IR 05000458/1989029
| ML20247L330 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/14/1989 |
| From: | Barnes I, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247L323 | List: |
| References | |
| 50-458-89-29, NUDOCS 8908010215 | |
| Download: ML20247L330 (6) | |
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APPENDIX U.S. fCCLEAR REGUIATORY COMMISSION l-
REGION IV
NRC Inspection Report: _50-458/89-29 Operating License: HPF-47
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-Docket: 50-458 Licensee: Gulf _ States Utilities (GSU)
P.O. Box 220-St. Francisville, Louisiana 70775 Facility Name: River _BendStation(RBS)
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Inspection At:
RBS, St. Francisville,' Louisiana Inspection Conducted: June,
'!, 1989 Inspector:
Nw 7 -/4. -99
[W. M. McNeill, Reactor Inspector, Materials Date and Quality Programs Section. Division of Reactor Safety Approted:
d8-r - /4 -Poi I. Barnes, Chief Materials and Quality -
Date Programs Section, Division of Reactor Safety Inspection Summary Inspection Conducted June 19-23, 1989 (Report 50-458/89-29)
Areas Inspected:
Routine, unannounced inspection of corrective actions.
Results: The observations of the corrective action activities found that
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programs and procedures were in place to identify problems, analyze root causes, and establish corrective actions.
Problems appeared to be tracked to resolution witn minor exceptions. A significant observation of the NRC inspector was that condition reports and certain quality audit finding reports appeared to have a less than an in-depth root cause analysis. No violations or deviations were identified.
8908010215 890718 PDR ADOCK 05000458 Q
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-2-DETAILS 1.
Persons Contacted-GSU V. P. Bacaskas, Eq'uipment-Qualification (EQ) Area Coordinator
- K. F. Bullen. Independent Safety Engineering Group (ISEG) Engineer
- J. L. Burton, ISEG Supervisor
- J; W. Cook, Lead Environmental Analyst
- T. L. Crouse. Quality Assurance (QA) Managtr
- J. C. Deddens, Senior Vice President
- D. R. Derbonne, Assistant Plant Manager
'*M.'S. Feltner, Nuclear Licensing Engineer C.:E. Fisher, Compliance Analyst
- W. J. Fountain 0A Engineer-
- J. R. Hamilton. Design Er.t ineering Director
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- G. K. Henry, Quality Operations Director K. P. Hughes, QA Engineer G. A. Jones, EQ Engineer T. Khaud, OA Enginer
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- R. J. King, Nuclear Licensing Supervisor J. E. Magee. QA Engineer
- I. M. Malik, Quality Systems Supervisor.
C. L. Miller, Compliance Analyst
- T. G. Murphy, Planning & Scheduling Supervisor C. D. Redding, QA Engineer
- M. F. Sankovich, Engineering Manager C. G. Soranaers. 0A Enaineer
- R. G. West,' Technical Services Assistant Plant Manager
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. Cajun Electric
- W. S. Day, Site Representative
- L. G. Johnson, Manager NRC
- W. B. Jones, Resident Inspector
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- Denotes those persons that attended the exit meeting on June 23, 1989.
The NRC inspector also contacted other personnel including administrative
and clerical personnel.
2.
Corrective Actions (92720)
The objectives of this inspection were to determine whether the licensee i
has developed a comprehensive corrective action program to identify,
follow, and correct safety-related problems. An initial inspection of i
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this activity was performed.during May 15-19, 1989, and documented in NRC
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of the Updated Safety Analysis Report (USAR)pector reviewed Section'17.2 Inspu; tion Report 50-458/89-26. The'NRC ins o
, Revision 1, dated'
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- August 1988, and the following procedures:
,QAD-16. " Corrective: Action," Revision 6; dated. August 23, 1988
RBNrJi7, " Corrective Action Program " Revision;0,(dated. June 30,
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1988 The NRC inspector. reviewed a sample of activities and the procedures for:
problem identification, root.cause analysis, corrective action, and tracking of problem resolution in the following subject areas:
a.
Employee Concerns
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The NRC inspector found employee. concerns were controlled by a procedure " Quality Assurance Tracking of Quality Concerns,"
QAP-1.14, Revision 2, dated November 5, 1987. A review.of a sample of.four recently resolved concerns found that the program was satisfactory with one exception.
Concern 89-03-002 dealt with an allegation of discrimination in employment by a contractor because the individual had identified training problems in security. Because of its nature, security, the concern was referred to GSU corporate' security for followup. The corporate security report appeared inadequate in that the reasons for requesting a resignation from the individual by the contractor were not verified by GSU corporate security,- Also, the problems identified.by the individual in regard to security training were not investigated to substantiate the accuracy and validity of the information. The licensee, after the identification of the above by the NRC inspector, took steps to verify the reasons for. requesting the resignation and to investigate the accuracy and validity of the information on the security training problems.
It should be.noted that there has been a previous case of employment discrimination by this contractor substantiated by GSU.. The problems identified by the individual were referred to an NRC Region IV security inspector onsite at'the time of this inspection for followup (see NRC Inspection Report 50-458/89-30).
b.
Condition Reports and Trending
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The NRC inspector found that trending requirements were identified in
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a procedure. " River Bend Station Trending Program." RBNP-052, Revision 0, dated March 17, 1989. Trend reports were issued every 6 months and weekly during the outage. As a result of review of the recent outage reports and the last two semiannual reports, the NRC inspector noted that the last three reports on outage activities established that there was a trend of procedural violations. 'It did not appear, however, that any actions were taken as a specific result I
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of this trend information. The failure to take adequate corrective action to prevent repeat procedura11 violations was identified as a violation in NRC Inspection' Report 50-458/89-11. The semiannual reports, although they summarized about 4,000 condition reports (CRs)
in each report, did not identify any significant trends. The NRC inspector also noted that the procedure established a CR Oversight Group (CROG) charged with the reytew of CRs for potential
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deportability of events. However, there were no procedures established on how CROG was constituted, accomplished its goals, and documented its activities.
The NRC inspector found that ISEG reviewed CRs on a sampling basis.
In review of this activity, the NRC inspector noted ISEG Surveillance 88-005 which reviewed a CR 88-0843 on a missing baffle in the spent fuel pool cooling and cleanup system backwash receiving tank. The surveillance noted that'the missing baffle led to contamination of the fuel building ductwork which resulted in automatic initiations of the fuel building filter trains by the radiation monitors located in the ventilation system. Such engineered safety feature initiations at RBS have been documented by CRs.88-0821, -0800, and -0697. The root cause analysis in these CRs was that the radiation monitors high signals were caused by background activity due to natural radon. The surveillance report demonstrated that the root cause analysis of CRs was not of sufficient depth to establish the actual root cause. The NRC inspector also noted that there is a history of other CRs on radiation monitors which have identified a root cause of random voltage spikes for high alarms.
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QA Audits and Trending The NRC inspector found the trending of QA audit results to be required by a procedure, "QA Trend Analysis Reporting," QAP-1.7, Revision 3, dated January 3, 1989 Audit activities were defined in two procedures, " Audit Performance, Reporting and Followup," QAI-2.1, Revision 6, dated September 14, 1988; and " Processing of Quality Assurance Finding Reports," QAP-1.15, Revision 4, dated January 12, 1989. The NRC inspector reviewed a sample of eight recently closed Quality Audit Finding Reports (QAFRs) and the recent trend report.
The trending process was undergoing a significant change to include root cause information into the trending data. This activity had not yet been completed.
The NRC inspector found in the review of QAFRs that audit findings were documented clearly and, with some exceptions, the root causes identified and appropriate corrective actions taken and verified.
The exceptions noted pertained to an E0 eudit (89-01-I-EQAL) which resulted in the issue of nine QAFRs and three CRs. Four of the closed QAFRs were reviewed in detail.
It was noted that the i
close-out information for QAFR 89-02-03, which cited noncompliance with a procedure, failed to include any other information that would
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yy provideassurancethat.the' activity-inquestion,planningofEQ$1'ife maintenance, was indeed controlled properly. This absence of such o
information was. considered of.some significance because the accepted."
corrective action-taken.in regard to'the QAFR was to delete the
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- requirements'from the procedure that had been cited in the QAFR.z,
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. Three of the QAFRs (89-02-04 through -06) cited problems with.
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preventive. maintenance (PM) tasks, guidance for PM record review, andl
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EQ life maintenance. No hardware deficiencies were found to exist,-
resulting in the CRs-(89-0064 and'-0065) associa'ted with these QAFRs
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b being voided in one case and dispositioned 'that there was no.
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nonconformance in the Other case.
It appeared to the NRC" inspector
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s that the' root cause for each of the problems was inadequateLEquipment'
Qualification Maintenance and. Surveillance Requirements (E0MSRs).
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The.QAFRs attributed, however,'other root causes'despite'the accepted
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corrective action for'each being to correct the specific EQMSRs.--Thel L-NRC inspector was concerned that inadequate analysis of root cause'
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may have resulted in insufficient consideration being given to
. whether the' audit findings were indicative of broader problems with
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EQMSRs.3 Licensee QA personnel' informed the NRC inspector that an;
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additional review would be performed of this. subject area. Review of actions taken is considered an inspector followup item.
(458/8929-01)
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Maintenance Work Orders and Condition Reports The RBS corrective action program provided for the identification of problems.on'CRs-and the documentation of corrective action for.
resolutioninamodificationrequestormaintenanceworkorder(MWO).
Theinitial.NRCinspection(50-458/89-26) inspected how modification requests were used as corrective actions for CRs. The.NRC inspector verified the completion'of corrective actions on recent CRs that were identified in the form of an MWO. A sample of six MW0s issued as-corrective' action to'CRs were reviewed. The NRC inspector identified that, in one case, the CR (88-0821) was not cross-referenced on the MWO (124758) as required by procedure. This reenforces a concern of the NRC inspector on the separation of the problem identification information from the problem resolution information that was identified.in NRC Inspection Report 50-458/89-26.
e.
NRC Inspection Findings The NRC inspector found that procedures " River Bend Station Action Program for ' Resolving NRC Regional Findings," RBNP-031, Revision 2, dated August 7, 1988; and " Processing and Tracking of Regulatory and m
Industry Correspondence," NLP-10-006, Revision'2, dated November 9,
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1988, required that NRC inspection findings be documented after an exit meeting on'a CR or Engineering Evaluation Analysis Request-(EEAR). Upon receipt of the corrective action to the CR or
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EEAR and the Notice of Violation from the NRC, a response was written. This process has been' verified with the NRC close-out of
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inspection findings. The NRC inspector noted that there appeared to
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ie-6-be no verification of completion of corrective actions by the licensee before submittal of a close-out package to the NRC.
For example, the close-out package for Violation 458/8801-01 was presented to the NRC inspector during this inspection. The NRC inspector found that the violation cculd not be closed as a result of a QA audit identification in a QAFR (89-03-008) that the committed corrective actions had not been fully implemented.
Summary The NRC inspector found the corrective action program to be established and implemented. Problems were identified and followed to resolution with a few minor exceptions'. One concern of the NRC inspector was that analysis on CRs and for certain QAFRs on the initial engineering level was not of sufficient depth to establish the root cause of problems identified. This appeared to be related to the root cause analysis training which has been limited to a Human Performance Evaluation System approach and does not include change analysis, barrier analysis, and other approaches. No violations or deviations were identified.
3.
Exit Meeting An exit meeting was held on June 23', 1989, with those individuals denoted in Section 1 of this report. At this meeting, the scope of the inspection
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and the findings were summarized. The' licensee did not identify, as
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proprietary, any of the information provided to, or reviewed by, the NRC j
inspector.
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