ML20195D825

Requests Addl Info Re Util 880930 Response to NRC 880901 Ltr Re Violations Noted in Insp Rept 50-458/88-18.Response Requested within 30 Days of Ltr Date

ML20195D825
Person / Time
Site:	River Bend
Issue date:	10/28/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8811070142
Download: ML20195D825 (2)

See also: IR 05000458/1988018

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OCT 2 81988

In Reply Refer To: 1

Docket: 50-458/88-18

Gulf States Utilities

ATTN: - Mr. James C. Deddens [

SeniorVicePresident(RBNG)  !

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P.O. Box 220

St. Francisville, Louisiana 70775

Gentlemen:

Thank you for your letter of September 30, 1988, in response to our letter

and the attached Notice of Violation dated September 1, 1988. As a result

of our review, we find that additional information is needed, as discussed with

your Mr. Rick J. King during a telephone call with our Messrs. W. Seidle and

R. Azua on October 25, 1988. Specifically, in the area of "Corrective Steps.

Which Will Be Taken To Avoid Further Violations " it was noted that corrective

steps were not identified for Items B and C that would preclude recurrence of

these events. In addition, the corrective steps described in the second

paragraph of the same section failed to assure that supervisor of the appropriste

discipline would be involved, as comitted to during the exit interview.

Please provide the supplemental information within 30 days of the date of this

letter.

Sincerely,

Original Simwo 3)

11 L Calbn ,

l L. J. Callan, Director

Division of Reactor Projects

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cc:

Gulf States Utilities '

ATTN: J. E. Booker, Manager-

i River Bend Oversight  !'

l P.O. Box 2951

Beaumont, Texas 77704

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Gulf States Utilities

ATTN: Les England, Director .

Nuclear Licensing - RBNG  ;

P.O. Box 220  :

St. Francisv111e, Louisiana 70775 l

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Louisiana State University,

l Goverreent Documents Department

Louisiana Radiation Control Program Director .

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W. Paulson, NRR Project Manager DRS

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OCT 51988 1 l

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U. S. Nuclear Regulatory Comission

Document Control Desk

Washington, DC 20555

Gentlemen:

RIVER 80I6 STATION - UN!T 1

REFER T0: REGT0h IV

DOCKET NO. 50-458/ REP 6RT &-18

Pursuant to 10CFR2.201, this letter responds to the Notice of Violation -

contained in NRC Inspection Report No. 50-458/88-18. The inspection was

performed by Messrs. H. F. Bundy and R. V. Azua during the period August

8-12, 1988 of activities authorized by NRC Operating License NPF-47 for

River Bend Station - Unit 1.

Gulf States Utilities Company's (GSU) response to Violation 8818-01,

"Failure to Properly Evaluate and Document Surveillance Test Results." is

provided in the attachment.

Should you have any questions, please contact Mr. Rick J. King at (504)

381-4146.

Sincerely,

f f.

J. E. Booker

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Manager-River Bend Oversight

River Bend Nuclear Group

Attachment ,

cc: U. S. Nuclear Regulatory Comission

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

NRC Resident inspector

P.O. Box 1051

St. Francisville, LA 70775

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UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

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STATE OF LOUISIANA

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PARISH OF WEST FELICIANA

$

f Docke. No. 50-458

In the Matter of

$

$

GULF STATES UTILITIES COMPANY

$

(River Band Station f

Unit 1) i

AFFIDAVIT

J. E. Booker, being duly sworn . .es that he is Manager-River Bend

OversightforGulfStatesUtilitiesCompany;thatheisauthorizedonthe

part of said Company to sign and file with the Nuclear Regulatory

'

Commission the documents attached hereto; theat he has read all of the

statements contained in such documents attached thereto and made a part

thereof; and that all such statements made and natters set forth therein

are true and correct to the best of his knowledge, information and belief.

.Vh

4. E. Booker

Subscribed and sworn to before me, a Notary Public in and for the State

and Parish above named, this .3d day of 'an im . _.

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% a $

N3fary Public in and for

West Feliciana Parish. Louisiana

My Commission is For Life.

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Attachment 1

Response to Notice of Violation 50-458/8818 01

Level IV

REFERENCE

Notice of Violation - Letter from L. J. Callan to J. C. Deddens, dated

September 1, 1988.

VIOLATION: FAILURE TO PROPERLY EVALUATE AND DOCWENT SURVEILLANCE TEST

RE5 ULT 3

Title 10, Part 50, Appendix B, Criterion" XI, "Test Control," of the Code of

Federal Regulations states, in part, . . . Test results shall be

documented and evaluated to assure that test requirements have been

satisfied." Criterion XI is implemented by RBS Quality Assurance Directive

(QAD)-11, Revision 5. "Test Control." This Directive ilso requires that

recorded data reveal the adequacy of the equipment of syster.c to meet the

specified requirement in the acceptance criteria. Further implementation

of these documents is provided by RBS adninistrative procedures (ADMs) as

discussed below. Section 8.3.1 of ADM-0015 specifically disallows use of

test exceptions when acceptance criteria cannot be met. Section 8.6 of

ADM-0015 requires that all data, calculations, notes, etc., which are

essential in proving the acceptability of s surveillance test procedure

(STP), shall be recorded on the data line provided or attached to the

procedure.

Contrary to the above, the following failures were identified:

A. Test data for STP-051-4210, completed on October 13, 1987, was

incomplete in that page 24 of the 60-page procedure contained no test

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data. This precluded ascertaining that the data had been properly

documented and evaluated as required by 10CFR50, Appendix B, Criterion

XI.

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B. Test exceptions were written for performance of Sections 7.3.4. and

" 5.4 of STP-402-0601, "Standby Gas Treatment System Annulus Mixing

System Functional Tests." Writing test exceptions of an acceptance

criter; n that cannot be met constituted a violation of Section J.3.1

of ADM-0013. Also, the adequacy of the system to meet the specified

requirements in, the acceptance criteria was not revealed by the

recorded data as rgquired by QAD-11.

C. The data and calculation for the average stroke rate of Yalve

1833-HYVF0 GOB timed in Step 7.4.12 of STP-053-0601, "Rectre Flow

Control Valve Operability Test," were not included in the data package

completed on October 24, 1981, as required by Section 8.6 of ADM-0015.

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REASON FOR THE VIOLATION

GSU has determined that the examples cited as failure to follow procedure

were caused by personnel oversite due to inattent'on to detail. However,

these examples are believed to be isolated cases. Further investigation '

into each example is discussed below.

A. Sincu page 24 of 60 for STP 051-4210 is unaccounted for and cannot be

duplicated for record purposes, it can only be assumed that the  !

technicians performing the STP were careless in maintaining the [

documentation.

B. STP-403-0601, completed 12/18/87 for operability of the standby gas

treatment system, was in violation of ADM-0015 Section 8.3.1. The  !

testing engineer identified an unnecessary siep in the procedure. He

labeled the step N/A, wrote a comment on the data page of the STP and ,

listed these steps as test exceptions. Since these steps were listed

in the STP acceptance criteria ne was required to either revise the

procedure or write a TCN to change the acceptance criteria.  ;

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C. For STP-053-0601 Rev. 2, the data chart was misplaced during  ;

transmittal to Pennanent Plant File,

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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVES

A. The missing sign-offs were determined to have no impact on the ,

successful completion of the surveillance test procedure (STP). The l

missing initials were for steps that would have been labeled N/A or

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steps that notified the operator that the STP was in progress.

B. A TCN has been issued for STP-403-0601 to reflect the actual testing l

requirements for the standby gas treatment system. An imediate

special test was performed 8/12/88 demonstrating operability of the ,

system and was documented on CR-88-0644.

C. Again, since missing documents cannot be recreated for record purposes,

the missing data was evaluated and determined to be backup data for the

completion of the test. The data from this chart was recorded in the

contents of the STP.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AY010 FURTHER VIOLATIONS

STP-053-0601, Rev. 2 will be revised to assure that the data chart is

identified as part of the c w pleted data package.

StationSupportProcedI;re(SSP)-1-003,"Rin.ordsManagement/ Permanent Plant

been reviewed for adequacy. Personnel in pennanent plant file

File}"

(PPF hashave been reinstructed on the receipt of STP data packages to assure

that verification of numbered pages and attachments is made, and to assure *

that shift clerks have numbered all attached data sheets. If a discrepancy

is noted by PPF, the document package is returned immediately to plant

staff for correction.

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GSU has begun a random review of STP documentation and completion process.

Results will be reported to the Plant Manager by October 31, 1988. Results

and recomendations resulting from the review will be evaluated to

deterinine what actions, if any, should be taken. A supplemental response

to the NRC will be provided during November, 1988.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVIS

1) GSU's review will be compieted by October 31, 1988.

2) Results of the review will determine any resulting orrective actions

and the date in which they will be completed.

3) A supp1r- ntal response will be provided during November, 1988.

4) STP-053-0601 will be revised by January 31, 1989 since this procedure

will not be run again until the second refueling outage scheduled in

March, 1989.

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