IR 05000458/1988018

Insp Rept 50-458/88-18 on 880808-12.Violations Noted.Major Areas Inspected:Surveillance Procedures & Records

ML20153E405
Person / Time
Site:	River Bend
Issue date:	08/30/1988
From:	Bundy H, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153E368	List: IR 05000458/1988018 ML20153E362 ML20153E374 ML20153E405
References
50-458-88-18, NUDOCS 8809060316
Preceding documents:	ML20195D825 (28 October 1988)
Download: ML20153E405 (8)

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l APPENDIX B

, U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report: 50-458/88-18 Operating License: NPF-47 Docket: 50-458 Licensee: Gulf States Utilities (GSU)

P.O. Box 220 St. Francisville, Louisiana 70775 Facility Name: River Bend Station (RBS)

Inspection At: RBS, St. Francisville, Louisiana Inspection Conducted: August 8-12, 1988 J

Inspector: *

b fMf//7 Date H.F.Bungf,ivisionofBeactorSafetyReactorInfpector,TestPrograms Section, D Accompanying Personnel: R. V. Azua, Reactor Inspector, Test Programs Section, Division of Reactor Safety Approved: /be// A W. C. Seidl Chief, Test Programs Section Date ;

Division of eactor Safety i

Inspection Summary Inspection Conducted August 8-12, 1988 (Report 50-458/88-18)

Areas Inspected: Routine, unannounced inspection of surveillance procedures I and record I Results: The surveillance testing program appears functional. The surveillance testing procedures (STPs) are generally adequate; however, some

1. ta sheets could be improved and betcer cross-referencing to the applicable gDRsO9060316 esopoi g ADOCK 0500o433 PDC

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> Technical Specifications should be made. There appeared to be an excessive

number of changes and test exceptions on completed STPs, particularly in the .'

instrumentation and control area. This suggested that the procedure verification process could be icproved. One violation involving failure to properly evaluate and document surveillance test results was identified (paragraph 2).

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DETAILS 1, Persons Contacted GSU

• J. E. Booker, Manager, RBS Oversight

• T. F. Plunkett, Plant Manager, RBS

• P. D. Graham, Assistant Plant Manager, Operations

• J. Hamilton, Director, Design Engineering

"L. England, Director, Nuclear Licensing

• H. F. Sankovich, Manager, Engineering Department

• 0. R. Derbonne, Assistant Plant Manager, Maintenance

• J. Huff, Supervisor, Operational Planning A. Frediem Operations Supervisor

• R. J. King, Supervisor, Nuclear Licensing T. Murphy, Supervisor, Planning and Scheduling D. Jernigan, Supervisor, Instrumentation and Control D. B. Reynolds, Supervisor, Administrative Support J. Venable, Assistant Operations Supervisor

• J. H. McQuirter, Licensing Engineer, Nuclear Licensing

• C. L. Miller, Senior Compliance Analyst

• K. F. Kennedy, Coordinator, Plant Permanent File

• C. W. Walling, Senior Mechanical Engineer, Field Engineering

• J. E. Spivey, Senior Quality Assurance (QA) Engineer J. D. Davis, Senior QA Engineer NRC

• J. Ford, Senior Resident Inspector W. B. Jones, Resident Inspector Others

• L. Curran, Site Representative, Cajun Electric Cooperative The NRC inspectors also interviewed other licensee employees during the course of the inspectio * Denotes those present during the exit interview held on August 12, 198 . Surveillance Procedures ar.d Records (61700)

The purpose of this inspection was to ascertain whether the surveillance of safety-related systems and components was being conducted in accordance with approved procedures as required by the Technical Specifications (TS).

Pursuant to this objective, the NRC inspectors reviewed the following licensee documents:

o Administrative Procedure (ADM)-0015, Revision 12. "Station Surveillance Test Program"

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o RBS TS Surveillance Test Procedure (STP) Cross Reference Matrix dated January 21, 1988 o Surveillance Test Scheduling and TrackinJ Systre Schedule Log from August 7-28, 1988  ;

I o Missing Surveillance Resulting in Licensee Event Report (LER) dated March 11, 1988 l

The RBS supervisor of operational planning dencribed the following vehicles for followup on TS surveillance test deficiencies:

o Formal review of a limiting condition for operation report on Mondt15, Wednesdays, and Fridays o Twice per-day meetings to review overdue TS required surveillance tests The NRC inspectors then selected certain TS surveilvance requirements and i reviewed the associated licensee STPs and an appropriate number of test I results records for each procedure. Also selected test personnel were verified to have appropriate certification. The TS surveillance requirements, together with the associated STPs reviewed by the NRC inspectors, are tabulated in the Attachment, i The NRC inspectors determined that the required tests were being scheduled and performed as required in accordance with approved procedure Acceptance criteria were specified in the nroc6dures and, with the exception discussed below, the records stated satisfaction of acceptance I criteria. Appropriate instructions for returning equipment to service l following testing were given. With the exceptions discussed below, there was evidence that surveillance tests were being properly etaluated and i documente l The following observations were made by the NRC inspectors:

o The STP data sheets should be more explicit on data requirements in '

some instances. For example, in completing STP-000-0201, Datt !

Sheet 1 most of the performers were writing their initials in the j column entitled POSITIO However, one performer wrote in the l observed valve positions. Insertion of both valve positions and initials would have been appropriate, o There appeared to be an exce*,sive number of test change notices (TCNs)

and test exceptions on completed STPs, particularly in the instrumentation and control area. For some STPs, almost every page was affected. This frequently made it difficult to interpret data. It appeared that many of these TCNs and test exceptions could have been avoided with a better procedure verification proces . .__

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o The STPs did not always properly reference the TS to which they were i responsive. For example, STP-203-0602 indicated satisfaction of TS 4.5.1.d. However, the cross reference matrix also required

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completion of STP-309-0603 to satisfy TS 4.5.1.d. The cross i reference matrix required completion of STP-309-0603 for satisfaction d

of TS 4.7.1.1.b. However, TS 4.7.1.1.b is not mentioned in STP-309-0603. In each instance, the cross reference matrix was verified correct. In most instances, Section 8, "Acceptance .

Criteria," of the STP did not reference the TS which were satisfie '

o As a result of most TCNs, several pages were added to most l procedures. The added pages were usually placed after that page to which the changes were being made. These added pages were given the same number, but with a suffix such as la, Ib, and so on. The NRC inspectors noticed that even though these pages were added, the pagination for the overall document was usually not changed to L accommodite them. This led to a situation where there were more

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pages in a document than were listed in the page count total. This pagination method could allow missing pages to go undetected and lead to situations where incomplete documents are filed or are sent for review with critical data missin .

i The following STP deficiencies identified by the NRC inspectors are i

examples of an apparent violation of 10 CFR 50, Appendix B, Criterion XI, l "Test Control," which states, in part, ". . . Test results shall be ,

I documented and evaluated to assure that test requirements have been '

satisfied." (458/8818-01)

! In reviewing STP-051-4210. "RPS/RHR Reactor Vessel Steam Dome ,

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i Pressure-High," which was performed and completed on October 13,

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1987, the NPC inspection noted that page 24 lacked initials for each j line ites. It was also noted that the page was stamped with the date

"March 8, 1988" which was 5 months after the test was performed. The 1 NRC inspectors inquired about this and were told by personnel at

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Permanent Plant Files (PPF) that when they originally received the I document, it was noted that the page was missing. The whole document .

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was returned to the sender. Attached to the document was a "Request !

i for Correction" which stated that page 24 was missing. The clerk I i that received the document apparently did not attempt to locate the i

original test page, but instead, replaced the missing page with a blank copy and stamped it with the date on which it was sent back to PP This is the test package that was finally placed in the PP '

Due to the absence of page 24, it was not possible to ascertain that

the test results had been properly documented in accordance with l

Criterion XI. The preliminary response by the licensee included the <

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(1) STP-051-4210 was reexamined to determine that the steps listed

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in the missing page did not have safety significance which would 1 have required reperformance of the test.

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(2) The Assistant Plant Manager for Maintenance generated interoffice memorandum APM-M-88-29 The Memorandum called on all personnel to return documents, which have missing pages, to the appropriate discipline superviso The supervisor will evaluate the significance of the missing data to determine if it is required to indicate successful completion of the work. If the missing page is found to have significant results, the supervisor will initiate immediate actions to reperforn the work, Test exceptions were written for performance of Sections 7.3.4 and 7.5.4 of STP-403-0601, "Standby Gas Treatment System Annulus Mixing System Functional Tests." This STP was completed on December 18, 1987. Completion of these sections was required by Acceptance Criterion 8.4 of STP-403-0601. Writing test exceptions on an acceptance criterion resulted in noncompliance with Criterion XI implementing documents as follows:

o Section 8.3.1 of ADM-0015 prohibits writing a test exception on ,

an acceptance criterio o Failure to revise STP-403-0601 in accordance with ADM-0015 constituted failure to initiate appropriate corrective action in accordance with Section 17.2.11. "Test Control," of the RBS Updated Safety Analysis Repor o The adequacy of the system to meet the specified requirements in the acceptance criteria was not revealed by the recorded data as required by Quality Assurance Directive-1 i A preliminary review of this test package by the licensee indicated that none of the required responses excepted were safety significan The data and calculation for the average stroke rate of i Valve 1833-HYVF0 GOB timed in Step 7.4.12 of STP-053-0601, "Recirc Flow Control Valve Operability Test," was not included in the data j package completed on October 24, 1987, as required by Criterion XI  :

and Implementing Document ADM-0015 Section ;

No further violations or deviations were identifie . Exit Interview The NRC inspectors conducted an exit interview on August 12, 1988, with the licensee personnel denoted in paragraph 1. At this meeting, the scope l and findings of the inspection were summarized. The licensee did not j identify as proprietary any of the materials provided to, or reviewed by, i the NRC inspectors during the inspectio !

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i ATTACHMENT PROCEDURES AND RECORDS REVIEWED ,

TS Description STP-Number 4.1.3.11b Verify scram discharge volume drain 052-3301, R2 and vent valves operable by cycling 4.2.la Daily verification that APLHGR is 000-0001, R9 2 limits  :

4.3.1.1, Channel calibration for reactor vessel 051-4209,' R4 '

Table 4.3.1.1-1 steam dome pressure-high 051-4210, R4 Item 3 051-4211, R6 051 4212, R5 4.3. Isolation Actuation Logic System 051-4253, R7 ,

Functional Test 051-4250, R5 -

051-4249, R5 051-4248, R6 051-4247, R6 051-4235, R6 051-4234, R7 '

051-4233, R6 051-4232, R8 051-4227, R6 051-4226, R9

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051-4225, R6 .

051-4223, R6 !

051-4224, R6 !

051-4254, R7 !

051-4222, R7 4.4.1.lb Verify rate of opening or closing for 053-0601, R2 recirculation loop flow control valve is 2 11 percent per second  ;

4.4. Determine jet pumps are operable 053-3001, R3 l 4.5.1d For HPCS, verifv suction is automati- 203-0602, R2 cally transferred from condensate 309-0603, R7 storage tank to suppression pool under specified conditions I 4.5.1 e 2 Manually open ea:h A05 valve with steam 202-06202, R4 pressure 5100 psig and verify proper responses

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4.6.1.lb Verify closure of primary containment 000-0201, RIO penetrations at least once per 31 days

4.6.3.2c Perform system functional test for 309-0601, R6 primary containment unit coolers 309-0602, R4 4.6.5.5b Verify each shield building annulus 403-0601, R3 mixing systeA operable by performing system functional test 4.7.1.lb Verify standby service water system 309-0601, R6 subsystems operable by verifying each 309-0602, R4 automatic valve actuates to correct 309-0603, R7 position and each pump starts on low pressure -

4.7.3c Verify RCIC system operable by performing 209-0601, R2 system functional test 4.7.6. Cycle each testable valve in the fire 251-3502, R4 ,

. suppression water system through at l 1 east one complete cycle of full travel

4.7.6.5c Perform inspection of yard fire hydrants 251-3501, R3

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and hydro associated hoses '

l i 4.8.1.1.2.f.7 Verify that, upon an ECCS actuation 309-0601, R6 i signal, all automatic diesel generator 309-0602, R4

trips are auto bypassed except engine 309-0603, R7 i

) overspeed and generator differential (

) current  ;

i 1 4.8.2.lc Verify for each 125V battery and charger: 203-1602, R3

! No visual battery damage 305-1600, R3 ; Cell-to-cell and terminal connections

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1 305-1601, R2

are clean and tight -6 203-1605, R4

) Terminal resistance 5150 X 10 ohm 305-1603, R3 1 j Battery chargers will supply minimum 305-1604, R3 !

current

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