IR 05000458/1985051

Insp Rept 50-458/85-51 on 850616-0815.Violation Noted: Attachments 1 & 2 for Electrical & Control Board Lineups Not Completed.Deviation Noted:Preoperational Test Procedure 1-PT-210 Did Not Demonstrate RHR Sys Will Inject to Vessel

ML20137W893
Person / Time
Site:	River Bend
Issue date:	09/18/1985
From:	Bennett W, Bess J, Bundy H, Chamberlain D, Craig Harbuck, Jaudon J, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137W835	List: IR 05000616/2008015 ML20137W833 ML20137W841 ML20137W893
References
50-458-85-51, NUDOCS 8510040415
Download: ML20137W893 (19)

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APPENDIX C U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-458/85-51 CP: CPPR-145 Docket: 50-458 Licensee: Gulf States Utilities (GSU)

P. O. Box 2951 Beaumont, Texas 77704 Facility Name: River Bend Station (RBS)

Inspection At: River Bend Station, St. Francisville, Louisiana Inspection Conducted: June 16 through August 15, 1985 Inspector - ._ . 42*(# //2O 7 8 85 rlain, Se(ior Resident Inspector Date

. f. Qia (pdrs.1, ,3,4,5,5',7,8,9,and15)

f+c 47-r- sh/tc Date W. R. Bennett, Reactor Inspector (pars. 1, 2, 10, and 11)

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Date

' ,~ Reactor Inspecto (pa .{arbu 1, , 12, and 14)

bh/l 9//8/85 W. M. KcNbill, Reactor Inspector Dtite /

(pars.Iand13)

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-2-Yn J. E. Bess, Reactor Inspector /

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(pars. I and 9)

W3M H. F. Bundy, Reactor 4Wspector MWrs Date (pars. l' and 2)

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Approved: , . /?42 e f/d/8b

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, chief,tProject Section A, Date J./P. (daud IReactor ojects Branch Inspection Summary Inspection Conducted June 16 through August 15, 1985 (Report 50-458/85-51)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings, site tours, fuel transfer operations witness, preoperational test program implementation, initial fuel loading procedure review, River Bend Unit 2 site restoration work implementation, pipe supports anti restraints system testing, allegation follow up, maintenance procedures review, preoperational test results evaluation, high energy / moderate energy line break system review, reactor vessel and internals record review, licensee identified construction deficiency review, and facility review committee (FRC)

system operability review. The inspection involved 325 inspector-hours onsite by six inspector Results: Within the areas inspected, one violation was issued in the area of fuel transfer operations witness (failure to follow an administrative procedure, paragraph '4)' and one deviation was identified in the area of

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preoperational test results evaluation (failure to meet FSAR test commitment, l paragraph 11).

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e-2-Details

., Persons Contacted

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Principal Licensee Employees K. Arnstedt, Quality Assurance (QA) Engineer

• H. Cahill, Jr. , Senior Vice President,~ River Bend Nuclear Group

• T. F. Crouse, QA Manager P. J. Dautel,' Licensing Staff Assistant

, C.:Deddens, Vice President, River Bend Nuclear Group

• D. R. Derbonne, Supervisor, Startup and Test

• S. L.-Driscoll, Supervisor, Radiological Engineering

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S. Finnegan, Control Operating Foreman

.P. E. Freehill, Superintendent, Startup and Test

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• D. R. Gipson, Assistant Plant Manager, Operations P. D. Graham, Assistant Plant Manager, Services R. W. Helmick, Director, Projects

• B. E. Hey, Licensing Engineer K. C. Hodges, Supervisor, Quality Systems

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D.~ Jernigan, Engineer, Startup and Test

• G. R. Kimmell, Supervisor, Operations QA

• V. King, Supervisor, Plant Services

• A. D. Kowalczuk, Assistant Plant Manager, Maintenance

• T. L. Plunkett, Plant Manager J. G. Propson, Electrical Supervisor, Nuclear Plant Engineering S. R. Radebaugh, Assistant Superintendent, Startup & Test S. F. Sawa, Control Superintendent, Startup & Test

• M. Searcy, QA Engineer

• J. E. Spivey, QA Engineer R. B. Stafford, Director, Quality Services K. E. Suhrke, Manager Project Planning & Coordination L. Sutton, QA Engineer

• P. F. Tomlinson, Director, Operations QA R. West, Supervisor, Startup and Test Stone and Webster D. P. Barry, Superintendent of Engineering F. W. Finger, III, Project Manager, Preliminary Test Organization (PTO)

P. H. Griffin, Site Advisory Manager

• B. R. Hall, Assistant Superintendent, Field Quality Control (FQC)

R. L. Spence, Superintendent, FQC General Electric S. Garg, Principal Engineer

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I-3-The NRC senior resident inspector (SRI) also interviewed additional licensee, Stone and Webster (S&W), and other contractor persor.nel during the inspection perio * Denotes those persons that attended the exit interview conducted on August 22, 198 NRC inspector, W. B. Jones, also attended the exit intervie . Licensee Action on Previous Inspection Findings (Closed) Open Item (458/8408-01): Determine if and how the diesel generator loading restrictions of calculation 12210-E-122 are implemented in plant' operating procedure Calculation 12210-E-122 was superseded by calculation 12210-E-192,

" Standby Diesel Generator Loading Calculation." Revision 1 to calculation E-192 was issued on August 7, 1985, to determine the maximum continuous loads to be supplied by the Division I and II standby diesel generators (EG1A and EG1B) during a loss of coolant accident (LOCA) concurrent with a loss of offsite power (LOP) and assuming a single failure of Division I, II or III. diesel generator Three load profile curves were generated and all three require operator action to drop certain loads 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after LOCA initiation prior to the adding of certain~ manually initiated load The SRI reviewed Abnormal Operating Procedure A0P-0004, " Loss of Offsite Power," Revision 2, to determine that the diesel generator loading restrictions of calculation E-192 were implemente All of the load restrictions from the load profile curves were implemented by A0P-000 This item is close (Closed) Unresolved Item (458/8408-04): Review of licensee program for tracking of commitments to the NR This item remained open for the SRI to evaluate the GSU method of identifying commitments that require closure prior to fuel 1 ca Many commitments made to the NRC include a committed date for completion and the committed date becomes the internal action completion date for tracking purposes. For items with no committed completion date, GSU nuclear licensing makes the determination whether the item requires closure prior to fuel loa The SRI reviewed the list of items that GSU nuclear licensing has determined can be completed after fuel load and no concerns were identifie This item is close , (Closed) Open Item (458/8415-01): Development of a. qualification matrix for project engineering and nuclear plant engineering personne .

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-4-The SRI was provided copies of the qualification matrixes for selected project engineering and nuclear plant engineering personnel and back up documentation for completed training. The qualification matrixes included education,. experience, and training requirements. All

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records reviewed were in orde This item is close (Closed) Open item (458/8424-02): Concern with the seismic adequacy of plastic tie wire supports used in combination with ~ spade type terminations in the control roo General Electric letter GSS-4676 dated June 13, 1985, confirms that the seismic testing of control room and other panels utilizing the spade lug with plastic tie wrap supports has been verified for seismic adequacy. The letter refers to design record file A00-579 for qualification documentatio This item is closed, (Closed) Violation (458/8512-02): Control of temporary alteration Corrective action included auditing of all temporary alterations and

. assigning dedicated personnel to control entries to the temporary alteration log and to verify correct installation and/or removal of temporary alterations. The NRC inspector verified the implementation of these corrective action This item is close (Closed) Open Item (458/8513-02): Issuance and approval of procedures for scheduling preventive maintenanc The NRC inspector reviewed procedures for scheduling' preventive maintenance and discussed the system with licensee personnel. The preventive maintenance system is considered adequate at this tim This item is close (Closed) Open Item (458/8522-02): Requirement for notification of quality control (QC) prior to the start of safety-related maintenance wor Administrative Procedure ADM-0028, " Maintenance Work Request,"

Revision 4, now states that "Q.C. shall be notified prior to performing safety-related "Q" maintenance and maintenance on the Radwaste, Radiation Monitoring and Fire Protection Systems."

This item is closed.

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+1-5- (Closed) Open Item (458/8522-03): A program has not yet been established for reviewing completed corrective maintenance records to assess the adequacy of the preventative maintenance program, to identify repetitive failures of parts and components, and to identify design deficiencie Administrative Procedure ADM-0048, " Performance Monitoring and Trend Analysis. Program," Revision 0, was issued on July 29, 1985, to establish "the program for monitoring plant, system or component performance and trending data as necessary to identify losses in MWe output, optimize plant performance and meet various performance monitoring and trending commitments." This monitoring includes such things as performance evaluations of power system efficiencies, vibration monitoring, and monitoring of failures of specific plant component This. item is close (Closed) Open Item (458/8522-04): Licensee has not established a definition of acceptable locking devices for valves and circuit breaker Administrative Procedure ADM-0020, " Plant' Key Control," Revision 1, establishes definitions of acceptable locking devices for valves and circuit breakers. These include a chain and padlock for locked valves, a padlock or other key locked restraining device for locked

' breakers and wired for sealed valve This item is close (Closed) Open Item (458/8522-05): The procedure which provides for

. tabulating performance data for motor operated valves was still in draft for Procedure CMP-1253, "Limitorque Motor Operated Valves'," Revision 2, was issued on July 25,-1985. Appendix A of this procedure provides a tabulation of motor operated valve data which includes torque to open and close valves, torque switch type, motor size, motor voltage,. full load amps, locked rotor amps, and valve stroke tim ,

This item is~ close (Closed) Open Item (458/8522-06): Procedure CMP-1026 is currently being revised to provide for tabulation of data pertinent to elec- -

trical breaker overload relays, heater size, breaker size, and. trip setting.

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Procedure CMP-1026, " Corrective Maintenance of MCC Starters,"

Revision 2, was issued on July 25, 198 Appendix A of this procedure provides a tabulation of data for electrical breakers which

' includes overload relay NEMA size, heater size, breaker size, and breaker trip settin This item is close . (Closed) Open Item (458/8522-08): GSU has not identified which motor operated valves have operators with nonlocking gears or brake assemblie GSU conducted a review of all motor operated valves at River Bend and determined that they all have self-locking gears and none of the valves have brake assemblie This item is clcse (Closed) Open Item (458/8522-09): Establishing a master schedule for preventive maintenanc The NRC inspector determined that a master schedule for preventative maintenance is being utilized at this tim This item is close (Closed) Open Item (458/8522-11): Cleanness classifications of plent systems have not been establishe This item involved a failure to establish cleanliness grades for all systems and inclusion of these grades in ADM-0018. This was accom-plished in ADM-0018, Revision 1. However, the NRC inspector ident-ified several apparent discrepancies in the program for the cleanin of fluid systems and associated components as follows:

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Section 4.2 of ADM-0018 states that the mechanical maintenance supervisor assigns cleanness grades. Section 5.1.1 of GM-0062, Revision 0, states that the general maintenance supervisor or designee assigns cleanness grade There appears to be a potential conflict of interest in either instance in that an individual who may be responsible for cleaning has been author-ized to establish acceptance criteri Also, it appears that assignment of cleanness grades should be an engineering functio . Grades of cleanness are defined in procedures ADM-0018, MSP-0013, and GMP-006 These definitions are not identica .

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. ANSI N45.2.1-1973 requires that cleanness inspection personnel be qualified per ..NSI N45.2.6. Procedure GMP-0062 is not clear on who.should sign for inspections and what qualifications the inspectors should hav Open item 8522-11 is closed with the resolution of the above noted discrepancies considered an open item. (458/8551-03) (Closed) Open Item (458/8522-13): Surveillance testing and calibra-tion control program'does not yet include the inservice testing /inspec

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tion requirements of 10 CFR Part 50.55(a).

There are two major testing / inspection programs scheduled to be in place at River Bend. One is the surveillance test procedure (STP)

program and the other is the in service inspection (ISI) progra The STP program deals with the functional performance and operability of systems and components required by technical specifications and the ISI program deals with nondestructive examination of components and pump and valve testing required by 10 CFR Part 50.55(a). ISI activities are generally covered by ISI procedures, however, 'there are some activities required by the ISI plan that are covered by STPs. These activities would include visual inspections, functional testing of' mechanical snubbers, and inspections of certain pumps and valves. In these instances, performance of the activities would be tracked in both the ISI and STP programs. As noted previously, a master schedule for surveillance testing / calibration has been established, but the River Bend 10 year ISI plan has not been submitted to the NRC. Per discussions with NRC licensing, the SRI was informed that the submittal of the ISI plan will be made.a low power testing license condition for River Ben Since the submittal of the ISI plan will be tracked as a license condition, this open item is closed, (Closed) Open Item (458/8522-31): Responsibility for reporting design changes and modifications to the NRC has not been establishe CFR Part 50.59 requires an annual report to the NRC of changes to the facility as described in the safety analysis report, River Bend Administrative Procedure ADM-0010, " Station Reporting Requirements",

identifies the requirement for an annual written report per 10 CFR Part 50.59(b) to be submitted to NRC Region IV and the Director of Inspection and Enforcemen This item is close (Closed) Open Item (458/8523-01): "Q list" was not inclusive and the procedures for control and use of the "Q list" were not approve ,_ ._ -. . . _ _

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The following nuclear plant engineering (NUPE) procedures for control and.use of the "Q list" have been approved and issued:

. NUPE AA-64, Revision 0, " River Bend Station Instructions and Requirements for Use of th_e~ River Bend Q-List"

. NUPE-AA-63, Revision 0, " Control and Maintenance of the River Bend Q-List" The procedures state that all River Bend project personnel are responsible for using the Q-list to determine whether a system',

structure, component or an activity relating to a system, structure, or component is safety-related. Activities which may be safety-related, and therefore shall include use of the Q-list to determine such,' include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifyin Revision 0 of the Q-list has been issued and the list is still not all inclusiv However, Q-list users are required to contact NUPE.if a desired mark number is not located in the Q-list to determine whether the component is safety-related or no This item is close (Closed) Violation (458/8523-02): Preoperational test procedure-1-PT-210 was approved for performance without the procedure being stamped to establish notification points for operations quality assuranc The test procedure was immediately stamped to establish notification points for operations quality assurance. Although the procedure was not stamped, project quality test group personnel were notified and were present during the conduct of testing. Also, in order to prevent recurrence of this violation, startup and test personnel-received special training on the requirements of test instruction-(TI) -8, " Conduct of Testin This item is close (Closed) Violation (458/8523-03): The procedure used for the conduct of the HVAC systems duct leakage testing at River Bend did not require the use of a temperature indicating device and no temperature monitoring was conducted during leak testing performanc S&W mechanical test procedure 1.MPGEN.003, "HVAC Pressure and Leak i Test Procedure for ANSI 509/510 Ductwork," was written to include the '

requirement for use of a " temperature indicating device accurate and l

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.-9-i readable to + or - 0.5 F. All previously tested safety-related ductwork is being retested utilizing the new procedure. This 100%

retest of safety-related ductwork is being monitored by the SRI as an NRC open item (458/8523-05).

This item is close (Closed) Violation (458/8523-04): The gas meter used for HVAC duct

' air leakage testing at River Bend was not calibrated in the range of us All safety-related ductwork is being retested utilizing mechanical test procedure 1.MPGEN.003, "HVAC Pressure and Leak Test Procedure for ANSI 509/510 Ductwork," which uses the pressure decay method for

- determining the leakage rate instead of the gas meter method. . This 100% retest of safety-related ductwork is being monitored by the SRI as an NRC open item (458/8523-05).

This item is close .

' Site Tours The SRI toured areas of the site during the inspection period to gain

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knowledge of the plant and to observe general job practices. The site tours conducted-included special tours on separate occasions with Mr. R. P. Denise (NRC Region IV Division Director) and Mr. R. D. Martin

_(NRC Region IV Regional' Administrator). The SRI also made several tours ,

of.the-containment and toured the suppression pool while it was drained for cleaning. During the tours it was noted that a number of tags remain on system components (e.g.,' jurisdictional tags', hanger as built tags, caution tags', etc.). The SRI discussed this with licensee management and action has been initiated to remove all tags that are no longer required for the operational phase activitie The removal of unnecessary equipment tagging will be an open item (458/8551-04).

No violations or deviations were identified in this area of inspectio . Fuel Transfer Operations Witness The SRI witnessed portions of the new fuel transfer from the spent fu'el pit to the containment refueling floor storage area. The licensee trans-ferred 200 fuel bundles through the inclined fuel transfer system in preparation for fuel loading of the reactor. During the witness of the fuel transfer operation, the SRI reviewed procedural documentation for TCN 85-1131 to procedure FHP-0005, " Fuel Transfer Tube Operations," which was required for conduct of fuel transfer operation It was noted by the SRI that the TCN was not stamped "TCN SHIFT SUPERVISOR APPROVED COPY"

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-10-in red ink and the fuel transfer evolution was being conducted even though the TCN was not followed exactly , which is in violation of administrative procedure ADM-003, " Development, Control and Use of Procedures,"

Revision 6. This failure to follow an administrative procedure was identified as a violation (458/8551-01). The licensee took immediate action to halt fuel transfer operations and to correct the procedural deficiencies identified. No other problems were identified with the fuel transfer operatio . Preoperational Test Program Implementation This area of inspection was conducted to assure that current design documents were being.used by test personnel for test development and conduct and to review the control of design change packages. The licensee startup program requires that all preoperational test procedure reference revisions be identified at the time of procedure development and that the latest revision be noted and checked for test impact at the time of test performance. This revision check is then administratively performed again during the review of test result The SRI checked 30 document references for the reactor protection system preoperational test and the correct revisions were verified at the time of test performanc The review of design change control packages revealed that in addition to the design requirements for review, approval and control of engineering and design coordination reports (E&DCR), the licensee has established a method of assembling design modification packages (DMP) to assure that all required actions are implemente No violations or deviations were identified in this area of inspectio : Initial Fuel Loading Procedure Review The SRI reviewed procedure 1-ST-3, " Fuel Loading," Revision 0. Several concerns and questions were generated as a. result.of this review primarily relating to the general prerequisites of the procedur All of the concerns and questions were discussed with the responsible startup and test personnel, and it was noted during these discussions that Major Change Request (MCR) No. 1 to the procedure had been issued and some of the concerns were already addressed by MCR-1. Subsequent to the discus-sions, MRC-2 to the procedure was issued to address the remaining concerns and questions of the SRI. MCR-1 and 2 addressed such concerns as:

. Composition of fuel handling crew

. Clarification of prerequisites for radiation monitoring and nuclear instrumentation

. Prerequisite for inspection of fuel

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. Prerequisite for containment status

. Prerequisite for reactor pressure vessel status

. Prerequisite for cleanliness requirements

. Addressed moderator temperature monitoring

. Addressed action for unexpected neutron flux or detector response behavior

. Referenced procedure for lowering of SRM setpoints The SRI believes that the initial Fuel Loading Procedure 1-ST-3, Revision 0, as amended by MCR 1 and 2, is consistent with licensee commitments, regulatory requirements, and applicable codes and standard No violations or deviations were identified in this area of inspectio . River Bend Unit 2 Site Restoration Work Implementation A Board Order dated November 20, 1984, states, "That applicants' request to withdraw without prejudice the application to operate River Bend Station Unit 2 is granted, and the proceeding is terminated as to Unit 2, subject to.NRC. Staff approval of the implementation of site restoration work described in applicants' June 1984 Report on Termination of Construc-

-tion."

NRC Region IV will monitor GSU implementation of the Unit 2 site restora-tion work and will notify the NRC Office of Nuclear Reactor Regulation, Division of Licensing, upon completion of the verificatio NRC Region IV will track this activity as an open item (458/8551-05). Pipe Supports and Restraints System Testing This area of inspection was conducted to review the licensee programs pertaining to the examination and testing of safety-related pipe support and restraint systems. The SRI review of this area revealed that two '

separate programs exist at River Bend, one for the General Electric.(GE)

scope of supply and one for the S&W scope of supply. A review of these programs. revealed that they both covered the following elements: Examination of piping support systems at various temperatures to detect interference to thermal expansio Setting and calibration of snubbers, restraints, and vibration arrestors at predetermined temperature E ,

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t-12- Examination of pipe support and restraint systems during transient l testing to ascertain that pipe motion and vibration are within design limit l Conduct af vibration tests, including resolution of high vibratio Displacement measurements at ambient and operating temperatur It was noted during this review that the GE program contained limits for expected minimum and maximum pipe movement and the S&W program only contained limits for expected maximum pipe movement. This was discussed by the SRI with responsible personnel, and the S&W program was modified to include expected minimum and maximum pipe movemen Any pipe movements that. exceed the expected minimum or maximum limits must be evaluated by GE or S&W engineerin .No violations or deviations were identified in this area of inspectio . Allegation Follow Up (Closed) Allegation: The NRC inspector reviewed and conducted a followup inspection on the concerns of an allegation made to GSU which could have an impact on plant safety. The following is a summary of this activity:

Allegation: The alleger stated that the "as wired" signal / ground circuit configuration of Rosemount trip units located in the control room PGCC panels does not comply with the Rosemount Instrument Manual Instruction in that~ signal common is not electrically isolated from chassis commo Signal common and earth common are tied together through a common earth groun This condition is causing spurious tripping of trip units when an adjacent unit is withdrawn from or inserted into a card fil Followup In'spection: The NRC inspector interviewed responsible personnel and reviewed available_ data to ascertain if a problem or problems existed which may have_an impact on plant safety. The NRC inspector reviewed the Rosemount Instrument Manual and examined the signal circuits in the Rosemount instrument panels. There were no discrepancies identifie However, after talking to several S&W, Gulf States Utilities (GSU), and GE personnel; it was noted that a conflict had been identified between a GE drawing for grounding and the "as installed" conditions. The conflict appeared to be that the GE drawing required the instrumentation ground to be isolated. The "as installed" configuration showed the instrument ground bus, the signal common bus, and the chassis ground bus to be connected to the floor section instrument ground bu The disposition of this conflict involved revising the GE drawing to reflect the "as installed" conditions of the panels. The NRC inspector reviewed GE Field

> Deviation Disposition Request (FDDR) No. LDI-3128, Revision 0, which was issued to evaluate and resolve this conflict. The NRC inspector also

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-13-reviewed. documentation relating to instrument calibration problems. The problem according to the PGCC engineering groups resulted from grounding busses being overloaded. A total of 42 FDDRs were issued to break up the

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busses, install larger wiring, and correct various cases of improper connection The NRC inspector randomly selected FDDRs to verify work completion and no discrepancies were identifie In' addition to the grounding problem, the NRC inspector inspected the alleger's concerns pertaining to the spurious trip The NRC inspector reviewed the following documentation for the Rosemount Trip / Calibration System:

. Instruction Manual - Trip / Calibration System Model 510 DV

. Elementary Wiring Diagram - Low Pressure Core Spray System

. Functional Block Diagram - Master Trip Unit The situation was also discussed with responsible GSU and GE personne GSU conducted a number of bench tests of the Rosemount trip units with various grounding arrangements in order to evaluate the spurious trip proble As a result of these tests, it was determined that the Rosemount trip units may produce random false trips and false alarms anytime one of these units is pulled (unplugged) from service. Isolation of the signal common did not appear to correct the problem. It should be noted that the false trips occur in trip units of a single channel which alone would not cause any plant trip, equipment trip or safety actuatio The NRC inspector reviewed the GE position (FDDR No. LDI-3178).which indicates that this problem appears to be an inherent design characteristic of the'

Rosemount trip units and is not caused by improper signal / ground circuit

. configuration. GSU action that is ongoing for this problem includes short term action to establish administrative controls for corrective / preventive maintenance of the Rosemount trips units ~which requires. installing the calibration read out assembly or removing a card from a card fil Maintenance procedures will be revised to identify trip units that may be affected during maintenance and to require the technician to notify the

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nuclear control operator prior to start of the maintenanc A long term solution is being pursued through ongoing engineering evaluatio Conclusion: Based o_n the above, the alleger's concerns with the grounding / bus problem was substantiated, but GSU was working ~to resolve the problem. The PGCC grounding problems have now been resolved and verified as not being the cause of the spurious trip The spurious- trip problem does exist, but it is not considered a safety problem due to the following:

. Once a trip unit is initially calibrated and tested it is not frequently remove . . - - - .

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. Spurious trips occur in single channels only and single safety channels do not cause any plant trips, equipment trips or safety actuatio . Administrative controls are being implemented to provide technician and operator awareness of the potential for spurious trips and alarms

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during the conduct of maintenance.

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Therefore, this allegation is closed, but the NRC inspector will monitor the implementation of the administrative controls and monitor the engineering evaluation for a long term solution to the spurious trip problem. This will be tracked as an open item (458/8551-06).

10. Maintenance Procedures ,

The objective of this portion of the inspection was to confirm that the plant maintenance procedures are prepared to adequately control maintenance of safety-related systems within applicable regulatory requirements.

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The NRC inspector reviewed the following procedures:

Procedure Title Revision Date f GMP-0077 Gasket Replacement and 0 1/16/85 Maintenance of Gasketed Surfaces TCn85-691 5/31/85 GMP-0081 Valve Maintenance 0 2//04/85 Program CMP-1001 Corrective Maintenance 1 7/07/85 of Potential Transformers CMP-1030 Battery Cell Jumpering 2 5/04/85 and Replacement TCN 85-088 5/09/85 CMP-1031 Activation and Initial 1 4/15/85 Charging of Dry-Charged Stationary Batterie CMP-1074 Corrective Maintenance of 1 7/06/85 RHR Pump Motors CMP-1245 Corrective Maintenance of 0 3/29/85 Emergency Diesel TCN 85-317 5/27/85

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-15-CMP-9107 Emergency Diesel Starting 2 6/26/85

~ Air Compressor, Disassembly, Inspection, Rework, and Reassembl CMP _-9144 - Main Steam Relief. Valve 2 6/26/85 Disassembly,. Inspection, Rework, and Reassembl CMP-9033 C11-0001 Hydraulic Control 2 6/25/85 Unit Component Removal, Dis-assembly, Inspection, Rework, Reassembly, and Inspectio MCP-4066 Calibration of Rosemount 1 3/28/85

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Model 1151 Transmitter

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MSP-0003 . Preventive Maintenance 2 5/01/85 Program MSP-007 Maintenance Planning 1 6/07/85

!and Scheduling The NRC inspector found several typographical errors in the maintenance U

procedures and notified the licensee of these error The maintenance

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, _ procedures were found to be adequate for the desired maintenance. .The_NRC inspector, utilizing the procedure review and interviews with maintenance personnel, determined that the preventive maintenance system is in the process of being established and is working at this tim No violations or deviations were identified in this portion of the inspectio +

1 Preoperational Test Results Evaluation The objective of this portion of the inspection was to assure that the licensee is performing an adequate evaluation of test results and to ascertain-that the licensee had adequately tested the remote shutdown system with results as follows: The NRC inspector reviewed completed Preoperational Test Procedure 1-PT-210, " Integrated Emergency Core Cooling System and Loss of Offsite Power." Review determined that the test did not ensure that the RHR system would realign and inject to the reactor vessel from the test mode as committed to in the River Bend FSAR. This is an apparent deviation (458/8551-02). Subsequent discussion with startup-and test personnel revealed that the realignment and injection from the. test mode was not performed because of possible RHR pump'run ou The NRC' inspector questioned if this was a concern during an actual loss of coolant accident and if this was addressed in the accident analysis. This is considered an open item (458/8551-07).

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-16- The NRC inspector reviewed the licensee's preoperational test results documented in procedure 1-PT-200, " Remote Shutdown System," (RSS),

and in the RSS portions of procedures 1-PT-202, " Automatic Depressur-ization System," and 1-PT-552, " Containment Monitoring System." It was determined that the RSS appeared to have been tested in accordance with the. requirements of-the licensee's startup manual (SUM), that the acceptance criteria had been met, and that test exceptions had been properly _dispositioned and closed with the following exception:

. Test Exception - 21 and the corresponding acceptance criteria, step 10.9, were still outstanding. The problem is that an interlock between two motor operated valves in the residual heat removal (RHR) system mandatory flow path to the pressure vessel, does not exist when control of these valves is trans-ferred to the RSS panel. The valves are 1E1Z*M0VF0278 (278) and IE12*MOVF0428 (428). The interlock is designed to prevent over pressurization of the RHR system during routine surveillance

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cycling of these valves by preventing the manual opening of either valve if the other valve is not fully shu The NRC inspector considered.this to be an open item (458/8551-08)

pending NRC review of the disposition and closure of this T . High Energy / Moderate Energy Line Break System Review The purpose of this area of inspection was to verify that the hardware associated with the design modification package (DMP-4) based on the high energy line break (HELB) detection and mitigation and the moderate energy line break (MELB) detection and mitigation had been installed and teste The NRC inspector reviewed a sample of the completed work documents and generic test data and visually inspected several temperature sensors and level sensors in'the plant (comparing them to the documents reviewed). It was concluded that DMP-4 appeared to have been properly implemented. The NRC inspector also determined that the special situation test (SST-53) for DMP-4 had been completed but was still undergoing licensee revie . Completion of the licensee review of SST-53 test results will remain as an open item (458/8551-09).

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No violations or deviations were identified in this area of inspectio . Reactor Vessel and Internals Record Review The objectives of this inspection were'to review a sample of reactor vessel and internals records and determine whether (a) the licensee system forfpreparing, reviewing, and maintaining records is functioning properly; (b) the selected records reflect work accomplishment consistent with NRC requirements and SAR commitments; and'(c) the records indicate any potentially generic problems, management control inadequacies,'or other weakness that could have safety significanc ,

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-17-The sample established for the inspection included steam separators, steam dryers, shroud,- jet pumps, control rod drive (CRD) housings, in-core housings, core plate and top guide in addition to the reactor vessel (RV).

The material certifications and receipt inspection of these components were reviewed. The records found on file were a~ GE product quality certification, ASME code reports, deviation report, certified material test reports (CMTRs) and NDE reports of welds. A number of errors were identified in these records. GE certification No.2645 was found to have an erroneous serial number (2007) for an in-core housing. A revised certification, No.10868, was issued by GE to correct these errors. The Sun Shipbuilding and Dry Dock Company data packages were found to have some errors. The shroud package did not have penetrant test (PT) reports for long seams L1 through L3 of the top flange rings (piece No. 5) although r6diographic test (RT) reports were on file for the same welds. The top guide package had a report on the repair of cubicle side walls. It documented that two heats of weld metal had been used (12051 and 16004C);

although the package had a CMTR for heat No. 16004C, it did not have a CMTR for heat No. 12051. Also in the same package were RT reports for long seams LS1 through LS8, but PT reports for only six seams for the water seal ring. The steam dryer had only a product quality certification and no additional data (e.g., CMTRs). It was noted that there was no product quality certification on file for the steam separator (non-code part) nor were there code forms, CMTRs, etc. for the CRD housing (code parts). CRD housing records are reportedly on file at GE, Wilmington, North Carolin The installation and inspection of installation records were reviewe These records were inspection reports of the RV and internals alignment, bolting, cleanliness, rigging and etc. It was noted that the RV was received with much of the internals installed (e.g., core plate, top guide, jet pumps CRD, and in-core housings. Storage records of the RV were reviewed to verify proper storage of the RV. In this regard the equipment storage history cards, maintenance check records and warm air system check logs were reviewed. It was noted that logs of the tempera-ture checks covered a time period from June 1981 to August 1983, however, the filter checks went on to June 1984 with a break in these filter records from January 1984 to April 1984. The RV was subsequently installed and inspected. This inspection indicated that the RV had been properly stored. In regard to the record problems identified above, open item (458/8551-10) was issued. The errors above are being followed by GSU Q The NRC shall review in a later inspection GSU review of NSSS records supplied by GE and the NSSS records to assure that no significant problems exist in these record . Licensee Identified Construction Deficiency Review This area of inspection was conducted to review action taken on the following licensee identified construction deficienc , -

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-18-(Closed) Construction Deficiency Report DR-295: '" GE AKD-6 480 V Switchgear".

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. Initial NRC notification date: March 27, 198 . Final - report: GSU letter RBG-21680 of July 24, 198 The corrective action for this reportable deficiency was to inspect the charging mechanisms. on the 28 breakers in question and-to correct any problems foun Part of this corrective action was to functionally test the breakers after repairs were made. A review of rework documentation by the NRC inspector revealed that all 28 breakers had been inspected, repaired, and tested as require . This item is close . Facility Review Committee (FRC) System Operability Review-This area of inspection was conducted to determine how the licensee was evaluating any remaining system related open items to determine the potential effect on system operability. The licensee has established a program for. the FRC to review outstanding system open items and to identify any~ items that potentially effect system operability. These FRC identified system operability items then require resolution prior to declaring the-system operabl The SRI reviewed several systems that had received the FRC: operability review and the program for system operability review is commendable. The potential sources of system open items (e.g., master punch _ list, nonconformance reports, engineering and design coordination reports, etc.) are being reviewed and any work items and/or paper items

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- that could~effect system operability are being identified for resolutio I

'No violations or deviations were identified in this area of inspectio . Exit Interview t -

An exit interview was conducted on August 22, 1985, with licensee '

representatives (identified in paragraph 1). During this

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interview, the SRI reviewed the scope and findings of the inspectio ,

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