Text

Insp Rept 50-458/97-05 on 970210-14.No Violations Noted. Major Areas Inspected:Licensee Implementation of Std TS
	ML20137A809
Person / Time
Site:	River Bend
Issue date:	03/14/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20137A790	List: IR 05000458/1997005; ML20137A785;
References
	50-458-97-05, 50-458-97-5, NUDOCS 9703210085
	Download: ML20137A809 (11)
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ENCLOSUR U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-458

l License No.: NPF-47 l

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Report No.: 50-458/97-05 ,

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Entergy Operations, In '

Licensee: Facility: River Bend Station

! Location: St. Francisville, Louisiana ;

j Dates: February 10 14,1997 l Inspectors: Thomas R. Meadows, Reactor Engineer ICriminer)

Thomas O. McKernon, Reactor Engineer (examiner)

Michael E. Murphy, Reactor Engineer (Examiner) j Approved By: John L. Pellet, Chief, Operations Branch !

Division of Reactor Safety l l

i Attachm9nt: Supplemental information

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a-9703210005 970314 PDR ADOCK 05000458 0 PM

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EXECUTIVE SUMMARY River Bend Station l NRC inspection Report 50-458/96-05 This inspection reviewed a portion of the licensee's implementation of the improved standard Technical Specifications. The inspectnre were to ascertain whether the licensee had invoked the appropriate provisions or conditions of the NRC approval documented in the safety evaluation. Particular emphasis was to be placed on licensee procedures and controls for those requirements that have been relocated from the Technical Specifications )

to other document Operations

The inspectors ccncluded that the licensee's audits, conducted up to the time of this inspection, were adequate in scope to review the transition process to the improved Technical Specifications (Section 03.01).

The licensee successfully revised its previous Technical Specifications to the format of NUREG 1434,"BWR Standard Technical Specifications," and relocated requirements to other documents as appropriate in accordance with the license Amendment 81 safety evaluation. The inspectors noted some vunerabilities in the licensees safety function determination program (Section 03.02).

The inspectors closed a violation for a failure to implement the requirements of Technical Specifications 3.0.6 and 5.5.10 (Sections 03.02 and 08.1).

The inspectors concluded through a sampling of relocated Technical Specification elements and a review of the supporting control process that the licensee had successfully implemented the Improved Technical Specification program. In addition, the majority of the recent problems identified with the licensee's surveillance program were not caused by the improved Technical Specification conversion process (Section 03.03).

The inspectors reviewed one safety related surveillance procedure to determine its adequacy and concluded that the surveillance test appropriately tested the affected circuits of the subject sensor and instrument loop (Section 03.04).

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Ecoort Details i

1. Operations 03 Operations Procedures and Documentation O3.01 Licensee Audits

. Inspection Scooe (Tl2515/130)

l l The inspectors reviewed the licensee's Technical Review ivianual Comment

Resolutions & Audits from October 1995 through November 1996. These licensee

audits were conducted to verify that the improved Technical Specifications

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contained all of the requirements from the original Technical Specifications or

there was documeated justification for relocation of the original requirements.

I Observations and Findinas The licensee's audits reviewed a sample of the requircloents from the Technical

Specifications, Technical Specification bases, and technical requirements manual.

The licensee's audits also included some of the revised surveillance procedure l The licensee determined that the more restrictive, less restrictive, and relocated i Technical Specification requirements were accounted for in the technical requirements manual or the Technical Specification bases and justifications were properly documented. The inspectors could find no Technical Specification requirements that were unaccounted for within the scope of the licensee's audits.

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The licensee also audited some surveillance procedures, revised as part of the

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Technical Specification transition. The licensee determined that the audited surveillance procedures complied with Plant Administrative Procedures, Conclusions The inspectors concluded that the licensee's audits conducted up to the time of this inspection were adequate in scope to review the transition process to the improved Technical Specification .02 Improved Technical Specification Implementation Insoection Scoce (Tl2515/130)

The inspectors reviewed the improved standard Technical Specifications, which the licensee implemented at the station in October 1995, using the format and guidance of NUREG-1434,"BWR Standard Technical Specifications." The inspectors compared the current Improved Technical Specifications with marked up copies of the previous Technical Specifications and the safety evaluation report, approved and

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issued for the requested license Amendment 81, to determine the disposition of requirements from the previous Technical Specifications. The licensee provided a change document which described the changes made to the previous Technical l Specifications and disposition of items and actions that were not transferred to the new Technical Specifications. The inspectors reviewed and verified the information

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and justifications given in the change document, Where previous Technical Specifications requirements were not transferred to the current Technical Specifications, the inspectors verified the requirements were dispositioned as noted in the change documen b. Observations and Findinas )

l All of the requirements the inspectors reviewed from the previous Technical l Specifications were properly dispositioned, either by capture in the current j

Technical Specifications, the Updated Final Safety Analysis Report, the technical l requirements manual, the Technical Specifications bases, or facility operating and l surveillance procedures. The inspectors noted severalinstances in which the l change document did not clearly describe the justification for some changes, but in each case a facility representative was able to provide additional documentation and explanstion as to the proper disposition of the requirement in question. Overall,

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the change document was detailed and provided an adequate reference for the j inspectors to conduct the inspectio The inspectors reviewed a sample of the licensee's improved Technical Specifications. All of the requirements sampled were appropriately dispositioned as noted in the change document. However, the inspectors noted that most of the associated improved Technical Specification surveillance procedures, in the selected inspection sample, did not require a change in con'w.,t exclusively due to the change from the old Technical Specifications. Beu .se of this, the inspectors selected an additional surveillance procedure for review that had been affected by the improved Technical Specification conversion and did a technical review of its adequacy (see Section 03.04).

The inspectors noted two potential vunerabilities in the licensee's Safety Function Determination Program Implementing Procedure (OSP-0040), and discussed these with the licensee staff for their consideration. One of the functions of this procedure was to provide operators guidance for determining the maximum out-of-service time allowed for a Technical Specification supported system such as high pressure core spray, when one or more of its supporting systems was inoperabl The inspectors believed that the definition of " Maximum Out-of-Service Time" was confusing. The inspectors thought that operators could incorrectly calculate this time, or at least initially generate some delay in taking required actions, if additional guidance was not provided by Procedure OSP-004 .

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-5-Second, the inspectors noted that Procedure OSP-0040 allowed the extension of a previously determined maximum out of service time by the licensee's Operations Superintendent, but gave no additional guidance such as: (1) how long this l

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extension would be, (2) what kind of safety review process would be initiated (i.e.,

10 CFR 50.59 review), or (3) who must be informed. The inspectors determined that Procedure OSP-0040 was vulnerable because it did not clearly discuss the disposition ano t andling of a situation where the Operations Superintendent would approve an extension of a previously assessed out of service time for a supported I syste The licensee acknowledged these two potential vunerabilities in Procedure OSP-004 Additionally, the inspectors noted that recently licensed operators failed to ;

implement the requirements of Technical Specification 3.06 and 5.5.10, " Safety l Function Determination Program." This incident was documented in NRC Inspection Report 50-456/96-16. The licensee determined that operators demonstrated inadequate knowledge of the design bases and Technical Specifications by not identifying that concurrently removing the high and low pressure spray systems from service could have constituted a loss of safety function and required entry into Technical Specification 3.03 (See Section 08.1). The inspectors noted that the licensee's process relied on iicensed operator integrated plant and system i

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knowledge for the correct implementation of the safety function determination program and the improved standard Technical Specifications. This was because a correct safety evaluation required not only interpreting the new improved Technical l Specification requirements but also knowledge of tha associated bases document This was not the case when interpreting the requirements of the old Technical Specifications since the operator merely applied the applicable action steps required for the supported system that was affected. This sometimes led to cascading Technical Specification action statements for multiple system applications that depended on the same support system. The inspectors noted that with the new improved Technical Specification, cascading Technical Specifications could be avoided with the proper use of the licensee's safety function determination progra Conclusions The licensee successfully revised its previous Technical Specifications to the format of NUREG-1434 and relocated requirements to other documents as appropriat However, the licensee's Safety Function Determination Procedure OSP-0040 had some potential vunerabilities in the clarity of the out-of-se, vice time definition and the depth of guidance for extending a previously assessed maximum out-of-service tim __ _ . -- .- - - . - . . - . - - - _ . . - - - - . - - . . - . - - . - - -

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1 03.03 Implementation of Controls f Inspection Scope (Tl2515/130)

l l The inspectors reviewed selected revisions to various sections of the relocated

Technical Specification elements listed in the attachment. The app!! cable change l control mechanisms identified in the safety evaluation report for the license

Amendment 81, as well as completeness for the conversion to the improved

Technical Specifications were verified.

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Observations and Findinos i

j The inspectors verified that the original Technical Specification elements were j accurately relocated to either the Updated Safety Analysis Report, Technical

! Specifications, or the technical requirements manual. For changes to the improved i Technical Specifications made since review of the licensee's amendment 81, such l l as surveillance testing amperage specifications for verifying high pressure core j spray diesel generator safety battery capacity in Surveillance Requirement 3.8.4.7, l

] the inspectors verified that the changes were controlled by the plant modification

process. Additionally, other changes which resulted in a lessening of the licensee's -l j previous Technical Specification were verified to be controlled by the 10 CFR 50.59

process. For example, the limited condition of operation action time for Technical Specification 3.5.3 increased from 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This change had been reviewed and accepted through the NRC safety evaluation review process.

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i The inspectors also noted that not all of the licensee's operating and surveillance l procedures identified for revision as apart of the Technical Specification transition i had been revised. The inspector found that the licensee had prioritized procedures

to be revised by order of safety importance. The inspectors found that the most l important procedures that the licensee identified had been revised at the time of this j inspection. The other procedures were scheduled to be revised within the scope of j the licensee's standard review plan. Furthermore, it was determined that the licensee had developed a cross reference document to assist the plant staff in meeting original or relocated Technical Specification requirements until all plant procedures could be revised per the standard review plan. The inspectors concluded that this approach appeared acceptable considering the magnitude of document revisions required by the Improved Technical Specification conversion proces Since implementation of the improved Technical Specification in October 1995, the ncensee had experienced numerous surveillance test related deficiencies. The inspectors reviewed these deficiencies and determined that the majority of the recent problems identified with the licensee's surveillance program were not caused by the improved Technical Specification conversion process. The inspectors found only two instances directly attributable to implementation of the improved Technical Specification, and both were licensee identified. The first was a failure to perform a

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-7- l surveillance test on the prefilters for the standby gas treatment, control room fresh air and fuel building ventilation systems. This surveillence requirement was added by the improved Technical Specification and the licenseo failed to identify the added requirement during the verification and validation reviews. The second was a failure to check the position of the hydrogen mixing valves on a monthly basis. This surveillance was missed because of an error in the renumbering system and I subsequent failure to properly include the surveillance in the cross reference during l the transition to the improved Technical Specification. These events were reported in detailin NRC Inspection Reports 50-458/96-26and 9617, respectivel Because of the continuing incidence of surveillance procedure problems at River Bend Station, the licensee staff indicated they continue their program of comprehensive audits of revised surveillance procedures and other affected procedures to ensure that all of the requirements of the original Technical Specifications have been retained in the improved Technical Specifications, or adequately dispositioned in other document Conclusion The inspectors concluded through a sampling of relucated Technical Specification elements and a review of the supporting control process that the licensee had successfully implemented the improved Technical Specification program. In addition, the majority of the recent problems identified with the licensee's surveillance program were not caused by the improved Technical Specification conversion proces .04 Sun'elllance Review Insoection Scoce (Tl2515/130)

The inspectors randomly selected for review Surveillance Procedure STP-508-4202,

"RPS/ Isolation Actuation Instrumentation Drywell Pressure-High Channel Calibration Test and Logic System Functional Test (C71-N0508, C71-N6508)," Revision 1 The review focused on comparing the test procedure against the applicable diagrams to verify the procedure adequately tested all actuations and trip logic functions as required by the improved Technical Specification QDservations and Findinas The inspectors verified that the surveillance tested the sensor device, performed required calibrations, and performed the logic channel functional test as required by the new impioved Technical Specifications. A review of the vendor drawings listed in the attachment against the procedure verified that all affected circuits were appropriately teste . - - . -- .. .- - - . - . . . - . . . - ._ - . - - . . ~ . . . . . - . . . . . . ~ . - .

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l 8-l P Conclusion

The inspectors concluded that the reviewed surveillance test appropriately tested the affected circuits of the subject sensor and instrument loo ,

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08 Miscellaneous Operations issues

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08.1 Violation 50-458/96-16 02 (Closed): failure to oroneriv implement Technical i Soecifications 3.06 and 5.5.10.

The inspector verified the corrective actions described in the licensee's response

! letter, dated February 6,1997, to be reasonable and complete. No similar problems

were identified.

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V. Manaaement Meetinas X1 Exit Meetina Summaly The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on February 13, and on March 7,1997. The licensee acknowledged the findings presented. No proprietary information was identifie _

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee D. Burnett, Senior Chemist M. Chilson, Licensing Specialist G. Davant, Licensing, Senior Staff T. Gates, Plant Engineering Supervisor i T. Hildebrandt, Outage Manager R. King, Director, Nuclear Safety and Regulatory Affairs ;

D. Lorfing, Licensing Supervisor l J. McGaha, Executive Vice President l J. McGhee, Operations Technical Assist .

W. O'Malley, Operations Manager l A. Shahkarami, Engineering Manager 1 W. Stacey, Business Services Manager j C. Sutherland, Training Supervisor i W. Trudell, Operations Training Supervisor L. Woods, Operations Supervisor G. Zinke, Quality Assurance Manager NRC i

W. Smith, Senior Resident inspector i

INSPECTION PROCEDURES USED Tl2515/130 Improved Standard Technical Specification implementation Audits ,

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ITEM CLOSED j

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50-458/9616-02 VIO Failure to implement the safety function determination program (Section 08.1)

LIST OF DOCUMENTS REVIEWED Standard Technical Soecifications:

Existing TS 2.1.4 " Reactor Vessel Water Level" Existing TS 3/4.1.2 " Reactivity Anomalies" l Existing TS 3/4.3.3 " Emergency Core Cooling System Actuation Instrumentation" l

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2-Existing TS 3/4.3.5 "RCIC System Instrumentation" Existing TS 3/4.4.1.3 " Recirculation Loop Flow" j Existing TS 3/4.4.2.2 "S/RVs Low-Low Set Function Existing TS 3/4,4.6.1 "RCS Pressure / Temperature Limits" Existing TS 3/4.4.9.2 "RHR Cold Shutdown" Existing TS 3/4.5.1 "ECCS-Operating" Existing TS 3/4.5.2 "ECCS-Shutdown" Existing TS 3/4.5.3 " Suppression Pool" Existing TS 3/4.6.1.4 " Primary Containment Air Locks" Existing TS 3/4.7.2 " Main Control Room Air Conditioning System" Existing TS 3/4.8.2.1 "DC Sources-Operating" Existing TS 3/4.8.4.3 "RPS Electric Power Monitoring" l Existing TS 3/4.6.9.2 "Special Reports" l l

v t e Inspection Report - River Bend - 1997005
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1997 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 10(0) 11(0) 12(0) 13(0) 14(0) 15(0) 16(0) 17(0) 18(0) 19(0) 20(0) 99(0) Security 201(0) Operator Exams 301(0) Emergency Planning Other

IR 05000458/1997005

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REGION IV

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