IR 05000267/1986025
| ML20215N835 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/30/1986 |
| From: | Chamberlain D, Farrell R, Jaudon J, Michaud P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20215N821 | List: |
| References | |
| 50-267-86-25, NUDOCS 8611070326 | |
| Download: ML20215N835 (11) | |
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r APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-267/86-25 License: DPR-34 Docket: 50-267
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Licensee: Public Service Company of Colorado (PSC)
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Facility Nanie:
Fort St. Vrain Nuclear Generating Station Inspection At:
Fort St. Vrain (FSV) Nuclear Generating Station, Platteville, Colorado Inspection Conducted: August 16 through September.30,1986 h
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Inspectors:
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'R. E. Farrell, Senior Resident Inspector (SRI)
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/d-9,!FL P. W.~ Michaud, Resident Inspector (RI)
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"4 Ah D. D.6 Chamberlain, Reactor Inspector Date Approved:
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J. P/. JaLddtr,-thief, P& ject S6ction A D6te '
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Rbctor Proksets Branch
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Inspection Summary Inspection Conducted August 16 through September 30, 1986 (Report 50-267/86-25)
Areas Inspected:
Routine, unannounced inspection of operational safety
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verification; surveillances; maintenance; security; design, design changes, and modifications; and followup of contamination incident / allegation 4-86-A-080.
Results: Within the six areas. inspected, five violations were identified (failure to follow procedures paragraph 2, failure to review modification control procedures paragraph 6, failure to sufficiently document design verification paragraph 5, failure to periodically t'est flow orifice valve limit paragraph 6, and failure to implement corrective action program -
paragraph 6).
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DETAILS-1.
Persons Contacted Principal Licensee Employees-D. Alps, Security Supervisor
- T.- Borst, Support Services Manager / Radiation Protection Manager
- D. Brown, I&C Supervisor
- R. Burchfield, Superintenc'r it Nuclear Betterment
- J. Capone, Licensing Engineer
- R. Craun, Site Engineering Manager M. Deniston, Shift Supervisor
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J. Eggebroten, Superintendent Technical Services Engineering D. Evans, Superintendent Operations
- M. Ferris, QA Operations Manager
- C. Fuller, Station Manager
- A. Greenwood, Supervisor Quality Assurance Auditing
- S. Hofstetter, Nuclear Licensing Engineer
- J. Gahm, Manager Nuclear Production
- T. McIntire, Supervisor Nuclear Site Engineering
- F. Novachek, Technical / Administrative Services Manager
- T. Prenger, QA Services Manager
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- L. Singleton, Manager QA
- D. Warembourg, Manager Nuclear Engineering
- J. Wojtisek, Plant Engineer The NRC inspectors also contacted other licensee and contractor personnel during the inspection.
- Denotes those attending the exit interview conducted August 22, 1986.
- Denotes those attending the exit interview conducted October 3, 1986.
2.
Operational Safety Verification
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The NRC inspectors reviewed licensee activities to ascertain that the facility
is being operated safely and in conformance with regulatory requirements and that the licensee's management control system is effectively
. discharging its responsibilities for continued safe operation.
The review was conducted by direct observation of activities, tours of the facility, interviews and discussions with licensee personnel, independent-verifications of' safety system status and limiting conditions for operation, ar.d review of facility record.
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Logs and records reviewed included:
Shift supervisor logs
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Reactor operator logs.
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Equipment operator logs
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Auxiliary operator logs
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Technical specification compliance-logs
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Operations order book
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Operations deviations reports
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Clearance log
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Temporary configuration reports
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Station service requests (SSR)
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.During tours of accessible areas, particular attention was-directed to the following:
Monitoring instrumentation
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Radiation controls
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Housekeeping
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Fluid leaks
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Piping vibrations
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Hanger / seismic restraints
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Clearance tags
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Fire hazards
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Control room manning
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On September 9, 1986, the SRI observed portions of the 8:00 a.m. to 4:00 p.m.' shift turnover to the 4:00 p.m. to midnight shift.
The shift supervisor being relieved was unable to turn the vital area and critical valve keys over to his relief as he did not have them in his possession.
The previously relieved shift supervisor (midnight to 8:00 a.m. shift)
when contacted at home did have the vital area and critical valve keys.
The keys were immediately returned to site by the off' duty shift supervisor.
The SRI checked the completed shift turnover procedure for the 8:00 a.m.
shift turnover of September 9, 1986.
There is.an item for checking that the vital area and critical valve keys are properly turned over.
The completed' procedure with all items checked is signed by the oncoming shift supervisor signifying completion of shift turnover.
This was done for the 8:00 a.m. shift turnover, and the vital area and critical valve keys were indicated as having been received by the oncoming shift supervisor, yet the keys had not been turned over.
This failure to follow procedures is an apparent violation.
(267/8625-01)
3.
Surveillances
.The NRC inspectors reviewed licensee activities to verify and maintain the quality of diesel fuel oil to power the emergency diesel generators, diesel driven fire water pump, and alternate cooling method (ACM) diesel.
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There are no surveillances specified in the licensee's Technical Specifications; however, the licensee does test the fuel oil to assure its quality.
The emergency diesel generator fuel oil tanks are tested monthly ~
with the sample taken using a tool called a " Tulsa Oil Thief." This tool allows the technician to take a' column sample of fuel in the elevation 1-inch to 13-inches off the bottom of the tank.
A second sample is taken in the elevation 6-inches to 18-inches from'the bottom of the tank (suction from the tank is taken at the 6-inch level).
If water or sludge
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is present, the chemistry department generates a maintenance request to have the bottom of the tank pumped out until the testing no. longer shows the presence of water or sludge.
This same sampling technique and frequency is utilized for the auxiliary boiler fuel oil tank which supplies the ACM diesel.
The diesel driven fire water pump is supplied by an above ground tank that serves as a storage tank and day tank.
This tank is not sampled, however, each supply of fuel oil brought on site is sampled as its delivered.
Between the auxiliary boiler fuel tanks and the ACM diesel day tank, there are a series of fuel oil filters, one up stream and one down stream of the transfer pump.
Between the ACM day tank and the ACM diesel,-there are two filters, one filter up stream of the fuel pump and one filter (two in parallel) downstream of the fuel pump.
The licensee's preventative maintenance plans call for semiannual change of the engine fuel oil filter elements, as needed cleaning of the filters between the fuel oil storage tank and the diesel day tank, and quarterly draining of condensate from the bottom tap of the day tank.
The diesel driven fire water pump has a screen, magnet, and fuel oil filter between the fuel oil storage tank and'the engine.
All are cleaned or changed as needed.
The emergency diesel generator day tank normally takes suction from the diesel generator fuel oil storage tanks.
There is one-' filter between the storage tank and the transfer pump to each day tank. -The alternate source to the diesel generator day tanks is the auxiliary boiler fuel oil tank, there is one filter upstream of the transfer pump and one filter downstream of the transfer pump; both upstream of the day tanks.
There are six fuel oil filters in series between each day tank and engine.
The licensee's preventative maintenance on the emergency diesel generator fuel systems are to clean the filters between the auxiliary boiler fuel oil tank and the engine day tank based on differential pressure readings across the filter, to change the day tank filter every 2 years and to change the engine fuel oil filters annually.
No violations or deviations were identified in this inspection area.
4.
Maintenance The NRC inspector witnessed the testing of motor operated valves utilizing M0 VATS equipment.
IE Bulletin 85-03 was reviewed to determine its requirements and whether the testing in progress met those requirements.
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- In response to this bulletin, the~ licensee has identified 16 motor-
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operated valves in letter.P-86356 of May 14, 1986, which require a program i
to' ensure the. switch settings are properly determined, set, and maintained.
Part of the program'is-to record the "as found" switch settings in accordance with the.IE Bulletin.
Since the licensee has~
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planned maintenance which will involve-disassembly.of each of the 16
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valves,'the as found switch settings are being recorded on all valves
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The.NRC inspector reviewed the procedure,-MPE1675-EQ, Issue 1, which. tests,
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reco_rds, and adjusts the motor operator switches.
The procedure appeared
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to be complete. As explained by the licensee, this phase of the program
'was solely to obtain the initial."as found" information.
However, out-of-tolerance switch settings would be corrected during this initial test in accordance with.the procedure.
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i The NR(, inspector observed ongoing equipment qualification work including.
installation of RAYCHEM splices and operability tests on solenoid valves in the reserve shutdown system.
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The NRC inspector observed mechanical maintenance on valve HV2215, Loop 1~
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Steam / Water Dump Valve, including hydraulic actuator removal and valve
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disassembly, reviewed procedure-MP 3712,. Revision 3, " Repair and Maintenance of Rockwell-Edwards Forged and Univalves," and procedure MP22,.
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" Maintenance and Repair of Rockwell-Edwards Valves, Pressure Seal. Type."
i Two sections of procedure MP-22 were.specified on SSR 86506300, dated August 27, 1986, for the. removal and replacement of.the hydraulic actuator
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since these steps are not included in procedure MP-37.-2.
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The NRC inspectors reviewed two documents _" Instructions for Assembly and'
l Maintaining High Seismic Racks for.Exide Batteries" and " Instructions for Installing and Operating Stationary Batteries" (also an Exide document) to determine the proper mounting configuration of the station Class 1-E
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batteries to comply with the seismic analysis of these batteries. The inspectors examined the station Class 1-E batteries to determine compliance with the manufacturers mounting instructions.
The batteries
j are mounted in accordance with the manufacturer's-instructions.
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No violations or deviations were identified in this-inspection area.
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5.
Security L
During this inspection period, the licensee continued work to upgrade the
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se_curity systems.
The NRC inspectors observed cable pulling, concrete placement, installation of towers for. closed circuit television, and
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-installation of microwave antennas.
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No violations or' deviations were identified in this inspection area.
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6.
Design,-Design Changes, and Modifications This area of inspection was conducted to evaluate the licensee program for control of design changes and modifications and to verify that changes.are being evaluated and reported to the'NRC in confonnance with the'
requirements of 10 CFR Part 50.59. 'The NRC inspector selected four change.
notices (CNs) from the latest " Annual Report of Changes, Tests, and Experiments not Requiring Prior Comission Approval Pursuant to 10 CFR 50.59" for a detailed review. These four were:
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CN 1272 Establish separate power sources to the two computer power
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distribution panels.
CN 1629 Install current limiting reactors on 480 volt motor control
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centers.
CN 1709 Install temperature sensors and monitoring system on co'ntrol
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rod drive and orifice assembly system.
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CN 1876 Modification to allow continuous movement of the flow
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orifice valves.
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In addition, ten CNs were selected from the licensee CN list to evaluate the basis for not including them on the annual report. The review of these ten additional CNs revealed that they were either included in a previous annual report submittal or the safety evaluation properly documented that the. change had no effect on the FSAR or Technical Specifications.
'Also, the NRC inspector reviewed the backlog status of plant modifications. The licensee stated that 841 proposed changes had not been entered into the design process and cnother 461 were at some stage of completion, but not closed out. The licensee has initiated a priority system for proposed changes which is intended to reduce the, backlog. This priority program is planned to be fully operational by the end of the
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j present equipment qualification outage. The backlog status of plant
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modifications will be monitored during future NRC inspections.
The review of the four change notice packages revealed four apparent violations and certain areas were noted where the licensee may be able to
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-strengthen the program. The apparent violations are discussed below:
Procedures ENG-1, " Control of Modifications and Documentation;"
ED-100, "CN Preparation and Document Control;" and CWPM, " Controlled Work Procedure Manual," were not reviewed by the plant operations review comittee (PORC), although Technical Specification section 7.4.b required that general procedures and administrative policies for control of modification work be reviewed by PORC. This apparent violation may apply to a number of procedures in addition to
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the three identified. 'This failure to review modification control procedures was identified by the NRC inspector as an apparent violation.
(267/8625-01)
The person performing the design. verification process for CN.1876 did not document their effort-in sufficient detail to provide a record of their work as-required by procedure ENG-1, " Control of Modifications.
and Documentation." The NRC inspector found that the " Check List cf Design Verification Question for Design Review Method" form for CH 1876 was signed and dated on one date and was initialed and dated on three subsequent dates with no details provided as to what was
. verified on each date. Also, no details were provided to record that each design sketch included in the CN package was checked by the design verifier.
This failure to sufficiently document the design verification was identified by the NRC inspector as an apparent-violation.
(267/8625-02)
The safety evaluation for.CN-1876 stated that the limit trip' feature in the close position for the flow orifice valves is required to be tested on a periodic basis to verify their design function of preventing an orifice valve from reaching the full closed mechanical stop.
The NRC inspector found that no provisions had been provided for periodic testing of the limit trip feature.of these orifice valves.
This was discussed with plant staff personnel and they stated that the valves could not be stroked to the 1.5 percent limit
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during plant operations or during outages due to the need for controlled core cooling at all times.
However, the NRC inspector concluded that the limit trip feature could be tested by simulating the 1.5 percent limit (as is done during calibration of the limit switch) and verifying that the valve will not move in the close direction.
The valves are routinely, stroked a small percentage in the open and close direction and this test could possibly be performed during'a routine stroking as required.
The licensee's approved quality assurance program requires that testing following-modifications be conducted when specified by the Change Notice package.
This failure to periodically test the flow orifice valve limit as specified by the Change Notice package was identified by the NRC inspector as an apparent violation.
(267/8625-03)
The installation instructions for CN 1876 noted that numerous
- discrepancies were identified with the existing vendor drawing.and these discrepancies were corrected as they were identified.
However, no corrective action was ini.tiated to review areas not affected by-the CN for similar discrepancies.
The NRC inspector would expect that the quality assurance (QA) review of CNs would.cause a corrective action program to be implemented when problems of this nature are documented.
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Criterion XVI to 10 CFR Part 50, Appendix B, requires that me'asures be established to assure that deficiencies are promptly identified
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and corrected. This. failure to implement a corrective action program when deficiencies were identified with vendor drawings was identified by the NRC inspector as an apparent violation.
(267/8625-04)
In addition to the above noted violations, the NRC inspector noted certain areas where the licensee may be able to strengthen the design control
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programs. The following items are provided for licensee consideration for program improvement:
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Design and work control procedure interfaces are not clear in some
instances.
For example, the CN forms are not always being signed by
the plant operations review committee (PORC) but the associated
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controlled work procedures (CWP) are being stamped by PORC when the
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CN and CWP are reviewed.. Also, some test requirements are. delineated in the CN and some are delineated in the CWP, but the procedures do not clearly' state where they should be contained.
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The modification control program does not presently address the maintenance of equipment qualification during the change notice process. The licensee stated that procedures are being modified or developed to address this issue.
Training requirements for plant modifications are addressed as a
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parallel activity during the change notice development, but there is no required feedback with training prior to returning a system to service.
The documentation package for CN 1876, which provides for continuous
movement of the flow orifice valves instead of the original' design of a timed step movement, did not contain any evidence that the basis
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for the original design was investigated. The licensee was able to produce a memorandum which documented that the original design basis was discussed with-General Atomic. The NRC inspector believes that this type of information should be included in the CN package. The basis for the original design could be discussed in the design input section of the CN package.
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The licensee does not date design sketches included in CN packages
and they do not identify the revision of~the original design document that is affected by the CN.
It is not clear to' the NRC inspector how
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p the licensee maintains control of the design document, revision
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process with these practices.
The NRC inspector noted that the licensee had made several changes in the design control process procedures within the last year. Three problem l
areas that were. identified by the NRC inspector with the older CNs that were reviewed had also been identified by'the licensee and procedure
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cnanges naa oeen implementea to prevent recurrence.
These i.iiree proisiem areas.that were identified, and procedures that were revised as a result were:
CN 1272 had mark outs on the installation instructions with no initials and date.
Procedure Q17, " Quality Records," had been revised to require that errors made be lined through, initialed and dated so that they could still be read and so that it was clear by who and when the record was changed.
There was no evidence of QA/QC involvement with performance of cold checkout testing (CCT) or functional testing (FT).
Procedure Q11,
" Test Control," had been revised to require QA/QC to identify hold and inspection points for CCT and FT test performance as appropriate.
CCT and FT results were not being reviewed after test performance.
Procedure Q11, " Test Control," was revised to require documented reviews of completed CCT and FT tests.
Conclusions and Recommendations Although some administrative problems and potential improvement areas were identified with the plant modification control program, it was evident that the licensee has made progress in identifying program improvements and all of the safety evaluations reviewed were detailed and in conformance with the requirements of 10 CFR Part 50.59.
The NRC inspector reviewed a relatively small sample of plant modifications and all reviewed were completed more than a year earlier.
As noted previously, the licensee has made several improvements in the modification control procedures and the NRC inspector did not specifically review the present program implementation.
The NRC inspector recommends that this area be reviewed again after the licensee responds to the identified findings and that the review be directed toward recently completed and/o. in process plant modifications.
7.
Followup of Contamination Incident / Allegation 4-86-A-080 Closed (Allegation 4-86-A-080):
On August 6, 1986, three workers decontaminating the hot cell facility at FSV discovered minor facial contaminatioa while self-frisking.
The workers were decontaminated by health physics, frisked, determined to be free of contamination, and allowed to go home.
The following day, the workers requested whole body radiation counts and one worker was discovered to have minor contamination.
The SRI reviewed the incident, reviewed the procedures used to calibrate the whole body counter, and interviewed the health physics technicians and radiochemistry technicians and supervisor to determine if the frisking, decontamination, and whole body counting activities were properly conducted.
The following is a narrative description of the licensee's activities in this are,a
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0:: nuge:t 5,1985, the thfee werkers decenteinating +he hot. cell were.
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observed periodically, but not continuously, by a' health physics
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technician. The health physics technician had to tell the workers several times not to touch their faces with their' gloved hands while working.in-a contaminated area.' When the workers exited the contaminated area they frisked with'a radiation detector to determine if they were contaminated.
Each worker discovered areas of facial contamination. The health physics technician was notified and escorted the workers to the health physics l
office where they were decontaminated with soap and. water..The workers were refrisked, determined to be free of contamination, and released. The
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workers requested whole body counts as a precautionary measure to determine if there was any additional contamination.
No results of this count were expected by health physics.
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l On August.7,.1986, the workers were whole body counted in the radiochemistry laboratory.
One worker was found to have some external contamination. The contaminated worker showered in the health physics
. facility and was then recounted wearing a paper jumpsuit which was
determined not to be contaminated.
Upon recounting, he was determined to be free of contamination.
-The inability of the frisker to detect contamination which was detected by the whole body counter is attributed to the much greater sensitivity of-the whole body counter and the-very small. amount of contamination detected.
The whole body counter is calibrated assuming the radiation detected is internal to the human body.
The radiation detected in this-
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case was the equivalent of 4.119 X 10-2 microcuries of Cobalt-60 if the
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contaminant was inside the lungs and shielded by the body.
Since showering removed the contamination, it was on the surface of the body and
consequently much smaller than 4.119 X 10-2 microcuries since it was not
' attenuated by shielding. The whole body counter was calibrated in accordance with the licensee's procedures utilizing sources traceable to-
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the. National Bureau of Standards.
It is routinely checked prior to usage:
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and had been checked at 7:23 a.m. (MDT), the day these workers were counted, the first worker counted was counted at 8:04 a.m. MDT, and was
the worker that had the contamination.
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The contamination detected via whole body counting was substantially below the amount of contamination permissible by regulation or the amount of
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- contamination that would cause' concern.
The licensee's actions were in accordance with'NRC regulations and the licenseC s procedures.
. This matter is considered closed.
8.
Exit Meetings
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Exit meetings were conducted August 22, and October 3, 1986, at which times the inspectors reviewed the scope and findings of the inspection.
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