RBG-23474, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-80.Corrective Actions:Revised Emergency Implementing Procedures EPIP-2-014 & EPIP-2-017 Submitted on 851210 & SSP-1-001 Revised to Address Revs Distribution

Responds to NRC Re Violations Noted in Insp Rept 50-458/85-80.Corrective Actions:Revised Emergency Implementing Procedures EPIP-2-014 & EPIP-2-017 Submitted on 851210 & SSP-1-001 Revised to Address Revs Distribution

ML20210S341
Person / Time
Site:	River Bend
Issue date:	04/04/1986
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20210S339	List: IR 05000458/1985080 ML20210S336 RBG-23474, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-80.Corrective Actions:Revised Emergency Implementing Procedures EPIP-2-014 & EPIP-2-017 Submitted on 851210 & SSP-1-001 Revised to Address Revs Distribution
References
RBG-23474, NUDOCS 8605210196
Download: ML20210S341 (6)

Text

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• G U Es F STATES UTILITIES COMPANY RIVER Bf.NO STATION POST OFFICE BOX 220 ST FRANCISVILLE. LOUISLANA 70775 ARE A CODE 504 635 6094 346 8651 April 4, 1986 RBG- 23474 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator __

Nu ear Regulatory Commission g g g3 611 Ryan Plaza Drive, Suite 1000

. Arlington, TX 76011 g,]g

Dear Mr. Martin:

uW River Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 85-80 This letter responds to the Notice of Violations contained in NRC I&E Inspection Report No. 50-458/85-80. The inspection was performed by Messrs. Nemen N. Terc and Charles A. Hackney during the period December 9-13, 1985 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 Violations 85-80 01, " Failure to Submit Changes to Emergency Implementing Procedures", and 85-80-02, " Failure to Document Procedure Review", are provided in the enclosed attachment. This completes GSU's response to the Notice of Violations.

Sincerely,

. /

W. J. Cahill, Jr.

Senior Vice President River Bend Nuclear Group WJC/ /je Attachments 8605210196 860507 PDR ADOCK 05000458 G PDR

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., a UNITED STATES OF AMERICA BUCLEAR REGULATORY C(BetISSIDE STATE OF IAUISIAEA 5 PARISE OF WEST FELICIAMA $

In the Matter of I Docket Nos. 50-458 GULF STATES UTILITIES COMPANY $

(River Bend Station, Unit 1)

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

t o

W. F Cahill, Jr. /

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

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Of/ , 19 l -

ban W. Middlebrookd

/NotaryPublicinandfor

' West Feliciana Parish, Louisiana My Commission is for Life.

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ATTACHMENT 1 RESPONSE TO NOTICE OF VIOLATION 50-458/8580-01 LEVEL IV REFERENCE Notice of Violation -

J. E. Gagliardo letter to W. J. Cahill, Jr.

dated March 5, 1986.

A. FAILURE TO SUBMIT CHANGES TO EMERGENCY IMPLEMENTING PROCEDURES Reason For Violation On October 10, 1985, Emergency Implementing Procedures (EIP) 2-014, Rev. 3 and EIP-2-017, Rev. 2 were approved by the Vice President, River Bend Nuclear Group. Subsequent to the approval of the EIPs, a 30 day submittal in accordance with 10CFR50, Appendix E, Section V, was not provided to the Nuclear Regulatory Commission (NRC) Region IV Administrator. During a NRC site inspection on December 10, 1985 it was discovered that the subject EIPs had not been submitted to the NRC due to the lack of a procedural mechanism to require the Administrative Services Department to transmit three copies of the revised EIPs to Nuclear Licensing. Therefore, Station Support Procedure (SSP) 001,

" Preparation, Revision, and Control of Station Support Procedures", was inadequate in requiring EIP approved revisions being transmitted to the Nuclear Licensing Department.

Corrective Steps Which Have Been Taken And The Results Achieved Upon discovery of the past due submittal, an immediate response was initiated and provided to the NRC on December 10, 1985 with EIPs 2-014, Rev. 3 and EIP-2-017, Rev. 2 attached. All EIPs were subsequently reviewed for approval dates on or before November 10, 1985. As a result, no additional revisions were identified which had not been previously submitted within 30 daye of their approval date under 10CFR50, Appendix E, Section V. For convenience, 4 additional EIPs were submitted on December 10, 1986. These procedures had been recently approved on Decembur 6, 1985. No revisions to the Emergency Plan have been initiated and approved since receipt of the River Bend Station (RBS) Operating License (August 29, 1985).

Corrective Steps which Will Be Taken To Avoid Further Violations A review of the approval, distribution and submittal cycle was performed. As a result of the review, a revision to SSP-1-001 was required. EIP-2-100, " Procedure Review, Revision, and Approval",

identifies the responsibilities for distributing EIP revisions.

However, SSP-1-001 did not specify distribution to the Nuclear Licensing Department for submittal to the NRC within 30 days of the EIP approvals. Therefore, SSP-1-001 has been revised to address distribution of revised and approved EIPs to the Nuclear Licensing Department within 15 calendar days of approval. Nuclear Licensing Procedure (NLP) 008 will be revised to reference NRC submittals in accordance with 10CFR50, Appendix E (V).

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EIP-2-101, " Periodic Review of the Emergency Plan," Section

4. 2.1. 3 (c) will be revised to require Plan changes be submitted to Nuclear Licensing within five working days of an approved Plan revision.

Date When Full Compliance Will Be Achieved

1. SSP-1-001 was revised on April 4, 1986.

2. EIP-2-101 and NLP-10-008 will be revised by May 1, 1986.

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ATTACHMENT 2 RESPONSE TO NOTICE OF VIOLATION 50-458/8580-02 LEVEL V REFERENCE Notice of Violation -

J. E. Gagliardo letter to W. J. Cahill, Jr.

dated March 5, 1986.

B. FAILURE TO DOCUMENT PROCEDURE REVIEW ,

Reason for Violation ,

Although all Emergency Implementation Procedure (EIP) changes had been reviewed against the criteria as specified in 10CFR50.54q and also stipulated in EIP-2-100, the procedure did not require that the Facility Review Committee document the completion of the review in a formal manner. Therefore, EIP-2-100 was inadequate in documenting that a 10CFR50.54q review had been performed.

Corrective Steps Which Have Been Taken and the Results Achieved EIP-2-100 entitled, " Procedure Review Revision and Approval" was revised on February 24, 1986 in Rev. 3. The approval sheet for the Facility Review Committee (FRC) Chairman's signature was revised to indicate that a review of changes to all EIPs has becn completed to ensure that the effectiveness of the Plan has not been decreased per 10CFR50.54q. In addition, Station Support Procedure (SSP) 001, " Preparation, Revision, and Control of Station Support Procedures", has been revised such that the procedure review and comment form also includes documentation that the applicable departmental reviewers have completed the 50.54q review. Also, the Emergency Plan Change Submittal Form in EIP-2-101, entitled " Periodic Review of the Emergency Plan," Rev.

3, was revised on February 24, 1986 to include a statement which references the completion of a 50.54q review.

Corrective Steps Which Will Be Taken To Avoid Further Violations A review of previous EIP revisions made since August, 29, 1985 (receipt of the River Bend Station Operating Licensing) was performed to ensure the intent of 10CFR50.54q was met. The results indicated that many revisions were initiated to enhance the e f fectiveness of the Emergency Plan and other revisions were editorial / administrative in nature. Many were initiated to address items raised during the 1985 training cycle, as well as previous NRC concerns from the December, 1984 Emergency Preparedness Appraisal and the GSU January, 1985 Emergency Preparedness Evaluated Exercise. Additionally, all revision were coordinated through the Supervisor-Emergency Preparedness who is responsible for maintaining the Plan. This control provides a level of assurance that the effectiveness of the Plan was not decreased.

In the future, changes to the approval sheet to EIP-2-100 and to the Emergency Plan Change Submittal Form to EIP-2-101 will provide

sufficient documentation for procedure and Plan changes which have been reviewed against 10CFR50.54q.

Date When Full Compliance Will Be Achieved EIP-2-100 and EIP-2-101 were revised on February 24, 1986.

SSP-1-001 was revised on April 4, 1986. Therefore, GSU is in full compliance.

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