RBG-23800, Responds to NRC Re Violations Noted in Insp Rept 50-458/86-16.Corrective Actions:General Maint Procedure 6MP-0092 Being Developed as Alternative to Torque Wrench Program

Responds to NRC Re Violations Noted in Insp Rept 50-458/86-16.Corrective Actions:General Maint Procedure 6MP-0092 Being Developed as Alternative to Torque Wrench Program

ML20211G099
Person / Time
Site:	River Bend
Issue date:	05/30/1986
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20211G071	List: IR 05000458/1986016 RBG-23800, Responds to NRC Re Violations Noted in Insp Rept 50-458/86-16.Corrective Actions:General Maint Procedure 6MP-0092 Being Developed as Alternative to Torque Wrench Program
References
RBG-23800, NUDOCS 8606190288
Download: ML20211G099 (6)

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GULF STATES UTIL1 TIES COMPANY Ye2 RIVER BEND STATION POST OFFICE BOX 220 Si FRANCISVILLE. LOUISIANA 70775 AREA CODE $04 635-6094 346-8651 May 30, 1986 RBG- 23800 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 @ @ @ yh DUM [lA'

Dear Hr. Martin:

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,i River Bend. Station - Unit 1 ; S Refer to: Region IV

__J Docket No. 50-458/ Report 86-16 9

This letter responds to the Notice of Violation contained in NRC I&E Inspection Report No. 50-458/86-16. The inspection was performed by Mr. Michael E. Skow during the period March 31 through April 4, 1986 of activities authorized by NRC Operating License NPF-47 for River Bend Station - Unit 1.

Gulf States Utilities Company's (GSU) response to Notice of Violation 86-16-01, " Failure to Have Adequate Procedures",

86-16-02, " Failure to Follow Procedures", and 86-16-03, " Failure to Follow Procedures", are provided in the enclosed attachment.

This completes GSU's response to the Notice of Violation.

Sincerely, a

W. J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group WJC/ D /je Attachments v-8606190288 860613 PDR ADOCK 05000458 G PDR f

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UNITED STATES OF AMERICA EUCLEAR REGULATORY C(EEEISSION STATE OF IMISIAE& 5 FARISE OF WEST FELICIAEA $ .

In the Matter of I Docket Bos. 50-458 GULF STATES UTILITIES C(EEFANY $

(River Bend Station, Unit 1) .

AFFIDAVIT W. J. Cahill, Jr., being duly sworn, states that he is a Senior Vice Pcesident of Gulf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory coussission the documents attached hereto and that all such documents are true and correct to the best of his knowledge, information and belief.

/s W. Cahill, Jr. /[

Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this M day of W a +7 ,

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an W. Middlebrooks ' ~

otary Public in and for West Feliciana Parish, Louisiana My Cosmaission is for Life.

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ATTACHMENT 1 RESPONSE TO NOTICE OF VIOLATION 50-458/8616-01 LEVEL IV Reference Notice of Violation - J. E. Gagliardo to W. J. Cahill, Jr. dated May 1, 1986.

A. FAILURE TO HAVE ADEOUATE PROCEDURES REASON FOR THE VIOLATION On March 25, 1986, in Memorandum No. PMG-M-86-62, the Plant Staff Maintenance Department removed torque wrenches from the controls of Administrative Procedure ADM-0029, " Control of Measuring and Test Equipment (M&TE) " , and provided new instructions for controlling torque wrenches. These program changes were made to provide controls for more reliable torque wrench calibrations by requiring the torque wrenches to have a calibration check before and after each use on plant equipment. The new program also expedited the process of issuing torque wrenches to Maintenance personnel. The M&TE device used to check the torque wrench calibrations remained under the control of ADM-0029. The new instructions also continued the use of M&TE Tracking Cards, as required by ADM-0029. Although the memorandum, issued on March 25, 1986, did establish controls for using torque wrenches at River Bend Station, the failure to implement an approved procedure in accordance with the requirements of ADM-0003 resulted in an apparent violation of Technical Specification Section 6.8.1.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The new program, as described in Memorandum No. PMG-M-86-62, was discontinued on March 27, 1986 when the torque wrench calibration check device was relocated from the Maintenance Shop to the Site Standards Laboratory. This change resulted from the device's calibration having been suspected as out of tolerance. When returned to the Standards Laboratory, the device's calibration was confirmed to be out of tolerance by a 1.4 percent error for readings above 225 ft-lbs when used in the counter clockwise direction. A review of the M&TE Tracking Cards for the torque wrenches used during the 3 days of the new program, revealed that the torque wrenches in question were not used in the counter clockwise direction or in the ranges found out of tolerance.

Therefore, all torque wrench applications during this period were acceptable.

As a result of the calibration check device being removed from service on March 27, 1986, subsequent torque wrenches issued were 1

required to be performed in accordance with the controls of ADM-0029. To ensure compliance with ADM-0029, Memorandum No.

APM-M-86-59 was issued on April 2, 1986 rescinding the new program described in Memorandum No. PMG-M-86-62, dated March 25, 1986.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The responsible Plant Staff Maintenance personnel are aware of the requirements of ADM-0003. General Maintenance Procedure, GMP-0092 is presently being developed as an alternative to the torque wrench program described in ADM-0029. The procedure will meet the intent of the program described in Memorandum No. PMG-M-86-62 and establish approved instructions for the calibration and control of torque wrenches. The approval of GMP-0092 is presently pending the receipt of a newly purchased torque wrench calibration check device. Torque wrt ches will remain under the controls of approved procedure ADM-0029 until GMP-0092 is approved and issued.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance with the requirements of ADM-0029 was achieved on March 27, 1986 after the relocation of the torque wrench calibration check device.

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• ATTACHMENT 2 RESPONSE TO NOTICE OF VIOLATION 50-458/8616-03 LEVEL V B. FATLURE TO FOLLOW PROCEDURES REASON FOR THE VIOLATION Procedure ADM-0005, Revision 4 (Station Document Control) requires that documents transmitted to satellite stations offsite be incorporated into manuals, etc. end the transmittal signed and returned within 10 working days of the date on the transmittal.

Contrary to this requirement, 17 document transmittals older than 10 working days had not been incorporated into manuals located in the Emergency Operating Facility (EOF). Emergency Response Personnel were not updating EOF documents as required by ADM-0005.

Also, Station Document Control (SDC) had not sent Delinquent Notices to the satellite station as also required by ADM-0005.

Root cause of the problem appears to be a change in EOF personnel resulting in responsibility for updating documents not being carried over and leniency on the part of SDC because of the new personnel in EOF.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED All documents were incorporated into their respective manuals on the day that the discrepancy was discovered by the NRC Inspector.

The transmittals were then signed and returned to SDC. The EOF Satellite Station is now in compliance with ADM-0005 requirements.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOILATIONS The new EOF personnel were given training by the SDC Supervisor to ensure they understood their satellite station custodial responsibilities. Documentation is available to support the training given. Station Document Control personnel have been verbally instructed to comply with ADM-0005 requirements for issuing Delinquent Notices. A memorandum has been issued restating the verbal instructions given to SDC personnel.

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.

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ATTACHMENT 3 RESPONSE TO NOTICE OF VIOLATION 50-458/8616-02

. /' LEVEL V C. FAILURE TO FOLLOW PROCEDURES REASON FOR THE VIOLATION Station Support Procedure (SSP)-1-004, Revision 0 (Station Document Control System) states that the IS-217 Report is the primary document for identifying outstanding changes against Stone and Webster design documents. However, a modified IS-217 Report exists that identifies changes in the form of Pipe Support Revision Notices (PSRNs) to Category II and III large bore pipe support design drawings (i.e., BZ/PSDD drawings). The modified IS-217 is not addressed in SSP-1-004. Station Document Control (SDC) was not aware of the existence of PSRNs or the modified IS-217. Both documents had been previously distributed by Stone &

Webster (S&W) Document System Group prior to this group's consolidation with GSU Station Document Control in late 1985.

PSRNs-were no longer being originated by S&W at the time of consolidation but some of those previously issued are not incorporated into their respective drawings, thus, they are still

-outstanding changes.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The modified IS-217 is addressed in the Stone and Webster Engineering Corporation Plant Services Procedure (PSP)-3.1-0,

" Applicability of Construction Phase Interim Design Change

, Mechanism to Operation", dated August 28, 1985. An approved change to SSP-1-004 has been implemented which addresses the modified .S-217 I Report and references PSP-3.1-0. SSP-1-004 also discusses the need; for using both the IS-217 and the modified

.IS-217'to ensure a BZ/PSDD is current.

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- CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The modified IS-217 will be distributed on a as-needed basis to

~ document, satellite stations. Since the IS-217 Report and the modified IS-217 Report are the only documents available for identifying outstanding changes against Stone and Webster design pfi, documents, this i's determined to be an isolated case.

1 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

!7 Full compliance has been achieved.

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