RBG-23253, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-77.Corrective Actions:Fcn 19 Corrected & FCN 23 Prepared to Consolidate All Outstanding Design Changes

Responds to NRC Re Violations Noted in Insp Rept 50-458/85-77.Corrective Actions:Fcn 19 Corrected & FCN 23 Prepared to Consolidate All Outstanding Design Changes

ML20205M295
Person / Time
Site:	River Bend
Issue date:	02/26/1986
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20205M292	List: ML20205M288 RBG-23253, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-77.Corrective Actions:Fcn 19 Corrected & FCN 23 Prepared to Consolidate All Outstanding Design Changes
References
RBG-23253, NUDOCS 8604150165
Download: ML20205M295 (6)

Text

'

e 8

GULF STATES UTILITIES COMPANY river BEND STATION POST OFF6CE BOX 220 ST. FRANCISVfLLE, LOUISLANA 70775 ARE A CODE 504 635-6094 346-6651 February 26, 1986 RBG- 23253 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlingt?n, TX 76011 gg mv --

gg R

Dear Mr. Martin:

VW 3 GE t :

River Bend Station - Unit 1 k-~ Ib Refer to: Region IV Docket-No. 50-458/ Report 85-77 This letter responds to the Notice of Violation contained in NRC I&E Inspection Report No. 50-458/85-77. The inspection was conducted by Messrs. D. D. Chamberlain, W. B. Jones, R. P.

Mulliken, R. E. Farrell, and W. R. Bennett during the period October 31 through November 30, 1985 of activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No. 1.

Gulf States Utilities Company's (GSU) response to the Notice of Violation 85-77-01, " Failure of Design Control Program", is provided in the enclosed attachment. This completes GSU's response to the Notice of Violation.

Sincerely, f, /

. J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group yh>%)#nt vWJCfRJK/je Attachment 1

l l

%kND G

k 1

l I

l ATTACHMENT RESPONSE TO NOTICE OF VIOLATION 50-458/8577-01 LEVEL IV REFERENCE l

Notice of Violation - J. E. Gagliardo to W. J. Cahill, Jr. dated January 27, 1986. I REASON FOR VIOLATION j Field Change Notice (FCN) #19 to Design Modification Request (MR) 85-0397 was comprised of several individual change documents.

One of the change documents provided page 36 of the FCN which ,

l added the contacts 7/8 and 3/4 of switch 43B into the circuit.  !

Fage 57 of the FCN was issued on a separate change document and l l removed the contacts to reflect a change in the design to allow l l operation of the diesel from its local control panel during normal operation. The second change document issued was the third revision of that particular change. The preparer of the I first two revisions recognized that changes were being made to an l existing change document and it was identified that the change '

removing the contacts " supplemented" or replace the original design which had added them. However, during the preparation of the third revision, a change in the philosophy of " supplementing" previous design changes was made and this change document did not replace the original design. This was incorrect and was the I apparent result of a failure by the preparer to recognize the i contradicting information and the need to replace it. In addition, at the time the third revision was prepared the base initial Modification Request for that revision had been cancelled. .m such the entire change should have been combined under a revision to the original change document.

The illegibility of several pages of FCN #19 due to poor reproductive quality was the result of a need to continually supersede existing change documents to provide new design information. This was necessary since the original design changes had not yet been incorporated into the base drawing. The need to provide original design information capable of yielding legible results following multiple reproductions was not recognized.

I CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED FCN #23 to MR 85-0397 was prepared to censolidate all outstanding design changes for this MR into a single FCN. The contradicting information of FCN #19 has been corrected and is properly shown on page 170 of 208 of FCN #23. This FCN eliminates all outstanding documents against the cancelled MR. In addition, l steps were taken to ensure the legibility and reproducibility of l the original information.

ATTACHMENT (cont'd.)

Page 2 RBG- 23253 February 26, 1986 CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS.

! The personnel involved in the preparation of such MRs. and FCNs have reviewed the discrepancies identified in FCN #19 to MR 83-0397 at the time FCN #23 was prepared. In addition, specific direction on the methods of providing clear and accurate design information, including the preparation of preprinted forms for use in MRs and FCNs has 'been issued and discussed with each engineer (attached). This has resulted in a noted increase in ,

the clarity and legibility of the design information. ,

1

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.

l l

?  !

. .e f

l

////////////// ////// / // // / / / / / / /// / / / ' / / / / ./ / . -

/,/ '

W - E6 FGN

_ ___ _ _ PAE I

I I CF _

I  ! l

/

/ NUPC USC CMT ,

/- SwCC USE CNLY

/

/ E&DCR '_ _ _ _ _ _ _ _

/

/ PAT l OF THE E&DCR -

j/

/

/ owa.m. _ _ _ _ _ _ _ _ _ _ _ _ _ _

coue o _ _ _ _ _ _ _ _ _ _ _ _ cc w r. _ _

7 ,

,// .

/ '

[/

/ -

/ -

M x .

4 -

led ,

a < .

E I

W - -

a /

5 ,

e .

/

8 '

4

/

/

h,/

~

$m . . .. . .. ._

/ / / ll /'

,/

w-es _ _ _ _ nCz Ce /

FCN I I l l l l /

/

~ NUPC USE ONLv /

SmEC uSE CNLT

/

/ .

E&DCR _ _ _ _ _ _ - -. __

/

y PAGE OF THE E&OCR /

I

/

/

/

l BLOCK 8 CONTNlm ELOCK TI CONTNLED /

RtreftNCE DOCUENTS # AFFECTED DOCLMWTS k#1/ ',,

_l /

/ /

/

- - _ - . - _ _ _ = _ _ - . - - - _ _ _ _ - ______________

l

/. ______________ _____________- l /

/

/ ______________ ______________ ,

/

f.

_ __ ___________ _____________- /

, /

t

- . - - . - - - - . - - - . - - - - _ - - . _ - - - . - - - . - - - - . j

-- - - - - - - . - - = = - - . - - - - - - - - - . . - - -

2 4 /

Q

• h -- -- - - - - - - - - - - - - - -

3 I <

I - _____________ l w _ _ _ __________- # '

i 7

tk y

B _ _ _ ___________ _____________

/

s. / i Q #

2 . - - . - -

l

.------m- -m ----. .- .-m-- - - - - --n. - ---..-.m -.--..----.-..--.m /

Q '

Q / '

/

- - - - - - - - - . - = = - - . . - _

f:

_ -_ _ _ _ = _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = _ l,

/

l

_ _ _ _ _ _ _ _ _ _ _ ___ _ ________ ____ f f

_ _ _ _ _ _ _ _ _ _ _ __- _ _____________ p l /

_______.-____- I ,

l

/

____________- /

/

_ _ --- - . _ - - - - . - - - - - - - - -. p

/

. /

- _ - _ _ /

_ _ _ _ _ _ _ _ _ _ _ ___ _ _= _ _ _ _ _ _= _ _ _ _ _ _

a

- ---. - - - _ _ - - - - --- - - . - - - - - - . - - - - - . - - - - - - _ = = - - - - - . - . -

r'

\

o # *

• r

1. r * / / /////////'///

~. -

i

! . i s. ,

i 2l UNITED STATES OF AMERICA  !)

NUCLEAR REGULATORT C(NSEISSION )

i1

.I STATE OF LOUISIANA 5 i PARISE OF WEST FELICIANA $

In the Matter of 5 Docket Nos. 50-458 CULF STATES UTILITIES COMPANY l I (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 Rggulatory Commission the documents attached heretos and that all such documents )

are true and correct to the best of his knowledge, information and belief.

l ,

W Cahill, Jr. //

l Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this b day of h /ufri/,19 .

i .

/ .

'N l<f fL . ff k' W JoanW.Midd1'ebrojks l

Notary Public in and for l West Feliciana Parish, Louisiana i

My Commission is for Life.

-. - -- ,, . -. - - . . . .