View source for RBG-24583, Forwards Supplemental Response to Violation 8620-02 Noted in Insp Rept 50-458/86-20.Corrective Actions:Missing Pipe Caps Replaced,Valve E12*VF063C Locked & RHR SOP Revised to Agree W/Existing Engineering,Piping & Instrument Drawings

{{Adams
| number = ML20215N076
| issue date = 10/17/1986
| title = Forwards Supplemental Response to Violation 8620-02 Noted in Insp Rept 50-458/86-20.Corrective Actions:Missing Pipe Caps Replaced,Valve E12*VF063C Locked & RHR SOP Revised to Agree W/Existing Engineering,Piping & Instrument Drawings
| 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-24583, NUDOCS 8611040248
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 6
}}

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f GULF STATES                         UTILITIES COMPANY RNER BEND STATION     POST OFFICE BOX 220    ST FRANCISVILLE. LOUISLANA 70775 APEA CODE 504     635 6094     346 8651 October 17, 1986 RBG-         24583 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

==Dear Mr. Martin:==

River Bend Station - Unit 1 Refer to:              Region IV Docket No. 50-458/ Report 86-20 This letter is in supplemental 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)                                      supplemental response to     the   Notice of Violation 8620-02,                                        " Failure         to Control Activities Affecting Quality", is provided in                                                   the   enclosed attachment.        This completes GSU's response to the Notice of Violation.
Sincerely, W. J..Cahill, Jr.
Senior Vice President River Bend Nuclear Group Attachment                                                            .
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UNITED ETATES OF AMERICA NUCLEAR REGUIATORY C(BAEISSION STATE OF IAUISIANA                                  5 PARISN OF WEST FELICIANA                            $
In the Matter of                                    I              Docket Nos. 50-458 GULF 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 Rggulatory Conunission the documents attached heretos and that all such documents are true and correct to the best of his knowledge, information and belief.
                                                                           .          /
W. Jf Cahill, Jr.
1 I
Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /7          ,
day of   /[ M W , 19 d .
                                                                   ' <tr o       O v       i   N i -
j 'Joan W. Middlebrooks
                                                        /     Notary Public in and for West Feliciana Parish, I                                                             Louisiana My Conunission is for Life.
I

ATTACHMENT Response to Notice of Violation'50-458/8620-02 Level IV FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY REFERENCE Notice of Violation-- Letter to W. J. Cahill,    Jr. from   J. E.
Gagliardo dated July 30, 1986.
Request for supplemental information - Letter.to W. J. Cahill, Jr. from J. E. Gagliardo dated September 16, 1986.
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 PID-27-7C was open, 3) valve E12*VF063C was not locked, although PID-4-3C- showed this valve to be locked, 4) differences were found between PID-27-7C       and   System _   Operating   Procedure, (SOP)-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 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 and 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 i
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         .. _                 ,            -        . . - --             - _       -       -_~        _ - - = - . - _ -
ATTACHMENT (cont'd.)                           Page 2 s-4             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.
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).                                                                                      ,
l           ~ Valve E12*VF063C has been locked as shown on PID-4-3C.
j              Operations has revised the RHR SOP to agree with existing PID's.
l              CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Nuclear' Equipment _ Operators on rounds will take notice of missing-pipe cape and replace them. A supply of caps has been placed in the ~ Control . Room for this purpose.                         Local Leak Rate Testing (LLRT) Procedures include a step to ensure replacement of caps which are . removed'for LLRT. -GSU Design Engineering, along with Stone & Webster (S&W) is in the process of determining which pipe caps are. required for a system to meet its intended design, i              A new procedure, Operation Section Procedure (OSP)-0014, " Control j              of Locked Valve's and Devices",- which directly controls locked
                                        ~
l             valves.and other devices required to be locked has been issued by                                     '
I              the' Operations Department.                                                                               ;
i' GSU Design Engineering has initiated two Modification Requests i               (MR's),         Nos. 86-1587 and 86-1588, to add notes to the-PID's j             .concerning valve position and pipe caps. A note will he added to PID's stating that valve positions'shown on the PID's are for the normal mode of operation and are for information only. The valve
!              positions indicated by the PID's are not to be used for actual                                           ,
!              valve lineups. Station Operation Manual                        (SOM)     procedures will
!              govern actual . valve position.                     Another      note   on the PID's will j              state that pipe caps are not                  required       for   system    operability.
Any exceptions to this note w'ill be identified on the PID.
A review of PID's against Flow Diagrams (FSK's) and Loop Diagrams by ~S&W began              in January         1986.      This         review    identified discrepancies in these drawings. MR's were initiated _to resolve c
these discrepancies in accordance with existing design control l              procedures. This initial review has been completed, however, all MR's have not been closed. Ninety-Five (95) MR's were identified i
I.._-._.         - - . . __--        -           - ,-._____.__._,-_u_..                   ._...._____..__...__i

ATTACHMENT (cont'd.)             Page 3 that affect PID's. Design Engineering will conduct a survey of a 10% sample of safety related.PID's to verify the effectiveness of the S&W review.         If additional discrepancies are identified, an MR is processed in accordance with NuPE-AA-0054, " Guidelines and Instructions for Processing Modification Requests".
PID's will be reviewed and revised to include locked open and locked closed designations for those valves which must be locked because of regulatory requirements. A list of locked valves will be generated and a Design Engineering procedure developed to control this list and to delineate the~ requirements for locking valves. Upon completion, this procedure will be forwarded to Operations for implementation under OSP-0014.
The      criteria     will divide locked valves into two groups:
regulatory required locked valves and administrative required locked valves.         Regulatory required locked valves are those valves that must be locked in ,accordance .with              regulatory requirements.        Administrative required locked valves are those which, at the discretion of the River Bend Operations Department, must be locked for safety considerations or other administrative reasons.
Overall, it is anticipated that this review process and the establishment of the locked valve criteria will reduce the number-of required locked. valves.
A review of PID's versus SOP's has been conducted.         Changes to
         'the procedure have been issued to agree with the PID's. ' Adequate configuration management control procedures are currently in place, and 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 procedural controls ensuring replacement of Local Leak Rate Testing Procedures are in place.
pipe   caps  inl Valve E12*VF063C        has .been verified to be locked at the time of this response.
MR's issued to correct discrepancies between PID's and FSK's -andl Loop Diagrams will be completed by December 31, 1986.
The review of PID's with respect to locked valve criteria and the procedures controlling these locked valves will be completed by November 30, 1986.

ATTACHMENT (cont'd.)                                                                   Page 4 i .
MR     86-1587 concerning pipe caps on PID's and MR 86-1588 concerning valve position will.be completed by December 31, 1986.-
The Design. Engineering survey of safety                                                           related                      PID's                     will be completed by December 1, 1986.                                                                                                                                                             ,
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