IR 05000458/1991003
| ML20217B968 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/04/1991 |
| From: | Bundy H, Murphy M, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217B966 | List: |
| References | |
| 50-458-91-03, 50-458-91-3, NUDOCS 9103120308 | |
| Download: ML20217B968 (9) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION P.EGION IV NFL Inspection Report: 50-458/91-03 Operating License: hPF-47 Docket: 50-458 Licensee: Gulf States Utilities (GSU)
P.O. Box 220 St. Francisville, Louisi6na 70775 Facility Naoe: RiverPendStetion(FIS)
Inspection At: Site, St. Francisville, Louisiana inspection Conducted:
February 11-15, 1991 Inspectors:
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M. 'E. Murphy /, Reacdoldfispector, Test Programs Date Section, Division of Reactor Safety kWYk"*'
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. W + b)I H. F. Bundy, Reactor Ins'pector, Test Frograms Date Section, Division of Peactor Saf ety Accompanied by:
W. C. Seidle, Chief, Test Programs Section Division of Reactor Saf ety (February 14-15,1991)
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Approved:
F. C. Seidle', Chief, Test Programs Section Date Division of Reactor Safety inspection Suninary inspection Conducted Februarv.11-15, 1991-(Report 50 458/91-03)
Areas. Inspected: Routine, announced inspection for followup of previously identified inspection findings and system entry retest (SERT) in the areas of modifications, temporary rrodifications, and maintenance activities.
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Pesults: The licensee was f ound to have a good program for identifying retest requirements and for the planning, developing, and performing of rctest procedures, retest requirements were satisfactorily addressed in tht creas of trodifications, prompt modific6 tion requests, and maintenance work orders.
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Responsitilities were defined and personnel training and experience were found j
to be good at all levels of involvement.
A teview of licensee actions on a previous inspection finding, Violation 458/8924-01, concerning a failure to provide edequate procedures for control of a special process did not result in a closure of the item. The review findings are discussed in detail in paragraph 2 of this report.
There were no violations or deviations identified during this inspection.
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i-3-DETAILS 1.
PERSONS CONTACT _ED
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G. Bysfield, Assistant Plant Manager, Systems Engineers
- J. Cook, Technical Assistant. Licensing
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.B. Chustz,itaintenance Support Supervisor
- W. Curren. Site Representative, Cajun Electric
- D.'Derbonne, Assistant Plant Manager, Maintenance A. Fredieu, Supervisor, Maintenance Services
- K. Giadrosich, Supervisor, Quality Engineers
- P.- Graham, Plant Manager
- J. Hamilton, Director, Design engineering
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- G. Henry, Director, Quality Operations
- D. Jacobsen, Senior Engineer, Nuclear Safety /dvisory Group-C. Lepisto, Supervisor, Engineering Administration l
D. Lorfing. Supervisor.-Licensing
- J. Maher, Engineer, Licensing
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J. Mead,- Supervisor, Design Engineering
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C. Mermigas, Project Engineering Coordinator
- W., Odell, Manager, Ovtrsight
- S. Radebaugh, General Naintenance Supervisor
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- K. Suhrke, General Manager. Engineering Administration
- D. Thomas Director, Administrative Services Ths inspectors also interviewed other licensee employees during the inspection.
- Denotes those attending the exit meeting on February 15, 1991.
2. ]!CENSEE ACTIONS ON JREVIOUS INSPECTION T1hDINGS.(92702)
(OPEN) Violation (458/8924-01): " failure to.ProvideLAdeounte Procedures for Control.of A Special Process."- This violation involved a freeze seal failure in a 6-inch service water line, which resulted in flooding and damage to
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switchgear, which caused a power outage in the cueiliary building. The'
-inspector reviewed the licensee's response (Letter RB0-317331 dated November 7,
'1989) and found that all but one of-the commitments contained therein had been
. satisfied. for instance, free 7e seal breaks in the auxiliary building had been analyzed..ModificationRequest(HR) 09-0135 for' plugging floor electrical a
'genetrationsinvolvedintheeventhad-beencompleted.
Procedure 11SP-009, _
Mechanical Maintenance Training Matrix," Revision 9, Attachment 3, had been
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- revised by Temporary Change Notice 89-0469 'to include Requirement 17.5,
" Establish and Maintain a freeze: Seal." Also, the inspector reviewed the
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training records for a course on_ freeze seals conducted for 22 licensee personnel _on September 11-13, 1990. The' course syllabus indicated that pertinent issues would be satisfactorily covered. However, the inspector reviewed Standing Order (50) 76, " freeze Seal Contingency Sheet." dated April 23,'1989,
. hich was addressed in-the respo se of November 7, 1989, and noted that 50 76 w
did not address the following:
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o The risk of the loss of shutdown cooling capability, which the engineering evaluation stated could occur within 30 minutes of freeze seal failure,
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was not oiscussed in 50 76, o
Safety reviews had not been performed by the licensee for most of the contingency plans prepared pursuant to 50 76. Since niost freeze seals are unique, a safety review for each contingency plan should be addressed.
o freeze stals are tensorary alterations; therefore the licensee should install them under t1e prortpt MR program, o
The procedure did not address wnen an operability determination was required for freeze seal installation.
This violation will remain open pending resolution of the above iten's.
3.
SERT INSPECTION OBJECT!VES AND METI'0D The overall objective of this inspection was to determine the licensee's performance in the area of system entry retett identification, documentation, and perforniance.
To accomplish this objective, the inspectors determined that retest requirements were evaluated during design change and maintenance planning and that the retest procedures met rt:gulatory requirements, commitments, and industry guides and standards.
It was also determined that rttest requirements were considered for all system boundary violations. The inspectors verified that the retests proved operability and assured that the design basis was satisfied for structures, systems, and components that vere modified or subjected to maintenance.
The inspectors reviewed the licensee's administrative procedures for modifications and maintenance. The following procedures were found to define the retest program, establish responsibilities, and provide procedure development:
o RBNP-010. " Design and Modification Control," Pevision 4 o
ENG-3-006, "RBS Design and Modification Request Control Plan," Revision 7
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ADM-0028, " Maintenance Work Order," Revision 10 l
o ADM-0023. " Conduct of Maintenance," Revision 9 l
!!odifications and maintenance work items accorrplished during the last refueling outage were assessed, and the inspectors selected seven modifications and twenty-five maintenance work orders for detailed review. Thirteen prompt modification requests (temporary modifications) were selected from the list of outstanding items for detaileo review. The selected items are listed in the Attachment.
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_ INSPECTION FINDINGS. SUMMARY The licensee was found to have a good program f or identifying retest requirements and for the planning, developing, and performance of retest l
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procedures. Petest requirements wert satisfactorily addressed in the areas of modifications, prompt modification requests, and maintenance work orders.
Responsibilities were defined and personnel training and experience were found to be good at all levels of involvement.
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No violations or deviations were identified curing the inspection.
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MODIFICATIONS (72701)
The purpose of this area of the inspection was to determine the process by which a permanent modification to structures, systems, or components was developed, reviewed, installed, and tested. Of specific interest was that post-modification testing ensured that structures, systems, or components were satisfactorily proven operable and that the design basis was met.
To gain an understanding of the licensee's program, the inspector reviewed the following procedures:
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o RBNP-010. " Design and Modification Request Control plan," Revision 4 o
ENG-3-006, "RBS Design and Modification Request Control plan," Revision 7 RBNP-010 provided the general requirements for initiating, controlling, and L
docurenting mocifications of RDS equipment, facilities, and supporting design docun.entation. Appropriate reviews and approvals of the modification were required. A modification request (MR) could be initiated by any plant person.
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When approved, the MR constituted a stand alone design document. The MR included identification of the design input, 10 CFR 50.59 evaluations, identification of quality list items, and inclusion or referencing of test procedures and acceptance criteria. The work packages could expand or embellish on the test requirements. Together, the MR package (design) and work package (installation) maae up a fully doeurcented "end-to-end" plant change.
ENG-3-006 implemented the requirements of RBNP-010 by establishing instructions for initiating, controlling, and docurenting actions pertaining to design and modifications of perr.anent stetion equipment and facilities at the River Bend Statien. The insoector noted that an independent peer review of the MR package was conducted.
In addition, a supervisory review was conducted.
To establish prograntnatic compliance, the inspector reviewed the MR packages listed in the Attachment. All of the MR packages reviewed had been releasec for field wo..:, and the majority were field work complete. The inspector noted
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that required testing and acceptance criteric were approprietely specified for U " "R.
Test results were consonant with acceptance criteria. Appropriate sws and approvals hao been obtained.
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TEMPORA 0Y.v.0DIFICAT10HS (72701)
Temporary nodifications or alterations were covered by the licensee's prompt NR(PMR) program. The PMR program contained the essential eierents of the HR program and was covered by ENG-3-006. The review and approsal processes were
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ilowever, documentation of field work completion and closecut was handled differently. Specifically, the " Field Work Completed" and
"Closecut" blocks on the MR form were not completed for PMRs. The inspector cbserved that this caused the records to appear incomplete for PMRs after closecut.
The inspector reviewed a PMR stetus report, dated February 13, 1991.
It listed 41 PMRs as open, with eight having been initiated in the 1906 and 1967 timefrarre.
The inspector concluded that these eight temporary alterations had in effect become permanent changes to the plant and that 41 PMRs appeared to be incre than would be expected.
To determine that the FMP. program had been properly implerrented, the inspector reviewed the PMR packages listed in the Attachment. The inspector found that systern configuration had been properly centro 11ed in each instance. Appropriate tests and acceptance criteria had been specified to deterroine both temporary modification installetion and removal. When appropriate, restoration of the system to original configuration had been properly docuriented. However, as discussed above, the MR form was not compatible with documenting IMR restoration and closecut.
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MAlllTENANCE.(62700)
The inspectors exemined the licensee's maintenance program to icientify ano evaluate the methods in place to control post-meintenance testing. This examination consisted of reviewing the administrative procedures and selected maintenance work orders as well as interviews of maintenance personnel.
The licensee's maintenance program is described in and controlled by Procedures ADM-0028, " Maintenance Work Order" and ADM-0023, " Conduct of Maintenance." The.se procedures identified the personnel responsible for and the steps to ensure that post-maintenance testing requirements were evaluated for the scope of work performed.
To determine the effectiver.ess of post-traintenance test implenentation, the inspectors reviewed 25 completed work packages perforn:ed during the last refueling outage. The documents reviewed are listed in the Attachment to this report. The review consisted of verifying that post-maintenance testing was considered during the plarning stage, that post-maintenance tests were
identified in the work package, end test procedures were identified or included
as approprir.te.
The review further verified that the testing specified was appropriate to the work performed.
Four of the work packages had no testing specified. The inspectors cercluded af ter reviewing the scope 01 the work performed that post-maintenance testing was not required.
Interviews were conducted with selected planners from each of the three traintenance areas: mechanical, electrical, and instrumentation and control. These interviews confirrard the procedural pro,ess and the level of experience in the planning department.
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-7-The review of the administrative procedures and work packages, elong with the interviews, confirmed that the licensee's program provided docup+nted guidelines for the evaluators to identify and develop retest requirements. The inspectors further confirmed that the retest requircrents were appropriate to the required work to restore the structures, components, or systems to an operational condition in keeping with the functions required by the design basis. Provisions were n.ade for review and evaluation of completed tests to ensure that test results meet the established acceptance criteria. Frovisions were also in place to resolve test devietions and accomplish retests where required. Procedures and responsibility had been established for returning equipment and systems to service.
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EXIT MEETII0 An exit meeting was held on February 15, 1991, with the individuals denoted in paragraph 1 of this report. At this teeting, the scope of the inspection and the findings were sunnarized. The licensee did not identify as proprietary any of the information provided to, or reviewed by, the ic pectors.
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ATTACHMENT MR!S-AND PHR'S REVIEWED Number Description MR 89-0128 Replace "B" PFD Transforn.er i
MR 87-0294 ITE 27B Relay Modifications HR 89-0243 Replace MSIV Dual Coil Solenoid Valves with Single
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Coil Soltnoid Valves MR 90-0007 Safety-Related Modifications for Chemical Cleaning
'FR 90-0084-Supply Chilled Water To Drywell Cooling System MR 89-0004 Redesign Safety-Related Dampers in Auxiliary Building
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.MR 87-0570 NSSSS Isolation Indication and Annunciation PMR 86-0069-Install Diode in B33-P001A PMR 86-0130 Mount Air Conditioner in RCIC Area
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PMR 86-0131-Document As-Built System PHR 88-0011 RTD and Lanyard Potentiometer Installation and Data Collection FMR 89-0022 Recirculation Pump Seal Purge and Leakoff Lines
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PHR 88-0030-Temporary Water Supply for Chemical Cleaning-PMR 89-0024 Install a Temporary Fan in RWCU Heat Exchanger Room
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PMR 90-0007 Eliminate Reactor Scram Caused by Loss of Power to a Single High Level Trip Circuit.
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FMR 90-0008 Install and Remove Temporary Lead Shielding PMR 90-0019 Temporary Power for Division 11 RCIS
'PHR 90-0020~
Provide Temporary Power to Soleroid Air Supply Valves for Airlock Door Seals PMR 90-0022 Defeat Shutdown. Cooling isolation Logic i
PHR 90-0032.
Install a Temporary Fan in The PWCV Pump Roon:
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-2-Maintenance Work Orders Reviewed Number Description HWO 127030 Problem With GE HFA Releys MWO 127033 Problem With GE HFA Relays MWO 127034 Prob 1cm With GE HFA Relays MWO 127035 Problem With GE HFA Relays MWO 127036 Problem With GE HFA Relays MWO 127056 Disassenble & Clean "C" RHR Peat Exchanger MWO 130403 Rod Position Problem MWO 132184 Redesign Safety Related Dampers - I&C MWO 132186 Redesign Safety Related Dampers - Electrical MWO 136790 Uncouple RCIC Pump From Turbine MWO R137336 Check Valve Leaking During LLRT MWO R137347 Failed Lt.RT MWO R138281 Replace Expended Squib Cartridge MWO R138330 Replace Installed Hein Steam Safety Relief Yalve MMO R138331 Replace Installed MSRV With New MSRV MWO R139585 Repair Feedwater Ptader Insulation Darage NW0 R139929 Repack /Liveload; Cut and Cap Leak-off Line MWO R141563 EDG Maintenance for RF-3 MWO R141565 EDG Maintenance for RF-3 MWO R141704 Rework Feed Reg. Volve Actuator HWO R141705 Rework Feed Reg. Valve Actuator MWO R142634 Repack and Liveload Valve MWO R143528 Install Lead Shielding on Drywell Piping MWO R144911 Control Rod Failed to Meet Max. Insertion Time
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