IR 05000267/1987017

Insp Rept 50-267/87-17 on 870701-31.Violations Noted.Major Areas Inspected:Followup of Licensee Action on Previously Identified Insp Findings,Operational Safety Verification,Esf Walkdown & Monthly Surveillance Observation

ML20238B474
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/19/1987
From:	Farrell R, Jaudon J, Michaud P, Plettner E, Skow M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20238B462	List: IR 05000267/1987017 ML20238B459
References
50-267-87-17, NUDOCS 8709010237
Download: ML20238B474 (12)

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l APPENDlX A S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/87-17 License: DPR-34 Docket: 50 '267 Licensee: Public Service Company of Colorado (PSC)

Facility Name: Fort St. Vrain Nuclear Generating Station

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l Inspection At: Fort St. Vrain (FSV) Nuclear Generating Station, l

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Platteville, Colorado and PSC Offices, Denver, 1 Colorado Inspection Conducted: July 1-31, 1987 l Inspectors: M8 R. E. Farfell,L5enior Resident Inspector (SRI) Date i

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Michaud, Resident Inspector (RI)

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M. E. Skow, Project Engineer, Project Section A Date Reactor Projects Branch

& T 7/D A. Plettner, Reactor Project Inspector 'Da t e he 'E .

Approved: [ k/d [e'?

A. fl. Jau~fon, Chieft, Project Section A fDate

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{ R4actof Projects Branch 8709010237 e70828 PDR ADOCK0500g7 G

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Inspection Summary- j Inspection Conducted July 1-31, 1987 (Report 50-267/87-17)

Areas Inspected: Routine, unannounced inspection of followup of licensee action on previously identified inspection findings, operational safety verification, ESF walkdown, monthly surveillance observation, monthly maintenance observation, '

security, radiological protection and design contro Results: Within the eight areas inspected, four potential violations were identified (failure to follow procedure, excessive operator overtime, breaker l identification, and inadequate design controls). .

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l Persons Contacted Principal Licensee Employees I D. Alps, Supervisor, Security ,

o *F. Borst, Manager, Support Services / Radiation Protection

• L. Brey, Manager, Nuclear Licensing and Fuels ,

• R. Craun, Manager, Nuclear Site Engineering '

D. Evans, Superintendent, Operations

• Ferris, Manager, QA Operations l W. Franek, Superintendent, Plan / Scheduling & Stores d

• C. Fuller, Station Manager

• J. Gramling, Supervisor, Nuclear Licensing Operations  ;

• M. Holmes, Manager, Nuclear Licensing I

• M. Niehoff, Manager, Nuclear Design

• F. Novachek, Manager, Technical / Administrative Services i T. Prenger, Manager, QA Services )

• T. Stokoe, Engineer, Quality Assurance 1

• P. Tomlinson, Manager, QA R. Walker, Chairman of the Board and CEO

• D. Warembourg, Manager, Nuclear Engineering

• D. Weber, Nuclear Production

• R. Williams Jr. , Vice President, Nuclear Operations The NRC inspectors also contacted other licensee and contractor personnel ,

during the inspectio I i

• Denotes those attending the exit interview conducted August 3, 198 . Followup of Licensee Action on Previously Identified Findings (Closed) Violation (267/8429-02): Failure to Follow Procedures. This item related to refurbishment activity on Control Rod Drive 21. The NRC inspectors found that the licensee had taken the corrective action discussed in their response to the violation. In addition, when the licensee subsequently performed their refurbishment programs on the control rod drives, revised procedures were used and the assemblies were teste This item is close (Closed) Violation (267/8429-03): Failure to Follow Procedures. This item related to safety-related design changes. The NRC inspectors reviewed Administrative Procedure G-9, Issue 7, and Change Notice CN-1629. The change notice appeared to be complete. Procedure G-9 required the preparation of a "CWP DR/NCR Page Schedule" prior to transmitting procedure deviation reports and nonconformance reports for modificatio _-__

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l Procedure G-9 also provided administrative restraints to ensure proper d documentation and accountability of controlled work procedures. This item i is close J (Closed) Violation (267/8429-04): Design Verification. This item concerned failure to perform design verification for design changes. The i NRC inspectors reviewed Administrative Procedures G-9, Issue 7, " Controlled I Work Procedures," and Q-3, Issue 11, " Design Control System." The I procedures have been revised to require independent design verificatio I This item is close . Followup on Previous Inspection Findings 4 The following is a clarification of the status and relationship between items in NRC Inspection Report 50-267/87-10. The report included a Notice of Violation, which opened two violations. It was the intent of NRC-Inspection Report 50-267/87-10 that item 8704-03 be closed and incorporated into Violation 267/8710-01. It was also intended that Item 267/8704-06 be closed and incorporated into Violation 267/8710-02. Based on sufficient ;

licensee corrective action, the Violations 267/8710-01 and -02 were also considered close . Operational Safety Verification The NRC inspectors reviewed licensee activities to ascertain that the j facility is being operated safely and in conformance with regulatory '

requirements and that the licensee's management control systein is effectively di,scharging its responsibilities for continued safe operatio i 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, and review of facility record The NRC inspectors observed control room activities on all shift '

Operator alertness and attention to duty did not vary from shift to shif There was no letdown of operator diligence during night time hour Logs and records reviewed included:

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 Station service requests (SSR)

Licensed operator time sheets

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During tours of accessible areas, particular attention was directed to the following:

Monitoring instrumentation Radiation controls Housekeeping Fluid leaks Piping vibrations Hanger / seismic restraints Clearance tags Fire hazards  !

Control room manning Annunciators During a tour of accessible areas of the plant, the NRC inspectors noted that compressed gas bottle storage was not in compliance with plant policies and procedures. Superintendent of Operations Administrative l

Procedure (SOAP) -5, "FSV Operations Equipment Check and Performance Data Recording Procedure," Issue 3, requires in paragraph 4.3.2, " General Area  ;

Inspection Items," Item P (Safety Hazards), Sub-item 2 that gas bottles are l secured. This is normally verified by plant equipment operators during

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plant tour The NRC inspectors found a gas bottle on Elevation 4756 of the reactor building that was not secured by the two chains' on the stand provided to secure the bottl On the same plant tour, the NRC inspectors i found in the building housing the ACM diesel batteries, a pair of gas bottles secured by chains to a vertical steel bea However, the.two gas  ;

bottles were not of the same height and the shorter of the two bottles was l secured to the beam by a chain wrapped around the neck of the bottle. The i neck of the compressed gas bottle is its weak point and securing it by i the neck could lead to a bottle failure causing a missile in the area which could damage plant equipmen The above instances of improper securing of compressed gas bottles in violation of approved

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I plant procedures is an apparent violation of NRC regulations (267/8717-01).

When reviewing the time sheets for licensed reactor operators, the NRC inspectors noted that the plant generally runs very close to the guidelines provided in Technical Specifications, Section 7.1.1.2.1, which states, that,

" operators should not work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period." This issue had been discussed with senior plant representatives previously, because it appeared to the NRC inspectors that the licensee was near the limi Many instances of these limits being exceeded were identified. However, the Technical  ;

Specifications do exclude shift turnover time from these limit According I to plant management a turnover time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is expected for the shift I supervisor and 1/2 hour per day for-licensed reactor operators in the ,

control room. Additionally, the licensee allows an operator to charge 1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of additionel time for meals whenever the operator is required to work 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or more of overtime in one period. This meal time is not always identified on the time sheets as being different from time worke When reviewing the operator's time sheets, the NRC inspectors subtracted 1/2 hour per day from each reactor operator's charged time as shift

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turnover time. Additionally, the NRC inspectors subtracted 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of time '

from the operator's listed work time every time the operators charged time l

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l exceeded 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> This was done to allow for shift turnover time and )

charged meal time and to conservatively gauge the actual time worked by the >

licensed reactor operators. Even with these adjustments, there were 2 instances when operators worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day perio Specifically, in 1 time period of 7 days, a senior reactor operator charged  !

81 1/2 hours of work. In another 7-day period, a reactor operator charged  !

81 1/2 hours. Subtracting 3 1/2 hours for shift turnover for 7 days and 1 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for meals for the 5 times when the overtirue exceeded 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in each case, each of these operators worked 73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> in a 7-day period. The excessive overtime appeared to be the result of operator vacations and other absences coupled with an operator shortage. There are operators now in training and this issue has been addressed in SALP. This is an apparent -

violation of the Technical Specification (267/8717-02).

5. ESF System Walkdown l l

The NRC inspectors performed a complete walkdown of the essential and j emergency electrical distribution systems. Applicable' sections of the '

FSAR, Technical Specifications, and reference design manual were reviewed by the NRC inspectors to ensure familiarity with the systems and requirement Plant drawings and diagrams were used to aid the NRC inspectors and were l compared to the as-found configuration to determine their agreemen '

Conditions of equipment, including the interior of selected panels, were inspected for any items which might degrade performance or affect safet Availability of an alternate power source was verified where appropriate and local and remote breaker positions were compared. Included in the walkdown were the 4160 VAC, 480 VAC, 120 VAC, and 125 VDC distribution j system The 120 VAC vital distribution system had a number of discrepancies between the plant drawings and the breaker directories on the individual cabinet door Breaker directories are a list of breaker numbers with their associated titles; individual breakers have only a number attached for identification. These directories were prepared in January 1987 and approved as operator aids by PORC on February 10, 1987. Prior to this, these breakers were identified with labeling tape directly on the breaker The discrepancies identified by the NRC inspectors were between Drawings E-1097 and E-1098, key diagrams for the 120 VAC vital distribution system, and the breaker directories for:

Identification of Breakers 8A, 11A, 14A, 1B, and rating of Breaker 17B '

on 120 VAC Bus Identification of Breakers 11A and 11B on 120 VAC Bus Identification of Breakers 17A, 14B, 8C, 100, 18C, 200, 26C, and ratings of Breakers 12C, 17C, 19C, 200, 21C, 23C on 120 VAC Bus 3.

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The NRC inspectors discussed these findings with plant management, operations, electrical, and results personnel. These individuals indicated the breaker directories had been physically walked down in mid-1986, prior I to their preparation as operator aid The 125 VDC distribution system was {

also walked down at that time and no discrepancies were identified on that J syste There were no problems with any equipment supplied by the 120 VAC ]

vital distribution system not having power available because of the i apparent mislabeling and the discrepancies would likely not have been identified except in a direct audit or inspection of the syste I Criterion V of 10 CFR 50, Appendix B and the licensee's quality assurance l plan requires activities affecting quality .to be prescribed by instructions, 1 procedures, or drawing The licensee's failure to correctly identify I

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vital electrical distribution breakers is an apparent violation (267/8717-03). No violations of this nature had been previously identifie No other violations were identified in this are . Monthly Surveillance Observation During the inspection period, the NRC inspectors observed calibration of ,

the linear power channels in accordance with Procedure SR 5.4.1.1.4.b-M/ l 5.4.1.4.2.b/M, " Linear Power Channel Scram Test," Issue 46. During the i calibration, the technicians reset the rod withdrawal prohibit and scram  !

setpoints from the setting for operation between 0 and 45 percent of reactor power to those settings for operation between 45 and 70 percent of reactor power. The NRC inspectors, also observed the 10-inch control rod scram test performed weekly on all rods and performed daily on the hottest single control rod drive when any of the control rod drive shim motors register a temperature above 215 F in accordance with interim Technical Specifications committed to by the licensee as part of the control rod drive refurbishment progra Additionally, the NRC inspectors monitored reactor operators' verification of compliance with Technical Specification LCOs, routine shif t surveillance, monitoring of reactor parameters, and reviewed at length with plant management and the Office of Nuclear Reactor Regulation compliance with LC0 4.1.7, which provides a curve for allowable core outlet temperature

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versus core inlet temperature in Technical Specification Figure 4.1.7-1.

' The plant's practice has been to operate, not only on the graph but on curves obtained by extrapolating the graph that is contained in the Technical Specifications. The purpose of the graph and the LCO is to limit power peaking factors and preclude fuel temperatures which could lead to l fuel degradation. After review with NRR and with GA Technologies personnel l involved in the origination of this Technical Specification, it was concluded that the practice is acceptable but the NRC inspectors and NRR

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personnel recommended that the licensee, as part of its Technical Specification upgrade program, provide a new graph as part of the LC0 which includes the extrapolated curves to which the licensee operates.

l No violations or deviations were identified in this inspection are . Monthly Maintenance Observation During the course of the inspection period, the NRC inspectors had the opportunity to observe routine maintenance and calibration performed on the linear power channels of the reactor, on the flux controller, and on miscellaneous plant equipmen Additionally, the NRC inspectors reviewed at length with operations and maintenance management the troubleshooting activities involved in the l circulator high speed trip, which occurred July 22, 1987. The NRC '

inspectors also reviewed the subsequent plans to remove and replace the i

"D" helium circulator, which showed unacceptably high vibration. This will '

be a major outage of approximately 6 weeks duration. It involves substantial removal of interferences and connecting auxiliary systems lines in order to remove the helium circulator which is installed inside the reactor pressure vesse The licensee appears to be applying those ,

techniques of planning and scheduling obtained during the environmental i equipment outage of 1986/8 It was noted during the troubleshooting of the circulator high speed trip and the planning for the circulator replacement outage, that the licensee is showing a conservative and generally well thought out approach to maintenanc No violations or deviations were identified in this inspection are . Security The NRC inspectors verified that there was a lead security officer (LS0) on duty authorized by the facility security plan to direct security activities onsite for each shift. The LSO did not have duties that would interfere with the direction of security activitie The NRC inspectors verified, randomly and on the backshift, that the minimum number of armed guards required by the facility's security plan were presen The NRC inspectors verified that search equipment, including the x-ray i machine, metal detector, and explosive detector, were operational or a 100 percent hands on search was being utilize ,

The protected area barrier was surveyed by the NRC inspectors. The barrier was properly maintained and was not compromised by erosion, openings in the fence fabric, or walls or proximity of vehicles, crates or other objects that could be used to scale the barrie '

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The NRC inspectors observed the vital area barriers were well maintained j and not compromised by obvious breaches or weaknesse The NRC inspectors observed access control procedures from the secondary alarm station where they could observe shift change without being observe The NRC inspectors observed that persons granted access to the site are-badged indicating whether they had unescorted or escorted access authorizatio ]

l No violations or deviations were identified in this inspectio'n are ! Radiological Protection l

The NRC inspectors verified that required area surveys of exposure rates i were made and posted at entrances to radiation areas and in other appropriate areas. The NRC inspectors observed health physics professionals on duty on all shift The NRC inspectors observed the health physics techr.icians checking area radiation monitors, air samplers, and doing area j surveys for radioactive contaminatio The NRC inspectors observed that when workers were required to enter areas j where radiation exposure is probable or contamination possible the health l physics techai::ians were present and available to provide assistanc No violations or deviations were identified in this inspection are j 10. Design Control  ;

During this inspection period, the NRC inspectors reviewed the temporary configuration report (TCR) log maintained in the control room. There are approximately 100 TCRs, which have been long standing in the log and installed in the plant. Temporary configurations are used for testing and other considerations that do not require a permanent design' chang Consequently, temporary configurations are reviewed by the licensee to assure that they will not be detrimental to plant operation for an undefined but relatively short period of time. TCRs do not receive the same depth of review as do permanent design change The NRC inspectors noted that there is an outstanding open item (267/8714-01) concerning the ft ct that no definition of " temporary" is included in the licensee's te> 70rary configuration progra Since there is no definition of

" temporary," the NRC inspectors concluded that the outside limit of

" temporary" is one refueling cycle. The NRC inspectors, also, concluded that since the plant has been shutdown for the majority of the last 3 years allowing time to make permanent modifications, temporary. configurations ,

installed in the plant for a period of several years, were permanent design '

changes. There are approximately 100 such TCRs installed in the plant that appear to be defacto permanent design change The NRC inspectors noted that the licensee's QA audit of this area identified similar problems, but corrective action has been slow. Examples of TCRs installed in the plant are:

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1 TCR 85-11-05, which superseded TCR 82-10-15', dated October 25, 1982, installed 1/4-inch copper lines with pressure gauges to test reactor vessel penetrations; this had been installed for approximately 5 year TCR 85-11-06, which superseded TCR 82-05-03, dated May 27, 1982, installed a pressure differential indicator to monitor compliance with Technical Specification LCO 4.2. This temporary change had been ;

installed for approximately 5 year TCR 86-04-04, which superseded TCR 85-12-15, which superseded TCR 81-08-65, which superseded a temporary change done under 4 Procedure ADM-22, Form 1, Number 6-15 originally installed June 25, l 1979, installed a level control on one valve and a manual control on another valve; both of these valves are seismically qualified and required for reactor vessel depressurization following a design basis event. This temporary change had been installed for approximately 8 year TCR 86-02-04, which superseded TCR 84-08-05, originally installed December 3, 1984, placed isolating transmitters between instrument connections and a recorder to monitor compliance with Technical Specification LCOs 4.2.1 and 4.2.2. This temporary change had been installed for approximately 3 year TCR 86-01-24, which superseded TCR 81-08-81, which superseded ADM-22, Form 1, Number 11-14, originally installed November 9, 1977, lifted leads to allow the moisture monitor low flow alarm system to comply with the existing Technical Specifications. This temporary change had been installed approximately 10 year TCR 85-12-25, which superseded TCR 81-08-54, which superseded ADM-22, Form 1, Number 2-7, originally installed February 10, 1976, added temporary TCs (thermocouple) to measure ambient temperature and flow element temperature in the moisture monitor penetrations. This was to l assure compliance with LC0 4.4-1, Table Note t(3) Page 4.4-9 of the Technical Specifications. This temporary change had been installed i for approximately 11 year TCR 86-01-29, which superseded TCR 83-05-12, originally installed May 13, 1983, installed nupro "T" type filters on the inlet sample lines to the PPS moisture monitors. The PPS is the plant protection system. This temporary change had been installed approximately 4 year TCR 86-01-21, which superseded TCR 81-06-07, originally-installed June 24, 1981, installed leads in 105 for connecting a recorder on the indication to ME-9306, ME-9307. ME-9306 and ME-9307 are the plant protection system moisture monitors. This temporary change had been installed approximately 6 year l

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Performing these changes under temporary configuration reports appear to be a violation of the design control process required by Criterion III of 10 CFR 50, Appendix B, and the licensee's approved quality assurance program. This is an apparent violation of NRC regulations (267/8717-04).

11. Exit Meeting 1 An exit meeting was conducted on August 3, 1987, attended by those identified in paragraph 1. At that time the NRC inspectors reviewed the i scope and findings of the inspectio {

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APPENDIX'B AGENDA FOR ENFORCEMENT CONFERENCE Date: September 10, 1987 I Time: 1:00 III. Place: NRC Region IV Office, Arlington, Texas I Agenda:  ;

1 Opening Remarks by R. Hall, Acting Division Director Discussion of Inspection Findings Related to Temporary Change Requests by J. P. Jaudon, Chief, Project Section A Licensee Response Discussion of Enforcement Policy by D. Powers, Enforcement Officer i

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