IR 05000267/1985026

Reviews Input from Insp Rept 50-267/85-26 Re Region IV Implementation of IE Insp Program.Agreement Found Between Results of Insp & Latest SALP Rept Performance Ratings

ML20138R777
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/15/1985
From:	Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8511190023
Download: ML20138R777 (4)

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NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20$55 p

• November 15, 1995

,,,g MEMORANDUM FOR: Richard P. Denise, Director Division of Reactor Safety and Projects e Region IV FROM: James G. Partlow, Director Division of Inspection Programs Qffice of Inspection and Enforcement SUBJECT: ASSESSMENT OF THE IMPLEMENTATION OF THE NRC INSPECTION PROGRAM AT FORT ST. VRAIN Inspection report 50-267/85-26 provides the results of an inspection performed at Fort St. Vrain by IE personnel. The inspection covered plant operations, the surveillance program for reactivity control and station batteries, main-tenance, and post-modification testing. The inspectors used inspection modules and procedures from the minimum, basic and supplemental programs. One aspect of this inspection was to provide input to IE management for assessment of Region IV's implementation of the IE inspection program. The results of this assessment are discussed below. A copy of the inspection report and a summary of 766 System Data are attached as Enclosures 1 and 2 respectivel The overall implementation of the inspection program by Region IV at Fort S Vrain is considered acceptable. General agreement was found between the results of this inspection and the performance ratings assigned by Region IV in the latest SALP report. The following observations are provided: Several Region IV inspection reports (84-01, 84-03, 85-01, 85-03 and 85-15) had identified QA deficiencies in the procurement program. Our findings confirm this poor history of procurement controls in that we identified material problems with each of the three Station Service Requests we reviewed. Region IV had rated FSV as SALP Category a in QA, which included procurement control There has apparently been no improvement by the licensee since that rating was assigne . Region IV had identified numerous problems with inadequate develop-ment and implementation of maintenance procedures (inspection reports 84-22,84-26,84-29,84-34,85-14and85-15). A SALP rating of Category 3 had been assigned by the region with the observation that the licensee did not endorse 100% post-maintenance testin Our findings reinforce the region findings that insufficient atten-tion was being paid to the development and implementation of main-tenance procedures, and that the post-maintenance testing program was inadequate. Also, our findings indicate there has been little progress by the licensee in this area since the last SALP rating was assigne . In November,1984 generic concerns about battery surveillance programs had been identified by this office at Cooper Nuclear Station. These concerns, with a request for followup, had been forwarded to all Re-gional Administrators by the IE Office Director. The requested follow- g up was not performed at FSV due in large part to resident inspector p 8511190023 851115 \

PDR ADOCK 05000267 G PDR j

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Richard P. D:nist -2-

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reassignments. 'However, a subsequent inspection of battery sur-veillance (and several other) procedures was performed by the region during the period June 25 - July 3, 1985, as documented in inspection report 85-19. The report states that no violations or deviations were identified. In view of the number of weaknesses, including violations, found by our inspectors during the period August 19-28, 1985, regional inspection in this area should have identified these problem . As noted in our inspection report, the region had made an issue of the general housekeeping condition of the plant. Our inspectors noted that these conditions had apparently improved. However, several deficiencies repeatedly identified by the region continue to exis Our findings reinforce the region findings that this area had been a major problem, that improvements have been made, and that more improvements are neede . The headquarters inspectors considered the licensee's control of l plant modifications to be inadequate. Numerous temporary modifi-cations had been installed for so long (up to nine years) that they had become de facto permanent changes to the plant without having gone through the revie.s and approvals required for per-manent modifications. The region had reviewed the temporary modification records monthly as part of the operational safety verification inspection, and deficiencies had been reported and corrected. However, we believe the region should have been more active in initiating licensee improvements regarding the licensee's failure to close out the temporary modifications (either by removal or approval of a permanent design change) in a reasonable tim If you have any questions concerning this assessment, please contact me or ( have your representative contact the team leader, Duke Wheeler (492-9038).

James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement Enclosures:

1. Inspection Report 50-267/85-26 2. 766 Data Distribution:

.DCS a < RL-t1 Spessard ulE ORPB reading J. G. Partlow, IE DI reading R. H. Vollmer, IE L. L. Wheeler, IE J. M. Taylor, IE L. J. Callan, IE P. F. McKee, IE

• SEE PREVIOUS CONCURRENCE:

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• IE: PAS:0RPB *IE: PAS:0RPB I PB IE: DD IE:b'D LLWheeler:jj LJCallan P Mc ee' JCP t ow 10/ /85 10/ /85 p/3/85 R(Sp(essard 1// /85 1 /85

Richard P. Deniss -2-

.o ', r;qu;st for followup, had been forward:d to all Regional Adminis-

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trators by the IE Office Director. The requested followup was not performed at FSV due in large part to resident inspector reassign-

.ments. However, a subsequent inspection of battery surveillance (and several other) procedures was performed by the region during ne 25 - July 3,1985, as documented in inspection report 85-1

~theperiodg9.'Ad The report states that no violations or deviations were identiff . In view of the number of weaknssses, including violations, found by our inspectors during the/ period August 19-28, 1985, your inspection in this area should have identified these problem N\ /

/ As noted in our inspection report, the region had made an issue of the general houseke'eping condition of the plant. Our inspectors noted that these conditions had apparently improved, particularly after Comnissioner Gilinskey's visit.' Several deficiencies repeat-edly identified by the regioit continue to exist. Our findings reinforce the region findings that'this area had been a major problem, that improvements ha've been made, and that more improve-ments are neede . Theheadquertersinspectorscdnsnieredthelicensee'scontrolof plant modifications to be inadequate. Numerous temporary modiff-cations had been installedf for so Tqng (up to nine years) that they had become de facto p'ermanent changes to the plant without having gone 'through the reviews and approvals required for per-manent modifications. ,The region had\ reviewed the temporary modification records monthly as part of the' operational safety verification inspection, and deficiencies had been reported and corrected. However,'an issue had not been made by the region of the licensee's failure to close out the temporary modifications (either by remova]'or approval of a permanent design change) in a reasonable time'. This office has not provided definitive guidance on what' constitutes a " reasonable time" for temporary modifications,[so the region action if they had inspected had for this no clear particular itembasis for enforcement and found deficiencies. In the case of Fort St. Vrain, this office con-siders enforcement action appropriate based on the licensee's failure to establish procedures to prevent circumventing the reviews and approvals required for permanent change If you have any questions concerning this assessment, please contact me or have your representative contact the team leader, Duke Wheeler (492-9038).

James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement Enclosures:

1. Inspection Report 50-267/85-26 2. 766 Data Distribution:

DCS L. L. Wheeler, IE R. L. Spessard, IE J. M. Taylor, IE ORPB reading L. J. Callan, IE J. G. Partlow, IE DI reading P. F. McKee, IE R. H. Vollmer, IE

• SE PREVIOUS CONCURRENCE:

• IE: PAS:0RPB IE :0RPB IE:DI:0RPB IE:DI:DD IE:DI:D hLLWheeler:jj LJCallan PFMcKee RLSpessard JGPartlow 10/3(/85 10/p /85 10/ /85 10/ /85 10/ /85

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Richard P. Denise -3-  ! Substantial resources have been required,,0ver a long period of

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time for higher priority efforts at NT0L sites, c TheregTondidhaveincreasedpresenc/ e at the site for a limited time, bu\this was in response to,the problems with failures of controlro(drivemechanisms. The primary focus was on the rod drive re(urbishment program, which had QA and maintenance aspects. Resources were not a9ailable for extensive program-wide QA and maintendnce inspection' effort ) 'N /

The region is follbwing 'the implementation of a special performance enhancement program that resulted from an NRC-prompted independent appraisal of the licensfee's overall management, organization and performanc / 'N The region has ackn/

'N owledged that the IE findings of no improvements (and confirmatiorr'of Category 3' ratings) indicates that increased inspection effo ts are required. 'Accordingly, more resources will be allocated they become available upon the completion of higher priority assi nment If you have any questions concerning this assessment, please contact me or have your representative contact the team leader, Duke Wheeler (492-9038).

James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement Enclosures:

1. Inspection Report 50-267/85-26 2. 766 Data Distribution:

DCS ORPB reading DI reading L. L. Wheeler, IE L. J. Callan, IE P. F. McKee, IE R. L. Spessard, IE J. G. Partlow, IE R. H. Vollmer, IE J. M. Taylor, IE l

IE:F '0RPB

IE: PAS:0RPB IE:DI:0RPB IE:DI:DD IE:DI:D LLWI ler:jj LJCallan PFMcKee RLSpessard JGPartlow 10/3 85 10/ /85 10/ /85 10/ /85 10/ /85

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- ENCLOSURE (1)

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UNITED STATES

1. g 8 o NUCLEAR REGULATORY COMMISSION y, l WASHINGTON, D. C. 20655 October 8,1985 k ..... # s

. Docket No. 50-267/85-26

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Public Service Company of Colorado ATTN: Mr. O. R. Lee,.Vice President ,

Electric Production P. O. Box 840 Denver, Colorado 80201 Gentlemen:

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This refers to the routine safety inspection conducted by L. L. Wheeler, J. E. Dyer and L. E. Whitney of this office on August 19-28, 1985 of activities at the. Fort St. Vrain Nuclear Generating Station authorized by

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NRC Operating License DPR-34. The inspection findings were discussed with

J. Gahm and othe,s r of your staff during and at the conclusion of the

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inspectio I The enclosed inspection report includes findings of significant weaknesses

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in several maintenance-related areas (maintenance of station batteries and motor ' operated valves, post-modification testing, and the safety-related qualification of replacement parts). The most recent SALP report (May 7, 1985) considered your maintenance activities to be minimally satisfactory with respect'to operational safety. The ' ladings of this inspection confirm that assessment and indicate that your tor ective action has not been effectiv The NRC will focus increased inspr,W < W ention on your maintenance and main-I - tenance-related activities until qt 4tg t erformance is achieve The enclosed report includes findings that may result in enforcement action Disposition of these potential enforcement findings, referred to as unresolved items in the report, will be made by the NRC Region IV offic In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of

this letter' and the enclosed inspection report will be placed in the NRC's Public Document Roo We will gladly discuss any questions you have concerning this inspection.

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Sincerely, g

h' uw r~rl 4 .

James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement Enclosure:

. Inspection Report No. 50-267/85-26

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OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF INSPECTION PROGRAMS PERFORMANCE APPRAISAL SECTION (PAS)

Report: 50-267/85-26 Docket: 50-267 Licensee Nos. DPR-34 Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840 Denver, Colorado 80201 Facility Name: Fort St. Vrain Nuclear Generating Station Inspection At: Fort St. Vrain (FSV) Site, Platteville, Colorado I Inspection Conducted: August 19-28, 1985

/O -2. - 75~ Inspectors: , --

Date t L. L. Wheeler, ORPB, IE, Team Leader QV /o-2- B r Date J. E. Dfer, ORP8, IE

) /0- 1 -85 M Date L. E. Whitne p RPB, IE Approved by: 4 / fr/M#N tc '/-K Date

. F. McKee, Chief, Operating Reactors Programs Branch Inspection Sumary Areas Inspected: This routine safety inspection involved 152 inspection hours on site in the areas of plant operations, sur-veillance programs, and maintenance.

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Results: Three potential enforcement findings, referred to as un-resolved items in the report and three open items were identified during the inspection. These items wi1? be followed up by the NRC Region IV offic . /m rt ir I UI } U l lU (G ,

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DETAILS Persons Contacted Licensee B. Barta, Nuclear Engineer

• F. Borst, Manager, Support Services

• B. Burchfield, Superintendent, Nuclear Betterment Engineering 0. Clayton, Tec.hnical Services Engineer

• Craine, Maintenance Superintendent D. Decatoire, Plant Operations T. Dice, Plant Operations

• D. Evans, Operations Superintendent

• M. Ferris, QA Operations Manager W. Franek, Plant Scheduling and Stores Superintendent

• C. Fuller, Station Manager

• J. Gahm, Nuclear Production Manager

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• J. Gramling, Nuclear Licensing

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R. Heller, Senior Plant Engineer D. Horshan, Plant Scheduling and Stores

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J. Jackson', QA/QC Supervisor C. Kasten, QA Computer Specialist 2 R. Kevan, Plant Operations S. Koleski, Plant Operations J. McCauley, Results Engineering Supervisor

• F. Novachek, Technical / Administrative Services Manager J. Petera, Maintenance Supervisor G. Redmond, QC Supervisor C. Schmidt, Results Supervisor

• L. Singleton, QA Manager

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H. Starner, Nuclear Site Construction Coordinator J. Vandyke, Plant Operations

• D. Warembourg, Nuclear Engineering Manager R. Webb, Maintenance Supervisor J. Weller, Plant Operations J. Wojtisek, Technical Services Engineer Other licensee employees contacted included technician, operators, and office personne NRC R. Farrell, Senior Resident Inspector

• Skow, Region IV Project Inspector

• Attended exit intervie .-. - _- _

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-2-2. Review of Plant Operations Operational Safety Verification The control room was inspected daily to verify compliance with minimum staffing requirements, access control, adherence to approved operating procedures, and compliance with limiting conditions for operation (LCOs).

Reviews were made of logs, tagging requests, night orders, bypass logs, and incident reports. Two shift turnovers were also observe General housekeeping and professional demeanor in the control room were satisfactor Normal background noise levels did not appear to have an adverse effect on operator performance. There were no unnecessary personnel observed in the control roo The following concerns were identified:

s (1) The licensee's equipment control procedures did not comply with the requirements of TMI Item I.C.6. Procedure P-2, Equipment Clearances and Operation Deviations, Issue 13, did

,' not require a second qualified person to verify the correct i implementation of tagging activities. On May 22, 1985, NRC Region IV had requested a response within 120 days to a similar finding that had been discussed at a Management Conference on November 14, 1984. Clearance control form revisions were noted to be in progress during this inspec-tio The licensee's compliance with the requirements of TMI Item I.C.6 will remain an open item pending Region IV acceptance of the licensee's response to their finding (50-267/85-26-01).

(2) Procedure P-1, Plant Operations, did not provide adequate control of temporary plant modifications. Specifically, Section 4.9, Control of Temporary Configuration, contained no provisions for ensuring the temporary nature of modifi-cations made under that procedure. At the time of the inspection, 37 Temporary Configuration Requests (TCR) were open from two to nine years. The licensee had initiated permanent design change notices (DCN) for several of these TCRs, however at least 11 of these DCNs had been in prepara-tion for over 2 year This lack of control of temporary changes resulted in permanent changes being made to the station without the necessary reviews being conducte The failure to establish and implement procedures to adequately control temporary plant nodifications was discussed with the licensee and will be incorporated into unresolved item 50-267/85-26-02 for followup by the Region IV Offic Corrective Action Systems The system for performing trend analyses and management review of Corrective Action Requests (CARS) was considered a strength. Cor-

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-3-rective Action Effectiveness Summary Reports were issued monthly with trend analyses and a current review of CARS by type (failure to follow procedures, lack of training, etc.). Monthly reports are also issued to responsible departments identifying responses due in the near future and overdue response Overdue responses received adequate management attentio Station Tours The inspectors toured accessible areas of the plant. During these tours, observations were made of equipment condition, fire and safety hazards, use of procedures, radiological controls and conditions, housekeeping, and surveillance activitie It was evident that a significant effort had been made to upgrade the general housekeeping conditions of the plant. Several major portions of the plant were clean and free of clutter, debris, et Maintenance personnel were observed making a deliberate effort to y clean up the work site after performing repairs. The licensee had developed an extensive list of insulation repair requirements.

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However, several safety hazards and basic housekeeping deficiencies t- were noted. These included a fire hazard from oil in overhead cable

trays, poor lighting in some areas, an open door on the back of an electrical cabinet, graffitti on the walls, some plant components in need of cleaning and repainting, a valve leaking onto exposed insulation repair work in progress, damaged operating instructions posted on an ammonia injection tank, chains for operating overhead valves hanging down into passageways, and a safety seal missing from a relief valv Some of these deficiencies had been identified in past Region IV inspection reports. The region had made housekeeping an open item twice in previous inspection reports (8325-03 and 8415-03), and the latest SALP report (May 7, 1985) noted that housekeeping had continued to be a problem. Procedure SMAP-13, General Housekeeping Program, specified inspection requirements, assigned responsibility for designated plant zones, and provided directions for reporting deficiencies. However, the procedure had no provisions for tracking specific deficiencies to ensure appropriate corrective action and management review. The apparent failure to develop and implement adequate procedures for correcting housekeeping deficiencies will remain an open item pending followup by Region IV (50-267/85-26-03). System Walkdown The inspector conducted a walkdown and performed a valve lineup of the ".B" diesel generator to observe equipment conditions and system lineups. No valves were found in improper positions, but one valve was not in accordance with the lineup sheet due to maintenanc Deficiencies were noted in that the lineup procedure did not include verification of the position of the following: diesel engine cooling ,

water temperature control valves (TCVs), air valves on the TCV

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regulators, lube oil drain valves, and lube oil drain plug The misposition of these items had the potential for causing damage to I the diesel engines to the extent that they could fail to operat l I

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-4-The lube oil heater inlet and outlet valves were not on the lineup sheets, and they were not labeled. The failure to provide adequate procedures'to ensure the operability of the diesel generators will remain an open item pending followup by Region IV (50-267/85-26-04).

3. Surveillance Activities lhe inspectors reviewed recent surveillance test results for the station and power plant systams (FPS) batteries, and the recently issued interim Technical Specifications (TS) for reactivity contro The following documents, tests and records were reviewed:

Document Number Topic SR 4.1.1.B. 1/2-W Control Rod Operability through 4.1.1.F.lb-R

SR 4.1.2.A.3-W Rod Position Indication Systems-through 4.1.2.c-x Operation

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$" SR 4.1.3.B-R Rod Position Indication Systems-through 4.1.3.D-W/R Shutdown SR 4.1.4.A-W/ Shutdown Margin SR 4.1.4-B-P-X SR 4.1.6.C/D-X Control Rod Position Requirements-Shutdown

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SR 4.1.8.A/8-W Reserve Shutdown System-Operation through 4.1.8.D-A SR 4.1.9.A/B-W Reserve Shutdown System-Shutdown through 4.1.9.D.1-R SR 5.4.5-M PCRV Cooling Water Flow Scan Functional Test SR 5.4.1.3.2.b-M Feedwater Flow Test SR 5.6.2a-W, Issue 23 Station and PPS Battery Check for weeks #29, 30, 31 (Weekly)

SR 5.6.2b-M, Issue 1, Station and PPS Battery Check for week #27 (Monthly)

SR 5.6.2b-Q, Issue 20, Station and PPS Battery Check for week #31 (Quarterly)

SR 5.6.2c-A, Issue 17, Station and PPS Battery Check for week #9 (Annual)

TCR 85-04-01 Request to jumper cell 35 out of Battery 1A (N9242)

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-5-Change Notice (CN) 1391 Replace Station Batteries 1A and IB. Replace PPS Battery 1 The inspectors found that the interim TS for reactivity control appeared to have been properly implemented by the surveillance procedure The surveillance procedures for the feedwater flow test and control rod operability also appeared adequat Procedure SR 5.4.5-M allowed the potential for errors in PCRV Cooling Water Flow alarm setpoint restoration. The licensee had previously identified this deficiency and was processing a procedure change to correct this weaknes The inspector reviewed the TS compliance log maintained by control room personnel and the daily surveillance status printouts provided by the licensee's scheduling organization. These documents appeared

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thorough, concise and effective. No missed surveillances were I.: identified in this review.

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b. The licensee failed to establish procedures that complied with TS z- requirements in the following instances:

(1) The weekly battery surveillance test, 5.6.2a-W, did not measure the temperature of cells adjacent to the pilot cell as required by TS 5.6.2 (2) Neither the monthly nor quarterly surveillance tests, SR 5.6.2b-M and SR 5.6.2b-Q, measured the height of the electrolyte in the sampled cells as required by TS 5.6.2 '

SR 5.6.2b-M verified that all cell electrolyte levels were within the vendor specified operating band, but this was recorded by a single check mark on the data sheet and there were no cell measurements taken or recorde (3) The licensee modified the configuration of a station battery and returned the battery to an operable status without adequa-tely considering whether the modified battery would meet the requirements of TS 5.6.2c. The annual discharge test of battery 1B conducted in April 1985 was performed with a spare cell connected to the battery (59 cells total). On the basis of the performance of this 59 cell battery during the discharge, the licensee determined that battery capacity was acceptable in accordance with TS 5.6.2c and the battery was operabl Subsequently, the spare cell was removed from battery IB, but there was apparently no discharge test or evaluation conducted to determine that the resulting 58 cell battery would meet the necessary operability requirements of the T The apparent failure by the licensee to develop procedures to ade-quately implement TS surveillance requirements for determining battery operability was discussed with the licensee and will be

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-6-incorporated into unresolved item 50-267/85-26-02 for followup by the NRC Region IV Office. TS 4.6.1 requires that the station and PPS batteries be operable before the reactor is operated at powe The surveillance test results reviewed by the inspectors were for

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a period when the reactor was shutdown and therefore the violation of a limiting condition for operation (LCO) was not involve The licensee failed to follow procedure SR 5.6.2c-A for the annual ;

battery partial discharge test. The results from this discharge  ;

test satisfied the TS 5.6.2c requirements, however, the following implementation deficiencies were identified:

(1) Procedure Deviation Request (PDR) 85-1032 revised the procedure to discharge the station batteries (1A, IB) at 85 amps for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the PPS battery at 79 amps for 12 hrs or until the battery terminal voltage reached 101.5 volts. Battery 1B was ,

, ; discharged at 85 amps for only 19.2 hrs and the PPS battery was

discharged at 79 amps for only 9.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> without either battery reaching its minimum terminal voltage. Interviews revealed that

.. these discharges were terminated by the personnel performing the

' tests without prior management approva a

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(2) The end of discharge specific gravities for each cell of battery 1A and IB were all recorded at 1.100 and 1.160, respectively. In-terviews with maintenance personnel revealed that these readings were the minimum detectable values of the hydrometers used to record the end of discharge data. The actual battery cell specific ,

gravities were lower than the recorded values and this information was not recorded on the surveillance data shee }

(3) Although cell 35 was jumpered from battery 1A and did not participate in the discharge test, the final individual cell voltage ICV and specific gravity readings decreased from 2.07 VDC to 1.88 VDC and 1.210 to 1.100, respectively. These post discharge readings were indicative of the cell participating in the battery discharge tes The apparent failure by the licensee to follow procedure SR 5.6.2c-A for the annual discharge test of the station and PPS batteries was discussed with the licensee and will be incorporated into unresolved item 50-267/85-26-02 for followup by the NRC Region IV Offic . Maintenance Activities l

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The inspectors observed the material condition of and reviewed completed maintenance actions and procedures for batteries and motor operated valves (MOV). The helium circulator turbine steam inlet isolation  :

i valves (HV-2245, HV-2246, HV-2247, HV-2248) were the MOVs of interest l during this inspection. Additionally, replacement parts used for safety-related maintenance actions were traced to their origin to determine their acceptability. The following documents were reviewed:

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Document Number Topic Station Operating Procedure Electrical Distribution - AC System (SOP) 92-06, Issue 7 Station Service Request (SSR) Replace Frequency Meter for Battery 84500238 P.O. 53476 1C Inveter SSR 84500283/287, Rebuild Snubbers P.O. N4585 SSR 84501102 Repair Motor For HV-2248 NCR 85-563 EMP 45, Disconnecting, Reconnecting and Issue 1 Testing of Limitorque or Rotork j

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MP 39.3, Maintenance and Repair of Rotork

.. Issue 3 - Valve Controllers * PM 92.10, Inspection and Preventive Main-Issue 24 tenance of Caterpillar Diesel -

Emergency Generator Units SMAP-21, Post Maintenance Testing Require-Issues 1 ments in Maintenance Related Procedures P-5, Material Control Issue 8 Q-4, Procurement Document Control Issue 6 91-M-1-28-5 Rotork Instruction Handbook for Synchroset Electric Valve Actuators The inspectors reviewed three safety-related station service requests (SSR) to determine the suitability of replacement parts being used for maintenance. Deficiencies were identified with each SSR as identified below:

(1) The safety-related frequency meter replaced by SSR 84500238 was procured under a non-safety related purchase order without any of the required certifications and no attempt was made to qualify the meter for safety related use. The installation of this meter was approved by Maintenance Quality Control (MQC).

(2) Safety-related snubber 0-Rings, replaced by SSR 84500283/287, were purchased via a parts distributor from a manufacturer not en the qualified vendors list. A certification of conformance was provided from the parts distributor to the licensee without supporting documentation from the manufacture This document

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approved QA progra (3) The motor installed on valve HV-2248 by SSR 84501102 was rewound by a vendor not on the approved vendors list. The licensee identified this deficiency with NCR 85-563 and had performed a component qualification test to upgrade the motor for safety-related applications. The qualification test consisted of meggering the motor windings to confirm proper electrical refurbishment and a post installation vibration test to verify corrset bearing installation. The only documentation of test performance was the statement " Valve test eks okay: Valve is electrically okay". There was no record of the measured test results or the instruments utilized to obtain the vibration and resistance measurement The licensee did not review the vendor's process or materials used for rewinding the moto ' The inspectors concluded that the tests and documentation were i,nadequate to ensure that the replacement motor was equal to

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or better than the original construction phase componen (4) Gearcase oil used for MOV applications differed from that recommended by the vendor manual and may not have been suitable for the environment of all plant MOVs. Procedure MP 39-3 and the vendor manual specify the use of SAE 80 EP oil in the gearcase of motor operated valves. Discussions with maintenance personnel revealed that Mobil 629 oil was being used for all MOV applications. The licensee had not performed an engineering evaluation to determine that the Mobil 629 oil was suitable for all MOV applications or compatible with residual oil that may have been in the gearcas The inspector also noted that SAE 80 EP oil was rated for operation only to 180*F and this was significantly below the 737'F helium circulator inlet steam temperature listed in the updated FSAR, Fig 10.2-3, for 100% power operations. During the inspection, the licensee measured the gearcase temperature of HV-2247 at approximately 140*F with lower temperature steam being supplied from the auxiliary boiler The suitability of both Mobil 629 and SAE 80 EP oil under these high temperature operating conditions is questionabl The Ft. St. Vrain Quality Assurance (QA) Plan, Appendix B to the FSAR, requires that safety-related items be purchased from approved suppliers, receipt inspected and, if procured sole source, procured to standards that will assure an equal to or better than original condition. The apparent failure to procure safety-related replacement items in accordance with their QA Plan was discussed with the licensee and will remain unresolved pending followup by the NRC Region IV Office (50-267/85-26-05).

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. -9- The inspectors reviewed the material condition of the four helium circulator turbine inlet steam isolation valves (HV-2245, HV-2246, HV-2247 and HV-2248). In addition to the improperly qualified motor installed in HV-2248 (see section 4.a.(3) of this report), valves HV-2247 and HV-2248 were leaking oil from their gearcase, and valves HV-2246 and HV-2248 local position indicators differed from their remote indicatio Both valves indicated in the mid position locally, while valve HV-2246 indicated shut remotely and valve HV-2248 indicated open remotel The licensee verified the remote positions to be correc Contributing to these material deficien-cies were the following procedure and implementation problems with the MOV maintenance program:

(1) The electrical maintenance procedure for MOV motor installation, testing and documentation was inadequat Procedure EMP 45 provided for verifying proper motor rotation by momentarily touching the motor leads to an energized terminal and jogging the motor in the closed direction. This appears contrary to 5'

the vendor manual which directs that the motor be energized from the operating switch to verify rotatio ,

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Paragraph 3.9 of procedure EMP-45 provided general guidance for documenting the as found/as left condition of the valve but there was no requirement to record the torque or limit switch settings when adjusting these setpoints. A review of two com-pleted SSR packages revealed that these setpoint values were not recorde The post installation testing for MOV motors consisted of cycling the valve to verify proper operation, circuit integrity and posi-tion indication. However, there were no quantitative acceptance criteria for determining proper valve operation even though nominal valve operating speeds were provided in the vendor manua MQC was not required to observe the test and the determination of proper valve operation was left to the judgement of the workman performing the maintenanc (2) The torque values listed for use in the MOV mechanical repair procedure had an inadequate technical basis and their use was optional. Procedure MP 39-3 had a table of MOV torque values that were based on bolt size. The table was identical to one in procedure PM 92.10 for diesel generator maintenance and was based on values in the diesel generator vendor manual. Addi-tionally, a note at the bottom of the table made torque wrench use optional by stating that:

An average man on a 12 inch wrench can develop about 100 ft. Ib. of torqu Therefore, if a torque wrench is not available, or cannot be used, use the following wrench-bolt combinations:

,

. . - - - - . - . . - , . - - - . , . ,-- .-,.,-,.-.---,,.-c --., - , - , . , , , , ----,w - ,~ . , . , . , . . - - . .

. . . . . _ _ _ _ . _ _ _ . _ _ _ _._._ .__ _

!

.

y e 2

' '

_ 10

.

Bolt Sizes. Inches 1/2 9/16 5/8 3/4 7/8 1-1/8

Wrench Sizes, Inches 6 9 12 18 24 36 i

For larger bolting where specific torque values are not stated and/or configuration precludes the use of j torque equipment, standard striking wrenches may be

used by qualified mechanics working to industrial journeyman standards, l:

i

! The technical basis for this note was a vendor valve manual

!' notation applying to stud n'uts and cap screws. The licensee had applied the torque values for diesel generators and other c valves to MOVs without any apparent engineering justificatio !

1 -(3) The post maintenance testing of valve HV-2246 was signed off by y

MQC as being complete when plant conditions would not support l > the operational test. Procedure MP 39.3, section 6.1, stated ,

I > that the post maintenance testing acceptance criteria was " Valve Stroke and limit switch settings are acceptable for system re-

c-*" quirements at operating pressure and temperature". There were no quantitative acceptance limits provided in the procedure to l *

'

determine this acceptability and MQC signed off this part of the procedure on February 23, 1985 for SSR 84500240. At this

!

time the reactor was shutdown and steam was being supplied to the helium circulators from the auxiliary boilers which are not capable of producing steam at operating temperatures and pressure ,

There was no outstanding action item to test this valve when the

'

plant was at normal operating temperatures and pressures. The i '. licensee had no assurance that this valve would operate as designed under expected operation conditions.

. Station battery maintenance and surveillance procedures were incon-

! sistent with the guidance provided by the battery vendor manua The following inconsistencies were identified:

.! (1) The battery ventilation low flow monitor was alarming in the

' control room and exhaust air flow from battery rooms 1A and IB

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appeared to be insufficient to meet the vendor manual recommen-dations for removing hydrogen gas during charging evolutions.

l (2) The upper temperature limit specified on the surveillance procedures for a battery receiving a float charge was 110* This was contrary to the vendor manual which recommended maximum allowable battery temperatures of 110*F during j

equalizing charge evolutions and only 90'F for float charge

conditions. The inspector observed a pilot cell temperature

! of 92'F in battery 1A on August 22, 1985. The battery vendor

' manual stated that continued operation at this elevated tem-

,

perature could degrade the battery capacity and life.

.

(3) Battery specific gravity and individual cell voltage (ICV)

measurements were not analyzed to determine whether an equali-

zing charge should be performed. The battery vendor manual

.- . , _ - . - , . . - . . , .-._,........__,_....-.-.~,-...y,_.--,-_ . , , , - . . . . . - ,m_ ,.._, y..,_.-.

f

.

. 'o .

.

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recommended that an equalizing charge be conducted when the specific gravity of any cell dropped .010 from an initial standard value or any cell ICV was below 2.13 VDC. Instead, the licensee performed an equalizing charge monthly in accor-dance with S0P 92-06. There was no in progress monitoring of these charges and the end of charge parameters were not measured to verify improved battery condition >

(4) There' were no procedures for periodically checking battery intercell resistances and connector tightness, adding water to individual cells, or cleaning the battery with approved solvent The apparent failure to establish, implement and maintain adequate battery, and MOV maintenance and testing procedures was discussed with the licensee and will be incorporated into unresolved item 50-267/85-26-02 for followup by the

,

NRC Region IV Offic . Post-Modification Testing The licensee did not ensure that all required post-modification tests 3a were developed as part of modification work packages. The NRC inspector reviewed Change Notices (CN's) 1798 and 1798-A and their associated Controlled Work Procedures (CWP's) 84-92, 84-93, 84-94, 84-95 and 85-560 which replaced Emergency Water Booster Pumps (Fire Water Booster Pumps)

P-2109 and P-2110 with pumps having a higher output head. These pumps could be used to drive the helium circulator turbine to achieve adequate core cooling in the event of the failure of three feedwater pumps. The CWP's for this modification did not contain post-installation flow tests

'

for the new emergency water booster pump The failure to develop adequate controls to ensure that all required post-modification testing was conducted was discussed with the licensee and will remain an unresolved item pending review by Region IV (50-267/85-26-06).

6. Unresolved and Open Items:

Unresolved items are matters about which more information is required to determine whether it is an acceptable item, a deviation, or a violatio A open item is a matter that requires further review and evaluation by the inspectors. The following unresolved and open items will be followed by the NRC Region IV offic (50-267/85-26-01) (0 pen Item) The revision of equipment control procedures to establish compliance with TMI Item I.C.6. This item will remain open

. pending NRC Region IV acceptance of the revised procedures (Item 2.a(1)).

(50-267/85-26-02) (Unresolved) The failure to establish adequate procedures for control of temporary plant modifications, station battery maintenance and surveillance tests, and motor operated valve maintenance. Also, the apparent failure to comply with procedures for battery surveillances and motor operated valve maintenance (Items 2.a(2), 3b, 3c, 4b, and 4c).

.. s,

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(50-267/85-16-03) (0 pen Item) The revision of housekeeping procedures to provide a means for ensuring specific deficiencies are corrected. This item will remain open pending NRC Region IV acceptance of the revised procedures (Item 2.c).

(50-267/85-16-04) (0 pen Item) The adequacy of the diesel generator valve lineup procedure to ensure the availability of the syste The item will remain open pending NRC Region IV followup of potential weaknesses in the lineup procedure (Item 2.d).

(50-267/85-26-05) (Unresolved) The failure to procure safety-related replacement items in accordance with the QA plan requirements (Item 4.a).

(50-267/85-26-06) (Unresolved) The failure to establish adequate

,

controls to ensure the performance of required post-modification

' testing (Item 5).

.?

7. The findings of this inspection were discussed with those persons indicated in paragraph 1 on August 29, 1985. e

.

1

O

's ,

J Enclosure (2) Program Requirements , " Surveillance Procedures and Records".

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Supplemental inspection program, , " Surveillance Testing and Calibration Control Program"

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Done once every three year , " Monthly Surveillance Observation"

- Done monthly by the Resident Inspecto , " Maintenance Program Implementation"

- Supplemental inspection procedur , " Maintenance Program"

- Done once every three year , " Monthly Maintenance Observation"

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D.one monthly by the Resident Inspector , " Instrument Maintenance"

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Supplemental inspection procedur , " Electrical Maintenance"

- Supplemental inspection procedur . 71701, " Operational Safety Verification"

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Done monthly by the Resident Inspecto . "ESF System Walkdown"

- Done bimonthly by the Resident Inspecto . Inspections conducted at Fort St. Vrain REPORT STAFF PCT NUMBER DATE HRS COMPLETE STATUS , " Surveillance Procedures and Records" 85-19 07/03/85 19 20 -- , " Monthly Surveillance Observation"

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84-01 02/29/84 10 100 C 84-10 03/31/84 6 100 C 84-13 04/30/84 6 100 C 84-14 05/31/84 10 100 C 84-22 08/31/84 3 100 C 84-29 10/31/84 10 100 C

, 84-34 01/31/85 3 70 85-03 02/28/85 3 100 C

.-. - . - _ . . . . . .- _ ._. ._ . _ . , _ - - . . - - _ .

.

• / ,

, , " Maintenance Program Implementation" 84-16 06/05/84 16 10 85-01 02/14/85 88 40 85-06 03/08/85 22 50 85-09 03/29/85 34 -60 85-12 04/19/85 35 70 .

85-16 06/28/85 30 100 C

! , " Monthly Maintenance Observation" 84-01 , 02/29/84 10 100 C 84-10 03/31/84 20 100 C 84-13 04/30/84 6 100 C

.84-14 05/31/84 6 100 C 84-15 -

06/30/84 8 100 C 84-18 07/31/84 4 100 C 84-22 08/31/84 32 100 C 84-26 09/30/84 12 100 C 84-29 10/31/85 10 100 C 84-30 12/07/84 27 100 C 84-34 01/31/85 18 100 C

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85-03 02/28/85 11 100 C 85-07' 04/30/85 65 100 C 85-14 05/31/85 27 100 C , " Operational Safety Verification" 84-01 02/29/84 54 100 C 84-10 03/31/84 40 85 C 84-13 04/30/84 28 70 C 84-14 05/31/84 36 80 C 84-15 06/30/84 48 90 C 84-18 07/31/84 35 50 C 84-22 08/31/84 50 90 C 84-26 09/30/84 26 80 C 84-29 10/31/84 35 100 C 84-30 12/07/84 15 50 C 84-34 01/31/85 15 100 C 85-03 02/28/85 21 100 C-85-07 04/30/85 40 100 C 85-14 05/31/85 25 100 C-2-t

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