ML20135A468

Insp Rept 50-458/96-17 on 961215-970201.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20135A468
Person / Time
Site:	River Bend
Issue date:	02/20/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135A456	List: ML20135A453 ML20135A463 ML20135A468
References
50-458-96-17, NUDOCS 9702270189
Download: ML20135A468 (24)

See also: IR 05000458/1996017

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ENCLOSURE 2

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-458  ;

License No.: NPF-47  ;

Report No.: 50-458/96-17 _

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Licensee: Entergy Operations, Inc.

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' Facility: River Bend Station  :

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Location: 5485 U.S. Highway 61

St. Francisville, Louisiana 70775 - i

Dates: December 15,1996 through February 1,1997

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Inspectors: W. F. Smith, Senior Resident inspector

D. L. Proulx, Resident inspector j

G. M. Good, Senior Emergency Preparedness Analyst,  ;

Division of Reactor Safety

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Approved By: P. H. Harrell, Chief, Project D -

Division of Reactor Projects  !

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Attachment: Supplemental information

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9702270139 970220

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EXECUTIVE SUMMARY I

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River Bend Station l

NRC Inspection Report 50-458/96-17

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This inspection included aspects of licensee operations, maintenance, engineering, and  !

plant suppcet. The report covers a 7-week period of resident inspection. I

Operations

In general, operator performance was good during this inspection period. Control

room activities were carried out in a business-like manner, with good

communications observed by the inspectors. Decisions made in support of  !'

maintenance were usually conservative.

The reduction in power in support of balance-of-plant repairs was completed

without incident, as were the control rod scram testing and mairi steam isolation

valve cycling activities (Section 01.1).

The licensee responded well to the cold weather advisories warning the River Bend

area of snow on December 18,1996. Operations developed a contingency watch

bill and the Emergency Planning organization interfaced with external authorities to

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ensure emergency evacuation routes would i,e kept open (Section 01.2). l

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• Continued configuration control problems were noted when an operator identified

i the control switches were in the OFF position for both of the Division 111 emergency

l diesel generator (EDG) starting air compressors. Though nonsafety related, the

compressors were important in that they maintained pressure in the safety-related

air receivers. Although the licensee was unable to determine the cause, the

licensee implemented good corrective actions and responded appropriately to the

issue of configuration controls (Section 02.1).

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• Equipment was properly staged for two emergency operating procedure (EOP)  ;

supporting enclosures. In addition, the on-shift operators demonstrated good I

knowledge to perform these procedures (Section 03.1).

l Maintenance

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• The licensee's response to the f ailure of Rod Control and Information System

l (RC&lS) Power Supply C11-PS1 demonstrated good teamwork, management

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oversight, quality assurance, and proper utilization of the licensee's administrative

controls over maintenance work and plant design configuration (Section M1.1).

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• The replacement of the standby service water (SSW) loop seal valves was

performed in a step-by-step manner and in accordance with procedures. Good

coordination was observed between operations and maintenance pes.m:! ;n

establishing conditions for the work, including a freeze seal (Section M1.2).

• Af ter repeated f ailures of the containment airlock door seal air ball valves, the

licensee appropriately formed a Significant Event Review Team (SERT) to determine

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the root causes and recommend permanent corrective action. Actions already

implemented, as well as those recommended, appeared to be appropriate to correct

the problem. Mechanics effectively performed the work and postmaintenance

testing (Section M1.3).

The licensee identified a fGilure to implement a Technical Specification (TS)

surveillance requirement (SR), which required monthly verification that the hydrogen

mixing valves were closed. The licensee made an error in renumbering requirements

for the Improved TS, which resulted in an incorrect procedure being referenced in

the TS/ surveillance procedure cross-reference matrix. The licensee's corrective

actions were satisf actory to prevent recurrence. A noncited violation (NCV) was

identified for failure to perform the TS surveillance at the correct frequency

(Section M1.4).

A procedure upgrade reviewer demonstrated excellent performance in identifying

and documenting on a condition report (CR) a missed surveillance requirement

associated with the control rod scram accumulator instrumentation testing. An

NCV was identified for f ailure to maintain the technical adequacy of the surveillance

test procedure implementing the requirement to test the common control room

alarm from each of the 145 scram accumulators (Section M1.5).

• The inspectors identified a violation for failure to follow instructions that were

instituted to preclude dropping items into the SSW cooling tower basin. The

inservice testing (IST) of the Division ll SSW pumps was otherwise performed

properly and in accordance with the procedure (Section M1.6).

• The surveillance test on the low pressure coolant injection (LPCI) Pump C start logic

was performed properly and in accordance with procedures. Technicians employed

good self-checking and sound electrical safety practices while performing this test

(Section M1.7).

Enaineerina

• Design Engineering demonstrated a good questioning attitude in reviewing the 1990

licensee response to NRC Information Notice 88-76, Recent Discovery of a

Phenomenon not Previously Considered in the Design of Secondary Containment

Pressure Control relative to possible secondary containment positive pressures

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caused by low outside temperature extremes, immediate action to provide the  !

operators with outside temperature dependent acceptance criteria for secondary I

containment pressure was appropriate to the circumstances pending implementation l

of permanent corrective action (Section E2.1).

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Plant Support

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Housekeeping in *a plant continued to be excellent. It was noteworthy that the

l construction area in which the new alternate decay heat removal system was being

installed was being maintained clean and orderly (Section 01.1).

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The commitment to perform on-shift dose assessments was appropriately described

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in the licensee's emergency plan and implementing procedures. Further evaluation

of the information obtained using Temporary Instruction (TI) 2515/134 will be

conducted by NRC Headquarters personnel (Section P3.1).

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REPORT DETAILS

Summarv of Plant Status

The plant operated at essentially 100 percent power for the duration of this inspection

period, except on January 18 through January 21,1997, when power was reduced to

approximately 60 percent in support of balance-of-plant maintenance and reactor control

rod repositioning.

1. Operations

01 Conduct of Operations

, 01.1 General Comments (71707)

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The inspectors conducted frequent reviews of ongoing plant operations including

f control room observations, attendance at plan-of-the-day meetings, and plant tours.

l In general, the conduct of plant operators was professional and reflected a focus on

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safety. Decisions made in support of maintenance were usually conservative based

on the inspectors' routine reviews of TS limiting conditions for operation (LCO)

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entered and exited. During plant tours, the inspectors found that housekeeping

continued to be excellent. Any minor discrepancies identified b" *.he inspectors

were promptly corrected. During several tours, the inspectors considered it

noteworthy that construction workers installing the new alternate decay heat ,

removal systems kept the areas orderly and clean. )

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The inspectors reviewed the operator actions to reduce power to 60 percent on i

January 18, in support of corrective maintenance on the nonsafety-related isophase l

bus duct cooling fan, which reduced the heat load on the isophase duct to a level

that would not cause overheating without the fan.

The operators followed the appropriate operating procedures to reduce power and

then subsequently restored power in a well-controlled manner. The licensee also i

utilized the lower plant power level to replace a shaft seal on a heater drain pump, l

replace a relief valve on a feedwater pump gear increaser, perform scram time

testing of five control rod hydraulic control units that were overhauled, and full-

stroke cycle the main steam isolation valves. Testing and repairs were successfully

accomplished without incident.

01.2 Licensee Actions in Response to Snow Warninas (71707)

On December 18,1996, the National Weather Service placed the St. Francisville

area, in a snow warning. The inspectors evaluated the contingency plans that were

l implemented in the event emergency response became necessary. Operations  !

! management published a shift coverage contingency plan that utilized qualified j

! personnel who resided close to the plant. Cold weather precautions had previously j

! been implemented. These actions were reviewed by the inspectors and were found j

! to be appropriate. Emergency Planning management interfaced with the Louisiana l

l Radiation Protection Division and confirmed that provisions were made through the

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Office of Emergency Preparedness and Federal Emergency Management Agency,

~ Region 6, to ensure that evacuation routes would remain open. }

The inspectors considered the preparations in response to the snow warning was l

appropriate to the circumstances. The forecasted snow did not arrive. i

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O2 Operational Status of Facilities and Equipment

O2.1 Additional Confiouration Control Deficiencies 9

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a. Lnjiipection

n Scope (71707)  ;

The inspectors evaluated the response to CR 96-1923, where an operator identified

continuing problems with s"/ stem configuration controls. i

b. Observations and Findinas

NRC Inspection Report 50458/96-15 cited four examples of failure of the licensee  !

to maintain configuration control of safety-related system valves and switches.

While in the process of implementing corrective actions focused on addressing the

apparent adverse trend in operations human performance, another problem was

identified by the licensee.

On November 8,1996, while perforraing the EDG building rounds, an operator

discovered the control switches for both starting air compressors for the Division Ill. I

EDG were in the OFF position. One of the two air tanks had dropped to 217 psig,-

which was below the pressure at which the compressor automatically starts. The

setpoint was approximately 225 psig. The operator informed the control room

promptly, placed the switches in the required auto position, and then initiated

CR 96-1923. The operations shift superintendent ordered a complete control board

lineup check on all three EDGs and no additional deficiencies were found. The

Division lli EDG was operable because air tank pressure did not decrease below the

160 psig minimum specified in the applicable TS.

The inspectors were concerned that although the compressors were not safety-

related equipment, the compressors had the important function of maintaining the

EDG starting air tanks at the required pressure. The licensee responded to the issue

by implementing a thorough investigation to determine the cause. Security

computer history was utilized to determine who was in the EDG building for the

time period it tould have taken for the air pressure to decay off. Each individual

was questioned, but none recalled leaving the switches in the OFF position. After

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about 2 months of investigation, the licensee concluded that the cause of the

l switches being out of the required position was indeterminate. The licensee did

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identify that, the operators sometimes turned off the compressors when checking

j the oil each shif t, especially when the tank pressure was near the setpoint for the

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compressors to start. The licensee theorized that an operator did that and forgot to l

l* restore the switches to the AUTO position.

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The licensee has since _ implemented many corrective action items as listed in the

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docketed reply to the Notice of Violation, dated January 24,1997. This issue was l

not cited as a violation because corrective actions were in the process of being' ]

implemented when this problem was identified.

l To avoid further violations, the licensee established a plant configuration control

l team, with the support of River Bend management, to maintain an aggressive

approach to monitor, track, and resolve configuration controlissues until j

performance is improved. The team leader and plant management have met with j

the inspectors on a periodic basis to keep the inspectors appraised of progress in

this area.

c. Conclusiong

l The inspectors concluded that th<s licensee is implementing good corrective actions

and has responded appropriately to the configuration control issues. The inspectors

l will evaluate the effectiveness of the licensee's actions during the followup

l inspections for closure of the violation in NRC Inspection Report 50-458/96-015.

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l 03 Operations Procedures and Documentation (71707)

O3.1 Walkdown of Enclosures for EOPs

On December <26 and 27,1996, the inspectors performed reviews of the licensee's

implementation of two enclosures for EOPs to verify the ' actions specified could be

performed. These support procedures were contained within Procedure EOP-5,

" Emergency Operating Procedures-Enclosures," Revision 9. The inspectors walked

down Enclosures 1 and 12, which addressed defeating the main turbine trip from

initiation of the reactor core isolation cooling system and injection into the reactor i

vessel with the condensate transfer system. The inspectors verified that all keys I

and tools were staged and that on-shift licensed operators were sufficiently familiar

with the actions stated in these enclosures. The inspectors concluded that the  !

L licensee adequately trained the operators and staged materials for effective

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implementation of Enclosures 1 and 12 of Procedure EOP-5.

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08 Miscellaneous Operations issues (92901)

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08.1 Survey of TS Interoretations

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l The inspectors conducted a survey of the licensee's TS interpretations and j

l determined that no documents existed with informal references to NRC review and j

i- approval without formal NRC documentation. The inspectors emphasized to the

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licensee, at the exit interview, that any informal reference to NRC review and

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approvalin a TS interpretation is not recognized by the Commission and is not an l

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11. Maintenance

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M1 Conduct of Maintenance

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M 1.1 Replacement of Failed RC&lS Power Supolv

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a. Inspection Scope (62707.37551)

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The inspectors observed the licensee's actions in response to a failed RC&lS power . l

, supply that placed the plant in a condition where the TS required the plant to be  ;

L shut down in 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> if not corrected. ,

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b. Observations and Findinas

On January 8,1997, at 4:30 a.m., while the plant was operating at 100 percent  !

power, the RC&lS inoperable alarm annunciated in the control room and could not '

l- be reset. Without this system being functional, the control rod withdrawallimiter '

l was inoperable, which prevented control rod withdrawal or insertion by normal

means, in addition, the control rod scram accumulator leakage and low pressure i

alarm function was disabled for all 145 control rods. The operators appropriately ,

entered Technical Requirements Manual Limiting Condition for Operation  !

l (TLCO) 3.1.5.1, which required the operators to immediately declare the scram

l- accumulators inoperable. This action led the operators to TS 3.1.5.B, which

! required the operators to declare the associated control rods inoperable within 1

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At 5:30 a.m., the operators declared the control rods inoperable, which further led

l the operators to TS 3.1.3.E, which required the operators to shut down the reactor

and place the plant in Mode 3 (Hot Shutdown)in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, in addition, because

the rod withdrawallimiter was inoperable, TS 3.3.2.1 prohibited any control rod

movement except to scram. This meant that power could only be reduced to

approximately 70 percent by reactor flow reduction, and then the plant would be

shut down by a reactor scram from that power level to achieve Mode 3 conditions,

i The operators assembled the appropriate maintenance and engineering support and

! promptly informed licensee management of the problem and the potential plant

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transient. To better ensure control rod scram capability, the operators increased

monitoring of control rod scram accumulator pressures from once per week to every

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4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. By approximately 8:30 a.m., the licensee had determined by

i. troubleshooting that RC&lS Power Supply C11-PS1 had failed. A new power

supply was obtained from the plant warehouse and the failed ' power supply was

, removed from the panel. By this time, the licensee developed several contingency

i plans. A change to TLCO 3.1.5.1 was being considered, which would have allowed

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monitoring the scram accumulator pressure and leakage alarm parameters instead of

declaring the accumulators inoperable. A backup power supply was sent in from  ;

another nuclear facility, a temporary alteration waa being considered to enable the  ;

accumulator alarms, and work was proceeding to install the new power supply in i

accordance with Maintenance Action item (MAI) 309925. However, the {

maintenance technicians discovered that two of the four mounting bracket screw

holes did not line up with the new power supply, which caused CR 97-0015 to be l

initiated.

The engineers supporting the work decided to repair the mounting bracket by drilling

new holes. They noted that another installed RC&lS Power Supply (C11-PS2) had a  !

bracket that was similarly modified to accommodate a previous power supply i

replacement. At this point, maintenance personnel converted the Reference MAI to

a Compliance mal in accordance with administrative procedures because. a repair

was involved, which necessitated explicit documentation and instructions The

Reference MAI was only appropriate for exact replacements using skil' of the craft

and referencing the applicable drawings and standards. The inspeuors reviewed ,

the MAI package and found it to be in order and appropriate to the circumstances. l

In order to expedite restoration of RC&lS ability to function, Engineering personnel

issued an interim disposition of the CR to allow installation of the new power supply

with the modified mounting bracket. The inspectors reviewed the technical

justification for the disposition and found that it had sufficient basis. The inspectors

observed installation of the new power supply at approximately 12 noon and the ,

RC&lS became fully operational as the postmaintenance test was completed l

satisf actorily. At 1:19 p.m., the Facility Review Committee completed review and

approval of the CR disposition to modify the power supply mounting bracket. The

approved documentation included a 10 CFR 50.59 safety evaluation screening,

which appropriately did not require a safety evaluation.

On January 11, another RC&lS inoperable alarm annunciated in the control room.

The power supply was checked and found to be satisf actory. In about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the

operators were able to reset the system and the cause was assumed to have been a

spurious signal from an individual hydraulic control unit transponder card. The

operators were instructed that should another alarm occur, to not attempt to reset

RC&lS until Engineering personnel analyzed the RC&lS panel diagnostic display.

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The licensee promptly revised TLCO 3.1.5.1 such that when the RC&lS became

inoperable, which disabled the hydraulic control unit accumulator alarms, the

l operators would no longer be required to declare the accumulators inoperable. The

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revised TLCO required verification of the affected accumulator pressure at equal or

greater than 1520 psig every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and verify the affected accumulator water

drained every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This change was appropriately made pursuant to

10 CFR 50.59.

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On January 20 and 21, additional RC&lS alarms occurred and as a result of l'

troubleshooting, the licensee determined that there was a broken multiple contact

plug 5 the RC&lS panel, which caused one of the connections to place intermittent '

noise on the signal. Also, while checking power supplies, the technicians found

alternating current noise on.the output of one of the power supplies and it was I

replaced. The licensee replaced the broken plug and the RC&lS was restored to i

operability. The system operated satisfactorily through the end of this inspection I

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The inspectors questioned what actions were to be taken to better ensure the

reliability of all 14 RC&lS power supplies. The licensee responded that closer i

monitoring of the power supply output voltage and noise would be incorporated into i

the preventive maintenance program for this system. i

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Throughout this maintenance activity, the inspectors observed good teamwork in an l

effort to minimize outage time, balanced with establishing sound technical bases for  !

the engineering decisions made. Continuous management oversight and quality I

assurance inspections were provided. The quality assurance inspector j

demonstrated a good questioning attitude and ensured that the work'was properly )

done. j

c. Conclusions

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The inspectors concluded that the licensee's response to the failure of RC&lS Power

Supply C11-PS1 demonstrated good teamwork, good management oversight, and )

proper utilization of the licensee's administrative controls over maintenance work

and plant design configuration.

M1.2 Replacement of SSW Looo Seal Valves

a. Insoection Scope (62707)

On January 16,1997, the inspectors observed the performance of MAI 224396,

which replaced SSW Valves SWP-V656 and -V657. In addition, the inspectors

observed the applicatir'n of a freeze sealin accordance with Corrective Maintenance 1

Procedure CMP-9186, " Freeze Seals," Revision 8C. I

b. Observations and Findinas  !

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The inspectors noted that the maintenance mechanics methodically established the  ;

freeze seal in accordance with the procedure and implemented all applicable  !

precautions. The licensee had previously exhibited weaknesses in the freeze sealing

process; therefore, the licensee's performance was noted to have been improved. 1

The inspectors noted that, except for minor administrative documentation errors j

that were immediately corrected, the task was performed properly and in i

accordance with the mal. Good coordination was observed between operations

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and maintenance personnel in establishing the freeze seal and draining the

associated piping.

c. Conclusions

The replacement of the SSW loop seal valves was performed in a step by-step

manner and in accordance with procedures. Good coordination was observed

between operations and maintenance personnelin establishing conditions for the

work.

M1.3 Repeated Failures of Containment Airlock Door Sealina Systems

a. Insoection Scope (62707.61726)

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On January 17,1997, the inspectors observed portions of the replacement of a

broken valve stem on the 171-foot elevation containment air lock inner door, upper

sealing system ball valve, in accordance with MAI 310118. The inspectors also

observed portions of the postmaintenance testing and reviewed the completed test

data.

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b. Observations and Findinas

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The inspectors found that the mal instructions were of sufficient detail for the skill ,

of the craf ts such that the quality of this maintenance activity was sufficiently l

controlled. The appropriate personnel and safety precautions were taken. The  !

clearance was found to be appropriate and the work area on the floor grating was l

covered with mats to help prevent losses of tools and parts into the suppression

pool. Craft supervision was present during some of the work and provided

appropriate oversight. The craftsmen appeared adequately trained and experienced

and performed their work in a professional manner in accordance with the MAI

instructions. The postmaintenance air drop tests were performed in an excellent

manner. The test performers followed the procedure and exercised great care in

establishing a stable initial pressure to obtain meaningful results. Completed test

data was legible and calculations were correct.

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This was the second failure of a containment airlock door sealing system ball valve

stem. On December 26,1996, the lower ball valve in the same airlock door failed.

The licensee replaced the stem and subsequently determined that the stem seal o-

ring groove had signs of chloride stress corrosion cracking. This weakened the type

316 stainless steel stem and it eventually f ailed while in service from apparent

fatigue.

The containment airlock door seal system ball valves had a history of leakage

problems over the past year. To ensure the systems were maintained leak tight, the

licensee iricreased the frequency of the air drop surveillance test from the TS-

required periodicity of 18 months to quarterly. The licensee experienced several

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test failures during the past year. The licensee replaced ball valve Tefzel seats and

i air lanced the carbon steel accumulators to remove the rust particles that appeared

j to have caused scratches on the balls resulting in seating failures. The licensee

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removed the lubricant from the ball valves because the lubricant appeared to trap

the rust particles in the seating areas, in addition, the licensee concluded, in

December 1996, that the valve body fasteners were not installed with sufficient i

i torque, thereby defeating the seat design. Successful drop tests following the l

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removal of lubricant and applying greater torque to the valve body fasteners led the

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licensee to believe they had solved the problem. However, tightening of the body '

i' and removing lubricant in combination with the presence of stress corrosion '

i cracking may have contributed to valve stem failure.

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The General Manager, Plant Operations directed a SERT be formed on January 21,

1997, to determine the root causes of the multiple failures of the air lock door

sealing systems and to implement permanent corrective actions. By January 24,

the SERT performed and implemented, in part, the following immediate corrective

actions:

Inspected ball valve balls and seats and replaced them if there were signs of

wear or scoring.

Replaced all of the Type 316 stainless steel ball valve stems with Type 630  ;

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stems, which were stronger and less vulnerable to chlorides.

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• Applied a light film of vendor-approved lubricant in the ball valves.

• Retorqued the ball valve body bolts to the greater torque.

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Air lanced the accumulator tanks to remove as much rust as possible.

Replaced the ball valve operating gear clamp pieces with new clamp pieces

with a thickness equal to the gear to ensure even forces on the valve stems.

The original clemp pieces were thinner than the gear, but were within -

drawing tolerances.

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• Removed all locking compound from the valves and fasteners. This

compound was four:d to be a potential source of chlorides which could lead

to stress corrosion cracking on stainless steel parts.

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The SERT was continuing its investigation as of tho end of this inspection period i

and has recomrnended a list of 31 action items, some of which were completed.

The SERT was considering design improvements that would eliminate the identified

causes of frequent ball valve failures. One example was to replace the carbon steel

accumulator tanks with stainless to eliminate rust as a potential ball valve failure

mechanism. In the meantime, the SERT established a monthly air drop test for each

of the airlock door sealing systems in lieu of the 18 month TS surveillance interval

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until confidence was established that the ball valves would not f ail, in addition, the

SERT implemented a weekly inspection for obvious leaks, which would precipitate

an immediate drop test.

c. _C_onclusions

After f ailures of the containment airlock door seal air ball valves, the licensee

appropriately formed a SERT to determine the root causes and recommend -

permanent corrective action. Actions already implemented as well as those

recommended appeared to be appropriate to correct the problem. Maintenance

technicians performed the work and postmaintenance testing in an excellent

manner.

M1.4 Missed Surveillance on Hvcroaen Mixina Valves

a. Insoection Scone (61726)

The inspectors evaluated the licensee's response to CR 96-2033,which identified

that the licensee had not met the surveillance requirement to verify that the

hydrogen mixing valves were closed every 31 days.

b. Observations and Findinas

On December 2,1996, during a procedure review to implement a TS change, the

licensee discovered that TS SR 3.6.5.3.2 was not implemented by Procedure

STP-000-0201," Monthly Operating Logs," Revision 15, as indicated by the

licensee's TS/ surveillance procedure cross-reference matrix. TS SR 3.6.5.3.2

requires the licensee to verify that the hydrogen mixing valves were in the closed

position every 31 days. The licensee reviewed other similar procedures and could

not identily any procedure in which the requirements of TS SR 3.6.5.3.2 were met.

Operators entered TS SR 3.0.3, which allows the licensee 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform a

missed surveillance before declaring the LCO not met. Operators verified that all of

the hydrogen mixing valves were closed and the licensee exited TS SR 3.0.3.

The investigaJon revealed that during the development of the improved TS, an error

in renumbering the new surveillance requirements was made such that the

TS/ surveillance procedure cross-reference was in error. The licensee also noted that

prior to February 1996, the valve position of the hydrogen mixing valves was i

verified daily, to track the amount of time that the valves were open in accordance

with Procedure STF-000-0001," Daily Operating Logs." However, because the I

improved TS no longer required the licensee to track the amount of time that the

hydrogen mixing valves were open, the licensee deleted the daily valve position )

verification of the hydrogen mixing valves. 1

The licensee f ailed to satisfy the requirements of TS SR 3.6.5.3.2 from February to

December 1996. However, this f ailure to meet the TS was mitigated because

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operators verified the position of the hydrogen mixing valves during the quarterly

operability surveillance test of the hydrogen mixing fans. Therefore, the licensee

had reasonable assurance that the valves were closed during the time period that

the surveillance was missed.

For corrective action, the licensee corrected their TS/ surveillance procedure matrix

and performed a review of the improved TS to ensure that no other TS renumbering

errors occurred.

The f ailure to verify the hydrogen mixing valves closed every 31 days is a violation

of TS SR 3.6.5.3.2. This licensee-identified and corrected violation is being treated

as an NCV consistent with Section Vll.B.1 of the NRC Enforcement Policy. l

Specifically, the violation was identified by the licensee, was not willful, actions

taken as a result of a previous violation should not have corrected this problem, and

appropriate corrective actions were completed (50-458/9617-01).

c. Conclusions

An NCV was identified for f ailure to implement TS Surveillance Requirement 3.6.5.3.2, which required monthly verification that the hydrogen mixing valves

wre closed. The licensee made an error in renumbering requirements for the

'

improved TS, which resulted in an incorrect procedure being referenced in the

'TS/ surveillance procedure cross-reference matrix.

M1.5 Missed Surveillance on Scram Accumulators

a. insoection Scoce (61726)

The inspectors evalua:ed the licensee's response to CR 96-2046, which identified

that the licensee had not met the surveillance requirement to perform a channel

functional test on the associated alarm circuit for each control rod scram

accumulator.

b. Observations and Findinas

On December 5,1996, during a procedure upgrade technical review, the reviewer

discovered that the testing methodology used for the channel calibration and

channel functional test of scram accumulator pressure and leakage alarms, '

respectively, did not test all circuits between the transmitters ar d the common

alarm located in the control room. Procedure STP-500-4201," Control Rod Scram j

Accumulator instrumentation 18 Month Channel Functional and 18 Month Channel j

Calibration," Revision 6, was revised in June 1994 to test the common alarm only  ;

'

once from one accumulator. The procedure reviewers assumed that sufficient

overlap was provided through the RC&lS system continuous diagnostic; however,

the procedure upgrade reviewer noted that not all of the alarm logic was being

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tested for each of the 145 accumulator transponder circuits. The AND gate for the

- pressure and leakage alarm was not tested by the self-diagnostic.

The operators entered Technical Requirements Manual SR 3.0.3, which allowed

declaring the accumulators inoperable to be dr,iayed for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit

accomplishment of the surveillance test. Prr,cedure STP-500-4201, Revision 7, was

changed and within the 24-hour period, all 145 accumulator circuits were

satisfactorily tested for common alarm annunciation. The inspectors observed

portions of the performance of the revised surveillance test and found no problems.

The procedure upgrade project is a corrective action commitment in progress for

previously identified inadequacies in surveillance test procedures. This process has

been effective in making improvements in technical content, usability, and format, i

Utilizing reviewers with technical experience and expertise in the instrument and i

controls area has enhanced this effectiveness as demonstrated by the appropriate

identification and dispositioning of this issue. For additional permanent corrective

action, maintenance management had discussions with the instrument and control

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technicians to reinforce sensitivity toward digital control and alarm systems. l

Failure to maintain Procedure STP-500-4201 technically adequale is a violation of-

TS 5.4.1.a. This licensee-identified and corrected violation is boing treated as an

NCV consistent with Section Vll.B.1 of the NRC Enforcement Policy. Specifically,

the violation was identified by the licensee, was not willful, actions taken as a result

of a previous violation should not have corrected this problem, and appropriate

corrective actions were completed (50-458/9617-02).

c. Conclusions

The procedure upgrade review 0r demoristrated excellent performance in identifying

and documenting on a CR a missed survCllance requirement associated with the

control rod scram accumulator instrumente. tion testing. An NCV was identified for

failure to maintain the technical adequacy of the surveillance test procedure

implementing the requirement to test the common control room alarm from all of the -

scram accumulators.

M1.6 IST of the Division 11 SSW System

a. Insoection Scope (61726)

On' January 17,1997, the inspectors observed performance of Procedure

~ STP-256-6304," Standby Service Water B Loop Quarterly Pump and Valve Testing,"

Revision 8.

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b. Observations and Findinas

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The test was performed with satisf actory restats and the operators followed the

procedure in a step-by-step manner. During previous performances of SSW IST, the

licensee did not take vibration data at the locations specified in Attachment 4 of

Procedure STP-256-6304,which was discussed as a violation in NRC Inspection

Report 50-458/96-15. The licensee corrected the procedural deficiencies for the

test performance of January 17.

However, the inspectors noted that a sign on the entrance to the SSW pump roums

stated that the SSW pumps were not protected by suction strainers and provided

instructions that all gaps in the floor must be covered during work to preclude

dropping items into the SSW basin. The inspectors questioned the operators as to l

wh'y they did not cover the holes in the floor during SSW pump testing per the

posted sign. The operators stated that they did not notice the sign upon entry.

The inspectors determined that this sign was posted on the entry as corrective

action for CR 91-0362, generated in 1991, which identified an item dropped into

the SSW pump basin during a previous performance of SSW IST. The inspectors

informed the shift superintendent, who wrote CR 97-0043 to address the

inspectors' concerns with the effectiveness of the' corrective actions for

CR 91-0362.

The licensee's investigation revealed that none of the operators that frequently

entered the SSW pump rooms had previously noticed the sign requiring holes to be

covered. The inspectors noted that although the corrective actions for CR 91-0362

appeared to be ineffective for alerting personnel to take proper precautions to

prevent dropping items into the SSW basin, no items were known to have fallen

into the basin; therefore, the licensee appeared to have reasonable assurance of

operability. However, the inspectors noted that the SSW system was the most

important system with respect to risk significance in the licensee's individual plant

examination, which emphasized the importance of taking conservative precautions  ;

to protect this system. The failure to implement instructions as corrective action to

preclude dropping items into the SSW basin is a violation of 10 CFR Part 50,

Appendix B, Criterion V (50-458/9617-03).

l c. Conclusions  !

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A violation was identified for the failure to take effective corrective actions to

preclude dropping items into the standby cooling tower basin. Because SSW was

the most important system in the licensee's individual plant examination, this

violation emphasized the importance of taking conservative precautions to ensure

operability. The IST cf the Division il SSW pumps was otherwise performed

properly and in accordance with the procedure.

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! M1.7 Surveillance Test of LPCI Pumn C Pumo Start Loaic (61726)

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On January 13,1997, the inspector witnessed performance of Procedure l

j STP-204-1302,"LPCI Pump C Start Time Delay Channel Calibration and Channel l

Functional Test," Revision 9A. The inspectors noted that the craf tsmen

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j consistently used good self-checking and sound electrical safety practices. The

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' surveillance was performed in accordance with the procedure and the data was

satisfactory.

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i M8 . Miscellaneous Maintenance issues (92902,92700)

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M8.1 (Closed) Violation 50-458/9525-03: Surveillance testing of the average power

l range monitors was not performed at the frequency specified by the TS.

Amendment 74 of the TS, issued on August 2,1994, reduced the frequency of a

j number of surveillance requirements from weekly / monthly to quarterly; however,

i the surveillance interval for the flow biased, thermal power trip remained at 7 days.

i Immediate corrective actions to perform the surveillance tests and revise the

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implementing procedures were reviewed by the inspectors at the time. The results

1 were satisf actory. The licensee reviewed all surveillance requirements associated

j with Amendment 74 and found no additional deficiencies. In response to this

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violation, the licensee referred to Licensee Event Report (LER) 50-458/95-009 for

j permanent corrective actions. The LER stated that implementation of TS

j Amendment 81, which was the improved TS, on October 1,1995, resulted in

severalimprovements such as improved format providing for unique surveillance

i requirement numbering, revised surveillance test procedure data base to facilitate l

} cross referencing specific surveillance requirements, and licensing proce'dures for  !

I processing license document changes were significantly revised to support

implementation of the improved TS. ,

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The above referenced corrective actions were not fully effective, as demonstrated l

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by the missed surveillances discussed in Sections M1.4 and M1.5 of this inspection

t report and in NRC Inspection Report 50-458/96-26. NRC Inspection Report

50-458/96-26 cited a violation for a breakdown in the licensee's surveillance testing  ;

i program, which included similar examples of missed surveillances. The extensive .

corrective actions implemented and planned by the licensee in response to that j

i enforcement action supersedes this item and the effectiveness of those actions will i

be evaluated during a future inspection. l

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l M8.2 (Closed) LER 50-458/95-002: Deficient IST surveillance of EDG air receiver check

j valves because of an inadequate procedure.

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- On March 21,1995, the EDG system engineer identified that the surveillance

j procedures for verifying the operability of the Division I and ll EDG air receiver tank

inlet check valves were deficient. The test incorrectly included nonsafety-related

j check valves in the test boundary. This LER was discussed and left open in NRC

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Inspection Report 50-458/96-16. One corrective action for this problem was to

train system engineers and other selected personnel who reviewed and verified IST

surveil 5nce procedures. When the inspectors reviewed the training records, they

found that 4 engineers were not trained in this regard. The LER was left open

pending completion of this training. After being informed of this observation by the

inspectors, the licensee documented the discrepancy in CR 96-2069. On

December 13,1996 training was provided for the 4 engineers plus one extra. The

inspectors reviewed the training attendance sheet. All system engineers who

reviewed IST procedures were trained.

Failure to perform IST surveillance testing of the correct skid-mounted check valves

in the EDG starting air system was a violation of former TS 4.0.5. This i

licensee-identified and corrected violation is being treated as an NCV consistent

with Section Vll.B.1 of the NRC Enforcement Policy. Specifically, the violation was

identified by the licensee, was not willful, actions taken as a result of a previous i

violation should not have corrected this problem, and appropriate corrective actions  !

were completed (50-458/9617-04). l

M8.3 (Closed) LER 50-458/96-003: Engineered safety feature actuations because of

electrical protection assembly brecker trip. This event was discussed in NRC i

inspection Report 50-450/96-002,Section 2.2. An unresolved item was identified  ;

which questioned industry practice for retesting breakers after they had been racked

out and then back in. The unresolved item was closed with no enforcement action -l

as described in NRC Inspection Report 50-458/96-05, Section 9.2.

Ill. Enaineerina

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E2 Engineering Support of Facilities and Equipment (37551)

E2.1 Outdoor Temoerature Effects on Secondary Containment Neuative Pressure

a. Insoection Scope

The inspectors evaluated the licensee's response to CR 96-1916, which was

initiated as a result of a design engineering review of previous CR 90-0673, which

pertained to the effects of extremely low outside temperatures on the ambient

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pressures required in secondary containment.

b. Observations and Findinos

NRC Information Notice 88-76, alerted licensees that the design of secondary

containment pressure control and monitoring systems may not have taken into

account the temperature-induced difference in pressure gradients versus elevation

when the atmosphere outside secondary containment was significantly colder than

the ambient temperatures inside. During unusually cold weather, if secondary

containment differential pressure was monitored and controlled near the lower

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elevations of the building, the differential pressure could be within TS limits in the

lower areas of the building; however, in the higher elevations the differential

pressure would be less negative or perhaps positive. This is because of the

difference in density between the inside and outside atmospheres. Consequently, j

after the postulated design basis loss-of-coolant accident (LOCA), radiation

exposures could be higher than originally calculated because of the increased time

there would be a positive differential pressure in the upper elevations of secondary

containment.

On November 6,1996, while updating calculations for standby gas treatment

system drawdown analyses for the purpose of converting the calculations over to a

new GOTHIC program, the design engineers reviewed the previous licensee

disposition of NRC Information Notice 88-76. The design engineers found that the

disposition confirmed that during cold weather, a slightly longer positive pressure

would exist in secondary containment at the start of a design basis LOCA, but the

exclusion area boundary thyroid dose would be less than the 300 REM established

by 10 CFR Part 100. The disposition stated that the concern addressed by NRC

Information Notice 88-76 was applicable but inconsequential to River Bend Station

and no further action would be taken. The design engineers found that the

licensing basis was not revised to reflect the increased positive pressure period or 1

the increased post-LOCA doses. ]

The design engineers determined by calculation that post-LOCA and postfuel- l

handling accident doses would be within the limits of 10 CFR Part 100, and control

room doses would be within the limits of 10 CFR Part 50, Appendix A, General  ;

Design Criterion 19, and Standard Review Plan Section 6.4, as long as the outside

temperature did not go below 10F. As an immediate corrective action, the

operators were instructed to place the standby gas treatment system and the fuel

building exhaust filtration unit in servk,e whenever the outside ambient reached  ;

10 F or below. The inspectors nuted that this low temperature extreme would

rarely be reached in the geographical area of River Bend Station. The licensee

stated that the bounding temperature of 10'F assumed a O psi differential at ground

level, an inside temperature of 85 F, and a relative humidity of 80 percent inside

and 0 percent outside. The insnectors questioned when, since startup in 1985, the

temperature was below 10 F. The licensee responded by producing meteorological

tower printouts that indicated on December 23,1989, the temperature dropped to

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7 F for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This had a negligible effect on the positive pressure period

l such that postulated dose limits would not have been exceeded.

l Until the differential pressure monitoring and alarm equipment could be modified to

j indicate the most conservative differential pressure, the design engineers provided

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curves indicating acceptable values of differential pressure as measured with

existing equipment as a function of outside temperature. The engineers developed

curves for the reactor building annulus, auxiliary building, and fuel building. The

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curves were incorporated into Procedure STP-000-0001," Daily Operating Logs,"

Revision 20. A 10 CFR 50.59 safety evaluation was completed in support of the

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change. The inspectors reviewed the change and the safety evaluation and found

them to be technically adequate.

For long-term corrective actions, the licensee was considering moving the

differential pressure monitoring and alarm equipment detectors to a higher elevation

and/or changing the setpoints to a more conservative value so that there would be

no problems with temperature-induced differences in pressure gradients in

secondary containment. ,

c. Conclusions

Design Engineering demonstrated a good questioning attitude in reviewing the

licensee's 1990 response to NRC Information Notice 88-76, relative to possible

secondary containment positive pressures caused by low outside temperature

extremes. Immediate action to provide the operators with outside temperature

dependent acceptance criteria for secondary containment pressure was appropriate

to the circumstances pending implementation of permanent corrective action.

E2.2 Review of Facility Conformance to Uodated Final Safety Analysis Reoort (UFSAR)

Descriptions

A recent discovery of a licensee operating their facility in a manner contrary to the

UFSAR description highlighted the need for a special focused review that compares

plant practices, procedures and/or parameters to the UFSAR description.

While performing the inspections discussed in this report, the inspectors reviewed

the applicable portions of the UFSAR that related to the areas inspected. The

following inconsistency was noted between the wording of the UFSAR and the

plant practices, procedures and/or parameters observed by the inspectors:

While reviewing the UFSAR as it pertained to containment personnel air locks,

discussed in Section M1.3 of this inspection report, the inspectors noted a minor

inconsistency between the design description of the airlock door interlocks in the

UFSAR and the actual design. Section 3.8.2.1.3.2 of the UFSAR stated that the

airlock design is such that a failure of two devices / systems (double failure) is

required to place the doors in a condition where both doors could nol be opened

simultaneously, thus satisfying the single-failure criteria. The word not was

incorrect, in that the installed doors could be opened simultaneously in the event of

a double interlock failure.

.

The licensee promptly initiated action to revise the UFSAR to delete the word nqt.

The licensee's response to this minor inconsistency was appropriate. No additional

documentation is required in this report.

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E8 Miscellaneous Engineering issues (92903)

E8.1 (Closed) Violation 50-458/9525-01: Failure to meet General Design Criterion 55.

The inspectors identified that a line connected to the low pressure core spray

system did not contain a locked closed manual valve or was not determined to be

acceptable on some other defined basis. For corrective actions, the licensee: (1)

performed a review to determine if any other lines had a similar problem and noted

that the residual heat removal system had a similar configuration, (2) identified the

containment isolation boundary and sealed closed the applicable valves, (3) revised

the applicable system operating procedures, (4) revised the UFSAR, and (5) revised

be engineering instruction that determined locking requirements. The inspectors

reviewed the licensee's documentation of corrective actions and determined that

these items were satisf actory. In addition, the inspectors verified that the valves in

question were locked in the field.

IV. Plant Support

R1 Radiological Protection and Chemistry Controls

R 1.1 General Comments (71750)

Throughout this inspection period, the inspectors observed performance in

radiological protection. For the activities observed, the inspectors noted that

personnel properly donned dosimetry and followed radiological postings. The

inspectors verified that a sample of radiation, high radiation, and locked high

radiation areas were properly posted and controlled.

S1 Conduct of Security and Safeguards Activities

S 1.1 General Comments (71750)

Throughout this inspection period, the inspectors observed security officers as they

performed their duties. The security officers were alert at their posts, security

boundaries were maintained properly, and entry screening processes were

performed properly at the primary access point. Except for one minor discrepancy

that was immediately corrected, the inspectors noted during night tours that the

protected area was properly illuminated. 1

P3 Emergency Preparedness Procedures and Documentation

Licensee On-shift Dose Assessment Capabilities (Tl 2515/134) I

P3.1

a. Inspection Scope

Using Tl 2515/134, the inspectors reviewed information regarding:

.

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• - Dose assessment commitment in emergency plan

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• On-shift dose assessment emergency plan implementing procedure

• On-shift dose assessment training

, b. Observations and Findinas .l

On December 16,1996, the inspectors conducted an in-office review of the

emergency plan and implementing procedures to obtain the information requested

j by the temporary instruction. The inspectors conducted a telephone interview with

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the licensee on December 17,1996, to verify the results of the review. Based on j

, the documentation review and the licensee interview, the inspectors determined i

' + that the licensee had the capability to perform on-shift dose assessments using real-

time effluent monitor and meteorological data and that the commitment was

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. described in the emergency plan and implementing procedures.

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i c. Conclusions

i The commitment to perform onshift dose assessments was appropriately described

{ in the emergency plan and implementing procedures. Further evaluation of the

, information obtained udmq the Tl will be conducted by NRC Headquarters

personnel.

V. Manaaement Meetinos

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X1 Exit Meeting Summary

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The inspectors presented the inspection results to members of licensee management at the . 1

conclusion of the inspection on February 6,1997. The licensee acknowledged the findings

presented,

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The inspectors asked the licensee whether any materials examined during the inspection i

should be considered proprietary. No proprietary information was identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

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Licensee

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J. P. Dimmette, General Manager, Plant Operations

M. A. Dietrich, Director, Quality. Programs

D. T. Dormady, Manager, Plant Engineering

J. Holmes, Superintendent, Chemistry

H. B. Hutchens, Superintendent, Plant Security

T. R. Leonard, Director, Engineering ,

D. N. Lorfing, Supervisor, Licensing I

C. R. Maxson, Senior Lead Licensing Engineer

J. R. McGaha, Vice President-Operations

W. P. O'Malley, Manager, Operations

W. H. Odell, Superintendent, Radiation Control

R. L. Roberts, Acting Manager, Maintenance

INSPECTION PROCEDURES (IP) USED

IP 37551 Onsite Engineer:ng

IP 61726 Surveillance Observations

IP 62707 Maintenance Observation

IP 71707 Plant Operations

IP 71750 Plant Support Activities

IP 9.700

. Onsite Followup of Written Reports of Nonroutine Events at

Power Reactor Facilities

IP 925 01 Followup - Operations

IP 92902 Followup - Maintenance

IP 92903 Followup - Engineering

Tl 2515/134 Licensee On-Shift Dose Assessment Capabilities

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ITEMS OPENED AND CLOSED l

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50-458/9617-03 VIO Failure to implement effective corrective action  !

(Section M1.6) i

Closed i

50-458/9525-01 VIO Failure to meet General Design Criterion 55 l

(Section E8.1)- I

50-458/9525-03 VIO Missed surveillance on average power range ]

monitors (Section M8.1) .

50-458/95-002 LER Deficient IST procedure for EDG air receiver. i

check valves (Section M8.2) I

50-458/96-003 LER Engineered safety feature actuations due to  ;

electrical protection assembly breaker trip 1

(Section M8.3) ,

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Opened and Closed 1

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50-458/9617-01 NCV Failure to verify hydrogen mixing valves closed every 31 days

(Section M1.4) i

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50-458/9617-02 NCV Failure to maintain Surveillance Test Procedure STP-500-4201

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technically adequate (Section M1.5)

50-458/9617-04 NCV Failure to perform IST of the correct check valves in the EDG

starting air system (Section M8.2)

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LIST OF ACRONYMS USED

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CR Condition Report  ;

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EOG Emergency Diesel Generator

EOP Emergency Operating Procedure

IP inspection Procedure

IST Inservice Testing

LCO Limiting Condition for Operation

LER Licensee Event Report

LOCA Loss-of-Coolant Accident 1

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LPCI Low Pressure Coolant injection

MAI Maintenance Action item

NCV Noncited Violation

PDR Public Document Room 1

psig Pounds per Square Inch Gage

RC&lS Rod Control and Information System

SERT Significant Event Review Team

SR Surveillance Requirement

SSW Standby Service Water

TI Temporary Instruction

TLCO Technical Limiting Condition for Operation

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TS Technical Specification

UFSAR Updated Final Safety Analysis Report