ML20235T533
| 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
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J.,
00T 6 - 1987
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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
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GULF STATES
UTILITIES COMPANY
RIVER DEND ST AflON
POST OFFICE BOX 220
ST FRANCISVuf.LOUIStANA 70775
AR( A CODE 504
635 6094
346 8661
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September 15, 1987
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RBG - 26628
File Nos. G9.5, G15.4.1
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U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, D.C. 20555
Gentlemen:
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River Bend Station - Unit 1
Refer to: Region IV
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Docket No. 50-458/ Report 87-16
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This letter responds to the Notice of Violation contained in NRC
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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
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cc:
U.S. Nuclear Regulatory Commission
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611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
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NRC Resident Inspector
P.O. Box 1051
St. Francisville, LA 70775
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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)
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J.
C.
Deddens,
being
duly sworn, states that he is a
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Senior Vice President of Galf States Utilities Company; that
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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.
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J.C.beddens
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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.
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et ,
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[#NotaryPublicinandfor
Joan W. Middlebrooks
West Feliciana Parish,
My Commission is for Life.
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ATTACEMENT
Response To Notice of Violation 50-458/8716-01
Level IV
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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.
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REASON FOR THE VIOLATION:
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Preoperational- type A test procedure 1-PT-57-1 was issued and being
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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..
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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,
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1985 (RBG-22000) indicated that the valve lineup would be reverified
by September 16, 1985 and that the incorporation of changes into the
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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.
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.This part of the _ violation was due to departmental management
oversight.
Field
Engineering,
.until
now,
has
had
no-
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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
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to clarify GSU's use of the Backwash Tank and sampling and analyzing
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for solid radioactive waste processing. This corrects the original
deviation.
The Senior Vice-President of Gulf States Utilities (GSU) Company River
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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
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assigned department coordinators to assure prompt attention and high
priority to corrective actioris (CA). Additionally, a task force was
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established to expedite delinquent actions by working with the various.
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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
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capabilities of the commitment tracking program. The program provides
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
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determine the latest status of commitments.
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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.
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