RBG-26873, Responds to Violations Noted in Insp Rept 50-458/87-20 on 870801-0915.Corrective Actions:Fuel Oil Analysis Requirements Entered Into Surveillance Test Procedure Tracking Program & CSP-0100 Reviewed & Revised

Responds to Violations Noted in Insp Rept 50-458/87-20 on 870801-0915.Corrective Actions:Fuel Oil Analysis Requirements Entered Into Surveillance Test Procedure Tracking Program & CSP-0100 Reviewed & Revised

ML20236H971
Person / Time
Site:	River Bend
Issue date:	10/30/1987
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RBG-26873, NUDOCS 8711050061
Download: ML20236H971 (5)

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[ GULF STATES UTILITIES CONTPANY g

eg RIVER 8END StADDN POSf 06HCE 80X 220 $T. FR ANCLGVILLE LOUISIANA 7077B AHEA CODE 504 6 M 6094 346 8661 October 30, 1987 RBG- 26873 File Noo. G9.5, G15.4.1 U. S. Nuclear Regulatory Commission Document Control Desk -!

Washington, D. C. 20555 Gentlemen: r River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 87-20' This letter responds to the Notice of Violation contained in NRC Inspection Report No.,50-458/87-20. The inspection was performed ,

by Mr. Chamberlain ~ durin's the period of August i through l September 15, 1987 of activities authorized by NRC Operating License NPF-47 ior River Bend Station.

Gulf States Utilities Company's (GSU) response to Notice of Violations 8720-05 " Failure to Vei Diesel Fuel 011 Properties within 31 Days" and 8720-06 " Failure to Include QA Controls in a Procurement Document".

Sincerely, 4

J. C. Deddens Senior Vice President JCD R /RJK/ /ehs Enclosure cc: U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector P. O. Box 1051 St. Francisv111e, LA 70775 871105COS1 871030 I PDR ADOCK 05000458 i G PDR f

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UNITED STATES CF AMERICA-

'; NUCLEAR REGULATORY COMMISSION .

1 STATE OF LOUISIANA )

' PARISII ~ OF WEST. FELICIANA )  !

In the Matter of ) Docket No. 50-458 50-459 GULF STATES UTILITIES _ COMPANY ) )

(River Bend Station,-

Unit 1)

AFFIDAVIT J. C. Deddens, being duly sworn, states that he is a

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Senior Vice President of Gulf States Utilities Company; that he is ' authorized on the part of said company to sign and l 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.

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J.k.Deddens

Subscribed and sworn to before me, a Notary Public in andfortheStateandParishabovenamed,thisobN_bdayof bd kD OF F , 19N .

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Middlebfrooks t//Joan W. Public in and for Notary West Feliciana Parish, Louisiana l

l My Commission is for' Life. l J

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ATTACHMENT 1 ) '

Response to Notice of Violation 50-458/8720-05 Level IV REFERENCE Notice of violation - letter from J.E. Gagliardo to J.C. Deddens, dated September 30, 1987.

FAILURE TO VERIFY DIESEL FUEL OIL PROPERTIES WITHIN 31 DAYS River Bend Station Technical Specifications, Section 4.8.1.1.2.d.3, requires verification within 31 days of obtaining a sample of diesel generator fuel oil, which is added to the storagc tanks, that all  ;

properties specified in Table 1 of ASTM D975-81 are met.  !

4 Contrary to the above, the semple analysis of diesel fuel oil, which was )

added to the storage tanks for the Divisions II and III emergency diesel )

generators on June 25, 1987, was not received from the vendor by the ]

licensee chemistry department until August 27, 1987, and verification was (

not completed until Septembe" 1, 1987, which is 37 days beyond the f specified 31-day limit.

REASON FOR VIOLATION On 6/25/87, two diesel fuel oil deliveries arrived for off-loading. Both )

were found acceptable based on initial receipt analysis testing completed by Gulf States Utilities (GSU) Chemistry. These tests do not include ash weight or distillation temperature. The fuel oil supplier (Exxon)

' Customer Inspection Report', provided upon receipt of the fuel oil, indicated all chemical properties met the acceptance criteria. These  ;

tests (performed by Exxon) did include ash weight and distillation temperature. The fuel oil was off-loaded into Standby Diesel Fuel Oil Storage Tanks IB and 1C (Div. II and Div. III). No fuel oil was off-loaded into the 1A (Div. I) storage tank. These storage tank additions were supported with documentation of tank levels and blocide additions made by GSU Chemistry when the fuel oil was off-loaded.

Fuel oil samples were sent to the CSU warehouse on 6/26/87 for shipment to i an offsite vendor laboratory (Petro-Check, Inc.) for futther analysis.

These fuel oil saa.ples were shipped along with several other routinely sent lubricating oil samples.

I On 7/27/87, thirty-two days after the sampling date, CSU Chemistry called l l

Petro-Check, Inc. to inquire on the fuel oil and lube oil sample results j documentation. Pctro-Check indicated that the analysis had been completed on 7/01/87, and they believed the documentation had already been i transmitted to GSU Chemistry by US Mail; however, this could not be i verified. Another set of documentation was to be sent to GSU via US Mail I l that same day, i l

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On 8/05/87, CSU Field Engineering called Petro-Check, Inc. again and obtained the same responsa as the Trevious call on 7/27/67. Pet ro -Check subsequently hand delivered to GSU Field Engineering, on 8/12/87, a copy of the fuel oil and lube oil sample results. ,

CSU Chemistry receiv6d, via US Mail on 8/27/87, Petro-Check, Inc. sample results for fuel oil and lube oil. Due to the sample date on the fuel oil analysis, this report was incorrectly assumed to be a duplicate copy of previously reported data. Further review and investigation made on 9/01/87 revealed that these documents represented previously unreported -

data which was overdue, and that. the ash weight and the distillation temperature were indicated to be not within the Technical Specification j acceptable limits. Condition Report (CR) 87-1038 was immediately 1 fnitinted, proper fuel oil analysis reporting documents completed, and appropriate management personnel notified. CSU Chemistry sarfpled all j

. Standby Diesel fuel 011 Storage Tanks on 9/1/87 and analyzed the samples for Ash Weight in accordance with the requirements of ASTMD975-81. {

The l results of these testa verified compliance with Technical Specifications. l J

The root cause of this Techaical Specification noncompliance was that a )

positive method of tracking fuel oil analytical results and ensuring due j dates were met was not in place. )

l CORRECTIVE STEPS VHICH HAVE BEEN TAKEN AND TI:E RESULTS ACHIEVED 1

To p reven t future Technical Specification noncompliance in this area, l fuel oil analysis requirements have been entered into the RBS Surveillance l

Test Procedure (STP) Tracking Program to assure completion in a timely j manner, via daily notification of scheduled due and overdue results.

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Training on this event and on the STP Tracking Program has been completed l by all Chemistry personnel. Technical Specification training has been J completed for the Chemistry Supervisor and applicable staff members. )l Additionally, CSP-0100, " Chemical / Radiochemical Technical Specification's .

' Surveillance," has been reviewed and revised to include the required fuel oil analyses. No other required surveillance were identified for i inclusion, i h i

i CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Additionally, to reduce the possibility of future fuel oil shipments which j may not meet tha Technical Specification acreptance criteria from being j off-loaded into the Standby Diesel Fuel Oil Storage Tanks, an Operations 4 Hold will normally be placed on future fuel oil receipts (i.e., use of an f interim storage hold tank) until all analytical results have been successfully completed and found to be within acceptable limits and applicable documentation completed.

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l I l

All corrective actions described above have been implemented and GSU is l currently in ecmpliance.

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ATTACM00rr 2 Response to Kotice of Violation 50-458/8720-06 Level IV ,

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REFERENCE:

Notice of ' violation fron J.E. Gagliardo to J.C. Deddens, dated September f 30, 1987, l l

FAILURE TO INCLU,DE QA CONTROLS IN A PROCUREMENT DOCUMENT:

Criterion IV of 10 CFR Part 50, Appendix B and the licensee's approved QA program require that procurereat documenta for material, equipment, and

. services include necessary QA program contro2s to provide assurance of adequate quality and an acceptable product. .l Contrary to the above, Rcvielon 2 of Purchase Order 5-ON-71594, issued on j May 5, 1986, to Petro-Check, Inc , removed all QA program requirements j previounly ine?uded. This purcha <3e order is for emergency diesel j generator fuel. oil analysis which is required by Technical Specifications to verify emergency diesel generator operability.

_ CORRECTIVE ACTION STATUSj Gulf States Utilities Company (GSU) is revf oing the criteria of 10CFR50 Appendix B for applicatir;n to fuel oil analysis; however, the review is l not complete. GSU therefore requests an additional 30 days to resp nd to '

this violation. Until such time as GSU provides its response and implements the appropriate corrective action, CSU has a member of the River liend Station (RBS) Chemistry Staff observe the techniques and procedures utilized for fuel analysis to ensure compliance with the

} appropriate. ASTM standards as designated in the RBS Technical

l. Specifications. Further information/ response will be provided by November 30, 1987. )

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