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{{Adams | |||
| number = ML20213E539 | |||
| issue date = 11/05/1986 | |||
| title = Ack Receipt of 860829 & 1017 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-20 | |||
| author name = Gagliardo J | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = Cahill W | |||
| addressee affiliation = GULF STATES UTILITIES CO. | |||
| docket = 05000458 | |||
| license number = | |||
| contact person = | |||
| document report number = NUDOCS 8611130209 | |||
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE | |||
| page count = 2 | |||
}} | |||
See also: [[see also::IR 05000458/1986020]] | |||
=Text= | |||
{{#Wiki_filter:, . | |||
NOV 5 1986 | |||
In Reply Refer To: | |||
Docket: 50-458/86-20 | |||
Gulf States Utilities | |||
. ATTN: William J. Cahill, Jr. | |||
Senior Vice President | |||
River Bend Nuclear Group | |||
P.-0. Box 220 | |||
St. Francisville, Louisiana 70775 | |||
Gentlemen: | |||
Thank you for your letters, dateo August 29, 1986, and October 17, 1986, | |||
in response to our letters, dated July 30, 1986, and September 16, 1986. We | |||
have no further questions at this time and will review your corrective action | |||
during a future inspectio'n. | |||
Sincerely, | |||
-cornai nma dy: | |||
# 1. r_ H A t. L* | |||
J. E. Gagliardo, Chief | |||
Reactor Projects Branch | |||
cc: | |||
Gulf States Utilities | |||
ATTN: J. E. Booker, Manager- | |||
Engineering, Nuclear | |||
Fuels & Licensing | |||
P. O. Box 2951 | |||
Beaumont, Texas 77704 | |||
' | |||
Louisiana State University, | |||
Government Documents Department | |||
Louisiana Radiation Control Program Director | |||
bcc: (see next page) | |||
' iV | |||
1 | |||
C /( C RPB | |||
JPJpu on:cs /kJEGagliardo g | |||
11/g/86 Wil/ /86 D\ | |||
4 y | |||
s \ | |||
8611130209 861105 | |||
PDR ADOCK 05000458 | |||
G PDR | |||
1 | |||
, . | |||
Gulf States Utilities -2- | |||
bec to DMB (IE01) | |||
bcc distrib. by RIV: | |||
RPB DRSP | |||
Resident Inspector R. D. Martin, RA | |||
Section Chief (RPB/A) D. Weiss, LFMB (AR-2015) | |||
MIS System RSB | |||
RSTS Operator R&SPB | |||
RIV File | |||
' ' | |||
. | |||
0 | |||
s. | |||
GULF STATES UTELETIES COMPANY , | |||
river BEND STATION Post OFFICE BOX 220 $7 FR ANCISVlLLE. louts 4ANA 70775 | |||
AREA CODE 504 635 6094 346 8651 | |||
August 29, 1986 | |||
RBG- 24275 | |||
File Nos. G9.5, G15.4.1 | |||
Mr. Robert D. Martin, Regional Adntinistrator | |||
U.S. Nuclear Regulatory Commission | |||
Region IV t | |||
_. | |||
g,. , | |||
611 Ryan Plaza Drive, Suite 1000 j 1:, y tf. t : | |||
Arlington, TX 76011 | |||
, | |||
' | |||
' | |||
i j | |||
Dear Mr. Martin: SEP - 41986 ', _ | |||
: | |||
" | |||
dO; | |||
River Bend Station - Unit 1 - | |||
Refer to: Regicn IV - | |||
Docket No. 50-458/ Report 86-20 | |||
This letter is in 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) response to the Notice | |||
of Violation 8620-01 and 8620-02 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 | |||
GP 6?S | |||
WJC/ ERG /RRS/kn | |||
Attachment | |||
, , | |||
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{)D V l I .f | |||
TL-ut(8to | |||
. . | |||
UNITED STATES OF AMERICA | |||
BUCIAAR REGUIATORY Ct3 MISSION | |||
- | |||
. | |||
STATE OF IRISIAEA 5 | |||
FARISE OF UEST FELICIANA l . | |||
In the Matter of $ Docket Boe. 50-458 | |||
CULF STATES UTILITIES CtBIFARY I | |||
(River Bend Station, | |||
* | |||
Unit 1) . | |||
AFFID&VIT | |||
W. J. Cahill, Jr., beins 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 heretos and that all such documents | |||
are true and correct to the best of his knowledge, information and belief. | |||
W. Cahill, Jr. // | |||
.- | |||
Subscribed and sworn to before me, a Notary Public in and for the | |||
State and Parish above named, this /7 day of dead ,19&. l | |||
l r | |||
tt o /% | |||
anW.Middlebloops I | |||
otary Public in and for | |||
West Feliciana Parish, | |||
Louisiana l | |||
l | |||
My Conunission is for Life. l | |||
1 | |||
- | |||
_ | |||
i | |||
. _ . _. . _ _ _ . ._ _ . _ _ _ _ __ . . , . | |||
. . | |||
. | |||
ATTACHMENT | |||
. | |||
Response to Notice of Violation 50-458/8620-01 | |||
{ | |||
Level IV | |||
FAILURE TO FOLLOW ADMINISTRATIVE PROCEDURES FOR ISSUANCE OF | |||
TEMPORARY CHANGE NOTICES (TCN's) | |||
REFERENCE: | |||
Notice of Violation - | |||
Letter to W. J. Cahill, Jr. from J. E. | |||
Gagliardo dated July 30, 1986. | |||
; | |||
' | |||
REASON FOR THE VIOLATION | |||
l During an NRC inspection conducted on May 1 through June 15, | |||
1986, the inspectors identified a failure to follow | |||
: Administrative procedures. As a result of personnel oversight, | |||
, I&C Maintenance Technicians failed to comply with the procedural | |||
requirements of Administrative Procedure (ADM)-0003, | |||
; " Development, Control and Use of Procedures" when initiating | |||
i Temporary Change Notice No. 86-0581 for procedure STP-051-4210. | |||
This resulted in an official work copy of the procedure | |||
, | |||
containing duplicate page numbers with different Temporary Change | |||
: Notice (TCN) Numbers on each page. | |||
i | |||
) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS' ACHIEVED | |||
; On April 10, 1986, prior to the NRC inspection, Memorandum No. | |||
: PAS-86-141 was issued identifying procedures with two or more | |||
TCN's having duplicate pages with different changes. | |||
' | |||
The | |||
; | |||
memorandum identified the deficiencies with STP-051-4210 and | |||
j requested that the faulty TCN's be corrected. | |||
i In response to Memorandum No. PAS-86-141, Procedure STP-051-4210, . | |||
l Revision 2, was submitted for revision on April 20, 1986 to ! | |||
l incorporate the outstanding TCN's and eliminate the duplicate | |||
pages. Revision 3 of STP-051-4210 was approved and issued on | |||
July 30, 1986. | |||
CORRECTIVE STEPS WILL BE TAKEN TO AVOID FURTHER VIOLATIONS | |||
The I&C Procedure Coordinator reviewed the TCN deficiencies with | |||
i | |||
the. responsible individuals and instrucLad the individuals to | |||
' | |||
comply with the requirements of ADM-0003 when initiating future | |||
TCN's. | |||
Memorandum No. PIC-M-86-116 was issued on July 9, 1986 requesting | |||
that TCN's issued by the I&C Maintenance Department be routed | |||
l through the I&C Procedure Coordinator prior to obtaining the | |||
, | |||
Shift Supervisor's signature. The IEC Procedure Coordinator is | |||
i responsible for reviewing TCN's being issued to assure compliance | |||
l with ADM-0003 and evaluates the necessity of the TCN. The | |||
; | |||
. - _ _ . _ _ , . _ _ . . . _ _- _ ___.____ _ _ _ - _ _ _ | |||
. . , - -- . - - - . - | |||
e | |||
f . . | |||
. | |||
ATTACHMENT (Cont'd) | |||
routing of the TCN through the I&C Procedure coordinator will be | |||
discontinued when the number of TCN's being issued is | |||
significantly reduced. | |||
] To prevent recurrence of similar violations, ADM-0003 was revised | |||
' | |||
on 8/6/86 to clarify procedural instructions for issuing a TCN to | |||
a page that has been previously changed by a TCN. | |||
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED | |||
' | |||
STP-051-4210 was reviied on July 30, 1986 to incorporate the | |||
* | |||
outstanding TCN's and eliminate the duplicate pages. | |||
; | |||
River Bend Station is currently in compliance. | |||
; | |||
e | |||
! + | |||
i | |||
! | |||
! | |||
I | |||
i | |||
l | |||
l | |||
, | |||
I | |||
i | |||
! | |||
-. . . . . - - - - - - - . - . - - - - . - . - - . . . - - - _ . - - - . . - . . _ . - _. | |||
- - . . _ - . - | |||
< | |||
, | |||
. . | |||
e | |||
Page 3 | |||
ATTACHMENT (Cont'd) | |||
Response to Notice of Violation 50-458/9620-02 | |||
Level.IV | |||
< | |||
FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY | |||
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 | |||
Engineering, Piping and Instrument Drawing PID-27-7C was open, 3) | |||
valve E12*VF063C was not locked, although Engineering, Piping and | |||
Instrument Drawing PID-4-3C showed this valve to be locked, 4) | |||
differences were found between Engineering, Piping and Instrument | |||
Drawing PID-27-7C and System Operating Procedure, SOP-0031, as to | |||
which valves were locked in position. | |||
Item 1 | |||
Investigaticns to determine the reason that the pipe caps are | |||
missing, although shown installed on Engineering, Piping and | |||
Instrument Drawing, 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 previour,1y 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 | |||
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. | |||
. . - - . _. _ _ - - . .- . -- . - __ . - . - | |||
i | |||
, | |||
e * . | |||
! | |||
. | |||
Page 4 | |||
; | |||
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). | |||
i | |||
Valve E12*VF063C has been locked as shown on PID-4-3C. | |||
Operations has revised the RHR SOP to agree with existing FID's. | |||
! | |||
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS | |||
: | |||
Nuclear Equipment Operators on rounds will take notice of missing | |||
. | |||
pipe cape and r? place them. A supply of caps has been placed in | |||
l the Control Room for this purpose. Additionally, Local Leak Rate | |||
! Testing (LLRT) Procedures will include a step to ensure | |||
i replacement of caps which are removed for LLRT. Nuclear Plant- | |||
l Engineering (NuPE), along with Stone & Webster (S&W) is in the | |||
process of determining which valve caps are required for a system | |||
j | |||
to meet its intended design. | |||
PID's will be revised to indicate valve position for a normal | |||
mode of operation, and Station Operation Manual (SOM) procedures | |||
; will govern actual valve position. | |||
1 . | |||
A new procedure, Operation Section Procedure OSP-0014, which | |||
directly addresses the control of locked valves has been issued | |||
i by the River Bend Operations Department. | |||
J | |||
' | |||
A review of all PID's versus SOPS has been conducted. Changes to | |||
i | |||
the procedures have been issued to- agree with the PID's. A | |||
review of the PID's is being performed by NuPE to determine which | |||
! valves should be locked and which should be left unlocked. NuPE | |||
l^ will also develop a procedure which will delineate the locked | |||
valve regulation requirements. Included in this review will be | |||
, the necessary changes of PID's to match these requirements. Upon | |||
completion, it is expected this will decrease the number of | |||
valves required to be locked. | |||
j Adequate configuration management control procedures are | |||
; | |||
currently in place. All changes to locked valve status will be- | |||
followed by updates to the SOP's via these controls, | |||
i | |||
i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED | |||
l The additional procedural controls ensuring replacement of pipe | |||
t | |||
caps in Local Leak Rate Testing Procedures will be completed by | |||
; | |||
October 30, 1986. | |||
d | |||
1 | |||
! | |||
- - - - - . - - -_ - - . _ - - - | |||
. | |||
. . , | |||
o | |||
ATTACHMENT (Cont'd) | |||
Valve E12*VF063C has been verified to be locked at the time of | |||
this response. | |||
Procedures being devel5 ped by NuPE for determining locked valve | |||
regulation requirements will be completed by November 30, 1986. | |||
, The;PID changes brought about by NuPE's reviews will be completed | |||
iby December 31, 1986. | |||
. | |||
E | |||
1 | |||
- | |||
,. . . . _ - - - - _ - - - - - _ | |||
e * . | |||
1;h | |||
' | |||
GULF STATES UTILETIES COMPANY | |||
eg | |||
RIVER BEND STAYtON POST OFFICE 80x 220 St FRANCISvtLLE. LOutslANA 70776 | |||
ARE A CODE 604 635 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 . | |||
, t ~i} f @ | |||
g~t | |||
< | |||
U | |||
,w> ) | |||
OCT 231986 | |||
Mc -,; - | |||
. | |||
. . . _ _ | |||
D | |||
. 3 | |||
.. . . . . . | |||
g g 59 6 Yo | |||
. | |||
. . | |||
, | |||
* UNITED STATES OF AMERICA | |||
BUCLEAR EEGULATORY CCESEISSION | |||
- | |||
, | |||
STATE OF IAUISIAEA 5 | |||
FARISE OF WEST FELICIAEA 5 | |||
In the Matter of I Docket Bos. 50-458 | |||
GULF STATES UTILITIES C(EEFANY $ | |||
(River Bend Station, | |||
Unit 1) . | |||
AFFID&VIT | |||
W. J. Cahill, Jr., being duly sworn, states that he is a Senior | |||
Vice President of Gulf States U' 111 ties Company: that he is authorized | |||
on the part of said Company to sign and file with the Nuclear Regulatory | |||
Commission the documents attached heretos and that all such documents | |||
are true and correct to the best of his knowledge, information and belief. | |||
W. J Cahill, Jr. | |||
.. | |||
Subscribed and sworn to before me, a Notary Public in and for the | |||
State and Parish above named, this /8 , | |||
day of #MM , 19ffe,. | |||
Q 9//] L U L L /, | |||
- | |||
L L.,. , | |||
Joan W. Middlebrooks | |||
Notary Public in and for | |||
West Feliciana Parish, | |||
Louisiana | |||
My Commission is for Life. | |||
_. . . -- - _ - - - - - . _ _ . .- . . - . _ . _ - _ _ . _ . - - . - . . _ - - _ _ _ _ . - . - _ _ . | |||
. . . | |||
, | |||
. | |||
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, | |||
i | |||
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. | |||
4 | |||
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 | |||
~ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ - _ . . _ . _ _ , _ _ _ _ . | |||
.. | |||
. . . | |||
, | |||
t | |||
ATTACHMENT (cont'd.) Page 2 | |||
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 | |||
4 | |||
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). | |||
I Valve E12*VF063C has been locked as shown on PID-4-3C. | |||
Operations has revised the RHR SOP to agree with existing PID's. | |||
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS | |||
Nuclear Equipment Operators on rounds will take notice of missing | |||
pipe caps 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. | |||
A new procedure, Operation Section Procedure (OSP) -0014, " Control | |||
of Locked Valves and Devices", which directly controls locked | |||
valves and other devices required to be locked has been issued by | |||
' | |||
the Operations Department. | |||
GSU Design Engineering has initiated two Modification Requests | |||
(MR's), Nos. 86-1587 and 86-1588, to add notes to the PID's | |||
concerning valve position and pipe caps. A note will be added to | |||
PID's stating that valve positions shown on the PID's are for the | |||
l | |||
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 | |||
state that pipe caps are not required for system operability. | |||
Any exceptions to this note will be identified on the PID. . | |||
I | |||
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 | |||
, | |||
these discrepancies in accordance with existing design control | |||
: procedures. This initial review has been completed, however, all | |||
l MR's have not been closed. Ninety-Five (95) MR's were identified | |||
4 | |||
I | |||
_. . _ _ _ _ _ . _ _ _ _ . _ , , _ _ __ _ _ _ _ _ . _ , _ _ _ _ . , . - . . - - | |||
.- - - . _. -_ - | |||
. .. | |||
, | |||
t | |||
t | |||
! | |||
! ATTACHMENT (cont'd.) Page 3 | |||
f | |||
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 | |||
i 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. | |||
i | |||
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 pipe caps in l | |||
i | |||
Local Leak Rate Testing Procedures are in place. | |||
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 | |||
l Loop Diagrams will be completed by December 31, 1986. andl | |||
I 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. | |||
1 | |||
i | |||
i | |||
!--. . . - . - - _ - - _ - - - _ - . - - - - - - | |||
. _ _ - . | |||
. , s | |||
. | |||
. | |||
ATTACHMENT (cont'd.) Page 4 | |||
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. | |||
> | |||
l | |||
!, | |||
i | |||
i | |||
l | |||
l | |||
t | |||
l - | |||
, | |||
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, | |||
; | |||
..- | |||
}} |
Latest revision as of 00:42, 5 May 2021
ML20213E539 | |
Person / Time | |
---|---|
Site: | River Bend |
Issue date: | 11/05/1986 |
From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | William Cahill GULF STATES UTILITIES CO. |
References | |
NUDOCS 8611130209 | |
Download: ML20213E539 (2) | |
See also: IR 05000458/1986020
Text
, .
NOV 5 1986
In Reply Refer To:
Docket: 50-458/86-20
Gulf States Utilities
. ATTN: William J. Cahill, Jr.
Senior Vice President
River Bend Nuclear Group
P.-0. Box 220
St. Francisville, Louisiana 70775
Gentlemen:
Thank you for your letters, dateo August 29, 1986, and October 17, 1986,
in response to our letters, dated July 30, 1986, and September 16, 1986. We
have no further questions at this time and will review your corrective action
during a future inspectio'n.
Sincerely,
-cornai nma dy:
- 1. r_ H A t. L*
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Gulf States Utilities
ATTN: J. E. Booker, Manager-
Engineering, Nuclear
Fuels & Licensing
P. O. Box 2951
Beaumont, Texas 77704
'
Louisiana State University,
Government Documents Department
Louisiana Radiation Control Program Director
bcc: (see next page)
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C /( C RPB
JPJpu on:cs /kJEGagliardo g
11/g/86 Wil/ /86 D\
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8611130209 861105
PDR ADOCK 05000458
G PDR
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Gulf States Utilities -2-
bec to DMB (IE01)
bcc distrib. by RIV:
RPB DRSP
Resident Inspector R. D. Martin, RA
Section Chief (RPB/A) D. Weiss, LFMB (AR-2015)
MIS System RSB
RSTS Operator R&SPB
RIV File
' '
.
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s.
GULF STATES UTELETIES COMPANY ,
river BEND STATION Post OFFICE BOX 220 $7 FR ANCISVlLLE. louts 4ANA 70775
AREA CODE 504 635 6094 346 8651
August 29, 1986
RBG- 24275
File Nos. G9.5, G15.4.1
Mr. Robert D. Martin, Regional Adntinistrator
U.S. Nuclear Regulatory Commission
Region IV t
_.
g,. ,
611 Ryan Plaza Drive, Suite 1000 j 1:, y tf. t :
Arlington, TX 76011
,
'
'
i j
Dear Mr. Martin: SEP - 41986 ', _
"
dO;
River Bend Station - Unit 1 -
Refer to: Regicn IV -
Docket No. 50-458/ Report 86-20
This letter is in 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) response to the Notice
of Violation 8620-01 and 8620-02 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
GP 6?S
WJC/ ERG /RRS/kn
Attachment
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TL-ut(8to
. .
UNITED STATES OF AMERICA
BUCIAAR REGUIATORY Ct3 MISSION
-
.
STATE OF IRISIAEA 5
FARISE OF UEST FELICIANA l .
In the Matter of $ Docket Boe. 50-458
CULF STATES UTILITIES CtBIFARY I
(River Bend Station,
Unit 1) .
AFFID&VIT
W. J. Cahill, Jr., beins 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 heretos and that all such documents
are true and correct to the best of his knowledge, information and belief.
W. Cahill, Jr. //
.-
Subscribed and sworn to before me, a Notary Public in and for the
State and Parish above named, this /7 day of dead ,19&. l
l r
tt o /%
anW.Middlebloops I
otary Public in and for
West Feliciana Parish,
l
My Conunission is for Life. l
1
-
_
i
. _ . _. . _ _ _ . ._ _ . _ _ _ _ __ . . , .
. .
.
ATTACHMENT
.
Response to Notice of Violation 50-458/8620-01
{
Level IV
FAILURE TO FOLLOW ADMINISTRATIVE PROCEDURES FOR ISSUANCE OF
TEMPORARY CHANGE NOTICES (TCN's)
REFERENCE:
Notice of Violation -
Letter to W. J. Cahill, Jr. from J. E.
Gagliardo dated July 30, 1986.
'
REASON FOR THE VIOLATION
l During an NRC inspection conducted on May 1 through June 15,
1986, the inspectors identified a failure to follow
- Administrative procedures. As a result of personnel oversight,
, I&C Maintenance Technicians failed to comply with the procedural
requirements of Administrative Procedure (ADM)-0003,
- " Development, Control and Use of Procedures" when initiating
i Temporary Change Notice No. 86-0581 for procedure STP-051-4210.
This resulted in an official work copy of the procedure
,
containing duplicate page numbers with different Temporary Change
- Notice (TCN) Numbers on each page.
i
) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS' ACHIEVED
- On April 10, 1986, prior to the NRC inspection, Memorandum No.
- PAS-86-141 was issued identifying procedures with two or more
TCN's having duplicate pages with different changes.
'
The
memorandum identified the deficiencies with STP-051-4210 and
j requested that the faulty TCN's be corrected.
i In response to Memorandum No. PAS-86-141, Procedure STP-051-4210, .
l Revision 2, was submitted for revision on April 20, 1986 to !
l incorporate the outstanding TCN's and eliminate the duplicate
pages. Revision 3 of STP-051-4210 was approved and issued on
July 30, 1986.
CORRECTIVE STEPS WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
The I&C Procedure Coordinator reviewed the TCN deficiencies with
i
the. responsible individuals and instrucLad the individuals to
'
comply with the requirements of ADM-0003 when initiating future
TCN's.
Memorandum No. PIC-M-86-116 was issued on July 9, 1986 requesting
that TCN's issued by the I&C Maintenance Department be routed
l through the I&C Procedure Coordinator prior to obtaining the
,
Shift Supervisor's signature. The IEC Procedure Coordinator is
i responsible for reviewing TCN's being issued to assure compliance
l with ADM-0003 and evaluates the necessity of the TCN. The
. - _ _ . _ _ , . _ _ . . . _ _- _ ___.____ _ _ _ - _ _ _
. . , - -- . - - - . -
e
f . .
.
ATTACHMENT (Cont'd)
routing of the TCN through the I&C Procedure coordinator will be
discontinued when the number of TCN's being issued is
significantly reduced.
] To prevent recurrence of similar violations, ADM-0003 was revised
'
on 8/6/86 to clarify procedural instructions for issuing a TCN to
a page that has been previously changed by a TCN.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
'
STP-051-4210 was reviied on July 30, 1986 to incorporate the
outstanding TCN's and eliminate the duplicate pages.
River Bend Station is currently in compliance.
e
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- - . . _ - . -
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Page 3
ATTACHMENT (Cont'd)
Response to Notice of Violation 50-458/9620-02
Level.IV
<
FAILURE TO CONTROL ACTIVITIES AFFECTING QUALITY
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
Engineering, Piping and Instrument Drawing PID-27-7C was open, 3)
valve E12*VF063C was not locked, although Engineering, Piping and
Instrument Drawing PID-4-3C showed this valve to be locked, 4)
differences were found between Engineering, Piping and Instrument
Drawing PID-27-7C and System Operating Procedure, SOP-0031, as to
which valves were locked in position.
Item 1
Investigaticns to determine the reason that the pipe caps are
missing, although shown installed on Engineering, Piping and
Instrument Drawing, 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 previour,1y 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
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.
. . - - . _. _ _ - - . .- . -- . - __ . - . -
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Page 4
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).
i
Valve E12*VF063C has been locked as shown on PID-4-3C.
Operations has revised the RHR SOP to agree with existing FID's.
!
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
Nuclear Equipment Operators on rounds will take notice of missing
.
pipe cape and r? place them. A supply of caps has been placed in
l the Control Room for this purpose. Additionally, Local Leak Rate
! Testing (LLRT) Procedures will include a step to ensure
i replacement of caps which are removed for LLRT. Nuclear Plant-
l Engineering (NuPE), along with Stone & Webster (S&W) is in the
process of determining which valve caps are required for a system
j
to meet its intended design.
PID's will be revised to indicate valve position for a normal
mode of operation, and Station Operation Manual (SOM) procedures
- will govern actual valve position.
1 .
A new procedure, Operation Section Procedure OSP-0014, which
directly addresses the control of locked valves has been issued
i by the River Bend Operations Department.
J
'
A review of all PID's versus SOPS has been conducted. Changes to
i
the procedures have been issued to- agree with the PID's. A
review of the PID's is being performed by NuPE to determine which
! valves should be locked and which should be left unlocked. NuPE
l^ will also develop a procedure which will delineate the locked
valve regulation requirements. Included in this review will be
, the necessary changes of PID's to match these requirements. Upon
completion, it is expected this will decrease the number of
valves required to be locked.
j Adequate configuration management control procedures are
currently in place. All changes to locked valve status will be-
followed by updates to the SOP's via these controls,
i
i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
l The additional procedural controls ensuring replacement of pipe
t
caps in Local Leak Rate Testing Procedures will be completed by
October 30, 1986.
d
1
!
- - - - - . - - -_ - - . _ - - -
.
. . ,
o
ATTACHMENT (Cont'd)
Valve E12*VF063C has been verified to be locked at the time of
this response.
Procedures being devel5 ped by NuPE for determining locked valve
regulation requirements will be completed by November 30, 1986.
, The;PID changes brought about by NuPE's reviews will be completed
iby December 31, 1986.
.
E
1
-
,. . . . _ - - - - _ - - - - - _
e * .
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'
GULF STATES UTILETIES COMPANY
eg
RIVER BEND STAYtON POST OFFICE 80x 220 St FRANCISvtLLE. LOutslANA 70776
ARE A CODE 604 635 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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OCT 231986
Mc -,; -
.
. . . _ _
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.. . . . . .
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.
. .
,
- UNITED STATES OF AMERICA
BUCLEAR EEGULATORY CCESEISSION
-
,
STATE OF IAUISIAEA 5
FARISE OF WEST FELICIAEA 5
In the Matter of I Docket Bos. 50-458
GULF STATES UTILITIES C(EEFANY $
(River Bend Station,
Unit 1) .
AFFID&VIT
W. J. Cahill, Jr., being duly sworn, states that he is a Senior
Vice President of Gulf States U' 111 ties Company: that he is authorized
on the part of said Company to sign and file with the Nuclear Regulatory
Commission the documents attached heretos and that all such documents
are true and correct to the best of his knowledge, information and belief.
W. J Cahill, Jr.
..
Subscribed and sworn to before me, a Notary Public in and for the
State and Parish above named, this /8 ,
day of #MM , 19ffe,.
Q 9//] L U L L /,
-
L L.,. ,
Joan W. Middlebrooks
Notary Public in and for
West Feliciana Parish,
My Commission is for Life.
_. . . -- - _ - - - - - . _ _ . .- . . - . _ . _ - _ _ . _ . - - . - . . _ - - _ _ _ _ . - . - _ _ .
. . .
,
.
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,
i
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.
4
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
~ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ - _ . . _ . _ _ , _ _ _ _ .
..
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t
ATTACHMENT (cont'd.) Page 2
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
4
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).
I Valve E12*VF063C has been locked as shown on PID-4-3C.
Operations has revised the RHR SOP to agree with existing PID's.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
Nuclear Equipment Operators on rounds will take notice of missing
pipe caps 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.
A new procedure, Operation Section Procedure (OSP) -0014, " Control
of Locked Valves and Devices", which directly controls locked
valves and other devices required to be locked has been issued by
'
the Operations Department.
GSU Design Engineering has initiated two Modification Requests
(MR's), Nos. 86-1587 and 86-1588, to add notes to the PID's
concerning valve position and pipe caps. A note will be added to
PID's stating that valve positions shown on the PID's are for the
l
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
state that pipe caps are not required for system operability.
Any exceptions to this note will be identified on the PID. .
I
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
,
these discrepancies in accordance with existing design control
- procedures. This initial review has been completed, however, all
l MR's have not been closed. Ninety-Five (95) MR's were identified
4
I
_. . _ _ _ _ _ . _ _ _ _ . _ , , _ _ __ _ _ _ _ _ . _ , _ _ _ _ . , . - . . - -
.- - - . _. -_ -
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f
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
i 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.
i
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 pipe caps in l
i
Local Leak Rate Testing Procedures are in place.
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
l Loop Diagrams will be completed by December 31, 1986. andl
I 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.
1
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ATTACHMENT (cont'd.) Page 4
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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