ML20247H461

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-458/89-11

ML20247H461
Person / Time
Site:	River Bend
Issue date:	07/26/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8907310027
Download: ML20247H461 (2)

See also: IR 05000458/1989011

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In Reply Refer To:

Docket: 50-458/89-11 .

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Gulf States Utilities

ATTN: Mr. James C. Deddens

!-

. Senior Vice President.(RBNG)

P.O. Box 220

St. Francisville Louisiana 70775

Gentlemen:

Thank you for your letter of July 7,1989, in response to our letter and

Notice of Violation dated May 31, 1989. We have reviewed your reply and find

.it' responsive to the concerns raised in our Notice of Violation. We will

review the implementation of your corrective actions during a future inspection

to' determine that full compliance has been achieved and will be maintained.

Sincerely,

Original Signed By

James L Milhoan

James L. Milhoan, Director

Division of Reactor Projects

CC:

Gulf States Utilities-

ATTN:

J. E. Booker, Manager-

River Bend Oversight

P.O. Box 2951

Beaumont, Texas'.77704

Gulf States Utilities

ATTN:

Les England Director -

.

Nuciear. Licensing - RBNG

P.O. Box 220

-St. Francisville Louisiana '70775

Louisiana State University,

Government Documents Department

Louisiana Radiation Control Program Director

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July

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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/ Report 89-11

Pursuant to 10CFR2.201, this letter provides Gulf States Utilities Company's

(GSU) response to the Notice of Violation contained in NRC Inspection Report

No. 50-458/89-11. The inspection was performed by Messrs. E. J. Ford and W.

B. Jones during the period of March 15 through April 30, 1989 of activities

authorized by NRC Operating Licensing NPF-47 for River Bend Station - Unit 1.

GSU's response to the violation is divided into two parts for the sake of

clarification and is provided in the attachments.

GSU will provide a

supplemental response to document the corrective actions taken by December

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15, 1989.

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Should you have any questions, please contact Mr. L. A. England at (504)

{

381-4145.

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Sincerel ,

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J. C. Deddens

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Sr. Vice President

River Bend Nuclear Group

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Attachments

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U. S. Nuclear Regulatory Commission

Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

NRC Senior Resident Inspector

P. O. Box 1051

St. Francisville, LA 70775

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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)

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.

I

h :::

J. C. D6ddens

Subscribed and sworn to before me, a Notary Public in

and

for

the

State

and

Parish

above named, this

Y

day of

(AlA)

19 d

.

My Commission expires with Life.

,

O

l

01a> & Aidwuct

Claudia F.

Hurst

Notary Public in and for

)

West Feliciana Parish, Louisiana

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ATTACFMENT 1

Response to Notice of Violation 50-458/8911-01A

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A.

REFERENCE.

Notice of Violation - Letter from L. J. Callan to J.

C.

Deddens, dated

May 31, 1989

VIOLATION

Criterion XVI of Appendix B to 10CFR Part 50 requires that measures be-

established to assure that conditions adverse to quality are promptly

identified and corrected.

Quality Assurance Directive QAD-16

" Corrective Action," Section 4.3,

states that procedures shall require that corrective action be promptly

initiated and adequately documerted by the responsible department to

correct the condition and to determine if action is necessary to preclude

its recurrence.

River.-Bend Nuclear Procedure RBNP-0047, " Corrective Action Program,"

Section 5.4, requires that corrective action be promptly initiated and

adequately. documented- by the responsible department to correct the.

condition and to' determine if action 'is necessary- to preclude its

recurrence.

Contrary to the above, adequate corrective actions were not taken to

prevent repeat violations

of

Administrative

Procedure

ADM-0027,

" Protective Tagging."

During the period of March 18 through April 12,

1989, the licensee identified eleven procedural violations of ADM-0027.

The corrective actions taken did not determine the extent to which

protective tagging program violations existed.

REASON FOR VIOLATION

GSU has reviewed the associated protective tagging program condition

reports

(CR) stated in Inspection Report 8911 and other related CRs

initiated during the second refueling outage (RF2). GSU has reviewed the

chronology presented in the Inspection Report and finds it accurate. The

various problems identified from our review of CRs can be categorized

into four major areas:

1.

Individuals working without a clearance or a wrong clearance,

2.

Tagging boundaries were violated,

3.

Clearances were released without work being finished, or

4.

Crews began work on the wrong train.

Several

root ~ causes have been identified from GSU's review.

The

contributing

causes were attributed to poor communication between

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contractor. work crews and their

supervisors,

contract

personnel

unfamiliarity with RBS plant design, and failure of contract personnel to

take adequate

to follow details

in RBS administrative

(ADM) precautions

procedure

-0027,

" Protective Tagging". GSU determined'the primary

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cause was

inadequate training of contract personnel

to

ADM-0027

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requirements.

In addition, the re-training provided as a corrective

action was not adequate to preclude future occurrences.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED

Numerous corrective actions were taken for each RF2 CR related to

protective tagging.

GSU took additional actions after recognizing that

previous corrective actions had not been adequate to prevent recurrence

of additional tagging violations.

Immediate corrective actions include:

1)

Contract personnel

responsible for the tagging violations were

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re-trained,

2)

Tagging procedure @ M-0027) was revised,

3)

Additional " Tool Box" and formal classroom training was conducted,

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4)

Individuals involved in violations were removed from the " Authorized

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Requestor" list,

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5)

GSU personnel were assigned to oversee and co-sign contractor

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clearances,

6)

A 100% review of open supplemental clearances and partial

reicases

as completed,

7)

GSU discontinued the use of supplemental clearances for RF-2,

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Operations Quality Assurance surveillance were increased for safety

and non-safety related work activities

for

review

of

work

documentation and tagging, and

9)

Tagging officials were retrained and instructed to give closer

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attention to details prior to resuming duties.

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The root causes mainly focused around contractor personnel events;

therefore, GSU believes the program implementation by GSU personnel is

satisfactory.

Supplemental clearances have been reinstituted, post

outage,

since the contractors involved are t.o longer performing work on

site. Contractors will not be allowed as holders of clearances under

ADM-0027 pending completion of task force review activities.

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CRs are sent to a wide distribution, including but not limited to Quality

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Assurance, Licensing, and the Independent Safety Engineering Group

(ISEG).

CRs are now reviewed and trended daily in accordance with a new

procedure, RBNP-052, " River Bend Station Trending Program", to determine

adverse trends. The recently developed and approved trending program is

designed to detect long term trends.

RBNP-0052 recommends that trend

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reports be issued at six month frequencies.

Short term trends are

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generally discovered through the various CR reviews and periodic trend

reports issued to RBS management (typically every 1-2 weeks).

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUTURE VIOLATIONS

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Long term corrective action falls into two areas that are being addressed

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separately.

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A.

GSU will enhance the existing program with the following r.ctions:

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1).

An upper tier River Bend Nuclear Procedure- (RBNP)

is being

developed to standardize root cause analysis based'on INP0 Good

Practice OE-907, " Root Cause Analysis".

2)

Training will be provided to all licensee personnel required to

provide root cause analysis for responses to condition reports

and other nonconformance documents.

3)

' Administrative Procedure,' ADM-0019, " Initiation and Processing

of Condition ; Reports" currently requires root cause analysis

under the following conditions:

a)

Conditions classified Quality Class I or QA Program

Applicable and result in significant conditions adverse to.

quality,

b)

Conditions reportable to the NRC, or

c)

Other conditions adverse to safety for which a ' root cause

determination is made

Additionally, all CRs are reviewed for potential deportability.

GSU also determines whether a root cause analysis is required

for selected CRs other than safety related conditions utilizing

the following guidelines:

-

a).

Conditions indicate repetitive problems,

b)

Conditions impact the reliability of the plant, or

c)

Conditions'have an impact on the safety of personnel or

the protection of equipment

This root cause determination effort will continue. The root

cause selection process will

be evaluated to determine its

effectiveness.

It is expected that the implementation of root

cause analysis, given sufficient review time, will

result in

effective and timelv corrective actions by GSU.

B.

The following actions for the ADM-0027 tagging program will be

perfomed:

1)

An RF-2 critique for lessons learned will be completed

2)

A task force will be developed to review the existing

tagging program considering:

a)

Use of supplemental clearances

(ALARA vs. safety

considerations)

b)

Differences between the RBS tagging program and the

GSU corporate program,

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c)

A tagging' computer program will be evaluated for use

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and recommendations will be provided to include

training,

d)

Tagging ' programs

in use at'other nuclear facilities

will be surveyed for recommended changes,

e)

Current tagging-.

forms

will-

be

reviewed

for-

simplification and improvement.

3)

-ADM-0027' may be revised based on the recommendations of

the task force.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

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The RBNP to standardize root cause analysis will be approved by September

30, 1989. A supplemental response will be submitted by December 15, 1989

to document all corrective actions after Final Task Force actions are

identified.

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ATTACFMENT 2

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Response to Notice of Violation (NOV) 50-458/8911-018

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B.

REFERENCE

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

May 31, 1989

VIOLATION

,

Criterion XVI of Appendix B to 10CFR Part 50 requires that measures be

established to assume that conditions adverse to quality are promptly

identified and corrected.

j

Quality Assurance Directive QAD-016, " Corrective Action," Section

4.3,

states that procedures shall require that corrective action be promptly

ini dated and adequately documented by the responsible department to

correct the condition and to determine if action is necessary to preclude

its recurrence.

River Bend Nuclear Procedure RBNP-0047, " Corrective Action Program,"

Section

5.4,

requires that corrective action be promptly initiated and

adequately documented by the responsible department to correct the -

condition and to determine if action is necessary to preclude its

recurrence.

Contrary to the above, corrective actions described in Licensee Event

Report (LER)87-029,

" Residual Heat Removal

System Isolation Due to

Inadvertent Jumper Grounding," were not adequately documented in that no

procedural

changes were implemented to prohibit the practice of taping

together two short jumper wires rather than using a jumper of the

appropriate length.

As a result, the unit underwent a loss of shutdown

cooling for six minutes on April 27, 1989, when a taped jumper separated

during a surveillance test.

REASON FOR VIOLATION

To address the second part of NOV 8911-01, the corrective action stated

in Licensee Event Report (LER)87-029 included prohibiting the practice

of taping jumper wires together for use inside control room cabinets.

This corrective action would have been sufficient; however, no mechanism

was in place to ensure that the corrective action would remain intact.

As a result of this omission, on April

27,

1989, a second incident

involving the separation of taped jumper wires caused an electrical

transient inside a ' control room cabinet leading to a temporary loss of

residual heat removal (RHR) system shutdown cooling.

GSU determined the

root cause to be inadequate corrective actions to revise ADM-015,

" Station Surveillance Test Program", to ensure continued compliance.

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' CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED

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Instrumentation -and Controls

(I&C) technicians were brie #ed about this-

incident and were cautioned to

exercise

care

while

performing

surveillance testing.

In addition, techniques for employing more secure

- test connections are being used within. the I&C Department to prevent

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similar incidents.

While the unit was in mode 5, the RHR shutdown

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cooling' isolation logic was removed to . prevent further isolations of

shutdown cooling.

The logic was restored to service prior to draining

the upper fuel pools to'less than 23 feet above the top of the reactor

pressure vessel flange.

Temporary change notice (TCN) 89-0898 was issued and approved against

'ADM-0015.to prevent the use of taped jumpers as well. as alligator-type

clips on jumpers within the control room.

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUTURE VIOLATIONS

The TCN incorporated into ADM-0015 also requires a generic statement

concerning the use of taped jumpers and alligator-type clips be added to

all

I&C and electrical surveillance test procedures during their next

revision.

I&C and electrical

technicians will

receive training on

TCN 89-0898.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

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I&C and electrical

technicians will receive training on TCN 89-0898 by

August 30, 1989.

I&C and electrical,

control

room

applicable,

surveillance test procedures (STPs) will be revised during their next two

,

year revision cycle by adding a generic statement on the use of secure-

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test connections.

The revision cycle for all subject STPs ends during

July, 1991.

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