View source for RBG-24325, Suppls Response to Violations Noted in Insp Rept 50-458/86-08.Complete Review of 1985 Internal Audit Files Will Be Completed by 861128,not 860831,due to Unanticipated Scope of Task

{{Adams
| number = ML20210D241
| issue date = 09/05/1986
| title = Suppls Response to Violations Noted in Insp Rept 50-458/86-08.Complete Review of 1985 Internal Audit Files Will Be Completed by 861128,not 860831,due to Unanticipated Scope of Task
| 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-24325, NUDOCS 8609190086
| package number = ML20210D222
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 8
}}

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o GULF STATES                        UTILITIES COMPANY RIVER BfhD STATION     POST OFFICE BOX 220     ST. FRANCISVILLE. LOul51ANA 70775 AREA COOE 504      635-6094      346 8651 September 5, 1986 RBG- 24325 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator                                                        -
                                                                                                               -g U.S. Nuclear Regulatory Commission Region IV                                                                               i    .
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E    i' 611 Ryan Plaza Drive, Suite 1000                                                        5#
Arlington, TX 76011 gg yg u6

==Dear Mr. Martin:==

River Bend Station - Unit 1 Refer to:               Region IV Docket No. 50-458/ Report 86-08 This supplemental letter responds to the Notice of Violations contained in NRC I&E Inspection Report No. 50-458/86-08.                                                The inspection was performed by Messrs. D. D. Chamberlain, R. E.
Farrell, and W. B. Jones during the period February 1 through March 15, 1986 of activities authorized by NRC Operating . License NPF-47 for River Bend Station.
Gulf States Utilities Company's (GSU) supplemental response to Notice of Violation 86-08-01, " Improper Disposition of Startup Test Deficiency", and 86-08-02, " Failure to Schedule an Audit Early in the Life of an Activity", are provided in the enclosed attachments. This completes GSU's supplemental response to the Notice of Violations.
Sincerely,
                                                                                                       -r l
                                                                                 . J. Cahill, Jr.
Senior Vice President
* iv r Bend Nuclear Group WJC/E   R   /P T/je Attachments 8609190086 860916                                                                                          j PDR  ADOCK 05000458                                                                                        '
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O
   .                                   UNITED STATES OF AMERICA EUCLEAR REGUIATORT CGGGSSION 1
STATE OF IOUISIAEA                      5                                                                                                                                                                           l FARISE OF WEST FELICIANA                5                                                                                                                                           .                               i In the Matter of                        5                                     Docket Bos. 50-458 GULF STATES UTILITIES CGIFANT           $
(River Bend Station, Unit 1)                                                                                                                                                                                                    .
AFFIDAVIT W. J. Cahill,   Jr.,  beins duly sworn, states that he is a Senior Vice Pra?ident of Gulf States Utilities Company                                           that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Cossaission the documents attached heretos and that all such documents are true and correct to the best of his knowindge, information and belief.
A W[. Cahill,'Jr//
Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this                     ay of                           Ma ,1986.
t     .   .
Joan W. Middlebroo(s Notary Public in and for                                                                                                                                                    1 West Feliciana Parish,                                                                                                                                                      I Louisiana My Comunission is for Life.
                          -                    -_                             .v   .,.

ATTACHMENT 1 f                                                              Response To Notice Of Violation 458/8608-01 1
Level IV                                                                                                l l
REFERENCE
 ,                                                                                                                                                                                               l
!                                                                                                                                                                                                i Notice of Violation                                            -
J. E. Gagliardo letter to W. J. Cahill, Jr.
dated May 1, 1986, Docket 50-458, License No. NPF-47.                                                                                                                        -
A. IMPROPER DISPOSITION OF STARTUP TEST DEFICIENCY l
I REASON FOR VIOLATION j
Condition Report (CR) No. 85-0622 was written to document a test                                                                                                           .
;                     exception (TE-1)                                           following performance of Start Up and Test                                                                      !
Procedure ST-31. The test exception was closed on 2/4/86 based on                                                                                                          i i                     NuPE's disposition to the noted CR. The violation occurred when it was discovered that a telecopied design evaluation from Stone &
Webster Engineering Corporation (SWEC) to Gulf States Utilities 1                     Company (GSU) which formed part of the. basis for the disposition to the CR, did not contain signatures of approval or verification.                                                                                                        ,
The responsible GSU system engineer did not notice that signatures                                                                                                         l 1
                  . were lacking and, therefore, proceeded to disposition the CR based                                                                                                         l on the unsigned telecopy which is not consistent with normal practice.
The CR was                                            presented to the Facility Review Committee (FRC) for approval of Test Exception 1 to ST-31, " LOSS OF OFFSITE POWER".
The FRC is responsible for reviewing and approving Startup Test Program Test Exceptions (TE). TE-1 to ST-31 required Condition                                                                                                             ,
Report (CR) No. 85-0622 be dispositioned prior b closure of TE-1.                                                                                                         '
:                     The CR was reviewed by NuPE and a summary disposition was presented to the FRC which stated that Modification Request (MR)                                                                                                           l No. 86-0035 was initiated. The MR was generated to assure that                                                                                                             )
,                     only one division of the Control Building Chilled Water System                                                                                                             l
!                     would start following a loss of offsite power. The FRC review was determined to be adequate for closure of the TE based on the disposition prepared by NuPE.                                                                                                                                              1 l
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
!                     SWEC was contacted via phone regarding the subject .telecopy, at
,                     which time it was noted that a formal calculation would not yield
.                     results different from those presented in the telecopy.                                                                                                            GSU
;                     requested SWEC to provide a formal calculation with appropriate reviews. Calculation PB-364 was formally transmitted from SW3C to GSU to document these results.                                                                 The results from calculation PB-364 did not differ from those presented in the unsigned i                     telecopy.                                           Therefore, the disposition to CR NO. 85-0622 did not change. It should be noted that neither the unsigned telecopy or i                     calculation PB-364 were attached to the CR, rather, they are a
_,.I

I ATTACHMENT 1 (cont'd.)
part of supporting documentation                                          used      to     form      a   basis                           for dispositioning the CR.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The      FRC       does       not track approved MRs.                             For this instance, CR No.
85-0622 was the source document for MR 86-0035.                                                 Control of the implementation and maintenance of the design process rests with NuPE as            specified in NPE-03-006, " Design                                          and       Modification l                  Control".            All       MRs                are     processed       internal      to    NuPE     in accordance with NuPE procedure                                 NuPE-AA-54,            " Nuclear          Plant       Engineering Guidelines and Instructions for Processing Modification Requests".
If MRs are cancelled, procedure NPE-3-006 requires the Design System          Engineer                        (DSE)            to  write        a     memorandum providing justification and requesting permission from the Plant Manager to cancel a MR. Upon obtaining the Plant Manager approval to cancel a MR, the Design Control Coordinator (DCC) must provide a copy of l                  the cancelled MR to the initiator, the DSE, and the Plant Manager.
1                  MRs that require changes to the Final Safety Analysis Report
:                   (FSAR)     require NuPE to generate a " Change to a Licensing Document j                   Form" in accordance with NuPE-AA-54. FSAR change request forms are        submitted              to Nuclear Licensing pursuant to RBNP-0027,
                    " Initiation of a Change to a Licensing Document".                                                                                                ,
NuPE procedure                 NuPE-AA-54 is being revised to require the DSE to                                                                  .
ensure that any documentation used during developing the design input for a MR, which is received form a vendor or agent, be
:                   officially signed and dated. In addition to this request, the i                   Engineering Coordinator will be procedurally required to review all MR's and FCN's for compliance with the added review required j                   in NuPE-AA-54.
!                  NuPE has assigned a Mechanical Engineer to review a random sample of approved and processed MR's for the subject concern. The review will be completed by June 15, 1986.                                                   Should the review j                  identify any reoccurrence of the aforementioned, appropriate
!                   corrective action will be implemented.                                            In addition, NuPE will i
take this opportunity to issue a memorandum which instructs its engineers to ensure that any documentation used during the design j                  process received from a vendor or outside agent be officially j                   signed and dated. This memorandum will be issued by June 6, 1986.                                                                                   l l
i                  DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
: 1)    ' SWEC calculation PB-364 was received on April 2, 1986.                                                                            )
l
: 2)       NuPE-AA-54 will be revised by June 15, 1986.
1
;                             3)       A  sample                     review           of MRs will be completed by June 15, i
1986.
I
   - . . . . - -    .-.,     ,   --       ..        . - _ . _ _ ~ ,          _ . - _      - -                                                       . . . - - . - , .

ATTACHMENT 1 (cont'd.)
: 4)   A memorandum instructing NuPE engineers will be issued by June 6, 1986.
e e

1 ATTACHMENT 2 5
Response To Notice Of Violation 458/8608-02
 !                                                                                                                                 Level IV l
l              REFERENCE Notice of Violation                                                                                -
J. E. Gagliardo letter to W. J. Cahill, Jr.
]               dated May 1, 1986, Docket 50-458, License No. NPF-47.                                                                                                                    ,
B.               FAILURE TO SCHEDU;.E AN AUDIT EARLY IN THE LIFE OF AN ACTIVITY i                               REASON FOR THE VIOLATION 1
!                                The failure to schedule an audit of Facility Review Committee
:                                  (FRC) review activities early in the life of this activity was due j                                to a lack of programmatic controls associated with follow-up l                               conditions related to Quality Assurance (OA) audits.                                                                                                    L j                                An audit addressing Startup                                                                         and Test       (SU&T)  activities and FRC j                                review                                    was                            performed                        in   February,     1985    (Audit No.
l                               GSUS/SU&T-85/02). However,                                                                          FRC review activities at that time j                                were predominantly review                                                                           and approval of start-up procedures as
:                               the actual start-up phase                                                                           had not yet commenced.              The audit l                               checklist documented this                                                                                fact and indicated that a subsequent i                              audit would be scheduled to                                                                              address these activities following commencement.
!                                Until recently, a procedural mechanism had not existed to assure j                                that activities, not covered in an audit scope, were brought forward for consideration in future audit conduct.
{
I                                Revision 0 of the Master Audit Schedule included an audit of I
Startup and Test activities. However Revision 1 of this schedule t                                deleted this audit. The justification for this deletion was not j
~
properly communicated and objective evidence could not be found in support of this deletion.                                                                                                                                ,
l                                Discussion with                                                              the past Audit Coordinator, who had recently l                                terminated as a GSU employee, indicated his intent was to include                                                                                        '
t                                FRC Review Activities in the scope (s) of related audit activity.                                                                                        l CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An evaluation of FRC Review of SUsT activities was included in the i                                scope of Audit 86-03-1-STPG,                                                                                  " Surveillance    Test        Program",
l                                conducted in March, 1986. The scope of this audit was increased
;                                to include the SU&T activities and FRC reviews performed during
:                                the subject period in February, 1985.
t l                             .One deficiency was identified relative to administrative controls I                                required by the RBS Startup Manual - the documentation of required
_ _ _   . . _ . _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ . - . - - _ . . _ , _ - _ _ _ . . _ _ _ _ . _ _ _ . ~ . . . _ _ _ . .                _

ATTACHMENT 2 (cont'd.)
reviews of the initial Startup Test Log.                                                         This deficiency- was i
documented                        as           Quality Assurance Finding Report .. (QAFR) No.
P-86-04-012 and is currently in the corrective action process.
As           part of the scope, the audit addressed a follow-up to the Operations QA Surveillance efforts. A finding had been identified in January, 1986 addressing deficiencies in the area of FRC Review and Approval of Test Condition (TC) Heat-Up without taking proper j
exception to ST-11, "LPRM Calibration", and ST-13, "NSSS Process Computer". Results indicated the corrective actions taken to 3                                            address QAFR No. O-86-01-02-D have prevented recurrence of this l                                            problem during subsequent FRC review and approval of TC-1 and l                                            TC-2.
l
)                                            Results of this audit effort indicated                                                             that         the     overall l                                           performance of Plant Staff in the review and approval of initial startup test results is considered satisfactory.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS I                                            In March of 1986, QA Systems performed a review of the GSU j                                            Internal                       QA Audit Program (QAI-2.1, " Audit Performance and a                                            Reporting")                      to assess adequacy and                                   effectiveness.                Results indicated weak programmatic controls relative to several elements, l                                           one of which involved audit schedule / scope reviews.                                                                 Two QAFRs (QAFR Nos.                     P-86-03-015                         and  P-86-03-016)      were          issued  to document l                                           these deficiencies and are currently in the corrective action i                                           process. The actions to correct and prevent similar recurrence of problems include:                                                                                                .
la.           Instituting a 100% review of all 1985 audit files against a given checklist of tasks, such as:
j                                                          -a              determination of any outstanding audit checklist items 4
identified as requiring attention during subsequent' audits, 4
and
:                                                          - an indication of those unsatisfactory audit checklist items
{                                                             which do not appear to be supported properly (i.e.,                                                                           ;
justified or referenced to QAFR number).                                                                                      i j                                            lb.           Assuring that these deficient                                         or      questionable              items are                l l                                                          corrected and/or accounted for.
I This review is projected to be complete by November 28, 1986.l Corrective action as applicable for those deficiencies identified i
by the review will be corrected by December 31, 1986.
l                                           2.             Revising procedure QAI-2.1 to include necessary programmatic i                                                          controls in sufficient detail                                              to     assure            commitments /                l i                                                          requirements are implemented properly.                                                                                           j i
i n
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ATTACHMENT 2 (cont'd.)
  ~
Procedure QAI-2.1 will be revised by July 15, 1986.
: 3. Provided training to the auditing          staff   on "the    proper implementation of these requirements.
This is currently an ongoing effort and     will    continue     following the issuance of the revised QAI-2.1.
Although QAI-2.1 has not yet been issued to address increased program controls, these controls have been invoked and are currently implemented. Completed audit files dating back to January,      1986   have been properly reviewed and maintained.
Personnel have been instructed in required procedural guidelines and mechanisms are in place to assure accountability of each audit scope.
2 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED la. A complete review of 1985 internal audit files will be completed by November 28, 1986. Forty-four (44) audits are being considered in this review of which thirty-three (33) have been reviewed and eleven (11) remain to be reviewed.
This date differs from the previously submitted completion date of August 31, 1986 because of the unanticipated scope of the task necessary to comprehensively complete this review.
Ib. The applicable corrective action        based   on     la will    be completed by December 31, 1986.
: 2. A revision to QAI-2.1 will be completed by July 15, 1986.
: 3. Training of auditors is ongoing. Training of auditors to revised QAI-2.1 will be completed by August 1, 1986.
l l
l 1
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