IR 05000458/1991006

Insp Rept 50-458/91-06 on 910211-15.No Violations Noted. Major Areas Inspected:Weaknesses & Concerns Identified in Insp Rept 50-458/89-04

ML20217B174
Person / Time
Site:	River Bend
Issue date:	03/07/1991
From:	Gagliardo J, Mckernon T, Whittemore J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217B170	List: IR 05000458/1991006 ML20217B165
References
50-458-91-06, 50-458-91-6, NUDOCS 9103120017
Download: ML20217B174 (3)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-458/91-06 Operating License: NPF-47 Docket: 50-458 Licensee: Gulf States Utilities Company P.O. Box 220 St. Francisv111e, Louisiana 70775 Facility Name: River Bend Station Inspection At: River Bend St6 tion, St. Francisv111e, Louisiana 70775 Inspection Conducted: February 11-15, 1991 Inspectors: ( .. . -

lo!9l y Th 0. McKernon, Reactor Inspector, Operational Date Programs Section, Division of Reactor Safety i

c.L+?ah f/ J. Nhit",emore, Reactor {nspector, Operational L'.

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Wu Date Programs Section , Divi on of Reactor Safety .I

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f Approved:r- [ ll A <' 11/[ b' 37 91_

pf. E. Gaglierdo/ Chief 4 Operational Programs Date  ;

-L Section, Divi $1on of Reactor Safety -l Inspection Summary Inspect. ion Conducted February 11-15, 1991 (HRC Inspection. Report.50-458/91-06)

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Areas. Inspected: This was a special, announced followup inspection that I reviewed weaknesses and concerns identified during the maintenance team inspection (MTI), NRC Inspection Report 50-458/89-04 Results: Within the scope of the inspection, no violations or devi6tions were identified. The inspectors observed several areas of irrprovement, particularly related to trending-programs and electrical safety. However, the inspectors

.also identified continued minor concerns related to the training of system  ;

engineers and planners and in the control and review of the work performed by contractor personnel and the verification of contractor qualifications. These were areas identified in the-MTl as weaknesse I 9103120017 91030s PDR 0 ADOCK 05000458 PDR

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DET_llS A EXIT MEETING. ATTENDEES:  !

GSU personnel P. D. Graham, Plant Manager D. R. Derbonne, Assistant Plant Manager-Maintenance

K. E. Suhrke., General Manager Engineering & Administration D. L. Andrews, Director-Nuclear Training G. K. Henry, Director-Quality Operations W. H. Odell,-Manager-Oversight E. M. Cargill, Director Radiological Programs R. L. Mullins, Supervisor, Contracts & Purchasing R. G. Easlit, Radwaste Supervisor J. E. Spivey, Senior QA Engineer / Audit Coordinator W. T. Bullard,-Nuclear Safety Analyses Group, Technical Assistant J. Cook, Technical Assistant-Licensing C. L. Fantacci, Radiological Engineering Supervibot  !

B. Chustz, Maintenance Support Supervisor J. C. Maher, Engineer-Nuclear Licensing  !

W. L.. Curran, Site Representative-Cajun Electric Coop J. R. Hamilton, Director-Design Engineering NRC l l

R. E. Baer, Senior Reactor Health physicist T. O. McKernon, Reactor Inspector L. T. Ricketson, Senior Radiation Specialist W. C. Seidle, Chief, Test Programs Section, DRS, Region IV l

J.,E. Whittemore, Reactor Inspector

' FOLLOWUP T0 pREVIOUSLY IDENTIFIED WEAKNESSES.IN.NRC IN5pECTION .

REPORI 50-456/89-04.(92701)

Inthemaintenanceteaminspectionreport(50458/89-04), a number of L weaknesses were identified in the Executive Sumary Section of the report

! and/or in the colur coded evaluation tree attached to the report. During this L inspection, the inspectors reviewed the licensee's corrective acticus related to these weaknesses, j

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2.1 Root Cause Analysis and. Determination During the inspection, the_ inspectors reviewed the licensee's program #or trending and evaluation of condition reports (CR). The licensee's nuclear safety analyses group (NSAG) was responsible for reviewing CRs and licensee l

event reports. They were also responsible for assigning causal factor codes as well as trending the data and analyzing for negative trends and the contributing root causes. The inspectors reviewed a special analyses and studies report, dated January 17, 1991; this report identified unacceptable trends found during

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I-3-the 1989-1990 period. As previously discussed in the MT1 NFC Inspection F.eport 50-4EE/89-04, the licensee had experienced a number of unplanned actuations and isolations during 1986-1988, of which approximatel3 one third were attributed to human errors. A review of the above report indicated that this was also true during 1989 and 1990. In addition, some events were attributable to a comunication proble'n between the planning and the operations groups in the design rtod4fication process. The result of this corrnunication probleir was a failure to M eclude unplanned isolations and actuations during modification installation. As a result of the above t'nding, the plant manager had directed a task force to evaluate proposed solutio.s and to submit recommendations. The report was scheduled for submittal w the plant manager by March 18, 1991. It was noted by the inspectors that many of the persistent problems appeared solveble through better coordination, interfacing, and prejob planning among the design engineering, systems engineering, planners, and the operations group, ble inspectors noted also that the design engineering and tredification control aspects of the probleras were currently being reviewed by the resident inspectors under Unresolved item 456/9029-02. Therefore, a separate tracking item has not been designated in this repor .2 Self-Assessments Discussions with key plant tranagers were conducted to ascertain if improvements had been trade durina the period since the MT1. The system engineers had been reorganized duriq June 1990. This group is now under an assistant plant manager. In addition, it was noted that the licensee had taken treasures to trend areat such as oil analysis, vibrational analysis, thermography, acoustic inonitoring, diagnostic testing of motor-operator valves, and recirc purrp seal pressures. Whereas some of the prograrrs were recently initiated, there appeared to be good potential for proactive identification of problems and correction prior to equipment failures. One example included efforts to monitor thermo-graphically the main transformer phase 1-C disconnect, which had been identified as a thermal hot spot (i.e., functioning above the nominal tenperature ranges typical for the equipment). The licensee was n:enitoring the condition r.,n a periodic basis and planned to repair the disconnect during the next planned omtag In addition to the above, the inspectors noted that, in general, trends for backlogs appeared to have decreased in the past year end a half. Areas observed included CRs norked by the system engineers and the number of open quality assurance finding reports (QAFRs) older than one year. However, the inspectors noted that in sone instances, implementation of scrre programs lagged or had been delayed because of other high priorities. Examp' s included the human perf ormance evaluations anc training programs for s" engineer .3 System Encineer Training ar,d Certification

'The maintenance team inspection report (HRC Inspection report 50-456/89-04)

stated that the requirements fer training and qualification of system engineers i

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were poor and constituted a significant weakness. The inspectors determined the changes that had been made in the training and qualification f or system engineers.

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The inspectors reviewcd Procedure TSP-0001, " System Engineering Personnel Training and Qualification," for the revisions incorporated to correct the noted weakness. Discussions on implementation of the procedure were also held with both training and system engineering supervision. The inspectors determined

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the current training and certification status of all system engineering personne Other documents reviewed included the engineering management memoranda detailing department goals and standards and expectations of management with regard.to system engineer Procedure APMS-90-356, " System Engineering Goals fc- 1991," stated that all system engineers hired Defore 1991 would complete the Procedure TSP-0001 required training. Further, each system engineer was to complete system qualification for at least one assigned system for which he or she was the primary engineer prior to November 30, 1991. System engineers were normally assigned responsibility as primary or backup engineer for five systems. The )

memorandum containing the standards and expectations of management stated that all system engineering personnel were expected to comply with the training and certification requirements of Procedure TSP-0033, " Conduct of System Engineering." The current treining program allowed the newW-hired system ngineer to start productive work af ter completion of general employee training, specific training deemed necessary by the discipline supervisor, and an indoctrination consisting of reading various site documents. The licensee stated that a new engineer's work was subject to strenuous peer and supervisory review af ter this initial training effort until certification was completed. All further training effort was directed toward the qualification on assigned systems and certification as a system enginee The certification process consisted of completing various attachments to Procedure TSP-0001. These attachments were identified as required training, supplemental training, and engineering test certificatio The required training attachment was to be completed by all system engineer as provided in formal training sessions in the areas of boiling This vetertraining reactor w(BWR) technology, root cause analysis, modification request, and-unreviewed safety question deterinination. The inspectors determined that 17 af the 29 assigned system engineers had completed this required training. It '4as also determined that the obvious importance of these training areas was no'.

reflected in the-training program, as Procedure TSF-0001 encouraged this training to be completed as soon as possible but did not require the enginetr to ecmplete the training prior to assuming engineering cognizance for a syste Licensee representatives told the inspectors that the primary responsibility of system engineers was to respond to CRs, which would seem to make rapid completion of this training desirabl The supplemental training attachcent consisted of applied fundamentals relating to nuclear power generaticn. This training was administered in a classroom

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5-setting for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day over an 11-week period. The inspectors detertained that poriions of the supplemental training could be waived if the engineer had previous eork or academic experience related to the specific area waive However, the procedure did not contein specific criteria or instructions for waiving the training. The current status printout obtained from the trairing cepartrient revealed that orly E cf the 29 system engineers had completed the supplemental training acdule, j The test qualification Lttachment was to be completed by system engineering personnel so that they could perform activities associated with testing. The h specific activities that could be perfornec were not delineated by the procedur The test cualification attachrent had been completed by 19 of the 29 system engineer A joint effort was underway t'y training and engineering supervision to develop [p system cualification cards. These cards were to be developed for 53 system ::

At the time of the inspection, 31 cards had been completed and approved, 8 additional cards were in the draft process. To complete a card the following "

activities had to be performed by the ?rospective system engineer:

o A system walkdown with an engineering supervisor; o A system checkout ecministered by a licensed operator or senior reactor operator;

o Reading a list of documents pertaining to the system; and o Passing a final evaluation consisting of a written examination or an oral g board with board members representing engineering, training, and managemen _

Ideally, each system engineer would complete the cards for the five systems be or she had either primary or backup responsibilit The inspector 'etermined that there were no procedures in place to update the required readi.g list portion of these cards. This was of concern for the Q-portion of the readino list titlec, " Regulatory Documents." The licensee couls not explain how NPC iaformation notices, tulletins, or generic letters that

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pertained to a specific system would be trackad for addition to the appropriate system qualification :ard reading list Tt4 inspector determited that an ambitious system engineering training program was in place. However, the program was difficult to understand without exten-sive explanation provided by various licensee personne In reviewing the developtant history of the program, the inspector determined that t% program was not put together utilizing the required elements of a ,

systematic approach tr training (SAT) methodology. Learning objectives were not developed from a task analysis but rather by a consensus of peers. The system engineering training program contained the attributes required of a successful training program; however, the program design appeared tc be fragmented

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-6-and relied heavily on other programs, procedu'res, and documents. The full implementation of an effective system engineer training program appeared to be

, lagging because of the findings noted abov '2.4 Maintenance Planner. Training The mainteaance team inspection report * stated that the implementation of training for maintenance department planners was inadequate. The inspector-reviewed the licensee's effort toward the training of maintenance planning personnel. There was no training program in place for planning personne However, the maintenance department had prepared and implemented a planning infor. nation guide notebook. This notebook contained policy guidelines intended to indoctrinate planners in the prope preparation of planning documents. The guide provided step-by-step instructkns for all tasks involved in issuing a completed approved planning package. New or contract planners were issued this guide to-work from for the initial preparation of planning packages. The licensee stated that new or contract planncrs were always assigned a lead or supervisory planner to work with for planning document preparation. The packages initially prepared by a new planner were critiqued and corrected by -

this lead planne There is.no requirement for formal training of personnel used as planner In the past, the-licensee had often required planners to receive training classes-in general systems, BWR technology, and print reading. The licensee g stated that the general systems class was viewed as a prerequisite course for the BWR techmlogy course. Thus, some personnel with previous experience have skipped the pre al systems course and taken the BWR technology course up front

. and effectively challenged the systems course. The licensee was tracking the status of training for planner .

The inspector reviewed training records and documents, and determined the following:

o Three of the ten planners had not taken either the systems or technology course, o Five of the ten planners had not received the BWR technology training, o Eight of ten planners had not received print reading trainin From the information provided to the inspector, it appeared that only two of the ten planners had received all of the desired training. During the MTI, it was determined that none of the nine planners employed at the time, had received all of the trainin It appeared that progress to correct this weak. area has

?- been slow. Training department personnel stated that there were plans to develop a formal training program for planner .5 Contract Maintenance A stated weakness in tiRC Inspection Report 50-458/89-04 was that the licensee had not.taken appropriate control of field maintenance activities and the l

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-7-review of completed work packages performed by contract maintenance persorael during Refueling Outage 2 (RF-2). Two significant problems nM:,4 were signifi-cant violations of the licensee's equipment clearance progrcm and imp.'cpcr closecut of work control documents. A separate issue in inis area was the licensee's failure to verify the stated education and experience of contract personne The inspectors reviewed Procedure ADM-0023, " Conduct of Maintenance," MSP-0028,

"Qbe11fication of Contract Maintenance Personnel," and the new shift organization for outage work control that was implemented for Refueling Outage 3. The inspectors also held discussions with key management personnel to obtain a detailed understanding of how contract maintenance activities were initiated, controlled, and closed ou Procedure ADM-0023, "Cunduct of Maintenance," did not address any aspect of contract maintenance. This procedure provided an overview of the activities of the onsite maintenance organization and defined supervisory and managerial responsibilitie Procedure ItSP-0028, " Qualification of Contract Maintenance Personnel," established the program for Gulf States Utilities (GSU) acceptance of contract maintenance i- personnel. To meet the program goal, the procedure defined the educational and experience requirements required of personnel qualified to Level I or II. The procedure also provided qualification matrix cards that were used to document this qualification attained through training or experience. The procedure did not require that contract personnel be trained or demonstrate minimum competency in the utilization of the licensee's clearance or administrative work control procedures. Much of this procedure appeared to be redundant and duplicated efforts already expended by the licensee's procurement and contract group. The procedure did require that contract personnel either work under the supervision of or with qualified personnel. The inspectors determined that this procedure did not address the problems noted during RF-2, when contract personnel violated the clearance program and improperly documented work activitie The inspectors were shown an uncontrolled document entitled, "RF-3 Maintenance Improvements." This document contained two organization charts labeled,

" Outage Work Control Organization." These charts showed that each contractor supervisor had been assigned a GSU facilitator. Discussions with management personnel revealed that the assigned individuals were senior GSU maintenance craft personnel, and their primary responsibility was to assist the contract supervisor to assure all GSU administrative clearance and work control procedures were utilized as -intended and that documentation was correct. Licensee personnel stated that this organization had been very effective in preventing abuse or violations of the administrative work control system during RF-3. The inspectors noted that this successful outage work control organization was not proceduralized and had been only graphically depicted in an uncontrolled documen The inspector reviewed the licensee's action regarding their failure to verify maintenance contract personnel education and experience. Procedures RBNP-003,

' Procurement of Material and Services," and NPP-15-205, "Procurerrent of Safety-Related ano Quality Assurance Program Applicable Materials and Services," were

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reviewed. The' inspectors also held discussions with licensee personnel involved

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with contracts, purchasing, training, and managemen j The inspectors determined that personnel services were contracted both from '

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' companies which were either self-screening and also from those that were nonself- ;

screening. For self-screening companies, the contracts were written to require that-the contracted company provide written certification of their employees i

. education, experience, and suitability for access, for nonself-screening companies the licensee was responsible for certifying the contracted employees !

qualification ' !

The inspectors determined that the licensee's fitness-for-duty program did in fact verify the suitability for access for each contracted employee. However, it could not be determined that contracted employees' statenents of experience or education were ever verified, even on a sample basis. Thus, the weakness

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discovered during the MTI still existed, and there was no evidence of corrective action to alleviate this conditio .6 Control of Electrical: Safety Equipment and Training During the MTI, irspettors discovered that plant operations personnel were unfamiliar with the proper use, storage, and testing of electrical safety equipment; this was reported as a significant weakness uncovered during that .

inspection. The inspectors-followed up on the corrective action taken to address this weakness by reviewing system operating procedures requiring the use of safety equipment, SOPS 45, 46, and 47. 'Also reviewed were the posted instructions for the use of high voltage gloves, Surveillance Procedure HVG-0001 t for testing rubber gloves, and the training department's Lesson Plan NE0-290-2,

-" Electrical Safety."

Applicable system operating procedures had been revised to include precautions directing operators to use the appropriate safety equipment. All qualified or licensed operators had been instructed in the proper use of electrical safety equipment _in accordance with the electrical safety lesson plan. This action was completed within the facility requalification program as of liay 1990. This training was made a permanent addition to the operator requalification program ;

and has also been integrated into the initial' training programs for licensed and nonlicensed operators. The licensee had initiated action to test high-voltage-rubber gloves periodically and to report the results as required surveillance. The seven locations where safety equipment was stored had been -

posted with instructions on how to use high-voltage gloves properly. It appeared that the licensee had taken all necessary corrective action to address this weaknes . EXIT MEETING On February 15, 1991, the inspectors held an exit meeting with Mr. P. Graham and GSU staff personnel. The inspection scope and findings were discusse Persons attending the exit meeting are listed in Section 1. The licensee did not identify as proprietary any of the raterial provided to or reviewed by the inspectors during this inspectio . - . - - - - . - - . . - - . - . _ _ . - . - . . . - - _ . ,