ML19323B264

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IE Insp Rept 50-267/80-02 on 800201-29.Noncompliance Noted: Failure to Use Latest Procedure Revisions While Performing Calibr & to Provide Record of Test Equipment
ML19323B264
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 03/18/1980
From: Collins R, Westerman T, Yandell L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19323B258 List:
References
50-267-80-02, 50-267-80-2, NUDOCS 8005120165
Download: ML19323B264 (12)


See also: IR 05000267/1980002

Text

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OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

IE Inspection Report No. 50-267/80-02

Docket No. 50-267

License No. DPR-34

Licensee:

Public Service Company of Colorado

P. O. Box 840

Denver, Colorado

80201

Facility Name:

Fort St. Vrain Nuclear Generating Station

Iaspection At:

Fort St. Vrain Site, Platteville, Colorado

Inspection Conducted:

February 1-29, 1980

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Inspectors:

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M. W. DickErson,;< Senior Resi, dent Reactor

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Inspector

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"'R. G. Spangler, Rettctor inspector

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uk.~E.' Collins, ResidentvReactor Inspector

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L. A. Yandell, Reactor Inspe(tof

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Approved by:

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T. F. Westerman, Chief, Reactor Projects Section

Date

Inspection Sununary

Inspection Februacy 1-29, 1980 (Report No. 50-267/80-02)

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Areas Inspected:

Routine, announced inspection of Event Reports; Calibration;

Surveillance; Bulletins / Circulars; Maintenance; Physical Security; Plant

Operations; Followup on Items of Noncompliance; Followup on Inspector

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Identified and Unresolved Problems; Emergency Planning; Core Safety Limit;

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and Report Reviews.

The inspection involved 227 inspector-hours on-site by

four (4) NRC inspectors.

Results: Within the ten (10) areas inspected, two items of noncompliance

were identified (infraction - Failure to use latest procedure revisions

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while performing calibration, paragraph Sa; and deficiency - Failure to

provide a record of test equipment, paragraph Sa).

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DETAILS

1.

Persons Contacted

L. Brey, QA Manager

W. Craine, Maintenance Superintendent

W. Franek, Results Supervisor

C. Fuller, Engineer Technical Services

J. Gamm, Supervisor Technical Services

E. Hill, Operations Superintendent

W. Hillyard, Administrative Services Manager

F. Mathie, Operations Manager

J. Solakiewicz, Superintendent Operations QA

G. Turner, Supervisor of Security

D. Warembourg, Manager Nuclear Production

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The inspectors also contacted other plant personnel including Reactor

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Operators, Maintenance men, Electricians, Engineers, Technicians and

Administrative Personnel.

2.

Licensee Action on Previous Inspection Findirgs

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(Close) Open Item (50-267/7703):

NI accuracy (Decalibration).

The

recommended circuit design to provide a solution to the decalibration

problem, a floating trip setpoint, was submitted to NRR by the licensee

January 11, 1979, in letter P-79012.

In the interim the linear power

channel scram and RWP are calibrated daily or whenever a 10% change

in power level has occurred, or a rod is fully withdrawn.

(Close) Open Item (50-267/7914):

Hanger 11-A-H-46448 initial audit

not in accordance with observations.

The inspector reviewed the reaudit

of the hanger and confirmed that no major discrepancies were overlooked.

(Closed) Open Item (50-267/7917-01):

No portable radios available for

emergencies in control room.

Operations order dated January 31, 1980 was

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issued regarding the control of portable radios.

Observations have

indicated that the required radios are now available.

(Closed) Open Item (50-267/7917-02):

Records not maintained for required

controller settings.

The required records are now maintained on

Report No. 5276 " Fort St. Vrain Master Setpoint List - Controllers."

(Close) Unresolved Item (50-267/7919-02):

Thread Engagement Depth

Sample Enlargement - Bulletin 79-02.

The licensee completed inspection

of 50 floor mounted bolts and an additional 99 wall mounted bolts, ie:

measuring for thread engagement.

Only one was measured to have

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inadequate thread engagement and was subsequently repaired.

The

measurements were a result of ultrasonic and w;ual measurements.

(Close) Unresolved Item (50-267/7919-03):

Verification of embedment

depth - Bulletin 79-02.

The licensee completed the UT testing program

in conjunction with physical measurements to verify embedment depth for

the bolts noted it. unresolved item 7919-02. Only one bolt had insufficient

embedment depth.

(Close)-Item of Noncompliance (50-267/7922-1):

Procedural instructions

not available.

Technical Services Procedure No. 13 was revised and

reviewed with operation personnel relating to the time that flow may be

removed from the primary and secondary coolant.

(Close) Item of Noncompliance (50-267/7922-2):

(a) Trash in the auxiliary

electric room and oil soaked paper towels, garbage can overflowing,

oil stored on lower level of rear building; and (b) PME-3 not completed

p rope rly.

All maintenance personnel were reinstructed regarding their

responsibilities for maintaining clean working areas and for completion

of data sheets in accordance with procedural requirements.

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 Operations

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, or

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

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Reactor Operator Logs

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Technical Specification Compliance Log

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Operating Order Book

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Form 1 Log (Jumper Log)

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Plant Trouble Reports

Selective Valve Lineups

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During the tour of accessible areas, particular attention was directed

to the following:

Monitoring Instrumentation

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Radiation Controls

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Housekeeping

Fluid Leaks

Piping Vibration

Hanger / Seismic Restraints

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Clearance Tags

Fire llazards

Control Room Manning

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Annunciators

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No items of nor conformance or deviations were identified.

5.

Calibration

a.

Technical Specification Requirements

The inspectors selected a sample of various instruments to verify

that the frequency of calibration required by the licens had been

met.

From this sample, documentation from 13 of these instrument

channels was selected and reviewed for (1) completeness, (2) proper

acceptance criteria, (3) use of proper revision, and (4) qualification

of individuals performing the calibration.

In addition, the

procedures were reviewed to verify that (1) they had been approved

as required by Technical Specification, (2) calibration was to

the required accuracy, (3) as-found as as-left conditions were

recorded, (4) calibration equipment used was traceable, and (5)

calibration sheets had been initialed by the technician performing

the calibration.

The following calibration records were reviewed:

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TS

Calibration

Reference

Dates

  • SR5.1.2bd-A

Reserve Shutdown System Hopper

5.1.2d)

4/3/78

Instrumentation Calibration

3/26/79

  • SRS.2.lc1 &

PCRV Overpressure Safety

5.2.1c)

(c1) 10/3/79

c2

System Instrumentation Cali-

12/14/79

bration

(c2) 6/7/79

  • SR5.2.9-A

Helium Circulator Bearing Water

5.2.9

11/30/78

Accumulator Instrumentation

10/29/79

Calibration

  • SR5.2.15-A

PCRV Penetration Interspace

5.2.15

1/30/79

Pressure Instrumentation Cali-

bration

2SR5.2.23-A

Fire Water Booster Pump

5.2.23

5/22/79

Instrumentation Calibration

  • SRS.3.5-A

Hydraulic Oil Accumulator Gas

5.3.3

3/22/79

Pressure Instrument Calibration

  • SR5.3.6-A

Instrument Air System Pressure

5.3.6

4/25/78

Instrument Calibration

7/16/79

SR5.4.1.1

Startup Channel Scram Cali-

5.4.1.1.3

12/1/78

3c-R

b ration

12/1/79

SR5.4.1.1

Linear Power Channel Scram

5.4.1.1.4

Week #1 1/5-6/80

4c-D

and PMP Calibration

Week #2 1/7-8/80

Week #8 2/18-22/80

  • SRS.4.1.1

Primary Coolant Moisture

5.4.1.1.b

10/30/78

bc-R

Calibration

11/14/79

SR5.4.1.1

Reheat Scram Temperature

5.4.1.1.8

9/10/78

Sc-R

Scram Calibration

9/11/79

SRS.4.1.1

Primary Coolant Pressure

5.4.1.1.9

3/1/79

9c-R

Scram Calibration

10/30/79

SRS.4.1.1

Circulator Inlet Temperature

5.4.1.1.10

6/7/78

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10c-R

Scram Calibration

7/9/79

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SRS.4.1.1

Hot Reheat Header Pressure

5.4.1.1.11

7/24/78

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11b-R

Scram Calibration

7/27/79

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  • SRS.4.1.3

Feedwater Flow Calibration

5.4.1.3.2

6/6/78

2d-R

3/19/79

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  • SR5.4.5A1

PCRV Cooling Water Flow Scram

5.4.5

9/26/78

Calibration

9/17/79

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  • SR5.4.10.5A/ Seismic Instrumentation

5.4.10

7/9/79

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B1-A

12/12/79

  • SR5.5.1-A

Reactor Building Sub-Atmospheric 5.5.1

3/2/79

Instrument Calibration

  • SRS.6. led-A

Diesel Generator Exhaust

5.6.1

5/26/79 to

Temperature Instrument

9/4/79

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Calibration

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  • These channels received the expanded review.

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As a result of these reviews, the inspectors had the following

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findings.

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While reviewing the Linear Power Channel Scram and RWP Calibration

Procedure SR 5.4.1.1.4c-D for week No. 1 (1/5-6/80) and week No. 2

(1/7-8/80), it was noted by the inspector that the test conductor

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had failed to identify the calibration equipment used in Section

3.0.

ADM-13, Administrative Procedure for Technical Specification

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Surveillance, states in Section 2.5d) that the test conductor, "is

responsible for assembling test equipment, special tools and other

items specified by the test procedure and identifying them in

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Section 3.0 of the SR."

The inspector determined that the

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calibration was performed properly, but the failure to follow the

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administrative procedure as noted above constitutes an item of

noncompliance at the deficiency level.

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In addition, the inspectors found that the following calibration

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procedures had been conducted using superceded procedure revisions:

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Date

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System

Perfo rmance

Revision Revision in Effect

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Procedure No.

Calibration

Began

Used

at Performance

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5.1.2bd-A

Reserve Shutdown

3/26/79

13

14 effective

1/31/79

5.3.5-A

Hydraulic Power

3/22/79

10

12 effective

2/28/79

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5.3.6-A

Instrument Air

7/16/79

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9 effective

3/5/79

5.4.1.1.11b-R

Hot Reheat

7/27/79

10

11 effective

3/5/79

5.4.1.3.2d-R

Feedwater

3/19/79

13

15 effective

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2/28/79

With the one exception below, it appears that only nonsubstantive

changes were involved in the above procedure revisions.

Procedure

5.4.1.3.2d-R, Feedwater System Instrumentation Calibration,

appears to involve a major rewrite between revisions 13 and 15,

and will require licensee review to verify the acceptability of

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the calibration.

The licensee's Quality Assurance Plan for Operations implements

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Criterion VI of Appendix B to 10 CFR 50, Document Control, which

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specifically states that procedures, including changes thereto,

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shall be distributed to and used at the locations where the

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prescribed activity is performed. This failure to utilize the

most current procedure revisions is contrary to the requirements

identified above and constitutes an item of noncompliance at

the infraction level.

The inspector also inspected two instruments used as primary

standards for calibration of the Omega RTD Temperature Probe

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No. 8177 (PSC No. M3119) and Heise Test Gage CM-7004 (PSC No. 3167).

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No further adverse findings were ident.ified.

b.

Technical Specification Related Instruments

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The inspector selected a sample of instrumentation from safet',-

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related systems to verify that (1) these instruments are included

in the licensee's program for routine calibrations, (2) the range

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and accuracy of the components is consistent with the application,

(3) approved procedures are available to calibrate the component,

and (4) calibration records are complete.

The following calibration

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records were reviewed:

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LI-2519, Liquid Nitrogen Storage Tank Level

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FR-4101, Liquid Effluent Blowdown Low Circulating Water Flow

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LI-4102-3, Circulating Water Makeup Storage Pond Level

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PCRV Outlet Subheader and Liner Cooling Tube Indicators and

Thermocouples

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When given the instrument calibration history cards for LI-2519, the

inspector noted that nothing had been done since 1976.

Further

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investigation found that the original device had been taken out of

service and replaced with a different type sensor in 1977.

Calibration cards did exist for the new device and calibrations had

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been performed, but some confusion existed because no entry had

been made on the original cards indicating that the device was no

longer in service.

While examining the calibration cards for L1-4102-3, it was deter-

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mined that the original level device has just been replaced by

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another type. However, the original calibration cards had been

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retained with the original device number removed and the new device

number listed.

By doing so, the calibration / repair history

for the original device also appears applicable to the new instrument.

In addition, LI-4102-3 was not listed in the latest Master Calibration

List used by the licensee to schedule routine calibrations.

Although

the calibrations had been performed, there was no mechanism identified

for ensuring that this would be done on a routine basis.

The

licensee indicated that LI-4102-3 would be incorpotated into the

Master Calibration List and that the problems identified above

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related to the calibration records would be investigated.

Therefore,

pending further review, these concerns are considered open items.

(8002-01)

6.

Core Safety Limit

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The inspector reviewed surveillance procedures regarding core safety

limits to verify that procedures exist requiring (a) periodic review

of reactor power and reactor power to flow ratios to assure that undue

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migration of fuel kernels has not occurred, and (b) calculation of the

amount of fuel kernel migration as required by the technical specifica-

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tion when the reactor power to flow ratio exceeds a specified valve.

Surveillance procedure (SR 5.1.6-w) was reviewed by the inspector through

December 28, 1979. Total migration experienced for Core 1 was 0.217 and

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that for core 2 to December 28, 1979 is 0.138.

No items of noncompliance or deviations were identified.

7.

Maintenance

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The inspector reviewed selected maintenance activities to determine

that those activities met acceptable maintenance practices, the licensee's

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applicable administrative and maintenance procedures, and where applicable

were in accor -c.ce with Technical Specifications.

Additionally, the

inspector obset 'd portions of maintenance activities to verify that

procedural requirei._

let, personnel were qualified, QC hold

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points were provided, ta a :; procedures were appropriate and the items

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were not reportable as reportable occurrences.

The maintenance activities reviewed were:

Circulator Replacement PTR1-72, CWP-410, CWP-465

Moisture Monitors 1117, 1121, 1122, CWP 443, CN 1083

Hydraulic Pumps Coupling Inspection PTR2-120, Maintenance Procedure #105

Hangers 11A-H-21325, 11A-H-21326, 11A-H-21327 CN 1178, WA869-98

The hangecs identified above were the result of findings from Bulletin 79-14.

No items c,f noncompliance or deviations were identified.

8.

Surveillance

The inspector observed Technical Specification required surveillance

testing as follows:

SR 5.6.lb-SA Loss of Outside Power and Turbine Trip.

No items o.' noncompliance or deviations were identified.

9.

Review of Licensec Event Reports

The inspector reviewed licensee event reporting activities to verify that

they were in accordance with Technical Specification, Section 7, including

identification details, corrective action, review and evaluation of aspects

relative to operations and accuracy of reporting.

The following reports were reviewed by the inspector:

  • R0 80-02

RO 77-17

  • RO 80-03

R0 80-02 as submitted did not contain sufficient : aformation regarding

reac+ivity changes which occurred during the repert period.

For

example, the R0 did not include information concerning the control

rods which were removed and reinstalled, during installation of the

core restraint devices.

The licensee plans to resubmit the report.

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During review of R0 80-03 the inspector noted that the hangers were

incorrectly identified as 11A-H-21235, 11A-H-21236 and 11A-H-21237.

The licensee will resubmit the report with the correct hangers as

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follows:

11A-H-21325, 11A-H-21326, and 11A-H-21327.

  • Still Open

No items of noncompliance or deviations were identified.

10.

Emergency Planning

The inspector observed the annual drill (FOSAVEX 80) to verify that

emergency actions were taken in accordance with the licensee's approved

emergency plan.

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The inspector observed the drill primarily from the site command post

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and control room.

The inspector noted several minor deficiencies

including:

Battery powered phone monitors were audibly weak and the batteries

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in use have a short lifetime.

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Total accunulated doses were not monitored closely by the licensee

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for both plant operators and off site personnel until approximately

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2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 15 minutes into the drill scenario.

The accumulated doses

would not have exceeded 10 CFR 20 limits up until that time, but

it had not been considered until the accident had been reclassified

as Category III.

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The licensee is taking action to resolve these concerns.

No items of noncompliance or deviations were identified.

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11.

IE Bulletin / Circulars

The inspector verified by record review, observation, and discussion with

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representatives of the licensee, the actions taken in response to IE

Bulletin / Circulars.

The following Circulars were reviewed:

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79-23 Motor Starters and Contactors Failed to Operate.

None with the

specified date code, model and serial Number were received by

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Fort St. Vrain.

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The following Bulletins were reviewed:

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77-01 Pneumatic Time Delay Relay Setpoint Drift Change Notice #594B was

completed by CWP #349 and 418. The change required replacement

with electronic timing mechanisms.

The replacement is now complete.

79-23 Potential Failure of Emergency Diesel Generator Field Exciter Trans-

former.

A test, T-125, was completed January 11, 1980 as required

by item 2 of the bulletin.

The results appear to be satisfactory.

79-25 Failures of Westinghouse BFD Relays in Safety-Related Systems.

Westinghouse BFD/NBFD relays as listed in the bulletin were not

used at Fort St. Vrain.

79-28 Possible Malfunction of NAMC0 Model EA180 Limit Switches at

Elevated Temperatures.

NAMCO Model EA180 Limit Switches as listed

in the bulletin were not used at Fort St. Vrain.

No items of noncompliance or deviations were identified.

12.

Report Reviews

The inspector reviewed the following reports for content, reporting

requirements and adequacy.

Annual Operating Report, January 1979 through December 1979.

Report of Changes, Tests, and Experiments, January 1, 1979

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through December 31, 1979.

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. Warembourg (Manager, Nuclear Production) and

other members of the Public Service Company staff.

At the interviews,

the inspector discussed the findings indicated in the previous paragraphs.

The licensee acknowledged these findings.