RBG-21985, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-19.Corrective Actions:All Errors Noted During Review of EE-340 Series Drawings Corrected Via Issuance of Engineering & Design Coordination Repts

Responds to NRC Re Violations Noted in Insp Rept 50-458/85-19.Corrective Actions:All Errors Noted During Review of EE-340 Series Drawings Corrected Via Issuance of Engineering & Design Coordination Repts

ML20133K951
Person / Time
Site:	River Bend
Issue date:	08/30/1985
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20133K949	List: IR 05000458/1985019 RBG-21985, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-19.Corrective Actions:All Errors Noted During Review of EE-340 Series Drawings Corrected Via Issuance of Engineering & Design Coordination Repts
References
RBG-21985, NUDOCS 8510220359
Download: ML20133K951 (5)

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M GULF STATES UTILITIES COMPANY RIVER SEND STATION POST OFFICE 80X 220 ST f RANCISVILLE LOUISIANA 70775 ARE A CODE 504 635 6094 346 8851 August 30, 1985 RBG- 21985 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Ccmnission Region IV 611 Ryan Plaza Drive, Suite 1000 '

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Arlington, Texas 76011 "

Dear Mr. Martin:

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River Bend Station - Unit 1 -

Refer to: Region IV Docket _No. 50-458/ Report 85-19 This is in response to the Notice of Violations contained in NBC I&E Inspection Peport No. 50-458/85-19. The inspecticn was perforTned by Mess-rs. I. Barnes and R. G. Taylor during the period March 11 - May 17,1985, of activities authorized by NRC Construction Permit CPPR-145 for River Bend Station Unit No. 1.

Gulf States Utilities Canpany's (GSU's) response to the Notice of Vio-lations 85-19-01, " Incorporation of E&DCR Information Into Drawings," and 85-19-02, "Use of External Historical Data in Evaluation of Suppliers," is provided in the enclosed attachment. This ccrnpletes GSU's response to the Notice of Violations.

Sincerely, W. J. Cahill, r.

Senior Vice President River Bend Nuclear Group

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1 ATTACHMENT August 30, 1985 RBG- 21985 Response to Notice of Violations Reference  !

-Notice of Violation - E. H. Johnson letter to W. J. Cahill dated August 1, 1985.

Refer to Docket No. 50-458/85-19 Response to 85-19-01 " Incorporation of E&DCR Information Into Drawings" Reason for the Violation

% e condition cited was caused by a series of events related to the check-ing process utilized for the drawings involved. During the preparation of the drawing revisions to incorporate the affected Engineering and Design Coordination Reports (E&DCRs), three individuals frm the Electrical Design Group were assigned to check the drawings. All of these individuals left the sploy of Stone & Webster Engineering Corporation (SWEC) prior to cm-pletion of the checking process and prior to placing their initials on the drawings as being responsible for checking. Wree additional individuals were then assigned to cmplete the checking process. These individuals did not adequately review the work perfomed by the previous checkers.

Corrective Steps Which Have Been Taken and Results Achieved A 100% review of all E&DCRs incorporated into the EE-340 series' drawings during the effort described above is ccmplete. 'All incorporation errors noted have been corrected via issuance of E&DCRs.

We individuals who took responsibility for the drawings' checking per-formed by those who left the ertploy of SWEC have been counselled to ensure

, that they thoroughly review work perfomed by others prior to placing their initials on the docment.

Corrective Steps Which Will Be Taken to Avoid Further Violations h e incorporation requirements for SWEC drawings prescribed in- River Bend Procedure (RBP) 12.0 do not mandate drawing revisions to incorporate E&DCRs until systerr. turnover to GSU or fuel load, h e effort to incorporate these E&DCRs prior to drawing transfer frm SWIr (Cherry Hill) to SWEC (Site Engineering Group) responsibility was unique. No other ' drawing revisions were being processed at that time. Therefore, it is GSU's position that the observed conditions were isolated and no further corrective steps are

necessary.

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Page 2 August 30, 1985 RBG- 21985 Date When Full Cmpliance Was Achieved Full cmpliance was achieved on June 28, 1985.

Response to 85-19-02 "Use of External Historical Data in Evaluation of Suppliers" Reason for the Violation The condition cited was caused by the failure to indicate a supplier as conditionally approved on the Qualified Suppliers List (QSL) when histori-cal data for that supplier showed quality programs which did not meet spec-ified requirenents.

Corrective Steps Which Have Been Taken and Results Achieved Transamerica Delaval, Inc. was audited by Systers Quality Assurance in July of 1985. As a result of progranmatic probles identified during this audit, a restriction has been placed on this supplier pending an acceptable corrective action response. Emergency purchases may be allowed on Quality Class I and QA program applicable items, but only when source surveillance is inposed in the procurement document.

A review of procurenent docunent files for the Guideline Instruments Cmpa-ny revealed that there has been no procurement activity with this supplier.

Additionally, it has been detennined that there is no projected procurement of services, thus this supplier has been downgraded to an inactive status.

Requalification of the supplier in the future shall require an audit or survey prior to approval.

An audit was scheduled for Hayward Tyler Pump Cmpany (HTP) in May of 1985.

IfrP informed GSU that they were in the process of ccmpletely revising their OA program for an upccming ASME re-certification and that their facility was in process of being physically relocated. Based.upon this notifica-tion, a restriction has been placed on this supplier for all procurement activities for Quality Class 1 and QA Program applicable itsns.

All current supplier files on the Qualified Suppliers List have been reviewed for similar conditions. Those with unsatisfactory performance history will be evaluated per Procedure OAI-2.4.

Corrective Steps Which Will Be Taken to Avoid Further Violations Procedures QAI-2.4 "OA Evaluation of Suppliers / Contractors OA Programs" and GAI-2.ll " Qualified Suppliers List" have been revised and issued for inple-mentation. The procedures were revised to specifically address the use of historical data (i'.e., other users' audits and surveys, NRC IE Bulletins and Notices, Vendor Programs Branch Inspection Reports, NUREG-0040) for initial qualification and annual evaluation of suppliers. 'Ihese procedures i

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August 30, 1985 RBG- 21985 provide specific direction as to appropriate action when historical data reflects an inadequate quality program.

Procedure OAI-2.4 now addresses use of this historical infonnation primari-ly for pre-award evaluation of suppliers. If'this history reveals unsatis-factory performance then the supplier will be surveyed per QAI-2.4 prior to approval.

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Date When Full Cm pliance Was Achieved Full empliance was achieved on August 19, 1985.

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA 5 PARISH OF WEST FELICIANA 5 In the Matter of I Docket Nos. 50-458 CULF STATES UTILITIES COMPANT 5 (River Bend Station, Unit 1)

AFFIDAVIT W. J. Cahill, Jr., 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 heretos and that all such docuraents are true and correct to the best of his knowledge, information and belief.

f J. Cahill, Jr. //  !

Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this C/Aday of dda Os f ,1986.

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. }Gr /C 6e an W. Middlebrooks bLbrf

/otaryPublicinandfor West Feliciana Parish, Louisiana My Commission is for Life. g L