ML20247H461
| ML20247H461 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/26/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| NUDOCS 8907310027 | |
| Download: ML20247H461 (2) | |
See also: IR 05000458/1989011
Text
y
.
.
.
.
,
.
U
' t
,
[. .
< -
-
..
1
,
.
,
Jtt 26 IIB
'
In Reply Refer To:
Docket: 50-458/89-11 .
'
,
Gulf States Utilities
ATTN: Mr. James C. Deddens
!-
. Senior Vice President.(RBNG)
P.O. Box 220
St. Francisville Louisiana 70775
Gentlemen:
Thank you for your letter of July 7,1989, in response to our letter and
Notice of Violation dated May 31, 1989. 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,
Original Signed By
James L Milhoan
James L. Milhoan, Director
Division of Reactor Projects
CC:
Gulf States Utilities-
ATTN:
J. E. Booker, Manager-
River Bend Oversight
P.O. Box 2951
Beaumont, Texas'.77704
Gulf States Utilities
ATTN:
Les England Director -
.
Nuciear. Licensing - RBNG
P.O. Box 220
-St. Francisville Louisiana '70775
Louisiana State University,
Government Documents Department
Louisiana Radiation Control Program Director
bectoDMB(IE01)
RIV:DRP/
C:DRP/C A4p
f
D:
JLMJha
I \\
GLMadsen
GLConstable
i
7/27/89
7/ay/89
7/:J/89
8907310027 890726
i
'
ADOCK 05000458
,
,
___ _____ f __
g
, _ _ _ _ _ - -
,
i
)
-
-
.
,
.
)
'
Gulf States Utilities
-2 .
i
bec distrib. by RIV-
RRI
R. D. Martin, RA
Section Chief (DRP/C)
Lisa Shea, RM/ALF
HIS System
a
RPB-DRSS
RSTS Operator
ProjectEngineer(DRP/C)
RIV File
W. Paulson, NRP, Project Manager (MS:
13-D-18)
1
i
i
J
-
i
i
!
i
!
I
L _ -_ _:_
_ - _ _ - _ _ _ _
-
-
.
..
, ..
.
3.
.
GULF STATES
UTILETIES
COMPAJ
}
~
\\
l
!
if.
V
lLg RI3S
f
L6
July
7, 1989
RBG- 31222
i
File Nos. G9.5, G15.4.1
U. S. Nuclear Regulatory Commission
Document Control Desk
Washington, D.C. 20555
Gentlemen:
River Bend Station - Unit 1
Refer to: Region IV
Docket No. 50-458/ Report 89-11
Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's
(GSU) response to the Notice of Violation contained in NRC Inspection Report
No. 50-458/89-11. The inspection was performed by Messrs. E. J. Ford and W.
B. Jones during the period of March 15 through April 30, 1989 of activities
authorized by NRC Operating Licensing NPF-47 for River Bend Station - Unit 1.
GSU's response to the violation is divided into two parts for the sake of
clarification and is provided in the attachments.
GSU will provide a
supplemental response to document the corrective actions taken by December
j
15, 1989.
]
i
Should you have any questions, please contact Mr. L. A. England at (504)
{
381-4145.
1
Sincerel ,
l
6-
/
J. C. Deddens
J
Sr. Vice President
River Bend Nuclear Group
/
/
f/WH0/TCC/gF
ch
Attachments
i
cc:
U. S. Nuclear Regulatory Commission
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
NRC Senior Resident Inspector
P. O. Box 1051
St. Francisville, LA 70775
%
$5Y(p Y Y"
0*
1
1
3
.
- _ - . - - - - - - .
.
.
' ,1
. . .
a
,
'.
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
STATE OF LOUISIANA
)
PARISH OF WEST FELICIANA
)
Docket No. 50-458
In the Matter of
)
GULF STATES UTILITIES COMPANY
)
(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.
I
h :::
J. C. D6ddens
Subscribed and sworn to before me, a Notary Public in
and
for
the
State
and
Parish
above named, this
Y
day of
(AlA)
19 d
.
My Commission expires with Life.
,
O
l
01a> & Aidwuct
Claudia F.
Hurst
Notary Public in and for
)
West Feliciana Parish, Louisiana
'
_ - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - -
- - __ - _- _
_
_ - _ _ _ _
. _ - -
4
.
N '.
3
,
ATTACFMENT 1
Response to Notice of Violation 50-458/8911-01A
1
A.
REFERENCE.
Notice of Violation - Letter from L. J. Callan to J.
C.
Deddens, dated
May 31, 1989
VIOLATION
Criterion XVI of Appendix B to 10CFR Part 50 requires that measures be-
established to assure that conditions adverse to quality are promptly
identified and corrected.
Quality Assurance Directive QAD-16
" Corrective Action," Section 4.3,
states that procedures shall require that corrective action be promptly
initiated and adequately documerted by the responsible department to
correct the condition and to determine if action is necessary to preclude
its recurrence.
River.-Bend Nuclear Procedure RBNP-0047, " Corrective Action Program,"
Section 5.4, requires that corrective action be promptly initiated and
adequately. documented- by the responsible department to correct the.
condition and to' determine if action 'is necessary- to preclude its
recurrence.
Contrary to the above, adequate corrective actions were not taken to
prevent repeat violations
of
Administrative
Procedure
ADM-0027,
" Protective Tagging."
During the period of March 18 through April 12,
1989, the licensee identified eleven procedural violations of ADM-0027.
The corrective actions taken did not determine the extent to which
protective tagging program violations existed.
REASON FOR VIOLATION
GSU has reviewed the associated protective tagging program condition
reports
(CR) stated in Inspection Report 8911 and other related CRs
initiated during the second refueling outage (RF2). GSU has reviewed the
chronology presented in the Inspection Report and finds it accurate. The
various problems identified from our review of CRs can be categorized
into four major areas:
1.
Individuals working without a clearance or a wrong clearance,
2.
Tagging boundaries were violated,
3.
Clearances were released without work being finished, or
4.
Crews began work on the wrong train.
Several
root ~ causes have been identified from GSU's review.
The
contributing
causes were attributed to poor communication between
Page 1 of 4
_ - _ _ _ - _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ .
- _ _ _ - _ _ _
__-_ - _
-.
_
_-
_ _ _ .
. - - _ - _ - - - _ _ _ _ - _ _ _ _ _ - -
.
..
, ~.
,.
,
"
contractor. work crews and their
supervisors,
contract
personnel
unfamiliarity with RBS plant design, and failure of contract personnel to
take adequate
to follow details
in RBS administrative
(ADM) precautions
procedure
-0027,
" Protective Tagging". GSU determined'the primary
I
cause was
inadequate training of contract personnel
to
ADM-0027
,
l
requirements.
In addition, the re-training provided as a corrective
action was not adequate to preclude future occurrences.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED
Numerous corrective actions were taken for each RF2 CR related to
protective tagging.
GSU took additional actions after recognizing that
previous corrective actions had not been adequate to prevent recurrence
of additional tagging violations.
Immediate corrective actions include:
1)
Contract personnel
responsible for the tagging violations were
i
l
re-trained,
2)
Tagging procedure @ M-0027) was revised,
3)
Additional " Tool Box" and formal classroom training was conducted,
,
4)
Individuals involved in violations were removed from the " Authorized
I
i
Requestor" list,
i
5)
GSU personnel were assigned to oversee and co-sign contractor
l-
clearances,
6)
A 100% review of open supplemental clearances and partial
reicases
as completed,
7)
GSU discontinued the use of supplemental clearances for RF-2,
-
l
8)
Operations Quality Assurance surveillance were increased for safety
and non-safety related work activities
for
review
of
work
documentation and tagging, and
9)
Tagging officials were retrained and instructed to give closer
l
attention to details prior to resuming duties.
1
The root causes mainly focused around contractor personnel events;
therefore, GSU believes the program implementation by GSU personnel is
satisfactory.
Supplemental clearances have been reinstituted, post
outage,
since the contractors involved are t.o longer performing work on
site. Contractors will not be allowed as holders of clearances under
ADM-0027 pending completion of task force review activities.
L
CRs are sent to a wide distribution, including but not limited to Quality
l
Assurance, Licensing, and the Independent Safety Engineering Group
(ISEG).
CRs are now reviewed and trended daily in accordance with a new
procedure, RBNP-052, " River Bend Station Trending Program", to determine
adverse trends. The recently developed and approved trending program is
designed to detect long term trends.
RBNP-0052 recommends that trend
I
reports be issued at six month frequencies.
Short term trends are
l
generally discovered through the various CR reviews and periodic trend
reports issued to RBS management (typically every 1-2 weeks).
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUTURE VIOLATIONS
l
Long term corrective action falls into two areas that are being addressed
'
separately.
Page 2 of 4
1
_ _ _ _ _ _ _ _ _ _ _ - _ - _ - -
_ - _ .
_
-
,
-
-.
__
- . - - -
_ __ _ _
V
.
.
.
g .K.
..
,.
'
A.
GSU will enhance the existing program with the following r.ctions:
,
,
1).
An upper tier River Bend Nuclear Procedure- (RBNP)
is being
developed to standardize root cause analysis based'on INP0 Good
Practice OE-907, " Root Cause Analysis".
2)
Training will be provided to all licensee personnel required to
provide root cause analysis for responses to condition reports
and other nonconformance documents.
3)
' Administrative Procedure,' ADM-0019, " Initiation and Processing
of Condition ; Reports" currently requires root cause analysis
under the following conditions:
a)
Conditions classified Quality Class I or QA Program
Applicable and result in significant conditions adverse to.
quality,
b)
Conditions reportable to the NRC, or
c)
Other conditions adverse to safety for which a ' root cause
determination is made
Additionally, all CRs are reviewed for potential deportability.
GSU also determines whether a root cause analysis is required
for selected CRs other than safety related conditions utilizing
the following guidelines:
-
a).
Conditions indicate repetitive problems,
b)
Conditions impact the reliability of the plant, or
c)
Conditions'have an impact on the safety of personnel or
the protection of equipment
This root cause determination effort will continue. The root
cause selection process will
be evaluated to determine its
effectiveness.
It is expected that the implementation of root
cause analysis, given sufficient review time, will
result in
effective and timelv corrective actions by GSU.
B.
The following actions for the ADM-0027 tagging program will be
perfomed:
1)
An RF-2 critique for lessons learned will be completed
2)
A task force will be developed to review the existing
tagging program considering:
a)
Use of supplemental clearances
(ALARA vs. safety
considerations)
b)
Differences between the RBS tagging program and the
GSU corporate program,
i
Page 3 of 4
i
_ _ _
- - - -
--
-
-
a
. _ .
.
.
<>u
. . -
.
.,
c)
A tagging' computer program will be evaluated for use
~
-
and recommendations will be provided to include
training,
d)
Tagging ' programs
in use at'other nuclear facilities
will be surveyed for recommended changes,
e)
Current tagging-.
forms
will-
be
reviewed
for-
simplification and improvement.
3)
-ADM-0027' may be revised based on the recommendations of
the task force.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
l
The RBNP to standardize root cause analysis will be approved by September
30, 1989. A supplemental response will be submitted by December 15, 1989
to document all corrective actions after Final Task Force actions are
identified.
l'
\\
-
1;
l
l
4
Page 4 of 4
- _ _ - -
_ _ - _ _ _ _ _ _ _ - _ - _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _
-__________-___-______________-_-______-________-_-_____A
.
l
.
.
...
. . .
,
ATTACFMENT 2
l
Response to Notice of Violation (NOV) 50-458/8911-018
l
B.
REFERENCE
Notice of Violation - Letter from L. J. Callan to J. C. Deddens, dated
May 31, 1989
VIOLATION
,
Criterion XVI of Appendix B to 10CFR Part 50 requires that measures be
established to assume that conditions adverse to quality are promptly
identified and corrected.
j
Quality Assurance Directive QAD-016, " Corrective Action," Section
4.3,
states that procedures shall require that corrective action be promptly
ini dated and adequately documented by the responsible department to
correct the condition and to determine if action is necessary to preclude
its recurrence.
River Bend Nuclear Procedure RBNP-0047, " Corrective Action Program,"
Section
5.4,
requires that corrective action be promptly initiated and
adequately documented by the responsible department to correct the -
condition and to determine if action is necessary to preclude its
recurrence.
Contrary to the above, corrective actions described in Licensee Event
Report (LER)87-029,
System Isolation Due to
Inadvertent Jumper Grounding," were not adequately documented in that no
procedural
changes were implemented to prohibit the practice of taping
together two short jumper wires rather than using a jumper of the
appropriate length.
As a result, the unit underwent a loss of shutdown
cooling for six minutes on April 27, 1989, when a taped jumper separated
during a surveillance test.
REASON FOR VIOLATION
To address the second part of NOV 8911-01, the corrective action stated
in Licensee Event Report (LER)87-029 included prohibiting the practice
of taping jumper wires together for use inside control room cabinets.
This corrective action would have been sufficient; however, no mechanism
was in place to ensure that the corrective action would remain intact.
As a result of this omission, on April
27,
1989, a second incident
involving the separation of taped jumper wires caused an electrical
transient inside a ' control room cabinet leading to a temporary loss of
residual heat removal (RHR) system shutdown cooling.
GSU determined the
root cause to be inadequate corrective actions to revise ADM-015,
" Station Surveillance Test Program", to ensure continued compliance.
Page 1 of 2
___-__
- _ _ - . - -
,
. .
- . . . 9
4. .
.
,
' CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED
'
Instrumentation -and Controls
(I&C) technicians were brie #ed about this-
incident and were cautioned to
exercise
care
while
performing
surveillance testing.
In addition, techniques for employing more secure
- test connections are being used within. the I&C Department to prevent
p
similar incidents.
While the unit was in mode 5, the RHR shutdown
'
cooling' isolation logic was removed to . prevent further isolations of
The logic was restored to service prior to draining
the upper fuel pools to'less than 23 feet above the top of the reactor
pressure vessel flange.
Temporary change notice (TCN) 89-0898 was issued and approved against
'ADM-0015.to prevent the use of taped jumpers as well. as alligator-type
clips on jumpers within the control room.
l
l
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUTURE VIOLATIONS
The TCN incorporated into ADM-0015 also requires a generic statement
concerning the use of taped jumpers and alligator-type clips be added to
all
I&C and electrical surveillance test procedures during their next
revision.
I&C and electrical
technicians will
receive training on
TCN 89-0898.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
'
.
I&C and electrical
technicians will receive training on TCN 89-0898 by
August 30, 1989.
I&C and electrical,
control
room
applicable,
surveillance test procedures (STPs) will be revised during their next two
,
year revision cycle by adding a generic statement on the use of secure-
'
test connections.
The revision cycle for all subject STPs ends during
July, 1991.
l
l
Page 2 of 2
i