IR 05000267/1984013

IE Insp Rept 50-267/84-13 on 840401-30.No Violations or Deviations Noted.Major Areas Inspected:Operational Safety verification,surveillance-refueling/maint,startup from Refueling & Startup testing-refueling

ML20197H146
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/17/1984
From:	Ireland R, Plumlee G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20197H124	List: IR 05000267/1984013 ML20197H122
References
50-267-84-13, IEB-83-08, IEB-83-8, NUDOCS 8406180349
Download: ML20197H146 (11)

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APPENDIX U. S. NUCLEAR REGULATORY C0?tilSSION  :

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REGI0ll IV

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NRC Inspection Report: 50-267/84-13 License: DPR-34 Docket: 50-267 Licensee: Public Service Company of Colorado (PSC) P. O. Box 840 - Denver, Colorado 80201 ,

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Facility Name: Fort St. Vrain Nuclear Generating Station Inspection at: Fort St. Vrain (FSV) Site, Platteville, Colorado-Inspection Conducted: April 1-30,1984 Inspectdr: h G. L. Pluinlee III, Senior Resident Inspector (SRI) 8-/b 4 Date Approved: [[ Me R. E. Ireland, Acting Chief 5-/ Date 7 N/ Special Projects & Engineering Section Inspection Summary Inspection Conducted April 1-30, 1984 (Report: 50-267/84-13) Areas Inspected: Routine / Reactive, announced inspection of Licensee Action on Previous Inspection Findings; Operational Safety Verification; Surveillance; Surveillance-Refueling / Maintenance; Plant Startup From Refueling; Startup Testing-Refueling; Review of Periodic and Special Reports; and IE Bulletin Follow U The inspection involved 79 routine inspector-hours and 14 reactive inspector-hours onsite by one NRC inspecto Results: Within the eight areas inspected, no violations or deviations were identified. Five open items were identified (LC0 discrepancy, paragraph 3; MQC training program documentation, paragraph Sa; safety-related work identification, paragraph Sb; inadequate maintenance procedure, paragraph Sb; and OPOP deficiencies, paragraph 6.) ' o!oo$k7 PDR __ _ _ _

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._ A-2-DETAILS Persons Contacted Principle Licensee Employees
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L. Bishard, Maintenance Supervisor T. Borst, Radiation Protection Manager s

W. Craine, Superintendent of Maintenance R. Craun, Supervisor Nuclear Site Engineering M. Deniston, Shift Supervisor M. Ferris, QA Auditing Coordinator W. Franek, Superintendent Operations C. Fuller, Technical / Administrative Services Manager

\ *J. Gahm, QA Manager  '

J. Hak, Shift Supervisor

 *M. McBride, Operations Manager
 > J. McCauley, Results Engineering Supervisor
 *M. Niehoff, Site Engineering Manager
 *F. Novacheki Technical Services Engineering Supervisor
,c  H. O'Hagen, Shift Supervisor
-  T. Orlin, Superintendent QA Services J. Petera, Electrical Supervisor G. Redmond, MQC Supervisor -

G. Reigel, Shift Supervisor

 *L. Singleton, Superintendent Operations QA   l H.'Starner, Coordinator Nuclear Site Construction J. Van Dyke, Shift Supervisor Administration
 *D. Warembourg, Manager Nuclear Production R. Webb, Maintenance Supervisor S. Willford, Training Supervisor
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The SRI'also contacted other plant personnel including reactor operators, maintenance men, electricians, technicians, and administrative personne N ,

  * Denotes those attending the exit intervie . Licensee Tction on Previous Inspection Findings NRMCA Certificate Not Availabl (Closed)

The Violation licensee (50-267/8326-01): received a copy of the NRMCA certificate for the Mobile

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Premix Concrete. Company's Brighton p} ant on October 12, 198 (Closed) Unresolved Item (50-267/8331-01): Revision to OPOP's ( Refer to paragraph 6 of this repor ,

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      -3- Operational Safety Verification

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The SRI reviewed licensee activities to ascertain that the facility is l being operated safely and in conformance with reculatory requirements and that the licensee's managenent control system is effectively discharging its responsibilities for continued safe operatio The review was conducted by direct observation of activities, tours of-the facility, interviews and discussions with licensee personnel, i independent verification of safety system status and limiting conditions I for operations, and review of facility record l Logs and records reviewed included: I l

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 . Shift Supervisor Logs
 . Reactor Operator Logs
 . Equipment Operator Logs
 . . Auxiliary Operator Logs
 . Technical Specification Compliance Logs
 . Operations Order Book
 . Operations Deviations Reports
 . Clearance Log
 . Temporary Configuration Reports
 . Plant Trouble Reports L
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During tours of accessible areas, particular attention was directed to the following:

  . Monitoring Instrumentation
 . Radiation: Controls
 . Housekeeping
 . ' Fluid Leaks
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 . . Piping Vibrations
 . Hanger / Seismic Restraints
 . Clearance-Tags
 . Fire Hazards
 . Control Room Manning
 . Annunciators The procedure was reviewed and implementation observed for Radioactive Gaseous Effluent Release 1135. The release appeared to have been made in a satisfactory manne On April 13, 1984, during a review of the licensee's Technical Specifi-cations Compliance Log, the SRI determined that Limiting Condition for

, Operation (LCO) 4.2.2, " Operable Circulator," is a definition as written and should not be considered as a LCO. The licensee stated that this had not previously been considered in their current review of Technical

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Specification rewrite. The licensee agreed with the SRI and is planning to incorporate LC0 4.2.2 into the body of LC0 4.2.1, " Number of Operable-Circulators." This is considered an open item (8413-01) pending submittal and approval of the proposed revisio No violations or deviations were identifie . Surveillance'(Monthly) The SRI reviewed aspects of surveillance testing involving safety-related systems. The review included observation and review relative to Technical Specification requirements. The surveillance tests reviewed and observed were: ESR 8.1.lbc-M Radioactive Gaseous Effluent System Test (Release 1135) SR 5.6.lb-SA Loss of Outside_ Power and Turbine Trip Due to the. extensive amount of work'(upgrading / modifications) performed during this refueling-outage on the 480 V system, the licensee performed both the first test and second test sections of SR 5.6.lb-SA to verify that the _ standby, diesel generators (D/G) automatic controls and load sequences are operable. _The first test section consists of testing auto-matic' load sequencing'in accordance with Program A - Sequence A, " Loads for First Standby Generator in Service to Control Buses l'and 2," and Program B - Sequence B, " Loads for Second Standby Generator in Service to Control Bus 3," which is accomplished by blocking 1B D/G such that

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. lA D/G starts first. The second test section consists of load sequencing in accordance with Program B - Sequence A, " Loads for First Standby Generator in Service to Control Buses 3 and 2," and Program A - Sequence B,

 " Loads for Second Standby Generator in Service to Control Bus 1," which is accomplished by blocking 1A D/G such that 18 D/G starts first. While running the second test section on April 19, 1984, the 1A D/G breaker failed to close apparently due to two wires (black and blue) being terminated incorrectly during installation of the new Class IE protective relaying for the 480 V buses. This was corrected, and a successful retest was performed on April 21, 198 No violations or deviations were identifie . , ' Surveillance - Refueling / Maintenance - Monthly To ascertain whether functional testing of the more complex safety-
 : related systems and subsystems is in conformance with Regulatory requirements, the SRI followed activities performed in accordance with Surveillances SR 5.2.2a-5y, " Tendon Corrosion and Anchor Assembly Inspection," which consisted of a tendon wire sample inspection, and SR 5.2.2c-5y, "Prestressing Anchor Assembly Inspection," which consisted of a visual examination of 5% of the prestressing anchor assemblies. Both surveillances are new in-service inspection (ISI) requirements as a result of Amendment 33 to Operating License DPR-3 (1) For this activity, the SRI performed the following:
 (a) Verified that the Technical Specification Surveillance Tests were covered by properly approved procedure (b) Verified that the procedures were consistent with Regulatory requirement (c) Witnessed selected portions of the tests to verify the following:
  . Maintenance QC (MQC) requirements were me ,
  . Test prerequisites were complete . Special test equipment required by procedure were calibrated and in servic . Required data was recorded for final review and analysis by proper personne . Procedure or appropriate revision available and in use by test personne (d) Verified the qualifications of two individuals (MQC and maintenance) participating in the surveillance . .
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  -6-During the process of qualification verification, the SRI determined that MQC's . qualification program as identified

. in Technical / Administrative Services Manager's Administrative Procedures (TASMAP) -2, "MQC Program," Issue 7, dated April 19, 1984, is in conflict with the requirements of the Training ! Programs Administrative Manual (TPAM), Issue 24, dated April 13,1983. The following problems were identified:

 . TASMAP-2, Section 4.9, states,
 "Each individual shall have his own training file in which these aforementioned tests and a form G-2 shall be kep These records are retained by Record Storage."

However, the TPAM states that the training supervisor will maintain all training records with some exceptions and MQC * is not listed as an exception. Also the form G-2 referenced above is not identified in the TASMAP as to what exactly a form G-2 i .- TASMAP-2 does not implement the requirements of ANSI N45.2.6 - 1973. However, the SRI did verify that MQC does maintain qualification records in records storage that comply with N45. The licensee was informed that the MQC training program problems identified above are considered an open item (8413-02).

(2) Problems identified during the anchor assembly surveillance necessitated development of an expanded inspection program by the licensee for which Regulatory Guide 1.35 was used as-guidance. The problems identified during this expanded inspection program are documented in PSC letter P-84110,

' dated April 12, 1984, as well as Licensee Event. Report 84-00 Additional information is contained in PSC letter P-84119, dated April 25, 1984. The licensee's proposed inspection program is continuin ,
(3) Reactive inspections performed as a followup by HRR, Region IV, and the' SRI in response to the licensee's initial reporting of the tendon corrosion problem on March 28, 1984, has resulted in issuance of an April 19, 1984, Order restricting plant operation to low power (up to 2% full power) provided the primary helium pressure is maintained at less than 450 psig

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pending completion of NRC's evaluation of the PCRV tendon wire

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   -7-b. Reactive and routine inspections performed by the SRI, during the-tendon inspection program, included reviews of records, ooservation of work in progress, and review of maintenance procedures, to verify that the maintenance activities developed for this inspection program were being conducted in accordance with approved procedures, Technical Specifications, and appropriate codes and standards. The following maintenance procedures and activities were reviewed and observed:

MP 11-6 PCRV Prestressing Tendon Liftoff Procedure, Issue 2, dated April 11, 1984 MP 11-7' PCRV Tendon Test Wires Removal and Inspection, Issue 1, dated April 5,1984 MP 11-8 Retentioning PCRV Tendons, Issue 1, dated April 6,1984 PTR 3-543 PCRV Tendon Inspection in Accordance with MP 11-6 (1) On April 17, 1984, during observation of the inspection performed on Vertical Tendon VI-20, the SRI determined that PTR 3-543 was marked as nonsafety-related. FSAR Update Revision 1, Table 1.4-3, identifies the PCRV as a Class I and safe shutdown structure. Plant trouble reports (PTR) are completed in accordance with Administrative Procedure P-7,

 " Work Control - Maintenance on Safety Related Equipment,"

Issue 6, dated March 13, 1984. Attachment P-7A, Step 9, requires the reactor operator to indicate if the equipment involved is or is not on the " Safety-Related" list identifying whether or not this is safety-related wor However, Speci-fication SR-06-12, " Safety-Related Component List," Issue AH, dated January 17, 1984, only identifies all tag-number items comprising Class I and safe shutdown systems and does not identify Class I and safe shutdown structures. The licensee was informed that this is considered an c u item (8314-03) pending development and implementation of some system by which all safety-related work can be identified as such on the PTR (2) During a review of MP 11-8, the SRI identified the following problems:

 (a) Data sheet referred to not exceeding a specification of 1753 kips which does not apply to FS .(b) Step 4.2.7 requires documentation of theoretical (calculated) elongation, but does not provide a method for obtaining this valu . .
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 .(c) Step 4.2.9 (b) contains an equation that is in erro ,
 (d) Steps 4.2.9 and 4.2.10 require documentation of elonga-tion but does not provide acceptance criteri (e) . Step 4.2.6 requires establishing an overstress and lockoff value but does not provide a method for calculatio An April 18, 1984, meeting to discuss the MP 11-8 problems with MQC and site engineering resulted in the licensee's commitment to rewrite MP 11-8 into a more meaningful documen Apparently the MP,had been developed from an outside
, . contractor's (Inryco) procedure and had not received a thorough review. This is considered an open item (8413-04)

pending issuance and the SRI's review of the revised r procedur '

- No violations or deviations were identifie Plant Startup From Refueling
 ~ To ascertain whether systems disturbed.or tested during the refueling outage were returned to an operable status before plant startup and to ascertain whether plant startup will be in accordance with

_ approved and adequate procedures, the SRI reviewed startup procedures and performed a walkthrough of appropriate portions of a system disturbed during the refueling outage to independently ascertain that it has been returned to service in accordance with approved procedure This effort' consisted of the following:

 (1) Review of all cold checkout tests (CCT) and functional tests (FT)

for CN 1294, " Replace 480 Volt Essential Load Center Switchgear and Electrical Connections on the Fire Protection System,

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4160-480 Volt Transformers, and Current Limiting Reactors."

t (2) Verified switchgear installation was in accordance with CN 129 (3) Observation of the successful Automatic Throwaver (ATO) Test in accordance with FT 1622 for CWP 84-62, " Class IE UV Protective Relaying for new 480 V Essential Buses 1, 2, and 3 (Terminations)," that occurred'on April 19, 198 (4) Observation of the Loss of Outside Power and Turbine Trip Surveil-lance SR 5.6.lb-SA and followup on the problems identified during the SR initial performance until successful performance was achieved on April 21, 198 r

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   -9-(5) Reviewed the licensee's clearance log and operations deviation log periodically during the CN 1294 modificatio (6) Verified and reviewed portions of the licensee's major systems walkdown beirg performed by operations personnel. This is a first time effort made by operators to perform complete system walkdowns on systems disturbed during an outage to verify that ,
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piping and instrumentation drawings (P&ID) agree with the as-built system, and that the system operating procedures (SOP) valve lineups also agree with the as-built system prior to plant , startup from refuelin L (7) Reviewed the Overall Plant Operating Procedure (OPOP).

As a result of Unresolved Item 8331-01, the SRI's review centered around new revisions to OPOP I, " General Plant Requirements," Issue 57, dated April 16, 1984, and OPOP III,

 "Startup Procedures," Issue 56, dated April 16, 198 b. During the OPOP review on April 24, 1984, the SRI identified the following problems:
 (1) OPOP I, Issue 57 (a) Section A, " Technical Specification Checklist," does not indicate that LC0 4.7.5 is applicable whenever spent fuel is in storag ~
 (b) Section A does not indicate that LC0 4.1.8 (SR 5.1.5-RX)

is also in effect during each startu (c) Section C.2 should also verify equipment operability required by LC0 4. (2) OPOP III, Issue 56 (a) Section E.3.a states, " Complete OPOP I.C.5." This apparently should refer to OPOP I. (b) Section E.3.b states, " Complete OPOP I, Table 2.2.3.1."

This apparently should be Table 2.2.2.1.

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 -(3) OPOP IV, " Plant Operation Between 30% and 100% Power,"

Issue 50, dated August 20, 1982

 . Needs to be updated to reflect revisions made to OPOP ,
 (4) OPOP VI, " Recovery From Main Turbine Trip," Issue 35, dated December 27, 1983
 . Needs to be updated to reflect revisions made to OPOP II The licensee was informed that Unresolved Item 8331-01 is considered closed and that the above remaining .0P0P deficiencies is considered an.open item (8413-05).

No violations or deviations were identifie ; 7,. Startup : Testing ~ - Refueling , To verify that facility operation following refueling is in conformance with NRC-requirements and licensee procedures, the SRI-reviewed the following core physics ~ tests for adequacy and approval prior to startup from refueling:

 . SR 5.1.3-RX, " Temperature Coefficient of Reactivity Calibration,"

Issue 2, dated October 28, 1983

 . SR 5.1.4-W-P, " Core Reactivity Status Check," Issue 32, dated April 11, 1984
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SR 5.1.5-RX, " Control Rod Reactivity Worth," Issue 3, dated April 19, 1984 !' . SR 5.1.7-X, " Region Peaking Factor Surveillance," Issue 3, dated August 26, 1983

 . S0P 12-02, " Reactivity Calculations," Issue 20, dated April 11, 1984
 . Core Management Guide (CMG) - 14, " Cycle 4 Rise-To-Power Test Coordination," Issue 1, dated April 11, 1984 No violations or deviations were identified.

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. Report Reviews
  - The SRI reviewed the following reports for content, reporting requirement,
  -and adequacy:

Monthly Operations Report for the month of March 1984 Report of Changes, Tests, and Experiments Not Requiring Prior Commission _ Approval for the period January 1,1983, through December 31, 1983 No violations or deviations were identifie . IE Bulletins The SRI verified by record review, observation, and discussion with the licensee, the action taken in response to IE Bulletins and reviewed

  - the following bulletia:
  (Closed) IE Bulletin ~ 83-08: Electrical Circuit Breakers with an Under-Voltage Trip Feature in use in Safety-Related Applications Other
  'than the Reactor Trip System. -The licensee concluded in PSC letter P-84094, dated April-2,l1984, that:
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  . FSV does not have Westinghouse Type DB, Type DS, or General Electric Type AK-2 in use in safety- related system None have been purchased
  .for future'use.

.. . None of their in-service safety-related breakers utilize an under- ! voltage trip attachment. This function at FSV is performed by undervoltage relays.

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  ' No violation or deviations were identified.

- 10. Exit Interview Exit interviews were-conducted at the end of various segments of .this

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  ~ inspection with Mr. D. Warembourg, Manager, Nuclear Production, and/or other members of- the PSC staff as identified in paragraph 1. At the L  ~
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inter /iews, the SRI discussed the findings indicated in the previous E . paragraphs.- The licensee acknowledged these findings.

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