ML20213E539

Ack Receipt of 860829 & 1017 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-20

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. 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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R. D. Martin, RA

Section Chief (RPB/A)

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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

_.

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,

611 Ryan Plaza Drive, Suite 1000

,

j 1:, y tf. t :

Arlington, TX 76011

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Dear Mr. Martin:

SEP - 41986

', _

River Bend Station - Unit 1

-

dO;

"

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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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

r

tt o

/%

anW.Middlebloops

otary Public in and for

West Feliciana Parish,

Louisiana

l

My Conunission is for Life.

1

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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

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

the. responsible individuals and

instrucLad

the

individuals

to

i

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

. - _ _ . _ _ , . _ _ . . .

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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.

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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).

Valve E12*VF063C has been locked as shown on PID-4-3C.

i

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

the procedures have been issued

to- agree

with

the

PID's.

A

i

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^

valve regulation requirements.

Included in this review will

be

will

also

develop

a

procedure which will delineate the locked

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

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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.

.

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'

eg

GULF STATES

UTILETIES COMPANY

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

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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

1. MM , 19ffe,.

,

Q

-

L

L.,. , 9//] L U L L /,

Joan W. Middlebrooks

Notary Public in and for

West Feliciana Parish,

Louisiana

My Commission is for Life.

_. .

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ATTACHMENT

Response to Notice of Violation 50-458/8620-02

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,

and

drawings:

1)

five

pipe

caps,

shown

as

installed

on

i

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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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

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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

Local Leak Rate Testing Procedures are in place.

i

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

andl

l

Loop Diagrams will be completed by December 31, 1986.

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.

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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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