IR 05000458/1986020: Difference between revisions

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{{Adams
{{Adams
| number = ML20210C329
| number = ML20235V413
| issue date = 09/16/1986
| issue date = 10/08/1987
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-20.Addl Info Re Review of P&ID Requested,Per 860911 Telcon.Supplemental Info Requested within 30 Days of Ltr Date
| title = Ack Receipt of ,Updating & Supplementing 861017 & 870109 Responses Re Violations Noted in Insp Rept 50-458/86-20.Commitment to Complete Incorporation of Mods to P&ID Drawings by End of First Quarter 1988 Acceptable
| author name = Gagliardo J
| author name = Gagliardo J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Cahill W
| addressee name = Deddens J
| addressee affiliation = GULF STATES UTILITIES CO.
| addressee affiliation = GULF STATES UTILITIES CO.
| docket = 05000458
| docket = 05000458
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8609180311
| document report number = NUDOCS 8710150140
| title reference date = 08-29-1986
| title reference date = 09-16-1987
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 2
| page count = 2
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OCT 8 - 1987 LIn' Reply Refer To:
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Docket: 50-458/86-20
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In-Reply Refer To:         ';
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Docket: 50-458/86-20       .,    ,
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Gulf States Utilities ATTN: Mr. James C. Deddens Senior Vice President, (RBNG)
Gulf States Utilities ATTN: William J. Cahill, Jr.     -
Nuclear Licensing P. O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:
Senior Vice President-River Bend Nuclear Group P. O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:
Thank you for your letter of September'16,1987, which updated and supplemented your response of October 17, 1986, and January 9, 1987, to our letters of
Thank you for your letter of August 29, 1986 , in response to our letter and the attached Notice of Violation dated July 30, 1986' As a result  .
      '
of our review, we find that additional information, as discussed with your Mr. E. Grant during a telephone call on September 11, 1986, is needed.
      ;I July 30, September 16, 1986 and January 23, 198 We understand that you have completed your initial commitment to the  )
100 percent revie We accept your commitment to complete incorporation of the remaining modification requests into piping and instrumentation drawings by the end of the first quarter, 1988, and will verify your corrective actions during a future inspectio


Specifically, we need more information on the review of piping and instrument drawings that we understand you are conducting.
Sincerely, oricinal Signed By J. P. Jaudon J. E. Gagliardo, Chief Reactor Projects Branch  j cc:
Gulf States Utilities    {
ATTN: J. E. Booker, Manager-    1 River Bend Oversight    i P. O. Box 2951 Beaumont, Texas 77704 Louisiana State University,    i Government Documents Department Louisiana Radiation Control Program Director bec: (see next page)    !
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Please provide the supplemental information within 30 days of the date of this letter..
Sincerely, Original signed By J. E. Gagliardo 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      {
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RPB:    DRSP Resident Inspector     R. D. Martin, RA  .
RPB-  DRSP Resident Inspector R. D. Martin, RA
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GULF STATES  UTELETIES COMPANY . j river SEND STATION POST OFFICE 80x 220 ST FR ANCISvtLLE. LOUISIANA 70775 AREA CODE 504 635 6094 346 8651
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August 29, 1986 RBG- 24275 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV      . ,_. , , 3 611 Ryan Plaza Drive, Suite 1000    , yI5 O, .s t ." U .
Arlington, TX 76011    4 j
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==Dear Mr. Martin:==
SEP - 41986 "; j -
River Bend Station - Unit 1  -  'dO Refer to: Region IV    '
Docket No. 50-458/ Report 86-20Y 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, f
        .
W. J. Cahill, Jr.
 
Senior Vice President River Bend Nuclear Group ca? #As WJC/ ERG /RRS/ks Attachment
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*  UNITED STATES OF AMERICA EUCLEAR REGUIATORT CGAESSION
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STATE OF UMTISIAEA  5 FARISn OF WEST FILICIANA  5  .
In the Matter of  I Docket Bos. 50-458 OULF STATES UTILITIES CGIFANY l (River Bend Station,
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Unit 1)    .
AFFIDAVIT
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W. J. Cahill, Jr., 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 Rggulatory Coussis sion the documents attached hereto and that all such documents are true and correct to the best of his knowledge, information and belief.
 
W. Cahill, Jr. //
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Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this /7 day of duud ,198
    # r L *  /#
anW.Middlebloops i
otary Public in and for West Feliciana Parish, Louisiana My Commission is for Life.


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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 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 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.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED On April 10, 1986,.orior 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 requested that the faulty TCN's be corrected.
l In response to Memorandum No. PAS-86-141, Procedure STP-051-4210, Revision 2, was submitted for revision on April 20, 1986 to 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
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the responsible individuals and instructed the individuals to l comply with the requirements of ADM-0003 when initiating future l 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 through the I&C Procedure Coordinator prior to obtaining the Shift Supervisor's signature. The I&C Procedure Coordinator is responsible for reviewing TCN's being issued to assure compliance with ADM-0003 and evaluates the necessity of the TCN. The l  _ . _ . _ _ -_ _- __ __ _ _ . _
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Page 2 ATTACHMENT (Cont'd)
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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
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a page that has been previously changed by a TCN.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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STP-051-4210 was revised on July 30, 1986 to incorporate the outstanding TCN's and eliminate the duplicate pages.
River Bend Station is currently in compliance.
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Page 3 ATTACHMENT (Cont'd)
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Response to Notice of Violation 50-458/8620-02 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 l Drawing 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 Engineering, Piping and Instrument Drawing, PID-27-7C, are indeterminate.
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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 l to be closed.
I 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 l
considered inaccessible.
! Item 4 j 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
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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
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updates to reflect commitments to lock specific valves.
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l GULF STATES  UTILITIES  COMPANY   i river SEND STAfiON POST OFFICE BOX 220 ST FRANCISVILLE LOUISIANA 70776 AREA CODE 604 636 6094 346 8651 September 16, 1987 RBG- 26646  N File No. G9.5, G15. U.S. Nuclear Regulatory Commission    '
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Document Control Desk        i Washington, D.C. 20555
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: Gentlemen:
River Bend Station - Unit 1 Refer to: Region IV    i
  . Docket No. 50-458/ Report 86-20
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This letter provides an updated status, as discussed with the onsite    !'
Senior Resident Inspector, to Gulf States Utilities Company's (GSU)
implementation of corrective action regarding the Notice of Violation contained in NRC Inspection Report 50-458/86-20 dated October 17, 198 The following is in reference to GSU's letter dated January 9,    l 1987 (RBG-25205) concerning a 100 percent review of Piping and Instrumentation Drawings (P&ID's).


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A total of seventy-seven (77) Modification Requests (MR's) have been    .
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initiated from a 100 percent review of two hundred twenty (220)    !
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P&ID' Initial 10CFR50.59 reviews of the P&ID document only changes have not identified any Unreviewed Safety Questions  (USQ). GSU estimates that approximately twenty-four hundred (2400) manhours will be required to process and approve the remaining MR' Incorporation  ,
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.
of the remaining MR's into P&ID's will be complete by the end of the    '
first quarter,.198


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).
Sincerely, j
 
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Valve E12*VF063C has been locked as shown on PID-4-3C.
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l J. E. Booker Manager, River Bend Oversight  l River Bend Nuclear Group  l
Operations has revised the RHR SOP to agree with existing PID's.
  /R RR / /ch cc: U.S. Nuclear Regulatory Commission      .
 
611 Ryan Plaza Drive, Suite 1000      !
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 Contrcl Room for this purpose. Additionally, Local Leak Rate
Arlington, TX 76011 NRC Resident Inspector Post Office Box 1051 St. Francisv111e, LA 70775 l
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Testing (LLRT) Procedures will include a step to ensure
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, replacement of caps which are removed for LLRT. Nuclear Plant Engineering (NuPE), along with Stone & Webster (S&W) is in the process of determining which valve caps are required for a system
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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.
 
A new procedure, Operation Section Procedure OSP-0014, which directly addresses the control of locked valves has been issued by the River 3end Operations Department.
 
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A review of all PID's versus SOPS has been conducted. Changes to j the procedures have been issued to agree with the PID's. A
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review of the PID's is being performed by NuPE to determine which
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valves should be locked and which should be left unlocked. NuPE 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 l completion, it is expected this will decrease the number of l valves required to be locked.
 
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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.
 
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The additional procedural controls ensuring replacement of pipe caps in Local Leak Rate Testing Procedures will be completed by October 30, 1986.
 
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ATTACHMENT (Cont'd)
Valve E12*VF063C  has been verified to be locked at the time of this response.
 
Procedures being developed 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 by December ~31, 1986.
 
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Latest revision as of 18:07, 17 December 2021

Ack Receipt of ,Updating & Supplementing 861017 & 870109 Responses Re Violations Noted in Insp Rept 50-458/86-20.Commitment to Complete Incorporation of Mods to P&ID Drawings by End of First Quarter 1988 Acceptable
ML20235V413
Person / Time
Site: River Bend Entergy icon.png
Issue date: 10/08/1987
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Deddens J
GULF STATES UTILITIES CO.
References
NUDOCS 8710150140
Download: ML20235V413 (2)
v • d • e


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OCT 8 - 1987 LIn' Reply Refer To:

Docket: 50-458/86-20

Gulf States Utilities ATTN: Mr. James C. Deddens Senior Vice President, (RBNG)

Nuclear Licensing P. O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:

Thank you for your letter of September'16,1987, which updated and supplemented your response of October 17, 1986, and January 9, 1987, to our letters of

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I July 30, September 16, 1986 and January 23, 198 We understand that you have completed your initial commitment to the )

100 percent revie We accept your commitment to complete incorporation of the remaining modification requests into piping and instrumentation drawings by the end of the first quarter, 1988, and will verify your corrective actions during a future inspectio

Sincerely, oricinal Signed By J. P. Jaudon J. E. Gagliardo, Chief Reactor Projects Branch j cc:

Gulf States Utilities {

ATTN: J. E. Booker, Manager- 1 River Bend Oversight i P. O. Box 2951 Beaumont, Texas 77704 Louisiana State University, i Government Documents Department Louisiana Radiation Control Program Director bec: (see next page)  !

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l GULF STATES UTILITIES COMPANY i river SEND STAfiON POST OFFICE BOX 220 ST FRANCISVILLE LOUISIANA 70776 AREA CODE 604 636 6094 346 8651 September 16, 1987 RBG- 26646 N File No. G9.5, G15. U.S. Nuclear Regulatory Commission '

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Document Control Desk i Washington, D.C. 20555

,

Gentlemen:

River Bend Station - Unit 1 Refer to: Region IV i

. Docket No. 50-458/ Report 86-20

'

This letter provides an updated status, as discussed with the onsite  !'

Senior Resident Inspector, to Gulf States Utilities Company's (GSU)

implementation of corrective action regarding the Notice of Violation contained in NRC Inspection Report 50-458/86-20 dated October 17, 198 The following is in reference to GSU's letter dated January 9, l 1987 (RBG-25205) concerning a 100 percent review of Piping and Instrumentation Drawings (P&ID's).

A total of seventy-seven (77) Modification Requests (MR's) have been .

initiated from a 100 percent review of two hundred twenty (220)  !

P&ID' Initial 10CFR50.59 reviews of the P&ID document only changes have not identified any Unreviewed Safety Questions (USQ). GSU estimates that approximately twenty-four hundred (2400) manhours will be required to process and approve the remaining MR' Incorporation ,

of the remaining MR's into P&ID's will be complete by the end of the '

first quarter,.198

Sincerely, j

.

l J. E. Booker Manager, River Bend Oversight l River Bend Nuclear Group l

/R RR / /ch cc: U.S. Nuclear Regulatory Commission .

611 Ryan Plaza Drive, Suite 1000  !

Arlington, TX 76011 NRC Resident Inspector Post Office Box 1051 St. Francisv111e, LA 70775 l

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