View source for RBG-27174, Responds to NRC Re Violations Noted in Insp Rept 50-458/87-27.Corrective Actions:Field Engineering Procedures Given Required Approvals & Repairmen Received Personal Instructions on Requirements for Use of Hot Work Permits

{{Adams
| number = ML20237E517
| issue date = 12/18/1987
| title = Responds to NRC Re Violations Noted in Insp Rept 50-458/87-27.Corrective Actions:Field Engineering Procedures Given Required Approvals & Repairmen Received Personal Instructions on Requirements for Use of Hot Work Permits
| author name = Deddens J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000458
| license number = 
| contact person = 
| document report number = IEIN-85-003, IEIN-85-3, RBG-27174, NUDOCS 8712290041
| title reference date = 11-17-1987
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 6
}}

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GULF STATES RIVER BEND STATION UTILITIES C'OMPANY POST OFFICE BOX 220 Ye2
                                                                                                                         $7 FRANCISVILLE, LOUISIANA 70775 AREA CODE 504              636-6094     346-8651 December 18, 1987 RBG - 27174 File'Nos. G9.5, G15.4.1 U. S. Nuclear Regulatory Commissions Document Control Desk Washington, D.C. 20555 Gentlemen:
River Bend Station - Unit 1 Refer to: Region IV
                                                                                  ~ Docket No. 50-458/ Report 87-27 This letter responds to the Notice of Violations contained in NRC Inspection Report No. 50-458/87-27. The inspection was performed by Messrs. Chamberlain and Jones during the period of October 1-31, 1987 on-activities authorized by NRC Operating License NPF-47 for River Bend Station Unit No. 1. Gulf States Utilities Cocpany's (GSU) response to Notice of Violations 458/8727-01, " Failure to 9btain Required Procedure Approval", and 458/8727-02 " Failure to Initiate it? brP Permit for Grinding Activity", is providad in the enclosed attachment pur>uant to 10CFR2.201. This completes GSU's response to these items.
                                                                                                                                                  -Sincerely,
[-
J. C. Deddens Senior Vice President River Bend Nuclear Group JCD/DRD/JWL/IN/ ERG JHM/tl cc:   U.S. Nuclear Regulatory Commission                                                                                     I 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector                                                                                                 i P. O. Box 1051 St. Francisville, LA 70775
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87125 0041 871218 PDR         ADOCK 05000458 0                         DCD                                                                                                           \

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA                                                    )
PARISH OF WEST FELICIANA                                              )-
In the Matter of                                                     .)         Docket No. 50-458 50-459 GULF STATES UTILITIES COMPANY                                         )
(River Bend Station, Unit 1)
AFFIDAVIT J.      C. Deddens, 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.
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[J   //w J. C.beddens-Subscribed                    and sworn to before me, a Notary Public in and for the State and Parish above named, this                                      /h day of h0PfYlbfr~ -                                          ,  19     .
                                                                                       'MA     ,  - .J          1A
                                                                                    /,Joan W. Middlebrooks FNotary Public in and for West Feliciana Parish,-              j Louisiana My Commission is for Life.
L__ _ _ _ __ ____________________-_____ - _ _ _ _ _ - _ _ _ _ - . _  _ _ _ _ .                                -           >

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ATTACHMENT Response To Notice of Violation 50-458/8727-01 Level V i

==REFERENCE:==

Notice of Violation - letter from L. J. Callan to J. C. Deddens, dated November 17, 1987.
VIOLATION - Failure to Obtain Required Procedure Approval River Bend Station Technical Specifications, Section 6.5.2.1, require that each procedure and program of Specification 6.8, which includes surveillance and test activities of safety-related equipment, shall be approved, prior to implementation, by the Plant Manager or one of the Assistant Plant Managers or the Supervisor-Radiological Programs.
Contrary to the above, on October 6,1987, during observation of a maintenance activity, the senior resident inspector found that Station Operating Procedure No. TP-87-29, "RCIC Signature Testing", was being implemented to test safety-related motor operated valves in response to NRC Bulletin 85-03. This procedure had been approved by the Director of Field Engineering, and not by the Plant Manager or one of the Assistant Plant Managers.
REASON FOR THE VIOLATION:
The Engineering Department was reorganized in September of 1986. A new group within the engineering department was formed.from several existing Technical Staff Groups combined with Nuclear Plant Engineering's Mechanical Engineering group to form the Field Engineering Group. The functions of the Technical Staff Groups were also assigned to the Field Engineering Group, along with the procedures necessary for implementation. Control of those procedures was transferred to the Director-Field Engineering by a change to ADM-0003, " Development Control and Use of Procedures", which controls the issuance and modification of procedures in the Station Operating Manual. However, Technical Specification (TS) Section 6.5.2.1 was not changed to reflect that the Director - Field Engineering has assumed signature authority for procedures in the Field Engineering area of responsibility. It was felt that Plant Manager approval of the change to ADM-0003 constituted adequate control. Therefore, the root cause was a result of the reorganization of engineering, and a misunderstanding of the changes required to allow transfer of procedural responsibility to the Field Engineering Group.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The reorganization of the Engineering Department is now complete.
Procedures which had been signed solely by the Director-Field Engineering were reviewed and signed as required by T.S. 6.5.2.1. Thus,    '
the Field Engineering related procedures now have the required approvals.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Corrective measures have been taken to assure STPs in use are properly approved. The Director-Field Engineering now initials applicable Field Engineering procedure changes and forwards them for approval in accordance with T.S. 6.5.2.1. ADM-0003, Figure 1, has been changed to eliminate signature authority for the Director-Field Engineering and has i                                                been replaced with the Plant Manager or Assistant Plant Manager. This I                                                assures that none of the applicable procedures will be issued without the approvals as required by T.S. 6.5.2.1. An initial review of other available procedures controlling signature authority under T.S. 6.8.1 was performed and determined that adequate signatures were controlled.
To ensure that the appropriate procedures are identified and controlled in accordance with T.S. Sections 6.5.2.1 and 6.8.1, a Quality Assurance review will be performed. This review is expected to be completed during January 1988.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The Technical Specifications applicable procedures in active use are signed by the PM or APM. The revisions or changes will be signed by the PM or APM as they are written. Quality Assurance evaluations will be completed during January 1988. Any recommendations will be reviewed for further corrective action.
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                          .                                  ATTACMENT                                               i Response To Notice of Violation 50-458/8727-02 Level V

==REFERENCE:==

Notice of Violation - letter from L. J. Callan to J. C. Deddens, dated November 17, 1987.
VIOLATION - Failure to Initiate Hot Work Permit for Grinding Activity                         ,
Technical Specification 6.8.1.g requires that written procedures be established, implemented, and maintained for activities implementing the fire protection program.
Fire Protection Procedure (EPP)-0060, " Hot work Permit," states that, "A Hot Work Permit shall be required whenever an ignition source is to be,                       ,
used in eny area of the plant, except those areas designated as Hot Work Area." An ignition source is defined as an open flame apparatus, welding, abrasive cutting and grinding, brazing, and other devices whose temperature exceeds the heat of~ ignition of materials in contact or close proximity to the device.                                                                 1 Contrary to the above, on October 24, 1987, at approximately 2 a.m.
(CDT), the resident inspector observed grinding operations on the                               l inboard main steam isolation valve 1B21*A0V022C for the removal of a                           I bolt stud without a Hot Work Permit having been obtained. The area had not been designated as a Hot Work Area, nor had a firewatch been established. Combustible materials were located within close proximity of the grinding activity.
REASON FOR THE VIOLATION:
i Procedure FPP-0060 defines the use of a Hot Work Permit during operation and outage work and requires a permit whenever an ignition source is used in any area of the plant, except those areas designated as permanent Hot Work Areas. During the rework of main steam isolation valves on MWO #105963, two repairmen violated procedure FPP-0060. After attempting unsuccessfully to remove a seized body-to-bonnet nut on 1821*A0VF022B using normal means, the person in' charge of the field work elected to " crack" the nut off. This process involved grinding a notch in the nut and then using a cold chisel to crack the nut in half. The grinding process created sparks in the area. This was a procedure                               I violation because there was not a designated fire watch nor did the                             ;
repairmen have a valid Hot Work Permit.                                                         )
The event occurred at about 0200 hours (eight hours into a 12 hour shift). Dress out requirements included double PC's and a respirator.
The person in charge of the field work decided to continue the job instead of leaving the work area to ensure a valid Hot Work Permit was in effect (a loss of time on the job estimated at two hours). Therefore the root cause of the incident is determined human error. The mechanics assumed that a Hot Work Permit existed rather than one of them leaving the work area to check.

4 CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The person in charge of the field work was given disciplinary action (verbal reprimand) by the Mechanical Maintenance Supervisor. Both repairmen also received disciplinary action and personal instructions on the requirements for use of Hot Work Permits.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
On November 3, 1987, D. R. Derbonne (Assistant Plant Manager -
Maintenance) issued memo number APM-M-87-342 which states the circumstances of the event and promulgates Maintenance Management's position on adherence to procedures.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Gulf States Utilities Company is currently in full compliance.
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