ML20244C356
| ML20244C356 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 06/05/1989 |
| From: | Barnes I, Ellershaw L, William Jones, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20244C346 | List: |
| References | |
| 50-458-89-18, NUDOCS 8906140230 | |
| Download: ML20244C356 (9) | |
See also: IR 05000458/1989018
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
~ NRC Inspection Report: 50-458/89-18
Operating License: NPF-47
Docket: 50-458
' Licensee: Gulf States Utilities Company
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Facility Name: River Bend Station
Inspection At: River Bend Station, St. Francisville, Louisiana
Inspection Conducted: May 1-5 and 15-19, 1989
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Inspectors:
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R. G. Stewart.Tsactor Inspector, Materials
Date
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and Quality Programs Section, Division of
Reactor Safety
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4. Allershaw, Reactor Inspector, Materials
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andquality Programs, Division of Reactor
Safety
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Sect n C, Division of Reactor Projects
Approved:
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, Chiet, Materials and Quality
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Pfogr ms Section, Division of Reactor
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Inspection Summary
Inspection Conducted May 1-5 and 15-19, 1989 (Report 50-458/89-18)
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- Areas Inspected: Routine unannounced and announced inspection of the River
Bend. inservice testing (IST)-program for pumps a'nd valves; witnessing of
welding activities associated with repairs to the service water system;
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and: review of your activities resulting from your self-initiated safety system
functional inspection (SSFI) of the instrument air system (IAS) conducted
during the period November 17, 1988, through January 20, 1989.
Results:~ -Within the areas' inspected, two apparent violations were identifi.ed
involving the failure to ensure the operability-of safety-related IAS
subsystems in the control building as required by Technical Specifications
(paragraph 3), and the failure to report the inoperability of the fuel building
HVAC isolation dampers found to be incorrect during the SSFI (paragraph 4).
In general, the NRC inspectors observed that the licensee's SSFI of the IAS
appears to have been' a significant undertaking deservir.g commendable. notice.
However, the apparent violations and the licensee's internal. responses to
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- their SSFI' findings needs to improve their engineering evaluation process for
determining safety system operability,
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DETAILS
1.
' Persons Contacted
GSU
-*J. C. Deddens Senior Vice President
4T. F. Plunkett, Plant Manager
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4*M. F. Sankovich, Manager, Engineering Department
+T. L. Crouse, Manager, Quality Assurance
+*K. F. Suhrke, Manager, Project Management
+*J. E. Booker, Manager, River Bend Oversight
+*L. A. England, Director, Licensing
+W. H. Odell, Manager, Administration
- J. R. Hamilton, Director Design Engineering
+*J. W. Cook, Lead Environment Analyst - Licensing
+*J. P. Schippert, Operations
- R. E. Buell, Design Engineer
- J. W. Leavines, Director Field Engineering
+*C. L. Millar, Senior Compliance Analyst
- D. A. Shelton, Nuclear License Engineer
4*G. K. Henry, Director Quality Operations
- D. L. Andrews, Director, Nuclear Training
+*W. L. Curran, Site Representative Cajon Electric
- P.
,E.
Freehill, Plant Staff
- J. J. Pruitt. Director, Management, Systems
4*W. J. Fountain, Senior Quality Assurance Engineer
+*I. M. Malik Supervisor, Quality Systems
- J. L. Burton, Supervisor, ISEG
+D. R. Derbonne, Operations Maintenance
+C. A. Rohemann, Training Systems Coordinator
+C. B. Mermigas, Project Engineering Coordinator
NRC
+*E.
J. Ford, Senior Resident
+*W. B. Jones, Resident Inspector
+D. D. Chamberlain, Section Chief, Projects Division
+D. R. Hunter, Reactor Inspector
+J. R. Boardman, Reactor Inspector
- W. M. McNeill, Reactor Inspector
- Denotes attendance at the exit interview conducted on May 19, 1989.
+ Denotes attendance at the exit interview conducted on May 5, 1989. The
NRC inspectors also interviewed other licensee employees during the
inspection.
2.
Welding-Observation of Work Activities
(55050)
During the period May 1-S, 1989, the NRC inspector reviewed the licensee's
program for controlling safety-related welding activities to assure that
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- welding is controlled and accomplished by. qualified personnel >using
qualified proceduresiin accordance with applicable codes and standards."
The following licensee documents were included in:the review:,
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Procedure SPP-70017 Revision 2. " General Welding Procedure ASME/ ANSI"
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Procedure ENG-3-003,' Revision 1. " Repair / Replacement Program"'
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. Procedure SPP-7009, Revision N. " Storage, Handling, and Issue Filler
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Materials"
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Procedure SPP-7010. Revision 3. " Preparation of Weld Data Sheets"
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Welding Procedure ' Specification, WPS-NO. W3-01, Revision 4 '
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- Although limited welding was in progress:during the inspection period, the
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NRC inspector. observed welding' activities associated with repairs to the
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service water system. Observations were made of weld buildup over an
area of minimum wall thickness on service water'line SWP-008-092-B, weld
X1FW-0012(DWG X1-SWP-092CDB). . The NRC inspector observed that' the welding
. as being conducted under Maintenance Work Order (MWO) R127530. The weld
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data sheet was correctly reflecting weld requirements and step-by-step
-processes QC hold points.
.The NRC inspector had no outstanding questions at the conclusion of the
welding process.
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No violations or deviations were identified.
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3.
IST Program Review (73756)
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During the week of May 1-5, 1989, the'NRC inspector reviewed the IST
-program relative to the testing requirements of the ASME Section III,
Class 13 portion of the instrumentation system (IAS) located in the control
building, fuel building, and auxiliary building. This included the
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solenoid operated valves-(SOVs), check' valves, and accumulator tanks.
As recuired by Article IWV-2000 in Section XI of the ASME Code, the
licensee has categorized the'IAS SOVs as Category B valves (valves for
which seat leakage in the closed position is inconsequential for
fulfillment of their function) which are stroke time tested only. The
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companion check valves are categorized as Category C valves (valves which
are self-actuating in' response to some system characteristic, such as
pressure'(reliefvalves)orflowdirection(checkvalves))whichare
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. exercise tested only. These categories include valves for which seat
' leakage is not limited to a specific maximum amount in the closed position
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in order to fulfill their function. The specific valves are as follows:
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IAS Control Building
IAS Auxiliary Building
IAS Fuel Building
IIAS-SOV36A
IIAS-50V45A
IIAS-50V41B
IIAS-SOV45B
IIAS-V562
11AS-V515
IIAS-V563
_IIAS-V609
The NRC inspector observed IST being performed on the accumulators, SOVs,
and the check valves. At that time, the NRC inspector was informed that
the IST was a retest resulting from the identification that tt.e 50Vs had
been improperly installed. Furthermore, this condition was also>
identified in the auxiliary building and control building.
It appears
that these valves had been installed incorrectly during construction.
In
any' event, upon identifying this condition, the licensee removed and then
correctly reinstalled the S0Vs in order to meet their design function. As
a result of making the S0V correction, the IST procedure was revised.
However, as the IST was being performed, it was noted that the revised
procedure was still not adequate; thus the IST was terminated.
4.
'The NRC inspector requested the documentation associated with the
. incorrect installation of the 50Vs.
Review of Condition
Report (CR) 89-0428 dated April' 10, 1989, revealed that the incorrect
installation would not isolate the associated air accumulators. The 50V
failure analysis stated that the 50Vs would provide positive isolation,
even if installed incorrectly, provided a positive closure check valve was
installed and the check valve had zero leakage.
The analysis then addressed the fact that positive closure Check
Valve 11AS*V514 in Division II leaked and could not hold reverse pressure.
It was concluded, that while this check valve leaked, the event was not
reportable since Check Valve 11AS*V515 in Division I passed the IST
functional test; therefore Division I remained operable.
However, the NRC inspector noted that Maintenance Work Order
Requests (MWORs) were attached to the CR. MWOR 124642 dated April 6,
1989,'showed that Check Valve lIAS*V514 (Division II) was leaking and
repairs were required.
In addition, NWOR 127972 dated April 12, 1989,
revealed that Check Valve lIAS*V515 (Division 1) was also leaking. The
applicable MW0s showed that the work on the two check valves was completed
on May 5, 1989. Therefore, the fact that both check valves were leaking
and the SOVs were incorrectly installed does not appear to be consistent
with the engineering analysis contained in the CR which stated that
Division I was operable. The NRC inspector further noted that the IST
(STP-122-3301) performed on Check Valve 11AS*V515 was in accordance with
paragraph IWV-3412 in Section XI of the ASME Code, which is an exercise
test end not a positive closure leak rate test.
It is more tht.n likely
that this condition may have existed for quite sometime since it was
subsequently noted during the week of May 15-19, 1989, that a finding
identified by the SSFI team indicated that the safety-related IAS
. subsystems in the control building, fuel building, and auxiliary building
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had not undergone preoperational and periodic functional testing.
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Section 9.3.1.1.2 in the River Bend USAR states in part, " Supplementary
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. ASME'!II . . . accumulator tanks are provided to ensure adequate air
supply to dampers in the . . . control building in the case of a loss of
offsite power or a LOCA."
Technical Specification 3/4.7.2 requires that the two independent air
handling unit / filter train subsystems of the main control room be operable
in all. operational modes and during the handling of irradiated fuel in the
primary containment or fuel building. The basis for this requirement is
to ensure that the control room will. remain habitable for operations
personnel during and following all design basis accidents.
Therefore, the NRC inspector concluded th'at the apparent failure to test
the subsystems and the observation that both S0Vs were reversed (unable to
perform their intended function) and both associated division check valves
were leaking, resulted in both trains / divisions of the control room air
handling unit / filter subsystems being inoperable for an indeterminate time
which is an apparent . violation of Technical Specification requirements
(458/8918-01).
4.
Fuel Building Ventilation System
a.
Identification and Review of Emergency Ventilation System
The fuel building ventilation system is designed to mitigate the
consequences of a fuel handling accident and loss of coolant accident
by limiting the plant site boundary doses to within 10 CFR 100
limits. The emergency ventilation system will automatically start on
a high radiation signal in the fuel' building exhaust duct or on a
loss of coolant accident signal which consists of high pressure in
the drywell on reactor vessel low low water level. The initiation
signal causes the ventilation system to realign to the two
independent emergency filtrations trains (1HVF*FLT2A/2B).
On December 28, 1988, the licensee initiated CR 88-0956 which
identified a deficiency in how the fuel building emergency ventilation
system was constructed. This finding resulted from the SSFI conducted
by the licensee.
Specifically, the CR identified that the inlet air
operated dampers (AODs), (1HVF*AOD 20A, B) and outlet dampers
(IHVF*AOD 31A, B) to their respective emergency filtration trains,
would fail in the closed position on a loss of instrument air
pressure. This would have resulted in the loss of both filtration
trains.
Safety-related instrument air accumulators are provided to maintain
the A0Ds operable following a loss of the nonsafety-related IAS. The
safety-related accumulators are automatically separated from the
nonsafety-related IAS by a spring loaded check valve and a SOV. The
SOVs are set'to close when the pressure between the safety-related
check valve and SOV decreases to 107 psig. The combination of the
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check valve and 50V in series is designed to limit the leakage of air
from the safety-related accumulators (IAS*TK-7A/78) to the
nonsafety-related IAS on a loss of instrument air pressure. The
licensee had previously determined that the accumulators were sized
to sustain A0D operation for 2.8 and 7.2 days respectively for IAS*TR
7A/78 following the loss of IAS pressure during an accident. This
determination was made utilizing engineering calculation PB-315
Revision 1.
On April 10, 1989, the licensee identified that the S0Vs utilized
downstream of the check valves had been installed backwards such that
a 4 psig higher differential pressure from the safety-related
accumulator would!cause the valve to lift off the seat. This
required the isolation function to be performed safely by the spring
loaded check valve.
It should be noted that the accumulator
capacities established-in PB-315, Revision 1, assumes isolation by
both the 50V and check valve.
The licensee had established Abnormal Operating Procedure A0P-0008,
" Loss of Instrument Air," Revision 3, to provide guidance to the
control room operators in the event IAS were to decrease or be lost.
Attachment I to this procedure describes operator actions to be taken
to mitigate the consequences of loss of instrument air.
The attachment stated that, " normal dampers fail closed; accident
inlet dampers fail open. This will result in loss of normal and
filtered supply and exhaust flow." The operator actions to mitigate
the event are, "When low pressure alarm for air damper accumulator is
received, observe A0D position, and shutdown filter train fans (if
running) when A0Ds fail." No instructions, air bottles, or support
equipment were provided for recharging the accumulators,
b.
Licensee Review and Corrective Actions
ModificationRequest(MR) 89-0003 was initiated on January 4, 1989,
to changed the A0Ds from fail closed to fail open to ensure
availability of the fuel building emergency filtration trains. The
licensee subsequently concluded on January 17, 1989, that the system
was designed to fail 1HVF*AOD 20A, 20B, 31A, and 32B in the closed
position and thus was not reportable.
MWO 133223 was released for work on March 19, 1989, to change
1HVF*AOD 20A/31A to fail open on a loss of instrument air pressure.
A0P-0008 was also changed to provide instructions for recharging the
Division II accumulator IAS*TK7B in the event low air pressure was to
occur in the accumulator. MWO 133224 was released on May 5, 1989, to
change 1HVF*A00 20B/31B from fail closed to fail open.
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c.
Apparent Violatibns/ Safety Significance =
River Bend Station Technical Specification 3.6.5.6 requires that
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two independent fuel building ventilation charcoal filtration
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subsystems be operable in Operational Conditions 1, 2, and 3.
The Associated Action Statement 3.6.5.6.a. only provides for one
division.of the fuel building ventilation charcoal filtration
subsystem being inoperable'in Operational Conditions 1, 2, and
<3.
The fuel building emergency filtration systems are designed to
. activate when the ventilation system is operated in the.
' emergency mode. This ensures a vacuum is maintained in the fdel
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building, and any release of radioactivity would be maintained-
within-10 CFR 100 limits following a design basis accident or
fuel handling accident.
10 CFR 50.73(a)(2)(V1) requires that any event or condition that
alone could have prevented the fulfillment of the safety
function of structures or' systems that are needed to control the
release of radioactive material shall be reported.
Paragraph (a)(2)(V1) states the events.may include one or more
procedural errors, equipment failures and/or discovery of
design, analysis, fabrication, construction and/or procedural
inadequacies.
The NRC inspectors have concluded that both divisions of the
fuel building emergency ventilation system were inoperable with
the inlet and outlet dampers failing to the closed position.
In
the event instrument air pressure was lost to the dampers with
the system in operation, the system would have to be shutdown
until the dampers could be reopened. The decay heat removal
fans would also not be available during this period because the
associated dampers could not be opened without sufficient
instrument air pressure. This condition has existed from
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initial fuel load in August 1985 until March 19, 1989, when the
Division I emergency filtration train. inlet and outlet dampers
were changed to the fail open position. Although the licensee
has determined that the IAS accumulators IAS*TR7A/7B could
supply the fuel building ventilation system dampers for 2.8 and
7.2 days respectively, this value has not been determined
through testing of the safety-related IAS. Actual test data
obtained from the control building ventilation system on May 19,
1989, for the Division II train indicated that the associated
accumulator would only maintain air pressure for 2 minutes as
opposed to the calculated value of 2.5 days. The failure to
declare both divisions of the fuel building emergency
ventilation system inoperable in accordance with
10 CFR 50.73(a)(2)(V1) was identified by the NRC inspectors as
en apparent violation (458/8918-02).
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It should be noted that during the NRC inspectors review of the
SSFI~ team report, it was' identified that a Stone and Webster
EngineeringCorporation:(SWEC)letterRBS-10242,-datedApril17,
1985, expressed similar concerns with fuel building heating and
-ventilation _ system design, and recommended:-
making provisions Lfor connecting an external air supply to
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the air accumulator tanks; and
include in the plant procedures appropriate actions to be
taken upon loss of accumulator air pressure when IAS.
pressure compressors are unavailable.
Until March 1989, these recommendations had not been
implemented.
5.
-Exit Interview
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An exit interview was conducted on May 5 and 19, 1989, denoted in
paragraph 1.
At the exit interviews, the NRC inspectors summarized the
scope of the inspection and-the findings. No information was presented to
the NRC inspectors that was identified by the licensee as proprietary.
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