View source for RBG-21-915, Responds to Violation Noted in Insp Rept 50-458/85-43 on 850501-0615.Disagrees That Violation Re Failure to Obtain Approval of QA Program Change Occurred.Qa Program on 2-yr Review Basis Effective 830311.No Subsequent Mods to Program

{{Adams
| number = ML20135E429
| issue date = 08/21/1985
| title = Responds to Violation Noted in Insp Rept 50-458/85-43 on 850501-0615.Disagrees That Violation Re Failure to Obtain Approval of QA Program Change Occurred.Qa Program on 2-yr Review Basis Effective 830311.No Subsequent Mods to Program
| author name = Cahill W
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = Martin R
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000458
| license number = 
| contact person = 
| document report number = RBG-21-915, NUDOCS 8509160394
| package number = ML20135E421
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}

=Text=
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.I GULF STATES                             UTILITIES COMPANY msvin SEND 5f At10N      POST O5FICE Box 220    ST FRANCISvtLLE Louts 6ANA P0775 AAf A CODE 604     636 6094     346 8651 August 21, 1985 RBG- 21,915 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator                                                         .
U.S. Nuclear Regulatory Omnission                                                                                     O
                                                                                                                     % @ g ,fi~ '
Region IV                                                                                                                ,
611 Ryan Plaza Drive, Suite 1000                                                                                        l Arlingtcn, Texas 76011                                                                                    i Alf 2 7 g i           

==Dear Mr. Martin:==
N  i
                                                                                                                                . 1/
l                                              River Bend Station - Unit 1                                                            .
i Refer to: Region IV
_ Docket No. 50-458/ Report 85-43
                   'Ihis letter is in response to the Notice of Violation contained in NBC I&E Inspection Report No. 50-458/85-43. The inspection was performed by Mr. D. D. Chanberlain, J. P. Jaudon, and J. R. Boardman during the period May 1 - June 15, 1985, of activities authorized by NIC Construction Permit CPPR-145 for River Bend Station Unit No. 1.
Gulf States Utilities Cmpany's (GSU) response to the Notice of Viola-l             tion 85-43-01, " Failure to Obtain Approval of a m Program Gange," is provided in the enclosed attachnent. This empletes GSU's response to the 4
Notice of Violation.
J l                                                                                            Sincerely, t /
                                                                                               . J. Cahill, Jr.
Senior Vice President River Bend Nuclear Group
:            R7CM'IOC/arg Attachment 8509160394 e50910 PDR     ADOCM 05000450 0                     PDR
          .[C -lM W

1 7
I ATI:ACHMENT August 21, 1985 RBG- 21.915 Response to Notice of Violation BeEerence Notice of Violation - E. H. Johnson letter to W. J. Cahill dated August     2, -
1985.
Refer to Docket 50-458/85-43.
Response to 85-43-01 " Failure to Obtain NRC Approval of a @ Program Change" Gulf States Utilities Capany disagrees that a violation occurred.
NRC Inspection Report 50-458/85-43 paragraph 8 (page 9)    states,   in part,
           " Discussions   with licensee personnel revealed that revised Section 17.1.2.4A reducing the periodicity of GSU review of all controlled docu-ments fra one (1) year to two (2) years was made after March 11, 1983."
mis information was given in error.
By letter RBG-15,234 dated June 10, 1983 CSU provided the NRC with the River Bend Station (RBS) Construction OA Program. As stated in that let-ter, "%e RBS Construction OA Program describes the quality assurance pro-gram in effect on March 11, 1983 and identifies changes to the quality assurance program since the issuance of the Cmstruction Permit."      Section 17.1.2.4A of this subnittal specifies that GSU reviews all controlled docu-ments which they issue every two years. The tun year review ccumitment was j          in effect on March 11, 1983, and no subsequmt modification to that ecmmit-ment has been made. GSU cmsiders that it is in ccepliance with the letter and intent of 10CFR50.55(f) (3) .
Please find enclosed a copy of GSU internal mmoranda No. W82-152 dated Decet)er 23, 1982 and pages 17.1-9 and 10 of its attachment. h is m moran-de served to distribute the latest revision of the RBS Construction QA Program to GSU perscnnel. 'Ihe text of Section 17.1.2.4A describes the two year cycle for review of controlled docments. The section heading " Yearly Review of controlled Doceents" is a typographical error and should have read " Periodic Review of Controlled Documents" and was subsequently cor-
!          rected in the June 10, 1983 submittal of the RBS construction Oh Program to the NPC.

n Page 2 August 21, 1985 RBG- 21,915 Corrective Steps Milch Have Been Taken and Results Achieved Not Applicable.
Corrective Steps Which Will Be Taken to Avoid Further Violations Not Applicable.
Date Wien Full Cmpliance Will Be Achie.wd Not Applicable.

UNITED STATES OF AMERICA NUCLEAR EEGULATORY C00stISSION STATE OF LOUISIANA                        5 PARISH OF WEST FELICIANA                  $
In the Matter of                          $            Docket Nos. 50-458 CULF STATES UTILITIES CONFANT             I (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 Regulatory Commission the documents attached hereto            and that all such documents are true and correct to the best of his knowledge, information and belief.
                                                    /      .
W      Cahiit,'Jr.'      //
Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this 2/ day of A .js.b             , 19     .
                                             -     fd (>_           }   41.       hrf
                                               /6an W. Middlebrooks (Notary Public in and for West Feliciana Parish, Louisiana Hy Comunission is for Life.

[          ,
MEMORANDUM TO:          Distribution                                         December 23, 1982 FRON: Nuclear Licensing

==SUBJECT:==
Construction QA Program Attached is the latest revision of the Construction QA Program for River Bend Station. This document has been prepared by incorporating the approved PSAR Change Notices into PSAR Section 17.1.
4                        Distribution and revision of this document is the responsibility of Nuclear Licensing. Please contact Eddie R. Grant at 733-2313 if you have any questions or comments, i
hak E.                          ros N die R. Grant Licensing Coordination
)
ERG /kt
 !                       Dist:ibution: P. D. Graham                      E. L. Hammond J. G. Weigand              W. F. Cummings J. H. Curless              J. E. Booker T. C. Crouse               V. J. Reed V. J. Normand              L. A. En.: . and M. E. Walton-              L. L. Die: rich /SSW C. W. Lambert              H. D. Pc ell /GE P. E. Freehill             NL-82-13; 1
1

   ~
RBS - i&2 PSAR Reporting of Significant Deficiencies Corrective Action Analysis Initiation of Site Stop Work Action QAP 17 h
I Preparation, Quality       Collection, Assurance   Records  StorageList and Maintenance of QA Records
(
Quality Assurance Records File QAP 18 Audit Planning and Scheduling Qualification and Training of Auditors Management Review of QA GSU Internal Audits Contractor Audits                                                                                         -
Vendor Audits                                                                                             i Audit Reports Follow-up and Close-out of Audit Reports The NQAM is considered by GSU to be a working document and the general content as shown above is subject to continual revision and change.
The NQAM is prepared by the QA Department.
Concurrence with each section is obtained supervisor.          from the appropriate department manager or Vice President-RBNG.The SQAM is approved by the Director-QA and the Senior and approval process. All revisions to the NQAM .ndergo the same review QA program requirements for startup testing and operations are described in the FSAR.                                                                      ,
17.1.2.3A Project Procedures documents are accomplished in accordance wit,h the GS Project Procedures Manual.
GE.                                    Similar procedural systems exist in S&W and of applicable GE and S&W procedures. Interface activity or coordination i i
The NQAM requirements affecting QA Department activities are which are approved by the Director-QA. implemented by Nuclear Q                                 ,
17.1.2.4A Yearly Review of Controlled Documents GSU reviews all controlled documents which they issue,including the Nuclear Quality Assurance Manual, every two years. Major                      revisions to December 1982 17.1-9 PSAR CN k
                                     . - - - . .         . - - - - - . . -     ,           . , - - -        c -

RBS - 1&2 PSAR documents may constitute this review.
lj'e,s,surethatdocumentsarereviewedforadequacyandapprovedforMeasures a release by authorized personnel and are distributed and used at locations where the activity is being performed. Quality Assurance, Project  Engineering, Licensing, and Administrative Services participate in this review.
17.1.2.5A Fuel QA Proaram GSU, as the plant owner, retains the responsibility for the quality of the nuclear fuel. GSU performs an overall audit and review of the GE Fuel QA Program. GSU may use consultants, as required, in preparation of the nuclear fuel contract, contract negotiations, and in preparation of a technical evaluation of fuel design, and an initial audit of the GE nuclear fuel quali y system. GSU may use consultants to further assist in evaluation of fuel design, recommended quality program changes and a system of detail audits during the fabrication cycle.
GSU provides instructions for receipt inspection, handling, and storage of the nuclear fuel.
GE performs the first level quality program, consistent with the requirements of 10CTR50, Appendix B for design and fabrication of the nuclear anticipated fuel, to assure the mechanical integrity of the fuel over its lifetime.
The GE fuel design and quality inspections
] .                  requirements are discussed in Chapter 4 j
GSU maintains the right to conduct special tests. in addition to GE's i                    QC inspection requirements, during the fuel fabr::stion phase. Special
;                    tests to be performed are established prior to fuel fabrications based on the state of the art and current industry prob'.ons.
!                   GSU Fuel QA Program requirements are delineated in the GSU SQAM. ,
17.1.2.6A QA Training
!                   The Director-Quality Assurance must have as a minimum five years in charge of responsible assignmentsign,                                construction, in the operation of a power plant. He draws upon t is experience in handling des,h or technical problems and personnel relations, as they arise.
j                  he familiarizes himself with the GSU QA manuals and policies to moreInitially, i                  adequately understand the overall program. He familiarizes himself with codes, standards, and regulatory requirements, related to quality
,                  assurance and to nuclear power plants in general. He participates in all phases of the audit program, including preparation of inspection plans, conduct of audits, and writing of summary audit reports.
GSU maintains a reading list to monitor QA employees' progress in acquainting themselves with regulatory standards, codes, GSU QA manuals, technical descriptions, and other related project literature.
December 1982 17.1-10 1                                                                                                      PSAR CN r
                                                                          . . - . .}}