View source for RBG-24275, Responds to NRC Re Violations Noted in Insp Rept 50-458/86-20.Corrective Actions:Individuals Instructed to Comply W/Requirements of ADM-0003 When Initiating Future Temporary Change Notices

{{Adams
| number = ML20210A595
| issue date = 08/29/1986
| title = Responds to NRC Re Violations Noted in Insp Rept 50-458/86-20.Corrective Actions:Individuals Instructed to Comply W/Requirements of ADM-0003 When Initiating Future Temporary Change Notices
| 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-24275, NUDOCS 8609170283
| title reference date = 07-30-1986
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}

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1 GULF STATES                           UTILITIES COMPANY .
RIVER BENO STAllON      POST OFFICE BOX 220    ST FRANCISVILLE, LOUISIAhA 70775 AstEA CODE SO4     635 6094     346 8651 l
August 29, 1986                                 l RBG-       24275                                )
File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator                                                                   '
U.S. Nuclear Regulatory Commission Region IV                                                                                    f.,                                  )
611 Ryan Plaza Drive, Suite 1000                                                             , "' 'j [};/  @ ,L.r, {j . <. ,'     ;
Arlington, TX 76011                                                                             s;                            ,

==Dear Mr. Martin:==
SEP - 41986        [
River Bend Station - Unit 1                                       -
Refer to: Region IV                                                                        '
Docket No. 50-458/ Report 86-20 This letter is in response to                                         the        Notice           of Violation contained in, NRC Inspection Report                                       No.         50-458/86-20.                   The inspection was            performed by Messrs. D. D. Chamberlain and W. B.
Jones during the period                           May       1     through            June        15,         1986,      of activities authorized by                       NRC Operating License NPF-47 for River Bend Station Unit No. 1.
Gulf States Utilities Company's (GSU) response to the Notice of Violation 8620-01 and 8620-02 is provided in the enclosed attachment.       This completes GSU's. response to the Notice of Violation.
Sincerely, l
W. J. Cahill, Jr.-
Senior Vice President River Bend Nuclear Group 19 025 WJC/ ERG /RRS/ks Attachment 8609170P83 860829                                                                                              k PDR       ADOCK 05000458                                                                                     0 G                              PDR y\

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UNITED STATES OF AMEEICA NUCLEAR EEGULATOET C(BSEISSION STATE OF IOUISIAEA                     $
PARISE OF WEST FELICIANA               5                              .
In the Matter of                       I          Docket Nos. 50-458 CULF STATES UTILITIES C(BEFANY         l (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 Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.
                                                                 /
e 1
W. Cahill, Jr. //
Subscribed -and sworn to before me, a Notary Public in and for the State and Parish above named, this /7 day of duud ,19f/o.
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banW.Middlebloops N/hAnh Notary Public in and for West Feliciana Parish, Louisiana My Connaission is for Life.

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ATTACHMENT Response to Notice of Violation 50-458/8620-01 Level IV FAILURE TO FOLLOW ADMINISTRATIVE PROCEDURES FOR ISSUANCE OF TEMPORARY CHANGE NOTICES (TCN's)

==REFERENCE:==

Notice of Violation        -
Letter  to W. J. Cahill, Jr. from J. E.
Gagliardo dated July 30, 1986.
REASON FOR THE VIOLATION During an NRC inspection conducted on May 1 through June 15, 1986,    the     inspectors   identified   a   failure   to    follow Administrative procedures. As a result of personnel oversight, I&C Maintenance Technicians failed to comply with the procedural requirements        of    Administrative    Procedure      (ADM)-0003,
      " Development, Control and Use of Procedures" when initiating Temporary Change Notice No. 86-0581 for procedure STP-051-4210.
This     resulted in an official work copy of the procedure containing duplicate page numbers with different Temporary Change Notice (TCN) Numbers on each page.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED On April      10,   1986, prior to the NRC inspection, Memorandum No.
PAS-86-141 was issued identifying procedures with two or more TCN's     having duplicate pages with different changes.           The memorandum identified the deficiencies with STP-051-4210 and requested that the faulty TCN's be corrected.
In response to Memorandum No. PAS-86-141, Procedure STP-051-4210, Revision 2, was submitted for revision on April 20, 1986 to incorporate the outstanding TCN's and eliminate the duplicate pages. Revision 3 of STP-051-4210 was approved and issued on July 30, 1986.
CORRECTIVE STEPS WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The I&C Procedure Coordinator reviewed the TCN deficiencies with the responsible individuals and instructed the individuals to comply with the requirements of ADM-0003 when initiating future TCN's.
Memorandum No. PIC-M-86-ll6 was issued on July 9, 1986 requesting that TCN's issued by the I&C Maintenance Department be routed through the I&C Procedure Coordinator prior to obtaining the Shift Supervisor's signature.        The I&C Procedure Coordinator is responsible for reviewing TCN's being issued to assure compliance l    with ADM-0003 and evaluates the necessity of the TCN. The

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Page 2 ATTACHMENT (Cont'd) routing   of the TCN through the I&C Procedure Coordinator will be discontinue ~d' when  the number of     TCN's   being ' issued   is significantly reduced.
To prevent recurrence of similar violations, ADM-0003 was revised on 8/6/86 to clarify procedural instructions for issuing a TCN to a page that has been previously changed by a TCN.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED STP-051-4210 was revised on July 30, 1986 to incorporate the outstanding TCN's and eliminate the duplicate pages.
River Bend Station is currently in compliance.

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Page 3 ATTACHMENT (Cont'd)
Response to Notice of Violation 50-458/8620-02 Level IV FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY REASON FOR THE VIOLATION A walkdown of the "C" Residual Heat Removal (RHR) system by NRC inspectors identified the following differences between actual system configurations and controlling instructions, procedures, and    drawings:   1)  five pipe caps,    shown as installed on Engineering, Piping and Instrument Drawing PID-27-C 'were not installed,   2) valve E12*MOVF064C, which was shown closed on Engineering, Piping and Instrument Drawing PID-27-7C was open, 3) valve E12*VF063C was not locked, although Engineering, Piping and Instrument Drawing PID-4-3C showed this valve to be locked, 4) differences were found between Engineering, Piping and Instrument-Drawing PID-27-7C_and System Operating Procedure, SOPS 0031, as to which valves were locked in position..
Item 1 Investigations to determine the reason that the pipe caps are missing, although shown installed on -Engineering, Piping and Instrument Drawing, PID-27-7C, are indeterminate.
Item 2 The minimum flow. valve E12*VF064C was placed in the open position, per the SOP-0031, however, PID-27-7C showed this valve to be closed.
Item 3 Operations personnel had previously performed an audit of locked valves on the RHR system and determined valve E12*VF063C was verified to be closed, but no lock was installed on the valve because it was approximately twenty feet above the floor and considered inaccessible.
Item 4 Operations was. aware of the differences between the two existing system drawing types snd the SOP's and was in the process of correcting 'this situation by revisions to the PID's and the SOP's. The cause of these discrepancies was determined to be the lack of configuration management programs to ensure procedure updates on the issuance of changes to drawings and drawing updates to reflect commitments to lock specific valves.

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Page 4 CORRECTIVE STEP WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The five missing pipe caps that are shown on PID-27-C have been replaced.
Since valve E12*MOVF064C was in the proper position in accordance with SOP-0031 it will be left in this position (i.e., open to allow minimum flow).
Valve E12*VF063C has been locked as shown on PID-4-3C.
Operations has revised the RHR SOP to agree with existing PID's.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Nuclear Equipment Operators on rounds will take notice of missing pipe caps and replace them. A supply of caps has been placed in the Control Room for this purpose. Additionally, Local Leak Rate Testing      (LLRT)   Procedures will include a step' to ensure replacement of caps which are removed for LLRT.       Nuclear Plant Engineering. (NuPE),     along with Stone & Webster (S&W) is in the process of determining which valve caps are required for a system to meet its intended design.
PID's will be revised to indicate valve position for a normal mode of operation, and Station Operation Manual (SOM) procedures will govern actual-valve position.
A   new procedure,- Operation Section Procedure OSP-0014, which       1 directly addresses the control of locked valves has been issued by the River Bend Operations Department.
A review of all PID's versus SOPS has been conducted.      Changes to the procedures have been issued to agree with the PID's.            A review of the PID's is being performed by NuPE to determine which valves should be locked-and which should be left unlocked.       NuPE will also develop a procedure which.will delineate the locked valve regulation requirements. Included in this review will be the necessary changes of PID's to match these requirements. Upon completion, it is expected this will decrease the number of valves required to be locked.
Adequate      configuration   management   control   procedures are currently in place. All changes to locked valve status   will be followed by updates to the SOP's via these controls.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The additional procedural controls ensuring replacement of pipe caps in Local' Leak Rate Testing Procedures will be completed by October 30, 1986.

c ATTACIIME.T N   (Cont'd)
Valve E12*VF063C   has  been verified to be locked at the time of this response.
Procedures being developed by NuPE for determining locked valve regulation requirements will be completed by November-30, 1986.
The PID changes brought about by NuPE's reviews will be completed by December 31, 1986.
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