IR 05000458/1989027

Insp Rept 50-458/89-27 on 890605-09 & 19-23.Violations Noted.Major Areas Inspected:Self Assessment Capabilities

ML20247K025
Person / Time
Site:	River Bend
Issue date:	07/12/1989
From:	Barnes I, Kelley D, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247J983	List: IR 05000458/1989027 ML20247J980 ML20247K011
References
50-458-89-27, NUDOCS 8907310423
Download: ML20247K025 (10)

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l" APPENDIX B

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U.S. NUCLEAR REGULATORY COMMISSION REGION IV -

NRC Inspection Report: 50-458/89-27 Operating License: NPF-47 Docket: 50-458 Licensee: Golf States Utilities (GSU)

P.O. Box 220 St. Francisv111e, Louisiana 70775 l

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Facility Name: River Bend Station (RBS)

Inspection At: RBS, St. Francisville, Louisiana Inspection Conducted: June 5-9 and 19-23, 1989 Inspectors: */ Me,w 7 -/2.- P*l pW. M. McNei11, Reactor Inspector. Materials Date ,

and Quality Programs Section, Division of Reactor Safety l Ocax.> 7 - s 2. - e 'l f6 D. L. Kelley, Reactor Inspector, Operational Date Programs Section, Division of Reactor Safety Approved: [ Osm I. Barnes, Chief, Materials and Quality Date 7 - / :2 - P 9 Programs Section, Division of Peactor Safety Inspection Summary Inspection Conducted June 5-9 and 19-23, 1989 (Report 50-458/89-27)

Areas Inspected: Routine, unannounced inspection of self-assessment capabilitie Results: The Nuclear Review Board (NRB) activities were found to have a limited agenda and, with the exception of subcommittee reports, to be in need of greater documentation. Improvements in controls for NRB review of safety evaluations for facility changes were specifically indicated to be needed, based on the observation that required reviews had not been performed for 2 out 8907310423 890717 PDR ADCCK 05000458 Q PDC

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-2-Overall ofFacility a sample of 19 Review facility (changes Committee examined FRC) activities by thetoNRC were found inspector be well documented with minor exceptions. Similar weaknesses to the NRB were noted, however, with respect to FRC review of facility changes. In the same sample of 19 facility changes, the meeting minutes identified that FRC had reviewed only 12 of the i changes. The failures of NRB and FRC to perform required reviews were identified (see paragraph 2) as an apparent violation of NRC requirements. The Independent Safety Engineering Group (ISEG) was an organizational strength, with its activities covering a broad spectrum, and reports being of high qualit .

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DETAILS Persons Contacted

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• D. L. Andrews, Nuclear Training Director J. E. Booker, River Bend Oversight Manager J. L. Burton, Independent Safety Engineering Group (ISEG) Supervisor

+ K..F. Bullen. ISEG Engineer

• D. C. Byrd, ISEG Engineer

• J. W. Cook, Lead Environmental Analyst

+ T. C. Crouse Quality Assurance (QA) Manager

+ J. C. Deddens, Senior Vice President

+ D. R. Derbonne, Assistant Plant Manager i D. E. Dietzel, Nuclear Training Coordinator

+*M. S. Feltner, Nuclebr Licensing Engineer

+ W. J. Fountain. QA Engineer

+*J. R. Hamilton, Design Engineering Director

+*G. K. Henry, Quality Operations Director

+ R. J. King, Nuclear Licensing Supervisor

• G. R. Kinanell, Quality Services Director

+ 1. h. Malik, Quality Systems Supervisor M. C. Trahan, FRC, Secretary

+ M. F. Sankovich. Engineering, Manager

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• K. F. Suhrke, Project Management Manager

• R. J. Vacken, Compliance Analyst D. H. Wells, Licensing Analyst

+*R. G. West, Assistant Plent Manager, Technical Services Cajun Electric

+* L. Curran, Site Representative

+ L. G. Johnson, Manager NRC

• E. J. Ford, Senior Resident inspector

+ W. B. Jones, Resident Inspector

• Denotes those persons that attended the exit meeting on June 9, 1989.

+ Denotes those persons that attended the exit meeting on June 23, 1989.

This inspection was extended from its original schedule to allow the licensee to gather additional information on NRB review of safety evaluation The NRC inspectors also contacted other personnel including administrative and clerical personne _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -

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-4- Licensee Self-Assessment Capabilities (40500)

The objective of this inspection was to evaluate the effectiveness of the licensee's self-assessment programs. In this regard, the NRC inspector

< reviewed the activities of the NRB, the FRC, and the.ISEG. The thrust of I'

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this inspection was to measure how effective these groups were in identification of concerns and following such to resolutio a .- NRB The activities of the NRB were governed by the " Nuclear Review Board Manual," Revision 4 dated September 18, 1987. The NRB met on an average of once a month. Eight meetings have been held in 1989 to-date. Most of the meetings were characterized as special' meetings with only one or two agenda items. Regular meetings were held once every 6 months. Regular meetings differed from the special meetings in that subcommittee reports were reviewed. The NRB membership was found to be as described in Technical Specifications (TS). The 1989 meetings addressed such agenda items as:

Technical Specification Change Requests (TSCRs)

Service Water Task Force Report Startup and Test Exception List

NRC Enforcement Conferences Quality Assurance (QA) Audit Program

Subcommittee reports on employee concerns, FRC oversight, unreviewed safety questions, and QA program audit The NRC inspector reviewed the meeting minutes of the first eight meetings held in 1989 in detail and attended NRB Meeting 89-0 The following observations were made:

The meeting minutes were a summary of the same information that was found in the attachments to the m'inutes. At the end of each summary, the minutes would state thr.t. after discussion, the agenda item was approved or tabled. When an agenda item was approved, there was no documentation of the discussion on the agenda item. The documentation of reviews by subcommittees of NRB was in subcommittee reports, which appeared to be detailed and comments were traceable to resolutlo When agenda items'were tabled and returned to NRB, the meetirg minutes did not clearly document that the issues which caused the agenda items to be tabled were indeed resolved. For example, in Veeting 89-06, TSCR 88-017 was tabled for further i

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information concerning common mode and/or common component failure of the diesel generators. When readdressed and approved in the 89-08 meeting, this issue was not readdressed in the meeting minutes. Similar events occurred in Neetings 89-04 and

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Meeting minutes identified " Action Items" and " Recommendations,"

but the NRB manual did not address how these were to be controlled. Controls on tracking and assignment of priorities of " Action Items" and " Recommendations" were informa " Recommendations" were identified in 89-03 and -07 meetings and  ;

" Action Items" were identified in other meeting '

It was noted that the independence of NRB could be jeopardize Six members are required to have an NRB meeting quorum. NRB and FRC have one common member, one NRB alternate is an FRC member and one NRB alternate is an FRC alternate. Therefore, one-half l Of the members of a meeting could be from FRC, which NRB is required to independently revie *

It was noted that NRB training requirements were not identified in the NRB manua It was also noted that the informally established requalification requirements were not adhered to in that the person who chaired all eight meetings in 1989 had not been nqualified. A review of training records found that two '

other members, who had attended six of the eight meetings, were also not currently requalifie The review of licensee event reports (LERs) and other items, such as NRC inspection reports, appeared to be a serial review by members prior to meetings. The NRB reviews of LERs and other items, prior to meetings, were not documented. Meeting minutes had only summary information presented. The summary information was not sufficient to support a technical revie "

The audit activities of the QA department were presented without any assessment of the audits and their findings. In Meeting 89-02, the QA audit activities reported were of six audits performed since the last report. The report did not attach any significance to the RBS self-administered safety system functional inspection audit of the instrument air system. This audit had 14 QA finding reports and 9 condition reports (CRs).

Additionally, the environmental qualification audit had nine QA finding reports and three CRs. The remaining 4 audits hao a total of 13 QA finding reports and no CRs. This information was in the attachments to the recting minutes appendices, and in the meeting minutes there was no discussion documented of the audits and the findings.

l The effectiveness of the FRC oversight subcommittee appeared weak in that in Meeting 89-02, the FRC oversight subcommittee l

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reported that it closed a question which had been raised on the requirement for FRC to review Quality Class 11 modification . Quality Class II is defined as equipment whose failure could result in a' loss of power generation'and/or challenge safety-related systems, but would not endanger public safet The subcommittee report stated that FRC did not have to review Quality Class-11 modifications based on a surveillance repor The surveillance report, however, did not support that conclusio *

The NRC inspector established a sample of 19 facility changes after review of the 1988-1989 annual 10 CFR 50.59 report dated August 29, 1988. These changes were identified by the licensee to be associated with the following modification requests (MRs):

85-041 86-593 87-103 85-042 86-653 87-301 85-168 86-1159 87-500 85-485 86-1847 87-514 85-517- 87-641>

85-927 87-662 87-683 87-697 87-750

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The NRB was asked to demonstrate that it had reviewed the safety evaluations for these changes. Only 17 of the changes were reviewe There was no evidence of review of the revised safety evaluation for MR 85-927 and the safety evaluation for MR 87-683. This was identified as one example of an apparent violation to TS, Section 6.5.3.7 (458/8927-01).

Summary The NRB meetings did not appear to be well documented and focused on a limited number of items. Reviews by NRB subcommittees were documented in reports, which appeared to be detailed. Improvements  ;

in controls for NRB review of safety evaluations for facility changes were indicated to be needed, based on the example of an apparent violation discussed abov FRC

.The activities of the FRC were governed by A6ministrative

' Procedure ADM-0002,'" Charter of the Facility Review Committee,"

Revision 9, dated July 19, 1988. The FRC met almost daily addressing from 1 to 14 new agenda items, averaging four per meeting. As of this inspection,101 meetings have been held in 1989. The FRC membership was found to be as described in TS. The meetings addressed such agenda items as:

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. Field Change Notice (FCNs) l l: .* Administrative Procedures

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o Test Procedures

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Partial Completion Packages

Licensee Amendment Requests

Unresolved Safety Question Determinations i The NRC inspector reviewed the meeting minutes, numbered 89-51 through -68, in detail. The inspector attended FRC meetings 89-98 and -9 The following observations.were made:

The FRC meeting' minutes had sufficient detail to track the discussions of most agenda-items. However, it was noted that, when items were tabled, it was not always documented as to why

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they were tabled. Examples of this were the LERs tabled in Meetings 89-59 and -54, and the action item in Meeting 89-5 The FRC procedure did not address " Action Items" or logs that

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I were maintained of meetings. The logs provided significant information such as at which meeting an agenda item was addressed. Controls on the tracking and assignment of

. priorities of " Action Items" were informal. It was noted that there were ten open " Action Items" listed in the current meeting minute *

Training and requalification requirements had been established in the procedure and other documents. It was noted in the 18 meetings reviewed, that the chairman of the Meeting 89-065, one member who attended five meetings, one alternate who attended three meetings, and two alternates who each attended one meeting, had not been requalified as required. The licensee had identified that requalification training will be completed by June 30, 1989. This is an inspector followup item (458/8927-0?).

The Procedure ADM-0002, paragraph 6.3, requires that meeting minutes should be disseminated within 10 working days to members. The NRC inspector found that minutes for meetings 89-69 to -90 from April 28 to May 25, 1989, meetings had not been disseminated as of the date cf this inspectio The licensee documented this problem on CR 89-079 *

The FRC was asked to demonstrate that it had reviewed the same sample of 19 F.Rs identified in the previous section on NRB activities. Meeting minutes showed that FRC had reviewed only 12 of the 19 MRs. Two of the MRs which were not reviewed

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(85-168 and -927) had revisions to the modification and the unreviewed safety question determination since they were first reviewed by the FRC. There were five additional modification that were not reviewed. Two were "as-built" changes o , (MRs 86-1159 and 87-500) and three were Quality Class II  ;

modifications (MRs 85-5:7. 86-1847, and-87-301). These l'

modifications dealt with relocation of the condensate storage

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tank water chemistry sampling point, energizing safety-related valves at the interface between residual heat removal and radwaste systems; and a change in the fuel building bridge crane j travel to slow travel over the fuel pool. This was identified as the second example of an a

.Section 6.5.1.6(458/8927-01)pparentviolationofTS,

. The reviews by NRB and FRC are to assure that facility changes do not result in the plant being in an unanalyzed condition beyond the design basis as described in the safety analysis report, safety evaluation report, accident analysis, and other design document ,

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.The FRC meetings appeared to be well documented with minor exceptions. .The agenda items were discussed in-depth and actions-followed up effectively. The review of modifications was not g

satisfactor ISEG i

The activities of the ISEG, in addition to its independent assessment

, function, was to review unresolved issues for the NRB under the title of the Unresolved Safety Question Committee (USQC).

The ISEG activities were governed by ISEG Procedure ISE-13-001, "ISEG Organization, Responsibilities and Training," Revision 4, dated August 24, 1988. Six other procedures described the various specific activities of ISEG, with an additional Procedure ISE-13-006, "ISEG Record of USQD Review," describing the USQC function of ISE ISEG performed various evaluations, surveillance, reviews, and analysis of operational activities in addition to the review of NRC documents and various industry operating experience reports. Several report formats were used by ISEG to document the results of their activities. In addition, a monthly report of the ISEG activities was  !

submitted to the River Bend Oversight Manager. In the role as the USQC, ISEG submitted the minutes of the USQC meetings which give the status of the results of their review of unresolved safety issue determinations to the NR In performing an assessment of the ISEG, the NRC inspector reviewed the monthly reports for the last 12 months and a random sample of Operating Experience Reports (0ERs), Special Analysis Reports (SARs). l r and Surveillance Reports (SRs) spanning the last 2-3 years. In 1

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L addition, a. random sample of the USQC minutes for the last 2 years

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The following observations'were made: i

The OERs SARs, and SRs contained detailed descriptions of the

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problems, well documented data and, when needed, special test data were attached.' The conclusions appeared to be based on sound engineering and were well documented. The recommendations -

were precise and appeared to address the root cause of the:

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The ISEG monthly reports to the River Bend Oversight Manager-contained the following information: i

- Status of reports issued and not issued

- Oversight activities (e.g., CRs reviewed, MRs reviewed, industry operation information, and document changes)

- Status of continuing projects

- Scram root cause elimination status

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Status of.ISEG recommendations'

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Trending and root cause analysis

-. Training and staffing status-The minutes of the USQC reported the results of the unresolveo safety issue reviews and any issues needing further evaluatio *

The NRC inspector noted that few ISEG recommendations remain open (e.g., as of May 30, 1989, only 76 of a total of i 715 recommendations are still open).

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The NRC inspector noted.two potential areas where improvement could be made. The first area involved the review of modifications and unresolved safety issues. Since a revision to a modification may be made during its implementation, a mechanism to flag revised modifications has the potential to strengthen the licensee's efforts to ensure that the revisions did not introduce an unresolved safety issue. The other observation was, there was no means to ensure completion of surveillences of a broad spectrum of activitie Summary The ISEG activities were found to cover a broad spectrum. The licensee's reports were found to be detailed, logical, and of a high quality. It was also noted that, in addition to the assessment

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-10-function assigned to the ISEG, the ISEG performed self-assessment on-itself. These internal evaluations have resulted in an overall improvement of ISEG's performanc . Exit Meeting Exit meetings were' held on June 9 and 23, 1989, with those individuals denoted in Section 1 of this report. At.these meetings, the scope of the inspection and the findings were summarized. The NRC resident inspector also attended. The licensee did not. identify, as proprietary, any of the infonnation provided to, or reviewed by, the NRC inspector .

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