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{{IR-Nav| site = 05000458 | year = 2001 | report number = 008 | {{Adams | ||
| number = ML020160005 | |||
| issue date = 01/11/2002 | |||
| title = IR 05000458/2001-008, Entergy Operations, Inc., River Bend Station, Baseline Inspection on 11/26-12/13/2001 of the Identification and Resolution of Problems. One Finding of No Color | |||
| author name = Gody A | |||
| author affiliation = NRC/RGN-IV/DRS | |||
| addressee name = Hinnenkamp P | |||
| addressee affiliation = Entergy Operations, Inc | |||
| docket = 05000458 | |||
| license number = NPF-047 | |||
| contact person = | |||
| document report number = IR-01-008 | |||
| document type = Inspection Report, Inspection Report Correspondence | |||
| page count = 23 | |||
}} | |||
{{IR-Nav| site = 05000458 | year = 2001 | report number = 008 }} | |||
=Text= | |||
{{#Wiki_filter:ary 11, 2002 | |||
==SUBJECT:== | |||
RIVER BEND STATION - NRC INSPECTION REPORT 50-458/01-08 | |||
==Dear Mr. Hinnenkamp:== | |||
On December 13, 2001, the NRC completed an inspection at your River Bend Station. The enclosed report documents the inspection findings which were discussed on December 13, 2001, with you and other members of your staff. | |||
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations, and the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures, representative records, observations of activities, and interviews with personnel. | |||
On the basis of the sample selected for review, the inspectors identified one issue that was determined to be appropriate to document as a finding of No Color. The finding related to programmatic and performance weaknesses in past-operability and reportability determinations. | |||
Otherwise, the inspectors concluded that problems were properly identified, evaluated and resolved within the problem identification and resolution programs. | |||
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | |||
Sincerely, | |||
/RA/ | |||
Anthony T. Gody, Chief Operations Branch Division of Reactor Safety | |||
Entergy Operations, Inc. -2-Docket: 50-458 License: NPF-47 | |||
===Enclosure:=== | |||
NRC Inspection Report 50-458/01-08 | |||
REGION IV== | |||
Dockets: 50-458 Licenses: NPF-47 Report No.: 50-458/01-08 Licensee: Entergy Operations, Inc. | |||
Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, Louisiana Dates: December 13, 2001 Inspectors: S. McCrory, Senior Operations Engineer, Operations Branch T. Stetka, Senior Operations Engineer, Operations Branch S. Schneider, Resident Inspector, Projects Branch B Approved By: Anthony T. Gody, Chief, Operations Branch, Division of Reactor Safety | |||
SUMMARY OF FINDINGS River Bend Station NRC Inspection Report 50-458/01-08 IR 05000458-01-08, on 11/26-12/13/200: Entergy Operations, Inc; River Bend Station. | |||
Baseline inspection of the identification and resolution of problems. One finding of No Color. | |||
The inspection was conducted by two regional senior operations engineers, and one resident inspector. The significance of issues was indicated by their color (green, white, yellow, red) and was determined by the Significance Determination Process in NRC Inspection Manual Chapter 0609. Findings for which the significance determination process does not apply are indicated by "No Color" or by the severity level of the applicable violation. | |||
Identification and Resolution of Problems | |||
* The licensee was effective at identifying problems and putting them into the corrective action program. However, the licensee's corrective action program procedures did not require an additional review of reportability when an operability determination was subsequently modified. In several instances documentation for past operability and reportability decisions was lacking. However, no instances were identified in which the licensee failed to make a required report. There were instances in which the licensee conducted reviews and evaluations as a part of their corrective actions that were related to events or conditions, but did not document these activities. The licensee implemented corrective actions, when specified, in a timely manner. The licensee performed effective audits and self-assessments. During interviews conducted during this inspection, the site staff expressed open willingness to input safety issues into the problem identification and resolution program (Section 4OA2). | |||
Cornerstone: None | |||
* No Color. In several instances, licensee records lacked evidence that evaluations for past-operability assessments were performed when equipment or systems failed routine surveillance tests. Further, in some instances, the licensee determined reportability before relevant evaluations were completed. Finally, as a matter of routine, the licensee did not re-assess the reportability of an event or condition following a revision to an operability determination subsequent to the initial reportability determination. However, no instances were identified in which the licensee failed to make a required report (Section 4OA.b(2)). | |||
The NRC evaluated the issue using the significance and documentation determination process of NRC Inspection Manual Chapter 0610*, Power Reactor Inspection Reports, Appendix B, Thresholds for Documentation. The NRC determined that the described reportability determination weaknesses, if left uncorrected, could cause the same issues under the same conditions to become a more significant safety concern, due to the latent potential to fail to make a required report. The NRC determined that the issue did not apply to any specific cornerstone and was, therefore, not subject to the Significance Determination Process. The NRC also determined that the issue had the potential to impact the NRCs ability to perform its regulatory function, specifically, the ability of the NRC to monitor compliance with safety standards. Therefore, the NRC considered the | |||
issue to have extenuating circumstances that warranted documentation as a finding of No Color. | |||
Report Details 4. OTHER ACTIVITIES (OA) | |||
4OA2 Problem Identification and Resolution a. Effectiveness of Problem Identification (1) Inspection Scope The inspectors reviewed items selected across the seven cornerstones of safety to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The inspectors reviewed several hundred summary reports of events, conditions, problems and deficiencies entered into the various licensee data bases and tracking systems including: condition reports, maintenance action items, engineering requests, emergency planning action tracking system, security deficiencies and training action items. The inspectors conducted detailed reviews of over 200 condition reports, maintenance action items, and engineering requests (listed in the attachment to this report) from a list of approximately 2000 documents, which had been issued between November 2000 and November 2001. | |||
The inspectors also reviewed licensees audits and self-assessments of the corrective action activity at the programmatic and departmental levels. The inspectors evaluated the effectiveness of the audits and assessments by comparing the audit and assessment results against self-revealing, external audits and NRC-identified issues. | |||
The inspectors evaluated the items contained in the various licensee problem reporting processes to determine the licensees threshold for identifying problems and entering them into the corrective action program. Also, the licensees efforts in establishing the scope of problems were evaluated by reviewing pertinent control room logs, work requests, engineering modification packages, self-assessment results, action plans, and results from surveillance tests and preventive maintenance tasks. | |||
(2) Issues and Findings The inspectors determined that the licensee was effective at identifying problems and entering them into the corrective action system. Licensee audits and assessments were of good depth and identified issues similar to those that were self- revealing or raised during previous NRC inspections. The inspectors identified no findings in this area. | |||
b. Prioritization and Evaluation of Issues (1) Inspection Scope The inspectors reviewed approximately 200 condition reports, maintenance action items, and engineering requests, and supporting documentation, including an appropriate analysis of the cause of the problem, to assess the licensee's evaluation of the problems identified. The inspectors focused on the licensees performance regarding operability, reportability, the full extent of conditions, generic implications, common causes, and previous occurrences. Specific items reviewed are listed in the attachment. | |||
-2-(2) Issues and Findings Based on a review of the licensees records, the inspectors concluded that the licensee effectively prioritized and evaluated issues. With respect to issues associated with significant conditions adverse to quality, however, the inspectors found weaknesses associated with the reportability determination aspect of the River Bend Station corrective action program. Although these weaknesses were not linked to a specific cornerstone, the inspectors determined that if left uncorrected, the weaknesses had the potential to impact the NRCs ability to perform its regulatory function. | |||
The inspectors reviewed over 75 condition reports (CR) for adequacy of operability and reportability determinations in the various cornerstones. Almost one third of the CRs reviewed addressed discrepancies identified during the performance of Technical Specification Surveillance Testing. With minor variation, the majority of the CRs sampled which identified a discrepancy during Technical Specification Surveillance Testing simply stated, This condition involves equipment issues that are not reportable. This condition was found during scheduled surveillance testing. Time of Discovery applies to past operability. | |||
The licensee had no other records to demonstrate the scope of assessment for past-operability and had to rely on individual recollection to provide any additional information. This level of performance was contrary to both NRC and licensee expectations. | |||
NUREG-1022, Event Reporting Guidelines, provided NRC expectations regarding past-operability assessment for determining reportability. NUREG-1022 states, in part, For testing that is conducted within the required time (i.e., the surveillance interval plus any allowed extension), it should be assumed that the discrepancy occurred at the time of its discovery unless there is firm evidence, based on a review of relevant information such as the equipment history and the cause of failure, to indicate that the discrepancy existed previously. | |||
River Bend Station procedure NSA-4.6, Nuclear Safety Assurance Reportability Guidelines, was the licensees guidance for performing reportability determinations. | |||
Paragraph 4 under the Management Expectations section stated, Boilerplate responses should be minimized. When documenting a reportability determination, the reporting requirements considered should be identified followed by the evaluation/discussion of that requirement. Enough information needs to be available for a reviewer to understand the issue considered/thought process that resulted in the given determination. | |||
The inspectors also identified that LI-102, Corrective Action Process, did not require the reportability determination to be reviewed again if the operability determination was subsequently revised. Discussion with licensee personnel responsible for making reportability determinations revealed that they used the information in the operability | |||
-3-determination statements to a great extent in determining reportability. A review of the CRs sampled identified several cases where the original operability determination was revised subsequent to the reportability determination with no re-review of the reportability potential. The inspectors also identified two instances involving fire barriers, in condition reports CR-RBS-2000-1944 and CR-RBS-2001-0898, wherein the reportability determination was made before the completion of any evaluation or safety significance determination of the reported condition. The licensee did not re-evaluate reportability after the evaluation and safety significance determination were completed. | |||
However, the inspectors did not identify any instance in which the licensee failed to make a required report. As a result of this inspection finding, the licensee initiated CR-RBS-2001-1607 to document the condition as a potential trap in the RBS reportability determination process. The CR was subsequently closed out to an Echelon corporate condition report, CR-ECH-2001-0132, since LI-102 was a corporate document and the potential trap applied to all Entergy sites who used LI-102. | |||
The inspectors evaluated the issue using the significance and documentation determination process of NRC Manual Chapter 0610*, Power Reactor Inspection Reports, Appendix B, Thresholds for Documentation. The inspectors determined that the reportability determination weaknesses described above constituted a latent condition that, if left uncorrected, could cause the same issues under the same conditions to become a more significant safety concern. The inspectors further determined that the issue had the potential to impact the NRCs ability to perform its regulatory function, specifically, the ability of the NRC to monitor compliance with safety standards. Therefore, the inspectors concluded that the issue constituted extenuating circumstances that warranted documentation as a finding of No Color. | |||
c. Effectiveness of Corrective Actions (1) Inspection Scope The inspectors reviewed condition reports and self-assessments to verify that corrective actions, related to the issues, were identified and implemented in a timely manner commensurate with safety, including corrective actions to address common cause or generic concerns. A listing of specific documents reviewed during the inspection is included in the attachment to this report. | |||
(2) Issues and Findings Based on a review of the licensees records, the inspectors concluded that the licensee effectively implemented corrective actions. The inspectors identified no findings related to the effectiveness of corrective actions. | |||
d. Assessment of Safety-Conscious Work Environment (1) Inspection Scope The inspectors interviewed members of the licensee's staff, which represented a cross-section of functional organizations and supervisory and non-supervisory personnel, regarding their willingness to identify safety issues. These interviews assessed whether | |||
-4-conditions existed that would challenge the establishment of a safety-conscious work environment. | |||
(2) Issues and Findings Based on interviews, the inspectors identified no findings related to the safety conscious work environment. The inspectors concluded, based on information collected from interviews with the licensee personnel, that these employees were willing to identify issues and accepted the responsibility to pro-actively identify and enter safety issues into the corrective action program. | |||
4OA3 Event Follow-up (Closed) Licensee Event Report 50-458/01-001: Unplanned Reactor Scram During Turbine Control Valve Testing. The event occurrence was documented in NRC Inspection Report 50-458/01-02. During this inspection, the inspectors reviewed Condition report CR-RBS-2001-0523, that the licensee issued to document the findings of its root cause determination and planned corrective actions. | |||
This event occurred during a surveillance test of the main turbine control valves while the reactor was at 54% power. As Control Valve 1 was being closed for the test, Control Valves 2, 3 and 4, which initially began to open as designed, stopped opening and started ramping closed causing a high reactor pressure and a subsequent reactor scram. The licensees Significant Event Review Team identified that a previous turbine modification, (completed in July 1999) which changed the turbine operation to a partial arc admission mode of operation, caused steam flow induced turbine rotor vibrations. | |||
This resulted in the generation of an erroneous increasing turbine speed signal, which caused the turbine control system to begin shutting the remaining three control valves. | |||
The inspectors noted that previous control valve testing (which was usually conducted quarterly) was conducted at a substantially higher or lower reactor power level, which did not result in a reactor scram. | |||
The inspectors observed that the licensee's Significant Event Review Team identified two contributing factors to the event that were not fully documented. The first factor involved a failure to review historical operating experience events as a part of the modification process. The licensee concluded that had a previous Significant Event Report, (SER 91-04, Asymmetric Turbine Loading), been reviewed, the effect of the partial arc admission steam flow on the surveillance test may have been recognized. | |||
During its investigation the licensee discussed the generic aspects of this factor and sampled other plant modifications to assess the extent of the condition. However, the inspectors observed that the licensee did not document these activities and their results. | |||
The second factor involved the isolation of the moisture separator re-heaters (MSRs). | |||
The inspectors observed that, in all testing performed since the turbine was modified, the only time the MSRs were isolated was during the April 21 test. Again, the licensee discussed the impact of the MSRs on the event and determined that they had no impact, but did not document this information. As the result of the inspectors' observations regarding these omissions in the documentation, the licensee issued an additional corrective action (#34) to the condition report CR-RBS-2001-0523 to document their review of the generic aspects of both factors. | |||
-5-The inspectors determined that the corrective actions for this event were appropriate and either completed or progressing in a timely manner. The inspectors also noted that control valve testing was not required by license conditions and that the licensee decided to suspend turbine control valve testing pending the results of further turbine inspections planned for the next refueling outage. | |||
4OA6 Meetings Exit Meeting The inspectors discussed these findings with Mr. Paul D. Hinnenkamp, Vice President - | |||
Operations and members of the licensee's staff in a telephonic meeting on December 13, 2001. The licensee's management acknowledged the findings presented. | |||
ATTACHMENT KEY POINTS OF CONTACT Licensee K. Aitken, Senior Coordinator, Security J. Antoine, Configuration Management Group Supervisor C. Bailey, Senior Technical Instructor R. Bare, Corrective Action and Assessment R. Biggs, Coordinator, Safety and Regulatory Affairs S. Burd, Turbine System Engineer D. Burnett, Superintendent, Chemistry J. Carlson, Shift Manager J. Clark, Assistant Operations Manager R. Cole, Manager, Systems Engineering N. Crane, Senior Operations Specialist A. Dalawari, Senior Civil Engineer M. Davis, Nuclear Specialist IV J. Dunkelberg, Civil Engineer D. Gilley, Maintenance Coordinator T. Glass, I&C Engineer R. Glueck, Senior System Engineer H. Goodman, Superintendent, Reactor Engineering H. Grimes, Senior Engineer, Quality Assurance T. Hildebrandt, Manager, Maintenance P. Hinnenkamp, Vice President, Operations K. Huffstatler, Senior Emergency Planner F. Hurst, Senior Emergency Planner R. Jackson, Code Engineer M. Kassar, Senior Civil Engineer R. Kerar, Fire Protection Engineer J. Leavines, Manager, Licenisng D. Marble, Supervisor, Electrical Maintenance J. McGhee, Manager, Operations J. Merchan, Senior Engineer, Programs ans Components Group P. Miktus, Supervisor, Design Engineering G. Miller, Senior System Engineer D. Mimms, General Manager, Operations D. Myers, Radiation Protection Specialist R. Northrup, Nuclear Safety Assurance C. Pratt, Design Engineer III M. Rathcke, Supervisor, Mechanical Maintenance D. Reynolds, Maintenance Specialist M. Robinette, System Engineer P. Sicard, Manager, Safety Analysis A. Spencer, Operations Coordinator C. Stout, Supervisor, Instrumentation and Control Maintenance N. Tison, Senior Emergency Planner W. Trudell, Manager, Corrective Action and Assessment | |||
-2-R. Tunstall, Senior Technical Instructor D. Williamson, Senior Licensing Specialist NRC P. Alter, Senior Resident Inspector, River Bend Station E. Connell, Senior Fire Protection Engineer, NRR P. Qualls, Senior Fire Protection Engineer, NRR D. Allison, Generic Issues, Environmental, Financial, and Rulemaking Branch, NRR J. Tappert, Chief, Generic Issues, Environmental, Financial, and Rulemaking Branch, NRR ITEMS OPENED, CLOSED, AND DISCUSSED Closed 50-458/01-001 LER Unplanned Reactor Scram During Turbine Control Valve Testing. (Section 4OA3) | |||
DOCUMENTS REVIEWED The following documents were selected and reviewed by the inspectors to accomplish the objectives and scope of the inspection and to support any findings: | |||
Procedures RBNP-078, Operability Determinations, Revision 6 P870-53, Alarm Response, Revision 7 SOP-0010, MSR & FW Heaters Extraction Steam and Drains, Revision 22 OSP-0102, Turbine Valve Testing, Revision 6 LI-102, Corrective Action Process, Revision 1 MCP-1005, Testing and Calibration of GE Type GGP-53C Relay, Revision 5A RBNP-083, Reactivity Management, Revision 2 EDG-AA-115, Engineering Request - Response Development, Revision 0 ADM-0022, Conduct of Operations, Revision 30 OSP-0003, Logs and Records, Revision 12 | |||
-3-SOP-0010, Moisture Separator Reheater and Feedwater Heaters Extraction Steam and Drains, Revision 22 AOP-0007, Loss of Feedwater Heating, Revision 20 RPP-STD-01, "Radiation Protection Standards," Revisions 12 and 13 AOP-009, Loss of Normal Service Water, Revision 12 RBNP-004, Event Notification and Reporting, Revision 12 NSA 4.6, Nuclear Safety Assurance Reportability Guidelines, Revision 1 Operations Policy 006, Active Limiting Conditions of Operations, Revision 13 Condition Reports (CRs) | |||
ECH-2001-0132 RBS-1999-1068 RBS-2001-1260 RBS-2001-0381 RBS-2001-0701 OPX-2000-0037 RBS-1999-1696 RBS-2001-0437 RBS-2001-0389 RBS-2001-0708 OPX-2001-0005 RBS-2000-0531 RBS-2001-0858 RBS-2001-0391 RBS-2001-0709 OPX-2001-0007 RBS-2000-0095 RBS-2001-1103 RBS-2001-0392 RBS-2001-0710 OPX-2001-0008 RBS-2000-0274 RBS-2001-0293 RBS-2001-0398 RBS-2001-0711 OPX-2001-0012 RBS-2000-0597 RBS-2001-0674 RBS-2001-0403 RBS-2001-0714 OPX-2001-0014 RBS-2000-0629 RBS-2001-0001 RBS-2001-0412 RBS-2001-0726 OPX-2001-0019 RBS-2000-0782 RBS-2001-0054 RBS-2001-0413 RBS-2001-0727 OPX-2001-0035 RBS-2000-0969 RBS-2001-0071 RBS-2001-0419 RBS-2001-0730 OPX-2001-0039 RBS-2000-1198 RBS-2001-0073 RBS-2001-0423 RBS-2001-0750 OPX-2001-0043 RBS-2000-1209 RBS-2001-0101 RBS-2001-0463 RBS-2001-0773 OPX-2001-0050 RBS-2000-1232 RBS-2001-0103 RBS-2001-0479 RBS-2001-0775 OPX-2001-0051 RBS-2000-1377 RBS-2001-0109 RBS-2001-0492 RBS-2001-0776 OPX-2001-0054 RBS-2000-1459 RBS-2001-0126 RBS-2001-0494 RBS-2001-0779 OPX-2001-0063 RBS-2000-1486 RBS-2001-0134 RBS-2001-0515 RBS-2001-0810 OPX-2001-0070 RBS-2000-1490 RBS-2001-0164 RBS-2001-0516 RBS-2001-0814 OPX-2001-0071 RBS-2000-1597 RBS-2001-0192 RBS-2001-0523 RBS-2001-0832 OPX-2001-0072 RBS-2000-1628 RBS-2001-0200 RBS-2001-0530 RBS-2001-0837 OPX-2001-0075 RBS-2000-1645 RBS-2001-0202 RBS-2001-0544 RBS-2001-0854 OPX-2001-0079 RBS-2000-1680 RBS-2001-0243 RBS-2001-0551 RBS-2001-0860 OPX-2001-0112 RBS-2000-1712 RBS-2001-0253 RBS-2001-0557 RBS-2001-0872 OPX-2001-0115 RBS-2000-1723 RBS-2001-0258 RBS-2001-0559 RBS-2001-0898 OPX-2001-0117 RBS-2000-1848 RBS-2001-0277 RBS-2001-0561 RBS-2001-0902 OPX-2001-0125 RBS-2000-1936 RBS-2001-0299 RBS-2001-0562 RBS-2001-0929 OPX-2001-0144 RBS-2000-1944 RBS-2001-0313 RBS-2001-0567 RBS-2001-0931 OPX-2001-0158 RBS-2000-1991 RBS-2001-0317 RBS-2001-0603 RBS-2001-0936 RBS-2001-1625 RBS-2000-1992 RBS-2001-0318 RBS-2001-0656 RBS-2001-0961 RBS-2001-1632 RBS-2000-1993 RBS-2001-0339 RBS-2001-0658 RBS-2001-0977 RBS-2001-1607 RBS-2000-2006 RBS-2001-0350 RBS-2001-0664 RBS-2001-0978 RBS-1996-1479 RBS-2000-2050 RBS-2001-0361 RBS-2001-0695 RBS-2001-0982 RBS-1998-1333 RBS-2000-2213 RBS-2001-0374 RBS-2001-0699 RBS-2001-0984 RBS-1999-0263 RBS-2001-0034 RBS-2001-0378 RBS-2001-0700 RBS-2001-0986 | |||
-4-RBS-2001-0995 RBS-2001-1141 RBS-2001-1215 RBS-2001-1309 RBS-2001-1520 RBS-2001-1006 RBS-2001-1143 RBS-2001-1216 RBS-2001-1336 RBS-2001-1632 RBS-2001-1008 RBS-2001-1169 RBS-2001-1249 RBS-2001-1337 RLO-2001-0102 RBS-2001-1086 RBS-2001-1174 RBS-2001-1254 RBS-2001-1345 RLO-2001-0111 RBS-2001-1086 RBS-2001-1182 RBS-2001-1269 RBS-2001-1358 RLO-2001-0126 RBS-2001-1087 RBS-2001-1199 RBS-2001-1285 RBS-2001-1368 RLO-2001-0136 RBS-2001-1130 RBS-2001-1201 RBS-2001-1285 RBS-2001-1369 RLO-2001-0152 RBS-2001-1134 RBS-2001-1214 RBS-2001-1298 Maintenance Action Item (MAI) | |||
MAI 336589 MAI 336211 MAI 312253 MAI 341311 MAI 341051 MAI 350593 MAI 341314 MAI 345236 MAI 351559 MAI 341313 MAI 347438 MAI 345172 MAI 341312 Engineering Request (ER) | |||
ER-RB-2001-0400, Postulated Fuel Assembly Drop Accident Analysis for High Density Spent Fuel Racks, 7/19/2001. | |||
ER-RB-2001-0114, Change yoke material for heater dump valves from cast iron to steel yokes, 7/16/01. | |||
ER-RB-2001-0198, Revise ERIS point associated with EHC system in main control panel, 4/23/01. | |||
Audits and Assessments April Oversight Report, 4/01 May Oversight Report, 5/01 June Oversight Report, 6/01 July Oversight Report, 7/01 Security Self Assessment, RLO-2001-0047, 5/25/01 Dominion Oversight Benchmarking Report, 6/01 QA-3-2001-RBS-1-Multi-site, ENSW QA Multi-site Audit of the Corrective Action Program, 7/3/01 QA-6-2001-RBS-1, RBS QA Audit of Effluent and Environmental Monitoring, 9/25/01 QA-7-2001-RBS-1, RBS QA Audit of the Emergency Planning Program, 5/15/01 QA-14-2001-RBS-1, RBS QA Audit of the Radiation Protection Program, 4/10/01 | |||
-5-River Bend EP (Self) Assessment, 11/00 Self-Assessment Topic: Radioactive Material Control, 12/18/00 Self-Assessment Report: ALARA Planning and Controls, 3/01 RPG-M-01-013, Effluent Dose Calculations Self Assessment, 2/23/01 RBS Self-Assessment - CA&A - Evaluation of NRC Corrective Action Inspections at Other EOI Sites and RBS, dated 11/20/00 RBS Self-Assessment - CR Disposition Corrective Actions, dated 11/29/00 RBS Self-Assessment - Maintenance Department Standards and Expectations, dated 3/29/01 RBS Self-Assessment - CA&A Process Review, dated 6/21/01 RBS Learning Organization Assessment, dated 6/27/01 ENSW Quality Assurance Multi-Site Audit of the Corrective Action Program, dated 7/03/01 River Bend Corporate Operations Training Assessment dated June 18, 2001 QA-12-2001-RBS-1, RBS Quality Assurance Audit of Operations dated July 5, 2001 Self-Assessment Topic: Protective Tagging dated December 8, 2000 Self-Assessment Topic: The Operator Aid Program dated March 15, 2001 Licensed Operator Requalification Program Inspection Readiness Self-Assessment dated June 18, 2001 OP-2001-01-RBS, River Bend Station Human Performance Self-Assessment dated December 11 - 14, 2000 Miscellaneous Documents System Engineering Handbook, Revision 1, 1/11/01, Guideline 6.9, Plant/System Walkdown Guidelines. | |||
Procedure Action Request (PAR) ARP-870-53R06CN-A dated 3/28/01. | |||
Operations Standards and Expectations, Revision 12 Monthly Report-October 2001, Sec-2001-0050 (Security), 11/05/01 Emergency Planning Action Tracking System summary data from 5/1 to 11/28/01 EP-M-01-07, "Exercise Evaluation Report, ERO Team A," 3/6/01 | |||
-6-Engineering Calculation G13.18.12.2, Evaluate the wall that separates Fire Areas AB-7 and AB-18, 12/5/00 RBS QA Surveillance Report-QS-2001-RBS-0011 dated May 29, 2001 RBS QA Surveillance Report-QS-2001-RBS-026 dated July 17, 2001 RBS Quality Assurance Surveillance Report, QS-2001-RBS-042 RBS Quality Assurance Surveillance Report, QS-2001-RBS-043 RBS Quarterly Trend and Analysis Report - First Quarter 2001 RBS Quarterly Trend and Analysis Report - Second Quarter 2001 Entergy Root Cause Analysis Desk Guide, Revision 5 Entergy Corrective Action Process Desk Guide, Revision 2 Entergy Problem Trending Guide, Revision 2 RBS Engineering Expectations Guidance Document RBS System Engineering Handbook, Revision 1 RBS System Engineering Qualification Card, Revision 4 RBS General Employee Training, Revised 12/19/00 EOI Orientation Workbook, Corrective Action Program, Revision 00 RBS, Unit 1, Facility Operating License No. NPF-47 RBS Maintenance Rule Function(s) Listing RBS Maintenance Rule Performance Criteria NUMARC 93-01, Revision 2, NEI Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants | |||
-7-Information Request 1 River Bend PIR Inspection (IP 71152) 01-08 The inspection will cover the period of December 19, 2000 to November 26, 2001. All requested information should be limited to this period unless otherwise specified. The information may be provided in either electronic (preferred) or paper media or a combination of these. Information provided in electronic media may be in the form of CDs (preferred), e-mail attachment(s), or 3 1/2 floppy disks. The agencys text editing software is Corel WordPerfect 8, Presentations, and Quattro Pro; however, we have document viewing capability for MS Word, Excel, Power Point, Access, and Adobe Acrobat (.pdf) text files. Where possible, it is preferred that the files be searchable text or data files vice image files. | |||
Please provide the following information to Stephen McCrory in the Region IV Arlington office by October 15, 2001. If you have questions or comments, please contact Mr. McCrory at (817) | |||
860-8265 or e-mail at slm@nrc.gov. | |||
1. Summary list of all currently open/active items for: | |||
a. condition reports of significant conditions adverse to quality b. engineering review requests c. maintenance requests 2. Summary list of all items completed/resolved/closed since December 19, 2000 for: | |||
a. condition reports of significant conditions adverse to quality b. engineering review requests c. maintenance requests 3. Summary list of all condition reports generated during the specified period and sorted by: | |||
a. chronology b. initiating organization c. responsible organization 4. All quality assurance audits and surveillances of corrective action activities since December 19, 2000. | |||
5. All self-assessments and Non-NRC third party assessments of corrective action activity and functional area performance since December 19, 2000. | |||
6. Corrective action performance trending/tracking information generated since December 19, 2000 and broken down by functional organization. | |||
7. Current revision of the following procedures: | |||
ADM-022, Conduct of Operations" ADM-0023, Conduct of Maintenance CPN LI-102, Corrective Action Process | |||
-8-EDG-PR-001, Maintenance Rule Program EDG-PE-002 Guideline for Performing 10 CFR Part 21 Applicability Reviews ENG-3-033, Modification Design Control Plan ENG-3-037, Engineering Request Process LI-102, Corrective Action Process OE-100, Operating Experience Program PEP-0219, Reliability Monitoring Program RBNP-002, Root Cause Determination Guidance RBNP-010, Configuration Management RBNP-030, Initiation and Processing of Condition Reports RBNP-062, River Bend Industry Events and Analysis Program RBNP-069, Significant Event Evaluation RBNP-078, Operability Determinations 8. Any additional governing procedures/policies/guidelines for: | |||
Condition Reporting Corrective Action Program Root Cause Evaluation/Determination Operator Work-Arounds Work Requests Engineering Requests Temporary Modifications Procedure Change Requests Deficiency Reporting and Resolution Training Needs Request/Evaluation 9. For each of the items (applicable to River Bend) listed below please provide the following: | |||
* Full text of the condition report (please indicate any findings that did not result in a condition report or corrective actions) | |||
* Any Roll-up or Aggregating Conditions Reports related to the generic communication or condition report. | |||
* Root Cause analysis report (if applicable) | |||
* Risk significance assessments | |||
* Probable Cause evaluation (if applicable) | |||
* Approved corrective actions | |||
* Basis for extending originally approved due dates | |||
* Evidence of corrective action completion (work packages, design change documentation, temporary modifications, training lesson plans/material, training attendance records, procedure revisions, etc.) | |||
a. Part 21 Reports 2001-01 through last issued (2001-24 or later) | |||
b. NRC Information Notices 2001-01 through last issued (2001-13 or later) | |||
c. All LERs issued since December 19, 2000 excluding LER 00-016-00 | |||
-9-d. All NRC identified NCVs and Violations issued since December 19, 2000. | |||
Information Request 2 River Bend PIR Inspection (IP 71152) 01-08 Please provide the information requested below to the PIR inspection team member indicated as soon as possible after the teams arrival on 11/26/01. All information may be provided in the medium most convenient (electronic or hard copy). If you believe that the NRC has previously comprehensively reviewed any of the following items with regard to problem identification and resolution, please identify them to the inspection team, who will assess the need for further review. | |||
Please arrange the requested interviews to begin no earlier than 8 AM on 11/27/01 and to be completed by 3 PM 11/29/01. The interviews should be scheduled for about 45 minutes with at least 1/2 hour between interviews. | |||
S. McCrory Full copies of the following CRs: | |||
2000-0095 2000-1992 2001-0317 2001-0412 2001-0860 2000-0274 2000-1993 2001-0339 2001-0551 2001-0986 2000-1232 2000-2006 2001-0350 2001-0562 2001-1174 2000-1597 2001-0243 2001-0361 2001-0727 2001-1199 2000-1991 2001-0253 2001-0381 2001-0773 Interview: | |||
Individual(s) to address the unsatisfactory assessments in the RBS Quality Assurance Audit of Effluent and Environmental Monitoring, dated 9/25/01 Individuals with PIR oversight responsibility for: | |||
Radiation Protection Security Emergency Planning M. Schneider Full copies of the following CRs: | |||
2000-1628 2001-0232 2001-0674 2001-0756 2001-0854 2000-1680 2001-0318 2001-0695 2001-0761 2001-0857 2000-1712 2001-0398 2001-0714 2001-0761 2001-0862 2000-2173 2001-0475 2001-0726 2001-0775 2001-0892 2000-2174 2001-0518 2001-0730 2001-0814 2001-0936 2000-2175 2001-0530 2001-0750 2001-0815 2001-1146 2001-0201 | |||
-10-Copies of with full event/condition descriptions, operability determinations, and reportability determinations for the following CRs (or full copies if thats easier): | |||
2000-2213 2001-0374 2001-0567 2001-0872 2001-1201 2001-0034 2001-0378 2001-0580 2001-0898 2001-1214 2001-0071 2001-0389 2001-0603 2001-0902 2001-1215 2001-0073 2001-0390 2001-0627 2001-0929 2001-1216 2001-0101 2001-0391 2001-0639 2001-0961 2001-1249 2001-0103 2001-0392 2001-0656 2001-0995 2001-1254 2001-0109 2001-0403 2001-0658 2001-1006 2001-1285 2001-0126 2001-0413 2001-0664 2001-1086 2001-1298 2001-0134 2001-0423 2001-0708 2001-1087 2001-1335 2001-0164 2001-0437 2001-0740 2001-1103 2001-1336 2001-0200 2001-0492 2001-0776 2001-1130 2001-1337 2001-0202 2001-0494 2001-0779 2001-1134 2001-1340 2001-0277 2001-0544 2001-0807 2001-1141 2001-1345 2001-0293 2001-0557 2001-0810 2001-1143 2001-1358 2001-0299 2001-0559 2001-0858 2001-1169 2001-1368 2001-0313 2001-0561 Copies of the following self-assesments: | |||
Maintenance and System Engineering Self-Assessments since 10/00. | |||
Interviews: | |||
Maintenance Manager - Tom Hildebrandt Maintenance Supervisors - Craig Stout (I&C), Danny Marble (Electrical), | |||
Mike Rathcke (Mechanical) | |||
Systems Engineering Manager - Amir Shahkarami (or his designate) | |||
System Engineering Supervisors - Paul Miktus (Civil), Ronnie Cole (E/I&C) | |||
Corrective Actions Program Manager - Bill Trudell | |||
}} | |||
Latest revision as of 07:22, 28 March 2020
| ML020160005 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/11/2002 |
| From: | Gody A Division of Reactor Safety IV |
| To: | Hinnenkamp P Entergy Operations |
| References | |
| IR-01-008 | |
| Download: ML020160005 (23) | |
Text
ary 11, 2002
SUBJECT:
RIVER BEND STATION - NRC INSPECTION REPORT 50-458/01-08
Dear Mr. Hinnenkamp:
On December 13, 2001, the NRC completed an inspection at your River Bend Station. The enclosed report documents the inspection findings which were discussed on December 13, 2001, with you and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations, and the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures, representative records, observations of activities, and interviews with personnel.
On the basis of the sample selected for review, the inspectors identified one issue that was determined to be appropriate to document as a finding of No Color. The finding related to programmatic and performance weaknesses in past-operability and reportability determinations.
Otherwise, the inspectors concluded that problems were properly identified, evaluated and resolved within the problem identification and resolution programs.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Anthony T. Gody, Chief Operations Branch Division of Reactor Safety
Entergy Operations, Inc. -2-Docket: 50-458 License: NPF-47
Enclosure:
NRC Inspection Report 50-458/01-08
REGION IV==
Dockets: 50-458 Licenses: NPF-47 Report No.: 50-458/01-08 Licensee: Entergy Operations, Inc.
Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, Louisiana Dates: December 13, 2001 Inspectors: S. McCrory, Senior Operations Engineer, Operations Branch T. Stetka, Senior Operations Engineer, Operations Branch S. Schneider, Resident Inspector, Projects Branch B Approved By: Anthony T. Gody, Chief, Operations Branch, Division of Reactor Safety
SUMMARY OF FINDINGS River Bend Station NRC Inspection Report 50-458/01-08 IR 05000458-01-08, on 11/26-12/13/200: Entergy Operations, Inc; River Bend Station.
Baseline inspection of the identification and resolution of problems. One finding of No Color.
The inspection was conducted by two regional senior operations engineers, and one resident inspector. The significance of issues was indicated by their color (green, white, yellow, red) and was determined by the Significance Determination Process in NRC Inspection Manual Chapter 0609. Findings for which the significance determination process does not apply are indicated by "No Color" or by the severity level of the applicable violation.
Identification and Resolution of Problems
- The licensee was effective at identifying problems and putting them into the corrective action program. However, the licensee's corrective action program procedures did not require an additional review of reportability when an operability determination was subsequently modified. In several instances documentation for past operability and reportability decisions was lacking. However, no instances were identified in which the licensee failed to make a required report. There were instances in which the licensee conducted reviews and evaluations as a part of their corrective actions that were related to events or conditions, but did not document these activities. The licensee implemented corrective actions, when specified, in a timely manner. The licensee performed effective audits and self-assessments. During interviews conducted during this inspection, the site staff expressed open willingness to input safety issues into the problem identification and resolution program (Section 4OA2).
Cornerstone: None
- No Color. In several instances, licensee records lacked evidence that evaluations for past-operability assessments were performed when equipment or systems failed routine surveillance tests. Further, in some instances, the licensee determined reportability before relevant evaluations were completed. Finally, as a matter of routine, the licensee did not re-assess the reportability of an event or condition following a revision to an operability determination subsequent to the initial reportability determination. However, no instances were identified in which the licensee failed to make a required report (Section 4OA.b(2)).
The NRC evaluated the issue using the significance and documentation determination process of NRC Inspection Manual Chapter 0610*, Power Reactor Inspection Reports, Appendix B, Thresholds for Documentation. The NRC determined that the described reportability determination weaknesses, if left uncorrected, could cause the same issues under the same conditions to become a more significant safety concern, due to the latent potential to fail to make a required report. The NRC determined that the issue did not apply to any specific cornerstone and was, therefore, not subject to the Significance Determination Process. The NRC also determined that the issue had the potential to impact the NRCs ability to perform its regulatory function, specifically, the ability of the NRC to monitor compliance with safety standards. Therefore, the NRC considered the
issue to have extenuating circumstances that warranted documentation as a finding of No Color.
Report Details 4. OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution a. Effectiveness of Problem Identification (1) Inspection Scope The inspectors reviewed items selected across the seven cornerstones of safety to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The inspectors reviewed several hundred summary reports of events, conditions, problems and deficiencies entered into the various licensee data bases and tracking systems including: condition reports, maintenance action items, engineering requests, emergency planning action tracking system, security deficiencies and training action items. The inspectors conducted detailed reviews of over 200 condition reports, maintenance action items, and engineering requests (listed in the attachment to this report) from a list of approximately 2000 documents, which had been issued between November 2000 and November 2001.
The inspectors also reviewed licensees audits and self-assessments of the corrective action activity at the programmatic and departmental levels. The inspectors evaluated the effectiveness of the audits and assessments by comparing the audit and assessment results against self-revealing, external audits and NRC-identified issues.
The inspectors evaluated the items contained in the various licensee problem reporting processes to determine the licensees threshold for identifying problems and entering them into the corrective action program. Also, the licensees efforts in establishing the scope of problems were evaluated by reviewing pertinent control room logs, work requests, engineering modification packages, self-assessment results, action plans, and results from surveillance tests and preventive maintenance tasks.
(2) Issues and Findings The inspectors determined that the licensee was effective at identifying problems and entering them into the corrective action system. Licensee audits and assessments were of good depth and identified issues similar to those that were self- revealing or raised during previous NRC inspections. The inspectors identified no findings in this area.
b. Prioritization and Evaluation of Issues (1) Inspection Scope The inspectors reviewed approximately 200 condition reports, maintenance action items, and engineering requests, and supporting documentation, including an appropriate analysis of the cause of the problem, to assess the licensee's evaluation of the problems identified. The inspectors focused on the licensees performance regarding operability, reportability, the full extent of conditions, generic implications, common causes, and previous occurrences. Specific items reviewed are listed in the attachment.
-2-(2) Issues and Findings Based on a review of the licensees records, the inspectors concluded that the licensee effectively prioritized and evaluated issues. With respect to issues associated with significant conditions adverse to quality, however, the inspectors found weaknesses associated with the reportability determination aspect of the River Bend Station corrective action program. Although these weaknesses were not linked to a specific cornerstone, the inspectors determined that if left uncorrected, the weaknesses had the potential to impact the NRCs ability to perform its regulatory function.
The inspectors reviewed over 75 condition reports (CR) for adequacy of operability and reportability determinations in the various cornerstones. Almost one third of the CRs reviewed addressed discrepancies identified during the performance of Technical Specification Surveillance Testing. With minor variation, the majority of the CRs sampled which identified a discrepancy during Technical Specification Surveillance Testing simply stated, This condition involves equipment issues that are not reportable. This condition was found during scheduled surveillance testing. Time of Discovery applies to past operability.
The licensee had no other records to demonstrate the scope of assessment for past-operability and had to rely on individual recollection to provide any additional information. This level of performance was contrary to both NRC and licensee expectations.
NUREG-1022, Event Reporting Guidelines, provided NRC expectations regarding past-operability assessment for determining reportability. NUREG-1022 states, in part, For testing that is conducted within the required time (i.e., the surveillance interval plus any allowed extension), it should be assumed that the discrepancy occurred at the time of its discovery unless there is firm evidence, based on a review of relevant information such as the equipment history and the cause of failure, to indicate that the discrepancy existed previously.
River Bend Station procedure NSA-4.6, Nuclear Safety Assurance Reportability Guidelines, was the licensees guidance for performing reportability determinations.
Paragraph 4 under the Management Expectations section stated, Boilerplate responses should be minimized. When documenting a reportability determination, the reporting requirements considered should be identified followed by the evaluation/discussion of that requirement. Enough information needs to be available for a reviewer to understand the issue considered/thought process that resulted in the given determination.
The inspectors also identified that LI-102, Corrective Action Process, did not require the reportability determination to be reviewed again if the operability determination was subsequently revised. Discussion with licensee personnel responsible for making reportability determinations revealed that they used the information in the operability
-3-determination statements to a great extent in determining reportability. A review of the CRs sampled identified several cases where the original operability determination was revised subsequent to the reportability determination with no re-review of the reportability potential. The inspectors also identified two instances involving fire barriers, in condition reports CR-RBS-2000-1944 and CR-RBS-2001-0898, wherein the reportability determination was made before the completion of any evaluation or safety significance determination of the reported condition. The licensee did not re-evaluate reportability after the evaluation and safety significance determination were completed.
However, the inspectors did not identify any instance in which the licensee failed to make a required report. As a result of this inspection finding, the licensee initiated CR-RBS-2001-1607 to document the condition as a potential trap in the RBS reportability determination process. The CR was subsequently closed out to an Echelon corporate condition report, CR-ECH-2001-0132, since LI-102 was a corporate document and the potential trap applied to all Entergy sites who used LI-102.
The inspectors evaluated the issue using the significance and documentation determination process of NRC Manual Chapter 0610*, Power Reactor Inspection Reports, Appendix B, Thresholds for Documentation. The inspectors determined that the reportability determination weaknesses described above constituted a latent condition that, if left uncorrected, could cause the same issues under the same conditions to become a more significant safety concern. The inspectors further determined that the issue had the potential to impact the NRCs ability to perform its regulatory function, specifically, the ability of the NRC to monitor compliance with safety standards. Therefore, the inspectors concluded that the issue constituted extenuating circumstances that warranted documentation as a finding of No Color.
c. Effectiveness of Corrective Actions (1) Inspection Scope The inspectors reviewed condition reports and self-assessments to verify that corrective actions, related to the issues, were identified and implemented in a timely manner commensurate with safety, including corrective actions to address common cause or generic concerns. A listing of specific documents reviewed during the inspection is included in the attachment to this report.
(2) Issues and Findings Based on a review of the licensees records, the inspectors concluded that the licensee effectively implemented corrective actions. The inspectors identified no findings related to the effectiveness of corrective actions.
d. Assessment of Safety-Conscious Work Environment (1) Inspection Scope The inspectors interviewed members of the licensee's staff, which represented a cross-section of functional organizations and supervisory and non-supervisory personnel, regarding their willingness to identify safety issues. These interviews assessed whether
-4-conditions existed that would challenge the establishment of a safety-conscious work environment.
(2) Issues and Findings Based on interviews, the inspectors identified no findings related to the safety conscious work environment. The inspectors concluded, based on information collected from interviews with the licensee personnel, that these employees were willing to identify issues and accepted the responsibility to pro-actively identify and enter safety issues into the corrective action program.
4OA3 Event Follow-up (Closed) Licensee Event Report 50-458/01-001: Unplanned Reactor Scram During Turbine Control Valve Testing. The event occurrence was documented in NRC Inspection Report 50-458/01-02. During this inspection, the inspectors reviewed Condition report CR-RBS-2001-0523, that the licensee issued to document the findings of its root cause determination and planned corrective actions.
This event occurred during a surveillance test of the main turbine control valves while the reactor was at 54% power. As Control Valve 1 was being closed for the test, Control Valves 2, 3 and 4, which initially began to open as designed, stopped opening and started ramping closed causing a high reactor pressure and a subsequent reactor scram. The licensees Significant Event Review Team identified that a previous turbine modification, (completed in July 1999) which changed the turbine operation to a partial arc admission mode of operation, caused steam flow induced turbine rotor vibrations.
This resulted in the generation of an erroneous increasing turbine speed signal, which caused the turbine control system to begin shutting the remaining three control valves.
The inspectors noted that previous control valve testing (which was usually conducted quarterly) was conducted at a substantially higher or lower reactor power level, which did not result in a reactor scram.
The inspectors observed that the licensee's Significant Event Review Team identified two contributing factors to the event that were not fully documented. The first factor involved a failure to review historical operating experience events as a part of the modification process. The licensee concluded that had a previous Significant Event Report, (SER 91-04, Asymmetric Turbine Loading), been reviewed, the effect of the partial arc admission steam flow on the surveillance test may have been recognized.
During its investigation the licensee discussed the generic aspects of this factor and sampled other plant modifications to assess the extent of the condition. However, the inspectors observed that the licensee did not document these activities and their results.
The second factor involved the isolation of the moisture separator re-heaters (MSRs).
The inspectors observed that, in all testing performed since the turbine was modified, the only time the MSRs were isolated was during the April 21 test. Again, the licensee discussed the impact of the MSRs on the event and determined that they had no impact, but did not document this information. As the result of the inspectors' observations regarding these omissions in the documentation, the licensee issued an additional corrective action (#34) to the condition report CR-RBS-2001-0523 to document their review of the generic aspects of both factors.
-5-The inspectors determined that the corrective actions for this event were appropriate and either completed or progressing in a timely manner. The inspectors also noted that control valve testing was not required by license conditions and that the licensee decided to suspend turbine control valve testing pending the results of further turbine inspections planned for the next refueling outage.
4OA6 Meetings Exit Meeting The inspectors discussed these findings with Mr. Paul D. Hinnenkamp, Vice President -
Operations and members of the licensee's staff in a telephonic meeting on December 13, 2001. The licensee's management acknowledged the findings presented.
ATTACHMENT KEY POINTS OF CONTACT Licensee K. Aitken, Senior Coordinator, Security J. Antoine, Configuration Management Group Supervisor C. Bailey, Senior Technical Instructor R. Bare, Corrective Action and Assessment R. Biggs, Coordinator, Safety and Regulatory Affairs S. Burd, Turbine System Engineer D. Burnett, Superintendent, Chemistry J. Carlson, Shift Manager J. Clark, Assistant Operations Manager R. Cole, Manager, Systems Engineering N. Crane, Senior Operations Specialist A. Dalawari, Senior Civil Engineer M. Davis, Nuclear Specialist IV J. Dunkelberg, Civil Engineer D. Gilley, Maintenance Coordinator T. Glass, I&C Engineer R. Glueck, Senior System Engineer H. Goodman, Superintendent, Reactor Engineering H. Grimes, Senior Engineer, Quality Assurance T. Hildebrandt, Manager, Maintenance P. Hinnenkamp, Vice President, Operations K. Huffstatler, Senior Emergency Planner F. Hurst, Senior Emergency Planner R. Jackson, Code Engineer M. Kassar, Senior Civil Engineer R. Kerar, Fire Protection Engineer J. Leavines, Manager, Licenisng D. Marble, Supervisor, Electrical Maintenance J. McGhee, Manager, Operations J. Merchan, Senior Engineer, Programs ans Components Group P. Miktus, Supervisor, Design Engineering G. Miller, Senior System Engineer D. Mimms, General Manager, Operations D. Myers, Radiation Protection Specialist R. Northrup, Nuclear Safety Assurance C. Pratt, Design Engineer III M. Rathcke, Supervisor, Mechanical Maintenance D. Reynolds, Maintenance Specialist M. Robinette, System Engineer P. Sicard, Manager, Safety Analysis A. Spencer, Operations Coordinator C. Stout, Supervisor, Instrumentation and Control Maintenance N. Tison, Senior Emergency Planner W. Trudell, Manager, Corrective Action and Assessment
-2-R. Tunstall, Senior Technical Instructor D. Williamson, Senior Licensing Specialist NRC P. Alter, Senior Resident Inspector, River Bend Station E. Connell, Senior Fire Protection Engineer, NRR P. Qualls, Senior Fire Protection Engineer, NRR D. Allison, Generic Issues, Environmental, Financial, and Rulemaking Branch, NRR J. Tappert, Chief, Generic Issues, Environmental, Financial, and Rulemaking Branch, NRR ITEMS OPENED, CLOSED, AND DISCUSSED Closed 50-458/01-001 LER Unplanned Reactor Scram During Turbine Control Valve Testing. (Section 4OA3)
DOCUMENTS REVIEWED The following documents were selected and reviewed by the inspectors to accomplish the objectives and scope of the inspection and to support any findings:
Procedures RBNP-078, Operability Determinations, Revision 6 P870-53, Alarm Response, Revision 7 SOP-0010, MSR & FW Heaters Extraction Steam and Drains, Revision 22 OSP-0102, Turbine Valve Testing, Revision 6 LI-102, Corrective Action Process, Revision 1 MCP-1005, Testing and Calibration of GE Type GGP-53C Relay, Revision 5A RBNP-083, Reactivity Management, Revision 2 EDG-AA-115, Engineering Request - Response Development, Revision 0 ADM-0022, Conduct of Operations, Revision 30 OSP-0003, Logs and Records, Revision 12
-3-SOP-0010, Moisture Separator Reheater and Feedwater Heaters Extraction Steam and Drains, Revision 22 AOP-0007, Loss of Feedwater Heating, Revision 20 RPP-STD-01, "Radiation Protection Standards," Revisions 12 and 13 AOP-009, Loss of Normal Service Water, Revision 12 RBNP-004, Event Notification and Reporting, Revision 12 NSA 4.6, Nuclear Safety Assurance Reportability Guidelines, Revision 1 Operations Policy 006, Active Limiting Conditions of Operations, Revision 13 Condition Reports (CRs)
ECH-2001-0132 RBS-1999-1068 RBS-2001-1260 RBS-2001-0381 RBS-2001-0701 OPX-2000-0037 RBS-1999-1696 RBS-2001-0437 RBS-2001-0389 RBS-2001-0708 OPX-2001-0005 RBS-2000-0531 RBS-2001-0858 RBS-2001-0391 RBS-2001-0709 OPX-2001-0007 RBS-2000-0095 RBS-2001-1103 RBS-2001-0392 RBS-2001-0710 OPX-2001-0008 RBS-2000-0274 RBS-2001-0293 RBS-2001-0398 RBS-2001-0711 OPX-2001-0012 RBS-2000-0597 RBS-2001-0674 RBS-2001-0403 RBS-2001-0714 OPX-2001-0014 RBS-2000-0629 RBS-2001-0001 RBS-2001-0412 RBS-2001-0726 OPX-2001-0019 RBS-2000-0782 RBS-2001-0054 RBS-2001-0413 RBS-2001-0727 OPX-2001-0035 RBS-2000-0969 RBS-2001-0071 RBS-2001-0419 RBS-2001-0730 OPX-2001-0039 RBS-2000-1198 RBS-2001-0073 RBS-2001-0423 RBS-2001-0750 OPX-2001-0043 RBS-2000-1209 RBS-2001-0101 RBS-2001-0463 RBS-2001-0773 OPX-2001-0050 RBS-2000-1232 RBS-2001-0103 RBS-2001-0479 RBS-2001-0775 OPX-2001-0051 RBS-2000-1377 RBS-2001-0109 RBS-2001-0492 RBS-2001-0776 OPX-2001-0054 RBS-2000-1459 RBS-2001-0126 RBS-2001-0494 RBS-2001-0779 OPX-2001-0063 RBS-2000-1486 RBS-2001-0134 RBS-2001-0515 RBS-2001-0810 OPX-2001-0070 RBS-2000-1490 RBS-2001-0164 RBS-2001-0516 RBS-2001-0814 OPX-2001-0071 RBS-2000-1597 RBS-2001-0192 RBS-2001-0523 RBS-2001-0832 OPX-2001-0072 RBS-2000-1628 RBS-2001-0200 RBS-2001-0530 RBS-2001-0837 OPX-2001-0075 RBS-2000-1645 RBS-2001-0202 RBS-2001-0544 RBS-2001-0854 OPX-2001-0079 RBS-2000-1680 RBS-2001-0243 RBS-2001-0551 RBS-2001-0860 OPX-2001-0112 RBS-2000-1712 RBS-2001-0253 RBS-2001-0557 RBS-2001-0872 OPX-2001-0115 RBS-2000-1723 RBS-2001-0258 RBS-2001-0559 RBS-2001-0898 OPX-2001-0117 RBS-2000-1848 RBS-2001-0277 RBS-2001-0561 RBS-2001-0902 OPX-2001-0125 RBS-2000-1936 RBS-2001-0299 RBS-2001-0562 RBS-2001-0929 OPX-2001-0144 RBS-2000-1944 RBS-2001-0313 RBS-2001-0567 RBS-2001-0931 OPX-2001-0158 RBS-2000-1991 RBS-2001-0317 RBS-2001-0603 RBS-2001-0936 RBS-2001-1625 RBS-2000-1992 RBS-2001-0318 RBS-2001-0656 RBS-2001-0961 RBS-2001-1632 RBS-2000-1993 RBS-2001-0339 RBS-2001-0658 RBS-2001-0977 RBS-2001-1607 RBS-2000-2006 RBS-2001-0350 RBS-2001-0664 RBS-2001-0978 RBS-1996-1479 RBS-2000-2050 RBS-2001-0361 RBS-2001-0695 RBS-2001-0982 RBS-1998-1333 RBS-2000-2213 RBS-2001-0374 RBS-2001-0699 RBS-2001-0984 RBS-1999-0263 RBS-2001-0034 RBS-2001-0378 RBS-2001-0700 RBS-2001-0986
-4-RBS-2001-0995 RBS-2001-1141 RBS-2001-1215 RBS-2001-1309 RBS-2001-1520 RBS-2001-1006 RBS-2001-1143 RBS-2001-1216 RBS-2001-1336 RBS-2001-1632 RBS-2001-1008 RBS-2001-1169 RBS-2001-1249 RBS-2001-1337 RLO-2001-0102 RBS-2001-1086 RBS-2001-1174 RBS-2001-1254 RBS-2001-1345 RLO-2001-0111 RBS-2001-1086 RBS-2001-1182 RBS-2001-1269 RBS-2001-1358 RLO-2001-0126 RBS-2001-1087 RBS-2001-1199 RBS-2001-1285 RBS-2001-1368 RLO-2001-0136 RBS-2001-1130 RBS-2001-1201 RBS-2001-1285 RBS-2001-1369 RLO-2001-0152 RBS-2001-1134 RBS-2001-1214 RBS-2001-1298 Maintenance Action Item (MAI)
MAI 336589 MAI 336211 MAI 312253 MAI 341311 MAI 341051 MAI 350593 MAI 341314 MAI 345236 MAI 351559 MAI 341313 MAI 347438 MAI 345172 MAI 341312 Engineering Request (ER)
ER-RB-2001-0400, Postulated Fuel Assembly Drop Accident Analysis for High Density Spent Fuel Racks, 7/19/2001.
ER-RB-2001-0114, Change yoke material for heater dump valves from cast iron to steel yokes, 7/16/01.
ER-RB-2001-0198, Revise ERIS point associated with EHC system in main control panel, 4/23/01.
Audits and Assessments April Oversight Report, 4/01 May Oversight Report, 5/01 June Oversight Report, 6/01 July Oversight Report, 7/01 Security Self Assessment, RLO-2001-0047, 5/25/01 Dominion Oversight Benchmarking Report, 6/01 QA-3-2001-RBS-1-Multi-site, ENSW QA Multi-site Audit of the Corrective Action Program, 7/3/01 QA-6-2001-RBS-1, RBS QA Audit of Effluent and Environmental Monitoring, 9/25/01 QA-7-2001-RBS-1, RBS QA Audit of the Emergency Planning Program, 5/15/01 QA-14-2001-RBS-1, RBS QA Audit of the Radiation Protection Program, 4/10/01
-5-River Bend EP (Self) Assessment, 11/00 Self-Assessment Topic: Radioactive Material Control, 12/18/00 Self-Assessment Report: ALARA Planning and Controls, 3/01 RPG-M-01-013, Effluent Dose Calculations Self Assessment, 2/23/01 RBS Self-Assessment - CA&A - Evaluation of NRC Corrective Action Inspections at Other EOI Sites and RBS, dated 11/20/00 RBS Self-Assessment - CR Disposition Corrective Actions, dated 11/29/00 RBS Self-Assessment - Maintenance Department Standards and Expectations, dated 3/29/01 RBS Self-Assessment - CA&A Process Review, dated 6/21/01 RBS Learning Organization Assessment, dated 6/27/01 ENSW Quality Assurance Multi-Site Audit of the Corrective Action Program, dated 7/03/01 River Bend Corporate Operations Training Assessment dated June 18, 2001 QA-12-2001-RBS-1, RBS Quality Assurance Audit of Operations dated July 5, 2001 Self-Assessment Topic: Protective Tagging dated December 8, 2000 Self-Assessment Topic: The Operator Aid Program dated March 15, 2001 Licensed Operator Requalification Program Inspection Readiness Self-Assessment dated June 18, 2001 OP-2001-01-RBS, River Bend Station Human Performance Self-Assessment dated December 11 - 14, 2000 Miscellaneous Documents System Engineering Handbook, Revision 1, 1/11/01, Guideline 6.9, Plant/System Walkdown Guidelines.
Procedure Action Request (PAR) ARP-870-53R06CN-A dated 3/28/01.
Operations Standards and Expectations, Revision 12 Monthly Report-October 2001, Sec-2001-0050 (Security), 11/05/01 Emergency Planning Action Tracking System summary data from 5/1 to 11/28/01 EP-M-01-07, "Exercise Evaluation Report, ERO Team A," 3/6/01
-6-Engineering Calculation G13.18.12.2, Evaluate the wall that separates Fire Areas AB-7 and AB-18, 12/5/00 RBS QA Surveillance Report-QS-2001-RBS-0011 dated May 29, 2001 RBS QA Surveillance Report-QS-2001-RBS-026 dated July 17, 2001 RBS Quality Assurance Surveillance Report, QS-2001-RBS-042 RBS Quality Assurance Surveillance Report, QS-2001-RBS-043 RBS Quarterly Trend and Analysis Report - First Quarter 2001 RBS Quarterly Trend and Analysis Report - Second Quarter 2001 Entergy Root Cause Analysis Desk Guide, Revision 5 Entergy Corrective Action Process Desk Guide, Revision 2 Entergy Problem Trending Guide, Revision 2 RBS Engineering Expectations Guidance Document RBS System Engineering Handbook, Revision 1 RBS System Engineering Qualification Card, Revision 4 RBS General Employee Training, Revised 12/19/00 EOI Orientation Workbook, Corrective Action Program, Revision 00 RBS, Unit 1, Facility Operating License No. NPF-47 RBS Maintenance Rule Function(s) Listing RBS Maintenance Rule Performance Criteria NUMARC 93-01, Revision 2, NEI Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants
-7-Information Request 1 River Bend PIR Inspection (IP 71152) 01-08 The inspection will cover the period of December 19, 2000 to November 26, 2001. All requested information should be limited to this period unless otherwise specified. The information may be provided in either electronic (preferred) or paper media or a combination of these. Information provided in electronic media may be in the form of CDs (preferred), e-mail attachment(s), or 3 1/2 floppy disks. The agencys text editing software is Corel WordPerfect 8, Presentations, and Quattro Pro; however, we have document viewing capability for MS Word, Excel, Power Point, Access, and Adobe Acrobat (.pdf) text files. Where possible, it is preferred that the files be searchable text or data files vice image files.
Please provide the following information to Stephen McCrory in the Region IV Arlington office by October 15, 2001. If you have questions or comments, please contact Mr. McCrory at (817)
860-8265 or e-mail at slm@nrc.gov.
1. Summary list of all currently open/active items for:
a. condition reports of significant conditions adverse to quality b. engineering review requests c. maintenance requests 2. Summary list of all items completed/resolved/closed since December 19, 2000 for:
a. condition reports of significant conditions adverse to quality b. engineering review requests c. maintenance requests 3. Summary list of all condition reports generated during the specified period and sorted by:
a. chronology b. initiating organization c. responsible organization 4. All quality assurance audits and surveillances of corrective action activities since December 19, 2000.
5. All self-assessments and Non-NRC third party assessments of corrective action activity and functional area performance since December 19, 2000.
6. Corrective action performance trending/tracking information generated since December 19, 2000 and broken down by functional organization.
7. Current revision of the following procedures:
ADM-022, Conduct of Operations" ADM-0023, Conduct of Maintenance CPN LI-102, Corrective Action Process
-8-EDG-PR-001, Maintenance Rule Program EDG-PE-002 Guideline for Performing 10 CFR Part 21 Applicability Reviews ENG-3-033, Modification Design Control Plan ENG-3-037, Engineering Request Process LI-102, Corrective Action Process OE-100, Operating Experience Program PEP-0219, Reliability Monitoring Program RBNP-002, Root Cause Determination Guidance RBNP-010, Configuration Management RBNP-030, Initiation and Processing of Condition Reports RBNP-062, River Bend Industry Events and Analysis Program RBNP-069, Significant Event Evaluation RBNP-078, Operability Determinations 8. Any additional governing procedures/policies/guidelines for:
Condition Reporting Corrective Action Program Root Cause Evaluation/Determination Operator Work-Arounds Work Requests Engineering Requests Temporary Modifications Procedure Change Requests Deficiency Reporting and Resolution Training Needs Request/Evaluation 9. For each of the items (applicable to River Bend) listed below please provide the following:
- Full text of the condition report (please indicate any findings that did not result in a condition report or corrective actions)
- Any Roll-up or Aggregating Conditions Reports related to the generic communication or condition report.
- Root Cause analysis report (if applicable)
- Risk significance assessments
- Probable Cause evaluation (if applicable)
- Approved corrective actions
- Basis for extending originally approved due dates
- Evidence of corrective action completion (work packages, design change documentation, temporary modifications, training lesson plans/material, training attendance records, procedure revisions, etc.)
a. Part 21 Reports 2001-01 through last issued (2001-24 or later)
b. NRC Information Notices 2001-01 through last issued (2001-13 or later)
c. All LERs issued since December 19, 2000 excluding LER 00-016-00
-9-d. All NRC identified NCVs and Violations issued since December 19, 2000.
Information Request 2 River Bend PIR Inspection (IP 71152) 01-08 Please provide the information requested below to the PIR inspection team member indicated as soon as possible after the teams arrival on 11/26/01. All information may be provided in the medium most convenient (electronic or hard copy). If you believe that the NRC has previously comprehensively reviewed any of the following items with regard to problem identification and resolution, please identify them to the inspection team, who will assess the need for further review.
Please arrange the requested interviews to begin no earlier than 8 AM on 11/27/01 and to be completed by 3 PM 11/29/01. The interviews should be scheduled for about 45 minutes with at least 1/2 hour between interviews.
S. McCrory Full copies of the following CRs:
2000-0095 2000-1992 2001-0317 2001-0412 2001-0860 2000-0274 2000-1993 2001-0339 2001-0551 2001-0986 2000-1232 2000-2006 2001-0350 2001-0562 2001-1174 2000-1597 2001-0243 2001-0361 2001-0727 2001-1199 2000-1991 2001-0253 2001-0381 2001-0773 Interview:
Individual(s) to address the unsatisfactory assessments in the RBS Quality Assurance Audit of Effluent and Environmental Monitoring, dated 9/25/01 Individuals with PIR oversight responsibility for:
Radiation Protection Security Emergency Planning M. Schneider Full copies of the following CRs:
2000-1628 2001-0232 2001-0674 2001-0756 2001-0854 2000-1680 2001-0318 2001-0695 2001-0761 2001-0857 2000-1712 2001-0398 2001-0714 2001-0761 2001-0862 2000-2173 2001-0475 2001-0726 2001-0775 2001-0892 2000-2174 2001-0518 2001-0730 2001-0814 2001-0936 2000-2175 2001-0530 2001-0750 2001-0815 2001-1146 2001-0201
-10-Copies of with full event/condition descriptions, operability determinations, and reportability determinations for the following CRs (or full copies if thats easier):
2000-2213 2001-0374 2001-0567 2001-0872 2001-1201 2001-0034 2001-0378 2001-0580 2001-0898 2001-1214 2001-0071 2001-0389 2001-0603 2001-0902 2001-1215 2001-0073 2001-0390 2001-0627 2001-0929 2001-1216 2001-0101 2001-0391 2001-0639 2001-0961 2001-1249 2001-0103 2001-0392 2001-0656 2001-0995 2001-1254 2001-0109 2001-0403 2001-0658 2001-1006 2001-1285 2001-0126 2001-0413 2001-0664 2001-1086 2001-1298 2001-0134 2001-0423 2001-0708 2001-1087 2001-1335 2001-0164 2001-0437 2001-0740 2001-1103 2001-1336 2001-0200 2001-0492 2001-0776 2001-1130 2001-1337 2001-0202 2001-0494 2001-0779 2001-1134 2001-1340 2001-0277 2001-0544 2001-0807 2001-1141 2001-1345 2001-0293 2001-0557 2001-0810 2001-1143 2001-1358 2001-0299 2001-0559 2001-0858 2001-1169 2001-1368 2001-0313 2001-0561 Copies of the following self-assesments:
Maintenance and System Engineering Self-Assessments since 10/00.
Interviews:
Maintenance Manager - Tom Hildebrandt Maintenance Supervisors - Craig Stout (I&C), Danny Marble (Electrical),
Mike Rathcke (Mechanical)
Systems Engineering Manager - Amir Shahkarami (or his designate)
System Engineering Supervisors - Paul Miktus (Civil), Ronnie Cole (E/I&C)
Corrective Actions Program Manager - Bill Trudell