IR 05000458/1998004

Insp Rept 50-458/98-04 on 980111-0221.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20248L897
Person / Time
Site:	River Bend
Issue date:	03/19/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248L894	List: IR 05000458/1998004 ML20248L892 ML20248L895
References
50-458-98-04, 50-458-98-4, NUDOCS 9803240342
Download: ML20248L897 (23)

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ENCLOSURE 2 U.S; NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-458 License No.: NPF-47 Report No.: 50-458/98-04 Licensee: Entergy Operations, In Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, Louisiana Dates: January 11 through February 21,1998

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Inspectors: G. D. Replogie, Senior Resident inspector, River Bend C. S. Marschall, Senior Project Engineer, Project Branch C N. P. Garrett, Resident inspector, River Bend K. D. Weaver, Resident inspector, Grand Gulf

. Approved By: E. E. Collins, Chief, Project Branch C I

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ATTACHMENT: SupplementalInformation

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9003240342 900319 PDR ADOCK 05000458 G PDR

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EXECUTIVE SUMMARY River Bend Station NRC Inspection Report 50-458/98-04 This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period of resident inspectio Ooerations

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The conduct of operations was generally professional and safety-conscious (Section 01.1).

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Operations' response to a control rod drive control valve failure was prompt and effectiv The flow control valve failed closed and operators effectively established manual control in the field (Section O1.2).

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Operations and Engineering erroneously concluded that only one abnormal operating procedure and no emergency operating procedures could be impacted by standby gas treatment system (SGTS) induced differential pressure (dp) across the auxiliary buildin The actual operation of the SGTS following an event and the force required to open doors with one train of the SGTS in operation were not appropriately considered in the evaluations. Errors made in one calculation resulted in significantly underestimating the force required to open doors. In addition, when an engineering manager and supervisor were unable to enter the auxiliary building (with one train of SGTS in operation) they failed to inform upper management and Operations of this information. Consequently, misperceptions regarding the difficulty accessing the auxiliary building were not corrected (Section O2.2).

Maintenance

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Maintenance activities were generally completed thoroughly and professionally (Section M1.1).

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A special auxiliary building accessibility test was poorly coordinated, which minimized the I value of the test. Specifically, when two trains of the SGTS were running, door testing was initiated and completed before the peak building dp was reached. A, additionally, when one train was running, the building dp was not permitted to stabilize after an initial entry l resulted in pressurizing the building above the test pressure. As a result, only one relatively well built individual gained access through the door at the test dp. Finally, problems with the test were not appropriately communicated to plant management, who had believed that the test was successful (Section O2.2).

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Overall, plant material condition was generally good. However, several significant material condition problems still challenged the plant, including excessive main generator hydrogen leakage, main turbine steam leakage, a failed emergency response information system computer, an inoperable postaccident sampling system, excessive dp across the j auxiliary building due to high suction from the SGTS, and an inoperable control building i i

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-2-heating, ventilation, and air conditioning (HVAC) chiller. Conversely, a suppression pool pumpback pump was repaired and returned to service (Section M2.1).

. Petcock valves on maintenance actuators for containment purge and ventilation Dampers HVR-AOV-128, -165 and -166 were not appropriately controlled and were not positioned in accordance with requirements contained in plant drawings. Consequently, the mispositioning of one of the petcock valves resulted in rendering Damper HVR-AOV-165 inoperable. The lack of controlled procedures precluded opportunities to identify this problem prior rendering the damper inoperable (Section M8.1).

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Corrective actions to address the long-standing problem of accessing the auxiliary building due to excessive SGTS induced dp were minimal and untimely. The primary corrective measure (a feasibility study to evaluate potential solutions) was not funded at the close of the inspection period (Section O2.2).

. Engineers demonstrated poor attention to detail when they utilized an inappropriate section of a design specification to accept smaller than permitted instrument sensing lines for flow meters, Lines of 3/8-inch diameter were utilized in some cases and the minimum size permitted by documents referenced by the specification was 1/2-inch diameter (Section E8.1)

Plant Suonoit l

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Housekeeping was considered good (section 02.1).

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Report Details Summarv of Plant Status l

The plant was in Operational Mode 1 at 100 percent reacter power for essentially the entire inspection perio l. Doerations  !

01 Conduct of Operations

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01.1 General Comments (71707)

The inspectors reviewed ongoing plant operations. The conduct of operations was generally professional and safety-consciou i O1.2 Ooerations Resoonse to Control Rod Drive (CRD) System Malfunction .

i Insoection Scooe (71707)

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A minor event resulted when a CRD control circuit power supply failed. The inspector observed the operator response to the even Observations and Findinas On February 4,1998, at 6:20 a.m., operators responded to a " charging water low pressure" alarm. Operators also noted that all CRD flows and pressures were indicating down scale. A loss of charging water to the accumulators would result in accumulator depressurization and a Technical Specification (TS) required plant shutdow A few minutes later, operators noticed higher than normal temperature readings for some of the CRDs (which indicated a reduction in cooling water to the drives). Subsequently, flow control Valve CRD-FCV-F002A was found in the failed closed position and the fuse to the control circuit power supply was found blown. By 6:44 a.m., operators had taken manual control of the valve in the field. Valve CRD-FCV-F002A normally maintains constant flow to the CRDs, with the balance of flow going to the accumulators. In response to a scram the valve fails closed, diverting flow to recharge the CRD accumulators. Later the same day, the faulty CRD power supply was replace The inspector considered the operators to be responsive to the event, which minimized .

the impact to the plant. Problem identification and compensatory actions were very prompt.

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2- Conclusions Operations' response to a CRD control valve failure was prompt and effective. The flow control valve failed closed and operators effectively established manual control in the fiel O2 Operational Status of Facilities and Equipment O2.1 Enaineered Safety Feature System Walkdowns (71707. 71750)

The inspectors walked down accessible portions of the following safety-related systems:

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High Pressure Core Spray j

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Residual Heat Removal (RHR), Trains A, B, and C l

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Reactor Core isolation Cooling i a

Division I, ll, and ill Switchgear and Battery Rooms

. SGTS Trains A and B

- Standby Service Water System Trains A and B The systems were found to be properly aligned for the plant conditions and in generally l good material conditio l During the plant tours, housekeeping was considered good. In a few minor instances tools were not properly stowed and in one instance a ladder was not properly secure .2 SGTS Performance Insoection Scooe (71707. 37551. 61726) I I

NRC Inspection Report 50-458/97-08 documented SGTS system decian problems in that I the system established an excessive negative pressure in the auxiliary bu? ding, resulting in dp between the auxiliary building and atmosphere. The excessive dp hangered entry into the auxiliary building by making the auxiliary building doors difficult to open. During this inspection period, the inspector reviewed the licensee's progress toward correcting ,

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this proble Observations and Findinas

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l Background: Difficulty accessing the auxiliary building during SGTS operation has been a long-standing problem at River Bend. Following a reactor scram on December 8,1994,

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L a chemistry technician and a nuclear equipment operator (NEO) could not open three different auxiliary building doors due to excessive dp across the building (both trains of l the SGTS were running). The individuals eventually entered the building through the 70

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foot elevation door (it opened inward) but did not attempt to exit the same door because of personal safety concerns (the door rapidly swung open during the entry and caused l

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damage to the adjacent concrete wall). The individuals called the control room and requested that one train of the SGTS be secured. They remained in the building until a  !

control room operator accomplished the task, approximately 30 minutes later. The delay l in exiting the auxiliary building contributed to the failure to meet TS chemistry sample l timeliness requirements (see NRC Inspection Report 50-458/94-20). l i

NOTE: The 70 foot elevation door is located in the auxiliary building stairwel Once the door is opened, the stairwell pressure tends to equalize with auxiliary building pressure, which makes door closure easie Following a reactor scram on May 6,1997, an NEO attempted to enter the auxiliary  ;

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building. His first attempts were unsuccessful due to the high dp across the doors. He then requested that one train of the SGTS be secured, but operators did not immediately i secure the train (securing one train of the SGTS is not immediately required by  ;

procedures). The NEO eventually entered the building through the 70 foot elevation doo l As documented in Condition Report (CR) 97-0281, on April 15,1997, two personnel strained their backs while attempting to open a 123 foot elevation auxiliary building door i during SGTS testin '

in May 1997, the NRC inspectors expressed concern about auxiliary building accessibility (NRC Inspection Report 50-458/97-08). The most limiting scenario involved implementation of Abnormal Operating Procedure (AOP) 31, " Shutdown from Outside the Main Control Room," where operators are required to enter the auxiliary building and take compensatory measures while two trains of the SGTS are in operation. Additionally, the normally open recirculation damper on one train is assumed to fail closed due to a hot short (from a control room fire), which would further maximize the dp across the buildin Licensee Evaluations: The licensee had initiated two CRs to address the above l concern (CRs 97-526A, SGTS damper alignment issues, and 97-0703 AOP-31 '

concerns). Corrective actions for CR-0703 were eventually integrated into CR 97-526 In short, the licensee concluded that a fire in the control room (a low probability event)

was the only occasion when entry into the auxiliary building may be hampered by excessive dp across the doors. A chain-fall was installed at the 95 foot elevation door to aid operator entry (to perform AOP-31 actions). A crowbar was installed on the opposing side of the door as an operator aid in exiting the buildin As additional corrective measures: (1) AOP 31 was revised to prompt operators about potential auxiliary building access problems; (2) operators were trained on the change to AOP-31 and the use of the chain-fall and crowbar; (3) operations personnel performed testing and demonstrated that the use of the chain-fall increased operator response time by approximately 20 seconds; and (4) on July 31,1997, a request for funding a feasibility study was initiated. The feasibility study was needed to evaluate potential solutions for the excessive dp problem.

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Recent NRC Observations Corrective Actions: During this inspection period, the inspector observed that the previously noted feasibility study was not funded and little progress had been made '

toward resolving the SGTS performance problem. The licensee stressed that a purchase order was written to update computer models that could be used in support of a related TS change. However, the inspector determined that, originally, the initiative was linked to other projects and problems. While the models could be used to perform analysis in i

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support of a TS change, the licensee had not yet determined that a TS change was necessary or desire Accessibility of the Auxiliary Building: The inspector determined that accessibility into the auxiliary building may be hampered due to excessive building dp when only one train of the SGTS is in operation. This could affect additional emergency operating procedures (EOPs) and AOPs in addition to AOP-31. Furthermore, both trains of the SGTS would be in operation during the initialimplementation of several EOPs and AOPs. The conclusions were based on the following:

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. The licensee's calculation contained in CR 526A had concluded that 260 pounds of force were required to open the 95 foot elevation auxiliary building door (the smallest door), assuming a dp of 4.0 inches W.G. However, the inspector reviewed SGTS test results and found that the assumed dp (4.0 inches W.G.)

corresponded to 1 train of the SGTS in operation. The calculation did not address '

two trains in operation. The licensee had not demonstrated that all Operations personnel (or other persons responding during an event) could exert this amount of force on an auxiliary building door. Furthermore, other doors were larger and would require even more force to open. The most convenient door for accessing the auxiliary building is a door at the 123 foot elevation, which is a larger doo Calculations performed to evaluate the structuralintegrity of the chain-fall and door handle used more conservative assumptions for building dp (6.0 inches with two trains in operation and 7.0 inches W.G. with an additional recirculation damper failed closed). While the calculations still underestimated the building dp for the conditions, a sizable factor of safety was utilized. As such, the inspector had no concerns with respect to the structuralintegrity of the chain-fall and doo . As part of the licensee's initial review of the issue, two members of engineering management attempted to open two auxiliary building doors with one train of the SGTS in operation (the 95 foot elevation door and the 123 foot elevation door).

While both individuals managed to open the 95 foot elevation door by applying considerable force, neither individual could open the 123 foot elevation door. The difficulty in opening the 123 foot elevation door was not reported to higher levels of management or Operations and was not evaluated. Misperceptions regarding the difficulty accessing the auxiliary building existe During an actual event, both trains of the SGTS would automatically star Although operators are permitted to secure one train of the SGTS, historically this step has not been promptly performed. For example, during the 1994 and 1997 events, operators did not secure a train of the SGTS until well after auxiliary building access was required. Since these events were relatively minor, the inspector concluded that it was not likely that one train of the SGTS would be secured during the initial phases of a more severe event; operators would be completing actions of higher priority firs Operations Survey: The inspector interviewed several members of the Operations staff to better understand Operations' understanding of the potential challenges to entering the auxiliary building. Persons interviewed included NEOs, reactor operators, control room supervisors, operations shift superintendents, and the assistant operations manager (AOM).

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Most individuals interviewed understood that the use of the chain-fall and crowbar would only be necessary for the implementation of AOP-31. Furthermore, most understood that entry into the auxiliary building would be achievable through any door with only one train of the SGTS in operatio .

When asked which door they would likely try to open first (while entering the auxiliary building in response to a major event) about half of the Operations staff stated that they would attempt to enter through the 123 foot elevation door, since it is the most convenient door. Others stated that they would attempt to enter the closest door to their location at the time. A few stated that they would likely attempt entry through the 95 foot elevation door because it was equipped with the chain fall, indicating that it might be needed. Only one individual realized that he would be assigned to the operations support center during an accident and stated that he would take the pathway specified by the health physics technicia !

. Approximately 50 percent of the interviewees were not readily familiar with the alternative method of entering the building if the 95 foot elevation door was unaccessible. Of the 50 percent that realized that the 70 foot elevation door opened inward (making building entry possibie), about half of those individuals ;

stated that they would not likely open the door because they were not confident that they could get it closed. They were concerned with maintaining secondary containment integrit . The responders were asked to state what actions would be required if they were unable to open an auxiliary building door (vital area door) while responding to an accident. Most believed that they would have initiated a security alarm and stated that they would contact security to have their key cards reset. The inspector questioned the security superintendent and was informed that an alarm would not be generated under these conditions. Furthermore, the individual would not be i

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locked out of the building and would be free to attempt entry through ancther door.

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As such, contacting security after a failed door entry would result in unnecessary l delay . When informed that access into the auxiliary building would require approximately l 260 pounds of force applied to one door, the AOM stated that this amount of force would only be required while two trains of the SGTS were in operation and with one of the recirculation dampers failed closed (this was consistent with the information contained in CR 526A). The AOM was previously involved with the disposition of CR 526A. Since the AOM was already familiar with the noted calculation, the inspector concluded that the inaccurate information in the document had misled the AOM into believing that the auxiliary building was readily l accessible for the implementation of all EOPs and most AOP As corrective action to the operators' lack of understanding of challenges to entering the auxiliary building, the licensee instructed the operators and other event responders that l the chain-fall at the 95 foot elevation auxiliary building door should be used for auxiliary building entry for any event in which the SGTS is in operation. Additionally, the pertinent i members of the license 6s staff were informed of the alternate method of entry into the I building, should access through the 95 foot elevation pathway become unavailabl These short-term corrective measures were acceptabl Auxiliary Building Accessibility Testing: On February 20,1998, Operations conducted a special test to evaluate the accessibility of the auxiliary building. Initially, two trains of the SGTS were started and operators attempted to open the 123 foot elevation doo None were successful. Additionally, two maintenance craftsmen were instructed to open ,

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and close the 70 foot elevation door to evaluate the safety hazards associated with operating the door. Concurrently, engineers were recording the peak building dp observed with two trains in operation. This information was not previously known. During the second phase of the test, one train of the SGTS was secured and the operators again attempted to enter the 123 foot elevation door. All but one operator opened the door. On the following day, the licensee informed the inspector that the evolution successfully i demonstrated that most operators could enter the building with one train of the SGTS in operatio The inspector observed the test and identified that the evolution was poorly coordinated,  !

I which minimized its value. Specifically, while two trains of the SGTS were running, door testing was initiated and completed and one train of the SGTS was secured before the peak building dp was attained. While one train of the SGTS was in operation (building dp 4.0 W.G.), the first operator was unsuccessful at opening the 123 foot elevation door. A second operator did manage to open the door. This entry into the auxiliary building l

resulted in a reduction in the negative dp, and the building dp was not permitted to re-establish or stabilize for the subsequent entries. Although successful, the subsequent i entries were made while the building was at a substantially lower dp (as low as 1.0 inch W.G. ). Operators then restarted the second train of the SGTS in order to obtain

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-7-maximum building dp information, which was observed to be 7.1 inches W.G. The inspector communicated these observations to one control room supervisor and one engineer, who were involved with the evolution. This information, however, was not considered when evaluating the test results. The inspector considered that the test results were of minimal value for demonstrating the accessibility of the auxiliary building with one train of the SGTS operatin NOTE: The 7.1 inches W.G. observed maximum dp does not bound the conditions described in the AOP-31 scenario. As mentioned previously, in that scenario both trains of the SGTS would be in operation and one of the recirculation dampers would fail closed. This would result in a greater dp than the 7.1 inches W.G. measured for two trains alone. Prior to the test, the licensee had assumed (based on engineering judgement) that the building dp would not exceed 6.0 inches W.G. with two trains in operation and 7.0 inches W.G. with an additional recirculation damper failed close Validation and Verification of EOPs: The inspector reviewed a sample of applicable EOPs and enclosures and identified that the documents did not contain appropriate guidance to minimize delays associated with auxiliary building entry while the SGTS was I in operation. Procedure OSP-0008, " Verification and Validation of Emergency Operating Procedures," Revision 8, states, in part:

This process in conjunction with validation is intended to address the following objectives . . . That EOP are usable; i.e., they can be understood and followed without confusion, dela . s, and errors . .

Since the licensee did not have reasonable assurance that auxiliary building entry could be accomplished through all auxiliary building doors following an event where the SGTS initiates, and operators were not generally aware that entry through some doors may not be possible (even with one train of the SGTS running), the EOPs and enclosures did not appear appropriately crafted to avoid the delays that may be experienced when operators fail to enter their first door of choice. The inspector had not completed inspection of the EOPs and AOPs at the close of the inspection perio Design Concerns: The inspectors identified several apparent design discrepancies with respect to the performance of the SGTS. As noted previously, following a design basis event, such as a loss of coolant accident (LOCA), one train of the SGTS will establish and maintain a negative pressure of 4.0 inches W.G. in the auxiliary building. However, this system response is not consistent with the Updated Safety Analysis Report (USAR). For -

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-8-USAR Section 6.2.3.3 states, in part:

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The results of the post-LOCA pressure response of the secondary containment system are shown on . . . Fig. 6.2-61b . . . for the auxiliary building . . .

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' USAR Figure 6.2-61b is a graph of auxiliary building dp versus time following a LOCA. This graph indicates that building dp stabilizes between negative 0.25 and negative .50 inches W.G. shortly after the initiating event and remains steady for the long-term system respons Furthermore, the system response as described in USAR Figure 6.2-61b was consistent with historical design documents. For example:

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System Design Requirements Document P50, " Standby Gas Treatment System,"

Revision 0, dated August 21,1987, states, in part:

A hand-operated recirculation damper is pre-positioned to maintain vacuum within the allowable range in the auxiliary building . . .

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Specification 216.300, " Specification for Air-Conditioning and Ventilation Systems

- Air and Hydronic Balancing, Subsystem (g) - Standby Gas Treatment,"

Revision 1, dated October 3,1985, states, in part:

Following an emergency . . 10,000 cfm is provided to maintain the Auxiliary Building at minimum -1/4 in. W.G. and maximum -1/2 i W.G. negative pressure relative to the outside atmospher Finally, auxiliary building access appeared to be an important consideration when the SGTS was designed. In response to a request to close the SGTS recirculation pathway, the following was contained in a June 25,1986, letter to the licensee from Stone and Webster Engineering Corporation:

The current damper design allows recirculation of excess air flow which is required to maintain the building at a negative pressure of 0.25 inches water gauge (WG). Designing this damper to stay closed will cause the I auxiliary building pressure to reach a negative pressure of approximately 9 in. WG. This would require a force of approximately 550 pounds to open the access doors. Post-accident access to the auxiliary building would

require shutting down the SGTS system in order to equalize the pressure i j on both side of the access doors to the auxiliary building. This would violate accident offsite radiation dose criteria, which is based on maintaining a continuous negative pressure in the auxiliary building and I

containment annulus during post accident condition '

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-9-At the close of the inspection period, the licensee had not provided pertinent design information to the inspector that would explain and justify the apparent deviations from the USAR and/or modification from the noted design requirement At the close of the inspection period, the inspector had not completed evaluations of EOP/AOP acceptability and the SGTS design. These issues will be considered unresolved pending further NRC review (URI 50-458/9804-01).

c. Conclusions Corrective actior.s to correct the long-standing problem of accessing the auxiliary building during SGTS operation were minimal and untimely. The primary corrective measure (a feasibility study to evaluate potential solutions) had not been funded at the close of the inspection perio Operations and Engineering erroneously concluded that only one AOP and no EOPs could be impacted by SGTS induced dp across the auxiliary building. The actual operation of the SGTS following an event and the force required to open doors with one train of the SGTS in operation were not appropriately considered in the evaluation Errors made in one calculation resulted in significantly underestimating the force required to open door Several months ago, while investigating auxiliary building access problems, licensee personnel failed to inform upper management and Operations of difficulties entering auxiliary building doors while one train of the SGTS was running. At the time, each individual attempted, but failed, to open the 123 foot elevation auxiliary building doo Consequently, there was a lack of understanding regarding the difficulty of accessing the auxiliary buildin Operators were not generally aware that special actions to gain entry into the auxiliary building may be necessary at any time the SGTS is running (even one train).

Furthermore, approximately 50 percent of the operators were not readily aware of a backup method of gaining access into the auxiliary building should radiological conditions, or a door failure, preclude access through the 95 foot elevation auxiliary building doo EOPs and most AOPs did not contain clarifying information to preclude potential delays caused by building accessability problems. Corrective measures to address the immediate concerns were acceptabl A special auxiliary building accessibility test was poorly coordinated, which minimized the value of the test. Specifically, when two trains of the SGTS were running, door testing was initiated and completed before the peak building dp was reached. Additionally, when l one train was running, the building dp was not permitted to stabilize before subsequent I individuals attempted entry through an auxiliary building door. As a result, only one l

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-10-individual effectively demonstrated the ability to gain access through the door at the maximum dp. Problems with the test were not appropriately communicated to plant managemen Miscellaneous Operations issues (92901)

08.1. (Closed) Violation 50-458/9602-03: failure to utilize at least one de-energized automatic isolation valve in 17 containment penetrations while shutdown in Refueling Outage 6 i The inspector determined that the corrective actions were acceptable, which included procedure revisions to ensure that penetrations were isolated with at least one deactivated automatic valv The inspector further noted, however, that the licensee had identified an inappropriate cause for the violation in their response to the NRC. The licensee responded to the violation in a letter dated April 22,1996, and stated that Licensee Event Report (LER) 96-006-00 documented the results of the root cause investigation. The cause, captured in LER 96-006, was attributed to poor wording of the TS Bases, which could permit l individuals to misinterpret the intent of the TS and TS Bases (implying that a violation did not occur). Furthermore, the LER stated that the procedure in question did serve to properly support the requirements of the TS. Contrary to what the licensee reported, the inspector determined that the actual cause for the violation was attributable to a failure of the licensee's staff to properly interpret the TS and TS Bases. Since, in the broader view of the issue, the licensee had incorporated appropriate procedural changes to prevent recurrence, the inspector considered the overall corrective measures to be acceptabl The above information is provided to correct information that the licensee had previously submitted on the docke !

i ll. Maintenance M1 Conduct of Maintenance M1.1 General Comments i Insoection Scoce (61726. 62707)

The inspectors observed portions of the following maintenance and surveillance activitie i

- Maintenance Action item (MAI) 315385, Diesel Generator Air Start System Air i

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Receiver Tank 1B Pressure Relief Valve EGA-RV5B Replacement and Testing i

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Plant Engineering Procedure PEP-0037, "CRD Performance Testing," Revision 7, Attachment 1, " Stall Flows /CRDs at Position 48" l

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MAI 315838, Special Evolution to Test Accessibility of the Auxiliary Building with

< the SGTS in Operation Observations and Findinos The performance of maintenance in a majority ofinstances was thorough and professional. Concerns with the coordination of MAI 315838 are discussed in Section O2.2 of this repor M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Review of Material Condition Durina Plant Tours Insoection Scoce (62707)

During this inspection period, the inspectors conducted interviews and routine plant tours j to evaluate plant material conditio Observations and Findinas

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Main Generator Hydrogen Leakage: Main generator hydrogen leakage continued to be high at greater than 3000 standard cubic feet per day. The identified leakage pathway was through the collector end generator seal and out of the roof vent. During this inspection period, the licensee installed a modification at the roof vent which effectively eliminated the potential for ignition of the hydrogen from an external source. A further worsening of this cond; tion could require a plant shutdown to support repair High Pressure Turbine Steam Leak: On February 15, the licensee identified water dripping on condensate bay piping at a rate of 50 to 100 drops per minut The water was believed to originate from a high pressure turbine steam leak, but the exact location of the leak was not known. The leakage has remained stable since initial identification. The licensee placed a video monitor in the control room to enable operators to frequently check the status of the leak and planned to perform more intrusive inspections during a scheduled power reductio .

Emergency Response Information System (ERIS): The ERIS * transient analysis" computer was out of service for the last week of the reporting period and had become relatively unreliable in the recent past. This computer provides information on the transitory behavior of many plant parameters following a transient or accident. A replacement computer has been on-site for approximately six months but was still being tested. The "real time" ERIS computer (used for plant information during an event) was still in service and was considered reliabl _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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Postaccident Sampling System (PASS): On January 12,1998, 'he PASS was removed from service to support a design change and a major system overhau The material condition of the system had been severely degraded and the system suffered relatively frequent and repetitive failures. Unavailability for the system was over 50 percent for the past 11 months. The risk associated with the long system outage was outweighed by the potential for greatly improved reliability and availability. The PASS is scheduled to be returned to service in early March 199 Excessive Auxiliary Building DP: The inspectors noted excessive dp across the auxiliary building when the SGTS was running. With only one train of the SGTS running, the dp (4.0 inches W.G.) was sufficient to hamper attempts at entering the building using normal methods. A detailed discussion of this problem is provided in Section O2.2 of this report. Entry into the auxiliary building is required to implement EOPs and AOP .

Control Building Chiller HVK-1 A: The chiller was taken out of service early this report period for chemical cleaning and remained out of service for the remainder of the report cycle. This chiller is one of two 100 percent chillers in the Division I control building HVAC system, which services multiple safety-related equipment rooms, including the control room. Loss of the chiller reduces the overall reliability of the HVK trai Material condition improvements included:

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Suppression Pool Pumpback Pump DFR-PSB: The subject pump failed inservice testing (IST) on December 22,1997, and was out of service until repairs were completed this inspection perio Conclusions Material condition concerns included main generator hydrogen leakage, main turbine steam leakage, a failed ERIS computer, an inoperable PASS, excessive dp across the auxiliary building due to high suction from the SGTS, and an inoperable control building HVAC chiller. A suppression pool pumpback pump was repaired and returned to servic M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Unresolved item (URI) 50-458/9719-02: HVR-AOV-165 found inoperabl During the performance of Surveillance Test Procedure (STP) 403-7301, " Containment Purge System isolation Valve Leak Rate Test," Revision 1, on January 8,1998, leakage

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through Damper HVR-AOV-165 was in excess of the capacity of the leak rate monitor (2000 secm). Further examination revealed that the maintenance actuator petcock valve was out of position (closed) and the actuator was partially extended. This prevented the i

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i-13-l damper from reaching the full closed position. The petcock was subsequently opened and the damper was observed to go to the fully closed position. The leak rate test was then successfully performe Petcock valves on Dampers HVR-AOV-128 and HVR-AOV-165 were also found closed, but did not affect their operability. Closure of the petcock valves alone did not render the dampers inoperable. The hydraulic actuators would also have to be manually operated (jacked) at least one time before the actuator pistons would extend and affect damper closur During this inspection period, the licensee completed the investigation into the event and believed that the petcock valves had been closed since 1994, when damper seal work was performed. The exact date that Damper HVR-AOV-165 became inoperable could not be determined. The damper had been previously leak rate tested approximately 90 days earlier. The cause of the event was determined to be inadequate controls for the positions of the petcock valves. Matryx Company Drawing 410318, dated October 10, 1980, required that the petcock valves be at least one turn open. No other documents controlled the position of the petcock valve As corrective measures, the licensee: (1) installed lockwires on the petcock valves to ensure that the valves could not be mispositioned; (2) added a note in the planner's computer data base instructing the planners to include a petcock restoration step in future work packages; and (3) planned to revise standard maintenance job plans to include a note requiring the petcock valves to be positioned one full turn open before returning the dampers to service. The inspector observed that the licensee had no plans to require reinstallation of the lockwire following maintenance where the lockwire might be remove ;

in response to the inspector's observation, the licensee revised the planned changes to l include such a requiremen NRC Assessment: While the January 8,1998, failure of Damper HVR-AOV-165 was identified through the licensee's surveillance testing program, the inspector considered the mispositioned petcock to be self-disclosing. It was not directly tested by the surveillance test and was not identified by multiple previous surveillance tests. The damper then became inoperable for an unknown time. These types of problems are of significant concer The inspector reviewed the licensee's evaluation and agreed with the licensee's root I cause. More specifically, however, the inspector considered the lack of controls to be contrary to the recommendations contained in Regulatory Guide 1.33, " Quality Assurance Program Requirements," which the licensee is committed to through the :

USAR. This Regulatory Guide endorses ANSI N18.7,1976/ANS 3.2, which states, in part:

I When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its

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-14-functional acceptability. Attention shall be given to restoration of normal conditions . . such as returning valves . . . to proper start-up or operating j positions . .

The licensee had not included restoration instructions for the petcock valves within the scope of any standing surveillance, maintenance, or system restoration procedure (such l as those used to establish system valve lineups prior to restoring operability, after an outage for example). Furthermore, Damper HVR-AOV-165 had been removed from service for maintenance and/or testing several times since 1994, but operating personnel did not check the position of the petcock valves prior to returning the damper to service in each of those instances. As a result, the petcock valves were in an inappropriate position for several years prior to the damper failur The failure to maintain the petcock valves in the open position when operating Dampers HVR-AOV-128, -165 and -166 in the safety-related mode, in accordance with the requirements of Matryx Company Drawing Number 410318, was a violation of 10 CFR Part 50, Appendix B, Criterion V, which requires the licensee, in part, to conduct activities affecting quality in accordance with drawings appropriate to the circumstances (Violation 50-458/9804-02).

M8.2 LGipsed) Violation 50-458/9615-03. Failure to Comolv with In-Service Test (IST) Vibration Requirements: The violation documented that the licensee did not comply with ASME/ ANSI OMa-1988, Part 6, and Procedure STP-256-6303, " Standby Service i Water 'A' Loop Quarterly Pump and Valve Operability Test," Revision 8. The ASME Code and the licensee's implementing procedure required that pump vibration readings be l taken and recorded on the upper motor bearing housing in three orthogonal directions, with one in the axial direction. Contrary to this requirement, workers obtained vibration readings on a lifting lug welded to the lower side of the pump motor covers (an unapproved location). The licensee attributed the violation to a lack of personnel accountability, inadequate procedures, lack of procedure adherence, and incomplete 4 trainin The licensee addressed personnel accountability with plant staff and provided training on procedure adherence and the use of the change notice process to plant engineering staff and individuals involved with IST surveillance. In addition, plant staff performed a walkdown of each pump in the IST program to verify correct vibration acquisition points for Code compliance. On December 30,1996, the licensee submitted Pump Relief Request PRR-006 to the NRC to request taking vibration measurements in alternate locations (due to configuration problems) on four standby service water pumps and three

diesel fuel oil transfer pumps. The NRC granted the relief request on April 28,1997. The licensee's corrective actions were acceptabl M8.3 (Closed) Viola _ tion 50-456/9616-03

failure to establish reference values prior to placing pump in service. The licensee had failed to establish new reference values and failed to

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-15-perform a valid IST prior to returning a spent fuel pool cooling pump to service. The pump was inoperable for 10 months because of low system flow, which was found to be caused by heat exchanger foulin As a corrective measure, the licensee revised Operations Policy 006 to require that operators document entry into a " Tracking Limiting Condition for Operations" document for an inoperable spent fuel pool cooling pump and to prohibit returning the pump to service before plant staff has determined the cause of the deviation and corrected it (which would include the performance of IST, when required). The licensee also briefed operators on this issue. The inspector considered the licensee's corrective measures acceptabl M8.4 (Closed) Unresolved item (URI) 50-458/9717-02: unexpected isolation of containment isolation valves during surveillance. Procedure STP-204-4802, "RHR System Isolation Logic System Functional Test," Revision 7, verified that certain containment isolation valves would isolats upon initiation of a test signal. During implementation, two containment isolation valves in the alternate deca / heat removal (ADHR) system unexpectedly isolated (RHS-AOV-63 and RHS-AOV-64). These containment isolation valves were part of the ADHR system modification that was made operational prior to the most recent refueling outag The licensee performed a root cause analysis and determined that the valves operated as designed but the procedure had not appropriately included the valves within the scope of testing. Additionally, the steps necessary to test the valves were included within the scope of Procedure STP-309-0602, " Division ll ECCS Testing," which was not the appropriate procedure for these particular tests. The following were found to be contributors to the event:

. Personnel responsible for the modification did not adequately evaluate changes necessary to support acceptable implementation in the operating plan Licensing personnel did not perform an appropriate review of the licending change documents and did not ensure that all appropriate departments reviewed the change . Written guidance for processing of license amendment requests did not provide detailed direction for conducting implementation review The licensee initiated a large number of corrective actions to address this event which, in part, included: (1) a review of all ADHR modification test activities: (2) revision of the affected surveillance procedures; (3) training of the staff to re-enforce expectations for licensing change reviews (as well as modification change reviews); and (4) development of a " user's guide," which will contain licensing change review guidance. The licensee's planned corrective actions were acceptable.

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Since TS required testing was accomplished, although by an undesirable procedure, no l violations of NRC requirements had occurred. However, poor coordination of surveillance activities in support of the modification resulted in the unexpected isolation of the containment isolation valves during surveillance testing, which was a significant distraction to operators. This aspect of the issue was previously addressed in NRC Inspection Report 50-458/97-17. This item is closed.

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_E8 Miscellaneous Engineering issues (92903)

M8.1 (Ocen) Insoector Followuo item (IFI) 50-458/9719-04: failure to comply with General Electric design specifications for flow meter instrument lines. This issue, in part, identified l an apparent discrepancy between the installation of flow meter instrument sensing lines i' and the requirements for installation contained in GE Design Specification 22A3137AA, Section 4.2.4.2, which states:

Installation and arrangement of differential head meters shall conform with the recommendations defined in Chapter II - 11 of ' Fluid Meters' for . . .

orifice and venturi type devices.. In no case shall the requirements of this specification be violated without specific GE Engineering approva I

! " Fluid Meters" recommends, in part, the following:

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. For connecting the primary element to the secondary element,1/2-inch tubing and fittings are recommended.

[ Contrary to this recommendation,3/8-inch tubing was utilized for portions of the I instrument line During this inspection period, River Bend engineers performed an evaluation and determined that the use of 3/8-inch tubing was acceptable based on information contained in Section 4.3.3.1.1 of GE 22A3137AA. Three individuals, including a design engineering supervisor signed the documen The inspector reviewed the licensee's evaluation and disagreed with the licensee's conclusion. Specifically, the information contained in Section 4.3.3.1.1 included generic requirements that applied to most instrument lines. However, the requirements for flow meter installation contained in Section 4.2.4.2 of the noted GE specification were above and beyond the generic minimum requirements for instrument lines. In evaluating the issue, engineers demonstrated poor attention to detai i i

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-17-In response to the inspector's continued concems, the licensee contacted GE for additional help. This item will remain open pending final resolution of this issue as well as other issues addressed by this IF V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the ,

conclusion of the inspection on February 26,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie )

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee J. P. Dimmette, General Manager, Plant Operations M. A. Dietrich, Director, Quality Programs D. T. Dormady, Manager, System Engineering T. O. Hildebrandt, Manager, Maintenance P. W. Chapman, Superintendent, Chemistry H. B. Hutchens, Superintendent, Plant Security D. N. Lorfing, Supervisor, Licensing J. R. McGaha, Vice President-Operations W. J. Fountain, Licensing Engineer W. P. O'Malley, Manager, Operations D. L. Pace, Director, Design Engineering A. D. Wells, Superintendent, Radiation Control INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support IP 92901 Followup, Operations )

IP 92902 Followup, Maintenance J IP 92903 Followup, Engineering (

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-2-ITEMS OPENED AND CLOSED Opened 50-458/9804-01 URI Standby Gas Treatment System Performance issues 50-458/9804-02 VIO Failure of Containment isolation Damper HVR-AOV-165 Closed 50-458/9602-03 VIO Failure to Establish Proper Containment isolation .

50-458/9615-03 VIO Failure to Comply with inservice Testing (IST) Vi' oration Requirements 50-458/9616-03 VIO Failure to Perform IST for Spent Fuel Cooling Pump 50-458/9717-02 URI Failure of containment Isolation Damper HVR-AOV-165 Discussed 50-458/9719-04 IFl Apparent Failure to Comply with Design Specification for Flow Meter instrument Lines

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i-3-LIST OF ACRONYMS USED ADHR alternate decay heat removal ;

ANS American Nuclear Society '

ANSI American National Standards institute AOM assistant operations manager AOP abnormal operating procedure ASME American Society of Mechanical Engineers CFR Code of Federal Regulations ,

CR condition report  !

CRD control rod drive dp differential pressure EOP emergency operating procedure l ERIS emergency response information system i

.HVAC heating ventilation and air conditioning ,

IFl inspector followup item l lST inservice testing LER Licensee Event Report  !

LOCA loss of coolant accident I

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mal maintenance action item NEO {

nuclear equipment operator i

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NRC U.S. Nuclear Regulatory Commission PASS postaccident sampling system PD public document room l RHR residual heat removal l sccm standard cubic centimeters per minute j SGTS standby gas treatment system '

STP surveillance test procedure TS Technical Specifications  !

l URI unresolved item l l, USAR Updated Safety Analysis Report l i VIO violation i water gage

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