View source for RBG-22012, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-49.Corrective Actions:Test Instruction 8 Revised to Incorporate Documenting Completion of Actions for Disposition of Test Exceptions

{{Adams
| number = ML20138C524
| issue date = 08/30/1985
| title = Responds to NRC Re Violations Noted in Insp Rept 50-458/85-49.Corrective Actions:Test Instruction 8 Revised to Incorporate Documenting Completion of Actions for Disposition of Test Exceptions
| 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-22012, NUDOCS 8510220453
| title reference date = 08-01-1985
| package number = ML20138C517
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
}}

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GULF STATES                           UTILITIES COMPANY                                                    ,
RfvER BEND $TATION    POST OFFICE BOX 220    St FRANCISVILLE. LOutstAN A 70775 AREA CODE 504    635 6094      346 8651 August 30, 1985 RBG- 22012 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator ff 611 Ryan Plaza Drive, Suite 1000
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Arlington, h xas 76011                                                                             gg , g g     l

==Dear Mr. Martin:==
River Bend Station - Unit 1
* Refer to: Region IV Docket No. 50-458/ Report 85-49 This letter-is in response to the Notice of Violation contained in NRC I&E Inspecticm Peport No. 50-458/85-49. 'Ihe inspection was performed by Mr. C. C. Harbuck during the period June 17-21, 1985, of activities author-ized by NRC Construction Permit CPPR-145 for River Bend Station Unit Ib.1.
Gulf States Utilities Cmpany's (GSU) response to the Notice of Viola-tion 85-49-01, " Failure to Adequately Review Preoperational Test Results,"
is provided in the enclosed attachment. This cmpletes GSU's response to the Notice of Violation.
Sincerel ,
                                                                                  & W. J. Cahill, Jr.
Senior Vice President River Bend Nuclear Group
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WJC/'ICC          /ebn Attachment 8510220453 851009 PDR   ADOCK 05000458' G ,                     PDR C_-IN I 8I L-

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ATIAGNENT August 30, 1985 RBG- 22012 Response to Notice of Violation                          !
i Reference                                                                        '
Notice of Violation - E. H. Johnson letter to W. J. Cahill dated August 1, 1985.
Refer to Docket No. 50-458/85-49.-
Reason For h e Violation                                                         ,
An inadequate review was conducted by the Joint Test Group (JIG) of precperational test ' procedure 1-PP-052 " Control Rod Drive Hydraulic" test results.
            %e Corrective Steps Which Have Been Taken and %e Results Achieved GSU's response to the NRC Notice of Violation is itemized as follows:
                                                                                             -I A. 1)   %e Startup Manual (SLN) does not require that action ' dates be included in the disposition of Test Excepticns except in the case of Nonconformance & Disposition Reports (N&Ds) and' Engineering &
Design Coordination Reports - (E&DCRs) per paragraph 3.3.5 of Test Instruction (TI)-8. A change however, was made to TI-8 to incor-porate the documenting of when actions for disposition of Test Exceptions are ccmpleted. This change was a@ roved by the JIG on August 19, 1985.
: 2)    It is not required to line out signatures 'of steps that are subse-     >
quently found to be in error. Wis is a convenience allowed by            r the StM and has no affect on subsequent close out of the Test          !
Exception written against that step.
: 3)   No date was written adjacent to a line out that was initialed.           ,
he data sheet contained a large amount of data and the error of cmission was not easily seen. The original data sheet and Test Exception data sheet were subsequently ccanbined to show "as left"       -
data which was approved by the JIG.
B. 1)   %e caission of the note, "1CR-06," was an error by the engineer, i
                      %e Major Change Request (MCR) has since been noted on the text page to correct this iten.

Page 2 August 30, 1985 RBG- 22012 C. 1)   hhile it is true that no justification was given in the procedure, there is no acceptance criteria for the ptmp curve, but only a step that the ptnp has adequate performance and capacity.          The curve closely approximated the manufacturers' curve and met Gener-al Electric (GE) system process diagram requirements of pressure and flow as required by the GE Test Specification. The error introduced was small. % e data at a flow rate higher than normal system flow with the minimtra flow subtracted shows systen pressure well above the requirement of the process diagram.       Generic data before and after the preoperational test without this minimum flow error has denonstrated adequate pump performance.
: 2)   Additional information added to a Test Exception was not dated and initialed.      %e testing was performed over a length of time which included a shift change at which time additional steps of the procedure were added to the Test Exception by the second shift engineer. Additions made prior to approval of the Test Exception by the Supervisor-Preoperational Test are not required to be dated and initialed.
: 3)  The valve position was incorrectly written. This Test Exception was written because valve position was difficult to determine by physical observation. The disposition was to verify valve posi-tion when the valve was to autcmatically reposition to open in a subsequent test step. The engineer's error was due to oversight ccmplicated by the many observations to be made during the short test time frame.       The Test Exception was corrected and re-approved.
: 4)  The test engineer failed to sign off steps for system restoration which had several lines of an MCR written in the confined area of the sign off blank. A Test Exception to re-verify the steps was written and ccrnpleted.
: 5)   'Ihere is no procedural requirement to initial and date a step against which a Test Exception has been written; however, it is generally done to indicate that the step is couplete. The Test Exception itself documen s cmpletion of a step.
The JIG Review Group was directM to re-review all cmpleted preoperational tests (PIs) for missing dates, signatures or other administrative items.
The review was empleted on July 4,1985 and no discrepancies were found.
We JTG Review Group also reviewed all pts for " accept-as-is" Test Excep-tiens to ensure the use of adequate qualifying statements to support the
           " accept-as-is" disposition.      %is review determined that twelve (12) of sixty (60) " accept-as-is" Test Exceptions should have additional technical information added. Twenty-eight (28) had minor administrative ccnments L-

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l Fage 3 August 30, 1985 RBG-    22012 added. On July 29, 1985 at JIG Meeting No. 284 the Test Exceptions that required additional technical and administrative justifications were re-subnitted and approved by the JIG.
           'Ihe Corrective Steps Which Will Be Taken to Avoid Further Violations
           '1he JIG Beview Group has been directed to pay particular attention to the items discussed above during the' performance of future reviews.
           'Ihe Date When Full Capliance Will Be Achieved It ' is GSU's position that_ full cmpliance has been achieved as of August 30, 1985.
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UNITED STATES OF AMERICA NUCLEu EEGULATORY ColetISSION STATE OF LOUISIANA                    $
PARISE OF WEST FELICIANA              5 In the Matter of                      I                Docket Nos. 50-458
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GULF STATES UTILITIFS COMPANY         l (River Bend Station, Unit 1)                                                                        '
AFFIDAVIT J. C. Deddens, being duly sworn, states that he is a Vice President of Gulf 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.
                                                              /               %
J. C[/Feddens~
Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this $ $ day of                Ud//b         , 19 v
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                                                                                   ~
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j                                                        an W. Middlebroo(s l                                                       otary Public in and for                   ,
West Feliciana Parish, Louisiana My Commission is for Life.
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