regulatory Commission

Document Control Desk

Washington, D.C. 20555

Gentlemen: {

River Bend Station - Unit 1

Refer to: Region IV i

Docket No. 50-458/ Report 87-16 l

l

This letter responds to the Notice of Violation contained in NRC

l Inspection Report No. 50-458/87-16. The inspection was performed by

Messrs. Chamberlain, Jones, Bennett, and Tapia during the period of

June 16 through July 31, 1987 of activities autho,rized by NRC

Operating License NPF-47 for River Bend Station.

1

Gulf Str.tes Utilities Company's (GSU) response to Notice of Violation

8716-01, " Failure of Followup Action", is provided in the enclosed

attachment pursuant to 10CFR2.201. This completes GSU's response to

this item.

S cerely

J. C. Deddens

Senior Vice President

River Bend Nuclear Group

JCD[E JIDf/ch

cc: U.S. Nuclear Regulatory Commission 4

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

l NRC Resident Inspector

P.O. Box 1051

St. Francisville, LA 70775

0N

zss

p4 &na Sr-

9

.rw) - _ - - - - -

-

,

Cb *, +

.

-(

UNITED STATES OF AMERICA

NUCLEAR REGUIATORY COMMISSION

STATE OF LOUISIANA )

PARISH OF WEST FELICIANA )

In the Matter of ) Docket No. 50-458

50-459

GULF STATES UTILITIES COMPANY )

(River Bend Station,

Unit 1)

I

AFFIDAVIT

J. C. Deddens, being duly sworn, states that he is a

Senior Vice President of Galf States Utilities Company; that I

1

he is authorized on the part of said company to sign and

file with the Nuclear Regulatory Commission the documents

j

attached hereto; and that all such documents are true and 1

correct to the best of his knowledge, information and

belief. )

l

i

-]J M_-

J.C.beddens

!

Subscribed and sworn to before me, a Notary Public in

and for the State and Parish above named, this / day of

nbG/17l')er , 19 EY.

.

- et , . 4 f% 7 i

Joan W. Middlebrooks

[#NotaryPublicinandfor

West Feliciana Parish,

Louisiana

My Commission is for Life.

- _ - _ _ _ - _ _ _ - _ - _ _

_

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

<

-l & '. . '

, ,

l

i

' ATTACEMENT

Response To Notice of Violation 50-458/8716-01

Level IV

1

REFERENCE:

-Notice of Violation - letter from J. E. Gagliardo to J. C. Deddens,

dated August 13,'1987.

FAILURE OF FOLLOWUP ACTION:

Criterion XVI of 10CFR Part 50, Appendix B and the licensee's approved . .

QA program requires that measures be established. to assure that

conditions. adverse to quality are promptly identified and corrected.

Quality Assurance Directive (QAD) 16, " Corrective Action," requires

appropriate departments to provide for timely followup reviews to

verify that specified corrective action has been properly implemented

and corrective action documentation has been closed out..

Contrary to the above, on June 30 and July 15 1987, respectively, it

was found that specified corrective action for NRC Violation

458/8531-01 and Deviation 458/8622-02 had .not been implemented.

Timely followup reviews had not been conducted to verify that

specified corrective action was properly implemented. Specifically,

corrective action for Violation 458/8531-01 included revisin's certain

surveillance test procedures by December 31, 1986, and this had not

been accomplished as of June 30, 1987. Also, corrective action for

Deviation 458/8622-02 included a commitment that operation of the

radioactive waste sludge tank sample collection system would commence

at the end of 1986. This sample collection system was- still not

operable as of July 15, 1987.

I

REASON FOR THE VIOLATION: 1

Preoperational- type A test procedure 1-PT-57-1 was issued and being .

3

used to conduct the Integrated Leak Rate Test, even though six  !

differential pressure instrument valves and one motor operated valve

which were required to be properly positioned were in fact not

included in the procedure's valve lineup. The valves were identified ,

during the performance of the test. Major Change Request (MCR) No.. 4 1

2

was issued to revise 1-PT-57-1 to add the missing valves to the

lineup. GSU in its response to Violation 8531-01 dated September 2, 1

1985 (RBG-22000) indicated that the valve lineup would be reverified

by September 16, 1985 and that the incorporation of changes into the 1

STP would be completed by December 31, 1986. Corrective action to

incorporate changes into surveillance test procedures' _ was not

completed as late as June 30, 1987. Subsequently, GSU submitted a

revised response (RBG-26189) requesting approval of a completion date

of December 31, 1987. j

!

l

'

i

i

4

_ _ - _ . . _ _ m m ___-__- -----

- - _ _ _ - _ _ _ _ - _ _ __

.

f6u

[ .This part of the _ violation was due to departmental management

5 oversight. Field Engineering, .until now, has had no-

intra-departmental method of tracking incoming correspondence, (i.e.,

due dates of commitments). Also, because the procedure is scheduled

to be performed during the second refueling outage (or about June,

1989), it received low priority.

GSU's response to Violation 8622-01 dated September 19.. 1986

(RBG-24432) _ indicated that the waste sludge tank installation is

complete with the~ exception of the sample collection system and system

testing. 'Also, it noted that.the engineering design was compler.e.with

operation on hold until the sample collection system equipnient is

delivered by the vendor and installed, and that installation of the

sample collection system is scheduled for completion by the' end of

this year (1986), with testing and operation to commence'thereafter.

This sample collection system was still not operable as of July 15,

1987, as outlined in the Notice of Violation.

The Isolok Sampler was installed in the system by the committed date,

December 31, 1986. Testing of the valve by the vendor. was completed'

by February. Testing of the tank itself was resumed but has had

further problems. Numerous problems have been encountered in the

Waste Sludge Pump, the tank level instrumentation, and the controller

logic circuit. GSU did not provide an updated response- to. the

deviation because it- was felt that the intent of the original

commitment was satisfied.

GSU has determined that the reason for the untimely corrective action

is due to a management failure to establish appropriate priority to

implement follow'up corrective action.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Field Engineering has implemented a Work Tracking System that includes

items such as NRC corrective actions. At the time the violation was

assigned, Field Engineering had no comprehensive method of tracking

incoming correspondence (such as due dates of commitments). This

"in-house" system, along with systems in place by other departments,

will alleviate the possibility of future occurrences similar to this

violation.

An FSAR change has been processed and submitted to the NRC in the USAR l

to clarify GSU's use of the Backwash Tank and sampling and analyzing {

for solid radioactive waste processing. This corrects the original

deviation.

The Senior Vice-President of Gulf States Utilities (GSU) Company River j

Bend Nuclear Group (RBNG) has established committed corrective actions

as one of the top priorities of River Bend Station. This direction

has been discussed directly with each Manager. Each Manager has ,

assigned department coordinators to assure prompt attention and high I

priority to corrective actioris (CA). Additionally, a task force was

]

I

_ _ _ _ _ _ u

_ _-_-

.

.

f .' , a

,

established to expedite delinquent actions by working with the various.

6 responsible departments to implement corrective. action in a timely

manner, establish a realistic date of completion for long term items,

maintain a status report to assist each department in resolving their

commitments in .the future, and review the commitment program for

recommended improvements. Overdue items identified by the task force

have been completed or submittals have been provided which contain

newly established completion dates.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIO,NS:

Field Engineering has established revised corrective action which has

been entered into the Field Engineering Work Tracking System. Future

corrective actions will also be tracked with this system.

For a period of approximately six months, the Compliance Department

has been assigned the task to track all commitments which are the

responsibility of Plant Staff. This is an in-house program which has

been very effective in notifying the responsible management personnel

of commitments which are near their due date. Based on establishment

of this tracking program, no further actions are required.

CSU Quality Assurance will followup with audits and/or surveillance

of corrective actions. This followup will provide additional

management attention and corrective actions to prevent recurrence of

any future breakdowns.

Monthly trend information is provided to Senior Management and will be

discussed at future staff meetings to assure continued management

attention is applied. Additionally, a refresher program will be  ;

provided for Managers and Coordinators to re-emphasize the purpose and 1

capabilities of the commitment tracking program. The program provides l

timely notification to the responsible managers of those commitments

made to the NRC that are coming due. In addition, the system can be  ;

accessed from any main frame based terminal within each department to j

determine the latest status of commitments. l

.

I

i

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Currently, there are no corrective actions with completion dates

provided to the NRC which are past due.

The Task Force is expected to continue its efforts through September

1987, or until GSU management is satisfied that corrective action

implementation is functioning satisfactorily.

!

L__-______-__ _ _ _ - _ _ _ ._