IR 05000311/2004019

Insp Rept 50-458/85-22 on 850311-0419.No Violation or Deviation Noted.Major Areas Inspected:Maint Program,Test & Measurement Equipment,Surveillance Testing & Calibr Control Program,Design Changes & Mods & Document Control

ML20129B372
Person / Time
Site:	Salem, River Bend
Issue date:	05/10/1985
From:	Farrell R, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20129B359	List: IR 05000311/2004019 ML20129B354
References
50-458-85-22, NUDOCS 8506050203
Download: ML20129B372 (17)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV~

NRC Inspection Report:

50-458/85-22, Construction Permit:

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: March 11 through A ril 19, 1985 64</

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Inspect r:

s g R. E. {arrel{, Sen r Resident-I6spect~ r '

Date o

~ Approved:

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5-f J.. P/ Ja (don, ie7,7roject Secti'on A Date Realtor *roje Branch 1 Inspection Summary Inspection-Conducted March 11 through April 19, 1985 (Report 50-458/85-22)

' Areas Inspected Routine, unannounced inspection of licensee action on previously identified inspection findings, maintenance program, test and measurement equipment, surveillance testing and calibration control program,

design changes and modifications, document control, allegation review, and site tours. -The inspection involved 148 direct inspection-hours by one NRC inspector.

Results: :Within the areas inspected, no violations or deviations were identified.

Thirty-three new open items were identified which will be reinspected in future inspections.

lDR6050203 850520 G

M 05000458 PDR

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DETAILS

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Persons Contacted

Principal Licensee' Employees

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.W. ~J. Cahill,: Senior Vice President,_ River Bend Nuclear Group

- *J.-C.'Deddens,-Vice President, River Bend. Nuclear Group

• T.'C. Crouse, Manager, Quality Assurance T.- F. Plunkett, Plant Manager P. Freehill, Superintendent, Startup and Testing

• P. D.-Graham, Assistant Plant Manager-LH. M. McClellan,' Senior Compliance Analyst

• G. V. King, Plant Services Supervisor

• R. B.-Stafford, Director. Quality Services

• K. E. Suhrke, Manager, Projects Planning & Coordination

• P. F.- Tomlinson, Operations Quality Assurance Supervisor

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L*I. M. Malik,: Supervisor, Quality Engineering R. E. Bailey, Supervisor, Quality. control L. B. Clauer, Attorney

' L. - A. England,. Supervisor, Nuclear Licensing'(Beaumont, Texas) :

P.-J. Dautel, Licensing Staff Assistant P. F._Gillespie, Compliance Engineer-K.:C.L Hodges, Supervisor, Quality Systems

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P. G.. McGill,: Senior Electrical Engineer

.*H. D. Kowalezuk, Assistant Plant Manager, Maintenance & Material

• G. R. Kimmell, Supervisor, Operations _ Quality Assurance

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D. B. Reynolds, Supervisor, Administrative Support

• M. E. Walton,: Supervisor, Design Engineering

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• Doug Gipson, Assistant Plant Manager, Operation's

'*J.'E..Spivey,. Quality Assurance Engineer

'*J. E. Booker, Manager, Engineering & Licensing

^*J. W. Lawrence. Engineer _ Licensing

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• J. M. Glazar,, Director, Nuclear, Plant Engineering

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• R. E.'Barnes,' Quality Assurance Engineer

• D.1J. Krueger, Supervisor Engineering Administration

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• N. M. Whitman, Supervisor Maintenance Planning

• G. A.'Bysfield, Technical Staff Engineer

• Bill'. Reed, Director,' Nuclear Licensing

--Stone and Webster (S&W)

~F. W.' Finger, III, Project Manager, Preliminary Test Organization-W.

I. Clifford, Vice President

.C. A. Goody, Resident Manager v

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'*B.JR. Hall, Assilstant Superintendent, Field Quality Control P.:D.-Hanks, General ~ Superintendent, Construction

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R. L.: Spence, Superintendent, Field Quality. Control

.D. P. Barry, Superintendent,. Engineering

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• W. T. Tucker,uAssistant to Superintendent, Engineering

• D.'E; Hill,: Maintenance' Engineer-

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The NRC senior lresidentLinspector-(SRI) also interviewed additional

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licensee personnel, S&W personnel, and other contractor personnel during this inspection.

• Denotes those present at the exit interview April 19, 1985.

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Licensee Action on Previous Inspection Findings

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1(Closed) Violati_on (458/8428-01):

" Quality Assurance Audit Program."

The-licensee has conducted an. extensive audit ~in the~previously omitted area, preventive maintenance, and reviewed and subsequently revised the current audit schedule to' meet.the requirements of ANSI.N18.7-1976,

" Administrative Controls and Quality, Assurance for the Operational Phase of. Nuclear Power Plants." This. violation i's closed.

(Closed)' Violation-(458/8428-02):

" Quality Assurance Records." The

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' licensee has brought his. quality assurance record keeping requirements in-conformance with the' record keeping requirements of ANSI N45.2.12-1977,

" Requirements for Auditing Quality Assurance Programs for Nuclear Power

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Plants." This violation is closed.

(Closed). Violation (458/8428-03):

" Control of Quality Assurance Procedures." The licensee has brought the quality assurance procedures under control and eliminated redundant' quality assurance-procedures. This violation is closed.

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Maintenance Program-

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The SRI reviewed the licensee's maintenance program for conformance with proposed technical specifications, the operations quality. assurance program, and 10 CFR 50,' Appendix B.

Procedures-reviewed'were:

ADM-0003, Revision 4, " Development, Control-and Use of Procedures" '

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'ADM-0005, Revision 1,~ " Station Document Control"

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~ADM-0006, Revision ~1, " Control of Plant Records"

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'.ADM-0007, Revision 1, " Selection, Training, Qualification and

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Evaluation of Plant Staff Personnel" ADM-0018,. Revision 0, " Plant Housekeeping and-Cleanness (Sic)

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Control" ADM-0019, Revision 0, " Initiation and Processing of Condition

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Reports" ADM-0022, Revision 1, "Condtet of Operations"

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ADM-0023, Revision 3, " Conduct'of Maintenance"

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ADM-0028, Revision 2, "i'aintenance Work Request"

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ADM-0051, Revision 0, " Imp 9rtant to Reliability Program"

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MSP-0001, Revision 1, " Maintenance Section Organization and

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Responsibilities" MSP-0002, Revision 0, " Corrective Maintenance Program"

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MSP-0003, Revision 1, " Preventative Maintenance Program"

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MSP-0007, Revision 0, " Maintenance Planning and Scheduling"-

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MSP-0011, Revision 0, " Certification and Training of Personnel for

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'Special Processes" MSP-0013, Revision 0, "Cleannes (Sic) and Cleaning Methods"

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MSP-0014, Revision 0, " Housekeeping"

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OSP-002, Revision 1, " Shift Relief and Turnover"

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FPP-0060, Revision 1, " Hot Work Permit"

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FPP-0070, Revision 0, " Duties of Fire Watch"

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RHP-0042, Revision 1, "Alara Pre-Job Review

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TPP-7-013, Revision 0, " Mechanical Maintenance Training"

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-TPP-7-014, Revision 0, " Electrical Maintenance Training"

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'TPP-7-015, Revision 0, " Instrument and Control Maintenance Training"

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QAI-2.1, Revision 1, " Audit Performance and Reporting"

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QAI-2.0, Revision'0,~" Planning and Scheduling GSU Quality Assurance

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Audits and Surveillances" QCI-3.2, Revision 0, " Inspection of Maintenance Activities Associated

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.with Maintenance Wo k Requests" As a result of this review, the NRC inspector had findings in the following seven areas.

a.

Corrective Maintenance

'(1) Written procedures have been established for initiating requests for routine and emergency maintenance.

(2) Criteria-and responsibilities for review and approval of maintenance requests including emergency maintenance requests, have been established.

(3) Criteria and responsibilities, that form the basis for designating the activity as safety or nonsafety-related, have been established.

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(4) Criteria and responsibilities have been designated for-performing work inspections of maintenance activities.

(5) Provisions and responsibilities have been established for the identification of appropriate inspection hold points related to maintenance activities.

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However, procedure ADM-0028, in the note to paragraph 5.10, says, in part, "... Workers shall not begin work until step 5.10, if applicable, has been completed." Step 5.10 is the quality. control (QA) supervisor signature on the maintenance work request (MWR) indicating that QC has had the opportunity to review the MWR adding any necessary inspection requirements..It is not clear from the procedure, who determines the "if applicable." Thisisconsideredanopenitem(8522-01).

Procedure ADM-0023 in paragraph 5.2.3F requires notification of

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QC for Category 1 emergency work, "as 'soon as practical."

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Procedure ADM-0028 in paragraph 6.1 states that for an emergency MWR, "QC will-be notified where possible." Notification of QC for safety-related work is required prior to the start of work unless emergency is very strictly defined.

Thisisconsideredanopenitem(8522-02).

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-6-(6)- Methods and responsibilities have been' designated for performing functional tests of structures, systems, or components, following maintenance work and/or prior to their being returned to service.

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(7) Administrative controls have been established requiring the following records to be prepared, assembled, received, and transferred to permanent plant files:

Approval of MWRs.

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Identification of personnel who performed the maintenance.

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Identification of the personnel who inspected the

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maintenance.

Cause of the malfunction or failure which necessitated the

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maintenance.

Description of corrective action taken.-

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Identification of past maintenance functional testing

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performed.

Identification of personnel that performed the post

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maintenance testing.

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Identification of test and measuring equipment used.

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(8) Responsibility to assemble and review the above identified records has been established.

(9) A program has not yet been established for reviewing completed

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corrective maintenance records to assess the adequacy of the preventative maintenance program, to identify repetitive failures of parts and components, and _to identify design deficiencies. MSP-0003 in paragraph 5.6 defines this review as being done by discipline supervision. This review however, wi.ll be based on trend data to be generated by others utilizing

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procedures not yet in existence.

This is considered an open item (8522-03).

(10)Responsibilitieshavebeenassignedtoassureimplementationof records reviews.

(11) Work control procedures requiring special authorization for activities involving welding, open flame, or other ignition

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sources and taking-into account nearby flammable material, cable

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U-trays or vital process equipment are established.

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-(12) Work control procedures requiring a: fire watch with capability

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ifor communication with the control room for-activities involving.

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._the; proximity of flammable material, cable trays, or vital

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process. equipment are established.-

No violations or deviations were identified in this area of:the

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'b.

Equipment Control

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. Methods and responsibilities for equipment control have been defined;

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these include the following:

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_ (1). Permission to release equipment or' systems for maintenance shall be granted by the operating staff.

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(2) ~ Prior to granting permission for removal of equipment for service, the operating staff is required to verify that-the

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equipment or system can be released without violating' technical specification requirements. Additionally, they detemine how long_it may be out of service. Granting of such permission is

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documented.

(3) When testing of redundant components or systems is required by

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Ni technical specifications or.10 CFR 50,.such testing is

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documented.

- (4). The status of equipment and systems is clearly identified.

(5) Procedures and responsiblity to determine when independent B

verification have been established.

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. (6) Procedures and responsibility for returning equipment to service have been established.

, (7)l The licensee has defined controls for the locking devices on the

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locked-open or lccked-closed valvrs and circuit breakers which

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assigns responsibility for authoridng removal of locking

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The.NRC inspector found that the licensee has not established a definition of acceptable locking devices for valves and circuit breakers. Thisisconsidered.anopenitem(8522-04).

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-8-No violations or deviations were identified in this area.

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Motor Operated Valve (MOV) Maintenance (1) Procedure CMP-1252, which provides for tabulating performance data, was reviewed; it included:

(a) Torque required to open and close valves; (b)

Type ' f torque switch and settings for open and close o

direction; and (c) Motor size, voltage, and full load and locked rotor amps.

This procedure is still in draft form.

This is considered anopenitem(8522-05).

(2) Procedure CMP-1026 is currently being revised to provide for tabulation of data pertinent to overload relays, heater size, breaker size, and trip setting. This considered to be an open item (8522-06).

(3) GSU has installed M0V magnetic trips that can be reset either manually or automatically. GSU ha', not established control to verify that all such resets are in t' e manual mode. This is an n

openitem(8522-07).

(4) GSU has not identified which valves have operators with nonlocking gears or brake assemblies. This is considered an openitem(8522-08).

As a result of this review, the NRC inspector found that GSU procedures assure that:

The torque switches supplied cannot demand a larger torque than

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the motor can supply.

TFe valve operator motors are not undersized for their particular

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load.

Tt a breakers are not undersized. The magnetic trip settings are

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based on motor maximum torque output.

The thermal overload relays and heaters have been sized for the

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licensee's desired locked rotor tripping time.

The sizing was studied and not randomly selected.

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It was also found'that GSU has' assured that' torque switch settings-will generate sufficient torqu.e to open and close the associated.

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No violations or-deviation's were: identified in-this' area.

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Preventative' Maintenance

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LA written preventive maintenance program for safety-related

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L structures,-systems and components'has.been established including:

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' Responsibility for the program.

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Documentation and review of-completion of preventive maintenance

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activities.

Responsibilities and methods for establishing PM frequencies.

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The NRC inspector. determined that a master schedule for preventative

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maintenance has not been established.

This is an open item

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No violations or deviations were identified in this area.

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-Special Processes s

Administrative controls for special processes, have been established

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as follows:

A requirement that only qualified procedures will be used.

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A-requirement that only qualified personnel will be used.

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The ALARA coordinator determines if mockups are necessary for

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ALARA consideration.

Other special-training.is identified and requested by'the discipline supervisors.

Responsibilities have been' assigned to accomplish the above

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listed items.

It was:also found that qualification requirements for procedures

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and personnel do not currently: address contract maintenance-personnel.

Procedures were'being revised to address this' item.

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This is~an open item (8522-10).

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i No' violations or deviations were identified in this area.

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Cleanliness' Controls

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Procedures have been developed for cleaning safety related

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componentsiand systems.

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JProcedures for maintaining:the~ cleanliness of previously' cleaned

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been established.'

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TheNkCinspectordetermined','howeve'r,-thatcleanliness.

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• lassifications'of_ plant systems have_not been. established.

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'an open item-(8522-11).

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?No violations or deviations were identified in this area.

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Housekeeping Controls

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" Administrative' controls and responsibilities for general housekeeping

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have.been established which include:

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Establishment of housekeeping' zones.

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Control.of housekeeping during work activities.

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Test'and Measurement Equipment

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L The objecti_ve of this inspection'was'to determine whether or not controls

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- had been established or test and measurement equipment. The NRC inspector L

determined the following:

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. Criteria and responsibility for assignment of the calibration /

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adjustment. frequency have been established.-

An equipment inventory list or equivalent has been prepared which

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identifies tbe following:

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(a) 'All test and measurement equipment which will be used for any

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reason on safety-related structures,' systems or components.

(b) The calibration / adjustment frequency for each piece of equipment.-

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(c) A calibration procedure to be used for each piece of equipment.-

The calibration procedure for each piece of equipment identifies the calibration standard to be used.

Formal requirements exist-for marking the latest inspection /

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calibration date on each piece of equipment or otherwise identifying

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the status of. calibration.

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A written requirement has.been established which prohibits the use of

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test and measuring equipment which has not been inspected and calibrated within the prescribed frequency and describes controls'to prevent inadvertent use.of such equipment.

Out-of-calibration controls have been established which require the

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following:

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(a) When a piece of equipment is found to be out-of-calibration, the acceptability of items previously tested or measured will. be evaluated and documented.

(b) Evaluation of cause of out-of-calibration.

A formal system has been established to assure that new test and

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measurement equipment will be added to the inventory list and calibrated prior to being placed in service.

Responsibilities have been assigned to assure that the test and

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measurement equipment controls identified above will be implemented.

It was also found that a system has not been provided for assuring that each piece of equipr.ent is calibrated and adjusted on or before the date required.

This is considered an open item (8522-12).

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No violations or deviations were identified in this area.

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Surveillance Testing and Calibration Control Program The' purpose of this inspection was to determine if the program for surveillance testing and calibration had been established.

The NRC inspector found that:

A master schedule for surveillance testing / calibration required by

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technical ~ specifications has been established which includes:

(a) Frequency for each test / calibration.

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(b) Plant group responsible for performing each test / calibration /.

inspection.

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(c) Surveillance test status.

Responsibility has been assig/ inspection schedule up-to-date.

ned in writing to maintain the master

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surveillance test / calibration-Formal requirements have been established for conducting surveillance

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tests and calibrations in accordance with approved procedures which include acceptance criteria, i

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Formal methods and responsibilities have been defined for review and

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evaluation of surveillance test / calibration ~ data including procedures-I for reporting deficiencies, failures, malfunctions -identified during -

the tests / calibrations with required verification that LCO requirements were satisfied.

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Responsibility has been assigned for assuring that required' schedules

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for all tests and inspections are satisfied.

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It was also found that this program does not yet include the inservice testing / inspection requirements of 10 CFR 50.55(a).

This is an open item

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(8522-13).

• No violations or deviations were identified in this area.

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Design Changes and Modifications The NRC1 inspector reviewed the procedures for the design change process after licensing.

The findings of this review are in the following six subparagraphs:

a.

Design and Modification Change Requests

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Methods for initiating a design or modification change request

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(MCR) have not yet been established.

This is an open item (8522-14).

i-Design change request control form, or equivalent, with

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I provisions for documenting completion of required reviews, evaluations, and approvals prior to implementing the change has not yet been established.

This is an open item (8522-15).

Methods for assuring that a proposed change does not involve an

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unreviewed safety question as described in 10 CFR 50.59 or a change in the technical specifications have not yet been established.

This-is an open item (8522-16).

Methods for assuring that applicable guidelines of R.G. 1.120,

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" Fire Protection Guidelines for Nuclear Power Plants," or approved NRC alternates are included in design and procurement documents and that deviations therefrom are controlled have not been established.

This is an open item (8522-17).

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No violations or deviations were identified in this area.

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Design Control The NRC inspector found that:

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IIdentification of the organization responsible for performing

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' design work has been established.in Quality Assurance

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, Directive-3,1" Design Control."'

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Responsidlities'andmethodsforconducting-safetyevaluations-k

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have:not been established. 'This-is anLopen item (8522-18).

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Procedures 1and.responsitiilities for identifying,. reviewing,and -

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'Japproving design input requirements have not been established.

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-This is an open item (8522-19).

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Methods, procedures',anbresponsibil'itiesforperforming

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. independent' design verifications have not been-established.

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This is an open ites (8522-20).

_D_esign interfaces.between-internal and/or external design

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{ organizations have'not been established. This is an open item

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(8522-21).

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Responsibility for final approval of design documents has not

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been established. This:is'an open item (8522-22).

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l-No'~ violations or deviation were identified in this area.

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Design Document Control It was determined that:

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Methods for controlling changes to approved design change L.

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H documents have not been established. This is'an open item

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(8522-23)..

Methods for controlling or recalling obsolete design change

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'have not been established.

This is an open item (8522-24).

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Methods for release of approved design change documents have'not-

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been established. This'is'an open item (8522-25).

Responsibility to assure compliance with design control

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. requirements has not been assigned.

This is an open item

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-(8522-26).

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No violations or deviations'were identified in this area.

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Operator Design Change Information

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-It was found that procedure ADM-0014, Revision 0, " Interim Design l-Change Control,"~provides administrative controls and assigns L

responsibilities to assure that design changes and modifications will

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be incorporated into:

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.(1)lPlantprocedures.

(2).Operatortraining.

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(3) Plant drawings.

No violations or deviations were-identified in this area.

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Design Change Implementation

- The. NRC inspector found that:

Administrative controls to collect and transmit design

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documentation including design review documentation to permanent plant files have not been established. This is an~open item (8522-27).

Administrative controls requiring that implementation of

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. approved design changes be in accordance with approved procedure have not been established. Thisis.anopenitem(8522-28).

Administrative controls requiring post modification acceptance

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testing be performed per approved test procedures and the results evaluated have not been established. This is an open item-(8522-29).

Responsibility for identifying post modification testing

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requirements and acceptance criteria has not been established.

This is an open item (8522-30).

Responsibility for reporting design changes and modifications to

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the NRC has not been established. This is an open item (8522-31)..

No violations or deviations were identified in this area.

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Temporary Modifications, Lifted Leads and Jumpers The NRC. inspector's review indicated that:

Controls requiring the review and approval of temporary

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modifications in accordance with Section 6 of the proposed technical specifications and 10 CFR 50.59 have not been established. Thereisanexistingopenitem(8506-01) regarding this item.

Controls require the use of detailed approved procedures or a

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design review when performing temporary modifications have been established.

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-'A formal record is maintained of the status of temporary x.

. modifications, -lifted leads and jumpers, temporary strainers,

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and_ temporary trip points.of control equipment.

Controls require evaluation of the need for independent

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verification where appropriate of installation and removal of

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temporary modifications, lifted leads-and jumpers.

Requirements for functional testing of equipment following

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installation or removal of~ temporary modifications have not been.

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'l Requirements for periodic review of lifted lead and jumper

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records including a check of~ outstanding entries are not established. This is an open iten (8522-33).

Procedures'reviewedLin 'his area ~ include:

t OSP-0002, Revision 1,." Shift' Relief and Turnover"

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ADM-0031' Revision 3, "Temporiary Alteration's"

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No violations or deviations were identified in this area.

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Document Control The purpose of this inspection was to determine if a document control mechanism was in place for operation of the plant after licensing.

It was found that:

Administrative controls require that design documents used by station

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personnel be the most current revisions.

Administrative controls are provided for obsolete documents.

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Master indices are maintained for drawings, manuals, tech specs,

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FSARs', and procedures, which indicate =the current revision.

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Indices are available for reference.

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Indices are periodically. reviewed.

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Procedures reviewed in this area include:

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(a) ADM-0005, Revision 1, " Station Document Control

(b) ASP-0001, Revision 2,." Operation of the Station Document

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No violations or deviations were identified in this area.

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Allegation Review

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Anonymous ^ Telephone Call NRC. Region IV'had received an anonymous phone call alleging that at River Bend:

Coaxial and multi-conductor' cable below the reactor pressure

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vessel had been wetted by dripping water, raising. questions as to the integrity of this cable.

Multi-conductor cables were being mated to plugs via crimping

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when the connection should be made by soldering.

Field Quality Control (FQC) inspectors had attempted to identify

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their concerns regarding these cables via a nonconformance and disposition (N&D) report'and the N&D was either suppressed or reworded by a supervisor such that the meaning was altered.

The SRI interviewed personnel responsible for installation,.

inspection, and supervision of work on the cables below the reactor pressure vessel.

Additionally, the SRI reviewed S&W site instructions and General Electric procedures for termination of the multi-conductor cables.

The results of the inspection were:

These cables are expected to be wet from time to time and are

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continuously in a high humidity environment.

Once terminated to a plug, the cable end should be water resistant. Wetting of cable end prior to mating the cable.to its plug could result in some capillary action causing the cable to absorb moisture and be degraded.

Some of the cables below the reactor pressure vessel had been wetted prior to being mated to a plug.

The multi-conductor plugs in question were supplied by General

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Electric.

The General Electric installation procedures specify crimping as the method for attaching these plugs to cables.

S&W followed the General Electric procedures adding some conservatism to assure an adequate crimp.

FQC supervision in general, and the supervisor responsible for

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inspection of these cables in particular, were already concerned with and acting upon the wetting of these cables when the SRI began his inspection of this activity.

Rather than suppressing concern over these cables, records indicated that FQC supervisors were highlighting it.

An N&D was writtea which identified the wetting problem and sought resolution for cables that would have been wetted before they were mated to a plu y

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'The SRI noted that the'N&D on cable wetting referred to specific

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cables and not to all the cable below the reactor pressure vessel.

It would be very difficult to determine which of the-cables had-been mated to plugs and which had not, when the cables were exposed to dripping water Consequently, the licensee agreed to test all of the cables below the reactor pressure vessel to assure cable integrity.

Such testing is to be 100% witnessed by FQC inspectors.

This testing is the subject of an existing NRC open item (458/8425-02). Work continues in this area.

The allegation that the cables were wetted was considered substantiated; however, it was determined that the licensee had identified this condition and initiated appropriate corrective action.

This allegation is closed.

9.

~ Site Tours-The SRI toured areas of the site during the inspection period to observe construction progress, general job practices, housekeeping, and fire protection.

No violations or deviations were identified in this area of the

. inspection.

10.

Exit Interview An exit interview was conducted April 19, 1985, with the licensee

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representatives identified in paragraph 1.

At this time the SRI reviewed the scope and findings of the inspection.

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