View source for RBG-31351, Responds to NRC Re Violations Noted in Insp Rept 50-458/89-27.Corrective Actions:Administrative Procedure ADM-0002, Charter of Frc, Will Be Modified to Include Review of All Proposed Changes or Mods

{{Adams
| number = ML20245J477
| issue date = 08/11/1989
| title = Responds to NRC Re Violations Noted in Insp Rept 50-458/89-27.Corrective Actions:Administrative Procedure ADM-0002, Charter of Frc, Will Be Modified to Include Review of All Proposed Changes or Mods
| author name = Deddens J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000458
| license number = 
| contact person = 
| document report number = RBG-31351, NUDOCS 8908180045
| title reference date = 07-17-1989
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
}}

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l                    GULF STATES                       UTILITIES COM1'ANY                             :
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August 11, 1989 RBG-31351 File Nos. G9.5, G15.4.1 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/89-27 Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation for NRC Inspection Report No. 50-458/89-27. The inspection was performed by Messrs. W.
M. McNeill and D. L. Kelley during the periods of June 5-9 and 19-23, 1989 of activities authorized by NRC Operating License NPF-47 for River Bend Station - Unit 1. GSU's response to the violation is provided in the attachment. GSU's response to this item is complete.
Should you have any questions, please contact Mr. L. A. England at (504)381-4145.
Sincerely, f
                                                                  /J. C. Deddens
                                                                                     .. m Senior Vice President River Bend Nuclear Group JCD/JEB/LAE/ JK/RGW/ SF/JLB/ch Attachment N
cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Senior Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 IIEO$
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF' LOUISIANA                                                      )
PARISH OF WEST FELICIANA                                                 )
Docket No. 50-458 In the Matter of                                                         )
GULF STATES UTILITIES COMPANY                                            )
(River Bend Station - Unit 1) l 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.
                                                                                                                              . f4 CPY J. Ci Deddens Subscribed and sworn to before me, a Notary Public in                                                            and for   the    State     and                    Parish above named, this                          //      day of h44 Minj        _,                19        Il  . My Commission expires with Life.
0 0 OlkbAL               .
Claudia F. Hurst Notary Public in and for West Feliciana Parish, Louisiana

                                              ' ATTACMENT .
RESPONSE TO NOTICE OF VIOLATION 50-458/8927-01 LEVEL IV REFERENCE Notice of Violation - Letter from J. L. Milhoan to J.      C. Deddens, dated July 17, 1989.
FAILURE TO REVIEW SAFETY QUESTIONS ASSOCIATED WITH MODIFICATIONS, Technical Specifications (TS) Section 6 established the. requirements for
            ~ the FRC and NRB and the requirements for these groups to review various activities. Section 6.5.1.6 requires FRC to be responsible for review of all modifications to structures, components, systems, 'or equipment :that affect nuclear safety. Section 6.5.3.7 requires NRB to be responsible for the review of safety evaluations for changes to equipment or systems l            completed under the provision of 10CFR50.59 to verify that such action did not constitute _an unreviewed safety question.
            ' Contrary to the above, the FRC and f RB had not reviewed the activities l-          ' required by TS.       FRC reviewed only 12 modification requests (MRs) of a sample of 19 facility changes described in the 1987-1988' annual '10CFR50.59-report. NRB reviewed only 17 safety evaluations associated with the same sample of changes identified above.
REASON FOR THE VIOLATION Regarding the FRC, the River Bend Station Safety Analysis Report (SAR),
paragraph 13.4.1.5 stated, "The FRC is responsible for ... review of all' prop 9 sed permanent modifications to safety-related structures,' systems, and components."     NUREG-0989,    " Safety Evaluation Report related      to the Operation of River Bend Station," section 13.4.1, " Facility                          Review Committee," concludes "The FRC responsibilities also cover the appropriate area of responsibility." Administrative Procedure (ADM)-0002, " Charter of the FRC." in section 5.11.4 states, "The FRC is responsible for the ...
review of all proposed changes to structures, components, systems or equipment that affect nuclear safety." To date, the FRC has only reviewed those modifications that are classified as safety-related.        A memorandum issued in August 1985 by the FRC Chairman and the Plant Manager stated, "Unless specifically requested by the Plant Manager, the FRC need not review non-safety related changes, changes to the fire protection systems, or changes to the radwaste systems."
Regarding the NRB, until August 1987, an unreviewed safety question determination (USQD) was performed on all MRs. At that time, the Initial Safety and Environmental Evaluation (ISEE) program was initiated to answer appropriate screening questions to determine if a USQD is required in accordance with 10CFR50.59.        The 10CFR50.59 safety      evaluations                for permanent plant modifications are reviewed by the Unreviewed Safety Question Committee (USQC). The USQC is appointed by the Nuclear Review Board (NRB) to conduct the post-reviews required by Technical Specification (TS) 6.5.3.7. The USQC is comprised of members from the Independent Safety 4
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1 Engineering Group (ISEG). The NRB chartered the USQC during initial plant start-up in late 1985.      Subsequently, a number of changes have been implemented     in the MR process.      As the USQC became aware of the implications of these programmatic changes, the USQC review methods were also changed. For example, the USQC Chairman requested Design Engineering to send the USQC copies of Field Change Notices (FCN) to MRs and USQDs, as well as, initial MRs and USQDs. This was done to ensure that changes and revisions to MRs did not invalidate the 10CFR50.59 reviews contained in the                 1 USQDs. This revuest was made when it was realized that review of FCN and USQD revisions'were not included in the USQC's original methods.                   Evidence i
exists that the USQC has reviewed a significant majority of completed MRs                     >
l l         with USQDs.
The root cause for the violation was the lack of USQC reviews of FCNs and
:          USQD revisions early in River Bend Station's operating history and a l          defined responsibility in the RBS SAR for FRC review to be different than the inspectors inspection criteria. The failure to perform a 100 percent review of USQDs was due to the tvolving nature of the MR program, i
CORRECTIVE ACTIONS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIGEC                            j Of the 19 facility changes described in the 1987-1988 annual 10CFR50.59                      i report, GSU has fond that eleven were reviewed and approved by the FRC.                      ;'
The remaining eight modification requests (MRs) were either classified as non-safety related or did not result in a physical modification of the                       l plant.                                                                                      j The USQC has commenced efforts to ensure its computerized database of                         l reviewed documents is up-to-date. This includes the entry of all documents                  j reviewed and listed in USQC meeting minutes prior to June 1988.                               '
CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS ADM-0002, " Charter of the FRC," will be modified to include the review of l         all proposed changes or modifications to structures, components, systems or l         equipment, changes to procedures, or tests and experiments described in the j          USAR which results in an USQD performed in accordance with 10CFR50.59 to l'         the responsibility of the FRC. Reference to the reviewed USQDs will be noted in the FRC meeting minutes and sent to the USQC Chairman for the l          NRB/USQC review in accordance with TS 6.5.3.7.
The expanded USQC database will be compared to the list of all USQDs for                     4 MRs. Any USQDs which have not received a USQC review will be reviewed in accordance with TS 6.5.3.7. Use of a task force for this will                        be considered if the increase in USQC workload causes a significant impact on other ISEG duties.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l
ADM-0002 will be revised by September 30, 1989.
l The USQC database update will be completed by October 31, 1989. .
l The USQC review of backlogged USQD's of unreviewed MRs will be completed by                  4 December 15, 1989.
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