IR 05000458/1986024

Insp Rept 50-458/86-24 on 860818-22.Deviation Noted:Failure to Verify Certain Abnormal Operating Procedures

ML20215L025
Person / Time
Site:	River Bend
Issue date:	10/21/1986
From:	Bennett W, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215L014	List: IR 05000458/1986024 ML20215L011 ML20215L017
References
50-458-86-24, NUDOCS 8610280432
Download: ML20215L025 (4)

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. 'o APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-458/86-24 License: NPF-47 Docket: 50-458 Licensee: Gulf States Utilities P. O. Box 220 St. Francisville, Louisiana 70775 Facility Name: River Bend Station (RBS)

Inspection At: River Bend Site, St. Francisville, Louisiana Inspection Conducted: August 18-22, 1986 Inspector: [

W. R. Bennett, Project Engineer, Project IMad/P4 Date Section A, Reactor Projects Branch Accompanying Personnel: J. Bongarra, Nuclear Reactor Regulation L. B. Myers, Consultant G. A. Sly, Consultant Approved: ,. - 64 //V\ fo 1/ M J.7.Jafdon,C f, Projecb Section'A, Dhtyr 'I bactoe Proj ts Branch Inspection Summary Inspection Conducted August 18-22, 1986 (Report 50-458/86-24)

Areas Inspected: Routine, unannounced inspection of emergency operating procedure Results: Within the one area inspected, one deviation was identified (failure to verify and validate certain abnormal operating procedures, paragraph 2).

8610280432 861023 PDR ADOCK 05000458 o PDR

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-2-DETAILS Persons Contacted Principal Licensee Employees D. L. Andrews, Director, Nuclear Training

• J. Cahill, Senior Vice President, River Bend Nuclear Group

• T. C. Crouse, Quality Assurance (QA) Manager

• W. Frayer, Supervisor, Projects

• O. Fredieu, Assistant Operations Supervisor D. R. Gipson, Assistant Plant Manager, Operations

• E. R. Grant, Director of Licensing

• 0. Imlay, Operations Foreman

• J. Normand, Supervisor, Administrative Services

• H. Odell, Manager, Administration

• H. Peters, Instructor

• R. Smith, Licensing Engineer

• J. E. Spivey, QA Engineer

• F. Tomlinson, Director, Quality Services D. Williamson, Operations Supervisor The NRC inspector also contacted other site personnel including administrative, operations, and training personne * Denotes those attending the exit interview conducted on August 22, 198 . Emergency Operating Procedures (EOPs)

The purpose of this inspection was to determine whether E0Ps are prepared in accordance with the NRC-approved Procedures Generation Package (PGP)

and are adequate to control safety-related functions in the event of system or component malfunctio The NRC inspector reviewed the following procedures:

Procedure Title Revision Date E0P-0001 Emergency Procedure-F.PV Control 6 8/18/86 E0P-0002 Emergency Procedure-Primary Containment Lontrol 5 8/18/86

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E0P-0003 Emergency Procedure-Secondary Containment 5 7/10/86 Control E0P-0005 Emergency Procedure-RPV Flooding 3 7/10/86 A0P-0021 Anticipated Transient Without Scram 0 4/18/85

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The procedures were reviewed for conformity with the writer's guide i (OSP-0009, " Authors Guide / Control and Use of Emergency Operating

- Procedures," Revision 1, dated May 3,1985), for conformity with the generic technical guidelines, and for useability and technical accurac Utilizing this review and a partial walkthrough of the procedures, the NRC inspector determined that the procedures performed all steps required by the generic technical guidelines and were written in accordance with OSP-0009. The NRC inspector provided several comments concerning the procedures to the licensee. These comments included:

Action statements were included in caution notes;

Precautions in the generic technical guidelines which should be included in the E0Ps;

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Jumper locations should be better marked; and E0P-0002 referred to a level of 1.25 feet and then referenced a graph

in the procedure which was labeled as 19-20 feet. The .25 feet is as read on a gauge which has a reference level of 19 feet 8 inche The licensee stated that the comments would be reviewed for incorporation in the next procedure revisio The NRC inspector also commented that the level restoration contingency of the generic guidelines had been incorporated into E0P-0001 without-vendor approval. The licensee consitted to have the vendor review the incorporation of the level restoration contingency into E0P-0001 to ensure the intent of the generic technical guidelines was me The NRC inspector noted that portions of the generic technical guidelines were incorporated into abnormal operation procedures (A0Ps) vice E0P ~

Discussions with licensee personnel disclosed that these A0Ps did not '

undergo the same validation and verification as the E0Ps. The licensee in letter number RBG 15,815, dated August 31, 1982,.[ sic] to.the NRC,.

committed to convert the generic techr.ical guidelines into E0Ps and-in

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letter number RBG 13,137, dated February 27, 1984, to the NRC, committed to verifying and validating all E0Ps in accordance with River Bend Procedure OSP-0008, " Verification and Validation of Emergency Operating Procedures." This failure to verify and validate A0P-20, -21, and -22, is considered a deviation (458/8624-01) of commitments made to the NRC.

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The NRC inspector observed a simulator exercise where the operators were

' required to use various E0Ps and A0Ps. All operators tock prompt and proper corrective actions. The control operating foreman was properly appraised of the situation and of all actions taken. The operators

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perforned in a proper and professional manner. Transition from one procedure to another was observed by the NRC inspector to be a problem area. This was evident during entry into and exit from different

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a *e e-4-paragraphs of E0P-0001 and A0P-0021. Due to these transition problems, it was unclear whether an emergency depressurization should be performed during an ATWS condition and potential existed for going to a cold shutdown condition prior to reactor vessel level being stabilized. This problem with transition between procedures is considered an open item (458/8624-02) and will be reviewed by an NRC inspector during a subsequent inspectio The NRC inspector requested information confirming that the condensate pump would inject into the plant at 600 psig as specified in E0P-000 This information was not provided to the NRC inspector by the completion of this inspectio The ability of the condensate pump to inject into the plant as specified in E0P-0001 is considered an unresolved item (458/8624-03) pending the provision of data to the NRC by the 4 licensee confirming injection by the condensate pump at 600 psi No other violations or deviations were identified in this inspectio . Unresolved Item An unresolved item is one about which additional information is required in order to determine if it is acceptable, a deviation, or a violatio There is one unresolved item in this repor Paragraph Item N Subject 2 8624-03 Use of condensate pumps for reactor vessel injection j Exit Interview

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An exit interview was held on August 22, 1986, with the personnel denoted in paragraph 1 of this report. The NRC resident inspector also attended this meeting. At this meeting, the scope of the inspection and the

, findings were summarized.

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