ML20153E405
| ML20153E405 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/30/1988 |
| From: | Bundy H, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20153E368 | List: |
| References | |
| 50-458-88-18, NUDOCS 8809060316 | |
| Download: ML20153E405 (8) | |
See also: IR 05000458/1988018
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report:
50-458/88-18
Operating License:
Docket:
50-458
Licensee:
Gulf States Utilities (GSU)
P.O. Box 220
St. Francisville, Louisiana 70775
Facility Name:
River Bend Station (RBS)
Inspection At:
RBS, St. Francisville, Louisiana
Inspection Conducted:
August 8-12, 1988
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Inspector:
H.F.Bungf,ivisionofBeactorSafetyReactorInfpector,TestPrograms
Date
Section, D
Accompanying
Personnel:
R. V. Azua, Reactor Inspector, Test Programs
Section, Division of Reactor Safety
Approved:
/be// A
W. C. Seidl
Chief, Test Programs Section
Date
Division of eactor Safety
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Inspection Summary
Inspection Conducted August 8-12, 1988 (Report 50-458/88-18)
Areas Inspected:
Routine, unannounced inspection of surveillance procedures
and records.
Results:
The surveillance testing program appears functional.
The
surveillance testing procedures (STPs) are generally adequate; however, some
- ta sheets could be improved and betcer cross-referencing to the applicable
gDRsO9060316 esopoi
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ADOCK 0500o433
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Technical Specifications should be made.
There appeared to be an excessive
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number of changes and test exceptions on completed STPs, particularly in the
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instrumentation and control area.
This suggested that the procedure
verification process could be icproved.
One violation involving failure to
properly evaluate and document surveillance test results was identified
(paragraph 2).
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DETAILS
1,
Persons Contacted
GSU
- J. E. Booker, Manager, RBS Oversight
- T. F. Plunkett, Plant Manager, RBS
- P. D. Graham, Assistant Plant Manager, Operations
- J. Hamilton, Director, Design Engineering
"L. England, Director, Nuclear Licensing
- H. F. Sankovich, Manager, Engineering Department
- 0. R. Derbonne, Assistant Plant Manager, Maintenance
- H. J. Huff, Supervisor, Operational Planning
A. Frediem Operations Supervisor
- R. J. King, Supervisor, Nuclear Licensing
T. Murphy, Supervisor, Planning and Scheduling
D. Jernigan, Supervisor, Instrumentation and Control
D. B. Reynolds, Supervisor, Administrative Support
J. Venable, Assistant Operations Supervisor
- J. H. McQuirter, Licensing Engineer, Nuclear Licensing
- C. L. Miller, Senior Compliance Analyst
- K. F. Kennedy, Coordinator, Plant Permanent File
- C. W. Walling, Senior Mechanical Engineer, Field Engineering
- J. E. Spivey, Senior Quality Assurance (QA) Engineer
J. D. Davis, Senior QA Engineer
NRC
- E. J. Ford, Senior Resident Inspector
W. B. Jones, Resident Inspector
Others
- W. L. Curran, Site Representative, Cajun Electric Cooperative
The NRC inspectors also interviewed other licensee employees during the
course of the inspection.
- Denotes those present during the exit interview held on August 12, 1988.
2.
Surveillance Procedures ar.d Records (61700)
The purpose of this inspection was to ascertain whether the surveillance
of safety-related systems and components was being conducted in accordance
with approved procedures as required by the Technical Specifications (TS).
Pursuant to this objective, the NRC inspectors reviewed the following
licensee documents:
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Administrative Procedure (ADM)-0015, Revision 12. "Station
Surveillance Test Program"
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RBS TS Surveillance Test Procedure (STP) Cross Reference Matrix dated
January 21, 1988
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Surveillance Test Scheduling and TrackinJ Systre Schedule Log from
August 7-28, 1988
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Missing Surveillance Resulting in Licensee Event Report (LER) dated
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March 11, 1988
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The RBS supervisor of operational planning dencribed the following
vehicles for followup on TS surveillance test deficiencies:
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Formal review of a limiting condition for operation report on
Mondt15, Wednesdays, and Fridays
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Twice per-day meetings to review overdue TS required surveillance
tests
The NRC inspectors then selected certain TS surveilvance requirements and
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reviewed the associated licensee STPs and an appropriate number of test
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results records for each procedure.
Also selected test personnel were
verified to have appropriate certification.
The TS surveillance
requirements, together with the associated STPs reviewed by the NRC
inspectors, are tabulated in the Attachment,
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The NRC inspectors determined that the required tests were being scheduled
and performed as required in accordance with approved procedures.
Acceptance criteria were specified in the nroc6dures and, with the
exception discussed below, the records stated satisfaction of acceptance
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criteria.
Appropriate instructions for returning equipment to service
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following testing were given. With the exceptions discussed below, there
was evidence that surveillance tests were being properly etaluated and
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documented.
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The following observations were made by the NRC inspectors:
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The STP data sheets should be more explicit on data requirements in
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some instances.
For example, in completing STP-000-0201, Datt
Sheet 1 most of the performers were writing their initials in the
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column entitled POSITION.
However, one performer wrote in the
observed valve positions.
Insertion of both valve positions and
initials would have been appropriate,
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There appeared to be an exce*,sive number of test change notices (TCNs)
and test exceptions on completed STPs, particularly in the
instrumentation and control area.
For some STPs, almost every
page was affected.
This frequently made it difficult to interpret
data.
It appeared that many of these TCNs and test exceptions could
have been avoided with a better procedure verification process.
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The STPs did not always properly reference the TS to which they were
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responsive.
For example, STP-203-0602 indicated satisfaction of
However, the cross reference matrix also required
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completion of STP-309-0603 to satisfy TS 4.5.1.d.
The cross
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reference matrix required completion of STP-309-0603 for satisfaction
of TS 4.7.1.1.b.
However, TS 4.7.1.1.b is not mentioned in
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STP-309-0603.
In each instance, the cross reference matrix was
verified correct.
In most instances, Section 8, "Acceptance
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Criteria," of the STP did not reference the TS which were satisfied.
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As a result of most TCNs, several pages were added to most
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procedures.
The added pages were usually placed after that page to
which the changes were being made.
These added pages were given the
same number, but with a suffix such as la, Ib, and so on.
The NRC
inspectors noticed that even though these pages were added, the
pagination for the overall document was usually not changed to
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accommodite them.
This led to a situation where there were more
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pages in a document than were listed in the page count total. This
pagination method could allow missing pages to go undetected and lead
to situations where incomplete documents are filed or are sent for
review with critical data missing.
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The following STP deficiencies identified by the NRC inspectors are
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examples of an apparent violation of 10 CFR 50, Appendix B, Criterion XI,
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"Test Control," which states, in part, ". . . Test results shall be
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documented and evaluated to assure that test requirements have been
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satisfied."
(458/8818-01)
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a.
In reviewing STP-051-4210. "RPS/RHR Reactor Vessel Steam Dome
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Pressure-High," which was performed and completed on October 13,
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1987, the NPC inspection noted that page 24 lacked initials for each
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line ites.
It was also noted that the page was stamped with the date
"March 8, 1988" which was 5 months after the test was performed.
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NRC inspectors inquired about this and were told by personnel at
Permanent Plant Files (PPF) that when they originally received the
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document, it was noted that the page was missing.
The whole document
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was returned to the sender.
Attached to the document was a "Request
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for Correction" which stated that page 24 was missing.
The clerk
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that received the document apparently did not attempt to locate the
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original test page, but instead, replaced the missing page with a
blank copy and stamped it with the date on which it was sent back to
PPF.
This is the test package that was finally placed in the PPF.
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Due to the absence of page 24, it was not possible to ascertain that
the test results had been properly documented in accordance with
Criterion XI.
The preliminary response by the licensee included the
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following:
(1) STP-051-4210 was reexamined to determine that the steps listed
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in the missing page did not have safety significance which would
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have required reperformance of the test.
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(2) The Assistant Plant Manager for Maintenance generated
interoffice memorandum APM-M-88-297.
The Memorandum called on
all personnel to return documents, which have missing pages, to
the appropriate discipline supervisor.
The supervisor will
evaluate the significance of the missing data to determine if it
is required to indicate successful completion of the work.
If
the missing page is found to have significant results, the
supervisor will initiate immediate actions to reperforn the
work,
b.
Test exceptions were written for performance of Sections 7.3.4 and
7.5.4 of STP-403-0601, "Standby Gas Treatment System Annulus Mixing
System Functional Tests." This STP was completed on December 18,
1987.
Completion of these sections was required by Acceptance
Criterion 8.4 of STP-403-0601.
Writing test exceptions on an
acceptance criterion resulted in noncompliance with Criterion XI
implementing documents as follows:
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Section 8.3.1 of ADM-0015 prohibits writing a test exception on
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an acceptance criterion.
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Failure to revise STP-403-0601 in accordance with ADM-0015
constituted failure to initiate appropriate corrective action in
accordance with Section 17.2.11. "Test Control," of the RBS
Updated Safety Analysis Report.
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The adequacy of the system to meet the specified requirements in
the acceptance criteria was not revealed by the recorded data as
required by Quality Assurance Directive-11.
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A preliminary review of this test package by the licensee indicated
that none of the required responses excepted were safety significant.
c.
The data and calculation for the average stroke rate of
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Valve 1833-HYVF0 GOB timed in Step 7.4.12 of STP-053-0601, "Recirc
Flow Control Valve Operability Test," was not included in the data
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package completed on October 24, 1987, as required by Criterion XI
and Implementing Document ADM-0015 Section 8.6.
No further violations or deviations were identified.
3.
Exit Interview
The NRC inspectors conducted an exit interview on August 12, 1988, with
the licensee personnel denoted in paragraph 1.
At this meeting, the scope
and findings of the inspection were summarized.
The licensee did not
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identify as proprietary any of the materials provided to, or reviewed by,
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the NRC inspectors during the inspection.
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ATTACHMENT
PROCEDURES AND RECORDS REVIEWED
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TS
Description
STP-Number
4.1.3.11b
Verify scram discharge volume drain
052-3301, R2
and vent valves operable by cycling
4.2.la
Daily verification that APLHGR is
000-0001, R9
2 limits
4.3.1.1,
Channel calibration for reactor vessel
051-4209,' R4
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Table 4.3.1.1-1
steam dome pressure-high
051-4210, R4
Item 3
051-4211, R6
051 4212, R5
4.3.2.2
Isolation Actuation Logic System
051-4253, R7
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Functional Test
051-4250, R5
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051-4249, R5
051-4248, R6
051-4247, R6
051-4235, R6
051-4234, R7
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051-4233, R6
051-4232, R8
051-4227, R6
051-4226, R9
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051-4225, R6
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051-4223, R6
051-4224, R6
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051-4254, R7
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051-4222, R7
4.4.1.lb
Verify rate of opening or closing for
053-0601, R2
recirculation loop flow control valve
is 2 11 percent per second
4.4.1.2
Determine jet pumps are operable
053-3001, R3
4.5.1d
For HPCS, verifv suction is automati-
203-0602, R2
cally transferred from condensate
309-0603, R7
storage tank to suppression pool under
specified conditions
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4.5.1 e 2
Manually open ea:h A05 valve with steam
202-06202, R4
pressure 5100 psig and verify proper
responses
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4.6.1.lb
Verify closure of primary containment
000-0201, RIO
penetrations at least once per 31 days
4.6.3.2c
Perform system functional test for
309-0601, R6
primary containment unit coolers
309-0602, R4
4.6.5.5b
Verify each shield building annulus
403-0601, R3
mixing systeA operable by performing
system functional test
4.7.1.lb
Verify standby service water system
309-0601, R6
subsystems operable by verifying each
309-0602, R4
automatic valve actuates to correct
309-0603, R7
position and each pump starts on low
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4.7.3c
Verify RCIC system operable by performing
209-0601, R2
system functional test
4.7.6.1.1
Cycle each testable valve in the fire
251-3502, R4
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suppression water system through at
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4.7.6.5c
Perform inspection of yard fire hydrants
251-3501, R3
and hydro associated hoses
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4.8.1.1.2.f.7
Verify that, upon an ECCS actuation
309-0601, R6
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signal, all automatic diesel generator
309-0602, R4
trips are auto bypassed except engine
309-0603, R7
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overspeed and generator differential
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current
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4.8.2.lc
Verify for each 125V battery and charger:
203-1602, R3
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No visual battery damage
305-1600, R3
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Cell-to-cell and terminal connections
305-1601, R2
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are clean and tight
203-1605, R4
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Terminal resistance 5150 X 10
ohm
305-1603, R3
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Battery chargers will supply minimum
305-1604, R3
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