ML20247D466
| ML20247D466 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/11/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8909140267 | |
| Download: ML20247D466 (2) | |
See also: IR 05000458/1989027
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SEP l'l 1989
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In. Reply' Refer"To:.
Docket:- 50-458/89-27
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Senior'Vice' President'(RBNG)
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Gentlemen:
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1Thank you for your letter of August 11,1989, in response to our letter and
Notice of: Violation dated July 17, 1989. We understand,-as discussed with;'
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your Mr.' Rick King during a' telephone call on August 29, 1989, that
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comparison'of the expanded unrevi_ewed safety question.conmittee' database-
'against the list of unreviewed safety question ' determinations '(USQDs) will .
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- address"all previous USQDs, with review by the' Facility Review CommitteeLand'
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the' Nuclear _ Review Board as required.
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We'will' review the implementation of your corrective actions during a future '
= inspection to determine'that full compliance has'been achieved and.will be1
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Sincerely,
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C%inalsigned sy:
Thomas P.Gwynn
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James L. Milhoan, Director-
Division of Reactor Projects
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ATTN:
J. E. Booker, Manager-
River Bend Oversight
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August 11, 1989
RBG-31351
File Nos. G9.5, G15.4.1
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U. S. Nuclear Regulatory Commission
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Gentlemen:
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River Bend Station - Unit 1
Refer to: Region IV
Docket No. 50-458/89-27
Pursuant to 10CFR2.201, this letter provides Gulf States Utilities
Company's (GSU) response to the Notice of Violation for NRC Inspection
Report No.
50-458/89-27. The inspection was performed by Messrs. W.
M. McNeill and D. L. Kelley during the periods of June 5-9 and 19-23,
1989 of activities authorized by NRC Operating License NPF-47 for
River Bend Station - Unit 1.
GSU's response to the violation is
provided in the attachment. GSU's response to this item ,is complete.
Should you have any questions, please contact Mr. L. A. England at
(504) 381-4145.
Sincerely,
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J. C. Deddens
Senior Vice President
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River Bend Nuclear Group
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Attachment
cc: U. S. Nuclear Regulatory Commissicn
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
Senior Resident Inspector
P.O. Box 1051
St. Francisville, LA 70775
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UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
STATE OF LOUISIANA
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PARISH OF WEST FELICIANA
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Docket No. 50-458
In'the Matter of
)
GULF STATES UTILITIES COMPANY
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(River Bend Station - Unit 1)
J.
C.
Deddens,
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 Regulatory Commission the documents
attached
hereto;
and
that
all such documents are true and correct to.
the best of his knowledge, information and belief.
.
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J. CT Deddens
Subscribed and sworn to before me, a Notary Public in
and
for
the
State
and
Paris.h
above named, this ,_//'
, day of
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My Commission expires with Life.
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Hurst
Not.*.ry Public in and for
West Feliciana Parish, Louisiana
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ATTACIMENT
RESPONSE TO NOTICE OF VIOLATION 50-458/8927-01
LEVEL IV
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REFERENCE
Notice of Violation - Letter from J. L. Milhoan to
J.
C.
Deddens, dated
July 17, 1989.
FAILURETOREVIEWSAFETYQUESTIONSASSOCIATEDWITHMODIFICATIOM
Technical
Specifications
(TS) Section 6 established the requirements for
the FRC and NRB and the requirements for these groups to review various
'
activities.
Section
6.5.1.6 requires FRC to be responsible for review of
all modifications to structures, components, systems, or equipment that
l
affect nuclear safety. Section 6.5.3.7 requires NRB to be responsible for
the review of safety evaluations for changes to equipment or systems
completed under the provision of 10CFR50.59 to verify that such action did
not constitute an unreviewed safety question.
Contrary to the above, the FRC and NRB had not reviewed the activities
required by TS.
FRC reviewed only 12 modification requests (MRs) of a
sample of 19 facility changes described in the 1987-1988 annual
report.
NRB reviewed only 17 safety evaluations associated with the same
sample of changes identified above.
REASON FOR THE VIOLATION
Regarding the FRC, the River Bend Station Safety Analysis Report (SAR),
paragraph 13.4.1.5 stated,
"The FRC is responsible for ... review of all
proposed permanent modifications to safety-related structures, systems, and
l
components."
" Safety Evaluation Report related to the
,
Operation of River Bend Station," section
13.4.1,
" Facility
Review
)
Committee," concludes "The FRC responsibilities also cover the appropriate
1
area of responsibility." Administrative Procedure (ADM)-0002, " Charter of
l
the
FRC,"
fn section 5.11.4 states, "The FRC is responsible for the ...
I
review of all
proposed changes to structures, components, systems or
equipment that affect nuclear safety." To date, the FRC has only reviewed
3
those modifications that are classified as safety-related.
A memorandum
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issued in August 1985 by the FRC Chairman and the Plant Manager stated,
"Unless specifically requested by the Plant Menoger,
the FRC need not
review non-safety related charges, changes to the fire protection systems,
or changes to the radwaste systems."
Regarding the NRB, until August 1987, an unreviewed safety question
determination (USQO) was performed on all MRs. At that time, the Initial
!
Safety and Environmental Evaluation (ISEE) program was initirted to answer
appropriate screening questions to determine
if a USQD is required in
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accordance with 10CFR50.5?.
The 10CFRSC.59 safety
evaluations
for
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permanent plant modifications are reviewed by the Unrev f wed Safety
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Question Committee (USQC). The USQC is appointed by the Nuclear Review
Board (NRB) to conduct the post-reviews required by Technical Specification , (TS) 6.5.3.7.
The USQC is comprised of members from the Independent Safety
Page 1 of 2
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$ngineering Group (ISEG). The NRB chartered the USQC during initial plant
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start-up in late 1985.
Subsequently, a number of changes have been
implemented
in the MR process.
As the USQC. became aware of the
implications of these programmatic changes,.the USQC review methods were
also changed.
For example, the USQC Chairman requested Design Engineering
to send the USQC copies of Field Change Notices-(FCN) to MRs and USQDs, as
well as,
initial MRs.and USQDs. . This was done to ensure that changes and
revisions to MRs did not invalidate the 10CFR50.59 reviews contained in the
USQDs.
This request was made when it was realized that review of FCN and
USQD revisions were not included in the.USQC's original methods. . Evidence-
exists that the USQC has reviewed a significant majority of completed MRs
with USQDs.
The root cause for the violation was the lack of USQC reviews of FCNs and
USQD revisions early in River Bend Station's operating history and a
defined responsibility in the RBS SAR for FRC review to be different than
the inspectors inspection criteria. The failure to perform a 100 percent
review'of USQDs was due to the evolving nature of the MR program.
CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
Of'the 19 facility changes described in the 1987-1988 annual
report, GSU has found that eleven were reviewed and approved by the FRC.
The remaining eight modifict. tion requests (MRs) were either classified as
non-safety related or did not result in a physical modification of the
plant.
The USQC has commenced efforts to ensure its computerized database of
reviewed documents is up-to-date. This includes the entry of all documents
reviewed and listed in USQC meeting minutes prior to June 1988.
CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
ADM-0002, " Charter of the FRC," will be modified to. include the review of
all proposed changes or modifications to structures, components, systems or
equipment, changes to procedures, or tests and experiments described in the
USAR which results in an USQD performed in accordance with 10CFR50.59 to
the responsibility of the FRC.
Reference to the reviewed USQDs will
be
noted in the FRC meeting minutes and sent to the USQC Chairman for the
RM/USQC review in accordance with TS 6.5.3.7.
The expanded USQC database will be compared to the list of sli USQDs for
Ws .
Any USQDr. which have not received a USOC review will be reviewed in
accordance with TS 6.5.3.7.
Use of a task force for this will be
,
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considered if the increase in USQC workload causes a significant impact on
other ISES duties.
DAl'E WHEN FULL COMPLIANCE WILL BE ACHIEVED
A0M-0002 will be revised by September 30, 1989.
The USQC database update will be completed by October 31, 1989.
The USQC review of backlogged USQD's of unreviewed MRs will be completed by
December 15, 1989.
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