RBG-23262, Submits Supplemental Response to Violations Noted in Insp Rept 50-458/85-69.Corrective Actions:Procedure Revised to Control Engineering Activities for Handling Mod Requests. Training of Personnel Commenced on 851209

Submits Supplemental Response to Violations Noted in Insp Rept 50-458/85-69.Corrective Actions:Procedure Revised to Control Engineering Activities for Handling Mod Requests. Training of Personnel Commenced on 851209

ML20210D262
Person / Time
Site:	River Bend
Issue date:	02/27/1986
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20210C976	List: IR 05000458/1985069 RBG-23262, Submits Supplemental Response to Violations Noted in Insp Rept 50-458/85-69.Corrective Actions:Procedure Revised to Control Engineering Activities for Handling Mod Requests. Training of Personnel Commenced on 851209
References
RBG-23262, NUDOCS 8603260391
Download: ML20210D262 (6)

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GULF STATES UTILITIES COMPANY river SEND STATION POST OFFICE 80X 220 ST. FA ANCISVILLL LOUISIANA 70775 AREA CODE 604 635 6094 346 8651 February 27, 1986 RBG- 23262 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV ,

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611 Ryan Plaza Drive, Suite 1000 j Arlington, TX 76011 t WDR - 5 tE6 -

Dear Mr. Martin:

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b River Bend Station - Unit 1 ,

Refer to: Region IV Docket No. 50-458/ Report 85-69 This supplemental letter responds to the Notice of Violation contained in NRC I&E Inspection Report No. 50-458/85-69. The inspection was performed by Messrs. D. D. Chamberlain, W. B.

Jones and R.P. Mullikin during the period September 16 through October 31, 1985 of activities authorized by NRC Operating License NPF-40 for River Bend Station Unit No. 1.

Gulf States Utilities Company's (GSU) supplemental response to the Notice of Violation 85-69-01, " Failure of Document Control Program" and 85-69-02, " Improper Use of a Field Change Notice (FCN) " , are provided in the enclosed attachment. This completes GSU's response to the Notice of Violation.

Sincerely,

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. J. Cahill, Jr.

Senior Vice President

-River Bend Nuclear Group WJC/ K/RRS/je Attachment i

B603260391 860311  !

PDR ADOCK 05000458 O PDR fc.-033 %

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UNITED STATES OF AMERICA BUCLEAR REGULATORY C(BSEISSION ,

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STATE OF IDUISIAEA 5 PARISR OF WEST FELICIAMA I In the Matter of I Docket Nos. 50-458 GULF STATES UTILITIES C(RIPANY l .

(River Bend Station, Unit 1)

AFFIDAVIT W. J. Cahill, Jr., being duly sworn, states that he is a Senior Vice President of Culf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear Rggulatory Consnis sion 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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A W. ahill, Jr. [

Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this MY day of [ J/7(df/,19h.

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Joan W. Middleprooks Notary Public in and for West Feliciana Parish, Louisiana My Commission is for Life.

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ATTACHMENT Response to Notice of Violation Severity Level IV Reference Notice of Violation - L. E. Martin letter to W. J. Cahill, Jr. dated November 19, 1985.

Request for additional information - J. E. Gagliardo letter to W. J.

Cahill, Jr. dated January 29, 1986.

Refer to Docket No. 50-458/85-69.

Reason for Violation A. On October 18, 1985, it was discovered that approved Modification Request (MR) design packages and approved Field Change Notices (FCN) had not been posted against affected design documents, and they had not been distributed to document control stations. For example, FCN 85-0397-19 was not posted against drawing 12210-ESK-5 ENS 06, and it was not available at the document control stations. Several other examples of the failure to post and distribute MRs and FCNs were noted. GSU determined the cause to be a result of insufficient guidance'on transmitting FCN's to the holder of the. design data base for posting and distribution.

Corrective Steps Which Have Been Taken and the Results Achieved Procedure NPE-3-006 (River Bend Station Design and Modification Request Control Plan) was supplemented by issuance of an- Interim Procedure Change IPC-3-006-2-2 on December 12, 1985. A revision to the Nuclear Plant Engineering (NuPE) procedure NuPE-AA-54 (Guidelines and Instructions for Processing Modification Requests) was issued December 4, 1985. This procedure controls River Bend Station's (RBS) engineering activities for handling MR's and, in conjunction with NuPE-AA-59, is used to ensure that the holder of the design data base is notified of design modifications and that RBS's Change Control Document Reporting System (IS-217 Report) is updated to list these changes against the affected documents.

NuPE-AA-59 (Updating and Distributing Design Documents) was revised and issued November 22, 1985. The revision to NuPE-AA-54 includes more detailed instructions for completing the MR and routing of same. In addition, this revision has a mandatory requirement that a computer data input form be completed and included as a numbered page of all MR's. This data input form

contains spaces which correspond to the input fields in the IS-217 Report~ referenced above. The location of this input form within the MR is identified on the MR Cover Sheet; it is normally the second sheet in the MR document. All documents affected by the MR are consolidated and listed on this input form. A similar practice has also been adopted for Field Change Notices .(FCN's) .

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Page 2 RBG- 23262 February 27, 1986 Upon approval of an MR or FCN by NuPE, the following occurs:

1 - A copy is forwarded to the field for-implementation.

2-A copy if formally transmitted to the holder of the design data base for updating the IS-217 Report and for making distribution to document control stations.

3-A copy is now forwarded to the control room document station for immediate posting via " redlining" the IS-217 Report.

Prior-to transmitting the change documents'to the holder of the design _ data base an internal review is performed by the NuPE Design Control Coordinator to ensure that procedural requirements (including completion of the IS-217 data input form) are-adhered to.

In addition to redlining the IS-217. Report, a verification is performed by the control room document station clerical supervisor to ensure that MR's or FCN's are included in subsequent issues of the report. This practice will continue until it has been demonstrated that change documents are posted in the appropriate manner.

A condensed IS-217 Report is now being issued which lists only the change documents which are required to be incorporated into a given affected document (i.e., information only changes are not included). This report is intended to reduce the information which must be considered to only those changes which have~ impact on the documents.

Administrative changes have been implemented by -NuPE and the holder of the design data base to reduce the time between design change approval and posting against the affected. documents. For example, the staff responsible.for updating the IS-217 Report has been relocated to an area immediately adjacent to the group responsible for design- control interface between GSU and the design data base holder. Initial surveillance indicates that the time lag between approval of the design modification and posting. I against the affected documents has been reduced significantly. I A 100% audit of the MR files, -which includes FCN's, has been conducted to determine if cases similar to those cited in this notice _ exist. Some additional discrepancies were ' discovered and steps have been taken to resolve them. However, all of these deficiencies occurred prior to issuance of the revised procedure, indicating that the above actions have-precluded the recurrence of similar events.

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Corrective Action-to Prevent Recurrence In addition to the actions implemented above, training of all Nuclear Plant Engineering Personnel responsible for completing or handling MR's and FCN's began December 9, 1985 and will continue with retraining as procedures are revised. l Also, verbal instructions have been provided as necessary by cognizant individuals on a continuing basis since such activities l began. j l

Quality Assurance surveillance conducted and . documented during i December, 1985 and January, 1986 has produced satisfactory results, indicating the effectiveness of these actions. The specific case (i.e., MR-85-0397 FCN 19) cited in this notice of violation was rectified at the time of discovery by posting it against the affected document' and distributing it to the Document Control Stations. This FCN was subsequently incorporated into l FCN-23 which was also posted in the IS-217 Report and distributed, j Date of Full Compliance The training mentioned above and the correction of other deficiencies identified as a result of the audit of the MR files was completed on December 31, 1985.

Reason for Violation B. On October 18, 1985, it was discoverd that MR 85-0397 FCN 19 was approved and implemented. to molify the function / control logic of the diesel generator output. breaker to allow remote shutdown operation from the diesel gererator panel in either the normal or l emergency mode. This viotation was a result of inadequate training and control of the FCN review process.

Corrective Steps Which Have Been Taken And The Results Achieved Nuclear Plant Engineering Procedure NuPE-AA-64 (Control and Approval of Field Change Notices (FCN's)) .was developed and issued November 18, 1985, and provides detailed instructions and r'estrictions for the use of FCN's and in certain cases requires additional reviews. The. limited use of FCN's for making changes to previously approved MR's is stressed throughout the procedure.

A parallel surveillance of FCN's during implementation is conducted by Quality Assurance to ensure compliance to the procedure.

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February 27, 1986 Corrective Action to Prevent Recurrence In addition to the' actions implemented above, training of all Nuclear Plant Engineering Personnel' responsible.for completing or handling MR's and FCN's was begun December 9, 1985 and will continue with retraining as pr>cedures are revised.

Also, verbal instructions have been provided as necessary by cognizant individuals on a continuing basis since such activities-began.

The specific case-(i.e., MR-85-0397 FCN 19) was determined to be l-technically correct and represented a procedural violation only. I Date of Full Compliance NuPE-AA-64 was approved and issued on November 18, 1985. The-training mentioned above and the correction of other deficiencies identified as a result of the audit of the MR files was completed on December 31, 1985.

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