IR 05000267/1976007
| ML20010B813 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/30/1976 |
| From: | Johnson E, Madsen G, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010B798 | List: |
| References | |
| FOIA-81-95 50-267-76-07, 50-267-76-7, NUDOCS 8108180135 | |
| Download: ML20010B813 (36) | |
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U. S. NUCLE!J REGULXiORY CO)1>!ISSION OFFICE Or INSPECTION AND ENFORCC5! INT
REGION IV
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IE Inspection Report No. 50-267/76-G*
Dochet Nanber 50-767 j
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Licensee: Public Service Company of Colorado Licce.se Na. DPP.-3?
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j Facility: Fort St. Vrain Nuclear Generating ':tation Category 3 l
i Location: Platteville, Colorado d
Type of Licensee: Power Reactor (HTCR 350, ?L'e-Cf;A)
g Type of Inspection: Routine, to.nounced
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Dates of Inspection: May 10-14, 18-21, and June 7-M, 1976 i
j Dates of Previous Inspection: May 3-4, 1976 i
Int.gector:
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'T. F. Wesn rean, Eca:ter Inspector Date
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'E. H. Johnson, Reacter Inspecter Date l
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i C. L. Madsen, Chief Recctor Operations Date
ar.d Nuc1 car Support Branch
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En f or e_e.en_! _ * * t ion A.
Sonconpliance Itens 1.
Violations None.
2.
Infraction 2 4 5, 10 CFR 50, and Contrary to Crite ion V, Appendi:
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the licensee's approved QA plan, PSA3, Section B.5(c),
licensee procedures were not adhered to in tne follav-ing cases:
(1) Change Notice 59 contained a nero change deleting a step cf the installatf or. procedure. This change had not been revieued or cpproved by the PG:C '. DETAILS, paragraph 11). A nndification to the cont ol circuit of safety related vslve HV2189-1 was accceplished under PTP 2-231.
This nodifica-tion vas not rc.'icued and approved by PO?C (DETAILS, paragraph 12).
Administratite Procedure ADM la requires PORC approval of all odificativns.
(2) The codification preceduren for Change Notices C!:34, CS58 and C;;39 did not contain post cain-tenance checkout requirc=ents. Quality Assurance Plan QAP 1403 specifically rcquires that nodifi-cation precedurcs include detailed QA require =ents for poj. codificaticn chechouts.
(3) Interdepart: ental Uork Procedure ItiP-2, prescribing the ceth:ds and control ceasures to be applied to control of design and design modifications has not been issued. The Quality Assuranec >!anual Section 6.7.3. spetifically states that !"P-2 shall be issued (DITAILS, paragraph 11).
(4)
?' nt Trouble Reports PTR 1-137 PTR 2-68, and
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Pr?. 3-13 failed to indicate a proper naintenance procedure or that no procedure was required for the safety related caintenance conducted under these decurents. Administrative Procedure AD?.-12 specifically requires thac the PTK indicate the appropriate procedure or specify "no procedure is required," (DETAILS, paragraph 12).
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-2-(5) Plant Trouble neport 9-223 r.pecificd that Procedure ;1P 12-0 was to be used to correct the inproper ntackup at Belleville washers on the control shaft for the control orifice of CPD No. 25.
The conpleted MP 12-6 doer not indicate that the procedure was used to encomplish the disasse Sly of the control orifice assembly of CKD No. 25 (OETAILS, paradraph 12).
(6) An approved change in accordance with the pro-visions of the Station Battery Dischar;:e Test (PORC 151/5-11-76) was not obtained when the discharte test was terminated at 109.4 Volts DC
vice 105 Volts DC (LETAILS, par 0 graph 2.b.(0)(d)).
(7) Class I cabic tray divider cove =ent and/or addition
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of extensions have occurred without proper Work A:u.ori:3 tion as required by ADM-27 (DETAILS, paragraph 2.b.(6)(f)).
(8) Unused 7018 weld rod was not being returned to the weld rod ovens as required by Section 6.4 of the contractors proceddre (DETAILS, para;raph 9.h.).
(9) Change Sotice CS59 was acconplished withoi.t the use of an approved controlled Ucrk Procedure.
The Quality Assurance Manual Section 6.4.(e) re-quires that modifications be accomplished in accordance with approved procedures. This in-fraction was identified by the licensee in his internal audit proCram under QADR 173 (DETAILS 4 paragraph 11).
(10) Change Notices CN34, 57, SB and 59 did not include a review of the completed acceptance testing and test results by the PSC cngineering department.
This review is required by Engineering Procedure ES-1.
This infraction was identified for several additional change notices by the licensee in his internal audit program as reported in QA Audit 1402 dated April 2?, 1976 (DETAILS, paragraph 11).
b.
.catrary to Criterion VI of Appendix B to 10 CFR 50 and the licensee's approved QA plan, FSAR Section B.5.5, the licensee failed ta update ae-built drnuinas to indicate system nodifiations for the following: Piping and Instru=entation drawing PI S2-1 was not updated for completed Change Notice CN34 and PI 41-1 was not updated for CN58 (DETAILS, paragraph 11).
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Deficiencies None.
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II.
Licen ee Action on Previou,1v Ident if !ed En'orcer.:ent Action Mone.
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DasU n Changen None.
IV.
Other SipIficant Find!nn A.
Current l'nresolved Itcas 7607-01 Changes t o Operat ica. Procedures to Refleet 'fodifications (DETAIT,'s, paragraph 11.c.(3)).
The Backup Bearing L'ater Systen Operatin;; Procedure and Fervice 1.'ater Systeo Operating Procedure have not 1:een changed to reflect the r.ystem codifications perforced under ICN 2691 and CN58 respee-tively.
7607-02 Records of ; fain & nance Perf or ed I'n 'er Pin 1-29'l (OETA1!S, paragraph 12.c,(2)).
The records to support the ruintenance described on PTR 1-293 could not be located by the licensee during this inspection.
Specifically, the ccaple :c4 copy of Maintenance Procedure MP 11-3 and the supporting supply docu ents fer the purge line c!.eck valves that were installed were not available.
7607-03 Functional Tc:tinz of 1.'ork Performed Under PTR 2-150 (DCTAILS, paragraph 17.c.(3)).
No records indicating that functional testing of the moisture monitor heater :::: roller worked on under this PTR vere available.
7607-04 Seissi: s.r.d Environrental qualifications Portions of Class I Systens have been identified as deficient in Scismic and erceironuental qualifications (DETAILS, paragraph 4).
7607-05 ASCO Snlenoid Valves Administ rative processing of the change of neal material f or the j
recen:ly nodified ASCO Solenoid Valves is considered unresolved (DP. TAILS, paragraph 30).
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!;t:stu2 _of Previcealv Id nt it ied l*r. resolved Ite _s i
t The followin;; previously identified unresolv>d it<.r.4 una j
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j revic = d by the inspector:;:
i 7605-01 Tray Divihr ':sverant/ Extensions (LETA*LS, para;:raph i
2.b. (l) (d)).
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j 7605-02 ::anhole unber 4 (DETAILS, paragraph 2.b. (*.)(c)).
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7601-03 Cable Audit To11cuup (DETAILS, paragraph 6).
7510-01 Cable Separation /S=:;rogation (DETAILS. p.radaph 7).
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7( 01-04 System 91 "Pydr.,ulic" (DETAILS, paragraph 8).
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t'nresolved ite: s 7695-02, 7601-03, and 7510-01 verc found by j
the inspector to be resolved. Unresolved ites 7605-01 has j
been leentified as an item of noncomplir.nce in the enforcement j
sectiun of this report. L'nresolved Stes 7601-04 vill require
additional inspecti:n follovup.
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thnnement Interviev
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Entrance intervicvs ucre hol.! with 1:r. Svart and other plant j
personnel on :-!ay 10,1S, and.%ne 7,1976.
I D:it interviews uere held with >:r. Svart and other plant personnel j
on ':ay 14, 21, and June 10, ~ 976.
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A.
Cencral
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j 1hc purpose of the ins;ection was stated r.o be to verify licensee's completed c:::ective acti:n of these items necessary
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j for the resumption of the rise to pcect testing, pro:: ram to 40'..
Plant naintenarce cnd 12si;n control ceasuras wro also stated
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l-to have been inspe:ted.
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Items of Nonconfe-2nce t
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The items of n:n::afornance identified i$ the surre.ary section of this rep::t verc discussed.
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Unresolved Itens a
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l The neu and previous unresolved itens identified in the su :ury
section of this tcport were discussed.
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Schedule
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._*ne schedule for start up of the plant was discus:.ed.
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_ DETAILS _
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Persons contacted _
f Public Service Cor.cany of Colorado i
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J. Reesy, Electrical Engineer a
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J. Readar, Resident Engineer
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F. Swart, Superintendent, Nuclear Production j
L. Brey, Superintendent, Operations D. Warer. bourg, Director of Q.'.
D. Rogers, Operation Supervisor i
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S. McCabe, Engineering l
J. Solakiewicz, QA Engineer H. Hillyard, Supervisor Technlen1 Services bepartment
J. Can=, Training Coordinator
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M. Revic. Q1 Engineer i
G. 31sset, QA Engineer j
H. Craine, Maintentnce Supervisor j
J. Liebelt, Electrical Maintensn:e Supervisor l
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L. McInroy, Engineering QA Supervisor
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j G. Lipsey, Electrical Engineering G. Brown, Plant Startup j
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i J. Uaage, Site Pro *cet Manager
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G. Uessnan, Engineerin,?
D. Pcetycord, Manager of QA
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A Electrical Separation /Segre.2 tion - Tornal Corrasconden_ce to UFC
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(IE Inspcetion Report 50-257/76-05)
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a.
Scope of Insoeccion The licensee's May 10, 1975, letter response to the Division of Rea: tor Li:ensing ( ?1), April 27, 1976, lettet and the out-standing items identified during IE Inspection 50-267/76-05 ucre i
reviewed 1.
res:1ution. The licensee's supplemental June 10, j
1976 Icteer to I?1 was used as the basis fer inspection of the
licensee's over:urrent protection study.
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Syt_us of C:'rrective __ Action
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(1) The liccusee has subaltted by letter dated Hay 10, 1976,
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the intended final resolution for resumption of stage 1 j
of the power ascensicn program.
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(2)
,C,qt ego ry 1 Cali; Uork AuthorJest.ons (UA 2917 and 2513) for the (a)
installation of asbestos cloth have been v.rified as complete by IE:1V.
(b) Justification has been provided in item XI.f. of the licensee's May 10, 1976, letter far the installa:ian of control cable conductors smaller thar. No.12A%0.
The inspector verified that the revies of No. 12AWO and smaller cable conductor had been completed by the contractor and licensee on !!ay 4 and 7,1976, respectively, and all circuits were found by the study to be consistent with the design of tha circuits involved. One cabic No. 6305 required carrective action. An additional No. 16AWC conductor (which was installed r. pare) was utilized to assure adequate ampac it y.
This work was verified by the inspector as complete f.2crk Authorization 3095).
The overcurrent protection study was revieved for
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confornance Vith the licensee's May 10 and supplenet.tal June 10, 1976, letters to DRL. The inspector found
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that proper cable arpacitics hsd been utilized. The inspector had initially found less conservative amparitics were used in the original overcurrent study, than those stated in item II.e. of t1 licensee's May 10, 1976, Ictter to DRL (i.e. 26 anps vice 17 anps for No. 12 AVG, and 34 amps vice 23 n=ps for No. 10AWG).
These apparent discrepancies have now been resolved.
The inspector vecified the licensee's identification of 185 cables with a protective device ratings greater than the derated anpacity of the cable by a 100 review of all tabulated data. The establish:.ent of the breaker / fuse siring in accordance with Table A of the licensee June 10, 1976, letter to DRL was verified by IE:IV. The inspector was informed by a phone call on June 13, 1975, by the licensee that the $1 group 1 (No.12AUS) fuses were replaced pc r ricld Change F
Notice 3361/Contro11cd Work Troetduce 131 and that the 1 ;.7up 2 (cable 13064) fusc has been codified by para 11 cling two No.10AUO conductors per Change Notice SE / Controlled Work Trocedure 134. The completion ei the work associated with these two iters was verified by licensce's QA organization. Croups 3,4,5, and 6 calic fuses / breakers, as identified in the licenr.ce's Jure 10, 1976, letter to DRL are to be nodified prior j
to exceeding 40% power / stage 1.
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-7-The inspector also compared the 20 amp fusetron russaan fuse tima current characteristics with that of No. 12N.00 cabla. The ru.,etron t're current curve does net exceed the No. 12.\\WC current time rating
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for triplex power cable. The Tusetron amp rating is approxitately the same (11 amp as the 3usanan UCS amp rating at 1000 seconds) (ton; tern protection). The
rusetron short term acp rating exceeds that of a Bussman NON fuse; however, as stated above, it is not j [
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in excess of the No. 12AWC triplex cable time current g,
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racing.
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I The inspector reviewed the derating of power calles
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(category 1 and 5) as tabulated in the overcur.cnt
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protection study. The study showed that in no cases
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were rated loads in encess of the cable derated a=pacity.
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of category 1 or 5 power cables.
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(c) The generic study of instrument and control cables
for the application of flacemantic/ asbestos cloth t
I was verified by the inspector to be complete. The study was based on the criteria stated in item II.f. of the T Ice nsee's May 10, 1976, letter. The results of l
the study are documented in a May 20, 1976, contrattor
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intarnal ceno (FGLP-1263). In no c'ases were the i
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estinated loads greater than 30% or the allowable j
ampacities assuming a maximum darating for tray fill.
This rtudy was.not required until stage 2 (407. power);
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however, the licensee is using this study in lieu of
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an individual evaluation for instrument and control
cables in the canholce which have flamemastic already J
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(d) Application of flamenastic and installation procedures L
rc=ains a stage 2 (40% power) limitation.
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l (c) The licer.see has accounted for all Category 1 cables
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vhich have been either added or deleted frds previous
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correspendence to the Division of teactor Liecnsing
(D?.L). This information was submitted in the licensee's May 10, 1976, letter.
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j P (f) P5CO engineering's review of the May 10, 1976; Attach-l eent b letter, to determint propct inclusion of all
cabic in the overcurrent protection study, han been l 3-r complete.
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Twelv. eabics were found to have been nisted, n1though b
the contractor had documented in Tield Inspection
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Report 626 that all cables had haen previcusly a ccnated for.
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These twelve cables have been now included in the
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overcurrent protection study. Cable Na. 6560 from this grou:. was identified on the cc=puter tabulatian as a No. 10AWG with 50 asp breaker protectio. (Dersted anpacity for this cable is 34 amps; and was scheduled for replacement. Durins field verification, the esble was found to be a No. 4AWG. To suppoct the basis that no calles have been found to be undereized, that run in
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cable trays, the 200 cabler inspected c. ring the recent Management Audit were field rechecked by the licensee for proper sizing. Two additional cablec, 2501 and 2507 y
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were f ound to be No.10AWG vice No.12AWG a:.d this does support the licensee's basis that cables have not been undersized which run in cable trays. One cable, No.
6814 was found to be undersized; however, this c.7ble h;.
is 14 inches in length and is routed in condui'. only.
In addition, the cable is vcndor supplied and is sized
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in accordance with the vendor supplied prints.
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IE:1V has no open itens regardlag Category 1 cables which require correceive action before stage i operatien.
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(3) Cater,ory 2 s.nd 3 Cable l
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I (a) The status of cables in category 2 and 3 which were y
scrouted has been conputerized in tabular form. All
Field Change Notices and associated k'ork Authorizations have been identified. The inspector verifica that the computeri:ed status now indicates that corrective 3y action has been conpleted for all rcrouted category 2 and 3 cables. The inspector also reviewed a licensee QA Meno (May 13, 1976) docu=enting 1000 verification ther all category 2 and 3 cables requiring reroute had been correctly identified,in the contracter's co:puterized status rcport.
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(b) Additional infornation has been provided 'in the May 10 1976, licensee letter as requested by the Division of
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Reactor Licensing April 27, 1976, letter with regard
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te Category 3 cables.
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Ttw licensee has stated in Item V.b. that all control /
pcwer-trays /rf=.*rs have been reviewed to.issure that
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they have a 6C3 v insulation rating and that thiu study is available for M C review. 'the inspretor j
found that per c. contracter. study dated 5-3-76. all g,-
cont al cables having less than 600 v rating have been identificd in Table V-I of L..e Ir. sue B of th.'
cable tabulation dated April 21, 1976. Table V-1 ide,tifies all control cable routed in control / power-
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trays / risers. Hiere is one cable, No. 2'd9 which
'f was procured as a communication cable and has no insulation rating. This cabic is associated with g
the River Water Tecperature Monitor. It is fused
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at 2 amperes and therefore is current 1hited. The j
licensee has performed a 4.8KV AC induced Voltano test, a UL vertical Flame Test and the conductor insulation has been nessured to be 30 mils and the cable insulation
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45 nils. No further action is planned by the licensee.
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IE:1V considers this item closed.
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All other additional information pravided f -
tenory 3 cables in Section V a-c of the May 10, 19 (censee letter was s 0mitted for clarification of e
.a only and invalves no additional rc.lews je
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availcble on site for URC review.
(4) C.gerory 4 Cable (a) The audit of Category 4 cable corrective action for stage 3. was inspected in conjunction with Category 1
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(See DETAII.$, paragraph 2.b.(2) of this report).
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The correcti.e action necessary for stage 1 was found to be c cplete by IE:1V, including: installation of asbestos cloth; review of control cable conductor
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smaller than No. 12AliC; and the overcurrent protection study.
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(b) One aff.i:ional, iten applicable to all control cabics as well as Catet.ory 1 and 4 cables was reviewed and i
verified as complete. This concerned the review of ecatrol cables with 300 voir in ation in accordance with the Criteria ststc4 in it_
XI.e. of the licensee's May 10,1976, Ictter to DRL. This study was documented as complete on 5-8-76 and the results reviewed by the inspector. These results indicate that there is no cable which exceeds.:.e voltage classification of the cabic and appears consistent with the design b1 sis q
of the circuits in which they are installed.
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(5) C:stee:orv 5 Ca* ale (a) The complation of corrective action is: Cat.3 cry 5 cabic including application of flazerastic rnd t'.:e deratin; study is not required until stage 2.
The derating of Category 5 cable has, htvever, been raviesta by IE:1V and no probica itcos vers identifiad (DETAILS,
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paragraph 2.b.(2)).
(6) Additional Inforeation, Attachment I. Licensee's Decerber 15, 1975, Letter (a) Iten 1-n through 1 _i The inspector verified that L'A's associated with ite=s 1-g through 1-j are conplete.
(b) Items 1-k thr., ugh 1-t associated rith cable teork to correct the 3us Internin l' roble =.
Field Inspec:fon Report 378 has been closed. All
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corrective work associated with Ites 1-k through 1-t
have been verifica as conplete by IE:IV.
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(C) Paragrgph (2) Associsted uith Bus Intermix Closed o"r in IE Inspectio'n Report 50-267/76-05 as co=plete.
(d) Paragraoh (3) issociated with the Installation of a
New Non-interrectabic 120 VAC Bus.
The work asst: tat <d with TCN's 296', 3007, 3003, 3009, and 3134 was verified to be complete. FCN's 3134 and 3009 have been co:pleted in additi:n to those identified in IC Inspection Report 50-267/76-05. The other tuo (,
inco=plet itens required for stage 1 operation, as identifiad in IE Inspection Eeport 50-267/76-05, were P
seismic qualifiestion of the installed "C-9 batteries and preeperational test of the new instru=ent bus.
The disposition of these two items is as follows:
The EC-9 batteries were scismically tested at an independent testing laboratory on a shaker table and the results are documented in a report dated May 7,1976.
l The test certified that the batteries could withstand
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in the hori: ental direction 1.6g for the SSE at.d 0.8g for the OBE, and in the vertical direction 1.2g for the SSE and 0.1g for the OBE.
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A functional tast (Station Eattery Dischargs Test)
f was perferned in accordanca uith IEEE StanCard 45':-1075, paragraphs 5.1, 5.2, 5.4.1, 5.5.1, and 5.7.
The K (
factor for the battery was 100.453. IEE! 100 cece.ataa:e criteria is based on a K f actor of 100 + and the l
battery satisfied this acceptance criteria. One
'
apparent ites of nonconpliance was identified during
-
review of the test data. The battery test uss terninateJ at 103.4 Volts. Section 6.d. of the Station Battery Discharge Test (pORC 151/5-11-76) statas with rc :ard to te::ainal voltage, "."sintain the cc.nstant e
discharge rate uncil the battery terminal voltagt falls to a ralue approximately equal to 105 v 2C."
An approved change was not obtained to terminate the dincharge test at 103.4 Volts. The " Review and Approval" section of the FT states, "The normal revicu process should be utilized to change procedures uhenever practicable; however, changes nay be cade with the approval of the PSC Shift Supervisor and one other person holding a Senior Operators License, provided that the intent of the original procedure or the basis of the Safet; Evaluation is not changed." The failure to follow prc:edures appears contrary to 10 CFR 50, Appendix B, Criterion V, and the TSAR, Section B.5 cf the licensee's approved QA plan whic'a states in part that, "The various aspects of plant operation will be defined and controlled by written procedures." The licensee has taken corrective cction. PSCO Engineering has evaluated the test results as acceptable and has forwarded to ? ORC the results of their review by ceso dated 5-21-75.
The ceno does recognize that the original test had been deviated frem, but recommends PORC concurren:e for the test deviation based on the acceptability of.the test results. IE:IV considers no further action is required en this item. The licensee's May 10, li7c, lettcr to DRL specifies that the new battery rec =, associated with the new instrument bu.<,
is sei..ie Class 1.
The inspector verFied that seitmic calculattens have been performed and ferwarded to the i
site by contractor letter SLF-1106 of 11ay 4,1976.
The c;*.:ulatiens were found by the inspector to coet the general scismic design criteria of Section 14.1.1.1 of the FSAR.
The inetall:tien and testing of the ncu =en-interruptnbic 120 VAC Eus is considered by IE:IV to be conplete. See DETAILS, paragraph 9.6 of this report with regard to changes to Technical Specifications and procedures resulting from this plant change.
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i (c) Para:rach 4 of Attachment 1 Associated ulch Place:astic
in all Areas of liinh-Cable Concentr: tion In the licens.:e's May 10, 1976 Ictter to DRL,Section VIII, co=nitter.ts have been nade with regard to can-holes 3,4,5,6, 7 and 8 nnd pull / transition boxes to the underground duce systes. A:tica on these itsas
is to be completed bcfore start of Stage 2 of the rise to power test progrr.m as vell as entrective action for i
all other areas of cable concentration.
l The ir_spector did verify that a pcuer cable derating study had been completed for the power cables in naa-
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holes which have had a limited application of flarecastic (May 10, 1976, contractor study, CLT-1057). The results
,
i of this study were found acceptable. The acceptability of the derating of instru=ent anr! control cables has also been cocpleted as discussed in the DETAILS, para-
,
'
graph 2.b.2. (:) of this report.
The addition af fire protection requirements for Hanho14s 3 and 4 to licensee's consit=ents in their i
t May 10,1976, '.etter to DRL resolves the previous unresolved iten (7605-02 Manhole Number 4).
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(f) Paracraph 5 of Atta:hrent 1 Associated with Tray Till The inspector verified that data for the eight tray sectiens 832,12T2,11B2, 55M2, R7, R48, and RS, which originally had exceeded the 100*. of useable tray fill criteria, had been forwarded to the architect engineer for review (::ntractor letter of April 27, 1;76). The architect-engi eer's review vas alte found by the inspector to have been forwarded to the site by letter dated May 3, 1976. The letter stated that the eight sections of :2ble tray had been reviewed in accordance with the ?SAR ::ay ill criteria and the architect-
,
'
engineer ::pa:ity criteria on which the tray fill is based. The letter concluded that the eight sections neet the criteria set forth above.
!
l The liccasee has been unable to provide docu entation of the tray divider novement/cxtension soverent which appears to have occurred in the above trayr sections.
The char.ges te trays containing d.sfely te mted cable =
without proper documentation appears contrary to
,
Adminir.trative Trocedure (ADM) 27, "Ad:Anistrative t
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V-13-Procedure fot !!a in t ena n c e /Repa i r /Po d i f i c a t ion /Te s t ing, Requested or Pecforced by Outside Persunnsl, Cantractora or Agencies." Section 4.1.1 of this procedure require; a "Reque.t for nodification or routine :aintenance and repair activitics shall be prep.ir2d on.i Uork isuthori::stion (UA) fore." The failure to follew p:o-cedures appearc contrary to 10 CFR 5'], Appenlix 3 Criterion V and the USAR Section 3.5 of the licen:,ee's approved QA plan. The licensee has taken car cctive action with re ;ard to thic iten.
All trays uith an r
available fill of 80'.' or creater vere physically t easured and documented per TCN 3237 on 4-20-76.
As discussed above, the 8 trays sections with greater than 100*. fill, based on original crgineering data, were revi:wed by the architect-engineering and found acceptabic. By a PSCO QA neco issued 4-19-76, engineering and plant persennel were advised that cabic traya are to be controlled as Class I in accordance with QAP-1400, ADM-18, and ADM 27.
IE:IV considers that the licenaee corrective action with respect to this item ir complete.
(7) Other Itecs nelatine to the livir kn of bactor I,1constne,
'
April 27, 1976, Let;cr_to,he Verif*ed hv IL:IV Prior to Startup.
(a) Cable Inspection The inspector verified that PSCO QA !'ecos were issued on 5-12-76 to PSCO Engineering and contractor personnel delineating that all inspections and records associated with the cable separation / segregation probles are to be forwarded to PSCO for records storage. PSCO QA had aircady obtained copies of all procedures utili::ed and the raw data is in process of being obtained.
IE:IV considers this itco closed.
(b) Color Code A.:dit Paragraph X.C.7 of the licensee's May 10, 1976 Ictter to D?l. has been revised to delete any reference to the TSAR, Question 7.4, with regard to the color code audit of cable.
IE:I'.' considers this item closed.
(c) 1:on-essential Sin:le Cabic Conduit Field data relating to the audit of non-essential single cabic conduit was verified as conplete by the inspector.
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i The fin 11 status of single cable conduit is as follows:
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280 Verified a2 being in conduit 29 0 vered by Field Chan;;e ::ctites 10 Auxiliary Flectric Econ Caly 10 T.rror in Original Count
IT.:1r considers this ites closed.
-
3.
Procedures for Degraded Conditions-
-
Based on the study of de;raded conditions perforced ':y the licensee's consultant, the inspector verifled that proceduras hrte been dev-lcped.
These procedures entitled, " Cooling with Degraded Plant Conditions" were recently reviewed as Revisicn 1, durin.; PO3C liS and issued on 5-27-76.
The procedures provide for 23 dif ferent degraded plant conditions. The licensee has allo.eed for the flexibility in operator sction for conditions which nay vary from those identified within l
the procedure.
Operator training sessions for degraded plant cenditions were verified I
during a previcus inspectica 50-267/76-05.
!
,
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_Srinnie Certification Durin; the procurenent of spare,* arts, the licensee hss identified apparen't nissing seisnic certifications including calcul:tians and/cr r
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test qualificatiens for sele:ted cenpanents. As e follevup, contracter l
furnished seisnic data has been reviewed by the licensee and a corres-ponding ccismic index has been established by the centractor. The i
seisnic index was conpared a;2 inst the current list of safety related
-
components 90-SR-6-1 and 5;-I1-6-2.
Additional missing seismic data
{
vas identified.
l l
l Examples of the t pe of sais it data found cissin;:
,
,
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Analysis of liclium Circulat: Flapper Valves.
l Analysis of Diesel Fire Pu=p Day Tank.
Analysis of Heliun Circulator Scaring tiater Accusulators.
I Seismic Test ?.ep::ts:
l Speed "cdules System *1 and 22.
e Pressure Differential Transnitters Systen 91 and 93.
1;uelcar Detectors.
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Items that have requir d actual plant nodif ient Oas ar.
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Service kater I! anger in the Diesel P.O..a.
~
Keplacement of 30 ner coid (eibrat ion '.-nsi_i/c) pre >sure nwitches.
Inatallation of aJJ:.tional restrainta for cir u;ator
.p ed riod u le s.
Modification of Synea 41 rest raints.
The licensee has stated that an unu;ual event repor: wC; Le
.u W.tted for this occurrence. Additionally, nelsnic data for interposing electrical conponents has been ideatified as being d.f.:ient.
Daring a meeting held May 24, 1976, it MRC 110adquarters ilth the licen -e, contractor, Of fice of In pect ic.n and 1:aforce=ent...rd the Diviaian of Reactor 1.icensing personnel, the licensee provided i schedule for the review of seismic Clasr. I desinn.ited systens.
it was the NRC position at this meet ing that the f ollowing things be accomplished:
1.
Seismic certifications ice to 1 e complete for all se, tens prior to startup with the ex:aption of interposing electrical companen:..
is to he con-2.
The study of interposin; electrical conponents pleted as outlined by t'ae licensee.
Two weeks to identify all interposing electrical coaponent;.
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b.
A month to six weeks to obtain seismic certif ication; where-available.
c.
Six nonths to obtain 100% seismic certification.
3.
The study should be complete at no case beycnd first refueling.
4.
Inconplete itens identified by the study are to be evaluated at 40% or bef ore phase '* of the power ascension program.
Due to instrucentation tha: has beca added to the safe nhutdown list as the result of the licensee's evaluation and a signment of cables as being essential, environmental qualificatiaa of this instrumentation has been iden:ified as deficient. In a June 3, 1976 licensee 1ctter (K. F. k'alker, PSCO to Bob C1srk, NRC), the licensee has cennit:ed to environmental qualification. The letter 40% power all renaining instrumentation to further states tha: at be environ entally qualified is to be reviewed with I & E and that a'.1 caviron ental rertification shall be in hand prior to resumin;;
c;rration following the first refueling.
.1
- As defined in the licensce'n Decenber 15, 1976 and May 10, 1976 letter to tbc ;ivision of Ecactor Licensing.
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11::1V has vertiled that the IIcensee's review of selanic l
Clans I systems for sci nte data has been coepicted and that corrective act ion has be.n completed with exception of seit.nic l
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certification for all interpo.sina electrical twnponents and l
environ -ntal qualification of all justrumentatlan necessary l
for nafe shutduwn.
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'his item is considered a> unresolved, i
5.
Fire _1rotection
The remaining incomplete stage 1 fire protection 1:ess identified in IE:!V Inspection I:eport 50-267/76-05 vere verified by the
,
inapector as being c o plete. The dispostion of these items is as follows:
.
A functional Test T-36 va's performed to determine range and identi[y any possible KF interaction with plant installed electronics. The test resultc were satisfactory and were reviewed during PORC 152. VA's 2917 and 2513, which covered the installation of asbestos cloth for ' cable jumpers, were verified as conplete by the inspector.
.
The duties of the roving fire watch have been recently assigned to the 0,uard force. The inspector verified that 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of forms 1 instruction had been provided the roving patrol on 4-30-76.
A fornal tour was also conducted by cognizant licensee engineering personnel ta familiarize the rovin; watch with their assigned duty sts: ions. Formal instructions were issued 2-25-76 (PORC 1453 IE:1V censidered all Stage 1 fire protection items cesplete.
6.
Cah_le Audit Followup (Previ: :s 1*nresolved Iten 7601-03)
The close out of corrective :: tion.ot noncor forming cable routing identified by IE:1V and :he licensee during the final audits of cable routing is as fs;1:vs:
Cabic 9266 was re auted by VA 3096.
Cable 6237 was.erified by the licensee as now being in tray
1941! vice 1917.
-
Cables 6562. 99;a, 25995, 5936, 7116, 40 1 iere identified by FIK 527 and corrective action taken in accordance with Tield Change Notices 3250, 3253, 3234 and Work Authorization 3027.
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The licensee has by letter dated May 12, 1976 to !*L, identified i
that they feel there is an approximate 17. uncertainty in routiago
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l as deternised by audits of cable routing. It is the licen;ee's position "that approxicate 1% uneartointy in circuit reuting, as
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deternined by our audits, is satisfactory s/ hen consid.3 red in light of the vark done and the connittents nada regarding dditional fire
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protection and the a? ernate cooling rethod installation."
i IE:1V action en this ites is considered co=plete.
'
Previously tinresolved Item Relatinq to C2ble Separstion/Se3:> ration
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(7510-1)
-
a Electriesl Systes Phannes Relatint to 10 CFR 59.59 (IR 75-10, i'
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'76-01, and 76-05).
.
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Tha licensee stated that a change to the Final Safety Analysis
!
report is to be submitted to documenc final electrical systes
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changes. Specific c:difications vill be reported in the Semi-I Annual Report.
,
This itco is considered resolved.
I b.
Connietion of Field Inseection h
j (1) Evaluation of Field Data (IR 75-10, 76-01 and 76-05)
,
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The licensee has by letter dated "ay 12, 1976, informed the Division of Reactor Licensing that the cable separation /
-
i segregation corret:ive work has nov heen finished and that
the electrical installation at Fort St. Vrain is nou j
essentially in ccepliance with the criteria for this facility.
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This item is considered resolved.
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(2) Service Error (IR 7.4-10 and 76-05)
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Tabic V-1 of the 11:ensee's Fay 10, 1976 letter to DRL contains a cable tabulation for control cables which, l
based on Issue B of the cable tabulation dated April 21,
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i 1976, are routed in control / power tray / risers at any pointa.
This ites is cor. -..ed resolved.
j 8.
P:tvieusly Unresolved Item Pelating System 91 "Hvdraulic" (7601-04)
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Tha licensee has submitted a letter dated !!ay 10, 1976, to the
Livtsien of Reactor Licensing (DRL) describing the actions being
.
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taken to reduce the ha:arda ci lire associated with the hydrauli i
i syntsn. IE:1V util (o1:09 up on the licensce's corrietive 3cti:n
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during; a subsequent insaection.
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Q:her It em _to 1_e V.7r f f_i,':d-bv Til' Priar to Resutat icn of _ :' r ?.i n J
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Punch 1. int (IR 76-01 r.nd 76 'th)
The licensee's punch litt of itens for tha star: ef Sta3e 1
,
I (rise to power testing p.onr.tn) * an varified by the inspector
to be ccrplcte with exception of final SRC':::iens :ethorizing the resunption of the rise to power testing ?r:;r:3.
l-IC:IV considers the licensee's required a::ians co plate.
-
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Fire Stops
j The repair of fire steps identified by QADR 133 was verifice by j
the inspector to have been closed cut on C-10-76, based on the i
coepletion of the deficiencies identified in~ rIR S71A (compiv:21 on 6-8-76).
,
'
rollowing the licensee's rc"few of fire c: p repair and tne
,
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review of risers including the G vall site of the tur' sine building, additional fire steps have been installed. Tire stops were installed in riters 16, 17 and 15 in a:curdance
,
with TCn 3280/2.\\ 3030, sad in risers 191, I'.uA, 23, 30, 31,
32, 33, 35, and 36 in e::erdan:e with FC:: 3203/WA?099. Cable
i tray drawings were rerieved by the in:pacter ;i:h the licensee
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for the adequacy of fire stop installation as delineated in l
the FSAR Question 7-A and Appendin C, Des.gn Criterion 3.
The
t inspector identifica n: further questionab.e areas.
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l The conpletion of re;at:A to cnistine firest:ps and the
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installation of the mili:icnal fire 3::ps idan:li::d steve I
is considered by IE !V :s resolve this item.
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c.
Revision of Plant ?rocedures
4 i
IC:IV's final : rieu of plant procedures (Standard Op.trating i
and Surveill:::e ?rocedures) associated with systen nodificatiens and Tc:hni:a Specifications (TE) changes is pendian :.ssuance of
'
tl.c licensee's prsently subnitted proposed TS chani;es by the I
i Divisfen of Reactor Licensing.
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Sequences Icad changes resultinr. fron reassigneert of :he 450
j vital switch rar loads scre reviewed by the inspector and
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found to have :een included in plant procedures 50p ).' - O '.
140/3-11-76) an.1 S!; 5.6.1.h.5\\ (PORC 15d/1-il-7i).
II.- I V w i l l follos up the necew ery revislun of plant prece.iur u c ar.nensur':Le with the Isr.uance of t he cutstandin; propcsed TS cha i t.o.
Ins licensee has 9.t ated t hat their Q\\ Organizatisn will scrity
'
that all neceasar y proccd ares are ir place prior t o reactor startup.
d.
!!ousekeep_ing A final inspection of the cable t rays for cleanlines rnd general housekeeping will be nade by IE:1V cocaensurr.te with plant startup.
i-i e.
Deu Point 'loisture Monitor The inspe ctor verified that ilerk Authorizations CIA'e.) 1612 and 2753 have been completed. These UA's cocplete the n cessary nodificatiens to the p: nt protect ion sy4 ten partion of tite Dew point Moisture Monitors, relatin;; to the changes incorporated into the presently praposed technical specificatico chan;;es
! i 1.C0 4.2.11 end
'.5.1.
T'ie inspector alr.o verified that plant
,
Chany.e ut ice (r:0 160 :.ad been codpleted. Thin C:1 cenpletee.
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the necessary install;. tion of the analytical irC.Z O'.s associat.ed
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with the above proposed technical speelficatioa channes.
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This iten is con;idered clos =d.
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_TIp's/FDR's
.
Outstanding' FIR /FDit's involving restraints to the rie:e to power were incorporated into the licensea's pun:'a list. The ita..s have been verified as conplete
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licensee's punch list
'
.
(DETAILS, paragraph 9.a of this report).
g.
PTP. Filer, All Plant Troubla ?..' port (PU's) hwe been incorporated into a cenputer progrca to assis,t in nain:aining a st.tus of out-standing it ems.
I t was the licensce'r. posit ion t hat no PfR will be out n:ri.n; that could prever.t conforr.ance t o Technical Specification 1.1:itina Conditions for Operatic.ns at the tine o
et reactor startep.
It':lV will continue to audit the status of the PfR files as a part of the routine IC innpect ion of operations.
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Dier.el Drivan Pur.ns for IACM
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The inspector teviewed tha procurecent, installation, :estia:,
and catablishuent of procedures for operation ef the Diesel l'
Driven Pumpa for t..e I ACM.
The installation of the Dies $1 l.
Driven Puups are required by the pending Techni:a1 Specifica:!on (TS) chan;es to 100 4.2.16 and sit 5.2.19.
These TS chan;es are to be icsued concurrently with the D3L le::ar authorizing plant startup for Stepe 1.
The two punps wer? procured to
-
Perp Specification D'.
for Interin Alternate Coo ~ ing Method
.
Hori:ontal Centrificsl Purps, Revision 2 (11-;~~75).
The pumps ucre specified to provide a ficv of crea:er than 1600 gym
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at 16.l' NPSH as referenced in the rFAR, Section 9.7.3.1 and the licenace's January 19, 1976 letter to DRL.
A supplicr's evaluatica was perforced by the licensee's centractor en
,
11-14-75.
The vendor's in place QC progran was focnd to be
'
based en MIL-1-45208A an3 considered adequate by the licensee based on the short procurenent natice given the vender. The capacity for both pumps were uitne. sed by the licensee';
contractor and found ra be greater than 1600 spn (Contractor Trip Report, 12-11-75).
The inspector verified that receipt inspection was perforced as directed by PCCO ):* ter of 1-7-76 to the centractor. Re elpt Inspection includfd:
PCR-200-C17309/ Diesel Pumps P0n-202-C17379/300 Callon Day Tank POR-200-C17309/2 Sets of Dierel ruel Piping and 2 Unter Jacket !! eat ers
'
POR-20-415/1 Rotary Hand Punp POR-20-377/1 Tank Trailer 6030 Gallon
.
The following Field Chan;e Notices (FCN's) aad Work Authorizaticas
.
(UA's) are assigned to icaplete installation of the IACM, in-cluding the two Diesel Cooling Water Pucps:
FCN 542 (Building',.;A2631 FC:: 3034 Rev. C (?!actrical Enercancy Lighting) UA2753 FLN 3272A (U.u:trical Am Built)
FCN 3039 (Switcles)
FCN 3316 (0 :unents:fon)
p, FCN 3030 (?ever IAC'.! Lighting / Stack Manitoring)
FCN 3?51A 7.sv. B (MCC to IACM) UA3018
,
FCN 3331 (Misec11aneous Instru=entation) UA2983
'
FCN 3351 (Frescure Controller As Built)
.
FCS 3103 (Machinical Components) I'32070 y
FCN 3117 (Electrical /Pneunitic Controls) RA2968 FCN 3118 (::cchanical AAVC) UA2960 If
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Final completed status of the above identifleo TC4's/;JA'n
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Tne following Tunctional Tests (ET's) have been verified as
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ccupleted by the, inspector:
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i FT IAO! Diescl Cooling Water Pumps
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FT IAC! Air Compressor j
FT E-1 IAO! Building Electric:.1 Systen
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FT E-4 Fire Water Flow Alarn
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TT's E-2 IAct Electrical Equipment Fron IAct Cenerator and j
E-3 IAoi Equipment Normal Power were verified as completc with exception of building 11ghting circuits. The plant
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procedure for operation of the IAO! (50P-48) was reviewed
j during PORC No. 151 cnd issued 5-14-76.
Section 2.14 of
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f this procedure usa reviewed by the insphetor and found
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j adequato. This section detatin operation of the Diesel
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Coo?.ing Water Pumps F-4301 and P-4802.
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IC:IV has no inco=plete items as reistes to the IAO! Diesel Cooling Unter Pumps; he.ever, the final co pletion of the l, ' -(;,-
11.01 system will require additional inspectica followup prior
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to Stage. 2 operation.
'Ihc inspector did identify one apparent itcs of noncompliance i
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with regard to veld rod control. The inspector found an open
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can of 7018 veld rod in a velder work box in the IACI Euilding.
Unused 7018 weld rod was also lef t outside the I'.Ct Beildina
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'T on a fit up tsble. The inspe ctor was informed that tha weld j
J; rod was not being used by any velder on shife. Tie cor. tractor's j
1-26-76 approvei procedure, "Approvsl of Procurc=ent an.1 Control j
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of Welding Material Procedure for Fort St. Vrain Nucicat l
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Cenerating Station," Section 6.4, stated in part. "Only enough covered electrode vill te renoved from the rod ovens to ecver
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t a naximum time of four h:urs., The unused covered electrode
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will be returned :f ter f:ur hours to the Warebcase Attendant
,
j to be riacce in a segnga:cd section of the oven for a mini =us of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> befor-reissue." The f ailure to follow procedure j
is contrary to 10 CFR 50. Appendix B Criterion V, and the n
31censee's approved QA Pisn for Operation, Section B.5.
The J
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folloving correcrive action has been taken by the IIcensee
in ren anse ta the inspector's finding. A Quality Assur1nce Deff d m y P.cpert No. 171 was issued to the contractor. '1he in:pect:r did subsequently verify that corrective act'.o:i was O
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being taken and that unused weld rod was being controlled.
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Enarnency Power 1.ead Secuencin;
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l The inspector verifftd that Field Chang 2 t'otice (TC3) 3210/
Uork Authori:atien (UA) 2374, FCN 3192/CU? 103, and TC; 3153:*
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CNP 111 nssociated with the Energency Pouer load Seque1cin; a
have bien conpleted.
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Verification of system pa*formance in to be condu::Jd daring survellisnet testing prior to the resunpticn of rea:tcr : tart tp.
IE:1V vill follow up on this item cor..ensurate v?.ta
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reactor stcrtup.
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10.
ASC3 Solenoid Valves i
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't As discussed in Inspection Report 50-267/76-05, the inspector found that the ASCO Solenoid Valves had becu nodified including the chnage
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of the seat natorial fron sofc to hard seats. This work had been c.
done under a Plant Trouble Report (PTP.)11-139 and not as a codificaticn covered by a Change Notice. During tb!a inepec:icn, the inspector had diccasaed with the liccnsee's QA personnel the rational fo. not processing the change of naterial as a nodification, subject to a fornal Change Notice. ine inspector uas inforced that a Qe.elity
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Assurance Deficicacy Report (QADR) 154 had alreafv baen issued whi:h i
id:ntified the apparenc failure to initinte a fo::a1 Change Notice
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in necordance with Quality /.ssurarce Proceduro QAP IL30 Section 2.0,
and Internal Work Procedure INP-2 (issued in tenporary for= as a PSCO March 10, 1976, QA Meno). There was some internal P3C0 discussion regarding tha basis for this chan;,e being classified as a nodificacien.
IU:IV's position was that a change of natorial in the valve.could 5:
appear to constitute a codification, i.e. the ca:erial ch:nge vould f
require evaluatien for' its specific application and cuviren=en:.
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This item d.s considered unresolved.
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11.
D3 sign Control a.
Ob_icetive l
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To verify that desi;n chan;es and codifications :re in con-
formance w' h the requirceents of the Technical Specifications and 10 CTR 53.53
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Arcas Retieve3 (1) The follocing design changes vere selecttd-for review:
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Field Char;s Notica/
Change Notico Title d
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CN 34 Inatrument Air C::presuar
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CN 57 Station 3attery Tes: Ap? ara:us j
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l,3 CN 5B Systen 41 31cvd:.m *.ine j
f CN 59 Service 'Ja:er !!airup Va' Jes j
FCN 2670 Buffer Recir. Oiacharge Chack Valves i
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FCN 2691 Eackup Eearing *Ja:er accunulators y
FCN 2774 Dev Point 3'oisture "onitors TCN 2774 Contral and Crifice Assesbly a
lj 'g (2) The aSove. design nodifications were reviewed to verify that:
,
I y(p (a) The changes were rude in accordance with 10 CFR 50.59; I
(b) Apptcpriate raview and approval procedures were follov+d;
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(c) Formal precedures were used which specified appropriate
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specificaticas, codes, inspections and acccptanco testa; (d) Acceptan e testing results indicated performance con-
forming to Tc hnical Specifications.
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i (3) Operating proceduras were selected to determine if the nodifications in (1) above vere reflected in appropriate
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j procedural changes.
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(4) Eight Piping and Instrunentation drawings were reviewed
to verify that they had been nodified to reflect system
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codifications.
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Findings (1) Ulthin the secpe of this inspection eff:rt, several items
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E of nonconplien:e vi h 10 CTR 50, Appendix L. Criterion V,
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were'identificd. This criterion requires in part that
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'e activitics affecting quality shall be governed by instructions, J
procedures er drawings and shall be accouplished in accordance
with these d::unents. This criterien is further noplified l
by the li:ensee's approved QA Plan, Final Safety Analysis,
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Se:: ion 3.5(c) which states in part that various aspects
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of plin: operation vili be defined and controlled by
written procedures.
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Contrary to the above requirenents, the following quality
related activities were not conducted in accordance with i:
the licensce's approved procedures.
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(a) During-the review of Change Notice 59 which providad
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for the repin:crent of nakeup centrol valves in the Service L'ater Systc=, the inspector noted that the ji
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Plan: Operations T.eview Con =ittee (PCRC) approved I
i installation procedure had been altered by a reso
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change chac was initiated by the desi;n engine 2r.
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This cene change cade a substantive altera:i:n to ':he
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installation procedure by deleting a s:ep callin:: for
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j the renoval of the orifice plate downstren: of FE 1210-2.
j This ce=o change had not been approved by the ? ORC.
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Administrative Procedure 18 requires that FCRC reviev j
and approve codifications to the plant. The failure of PORC to review the above nodification change is
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cor.crary to the requirements stated in C.(1) above.
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This concompliance with ADM 18 was brought to the j
attention of :he licensee and a PORC review of the
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neco change was conducted during the course of this i
inspection. This review satisfies the i==edia:e
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b corrective action for this iten of noncoepliance.
Several weeks prior to the Inspection :he licensee
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JI had instice:sd a Deviation Request procedure which
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provides the reans of naking temporary changes to field change notice or channe notice installation i
procedures when in-field difficulties are encountered
and provides for a PORC ree'.<w and approval of these
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tempor ry changes. A lie asee representative stated
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that this r.e:hanis= is sufficient to ensure that
I further rosne::pliance in this area vill be avoided.
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Based on the above actions the inspector had n) further i
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questions en :his iten. No additional response is required fc: this ites of nonco:pliance.
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that the modifi::tica procedure did not include a i
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post ::. fica:1:n checkout of the modified co=ponents alth: 3?. these changes were ce:plete.
QAP 1'00. Quality Assurance Plan Modification of~
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Uc: lear _ Class I 5ystens and Strdeieres Section 6.1
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re uires in part that. "nodific=tten Preecevres sh-)1 contain appropriate and detalicd QA requirc ents an.'
checklists for all phases of the work including, where
applicable:.. (h) Post nodification check out.... "
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The failure to provide a post nodification checkaut on th: systers codified by the indicated changt notice-is contrary to the requirceent in c. (1),
that quality related activities shall be conducted in accordance viti approved procedures.
(c) During the review of Change Notices 31, 57, 53 and 59, the inspector noted that the :: pleted thange ;2ckages,
had not been reviewed by the PSC engineerin,c group
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to icrify that the acceptance test results were ir
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cecordance with the desir,n requircrents for the sy.cen.
The licensee's procedute ENC-1 requires in part that the Engineering Project Coordinator reviev the co:pleted test results to determine their acceptability in relation to the design requirccents.
The failure to review the above corpicted change
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packages to the above change notices is contcary to
requirc ents in c.(1) that quality related activitics shall be conducted in accordance with approved procedures.
This type of nonco:pliance was also noted by the 1!censee in his internal audit progras on Quality
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Assurance Audit 1402 dated April 22, 1976, in which he identified a s1=ilar failure on several additional change notices.
Based on the above, the inspector had no further questions on this ites. No additional response vill be required f ar this itca of noncompliance. The licensee's c:rrective action for this itcs vill be revicued duri:; a subsequent inspection.
(d) Durinh the review of the completed change package for Change Noti:e 59, the inspector noted that this codific:tien had been ce=pleted without the use of an a;;r:ted es. trolled work procedure.
The li:!:see's Quality Assurance !!anual, Section 6.4.(e)
.quiras in part that nodifications shall be accorplished subja:t to the following "...(3) Using approved protsdurcs, the appropriate departcent of TSCO vill provide f or cenpletion of the work by qualified individuals or subcontractors.
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The failure to use an appre cd controlled work procedure to accomplish the nodification described in Change Notice 59 is in noncoepliance with the requirement
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-2e in c.(1) that q'sality rrlated activities chall be t
ccnducted in accordance with approved procedures.
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The licenser had identified this item in his own
internal aut.it prov, ras at doct::ented *:,' Q.Un 173 (Quality Asturance Deficiency keport).
Based on the alove probics identifica: ion by the licensee, no additional response ta this iten vill be required and the licensee' + actions to c:rrect
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the identified deficiwney vill be reviewed at a subsequent inspectinn.
(c) During. the revicu of the licensee's procefursa for controlling nodification vork, the inspeccar noted tha the licensee's Qaality Assurance !!a.ual Section 6.7.3
states in part, "An Interdepart ental b*ork Procedure'
shall be prepared to prescriba in detail the nethods and control reasures to be ap lied to control of desQn and design : edifications." Further, this sectie, identifies the procc.ure by stating, "This Procedure (I'-7-2) shall include.
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T!.e inspector asked to exanine this procedure and was told that it had not been issued yet.
In the interin, r,uidance docu=ent was in use to specify the control c.casures to te applied to contral of dasign, and design todifications. The failure to provide the specified IL*P-2 procedurc is in nonconplisuce vith the require-cent in c.(1), that quslity related activities shall be conducted in accordance with approved procedures.
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(D The inspector exa:ined eight Piping end Instru:entation Drawings to d#ter..e if the applicable drawings had been updated to refice design todifications.
10 CFP. 50, A' pendi:: 3. Criterien VI requires that, ":casures
shall be est nlis.ed to control the issue,ee of d cuments
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such as..
drawin g and changes thereto.
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is further a:plifi:d by the licensee's approved QA Plan, Final 5sfety Analysis, Section B.5.5 which states in part,
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"k'here.e:enary, because of desir,n evJifications..
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neccasary revisions vill be made to the 'As-Euilt' drawings
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and s;e:ifications to incorporate the new requirements."
Centrary to the above requirements. the following s'iping and Instru.entation drawings did not reficct the indicated design codificatiens either by a change or by a sta: ped entry on the drawing that such a change had been issued
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I which affected the systen:
D.r.,_v i.n a Chan'ac 1:otice
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CN 30 l
pi S2-1 pI 41 1 CN 53 The inspector crialued the applicable C
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(3)
to r2fiecr to det : rnine if procedural th..nges had h un I.,ued Of the C -ht desijn chanJcs tue system design nodification.
f;ve ure e' such reviewed during this inspection cifort.
/e 'cen necessary.
a nature that procedural char. gas vauld no:..
a The in.;pector exantaed the procedures asseri ned with tae One desi.:n chaa.:e had been remainin.; three design enanges.
conpleted only two weeks earlier and a change to the pra-cedure was in the process of being draf ted.
The System Operating procedures for the Backup Learin,"
1:ater Systen and Service k,ter Systens were exanined, and although these procedures were affected by FCN 2691 and issued.
CN SS respectively, no procedural revisions were yet the Lack.p FCN 2691 added N;trogen charged accumu'.. tars ta however, the Systen Operating Prccedare Scaring L'ater Systen; it is to be r:;,tnined na mentian of thin additon er how CN SS added a 6 inch crosstie line to the operated.
rervice cater systen including a cross tie isolatica valve.
The systen oierating procedure contcined no instructions t
fot operatint: this crosstic line nor did the valve list in this procedure reflect the additional valve. The in-spector dIucussed this iton with a licensee representative who stated that these procedures would be reviewed and It was further indicated to the revised as necessar,:.
inspector that the procedures for handling dc3ign change packages vould b" altered so that the operating group responcible f:r issuing precedures cnd prreedare chan3:es veuld be in:1. icd in the routing of design nodificacian packages to ensure that procedure changes k.iuld be instituted when required.
vill rc=ain unresolved pending review of the This it(=
licer.sce's actions on this matter.
12.
S_S.i_n t e na n c e Thier:fyc s.
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To accertain whether naintcnance activities on safety relar.d systv=s and conpanents were conducted in accordance with Il
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-20-approved procedures, regulatory guir s and indutry code.s and stand:ards aad in confornance with Technical ::pecification r.:pire-r..e n t s.
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Areas lieviewed
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(1) The in spec tor revj ewed th. f ollewin, :: air.:.nar.0 2 a :1 t::1.*s:
Plant Trou' ale Report /
Uork Autharization Titic
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PTR 3-53 (1976)
Cireulator 1:,w s.;eed Trip I oraper PTR 2-231 (1975)
N.I. Channel O n:Ise spiles pin 1-293 (1976)
CRD purge lines blocked
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PTk 1-110 (1976)
Diesel generator clutch.;olenoid l
valve leaking PTR 2-150 (1976)
Moisture nanitar heater alars
!!A 2161/i?A1974 Chanp.eout of
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circulator UA 2121 P.epair leak en valve SV2105 PTR 1-137 (1976)
N9 2 3 5-l ' P. ' instrument power inverter trip PIR 9-223 (1975)
CRD #25 - control orifice operator Selleville vasher inproper.stackup
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PfR S-250 (1975)
!:rserve sh.:down syste:2 alarn nalfunction P f t: 1-271 (1976)
FT21428 failure UA 246S Replace PDI l'258 i
PTR 3-13 (1976)
Speed switch r.odule 1105-11 an:1 1106-12 rea.lin; lot.w cale
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(2) The inspector reviawed the following cc:2pleted controlla.i work procedures (Ci?):
CUT Nunber Titic CUP 49 Inspect Hn and re71ar :.cnt of pict on, pistoa rings, cy1!; der liners in-diesel engine 9205X CUP 69 Inst,ection and reinstallation of orifice valve control shaf t nut and Belleville washers Cr.D #20 '
Ci? 76 Replace 't" SS. valve V211193
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C'.i? 7 7 Safety valve seat repair V-46535 i
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(3) During the review af the r:alntenance.ictivities (2) al.ove, the inapector veritied 'that:
The Technical specif icat ion I.Initing Cen.* i:irn '. r Ope: d an,
. s ea; of e..
vi;e.
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if applicable, was cet chile the componen:
admi.i-nalatenance vas emducted i:nder the :sppreur.at Th(-
st rat ive approv 11s.
Approved procedures were used.
The r.aintenance was inspected in accordance with the I f eensee's requirements.
Functional test in; was perforced upon re:urnin.; the component to s.f rvice.
reviewed the qualificarians of two techanical The inspector (4)
nalntenance pers.'anel, one instrusen:ation technician and were in one electrician to inaure that their quali Ication4
.
confor:ance with,'d.SI ?;l8.1.
the reiinten inee The Quality Contra *. recorda to r.upport (5)
perforced for PTR 1-137 I'TR 9-p33 and ?T2 2-6s were em.nined to determine t!.): : hey were being :.iintaiaed la c.ceordance with the licen.see's instructions.
The circunstances surrounding the cair.:en.nce p. rformed (6)
f or PTi!'3-13. P!n 1-137, IT!? l-110 and ?In ')-233 were exa ained to deter:.ine if these events v. re reportable occurrences as de~1ned in the Technice. Specifications.
c.
Findinn
.;erel ite:n (1) Ulthin the scope ef this inspection effart.
of nonco: plianze vi:h 10 Cra 5d, App-ndin.. Criterica V is crit erion requires in part that vere identified.
a activitics affectin; quality r.hal) !.e governed by instruct ions, dravi..;,s and shall be accomp: Nhed in accordance procedures o:
This criter'::.. is further anplified with those d:.unents.
by the li:(.2ce's approved QA Plan, final Safety Analysin.
Section E.5.(c) which states in part th,t various aspecta of pl:n: operation will be. deft..cd and controlled 1y written
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procedures.
Contrary to the.above requirementn, the follo.lun act ivit:cu affecting quality were not conductcd in accordanec with
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approved licensee procedures:
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The inspector reviewed I'TR 2-201 of 1975 ahich descriSed (a)
ns Le spikes in nuclear instrucentatica Channel I concurrent with the operation of valve liv 2159-1.
The operatir.g* switch f or this valve is on the sa:e par.el as the nuclear instrumentation readout deviq#.
The S1 naise spikes were evaluated to be caused by relay noise from the uperation of valve ??2123 '. Sc.th
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ll?21S9-1 cad its operating switch are inclu :-d in the licensee's safety reisted itcas $.isting.
?!R 2-231 indicates in the " Nature of Repair" section : hat
" Electricians have installed are suporessers to help
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alleviate this problem." Th r.1 inspe::or was inforced that these arc suppressors were diodes installed
.
across the relay to eliminate the generated noise.
Administrative Procedure (ADM) 27, Section 3.6
!cfines modification as follows:
"Any change or addition such that the original design or operational. Intent is altered to un extent that the original process, function or logic is altered or sys:cs piping, circuitry, equip =ent, co ponents, structurcs er natorials are changed such as to requ',rc design of new selsale hangers, cable routing, selssic
re-evaluation, separation re-evaluation or new analyses of design, failure, or safety."
The licensee *3 Quality Assurance instruction QAl-3 contains a -inilar definition. The addition of diodes to the cperating circuit for the safety related valve
!!V 2159-1 creates an additional potential f ailure node not considered in the originsi desi;n and thus should be treated as a codification.
Administratite Procedure IB rcquires in part that all proposed d.;.;ations be approved by the Superintendent of Oper::ians ard reviewed and approved by the PORC.
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The ins::llation of arc suppressors in the circuit for valve F.7 2189-1 under PTR 2-341 which was acco=plished vi:h:2: the required safety analysis ar.d PORC revicu ar.d approval is in nonco=pliance with require =ent of (c)(1) above, that all quality related activities shall be conducted in accordance with approved procedurer..
r (b) Purian review of t,hc taintenance setivitics indicated in Section b.(1) above, the inspector noted that on i
PIR 1-137, PTR 2-63 and PTR 3-13, the Maintenance
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and Supervisors entries ware varioucly " Trouble 3 boot
correc* problen" for the forner and "Per ADM-12" t or
the latter two PTR's.
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Adsinistrative' Procedure (ADM) 12, which r.overns thi l
perf 0rnance of naintenance under the P.R systeo states
in part in section 4.3.1:
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" Procedures.
.shall be u;ed for work on equipment
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.un css no proce ure-de;1gnated as safety-relaced.
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is required, in which case the PTR or b'ork Request shall be so rarked."
,
ADM 12, Section 2.5 defines naintenance procedures j
as " Written instructions which define nair.tenance
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activities and prescribe the nethods, materials, j
specisi trade qualifications (if any), manuals and
pro: esses to be used, required Inspections and post
naintenance calibration and testing."
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The failure to provide a proper naintenance procedure
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or to clearly indicate that na procedure is required it j
is in nor.co:plisace with the require:ents in c.(1)
above, that all quality related activitics shall be conducted in accordance with approved procedures.
j (c) The inspector revicued PTR 9-223 which proscribed the dissatsetbly :nd reassecbly of Control Rod Dcive (25 j !
to correct ar. ir. proper stacking of Sci:.eville washers q*
on the control orifice operating shaft. PTR 9-223 j
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spceified that this naintenance activity wa.4 to bc ll con? cted per Maintenance Procedura 12-6.
This pro-I cedute references the General Atomic Minual 9S06, a
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detailed C23 dissasseably and reassehbly procedure and prmtides tha ceans of documenting the completion j
of each ste; in the dissassembly and reassembly of
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i On review of the completed MP 12-6 for this activity, r
the ir,spector r.oted that the portion of the procedure for dissassenbly of tb2 control arifice asscobly was
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nat ased, whereas the corresponding assedbly portion vss properly used.
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The failure rn perInrn tha dise,ssombly of CRn #75 per the spproved naintenance procedure MP 12-6 Ir. in non-
compliance with the requirements in c.(1) above, that q
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quality related activitics shall be conducted in
acentdance with approved procedures.
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(2) Doric;t the review sf ro;atei.auf.e rictivitiaa pecitie! In
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j support of s i.e ralutenance un t h. C'D par,. lira., p-t '; r.r :i un ler PTi' i-293..i;y the ei.J uf the inopce ir.
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(3) The Ir t.p. e t or :iat ed t hat ne :@ sa rent. :une:i n2 r.te:in; c:ts p. rf ururd on t he noisturu ranitor i.e..:e- :.n:r:1:er
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l f..llawing its repair und.er Pi*. 2-lM.
A hhe;fa there 13
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a surveill..nce tes to cover the funeth :f. en chu: cf this device it wa:, not used to verif y ::,nrenen'. re-pon3e follorIng r.Intenan:c. The in,pectar di cussed this it ta
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with a IIccu,ee rs pcer.entativa. This it.n.111 re-aia
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unresulved pending a review of-the licen.ee'c actions en
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j (4) 11 urin;; a review of th licen.See's precadure; to central j
work by out side c..ntractors and suocon:ractors, the in-l spector discovered that a systeni of co'.c checkou; tcst procedures and func: f onal test 1.raeciarn had been de-veloped. These prac2dures were spet.iii: ally f or the un
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I of the PSCO r:sintenance org.anizatiens.nd f or the ;mrpo,s l
of perforning pas: r.aintenance in;pectiun ar.d checkosts.
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The cold thecioot tests conaist.ed of such i:cas as verifi-
l catlun of systes wirlag and verification of proper valve I
strokin;; f 011ovir., valve work. runctienal tes: procedure.
have been specifi6. ally deseloped to cavek out spacific
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conponents followin.: the reroute of centrol and/or power j
cablin;;. t!ovever, the inspecter noted that these tests l
vere r,cnerally no: specified in the nintenance procedures I
nor were called cat on the PTR's for n-intenance a:civities
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perforned solely b; the PSCO organi:ati:n.
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The inspector a::ed that it was difficult to deternine hether or no
.n.'.ppropriate f unctidnal t e.t h.ed been
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j perforced foll: win a ;;iven aintenance act tvity. The inspector pois:cd c.t: that the ccid cheeko :- test procedurea
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co ild easily be u.ted f or this purpose. Ada. lonally, the i
need to care specifically define the oppropriate level of
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post n.aitten nce testing even for those norc basic rntnten-ance activi:ics contro11cd by a PTR for which it is detet-i
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l cined that no procedure is rcquired was pointed out to
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The inspector indleated that much of the post r2aintenance
l functional tentin:: on safety related systene vauld bc
.dequately satisfied by the perforr.anec of the appropriata
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t.urveillance test.
Additionally, the in,pector painted out that the pin as a uaintenance cont rcl :!xurent wa not fornatted to ensure that all required procedur
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- ns'e::ioaa cnd functional te; tin;s was specified.
A li:ensea represen-tative statcd that this area would be r;v!<.ed for pessible changes. Post naIntenance f unctional t est f : c,.till r( naln an open iten to be revtewed during a subsecuent i:: ape c tion.
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(5) The inspector had no questions in the area of r.aintenance personnel qualifications.
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(6) During review of the events surrounding ssf6 y related raintenance, the inspector had no questions. He noted that the type of failure corrected under PIR 9-223 was reported in Licensee Event Report UE 75-17.
The inspector noted the failure of a circulator speed sensing network
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repaired under PTR 3-13, although not required to be reported as the plant is in a nonoperational stato, is of such a nature as requiriag a Licens2e Event Report-when the y,uidance of Regulatory Guide 1.16 is incorporated in 0 the T.'t.hnical Specifications.
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