View source for RBG-23566, Suppls 860227 Response to Violations Noted in Insp Rept 50-458/85-81.Departmental Review of All Station Operating Procedures in Main Control Room Controlled Copy 3 Conducted & Station Document Control Reassignment Made

{{Adams
| number = ML20205P383
| issue date = 04/22/1986
| title = Suppls 860227 Response to Violations Noted in Insp Rept 50-458/85-81.Departmental Review of All Station Operating Procedures in Main Control Room Controlled Copy 3 Conducted & Station Document Control Reassignment Made
| 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-23566, NUDOCS 8605210389
| package number = ML20205P374
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}

=Text=
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GULF STATES                         UTELETIES COMPANY RIVER SEND STATION    POST OFFICE BOA 220     ST FRANCISVILLE.LOUISaANA 70775 AREA ~ 00E 504   635 6094      346 8651 April 22, 1986 RBG- 23566 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV
                                                                                                     %@@@%$ h 611 Ryan Plaza Drive, Suite 1000                                                           #                    i f1 Arlington, TX 76011                                                                               kWW - 5 886 ; !?

==Dear Mr. Martin:==
f"J River Bend Station - Unit 1 Docket No. 50-458/ Report 85-81 As discussed with Mr. J. E. Gagliardo of your staff on April 18, 1986, this letter is being provided at this time as a supplement to Gulf States Utilities Company's (GSU) February 27, 1986, response to the Notice of Violations contained in NRC I&E Inspection Report No. 50-458/85-81. The inspection was conducted by Messrs. D. D. Chamberlain and W. B. Jones during the period December 1-31, 1985 of activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No. 1.
GSU's supplemental response to the Notice of Violations 85-81-01,     " Failure of Document Control Program" and 85-81-02,
           " Inadequate Retest Following a Modification or Repair",                                                     is provided in the enclosed attachments.                                           This           completes GSU's response to the Notice of Violations.
Sincerely,
                                                                                                          .? /
                                                                                                           /
W. J. Cahill, Jr.
Senior Vice President River Bend Nuclear Grcup tut WJC/[3/je Attachments fDR           O                   h G
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UNITEu STATES OF AMERICA EUCLEAR EEGUIATORT COISEISSION STATE OF IAUISIAEA                     5 PARISE OF WEST FELICIAMA               $
In the Matter of                       I         Docket Nos. 50-458 GULF STATES UTILITIES COMPANT          5 (River Bend Station, Unit 1)
AFFIDAVIT W. J. Cahill,   Jr.,  being duly sworn, states that he is a Senior Vice President of Gulf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear Rggulatory Commais sion the documents attached hereto      and that all such docuuents are true and correct to the be st 9f his knowledge, information and belief,
                                                              /(
t W @ 'Cahill, Jr. /
Subscribed and sworn to before me, a Notary Public in and for the.
State and Parish above named, this [ day of        Or/ [    ,19[a l4 tit           it .      I     U
                                            /Joan W. Middlebrooks Notary Public in and for
[,WestFelicianaParish, Louisiana My Conunission is for Life.

ATTACHMENT 1 RESPONSE TO NOTICE OF VIOLATION 50-458/8581-01 LEVEL V REFERENCE Notice of Violation - J. E. Gagliardo letter         to   W.      J. Cahill,   Jr.
dated Jaauary 29, 1986.
A. Failure of Document Control Procram
                 , REASON FOR VIeLATION Station Operating Procedure SOP-0035, Revision 0, " Reactor Core isolation Cooling", did not have included in the Main Control Room working     copy, tempetary change notice        (TCN)      85-1287. Upon discovery,    research to     identify    the    probable       cause    was inconclusive. The TCN was issued July 31, 1985. Records show the TCN was transmitted and received in the Control Room. The TCN may                 l have been inalvartently removed by personnel updating the manuals, or petlmps war uisplaced by personnel using this controlled copy for work.
CORRECTIVE STEPS Wi!ICH HAVE DEEN TAKEN AND THE RESULTS ACHIEVED An    immediate departmental review of all SOP's in the Main Control Room controlled ccpy No. 3 s,a s conducted by the Shift Clerk.
Several SOP's with duplicate copies of the same TCN and a few TCN's which were filed with the wrong SOP were identified.              This controlled set of SOP's is updated immediately on issuance of a TCN     After final approval of a TCN, it is reissued by Station Document Control     (SDC) to all manual holders. Upon receipt, the copy of the originally issued TCN is re,71 aced in the Control Room Manual by the Shift Clerk, with the final approved copy. This appears to have been overlooke d in a few . instances resulting in two copies of the same. TCN ir a given SOP. These were removed at the time of the immediate departmental review and the misfiled TCN's     relocated. Subsequent to this review an independent departmental review ccnfirmed that the original findings had been corrected.
CORRECTIVE STEPS UHICH UILL BE TAKEN TO AVOID FURTHER VIOLATIONS A    tuastignment ci tuoponsib!11 ties has been made to SDC. SDC personnel assignen to update th3 controlled drawing station in the Main Control Room have been given the new responsibilities of maintaining and ensuring that updates to Main Control Room procedure manuals are approprfately filed. After assignment of this responsibility to SDC, a ;rulete review of the Main             Control Room COP's was performed.         The review identified some missing procedures and TCNs. These discrepancies have been corrected.
SDC will conduct periodic reviews in accordance with ADM-0005,

           " Station Document Control", Section   6.6 to maintain the Main Control Room SOP's.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved
* O O
ATTACHMENT 2 RESPONSE TO NOTICE OF VIOLATION 50-458/8581-02 LEVEL V REFERENCE Notice of Violation     -
J. E. Gagliardo letter to W. J. Cahill, Jr.
dated January 29, 1986.
A. INADEQUATE RETEST FOLLOWING A MODIFICATION OR REPAIR REASON FOR VIOLATION As a result of personnel oversight, adequate retests were not provided following maintenance and modifications activities. It has been concluded that the personnel oversight resulted from inadequate procedural guidance when addressing the individual responsibilities for evaluating retest requirements.
Conoition Report No. 85-0559 was issued on 11/29/85 revealing that maintenance activities were performed on the wiring to backup scram valves C11*SOVF110A and C11*SOV110B with no documented continuity checks or functional test performed.         During the restoration of the system the subject wiring was connected in accordance with the approved design drawing. However, the failure to perform a    functional test resulted in a design error being undetected prior to placing the system into service.
Condition Report No. 85-0561 was issued on 11/20/85 revealing that a wiring modification was made to shutdown cooling suction valve E12*MOVF008 with no functional test performed upon completion of the modification.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Temporary Alteration No. 85-RPS-11 was initiated to correct the wiring discrepancy encountered with the backup scram valves. Upon installing the Temporary Alteration, a functional tect          una performed by operating the manual scram controls while filed verifying the venting of the valves. The Temporary Alteration was cleared on 12/13/85 after the implementation of permanent wiring changes identified by Modification Request No. 85-1099. Prior to returning the system to service, a functional test was performed by inserting a manual scram and observ;ng actual operation of C11*SOVF110A and C11*SOVF110B.      The successful results of the functional test are documented on Maintenance Work Request No.
014461.
Upon discovering the wiring problems associate 1 with RHS Suction Cooling Valve 1E12*MOVF008, Maintenance Work Request No. 014307 was initiated to investigate the        circuit. Following   the completion of the corrective maintenance, a functional test was

performed in accordance with the requirements of Maintenance Procedures CMP-1253,       "Limitorque Motor Operated Valves", and GMP-0042,    " Control   Circuit Testing". The   valve     was    also successfully operated form both the Control Room and the Remote Shutdown Panel. The successful results of the functional test are documented on Maintenance Work Request No. 014307.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS To support the belief that these events were isolated occurrences, and not indicative of programmatic problems, a random sample review,   in accordance with Mil Standard          105D, of previously performed safety related Maintenance Work Requests             (MWRs)   is presently being conducted.          The objective is to ensure that adequate rotests have been performed following modifications and repairs. The sampling of the MWRs will cover the period from            ,
initial criticality (10/31/85) to the date of the last noted               ,
inadequate retest       (11/29/85). The acceptance criteria of the      !
sampling will be based on a ninety-five percent confidence level           !
that ninety-five percent of the total population for the period is acceptable.      If t'he sampling method       identified     any   major deficiencies, then the total population of the MWR's for this period will be reviewed. The Quality Assurance          IQA)   Department was involved in the review and approval of this approach.
To prevent further violations, ADM-0028 " Maintenance Work Request" has been revised to include additional guidelines for ensuring that Retesting Requirements are evaluated prior to returning components / systems     to service. A  separate attachment " Post Maintenance Functional / Operability Testing Form", to the MWR and its requirements have been included in the revised procedure. The requirements for this form have been established to ensure that retest are adequately evaluated and conducted.               The revised procedure also clearly delineates the responsibilities of the Maintenance     and Operations Departments when identifying and performing retest activities.          Documented training has        been conducted for the Maintenance and Operations Departments on the requirements of ADM-0028 Revision 5.            Also included in the Training were Shift Supervisors and Control Operating Foremen.
Immediately upon discovering the events which lead to this violation,     the     Assistant Plant Manager of Maintenarce and Materials instructed the Maintenance Supervisors to maintain a close vigilance of the functional test requirements when approving Maintenance     Work     Requests. Maintenance   and     modification activities on safety related equipment are not to be approved until functAonal test requirements are appropriately addressed.
Control Rcom Night Order Log entries have been established for instructing Operations personnel of the violation and the events which lead to it.          The night order instructions emphasized the jmportance of adequately specifying and            documenting     retest requirements on the MWR when performing Maintenance / Modification
: o.    .
activities. The instructions also emphasized that         Limiting Conditions    of Operations    (LCO's) are to be initiated when Maintenance / Modification activities are performed on Technical Specification Equipment.
Additional action taken to ensure the performance of retest activities include the revision of Administrative Procedures ADM-0022, " Conduct of Operations". The procedure has been revised to include instructions for initiating Tracking LCO Status Sheets.
The Tracking LCO Status Sheets provides an administrative means for tracking inoperable technical specification equipment or parameters, even though the equipment is not required to be operable under the current plant condition.
In addition to the above corrective action taken by Maintenance and    Operations,   Nuclear Plant Engineering      (NuPE)  procedure NPE-3-006, Revision 3, " River Bend Station Design Modification Request    Control   Plan",   includes applicable functional test requirements when issuing Plant Modification Request packages.
When    NuPE   identified    functional test requirements in the Functional Test and Restoration Section of the Maintenance Work Request.
QA Program applicable MWR's have QA/QC involvement associated with the review and actual work process. Quality Control (QC) reviews applicable MWR's for insertion of notification           points   for functional testing activities.       QA monitors the performance of selected Surveillance Test Procedures        associated    with   the functional testing activities.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The initial sample review of the previously performed MWR's will be completed by May 15, 1986. Any deficiencies noted from the review    will be identified, dispositioned and tracked on a Condition Report in accordance with ADM-0019.}}