ML19294B937

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IE Insp Rept 50-267/79-22 on 791201-28.Noncompliance Noted: Failure to Follow Procedures & Write Procedure
ML19294B937
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 01/10/1980
From: Collins R, Rich Smith, Westerman T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19294B928 List:
References
50-267-79-22, NUDOCS 8003060428
Download: ML19294B937 (10)


See also: IR 05000267/1979022

Text

U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

IE Inspection Report No. 50-267/79-22

Docket No. 50-267

License No. DPR-34

Licensee:

Public Service Company of Colorado

P. O. Bcx 840

Denver, Colorado 80201

Facility Name:

Fort St. Vrain Nuclear Generating Station

Inspection At:

Fort St. Vrain Site, Platteville, Colorado

Ins;' action Conducted:

December 1-28, 1979

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05'd dO'

Inspectors:

/

fl. W. Dickerson, Senlogesident Reactor Inspector

Date

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R'.Smitn,Repctordnspector

Date

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4. E. Col tiny, Resident / Reactor Inspector

Date /

Approved By:

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'T. F. Westerman, Chief, Reactor Projects Section

Date

Inspection Summary

Inspection December 1-28, 1979 (Report No. 50-267/79-22)

Areas Inspected:

Routine, announced inspection of Reserve Shutdown System;

Radiation Protection; Surveillance; Part 21 Report; Maintenance; Physical Security;

Plant Operations; Training; Requalification Training; followup on itemt of non-

compliance; and followup on inspector identified and unre' alved problems.

The

inspection involved 168 inspector-hours on-site by three (3) NRC inspectors.

Results:

Within the eleven (.11) areas inspected, two items of noncompliance were

identified (infraction - failure to follow procedures (.two examples), paragraphs

4 and 8; infraction - failure to write a procedure as required by Technical

Specifications, paragraph 4).

8003060 f

.

-2-

DETAILS

1.

Persons. Contacted

L. Brey, QA Manager

W. Crane, Maintenance Superintendent

W. Franek, Results Supervisor

J. Gamm, Supervisor Technical Services

E. Hill, Superinter. dent of Operations

W. Hillyard, Administrative Services Manager

J. Liebelt, Electrical Supervisor

T. Mathie, Operations Manager

J. Solakiewicz, Superintendent Operations QA

G. Turner, Supervisor of Security

D. Warembourg, Manager Nuclear Production

The inspector also contacted other plant personnel including reactor

operators, maintenance men, electricians, engineers, technicians and

administrative personnel.

2.

Licensee Action on Previous Insoection Findinas

(0 pen)

Unresolved Item (.50-267/7512-1): Records Procedure.

The records

procedure is to be changed to reflect the requirement for record retention

periods.

The change is expected to be completed by January 1, 1980.

(Closed) Open Item (50-267/76-09):

Compliance with ANSI N45.2.11, Quality

Assurance requirements for the design of nuclear plants.

The licensee

has completed and implemented procedures QAP 1400, QAP 1700, IWP 2 and

ENG 1 and 2, in accordance with the requirements of ANSI N45.2.11 - 1974.

(0 pen) Unresolved Item (50-267/7714-1):

Pulled Fuses.

The licensee has

indicated that the required input for a procedure for the control of fuses

will be completed by May 1, 1980.

(Closed)

Unresolved Item (50-267/7901-2):

PROC Review of TS 7.1.2.e(7)

requirements.

The Plant Operations Review Committee has initiated review

of additional areas of reactor operation as specified in a PORC policy

memo.

(Closed) Open Item (50-267/7912):

Status tags not controlled.

Changes have

been made to ADM-10 which provide for use and control of the status tags.

(Closed) Unresolved Item '50-267/7914): ACM diesel generator doors

unlocked.

Keys for the diesel generator doors are now controlled by the

shift supervisor and instructions for security checks of the doors by the

guards have been issued.

-3-

(Closed) Item of Noncompliance (50-267/7915):

Valves found not sealed,

valves found closed, and no PTR written for inoperative recorder.

The

inspector has reviewed the corrective action specified in the licensee's

letter dated December 3,1979 and this matter is considered closed.

3.

Physical Protection

The inspector reviewed portions of the licensee's physical protection

program by review of selected records and observation of the activities

of access control, search, escorting, and communications.

No items of noncompliance or deviations were identified.

4.

Review of Plant Ooerations

A review of plant operations was conducted to ascertain whether facility

operation was in conformance with the requirements established in Technical

Specifications,10 CFR, and Administrative Procedures, ar licensee

commitments discussed in correspondence to the Commission.

Included in the inspection were observation of control room activities,

review of operational logs, records, and tours of accessible areas.

Logs

and records reviewed included:

Shift Supervisor Logs

.

Reactor Operator Logs

.

Technical Specification Compliance Log

.

Operating Order Book

.

Form 1 Log (Jumper Log)

.

Plant Trouble Reports

.

Selective Valve Lineups

.

During the tour of accessible areas, particular attention was directed to

the following:

Monitoring Instrumentation

.

Radiation Controls

.

Housekeeping

.

Fluid Leaks

.

Piping Vibration

.

Hanger / Seismic Restraints

.

Clearance Tags

.

Fire Hazards

.

Control Room Manning

.

Annunciators

.

-4-

During this aspect of the inspection, the inspectors noted that (a)

a trash container located in the auxiliary electric equipment room was

found to be overflowing with paper and had a cardboard box piled on top

of the trash container, and (b) on the lower level of the reactor

building adjacent to tne hydraulic oil system, numerous oil soaked

paper towels were stuffed between the concrete wall and the work area,

a garbage can was full of soiled pacer towels and was overflowing, a

partial bucket of oil was stored adjacent to the garbage can and

additional paper towels and empty boxes were strewn about the work

area.

The failure to control the combustible material is contrary to

the requirements specified in Administrative Procedure ADM-30.

ADM-30, Procedure for Control of Combustibles, Section 4.2, requires

that, " Flammable items such as some anti-C clothing and wiping rags shall

be kept in a noncombustible bin or contai rer until required and placed

in approved small waste storage upon disposal." Additionally, Criterion

V of Appendix B to 10 CFR 50 requires in part that, " Activities affecting

quality . . . shall be accomplished in accordance with these instructions,

procedures, or drawings." This is further amplified by the licensee's

approved QA Plan, Final Safety Analysis Section B.5(c) which states in

part, "The various aspects of plant operation will be defined and con-

trolled by written procedures . . . ."

The licensee was informed that failure to control the combustibles

specified above in accordance with the approved procedures was considered

an item of noncompliance.

On December 4,1979, the inspector discussed with operators and the shift

supervisor how the instructions entered in the operations log, Book 11,

page 0-1 at 0905 on December 3,1979, were being handled.

The entry as

stated read in part that, " . . . both primary and secondary coolant can

be shut off #1 46 hrs. to not exceed 4000F Top Hd He Temp. or #2 120 hrs.

to not exceed 7600F top Hd He Temp." At 1235, the entry read "All P/C

and S/C shut off for WA 825-21." A copy of Data Sheet 2, " Calculating

the Hours Forced Cooling May Be Off (knowing maximum fuel temperature

to be allowed)" was available in the control room.

It became apparent during the discussions that no written instructions

were available to either the shift supervisor or the operators and that

confusion existed on how to utilize this information.

Some operators

had recorded core outlet temperature during the time when coolant was

off, although temperatures at this time would not be representative of

fuel or top head temperatures.

Moreover, the controlling aspect was

the time that flow could be off before the specified temperatures

would be exceeded and therefore, required return of the flow within

these times, depending upon restrictions regarding the restart of the

steam generator coolant flow.

When this became apparent, the inspector

-5-

discussed the problem with the Manager of Nuclear Production who

indicated he would correct this situation.

This failure to provide

written procedures / instructions is contrary to the requirements of

Technical Specification 7.4.a, Procedures, Administrative Controls.

Technical Specification 7.4.a requires in part that, " Written procedures

shall be established, implemented and maintained covering . .

1.

The

applicable procedures recommended in Appendix A of Regulatory Guide 1.33,

November 1972." Contrary to this requirement, no written procedure was

available to the shift supervisor or operators for the removal of forced

cooling (primary and secondary) from the reactor.

The licensee was

infonned that failure to provide the written procedure in accordance

with the requirement specified above was considered an item of noncom-

pliance.

Since the work in progress required that coolant be shut off, WA 825-21 was

broken up into discrete packages.

The coolant was restored within the

required time periods.

Some of the core outlet temperatures at specified

times with coolant restored were:

Date

Time

Deg. F

U

12/3/79

0800

254U

12/3/79

2400

234U

12/4/79

0200

237U

12/4/79

0400

236U

12/4/79

0600

239U

12/5/79

1000

273U

12/6/79

1000

370

U

12/10/79

1200

340

The inspector had no additional questions in this area.

5.

Startup Report

The thirteenth Startup Report for Fort St. Vrain for the period August 23,

1979 through November 22, 1979, reviewed by the inspector, contained no

relevant information on the initial approach to power tests since none

were performed during this period of time.

6.

Part 21 Report

On November 9, 1979, in letter P-79271, the licensee submitted to Region

IV a Part 21 Report No. 50-267/79-01 regarding 1-1/2" X 36" long full

threaded rods which did not meet the reduction area specification as required

by ASTM A-193-87.

As a result, the material in warehouse stock was replaced

by the manufacturer.

Additionally, the materials used for the steam inlet

-

.

-6-

supply pipe flange bolting on circulators C-2102 and C-2103 have been

removed and replaced.

The replacement was accomplished utilizing PTR's12-258 and 12-259.

The replacement studs,16 per circulator, were of

material procured in accordance with ASTM A-193-87.

During the removal of the defective material, it was noted that six nuts

on circulator C-2102 and two on C-2103 were finger tight.

It is suspected

that the material may have yielded.

To determine this, the licensee

intends to conduct tests on the material removed.

Additionally, several

nuts installed on one of a.e other two circulators will be checked as

confirmation that the loose nuts were related only to those placed on

defective bolts.

7.

Radiation Protection

The inspector reviewed the licensee's exposure control and high radiation

Additionall , radiation protection instruments

area posting and control.

3

in use at the time were examined for operability and calibration.

However,

at the time of the review no RWP's were in use so selected RWP's from

December 14 and December 15, 1979 were reviewed.

These were:

RWP #

Date

Reason

2243

12/14/79

Replace Cover on HV-2301 and HV-2302;

General cleanup of RWP area.

2244

12/14/79

Change out System 62 resin from cartridge.

2245

12/15/79

Change F 6201S

The following instruments and calibration records were reviewed:

Instrument & Number

Calibration Date

Calibration Due Date

Proportional Counter M3365

10/24/79

1/30/79

Eberline RM-14 - M3353

12/15/79

3/80

- M3351

12/15/79

3/80

"

"

- M3359

12/15/79

3/80

"

"

- M3360

12/15/79

3/80

"

"

- M3354

12/16/79

3/80

"

"

- M3352

12/15/79

3/80

"

"

- M3342

12/16/79

3/80

"

"

R0-2 - M3314

12/4/79

1/80

"

Eberline Portal

Monitor

- M3340

10/1/79

Eberline Beta

Particle Monitor - fi3317

Presently not calibrated (not required according

to the manufacturer).

However, a procedure for

calibration has been developed and the instrument

will be calibrated in 2/80 and then on a frequency

of every three months.

.

.

-7-

Calibration of radiation monitors for liquid effluents, gases, process

monitors and area monitors were reviewed in conjunction with the follow-

ing surveillance tests.

SR 5.4.9.A-1, Process Gamma Monitors Calibration, completed 8/31/79

SR 5.4.9.A-2, Process Beta Monitors Calibration, completed 9/11/79

SR 5.4.9.A-3, Area and Equipment Monitors Calibration, completed 8/27/79

SR 5.8.le-A, Radioactive Gaseous Effluent Flow Recorders, Calibration,

completed 9/10/79

SR 5.8.lcd-Q, Radioactive Gaseous Effluent System Calibration, completed

9/5/79

SR 5.8.2c-Q, Radioactive Liquid Effluent Activity Monitors Calibration,

completed 9/5/79

No items of noncompliance or deviations were identified.

8.

Maintenance

The inspector reviewed selected maintenance activities to determine that

those activities met acceptable maintenance practices, the licensee's

applicable administrative and maintenance procedures, and where applicable

were in accordance with Technical Specifications.

Additionally, the

inspector observed portions of maintenance activities to verify that

procedural requirements were met, personnel were qualified, QC hold

points were provided, tagging procedures were appropriate and the items

were not reportable as reportable occurrences.

The maintenance activities reviewed were:

PTR 5-805, Inspect Diesel Generator (DG) 1B - Control Cabinets

and Generator End per PME-3

PTR-12-258

PTR 12-259

During observations of maintenance performed as a result of PTR 5-805,

Inspec+ Diesel Generator (DG) 1B - Control Cabinets and Generator End

per PME-3, it was determined that Work / Test Instructions did not

indicate the data to be recorded on Attachment No. 1, Insulation

Resistance Sheet Table, of PME-3.

Moreover, the tables for data to be

recorded were not used, all of the data listed was not taken, and only

the ' Remarks' section was used to record the data.

.

.

-8-

Criterion V of Appendix B to 10 CFR 50 requires in part that, " Activities

affecting quality . . . shall be accomplished in accordance with these

instructions, procedures, or drawings." The l'censee's approved QA

Plan, Final Safety Analysis Section B.5(c) states in part, "the various

aspects of plant operation will be defined and controlled by written

procedures . . . ." Administrative Procedure (ADM) No. 12, Maintenance

and Repair Procedures, Section 5.1.3(10)d, states that work / test

instructions shall include the following " Acceptable criteria and data

to be recorded / verified."

The failure to comply with these requirements as indicated above were

discussed with the licensee who was infonned that this was an apparent

item of noncompliance for failure to follow procedures and was

considered an infraction.

The inspector had no additional questions in this area.

9.

Surveillance Activities

The inspector observed Technical Specification required surveillance

test 5.4.1.2.1.d-M, Steam Pipe Rupture (Pipe Cavity) Test.

The inspector verified that test results were in conformance with

Technical Specifications and procedure requirements and that they were

reviewed by appropriate personnel.

The inspector verified that deficiencies identified during testing were

properly resolved and reviewed by appropriate management personnel.

10.

Calibration

The inspectcr reviewed the calibration of the instruments noted in

paragraph 7 of this report and verified that calibration was in confor-

mance with requirements.

No items of noncompliance or deviations were identified.

11.

Training and Recualification Training

The purpose of this inspect #an was to evaluate the licensed operator and

maintenance personnel training program and detennine if the training

program was in conformance with the regulatory requirements and requal-

ification training program approved by NRC.

.

.

-9-

The inspector's review included the following points:

The inspector reviewed records for nine licensed operators of

.

which four were senior operators (S0), three were special

refueling (SLO), and two were licensed operators.

Annual requalification exams.

.

Records of requalification lecture attendance.

.

Records of on-the-job training, including reactivity manipulations.

.

Annual operator evaluations.

.

Reviewed three lecture lesson plans.

.

Interviewed selected operators from the group of records reviewed.

.

Reviewed requalification program for changes since last NRC review.

.

Reviewed training records for selected maintenance personnel.

.

The inspector reviewed the 1979 annual requalification exams for SLO and

R0's to determine if the subsequent training program lectures had been

scheduled and conducted for areas where the operators had made a score of

less than 70%.

No items of nonconpliance or deviations were identified.

12.

Reserve Shutdown System

The inspector reviewed surveillance procedures, operating procedures,

records of tests and procedures performed, and inspected the reserve

shutdown system to detennine that the licensee conformed to Technical

Specification, the FSAR and approved procedures.

The surveillance procedures were reviewed to determine whether the procedures:

Require application of test pressure to the reserve shutdown hoppers

.

in accordance with the Technical Specifications and the FSAR.

Identify appropriate initial conditions.

.

Include acceptance criteria related to perfonnante of the actuating

.

valves, integrity of the rupture disc, and performance of the orificed

vent.

.

.

-10-

Identify proper valve lineup to each hopper for returning the

.

system to normal and require verification of the valve lineup.

Require periodic calibration of the pressure indicators.

.

Require testing a hopper and a rupture disc in accordance with

.

requirements in the Technical Specifications and the FSAR.

Specify appropriate handling requirements, test conditions, and

.

acceptance criteria.

Require inspection of the hopper after the rupture disc ruptures

.

to determine whether all the balls were released from the hopper.

Identify appropriate specifications for the replacement rupture

.

disc and requirements for inspection of the replacement rupture

disc prior to and following installation.

No items of noncompliance or deviations were identified.

13.

Exit Interviews

Exit interviews were conducted at the end of various segments of this

inspection with Mr. D. W. Warembourg (Manager, Nuclear Production) and/or

other members of the Public Service Company staff.

At the interviews, the

inspectors discussed the findings indicated in the previous paragraphs.

The licensee acknowledged these findings.

't