RBG-24325, Suppls Response to Violations Noted in Insp Rept 50-458/86-08.Complete Review of 1985 Internal Audit Files Will Be Completed by 861128,not 860831,due to Unanticipated Scope of Task

Suppls Response to Violations Noted in Insp Rept 50-458/86-08.Complete Review of 1985 Internal Audit Files Will Be Completed by 861128,not 860831,due to Unanticipated Scope of Task

ML20210D241
Person / Time
Site:	River Bend
Issue date:	09/05/1986
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20210D222	List: IR 05000458/1986008 RBG-24325, Suppls Response to Violations Noted in Insp Rept 50-458/86-08.Complete Review of 1985 Internal Audit Files Will Be Completed by 861128,not 860831,due to Unanticipated Scope of Task
References
RBG-24325, NUDOCS 8609190086
Download: ML20210D241 (8)

Text

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o GULF STATES UTILITIES COMPANY RIVER BfhD STATION POST OFFICE BOX 220 ST. FRANCISVILLE. LOul51ANA 70775 AREA COOE 504 635-6094 346 8651 September 5, 1986 RBG- 24325 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator -

-g U.S. Nuclear Regulatory Commission Region IV i .

kh _

E i' 611 Ryan Plaza Drive, Suite 1000 5#

Arlington, TX 76011 gg yg u6

Dear Mr. Martin:

River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 86-08 This supplemental letter responds to the Notice of Violations contained in NRC I&E Inspection Report No. 50-458/86-08. The inspection was performed by Messrs. D. D. Chamberlain, R. E.

Farrell, and W. B. Jones during the period February 1 through March 15, 1986 of activities authorized by NRC Operating . License NPF-47 for River Bend Station.

Gulf States Utilities Company's (GSU) supplemental response to Notice of Violation 86-08-01, " Improper Disposition of Startup Test Deficiency", and 86-08-02, " Failure to Schedule an Audit Early in the Life of an Activity", are provided in the enclosed attachments. This completes GSU's supplemental response to the Notice of Violations.

Sincerely,

-r l

. J. Cahill, Jr.

Senior Vice President

• iv r Bend Nuclear Group WJC/E R /P T/je Attachments 8609190086 860916 j PDR ADOCK 05000458 '

G PDR fo220/g

O

. UNITED STATES OF AMERICA EUCLEAR REGUIATORT CGGGSSION 1

STATE OF IOUISIAEA 5 l FARISE OF WEST FELICIANA 5 . i In the Matter of 5 Docket Bos. 50-458 GULF STATES UTILITIES CGIFANT $

(River Bend Station, Unit 1) .

AFFIDAVIT W. J. Cahill, Jr., beins duly sworn, states that he is a Senior Vice Pra?ident of Gulf States Utilities Company that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Cossaission the documents attached heretos and that all such documents are true and correct to the best of his knowindge, information and belief.

A W[. Cahill,'Jr//

Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this ay of Ma ,1986.

t . .

Joan W. Middlebroo(s Notary Public in and for 1 West Feliciana Parish, I Louisiana My Comunission is for Life.

- -_ .v .,.

ATTACHMENT 1 f Response To Notice Of Violation 458/8608-01 1

Level IV l l

REFERENCE

, l

! i Notice of Violation -

J. E. Gagliardo letter to W. J. Cahill, Jr.

dated May 1, 1986, Docket 50-458, License No. NPF-47. -

A. IMPROPER DISPOSITION OF STARTUP TEST DEFICIENCY l

I REASON FOR VIOLATION j

Condition Report (CR) No. 85-0622 was written to document a test .

exception (TE-1) following performance of Start Up and Test  !

Procedure ST-31. The test exception was closed on 2/4/86 based on i i NuPE's disposition to the noted CR. The violation occurred when it was discovered that a telecopied design evaluation from Stone &

Webster Engineering Corporation (SWEC) to Gulf States Utilities 1 Company (GSU) which formed part of the. basis for the disposition to the CR, did not contain signatures of approval or verification. ,

The responsible GSU system engineer did not notice that signatures l 1

. were lacking and, therefore, proceeded to disposition the CR based l on the unsigned telecopy which is not consistent with normal practice.

The CR was presented to the Facility Review Committee (FRC) for approval of Test Exception 1 to ST-31, " LOSS OF OFFSITE POWER".

The FRC is responsible for reviewing and approving Startup Test Program Test Exceptions (TE). TE-1 to ST-31 required Condition ,

Report (CR) No. 85-0622 be dispositioned prior b closure of TE-1. '

The CR was reviewed by NuPE and a summary disposition was presented to the FRC which stated that Modification Request (MR) l No. 86-0035 was initiated. The MR was generated to assure that )

, only one division of the Control Building Chilled Water System l

! would start following a loss of offsite power. The FRC review was determined to be adequate for closure of the TE based on the disposition prepared by NuPE. 1 l

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

! SWEC was contacted via phone regarding the subject .telecopy, at

, which time it was noted that a formal calculation would not yield

. results different from those presented in the telecopy. GSU

requested SWEC to provide a formal calculation with appropriate reviews. Calculation PB-364 was formally transmitted from SW3C to GSU to document these results. The results from calculation PB-364 did not differ from those presented in the unsigned i telecopy. Therefore, the disposition to CR NO. 85-0622 did not change. It should be noted that neither the unsigned telecopy or i calculation PB-364 were attached to the CR, rather, they are a

_,.I

I ATTACHMENT 1 (cont'd.)

part of supporting documentation used to form a basis for dispositioning the CR.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The FRC does not track approved MRs. For this instance, CR No.

85-0622 was the source document for MR 86-0035. Control of the implementation and maintenance of the design process rests with NuPE as specified in NPE-03-006, " Design and Modification l Control". All MRs are processed internal to NuPE in accordance with NuPE procedure NuPE-AA-54, " Nuclear Plant Engineering Guidelines and Instructions for Processing Modification Requests".

If MRs are cancelled, procedure NPE-3-006 requires the Design System Engineer (DSE) to write a memorandum providing justification and requesting permission from the Plant Manager to cancel a MR. Upon obtaining the Plant Manager approval to cancel a MR, the Design Control Coordinator (DCC) must provide a copy of l the cancelled MR to the initiator, the DSE, and the Plant Manager.

1 MRs that require changes to the Final Safety Analysis Report

(FSAR) require NuPE to generate a " Change to a Licensing Document j Form" in accordance with NuPE-AA-54. FSAR change request forms are submitted to Nuclear Licensing pursuant to RBNP-0027,

" Initiation of a Change to a Licensing Document". ,

NuPE procedure NuPE-AA-54 is being revised to require the DSE to .

ensure that any documentation used during developing the design input for a MR, which is received form a vendor or agent, be

officially signed and dated. In addition to this request, the i Engineering Coordinator will be procedurally required to review all MR's and FCN's for compliance with the added review required j in NuPE-AA-54.

! NuPE has assigned a Mechanical Engineer to review a random sample of approved and processed MR's for the subject concern. The review will be completed by June 15, 1986. Should the review j identify any reoccurrence of the aforementioned, appropriate

! corrective action will be implemented. In addition, NuPE will i

take this opportunity to issue a memorandum which instructs its engineers to ensure that any documentation used during the design j process received from a vendor or outside agent be officially j signed and dated. This memorandum will be issued by June 6, 1986. l l

i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

1) ' SWEC calculation PB-364 was received on April 2, 1986. )

l

2) NuPE-AA-54 will be revised by June 15, 1986.

1

3) A sample review of MRs will be completed by June 15, i

1986.

I

- . . . . - - .-., , -- .. . - _ . _ _ ~ , _ . - _ - - . . . - - . - , .

ATTACHMENT 1 (cont'd.)

4) A memorandum instructing NuPE engineers will be issued by June 6, 1986.

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1 ATTACHMENT 2 5

Response To Notice Of Violation 458/8608-02

! Level IV l

l REFERENCE Notice of Violation -

J. E. Gagliardo letter to W. J. Cahill, Jr.

] dated May 1, 1986, Docket 50-458, License No. NPF-47. ,

B. FAILURE TO SCHEDU;.E AN AUDIT EARLY IN THE LIFE OF AN ACTIVITY i REASON FOR THE VIOLATION 1

! The failure to schedule an audit of Facility Review Committee

(FRC) review activities early in the life of this activity was due j to a lack of programmatic controls associated with follow-up l conditions related to Quality Assurance (OA) audits. L j An audit addressing Startup and Test (SU&T) activities and FRC j review was performed in February, 1985 (Audit No.

l GSUS/SU&T-85/02). However, FRC review activities at that time j were predominantly review and approval of start-up procedures as

the actual start-up phase had not yet commenced. The audit l checklist documented this fact and indicated that a subsequent i audit would be scheduled to address these activities following commencement.

! Until recently, a procedural mechanism had not existed to assure j that activities, not covered in an audit scope, were brought forward for consideration in future audit conduct.

{

I Revision 0 of the Master Audit Schedule included an audit of I

Startup and Test activities. However Revision 1 of this schedule t deleted this audit. The justification for this deletion was not j

~

properly communicated and objective evidence could not be found in support of this deletion. ,

l Discussion with the past Audit Coordinator, who had recently l terminated as a GSU employee, indicated his intent was to include '

t FRC Review Activities in the scope (s) of related audit activity. l CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An evaluation of FRC Review of SUsT activities was included in the i scope of Audit 86-03-1-STPG, " Surveillance Test Program",

l conducted in March, 1986. The scope of this audit was increased

to include the SU&T activities and FRC reviews performed during

the subject period in February, 1985.

t l .One deficiency was identified relative to administrative controls I required by the RBS Startup Manual - the documentation of required

_ _ _ . . _ . _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ . - . - - _ . . _ , _ - _ _ _ . . _ _ _ _ . _ _ _ . ~ . . . _ _ _ . . _

ATTACHMENT 2 (cont'd.)

reviews of the initial Startup Test Log. This deficiency- was i

documented as Quality Assurance Finding Report .. (QAFR) No.

P-86-04-012 and is currently in the corrective action process.

As part of the scope, the audit addressed a follow-up to the Operations QA Surveillance efforts. A finding had been identified in January, 1986 addressing deficiencies in the area of FRC Review and Approval of Test Condition (TC) Heat-Up without taking proper j

exception to ST-11, "LPRM Calibration", and ST-13, "NSSS Process Computer". Results indicated the corrective actions taken to 3 address QAFR No. O-86-01-02-D have prevented recurrence of this l problem during subsequent FRC review and approval of TC-1 and l TC-2.

l

) Results of this audit effort indicated that the overall l performance of Plant Staff in the review and approval of initial startup test results is considered satisfactory.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS I In March of 1986, QA Systems performed a review of the GSU j Internal QA Audit Program (QAI-2.1, " Audit Performance and a Reporting") to assess adequacy and effectiveness. Results indicated weak programmatic controls relative to several elements, l one of which involved audit schedule / scope reviews. Two QAFRs (QAFR Nos. P-86-03-015 and P-86-03-016) were issued to document l these deficiencies and are currently in the corrective action i process. The actions to correct and prevent similar recurrence of problems include: .

la. Instituting a 100% review of all 1985 audit files against a given checklist of tasks, such as:

j -a determination of any outstanding audit checklist items 4

identified as requiring attention during subsequent' audits, 4

and

- an indication of those unsatisfactory audit checklist items

{ which do not appear to be supported properly (i.e.,  ;

justified or referenced to QAFR number). i j lb. Assuring that these deficient or questionable items are l l corrected and/or accounted for.

I This review is projected to be complete by November 28, 1986.l Corrective action as applicable for those deficiencies identified i

by the review will be corrected by December 31, 1986.

l 2. Revising procedure QAI-2.1 to include necessary programmatic i controls in sufficient detail to assure commitments / l i requirements are implemented properly. j i

i n

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ATTACHMENT 2 (cont'd.)

~

Procedure QAI-2.1 will be revised by July 15, 1986.

3. Provided training to the auditing staff on "the proper implementation of these requirements.

This is currently an ongoing effort and will continue following the issuance of the revised QAI-2.1.

Although QAI-2.1 has not yet been issued to address increased program controls, these controls have been invoked and are currently implemented. Completed audit files dating back to January, 1986 have been properly reviewed and maintained.

Personnel have been instructed in required procedural guidelines and mechanisms are in place to assure accountability of each audit scope.

2 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED la. A complete review of 1985 internal audit files will be completed by November 28, 1986. Forty-four (44) audits are being considered in this review of which thirty-three (33) have been reviewed and eleven (11) remain to be reviewed.

This date differs from the previously submitted completion date of August 31, 1986 because of the unanticipated scope of the task necessary to comprehensively complete this review.

Ib. The applicable corrective action based on la will be completed by December 31, 1986.

2. A revision to QAI-2.1 will be completed by July 15, 1986.

3. Training of auditors is ongoing. Training of auditors to revised QAI-2.1 will be completed by August 1, 1986.

l l

l 1

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