ML20006A356

Responds to Violations Noted in Insp Rept 50-458/89-37 on 891001-31.Corrective Action:Managers Instructed to Hold Meetings W/Personnel to Stress Importance of Procedural Compliance

ML20006A356
Person / Time
Site:	River Bend
Issue date:	01/12/1990
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-32101, NUDOCS 9001260164
Download: ML20006A356 (5)

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GULF STATES UTILITIES COMPANY NNEP Mt D STAfsON POST ortict Box 220 ST F$tANC1SVILLL LOUISIANA 70776 AALA CODC 604 Ob 0094 - 3 4 8661 January 12, 1990 RBG- 32101

' File Nos. G9.5, G15.4.1 U. S. Nuclear Regulatory Commission Document Control Desk <

Washington, D.C. 20555 Gentlemen: s River Bend Station'- Unit 1 Refer.to: Regio'n IV-Docket No. 50-458/89-37 Pursuant to-10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation' for -NRC Inspection? Report' Ho.

50-458/89-37. The-inspection was conducted by^ Messrs. Ford, Azua,'and' Jones during the period of October 1 - 31, 1989 ofs activitiesE authorized by' NRC Operating License NPF-47 for River: Bend Station Unit 1. GSU's response.to. j the violation is provided in the attachment and'is being submitted;:at this.

time per agreement with Mr. L. Constable.

Should 'you have any questions, please contact ' Mr. L. A. England : at (504)381-4145.

~ Sincerely,

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J. C. Deddens Senior Vice President River Bend Nuclear Group 90 JCD/ E /L /DNL C./DET/ch Enclosure cc: U.S.NuciearRegulatoryComiission Region IV 611-Ryan Plaza Drive,-Suite 1000.

Arlington', TX ' 760111 --

Senior Resident Inspector- '

Post Office Box 1051 St. Francisville,.LA 70775 9001260164 900112 PDR ADOCK 05000458 J

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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.

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'+v J. C/ Ueddens Subscribed and sworn to before me, a Notary Public in and

.for he State and Parish above named, this / EN day of J/*= . ,

19 M . My Commission expires with Life.

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0ASd. /AwiC Claudia F. Hurst Notary Public in and for

. West Feliciana' Parish, Louisiana

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f-ATTACMENT RESPONSE TO NOTICE OF VIOLATION 50-458/8937-01 LEVEL IV REFERENCE Notice of Violation - Letter from S. J. Collins to >J. C. Deddens,- dated December 1, 1989.

FAILURE TO FOLLOW PROCEDURE FOR MODIFICATION OF PERMANENT PLANT EQUIPMENT 10 CFR 50, Appendix B, Criterion III and the licensee's Quality Assurance Directive QAD-3, " Design Control," require that measures-be established' for-the identification and control of design interfaces and for coordination' among participating design organizations. These measures shall include the establishment of procedures among participating design organizations;for the review, approval, release, distribution, and ievision of documents involving design interfaces.

Engineering Procedure ENG-03-006, " River Bend-Station Design & Modification  !

Request Control Plan," Revision 5, paragraph 6.12.5 requires that maintenance use the transmitted copy of the prompt modification request'(PMR) for generation of the maintenance work orders (MW0s) necessary to implement the PMR.

Contrary to the above, on September 16, 1989, modifications were made to Power Line Conditioner 1RPS*XRC10B1, which included rerouting conduit and the pull and termination of electrical cable prior to review and approval of PMR-89-0025. PMR 89-0025 provided the instructions to. reroute 120 .VAC secondary conductors from 1RBS*XRC1081 to the instrument panel-previously supplied by failed power line condition ISCM*XRC1481. The work activity was l performed utilizing MWO R056460, which was originated'for troubleshooting the ]

failed power line conditioner. MWO R056460 was later utilized to implement  !

the PMR.

REASON FOR THE VIOLATION The events described in the violation occurred on a weekend under the I direction of the assigned Design Engineering Duty Supervisor. The condition was investigated through a debriefing with the Duty Supervisor the following Monday.

i The supervisor gave verbal authorization to reroute conduit and pull. and terminate cable prior to the field work. release of PMR 89-0025. The Duty Supervisor's decision was influenced by the urgency of the s.ituation, i.e.. a half isolation condition, 8-hour LCO, and risk of spurious. main steam.

isolation involving a challenge to safety systems. The authorizatwa is f contrary to the requirements of ENG-3-006, which describes a sequence of  ;

actions in which the PMR is required to be ' field work released' prior to  !

generation of the Maintenance Work Order. Thus, the. Duty Supervisor.  !

authorized a deviation from the sequence' of steps prescribed in' the- j

. procedure, but did not authorize any procedure requirement to be omitted. 1 The work was performed under .an MWO with Engineering and' Maintenance )

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supervisors and QC personnel present. The engineering supervisor was present-when the decision to perform the work was made and was satisfied that' no ,

unreviewed safety question existed due to the nature of the work and the previous declaration of the component as inoperable.

Prior to the verbal authorization of field work, engineers knowledgeable in ,

cable and conduit routing, conduit support, electrical design, engineering analysis, and equipment qualification were summoned to the site, and developed the proposed design. The development included hands-on walkdowns and eyes-on inspection of the proposed installation. An expedited parallel effort was initiated to complete the documentation, approva'1, and Facility Review Committee review of the modification prior to completion of field i work. The actions taken minimized the time period during which the plant was exposed to a spurious isolation and shutdown, and there was no effect on plant or public safety.

Based on additional review by management, it was determined that, while the technical guidance given to Operations and Maintenance prior to issuance ~ of the PMR was appropriate, ENG-3-006 did not provide adequate guidance for the ,

situation and the use of verbal authorization prior to issuance of the PMR' was not appropriate.

The root cause is therefore considered to be procedure violation. The ,

supervisors on duty for Maintenance, Operations, and Engineering failed to recognize the bounds of the governing procedures. Consequently.- some work was performed which should have taken place under an approved modification request. Additionally, the existing procedural guidance was not considered adequate to exercise pmper controls to_ disallow modifications' to the plant under the WO procedure, A0M-0028.

With regard to procedural compliance in general, a number of instances of  ;

noncompliance have been identified by River Bend Station (RBS) personnel via 1 the Condition Report program and other programs.

CORRECTIVE ACTIONS WHICH HAVE 3EEN TAKEN AND THE RESULTS ACHIEVED After identification by a Qit supervisor that the activities' appeared to be outside the scope of procedures, work was voluntarily stopped on the  !

modification. Work resumed folkwing the issuance of the PMR in accordance j with existing procedures. 3 In order to reduce procedural noncompliance, the Senior Vice President has ,

issued to all RBS managers a memo instructing them to re-review this  !

Inspection Report, particularly noting the llRC comments in the cover letter J pertaining to procedural compliance. The managers were further instructed to I hold meetings with management personnel dowr to the supervisor / foreman level, stressing the importance of procedural compliance and the necessity to reduce the incidence of noncompliance. l t

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. CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

-ADM-0028 was revised to specifically state that field work inter ded for implementation of a modification may not occur until author! zed by ENG-3-006.

ENG-3-006 was revised to provide a mechanism for Engineering to. evaluate and authorize field work parallel to the development of the modification request.

Personnel in Maintenance, Operations and, Engineering, and. QA who are involved in the review, approval, and implementation of modifications will be trained to the chances in the procedures. It will also be emphasized in' the -

training sessions that personnel are required to follow procedural requirements without deviation.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED ENG-3-006 and ADM-0028 were revised December 20, 1989 and November. 3, 1989, respectively. Training will be completed by February 15, 1990.

The Senior Vice President issued the memo to the managers on January 9, 1990.

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