IR 05000458/1986007
| ML20204A539 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/05/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20204A532 | List: |
| References | |
| 50-458-86-07, 50-458-86-7, NUDOCS 8605120323 | |
| Download: ML20204A539 (50) | |
Text
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SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC APPRAISAL OF LICENSEE PERFORMANCE Inspection Report 50-458/86-07 Gulf States Utilities River Bend Station January 1,1985, through January 31, 1986 8605120323 860505 PDR ADOCK 05000458 G
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I.
INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance _ based upon this information. The SALP program is supplemental to the normal regulatory processes used to ensure compliance with NRC rules and regulations.
The SALP program is in'. ended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on March 25, 1986, to review the collection of performance observations and-data and to assess licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at River Bend Station for the period January 1,1985, through January 31,-1986.
SALP Board for River Bend Station:
E. H. Johnson, Director, Division of Reactor Safety and Projects, RIV J. E. Gagliardo, Chief, Reactor Projects Branch, RIV W. Butler, Director, BWR Project Directorate No. 4, NRR B. Murray, Chief, Facilities Radiological Protection Section, RIV J. P. Jaudon, Chief, Project Section A, RIV S. Stern, Project Manager, NRR D. D. Chamberlain, Senior Resident Inspector, RIV Other personnel who participated in all or part of the SALP Board were:
W. C. Seidle, Chief, Technical Support Staff, RIV W. R. Bennett, Project Engineer, Project Section A, RIV W. B. Jones, Resident Inspector, RIV II.
CRITERIA Licensee performance was assessed in 12 selected functional areas.
Functional areas normally represent areas significant to nuclear safety and the environment.
Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
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-2-One or more of the following evaluation criteria were used to assess each functional area:
1.
Management involvement and control in assuring quality.
2.
Approach to the resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Operational and construction events (including response to, analyses of, and corrective actions for).
6.
Staffing (including management).
,
However, the SALP Board is not limited to these criteria, and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definitions of these performance categories are:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety and construction quality is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect tc operational safety and construction quality is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety and construction quality is being achieved.
III. SUMMARY OF RESULTS The SALP Board review revealed licensee areas of significant strength with high level management involvement in assuring quality and with a strong approach to the resolution of technical issues from a safety standpoin o
-3-The management involvement is especially strengthened by the full-time onsite presence of the Senior Vice President and the Vice President of the River Bend Nuclear Group. The licensee resolution of technical issues has been strengthened by the use of task forces with assigned managers and personnel with various areas of technical expertise to resolve significant technical issues.
Apparent areas of weakness included the licensee design control program when design control responsibility was assumed from the contractor by the licensee for the control of temporary plant alterations. These weaknesses are in the functional area of Quality Programs and Administrative Controls Affecting Quality.
Licensee management has taken action to control this area on an interim basis, while long term corrective actions are implemented.
The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation period.
Previous Present Performance Category Performance Category Functional Area (8/1/83 to 12/31/84)
(1/1/85 to 1/31/86)
A.
Plant Operations 2 (Preparation Only)
B.
Radiological Controls
2 C.
Maintenance Not Assessed
D.
Surveillance Not Assessed
E.
Fire Protection Not Assessed
F.
2 G.
Security
2
,
H.
Outages Not Assessed Not Assesser I.
Quality Programs and
2 Administrative Controls Affecting Quality J.
Licensing Activities
2 K.
Training and Qualification
2 Effectiveness L.
Preoperational Testing
2
.
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_4 Previous Present.
Performance Category Performance Category Functional Area (8/1/83 to 12/31/84)
(1/1/85 to 1/31/86)
M.
Startup Testing Not Assessed
L" N.
Construction Not Assessed Not Assessed Completion i
Eighty-four NRC inspections were conducted during this SALP evaluation period, involving a total of 9,897 direct inspection manhours, j
IV. PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis
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j This area has been inspected on a continuing basis by the NRC resident inspectors and on many occasions by NRC regional
'
inspectors.
Specific areas inspected included operating procedures review, technical specifications review, operational
.
safety verifications, safety system walkdowns, licensee event l
- report reviews, and plant tours.
Four violations of NRC regulatory requirements were identified in this functional area as listed below:
Inadequate Operating Procedures.
(Severity Level V, 85-20)
.
Failure to Follow an Administrative Procedure.
(Severity
.
Level IV, 85-51)
Failure to Properly Prepare Temporary Change Notice.
.
(Severity Level IV, 85-66)
i Failure to Follow Procedure for Temporary Circuit
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Alterations.
(Severity Level IV, 86-02)
There were 21 Licensee Event Reports (LER) issued that were associated with plant operations as listed below:
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A reactor protection system actuation occurred when the
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intermediate range monitor mode switch was inadvertently
_
moved from operate to standby.
(85-05)
A reactor protection system actuation occurred because of
.
the failure of an electrical protection assembly.
(85-06)
The standby cooling tower level was discovered to be below
.
the minimum level required by Technical Specifications.
(85-14)
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-5-It was discovered that both the A and B channels of the
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control room ventilation local intake radiation monitors were inoperable because both of the sample pumps were off.
(85-15)
The reactor water cleanup system isolated because of
.
unstable high differential flow readings.
(85-24)
Reactor water conductivity recorders were taken out of
.
service and conductivity samples were not taken every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(85-25)
A reactor water cleanup system isolation occurred as a
.
result of a spurious reactor water cleanup filter
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demineralizer room high temperature alarm.
(85-30)
The fuel building ventilation normal supply and exhaust
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system isolated and the Division I charcoal filter train auto started due to a spurious low flow signal.
(85-32)
A reactor water cleanup isolation occurred as a result of a
.
switch failure on the demineralizer receiver tank room temperature differential trip unit.
(85-35)
A reactor water cleanup system isolation occurred because
.
of a defective trip unit.
(85-37)
The reactor water cleanup system isolated because of unstable high differential flow readings.
(85-39)
A reactor scram occurred on low reactor water level.
The
.
low level resulted from a trip of the reactor feedwater pump and the inability to place a standby feedwater pump in service prior to reaching the reactor low water level scram trip setpoint.
(85-41)
A reactor water cleanup system isolation occurred because
.
of a high temperature in the heat exchanger room due to a loss of chilled water to the containment coolers.
(85-43)
A reactor scram occurred on an intermediate range monitor
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upscale trip. This resulted from a reactor water level / pressure transient introduced by breaking condenser vacuum during an initial turbine roll.
(85-47)
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A residual heat removal system isolation occurred because
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l of an equipment area high temperature signal.
(85-52)
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-6-An automatic initiation of standby gas treatment, annulus
.
mixing and control room ventilation occurred because of a voltage transient.
(85-57)
A reactor water cleanup system isolation occurred as a
.
result of o foiled copocitur internal to o Leinperature ruitch.
(85-58)
A reactor scram occurred on low reactor vessel water level.
.
The low level resulted from the trip of the running feedwater pump "C" and the inability to open the discharge valve on the standby pump after it was started.
(85-60)
A turbine generator trip occurred on a false turbine
.
generator load imbalance. A reactor scram occurred 7 seconds later on high pressure. The false turbine trip occurred because of a failed transmitter coupled with a lightning strike on a transmission line.
(85-63)
With the main condenser off-gas hydrogen analyzers declared
.
inoperable, a grab sample was not obtained every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by Technical Specifications.
(85-64)
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A reactor scram occurred due to low reactor water level.
.
The low level was caused by a loss of feedwater when both low pressure feedwater heater trains isolated coincident with a failure of the low pressure feedwater heater bypass valve to open.
(86-01)
- Indicates those events deemed to involve personnel and/or procedural errors.
One additional, significant event occurred when a shift supervisor misunderstood a license conoition, and attempted to increase power above the five percent limit.
Indicated power did exceed five percent, although actual power did not exceed the limit.
The licensee identified this problem and took prompt and effective corrective action which consisted of, in part, manage-ment personnel being present at all shift turnovers.
River Bend Station received a low power operating license on August 29, 1985; initial criticality occurred on October 31, 1985; and the full power license was issued on November 20, 1985. Although several inspections were conducted for operational preparations (e.g., procedure review, Technical Specification review, staffing review, etc.), the actual operating history during this SALP evaluation period was limited to the time period from receipt of the low power operating license on August 29, 1985, to January 31, 1986. The highest power level attained during the rating period was 35 percen.
.
-7-However, the resident inspectors and regional inspectors observed several plant startups and shutdowns and were present in the control room during plant transients.
The conduct of operations was observed to be well coordinated and efficient and good control room professionalism was evident.
Equipment problems with balance of plant (BOP) equipment caused the operations staff to operate in unusual BOP lineups and caused some of the licensee events reported. The operational response to these events and to other off-nomal conditions was observed to be prompt and controlled and the plant was operated in accordance with procedures. Also, during plant tours, the plant-wide housekeeping was observed to be good.
A general area of concern was identified with control room alarms. There were a relatively large number of annunciator alarms present with the plant operating. This is primarily because of equipment problems and annunciator alarm design. A related concern exists with a lack of reflash on alarms that can be triggered by more than one input. This means that once a single input is in the alarm state, no subsequent alarm (reflash) will be received if a second alarm input is received.
The licensee is aggressively addressing the alarm situation including a review of alarm designs for needed changes.
Management involvement in assuring quality was evident in this performance category. The licensee has a condition report system for identifying problems. Condition reports are reviewed daily by plant management and tracked to resolution. Management involvement is especially strengthened by the full-time onsite presence of the Senior Vice President and Vice President of the River Bend Nuclear Group. This aids in assuring that proper management attention is given to timely, thorough and technically sound resolution of issues.
Licensee management uses multidiscipline task force teams to attack identified problems. This has resulted in timely resolution of problems.
A significant strength noted by the resident inspectors was the deliberate, methodical approach to plant operations that was exhibited by the staff with apparent management support.
The operational staffing, including management, is an area of strength in that:
positions and responsibilities are well defined; vacant key positions are filled on a priority basis; experience levels are high, and staffing is adequate. There were occasional difficulties with work backlog and with overtime because of the heavy workload during this SALP evaluation perio,
-8-2.
Conclusion The licensee demonstrated a clear understanding of issues, a technically sound and thorough approach, timely resolutions, and routine conservatism toward operations.
The licensee's response to NRC initiatives is another area of strength as indicated by the meeting of deadlines with technically sound and thorough responses. The resolutions proposed are generally acceptable and complete when initially proposed.
The enforcement history in this functional area indicates only occasional and minor programmatic weaknesses as might be expected during the startup phase.
Corrective actions are timely and effective in most cases.
Some occasional, significant operational events occurred which were attributable to causes under the licensee's control. These events were promptly and completely reported, and properly identified and analyzed.
Although some minor weaknesses were evident during this assessment period, licensee management responded rapidly to problems by initiating prompt corrective actions.
The overall evaluation of this category indicated a strong plant operations program at River Bend Station.
The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions Since there has been limited operational history, the NRC inspection effort in this functional area should remain at its current high level.
b.
Recommended Licensee Actions The licensee should continue a high level of management attention in this functional area. Also, the licensee should take action to expeditiously complete the review ~of the control room alarm situation and is encouraged to add alarm reflash to multiple input alarm.
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B.
Radiological Controls 1.
Analysis Fifteen inspections concerning radiological controls were conducted during the assessment period by region-based radiation specialist inspectors.
These inspections involved the following areas: occupational radiation safety; radioactive waste management; radiological effluent control an'dimonitoring; transportation of radioactive materials; and water chemistry.
Five violations and two deviations were identified:
i Failure to provide training for health physics technicians.
.
(Severity Level IV, 85-73)
,
Failure to maintain training records for health physics
.
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technicians.
(Severity Level IV, 85-73)
Failure to calibrate containmen't high range monitors.
.
(Severity Level IV, 85-82)-
Failure to maintain calibration records for gas
.
,
chromatograph.
(Severity Level V, 86-05)
Failure to use Offsite Dose Calculation Manual (ODbM) alarm
.
setpoints.
(Severity Level IV, 86-01)
Failure to provide BWR technology trainjng for the health
.
,
physics staff.
(Deviation, 85-73)
J Failure to maintain emergency response equipment.
.
(Deviation,86-01)
a.
Occupational Radiation Safety This area was inspected five times during the assessment period.
'
A large turnover among the senior health physics staff (four out of five positions) was noted during the assessment period. The licensee also places a large
,
i reliance on contractor health physics technicians to supplement the permanent plant staff. About 30 percent of the health physics technicians are provided by an offsite contractor.
No significant problems were identified in the areas of
,
exposure controls, surveys, control of radioactive materials, contaminated controls, and the ALARA program.
,
The health physics staff consists of well qualified
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-10-personnel. The licensee has demonstrated a positive attitude toward the resolution of NRC initiatives.
Licensee oversight of this area was evident by the performance of QA audits.
No problems were identified in the areas of general employee training and radiation worker training. Management support for the radiation protection program has been demonstrated by establishing excellent facilities and acquiring state-of-the-art equipment and instrumentation.
b.
Radioactive Waste Management This area was inspected twice during the assessment period.
The inspections of this area identified the following observations:
(1) a radioactive waste management policy statement had not been issued, (2) a waste classification program concerning sampling frequency, identification of waste streams, and the selection of a qualified vendor to analyze the samples had not been established, and (3) a program had not been established concerning monitoring and segregation of waste material collected within the radiologically controlled area.
c.
Radiological Effluent Control and Monitoring This area was inspected five times during the assessment period. These inspections involved gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, radiological environmental monitoring, and onsite confirmatory measurements for the radiochemistry and whole body countiig programs.
The first radiochemistry confirmathry measurements inspection involved onsite comparctive measurements between the licensee and the NRC mobile lasoratory on prepared counting standards.
These results 1.idicated about 99 percent agreement. However, the second inspection involving comparative measurements was conducted after the plant was operational and involved actual plant gaseous and liquid effluents. The results from the second inspection indicated only about 82 percent agreement. The expected agreement for these kinds of measurements should be greater than 90 percent.
Inspection of the radiological environmental monitoring program revealed that the licensee had relied on a contractor to implement the initial monitoring progra.
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This individual had recently completed his contract and the
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licensee was now conducting the program in-house.
It was noted that the licensee was experiencing some difficultie's
'
in carrying the program at the same performance level as f'
'
provided by the contractor.
The licensee had used an
'
offsite contractor to perform radiological sample analyses,
,
but was in the process of establishing an in-house program to perform these analyses.
However, the environmental
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required sample analyses.
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The inspection of the radiological effluent control and monitoring program identified two procedure weaknesses:
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(1) procedures had not been developed to obtain and analyze samples from storm drains and sewage systems, and (2)
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procedures had not been established to response test,
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functional check, 7r calibrate effluent and process monitors not identified in the Technical Specifications.
d.
Transportation of Radioactive Materials a.
This area was inspected twice during the assessment period.
The inspection results noted that:
(1) the licensee had not submitted a QA program to the NRC for approval to ship radioactive materials in quantities greater than type A, and (2) the licensee had not applied to the NRC for
,
approval to use NRC certified casks for the shipment of radioactive materials.
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e.
Water Chemistry Controls
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This area was inspected in conjunction with the radiochemistry and confirmatory measurement inspections.
No significant problems were identif fyd. ;
-
.
2.
Conclusions A high turnover rate was noted among the health physics
!
technical staff. The licensee places a heavy reliance on< i contractor health physics technicians in order to supplement the permanent plant staf f.
The high turnover rate combined with the heavy reliance on contractor personnel has the potential for
,
affecting this functional area deleteriously.
The licensee's
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performance in the radiochemistry confirmatory measurements f
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results is considered below average.
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-12-The licensee had not submitted their transportation QA program to the NRC for approval nor applied to the NRC for approval to use certain shipping casks.
The licensee was experiencing difficulties in implementing an in-house radiological environmental monitoring program at the same performance level established by the previous offsite contractor.
Management oversight was evident for the various radiological control program areas by the performance of QA audits and program reviews.
Excellent facilities and state-of-the-art equipment and instrumentation have been established for the radiation protection and chemistry programs.
No significant
. problems were identified in the areas of resolution of technical issues, responsiveness to NRC initiatives and reportable events.
The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine program, b.
Recommended Licensee Actions
,
Management needs to investigate and correct the high
,
turnover rate among the health physics technical staff.
'
Management should also: (1) review the radiochemistry program in order to increase the performance level in this
area, (2) assure that the r.ecessary NRC approvals are obtained concerning the transportation program, and (3)
assure that a proper in-house environmental monitoring
program is implemented.
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C.
Maintenance i
1.
Analysis This area was inspected by region-based NRC inspectors and on a continuing basis by the NRC resident inspectors.
Two violations
of NRC regulations were identified in the functional area of Maintenance as listed below:
Improper use of a Field Change Notice.
.
85-29)
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-13
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Inadequate Retest of Modification / Repair.
(Severity Level
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IV,85-29)
There were 10 LERs issued in the functional area of Maintenance as listed below:
The reactor protection system actuated first on a high main
.
steam line radiation signal, 2 minutes later on high scram discharge volume level, and 2 minutes later a third actuation occurred on a high main steam line radiation signal. This was caused by having Channel "A" tripped during calibration coupled with inadvertent noise spikes
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generated by a physical inspection of the main steam line radiation monitors in Channel "B".
The high scram i
discharge volume level actuation resulted from the initial actuation.
(85-02)
I A reactor protection system actuation occurred because of
the inadvertent shorting of a contact while installing an electrical jumper.
(85-03)
It was discovered that a level transmitter for the scram
.
'
discharge volume had been replaced with an unqualified component.
(85-07)
An emergency core cooling system actuation occurred due to
.
,
]
inadvertent venting of the low pressure side on a reactor vessel level instrument while attempting to repair a leak.
(85-26)
An emergency core cooling system actuation occurred because
.
of an erroneous reactor vessel low water level signal.
This signal was caused by the backfilling of a common
,
reference leg for reactor vessel level instruments.
(85-27)
An electrical technician inadvertently tripped the main
i
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supply breaker to a normal switchgear bus. The loss of
'
power to the electrical bus caused a loss of power to the
reactor protection system "B", a reactor water cleanup isolation, the starting of safety-related equipment and a
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recirculation pump trip.
(85-28)
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A reactor water cleanup system isolation occurred when a
.
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temperature module was removed for maintenance.
(85-40)
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-14-A reactor water cleanup system isolation occurred when an
.
electrical cable to a bypass switch was disconnected during the implementation of a design modification.
(85-53)
A residual heat removal system isolation occurred because
.
of the incorrect installation of an electrical jumper during maintenance.
(85-56)
A reactor water cleanup system isolation occurred because
.
of high differential flow due to leaking valves on which a maintenance work request had been issued.
(85-59)
" Indicates those events deemed to involve personnel and/or procedural errors.
The majority of the NRC inspection effort was directed toward the preventive maintenance program.
The licensee conducts daily meetings to prioritize required preventive and corrective maintenance.
Since no major outages have occurred during this assessment period, the staffing has not been challenged in the performance of maintenance tasks.
A problem was found with the control of design changes and the identification and performance of required retests.
2.
Conclusion The licensee has developed an effective _ preventive maintenance program.
Several operational events attributable to causes under the licensee's control have occurred that are relevant to this functional area. These events occurred because of maintenance personnel not fully realizing the effects of their action on the plant. This was evidenced by the problems in identifying proper retests.
Key positions in the maintenance staff were identified and responsibilities were defined, and staffing appeared to be adequate.
The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendation a.
Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection progra ;
..
.
-15-b.
Recommended Licensee Actions Licensee management should focus on the implementation of the preventive maintenance program and should provide the training to assure that maintenance personnel understand the potential effects of their actions.
This may be.
accomplished both by improved communications with operations personnel and through improved training of maintenance personnel. Management should take actions to improve control of design changes and retesting.
D.
Surveillance 1.
Analysis This area has been inspected by region-based NRC inspectors and on a continuing basis by the the NRC resident inspectors.
Included in the inspection effort were two major team inspections by region-based inspectors and contractor personnel on Technical Specifications and their implementing surveillance procedures.
Two violations of NRC regulations were identified in the functional area of Surveillance as listed below.
Failure to Follow Administrative Procedure.
(Severity
.
Level IV, 85-62))
Inadequate Surveillance Procedure.
.
85-71)
There were 27 LERs issued in the functional area of Surveillance as listed below:
During the surveillance testing of the average power range
.
monitors, all steps to verify operability were not performed.
(85-04)
A reactor protection system actuation occurred due to low
.
reactor vessel water level when the residual heat removal system suppression pool suction valve was opened before the shutdown cooling suction valve was fully closed during restoration from a surveillance test.
(85-08)
A reactor water cleanup system isolation occurred when a
.
temperature device was placed in the " READ" position.
(85-09)
.
.
-16-A Division II main steam line isolation signal was
.
generated and primary containment / secondary containment isolations were actuated during the performance of a surveillance test.
(85-11)
A shutdown cooling suction isolation occurred when an
.
electrical jumper slipped off a terminal during a surveillance test.
(85-16)
A shutdown cooling suction isolation occurred when a
.
technician inadvertently grounded a recorder lead while attempting to attach the lead to an electrical relay terminal.
(85-17)
A shutdown cooling system isolation occurred when an
.
electrical relay was improperly identified during a surveillance test.
(85-18)
A reactor water cleanup system isolation occurred when an
.
installed electrical jumper came loose during a surveillance test.
(85-19)
A reactor water cleanup system isolation occurred when an
.
electrical jumper touched a relay separation casing and blew a fuse during a surveillance test.
(85-20)
An automatic initiation of the high pressure core spray
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system occurred during the performance of a surveillance test.
(85-21)
.
A reactor water cleanup system isolation occurred when an
electrical jumper was installed on the wrong relay contacts
,
during a surveillance test.
(85-22)
A reactor water cleanup system isolation occurred when an
.
electrical jumper fell off of a relay terminal during a surveillance test.
(85-23)
A reactor water cleanup system isolation occurred
.
apparently because of a noise spike trip on a "Riley" temperature module.
(85-29)
A reactor water cleanup system isolation occurred when an
.
area temperature switch was placed in the " READ" position prior to placing the isolation switch in bypass during a surveillance test.
(85-31)
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-17-An emergency core cooling system actuation occurred when a
.
reactor vessel level transmitter low pressure isolation valve was bumped open with the bypass valve open during a surveillance test causing an erroneous low level signal.
(85-36)
A reactor water cleanup system isolation occurred when the
.
trip logic was not jumpered out during a surveillance test.
(85-38)
A reactor core isolation cooling steam line isolation
.
cccurred while testing the main steam safety relief valves apparently due to pressure and flow fluctuations.
(85-42)
The area temperature switch settings for a reactor water
.
cleanup heat exchanger room were found outside of the Technical Specification allowable values because of a procedural problem.
(85-43)
A high pressure core spray system initiation occurred
.
because of a false low water level signal received from improperly valving a transmitter into service during the performance of a surveillance test.
(85-45)
A main steam line isolation occurred when a temperature
.
reading was taken on a leak detection temperature module prior to going to bypass during a surveillance test.
This caused a full isolation because a half isolation was already present from a previous reading.
(85-46)
A reactor water cleanup system isolation occurred when a
temperature switch was placed in the " READ" mode prior to placing the isolation switch in the bypass position during a surveillance test.
(85-48)
It was discovered that pump and valve operability quarterly
.
surveillance for residual heat removal subsystems were missed during the last surveillance interval.
(85-50)
.
A reactor water cleanup system isolation occurred when a
temperature switch was placed in the " READ" mode prior to going to bypass during a surveillance test.
(85-51)
It was discovered that the surveillance frequency was not
.
increased and the surveillance interval was exceeded for the standby service water pumps and the low pressure core spray pump after pump vibration was measured in the alert range during inservice inspection testing.
(85-54)
The plant experienced a loss of reactor protection system
.
bus "D" power, a loss of the annulus pressure control
_
.
.
-18-system, a reactor water cleanup system isolation, and a residual heat removal isolation. These events occurred during the baseline performance of a surveillance test when two electrical terminals were shorted.
(85-55)
A reactor water cleanup system isolation occurred during
.
the placement of a test switch and was a result of an error contained in the surveillance procedure.
(85-61)
A reactor water cleanup system isolation occurred during a
.
surveillance test because of an error contained in the procedure.
(85-62)
- Indicates those events deemed to involve personnel and/or procedure errors.
Review of the River Bend Station surveillance program indicated that all components and systems reviewed had been tested in accordance with controlled procedures and had been tested on schedule. The number of LERs in the functional area of surveillance was greatly affected by a weakness in the use of jumpers during surveillance testing.
The licensee took corrective action concerning the use of jumpers, and the results have shown a significant reduction in jumper related problems indicating that the corrective action was effective. The licensee baselined (performed whether or not they were due to be performed) the majority of the surveillance procedures prior to initial criticality, and all surveillance procedures have been baselined during this assessment period. The decision to baseline all _ surveillance procedures contributed to the number of LERs in this period, but it is-believed that in the long term it will help prevent future problems. A significant number of events were caused by personnel not paying attention to detail during performance of surveillance procedures. The licensee's computerized surveillance tracking system appears to be providing an accurate status of pending surveillance requirements. All surveillance procedures reviewed were found to be complete, well maintained, and readily available.
Observations of surveillance tests indicated that there was good adherence to procedural requirements.
2.
, Conclusion The licensee demonstrated a clear understanding of the problems associated with the surveillance program. The licensee's efforts to improve the surveillance program have produced good results.
i a
.
.
-19-The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program.
b.
Recommended Licensee Actions Licensee management should continue to focus on this area to continue the improvements in the surveillance program.
Specific management attention should be devoted to reducing the number of personnel errors caused by inattention to detail and to ensuring that lessons learned during performance of surveillance are promulgated to all personnel to prevent recurrence of similar problems.
E.
Fire protection 1.
Analysis This area was the focus of a special team inspection comprised of personnel from Region IV, NRR, and Brookhaven National Laboratory. The areas inspected were the establishment and implementation of the fire protection program, and compliance with the requirements of 10 CFR Part 50, Appendix R, per FSAR commitments and the safety evaluation report. The results of this inspection were documented in NRC Inspection Report 50-458/85-27.
There were no violations or deviations identified in these areas.
There were, however, open items in the area of fire protection as a result of this inspection.
These open items resulted from the fact that some commitments were not completely finished at the time of the inspection. These open items were reinspected and closed in subsequent NRC inspection reports.
There was one LER issued that was associated with fire protection as identified below:
It was discovered that a direct current power supply for
.
the remote shutdown panel was located in the main control room which did not meet fire isolation requirements.
(85-13)
<
- -.,
, --
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-
,.
-. -,, - -
,
.-..,
.
.
-20-This event was deemed to involve a personnel or procedural error during the initial design.
Responsibility for the fire protection program is currently divided among four groups--operations, projects, training, and nuclear plant engineering.
The fire brigade is made up of operations, chemistry, and instrument and control personnel.
The leader of the fire brigade is required to be qualified as a nuclear control operator.
2.
Conclusion The licensee has demonstrated a commitment to developing and implementing an effective fire protection program.
The licensee is considered to be in Performance Category 1 in this area.
3.
Board Recommendation a.
Recommended NRC Action The NRC inspection effort in this functional area should focus on implementation of the fire protection program consistent with the routine inspection program.
b.
Recommended Licensee Action The licensee should continue to exercise strong management involvement in the fire protection program, and consideration should be given to placing the fire protection program under the control of a single person.
F.
Analysis Four inspections and one emergency exercise were conducted during the assessment period by region-based emergency preparedness inspectors. Two violations were identified:
Failure to submit changes to emergency implementing
.
procedures.
(Severity Level IV, 85-80)
Failure to document procedure review.
(Severity Level V, 85-80)
..
..-
,
.- ~
-
- -...
.
_ -..-
-
.-.
s
.s.
^
-21-
,
An Emergency Preparedness Appraisal had been conducted during
,
the period of December 3-14, 1984, by an NRC team which resulted
'
in 35 significant' deficiencies and 75 improvement items being identified.
During three followup inspections conducted during this evaluation period, all 35 significant deficiencies were corrected by the licensee and closed out by the NRC.
The annual emergency exercise was conducted on January 15-17,
'
1985, and the NRC team concluded that the licensee's performance was acceptable.
Eight deficiencies were identified in the areas of notifications to the NRC, status board displays, assessment of protective actions, unapproved procedures, space and
interface requirements for the NRC site team, notifications of
&
emergency classifications and protective action recommendations
'
to offsite authorities, release of news information, and work space for media representatives.
Throughout the conduct of the inspections made during the
"
evaluation period, the NRC inspectors noted that the licensee i
provided satisfactory resolution to NRC findings and, in
]
general, made an effort to improve areas in excess of regulatory requirements.
2.
!
2.
Conclusions
,
The licensee has taken major steps to improve their program in
,
'
the resolution of the deficiencies identified by the NRC.
The
licensee has in place an emergency preparedness organization aimed at good performance, and the staff and resources being
,
utilized appear to be adequate.
The program is still undergoing
,
changes and improvements based on actual operating conditions.
,
I The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Board Recommendations
,
a.
Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program.
b.
Recommended Licensee Actions
,e
'
The current level of management attention should continue with emphasis being given to addressing NRC violations and
~
deficiencies and to modifying the program, as necessary, to incorporate operating experience.
y
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-,,-.,.._,----,-.-c-
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. _
.
-
'e
.
-22-G.
Security 1.
Analysis Five inspections were conducted by region based NRC physical security inspectors during the first 9 months of this assessment period when the plant was in the preoperational phase, and no violations or deviations were identified.
During the remainder of the assessment period, this area was inspected three times by region based inspectors and on a continuing basis by the resident inspector.
Five violations were identified:
Failure to provide proper escort.
.
85-67)
Failure to control badge / key cards.
.
85-67)
Failure to make timely notification of a reportable event
.
(Severity Level IV, 85-67)
Failure to properly control master keys.
( Severi ty
.
Level IV, 85-75)
.
Failure to meet security plan requirement (fence height).
(Severity Level IV, 86-03)
The licensee has demonstrated evidence of prior planning and assignment of priorities with regard to his security systems and security organization. The licensee has demonstrated a clear understanding of the issues and routinely shown conservatism in their decision making.
The licensee responds to NRC initiatives with technically sound and timely resolutions.
During the plant operating phase, reporting on safeguards events was late and/or incomplete about 50 percent of the time.
2.
Conclusion Licensee corporate and site management attention and security actions are strong and responsive to NRC initiatives.
Staffing is adequate and training is sufficient to overcome minor personnel errors which have resulted from delaying implementation of security practices until issuance of the plant operating license. The licensee's security program appears to have a strong foundation, but is experiencing start-up problems.
The safeguard event reporting system has not been timely during this assessment period.
No programmatic weaknesses were identified in the violations listed abov b.
..
-23-The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program.
b.
Recommended Licensee Actions The security program should receive increased internal auditing during the first year of commercial operations.
More attention should be directed at integration of the security organization with operations and maintenance activities. The safeguard event reporting system should be revised to ensure timely, complete reports.
H.
Outages 1.
Analysis Since issuance of the low power operating license on August 29, 1985, and during the startup test program conducted, there have been several mini-outages, both planned and unplanned.
The NRC resident inspectors have monitored these mini-outages including attending outage meetings, monitoring outage scheduling, monitoring outage personnel staffing, etc.
No violations of NRC regulations have been identified and no LERs have been issued in this functional area.
The licensee has shown a strong commitment to a well organized outage program.
During the mini-outages there was an assigned outage manager with outage directors on each shift. The licensee conducts at least two outage meetings each day and work is prioritized through an outage scheduling program. Additional operators are routinely added on shifts to aid with the control of outage work. The licensee intends to have a full-time outage manager assigned for future plant outages.
2.
Conclusion Specific inspections to assess outage performance were not performed. Although the licensee has shown a strong management commitment to a well organized outage program, the licensee was not assigned a performance category in this functional area.
.
.
s
.
-24-3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be maintained consistent with the basic inspection program and consistent with scheduled outages in order to broaden the data base for future evaluations of this area.
b.
Recommended Licensee Actions The licensee is encouraged to continue the apparent strong management commitment to a well organized outage program.
I.
Quality Programs and Administrative Controls Affecting Quality 1.
Analysis This area has been inspected on a continieng basis by the NRC resident inspectors and on several occas ons by NRC regional inspectors.
Specific areas inspected i'cluded procurement control, records, operations quality a'surance (QA) program, offsite storage of material and equir..ent, audits and surveillances, licensee management <( QA activities, preoperational testing QA, OA/QC administration, independent safety engineering group, safety committees, quality concern program, IE Bulletin followup, fitness for duty program, TMI action item followup, allegations review, startup test program QA, and licensee design control program.
Eight violations of NRC regulations were identified in this functional area as listed below:
Failure to Update Procedures after Issuance of Three
.
Temporary Change Notices.
(Severity Level IV, 85-66)
.
Change and Issuance of a Temporary Change Notice after Final Approval.
(Severity Level IV, 85-66)
Failure of Document Control Program.
.
85-69)
Incomplete Quality Data Package.
(Severity Level IV, 85-74)
Failure of Design Control Program.
.
85-77)
.
-
.
-25-Failure of Document Control Program.
(Severity Level V, 85-81)
Failure to Administratively Control Temporai, Circuit
.
Alterations.
(Severity Level IV,.86-04)
Failure to Schedule a Supplemental Audit / Surveillance.
.
(Severity Level IV, 86-04)
There were three LERs issued that were associated with quality programs and administrative controls affecting quality as listed below:
A standby liquid control system squib valve was determined
.
t' be incorrectly wired, which resulted in Division I being perable.
(85-10)
During testing, following modifications that installed
.
remote shutdown capability in the event of a control room fire, it was found that excessive control circuit voltage drops were created by long electrical cable runs.
Under degraded battery voltage conditions, the control circuit would not deliver the manufacturer's specified voltage.
~
,
(85-12)
'
An unauthorized electrical jumper was found in a main i
control room panel which would have inhibited a Division I reactor water cleanup system isolation.
(86-03)
i.
All three of these events were deemed to involve personnel and/or procedural errors.
,
This area may be viewed as the comprehensive management system for controlling the quality of work performed as well as the
,
verification of activities that confirm that work was performed
'
correctly.
It is important to note that this includes i
management actions to assure that adequate resources are
'
i provided in such areas as the administrative staff for revision and updating of procedures, document control, etc.
i While management involvement in assuring quality was evident in
,
this functional area, apparent weaknesses existed with the
'
occasional repetition of problems indicating a failure to
- correct the root cause of a problem, with the transfer of design control responsibility from the contractor to the licensee design control group, and with the failure to provide timely l
updating of procedures and drawings utilized in the control l
room. The enforcement history in this functional area reflected
_ - _ _
._ _
.. - ~..
..
__
.O
...
&
-26-the programmatic weaknesses in the areas of design document control, design control and administrative control of temporary circuit alterations.
This is not only evidenced by NRC findings, but also confirmed by followup reviews performed by the licensee QA organization. Because of the problems identified in the design control area, the licensee placed a i
hold on the performance of Category 1 (safety-related) design work by Nuclear Plant Engineering (NUPE).
'
While occasional significant operational events occurred which were attributable to causes under the licensee's control, events were reported in a timely manner and properly identified and analyzed. Certain events that occurred or problems that were j
identified potentially indicated more serious concerns and extensive corrective action was required in some instances.
In these cases, management attention was marshalled to effectively address all issues.
The QA audit program generally appeared to be effective in identifying problem areas and in effecting required corrective
,
actions.
However, a slight downward performance trend was noted at the end of the SALP period as evidenced by the failure to
-
schedule a supplemental audit in a problem area and by an apparent short-term manpower shortage in the audit group.
General plant staffing appeared to be adequate, although during peak workload periods, difficulties existed with work backlog i
and/or overtime. The difficulties with work backlog were
!
especially evident in the areas of incorporation of design changes, issuance of procedure revisions, etc.
This may have indicated a short-term weakness in staffing for administrative support.
2.
Conclusion t
,
While there were programmatic weaknesses evident in this functional area, the licensee has aggressively addressed the problem areas. The licensee's approach to the resolution of technical issues from a safety standpoint indicates a general understanding of issues, general conservatism, timely resolutions, and technically sound and thorough approaches. The
,
licensee's response to NRC initiatives is an area of strength as indicated by meeting deadlines, timely resolution of issues, technically sound and thorough responses, and by generally acceptable resolutions.
!
The licensee is considered to be in Performance Category 2 in this functional area.
.
.
-.
- -,. -.-, -.. -.-, -. -.
. -. - - -.
. -... - -. - -.
.---. -
.- -.
--
_-
-
-
-
. _ - _ _
- -.
.
.
-27-3.
Board Recommendations
'
a.
Recommended NRC Actions
The NRC inspection effort in this area should be maintained at a level consistent with the routine inspection program with special emphasis placed on licensee design control activities.
,
b.
Recommended Licensee Actions
-
The licensee should continue the aggressive approach to problem areas and should objectively evaluate the effectiveness of existing administrative control programs.
The licensee should factor lessons learned in the startup phase into improved operational programs. The hold on NUPE design control activities should be maintained until management is assured that the design control program is adequate and that it can be effectively implemented by the NUPE staff.
The licensee should also maintain vigilance over staffing shortages and take immediate staffing action as needed.
J.
Licensing Activities 1.
Analysis The NRC Office of Nuclear Reactor Regulation has performed an evaluation of licensee performance in the functional area of Licensing Activities.
The licensee has, in general, continued the high level of performance of the previous two SALP evaluations in the Licensing Activities area. There were a few exceptions to this
!
general high level of performance; specifically, continued last-minute changes in plant design, evidenced by two rather large FSAR amendments in the few weeks immediately preceding low power license issuance, complicated the staff's task to perform an integrated safety review of the plant design.
However, the
!
licensee's response to staff inquiries on the impact of these changes was responsive, comprehensive and technically sound in most instances.
t Overall, the licensee's strongest point is management. The
'
licensee proposed and the staff agreed (in part) to proposals to issue the low power operating license prior to completion of I
certain selected construction and test items. The staff was satisfied with the procedures implemented by the licensee to l
l'
l-l t
, -
~, -
.--,
-
-
- -. -
.
,,, - - -
o
.
-28-manage the list of construction and test completion items.
In fact, the NRC Commissioners recommended that the management practices employed at River Bend for managing work queues be considered for possible application to other plants. A weak point may be in the area of monitoring and implementing lessons learned from others in the instrumentation and control area.
2.
Conclusion Based on the assessment approach discussed in Attachment 1, the licensee's performance in the functional area of Licensing Activities is rated Category 2.
3.
Board Recommendations a.
Recommended NRC Actions The NRC should continue timely processing of licensing actions.
b.
Recommended Licensee Actions Licensee managenent should continue to be highly involved in licensing activities. They should concentrate on those items suggested for improvement in Attachment 1.
K.
Training and Qualification Effectiveness
,
1.
Analysis The NRC inspection effort in this functional area included review of operating staff training, startup and test personnel training, emergency preparedness training, chemistry /
radiochemistry personnel training, and radiological protection personnel training. Also, River Bend Station's initial set of cold operator licensing examinations were administered by the NRC in January 1985. Subsequent examinations were administered in liay and July of 1985. A total of forty-six candidates were examined, with 10 reactor operator licenses, 28 senior reactor operator licenses and 2 instructor certifications being issued.
Examinations were being prepared as of the end of this SALP evaluation period to reexamine 5 of the 6 candidates who failed to obtain licenses or instructor certifications from the July 1985 examination.
Two violations and one deviation of NRC regulations were identified in this functional area as listed below:
-_
.
.
.s.
-29-Failure to Provide Training for Health Physics Technicians.
.
(Severity Level IV, 85-73)
Failure to Maintain. Training Records.
.
85-73)
Failure to Provide BWR Technology Training to Health'
- .
Physics Technicians.
(Deviation,85-73)
- Also listed in Radiation Protection functional area.
There were no LERs issued that,were specifically linked to training and qualification effectiveness. However, several operational occurrences might have been prevented by a more effective training program. The analysis of these occurrences resulted in a general strengthening of the training program.
NRC personnel have toured the licensee training facilities on several occasions, and the facilities are considered excellent.
The training facilities include a plant-unique simulator, which has been used for plant operator and plant staff training throughout this SALP evaluation period.
It is apparent that the licensee has given training high priority as evidenced by the excellent training facilities and by the practice of assuring that key personnel from all areas are available for advanced training.
Based on specific observations and discussions with licensee management, it is apparent that the licensee has a program for factoring lessons learned into the training program. The licensee has also used the simulator to prepare for specific plant evolutions prior to performing those evolutions for the first time in the plant.
One weakness in this functional area was a lack of training effectiveness in the instrumentation and control area as evidenced by the occurrence of several personnel error-type events in this area. Discussions with licensee management revealed that'this area was one where personnel availability for training was limited because of the heavy workload in the instrumentation and control area during startup. The licensee took action to assure instrument and control personnel would not miss scheduled training without the prior concurrence of senior managemen.
-30-2.
Conclusion The licensee has provided excellent facilities and has demonstrated a strong commitment to quality training.
The licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be maintained at a level consistent with the routine inspection program, b.
Recommended Licensee Actions The licensee has given management attention to training for the instrumentation and control area. This emphasis and management. overview should continue. The licensee's overall training commitment is strong, but they should look at job-specific training needs for all employees.
L.
Preoperational Testing 1.
Analysis This area has been inspected on a continuing basis by the NRC resident inspectors and on numerous occasions by NRC regional
.
inspectors. This effort included a specific concentration of effort to complete required inspections and close out open issues prior to issuance of the low power operating license on August 29, 1985.
Specific areas inspected included preoperational test procedure review, preoperational test witnessing, preoperational test result evaluation, maintenance, test and measuring equipment calibration program, and allegation review.
Eleven violations of NRC regulations and two deviations
from commitments were identified in this functional area as
'
'
listed below:
Failure to Implement Procedures.
.
85-07)
.
Control of Temporary Alterations.
(Severity Level IV, 85-12)
,
Implementation of "Z Series E&DCR." (Severity Level IV,
.
l 85-20)
i i
i--
.
-.
-31-Failure to Follow Procedure - Time Delay Control Relay
.
Setpoint Verification Testing.
(Severity Level V, 85-20)
Failure to Follow Procedure - QA Hold Points.
(Severity
.
Level V, 85-23)
Failure to Monitor Temperature.
(Severity Level IV, 85-23)
.
Failure to Calibrate Gas Meter Used in Testing. (Severity
.
Level IV, 85-23)
Inadequate Test Procedure.
(Severity Level V, 85-31)
.
Control of Temporary Alterations.
.
85-42)
Failure to Adequately Review Preoperational Test Results.
.
(Severity Level IV, 85-44)
.
Improper Disposition of Nonconformance and Disposition Reports.
(Severity Level IV, 85-59)
Failure to Meet FSAR Commitment.
(Deviation,85-07)
.
Failure to Meet FSAR Commitment for Preoperational Testing.
.
(Deviation,85-51)
No LERs have been issued associated with this functional area.
Although the enforcement history indicated areas of weakness, numerous NRC inspections were conducted and the only major programmatic weakness identified was an especially weak testing program for the duct pressure and leakage testing of the heating, ventilation and air conditioning (HVAC) systems.
The findings identified in the HVAC testing area resulted in the licensee performing a 100 percent retest of the HVAC ventilation duct leakage testing.
2.
Conclusion While there were programmatic weaknesses evident in this
.
functional area, the licensee has aggressively addressed the l
problem areas.
Specific licensee areas of strength included the strong responsiveness to NRC initiatives and strong staffing with highly experienced personnel.
f The licensee is considered to be in Performance Category 2 in this functional area.
,
!
f
.'
. - _ _ _. _, - _ - _ _, _
- _ _ _ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _-- - __ __
s
-32-3.
Board Recommendations a.
Recommended NRC Actions Not applicable.
b.
Recommended Licensee Actions The licensee should factor lessons learned in the preoperational test program into the startup test program, maintenance retest programs and major outage programs.
M.
Startup Testing 1.
Analysis This area has been inspected on a continuing basis by the NRC resident inspectors and regional inspectors since receipt of the low power operating license on August 29, 1985.
Specific areas inspected included startup test program implementation, startup test procedure review, startup test witness, and startup test result evaluation.
One deviation from commitments was identified in this functional area.
.
Failure to Implement a FSAR Commitment in a Startup Test Procedure.
(85-81)
There were two LERs issued that were associated with startup testing as listed below:
The reactor protection system actuated on high source range
.
monitor counts when the initial fuel bundle was placed in the core.
(85-01)
.
A reactor core isolation cooling steam line isolation occurred while testing the main steam safety relief valves for a startup test.
(85-49)
Neither of the above two events were deemed to be caused by personnel or procedural problems. They were instead classified as the type of events that the startup test program should identify.
The sample review of startup test procedures indicated that the licensee's procedures implamented regulatory requirements and
"ommitments except for tne one deviation identified. The NRC
.
..
.
..
.
. _
..
.
-33-resident inspectors have witnessed the performance of several startup tests during this SALP evaluation period, including initial fuel loading, initial criticality, reactor core isolation cooling, relief and bypass valve capacity tests, loss of offsite power and core performance.
The test evolutions witnessed have been well coordinated arm controlled. There appeared to be good communication and coordination between startup test personnel and operations personnel. The licensee facility review committee was heavily involved with startup.
testing and provides approval prior to changing test conditicns.
Management involvement.in assuring quality was evident in this functional area. The licensee approach to the resolution of technical issues from a safety standpoint indicates a clear understanding of issues, routine conservatism, technically sound and thorough approaches, and timely resolutions. The responsiveness to NRC initiatives is excellent.
The enforcement history for this functional area does not indicate any programmatic breakdowns and corrective action is prompt and effective.
There were no apparent operational events that were attributable to causes under the license's control that occurred relevant to this functional area.
The general staffing in this functional area appears to be strong with well-defined positions, ample staffing, and high experience levels.
2.
Conclusion It appears that the experience gained in the preoperational test program has contributed to a strong startup test program at River Bend Station.
The licensee is considered to be in Performance Category 1 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be maintained at a level consistent with the routine inspection progra,
.-
-34-b.
Recommended Licensee Actions The licensee should continue the controlled and deliberate approach to startup testing, and apply this approach to normal plant operations and post-maintenance testing.
N.
Construction Completion 1.
Analysis
.
This area was inspected on several occasions by the NRC senior resident inspector for construction and by NRC regional inspectors.
The construction inspection program was closed and the low power operating license was issued on August 29, 1985.
Eighteen violations of NRC regulations and one deviation from commitments were identified in this functional area as listed below:
Document Control Surveillance.
(Severity Level V, 85-01)
.
Control of Nonconformances.
(Severity Level IV, 85-01)
.
Warehouse Controls.
(Severity Level IV, 85-02)
.
.
Records Storage. (Severity Level V, 85-02)
Construction Records.
(Severity Level V, 85-02)
.
.
Failure to Accurately Check Calculations.
(Severity Level IV,85-09)
Failure to Document and Verify Assumptions. (Severity
.
level IV, 85-09)
Failure to Provide Basis for Design Input.
(Severity Level
.
IV,85-09)
Failure to Provide Adequate Disposition of Construction
.
Deviation.
(Severity Level IV, 85-09)
Compliance with Welding Material Control Procedure
.
Requirements.
(Severity Level V, 85-10)
Independent Review of Design Change Calculations. (Severity
.
Level IV, 85-12)
.
Incorporation of E&DCR Information into Drawings.
(Severity Level IV, 85-19)
_,we,y M---*w-6--6r:-*c 6w*w r--~we-s----,--=
ra p
w>
e+wn-we-y-wm ym--
-
--w_e-,ui,m
.
-35-i
.
Use of External Historical Data in Evaluation of Suppliers.
(Severity Level IV, 85-19)
.
Posting of 10 CFR Part 21.
(Severity Level V, 85-21)
Failure to Assure Conformance of Safety-Related Structural
.
Steel Welds with Requirements.
(Severity Level IV, 85-29)
.
Failure to Document Changes to Inspection Report Results.
(Severity Level V, 85-33)
High Strength Steel Bolts Preload.
.
85-40)
Inspection Records.
(Severity Level IV, 85-40)
.
Safety-Related Display Instrumentation Ranges
.
(Deviation,85-18)
There were two LERs issued that were associated with construction completion as listed below:
A review of documentation revealed that 36 electrical junction boxes had not been sealed as required for environmental qualification of the contained electrical connections.
(85-33)
It was discovered that installation and erection of
.
supplemental support steel in piping tunnel,
"G" and "H" was not complete. This missing Category I structure affected the safety-related piping of tne standby service water system which was subsequently declared inoperable.
(85-34)
Both of these events were deemed to involve personnel and/or
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procedural errors.
The licensee identified 45 potentially reportable items per 10 CFR Part 50.55(e) during this assessment period. Of these, 20 were determined to be reportable and the remaining 25 were determined not to be reportable. All 45 of the potentially reportable items were reviewed by the NRC.
The construction inspections performed during this assessment period did not reveal any major programmatic breakdowns and the construction completion effort was controlled.
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Conclusion The licensee was not assigned a performance category in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions No additional NRC actions are required since the construction inspection program is complete.
b.
Recommended Licensee Actions The licensee should maintain a high level of management attention for any major maintenance or construction activities so that safety-related activities are not affected.
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V.
SUPPORTING DATA AND SUMMARIES
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A.
-Licensee Activities This SALP evaluation period covered several activity areas for the licensee..These included completion of construction, completion of operational preparations for the receipt of the low power operating license and the beginning of the startup testing program. Major.
milestones completed during this period included receipt of the low
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power operating license on August 29, 1985; beginning of fuel load on August 31, 1985; completion of fuel load on September 21, 1985; initial criticality on October 31, 1985; receipt of full power
operating license on November 20, 1985; and achievement of a reactor power level of 35 percent as of January 31, 1986.
The licensee also conducted an emergency drill involving onsite and offsite groups during January 1985.
B.
Inspection Activities Major NRC inspection activity during this assessment period included 84 NRC Region IV inspections performed with approximately 10,000 direct inspection manhours expended. These inspections included the followup inspections to the construction assessment team (CAT)
inspection, a special fire protection inspection, emergency preparedness drill evaluation and two special inspections of
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Technical Specifications and their implementing procedures. The NRC closed out the construction inspection program and the preoperational test inspection program during this assessment period.
Table 1 provides a tabulation of NRC enforcement activity for each.
functional area evaluated.
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Investigations and Allegations Review No major investigative activities were conducted during this SALP
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evaluation period.
D.
Escalated Enforcement Actions No escalated enforcement actions were taken by the NRC during this SALP evaluation period, and none are pending at the close of the assessment period.
E.
Licensee Conferences Held During Appraisal Period
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Although several management meetings between NRC management and licensee management were conducted during this SALP evaluation period, no official management conferences that dealt with regulatory performance or enforcemen+. were held.
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F.
Confirmation of Ac+ ion Letters
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No confirmation of action letters were issued by the NRC during this SALP evaluation period.
G.
Licensee Report Data
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1.
Licensee Event Reports There were 66 LERs issued during this SALP evaluation period.
Trends were noted in the following areas:
a.
Electrical jumper problems - a large number of events occurred due to misplaced jumpers, jumpers falling off, etc. The licensee addressed this issue by relocating jumpers and by installing " banana plugs" to prevent jumpers falling off. There was a definite reduction in jumper-related events after the licensee took corrective action in this area.
b.
Reactor water cleanup (RWCU) system isolations - a large number of RWCU system isolations occurred due to various operational / equipment problems.
The licensee is using a task force to review RWCU system design and operation for improvements.
c.
"RILEY" temperature switch problems - a large number of events occurred due to spurious trips occurring when
"RILEY" temperature switches were placed in the " READ" mode. The licensee took interim administrative action to V
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-38-require bypassing trips before going to the " READ" mode. A permanent design change to correct the problem had been implemented on most of the "RILEY" switch modules by the end of the period.
d.
Feedwater problems - some events occurred because of various feedwater operational and equipment problems. The licensee has assigned task forces to review all of the feedwater problems und to make necessary improvements.
The licensee also performed a baseline test of all Technical Specification surveillance tests during this SALP evaluation period and this contributed to the number of LERs issued.
2.
Licensee Identified Deficiency Reports The licensee identified 45 potentially reportable items per 10 CFR Part 50.55(e), during this assessment period. Of these, 20 were determined to be reportable and the remaining 25 were determined not to be reportable. The NRC has reviewed all 45 of the potentially reportable items. No particular trends were noted during this review.
3.
10 CFR Part 21 Reports No 10 CFR Part 21 reports were issued by the licensee during this SALP evaluation period.
H.
Licensing Activities See Attachments 1 and 2.
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1ABLE 1
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ENFORCEMENT ACTIVITY
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FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL AREA V
IV III II I
Deviations
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A.
Plant Operations 1/ 3 B.
Radiological Controls
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2*
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Maintenance
D.
Surveillance
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Fire Protection F.
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Security
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Outages I.
Quality Program and
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Administrative Controls Affecting Quality J.
Licensing Activities
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Training and Qualification 2*
Effectiveness
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Preoperational Testing
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Startup Testing
N.
Construction Completion 6,
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TOTAL
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43*
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3*
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- Two violations ind or.e deviation were deemed germane to both the radiological controls and the training functional areas.
Hence, the discrepancy between the sum of the violations / deviations and the total listed.
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ATTACHMENT 1 - Licensing Performance Analysis
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The.licens~ee's performance'for the Licensing -Activities functional area was based'on 'the staff's evaluation of the licensee's performa?ce in support of licensing actions which had'a.significant level of activity during the
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assessment period. These actions included preparation of four supplements to t the SER, low power licensing, meeting with the ACRS, presentations in support of the proposed full power license for the Commission, and operation of the plant during the startup testing program throughout half. of the rating period.
An extensive effort was required by the 1.taff and the licensee to support these actions during the rating period. Those actions which w'ere explicitly identified as completed licensing actions and reported in SER supplements are listed below (92 actions):
OUTSTANDING LICENSING ISSUES RESOLVED DURING SALP PERIOD 1.
Moderate-energy line break 2.
High-energy line break 3.
Inservice test program (including RCS pressure boundary valve leakage)
4.
Seismic and dynamic qualification of equipment 5.
Environmental qualification of equipment 6.
Preservice inspection program 7.
Containment loads 8.
ECCS~LOCA analysis (II.K.3.31)
9.
Bypassed 'and inoperable status 10.
Emergency diesel generators electrical loads 11. Qualification of TDI diesel generators 12. Auxiliary support systems 13. Submergence of electrical equipment 14. Heavy-loads handling system 15. Safe / alternate shutdowr 16. Communications systems 17. Lighting systems 18. HPCS diesel generator 19. Fuel oil storage 20.
Separation of electric circuits 21. Safety parameter display system 22.- Control room survey 23. Resolution of HEDs 24. Standby service water system 25. Standby liquid control system 26. Low-pressure interface leakage 27. Equipment and floor drains 28. ' Control building ventilation 29. Miscellaneous HVAC systems 30. Starting voltage for Class 1E motors 31. Hydrogen control - degraded core accident
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-2-CONFIRMATORY LICENSING ISSUES RESOLVED DURING SALP PERIOD 1.
West Creek sediment removal
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Slope stability 3.
Pipe failure modes and check valve stress analysis 4.
Annulus pressurization 5.-
Thermal and anchor displacement loads 6.
Fuel rod mechanical fracturing 7.
Fuel assembly structural damage 8. -
LOCTVS/ CONTEMPT-LT 28 computer codes 9.
Reactor vessel cooldown rate 10. SRV discharge testing 11. Mark III-rated issues 12. Containment repressurization 13. Containment purge valves 14. PVLCS leakage 15.
Electrical and instrumentation and control diagrams 16. Routing of circuits and sensors 17.
Instrumentation setpoints 18. RPS power supply protection 19. RPS and ESF channel separation 20.
Isolation devices 21. Reactor mode switch 22. ADS actuation 23. ESF reset controls 24.
Initiation of ESF support systems 25.
Instrumentation of ESF support systems 26. RCIC system 27. Standby liquid control system (SLCS)
28. Postaccident monitoring instrumentation 29. Temperature effects on level measurements 30. High/ low pressure interlocks 31.
End of cycle recirculation pump trip 32. NMS and RCIS isolation 33. Rod pattern control system 34. DRMS 35. High-energy line break control system failures 36. Multiple control system failures 37. Emergency Response Information System (ERIS)
38. LPCS/RHR A pump procedures 39.
EPA /RPS motor generator set interconnection 40. Second level undervoltage protection relay setpoint 41. Safety cable identification
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43.
Postaccident sampling system 44. Diesel generators - mechanical issues l
45. TMI Item II.F.1, Attachment 2 46. TMI Item II.B.2 47. Backup RPM designate 48. THI Item I.C.1
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-3-CONFIRMATORY LICENSING ISSUES RESOLVED DURING SALP PERIOD (con't.)
49.
Initial test program revisions 50. Proper ESF function (11.K.1.5)
51. Ultimate heat sink with delayed fan start 52. Participation of human factors specialists in detailed control room design review 53. Task analysis documentation 54. Control room modifications 55. Containment venting procedures 56. Monitoring instruments for HPCS 125-V ac system 57. - Protection for lighting penetration circuits 58. Process Control Program 59. Subcompartment pressure analysis 60. Cable derating 61. Equipment qualification - audit A.
Management Involvement and Control in Assuring Quality The licensee's management participated directly in almost all of the major licensing activities addressed in this report. Notable examples of the contributions that resulted from this management involvement are sumarized below:
The Senior Vice President - River Bend Nuclear Group and the plant manager were directly involved in the headquarters management review of the status on construction and test completion (March 26,1985),
and the site visit by the Director, NRR and staff on readiness for licensing (May 13-14,1985).
The Commissioners comended Gulf States Utilities (GSU) for its innovative practices for managing the queue of remaining construction activities during the latter stages of licensing and early stages of low power startup.
Furthermore, the NRC Commissioners comended GSU for its communica-
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tions with the Commissioners, themselves, over their accelerated
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approach to completion of licensing.
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In January 1986, the staff had some concerns over the number of reportable events, scrams and LERs during the River Bend startup.
The staff was impressed with the innovative programs instituted by GSU to prioritize activities and focus resources on problem areas.
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In particular, the staff was impressed with direct senior management
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(vice presidential level) involvement in these problem area
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renediation activities.
Furthermore, GSU has displayed a corporate commitment to resolution of issues through participation in various licensee review groups and owners
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groups. ' The staff views this approach as indicative of a positive atti-tude towards management involvement and control in licensing activities.
In a'few instances, notably outstanding licensing issue Nos. 4, 5, and 10,-the staff raised concerns to GSU senior management over delays in resolution. GSU senior management became directly involved and mutually satisfactory resolutions of these issues were developed and implemented.
Based on the above detailed observations, GSU is rated Category 1 for this attribute.
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B.
Approach to Resolution of Technical Issues From a Safety Standpoint Responses to NRC inquiries by GSU have been generally viable with
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technically sound, conservative and thorough approaches in almost all cases. The applicant has demonstrated a clear understanding of most
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technical issues involved in many review areas including containment systems, power systems, and instrumentation and control. GSU was willing to perform additional studies, as necessary, to resolve technical issues.
However, in several areas, particularly outstanding licensing issue Nos. 3, 4, 15 and 31, the staff questioned the licensee's lack of understanding of the technical issues involved or the depth of their technical responses.
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While GSU is aggressive in resolving many safety issues, the staff feels that the utility has relied excessively on its architect-engineer for technical responses. Additionally, the staff is of the opinion that GSU tends to be more concerned in many instances with cost rather than taking
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the more conservative approaches to issue resolution.
On the basis of the above observations, GSU is rated Category 2 in this a rea.
C.
Responsiveness to NRC Initiatives GSU proposed an accelerated licensing schedule, which involved the resolution of a large number of open licensing items during the latter phases of licensing. This accelerated licensing schedule was complicated by GSU's desire for a low power license while several construction and test items remained to be completed.
Given the potential complexities of the " tight" review schedule, GSU performed very well indeed.
GSU demonstrated an aggressive attitude in the resolution of many issues, requesting conference calls and meetings which were promptly followed up with submittals or responses. Responses were generally technically sound and addressed staff concerns. However, several'submittals, particularly those for outstanding items 4, 5, 6 and 31, either required frequent slippages in schedules or were late.
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-5-Of particular concern was the submission of voluminous last-minute amend-ments to TSe FSAR in the weeks preceding the low power licensing. While most of these FSAR amendments reflected previous docketed comitments, there was sufficient new material in these to complicate the staff's tight review schedule.
On the basis of these observations, considering the compressed licensing schedule, a rating of Category 2 is appropriate for this area.
D.
Enforcement History No basis for rating in this area.
E.
Staffing The comments in this area are based on the project manager's observations during the rating period.
Positions within GSU's organization are identified and authorities and responsibilities well defined. GSU licensing and engineering groups appear to be well staffed as indicated by representatives present at review meetings and site groups. During licensing, GSU consistently had staff available to discuss review items.
NRR's principal involvement with staffing issues during the review period involved the issues of engineering expertise on shift. On this topic, the licensee was faced by a change in Comission policy during the period between low power and full power licensing. Licensee management and the staff negotiated a phased resolution on shift staffing which was accept-able to the Commissioners.
Accordingly, the staffing attribute at River Bend Station is rated Category 1.
F.
Reporting and Analysis of Reportable Events GSU received its low power operating license for the River Bend Station on August 29, 1985, and their full power operating license on November 20, 1985. This evaluation covers the low power license period and full power license period through January 31, 1986.
During this 5-month period, the licensee reported 95 nonsecurity events.
Approximately 10 percent of these events do not appear to be reportable. Approximately one half of the events are associated with isolation of the Reactor Water Cleanup System or Residual Heat Removal System due to personnel error or leakage detection system temperature switch module malfunctions. Corrective measures instituted by the licensee reduced the number of events con-siderably during the month of January.
None of the reported events were considered individually significant enough to warrant detailed staff followup. The above average number of events overall, however, prompted staff attention and a site visit January 28-30,
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i to discuss RBS operating experience. The events that were most safety significant were the loss of offsite power, feedwater system problems, and
valve operator bolting inadequacies (may be generic). Operator errors in general, including the RHR isolations, are also a concern. The number of I
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such events appears' to be decreasing, based on a review of the' January reports.
RBS experienced seven reactor scrams during the evaluation period.
This number is not abnormal for a new plant, but is higher than the average frequency of 5.9 scrams / plant / year. All equipment operated normally
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-following each scram.
The majority of the events appear to have been reported promptly and
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accurately.
Based on these evaluations of reportable events, and the reactor scram
experience, we recommend a rating of Category 3 for the licensee's performance in frequency, reporting, and analysis of reportable events.
G.
Training and Qualification Effectiveness No basis for rating in this area.
t H.
Housekeeping During the rating period the licensee was completing an accelerated
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construction program. Based on the observations of the project manager
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during four site visits during this period, the licensee made great j
strides in cleaning up the plant prior to the commencement of fuel loading and has maintained a satisfactory level of cleanliness since that time.
(Insufficient basis for rating in this category.)
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ATTACHMENT 2 - Licensing Supporting Data and Summary 1.
NRR/ Licensee Meetings (for low power license)
Discuss River Bend Station (RBS) Technical January 29, 1985
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Specifications Discuss findings of Equipment Qualification Audit January _31,1985
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Team February 14, 1985 - Brief incoming Director of DL on status of RBS February 25, 1985 - Review security plan implementation at RBS February 20-21, 1985 - Review documentation and hardware for standby Emergency Diesel Generators at RBS February 27-28, 1985 - Review Power Systems implementation items at RBS 11 arch 8,1985 - Technical Specifications for RBS March 14, 1985 - Technical Specifications for RBS March 26, 1985 - Management Review April 3,1985 - Diesel Generators for RBS April 4, 1985 - Technical Specifications for RBS April 24, 1985 - Technical Specifications and Diesel Generators for RBS April 26,1985 - Diesel Generators for RBS May 10, 1985
- Discussion on possible GSU initiative to lessen emergency electrical loads on TDI diesel generators May 13, 1985
- Management discussion of the status of RBS readiness July 2, 1985
- Discussion of the impact of FSAR Amendment #20 on the SER July 12, 1985 - One time exception to Technical Specifications to allow use of drywell purge and vent system during modes 2 and 3 July 22, 1985 - One-time exception to Technical Specifications to allow use of drywell purge and vent system during modes 2 and 3 July 31, 1985 - Staff comments on hydrogen control-degraded core for RBS 2.
Commission Briefings November 15, 1985, Consideration of Issuance of Full Power License 3.
Schedular Extensions Granted a)
Low Power License Conditions (NPF-40, Issued 8/29/85)
1.
Turbine systems maintenance program - submit by October 26, 1987 2.
Seismic and dynamic qualification of seismic Category 1 oechanical and electrical equipment:
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- modify hydraulic control units by May_15, 1986 - seismic qualification of the in-vessel racks prior to use.
3.
Equipment qualification (environmental) - by November 30, 1985.
4.
Mark III containment issues - prior to startup following first refueling outage.
5.
Inservice Inspection Program - submit for review and approval by August 29, 1986.
6.
Bypassed and inoperable status indication - implement system modifications prior to startup tfollowing first refueling outage.
7.
TDI' diesel engines - final approval of staff of the overall design review and quality revalidation program prior to operation beyond the first refueling outage.
8.
TDI diesel engines - reduce maximum emergency service load prior to exceeding 5 percent rated power.
9.
Ultimate heat sink - acceptable temperature monitoring system prior to startup following first refueling outage.
10. Operating staff experience - training of advisors and shift crew prior to achieving criticality.
11. Testing of the off gas system and off gas vault refrigeration system - prior to installing the reactor head.
12. Fire protection system - complete modifications prior to exceeding 5 percent rated power.
13. Radwaste systems - complete testing and place into service prior to exceeding 5 percent rated power.
14. Suppression pool valves - complete modifications prior to exceeding 5 percent rated power.
15.
Post-accident sampling system - complete modifications prior
to exceeding 5 percent rated power.
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16. Station electric distribution voltage analyses - verify prior to completion of initial test program.
17. Emergency lighting system - complete modifications prior to completion of initial test program.
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O-3-18. Fuel building sampling system - operational prior to the first refueling outage.
20. Safety Parameter Display System - installed and operacional prior to March 31, 1986.
21.
Emergency procedure guidelines for containment venting -
submit, review and approved prior to exceeding 5 percent rated power.
22.
Instrumentation - specified instruments must be modified consistent with Reg. Guide 1.97 prior to start up following the first refueling outage.
b)
Full Power License Conditions (NPF-47, issued November 20,1985).
All stated above except:
1 - replaced by FSAR commitment 3 - completed 8 - completed 10 - completed 12 - completed 13 - completed 14 - completed 15 - completed 19 - completed 20 - replaced by FSAR commitment 21 - completed 4.
Exemptions Granted d) low Power License -
From GDC-2 for qualification of air operated valves in suppression pool pump back systen.
(SSER3)
b) Full Power License None 5.
License Amendments Issued One request for an amendment of the low power license Technical Specifications was received during the rating period and granted on an emergency basis (see item 6 below).
No request for amendments of the full power license Technical Specifications were received during the rating perio.
e-4-The following activities relevant to the issuance of a low power license occurred:
August 1985, SER Supplement No. 2 August 1985, SER Supplement No. 3 August 29, 1985, Low Power Operation License (NPF-40) issued.
The following activities relevant to the issuance of a full power license occurred:
September 1985, SER Supplement No. 4 September 11, 1985, ACRS Sutcomittee meeting September 1?,1985, ACRS meeting November 1985, SER Supplement No. 5 November 15, 1985, Comission meeting on full power license fiovember 20, 1985, Full Power License (NPF-47) issued.
6.
Emergency Technical Specification Changes Granted September 25, 1985; to revise Technical Specifications on transient generator voltage following a full load rejection by HPCS.
7.
Orders Issued None 8.
fiRR/ Licensee Management Conference March 26, 1985 - Briefing for
e Director, NRR and staff by the appli-cant, GSU. on the overall status of construction and test completion.
May 13-14, 1985 - Site visit by the Director, NRR and staff to evaluate readiness for operating license.
Jan. 28-30, 1986 - Site visit by staff of NRR, IE and Region IV to review startup program.