ML20040E010
| ML20040E010 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/13/1982 |
| From: | Randy Hall, Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20040D986 | List: |
| References | |
| 50-267-81-25, NUDOCS 8202020485 | |
| Download: ML20040E010 (8) | |
See also: IR 05000267/1981025
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Report:
50-267/81-25
Docket:
50-267
License:
Licensee:
Public Service Company of Colorado
Post Office Box 840
Denver, Colorado 80201
Facility Name:
Fort St. Vrain Nuclear Generating Station
Inspection at:
Fort St. Vrain Site, Platteville, Colorado
Inspection Conducted:
November 16-20, 1981
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Inspector:
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E. H. Johnson, Reactor Inspector, Systems and Technical
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Section
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Approved:
R. E. Hall, Chief, Systems'and Technical Section
Date
Inspection Summary
Inspection Conducted November 16-20, 1981 (Report 50-267/81-25)
Areas Inspected:
Routine, unannounced inspection of maintenance and fire
protection / prevention program implementation.
The inspection involved
36 inspector-hours by one NRC inspector.
Results: Within.the two areas inspected, no violations or jeviations were
noted in one area; but one violation was identified in the other area
(violation - failure to perform surveillance testing at the intervals
required by Technical Specifications
paragraph 2).
8202020485 820115
PDRADOCK05000g
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DETAILS
1.
Persons Contacted
- M. Block, Superintendent of Operations
- T. Borst, Radiation Protection Manager
P. Brearly, Training Instructor
W. Craine, Superintendent of Maintenance
M. Ferris, Supervisor, QA Technical Support
- W. Franek, Site Engineering Manager
- J. Gahm, QA Manager
J. Glass, Acting Supervisor, Scheduling and Maintenance
- F. Hill, Station Manager
- A. Kitzman, Clerical Supervisor
G. Redmond, Acting Supervisor, Maintenance QC
R. Wadas, Training Supervisor
- D. Warembourg, Manager, Nuclear Production
S. Wilford, Training Instructor
The NRC inspector also contacted other plant personnel including
administrative operations and maintenance personnel.
- Denotes those persons present at the exit interview.
2.
Fire Protection / Prevention Program Implementation
The objective of this inspection effort was to determine whether the
licensee is implementing a fire protection / prevention program in
conformance with regulatory requirements, technical specifications,
and industry standards.
The following elements were included in this area of the inspection:
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fire prevention / protection organization
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control of combustibles during maintenance and modification
activities
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general facility housekeeping
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fire protection system components, functional and properly
maintained
surveillance testing of fire protection systems
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fire brigade training and fire drills
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The NRC inspector reviewed the below listed licensee procedures to
determine how the regulatory requirements and commitments were
translated into practice at the station:
Procedure / Revision or Date
Title
P-8/ August 4, 1980
Fire Fighting and Prevention
P-10/May 4, 1981
Safe Work Practices
Revision 6
Fire Suppression and Prevention
Manual
Revision 17
Training Practices Administra-
tive Manual
It was noted that Procedure P-8 specifies that primary fire fighting
and fire prevention responsibility at the station is vested in the
Operations Manager.
A recent organizational change, it was observed,
had changed this title to Station Manager.
In addition, the NRC
inspector learned from review of the results of a Nuclear Facility
Safety Committee audit, it was recommended that a specific fire pre-
vention coordinator be appointed.
The recommendations resulting from
this audit were still in resolution at the time of this inspection;
thus, this item will remain open for further inspection at a future
date.
(0 pen Iten 8125-01)
Fire brigade training to meet or exceed the requirements of Appendix R
to 10 CFR 50 is required by the licensee of all brigade numbers.
For
all newly reporting station personnel (except clerical staff), atten-
dance at initial fire fighting training is required.
This program
consists of a video taped fire fighting fundamentals lesson, hands-on
training using fire extinguishers and hoses in fighting an acutal staged
fire, fire protection system familiarization, and fire strategy training.
Continuing training for all fire brigade team members consists of one
fire drill per shift fire brigade each quarter, one fire training session
for each shift fire brigade each quarter, and an annual all day fire
fighting refresher conducted by Kodak Company using their own industrial
fire fighting course.
This latter training includes actual fire fighting.
These training elements are set out in the Training Practices Administrative
Manual only on a record form used to track completion of each element for
each brigade member.
An additional requirement for an annual physical
for each fire brigade member is also included on this form.
The training
department maintains all records of completed fire brigade training.
The fire brigade training appeared to meet the requirements of Appendix R
to 10 CFR 50, and the industrial fire fighting training provided by the
Kodak Company was noted to be a strong element of the program.
However,
the NRC inspactor noted that this program had not yet been promulgated as
a formalized descriptive procedure to document the program and describe,
in detail, all the areas to be covered during the initial fire brigade
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training and quarterly retraining sessions.
Lacking such direction, the
NRC inspector indicated at the exit interview, could lead to omission of
critical elements of the program in the future and would not guarantee a
continued uniformity in training that heretofore had apparently been
achieved.
The NRC inspector said that this item would be designated
unresolved pending further inspection of fire brigade training.
(Unresolved Item 8125-02)
The NRC inspector conductei a detailed tour of all accessible areas of
the station to observe gen 2ral housekeeping conditions and the control
of combustibles during maintenance and modification.
Additionally,
this tour included an inspection of installed fire protection equipment
and systems; such as, positions of selected valves, fire barrier condi-
tion, hose stations, Cardox and Halon system lineups, fire lockers,
and hose houses.
No items of noncompliance or deviations were noted.
Several minor discrepancies; such as, a missing fire blanket and one
hose station that had become unracked were noted.
These were brought
to the attention of the licensee and were rectified prior to the end
of the inspection.
General housekeeping conditions were satisfactory,
and in spite of a major modification in progress at the time of the
inspection, work areas appeared to be orderly.
The final element of this area of the inspection was a review of the
surveillance testing of fire protection systems and related Technical
Specification requirements.
Of the latter, Technical Specification 7.1.3, 7.b(8) requires an audit of the fire protection program by an
outside fire protection consultant each three years.
The results of
this audit were reviewed (NFSC Audit H-81-1).
A number of significant
recommendations resulted from this audit.
These items included the
designation of a fire prevention coordinator (as discussed above), the
need for specific fire brigade leader training, control of hot work,
inspection of unsealed valves, improved fire strategies, and the need
foradikebetweenthedieselgeneratorrooms.
These recommendations
were entered into the licensee s management follow up system as
corrective action requests (CAARs) 341, 342, 344, 346, 347, 348, and 349.
The NRC inspector indicated, during the exit interview, that he shared
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the same concerns as were expressed in these findings and recommendations;
but as they were identified by the licensee and corrective actions were
still in progress, he would identify this as an unresolved item.
(Unresolved Item 8125-03)
To verify conformance to the fire protection system surveillance re-
quirements, the NRC inspector first selected five surveillance procedures
for a detailed review of technical adequacy.
The NRC inspector found the
content of these procedures satisfactory.
Next, the records of completion
for 24 surveillance tests were reviewed to verify that testing was per-
formed at the intervals required.
The NRC inspector discovered three
instances where testing had not been accomplished as required.
These
discrepancies are detailed below:
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a.
Technical Specification 5.2.10(a)(3) requires the diesel engine for
the diesel driven fire pump be inspected each refueling shutdown;
the engine was last inspected in September 1980 and was not
inspected during the spring 1981 refueling.
b.
Technical Specification 5.10.1 requires annual actuation testing
of the heating and ventilation isolation dampers and associated
fans in the three room control complex; this surveillance test
was last performed on July 17, 1980, an interval of 16 months
to the date of the present inspection.
c.
Technical Specifications 5.10.2(a) and (b) require the Halon
storage cylinders to be verified operable quarterly by checking
their weight and pressure.
During 1981, these tests were per-
formed on February 20, July 1, and October 23.
The interval
between the first two tests is 19 weeks.
For these latter two discrepancies, the Technincal Specifications permit
the normal surveillance to be extended by 25 percent.
However as can be
seen above, this extended interval was exceeded.
The failure to perform
surveillance testing at the frequencies required by the Technical Specifi-
cations is an apparent violation.
(Violation 8125-04)
This item was discussed with the licensee's staff at the exit interview.
They indicated to the NRC inspector that their practice in the past had
been to establish a scheduled date for each surveillance item, and as long
as the actual date of performance fell within +25 percent of the total
interval duration based on this schedule date, the surveillance require-
ment was satisfied.
The NRC inspector indicated that this practice could
lead to as much as an 18-month interval between performances of an annual
surveillance test.
Following the inspection, the NRC inspector discussed this item with the
Manager of Nuclear Production and his staff.
The NRC inspector learned
that the licensee would review the method for establishing a due date
for surt:eillance.
What would probably evolve, the NRC inspector was told,
would be that when a surveillance was performed prior to the scheduled
date, a new "next due" date for the surveillance test would be established
based on the actual date of the test performance.
Where a test was done
after the scheduled date, then the original scheduled date would be used
to establish a "next due" date.
3.
Maintenance
The objective of this inspection effort was to ascertain whether mainte-
nance activities on safety-related systems and components were conducted
in accordance with approved procedures and in accordance with Technical
Specification requirements.
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The below listed maintenance activities were reviewed to determine that
the activities were properly approved, that the maintenance was conductad
in accordance with an approved procedure, and that inspection and testing
were performed as required.
Several of these procedures were revien d in
detail to determine if they appeared to be technically adequate.
Plant Trouble Report (PTR)
Maintenance Activity
Procedure
81-10-117
Refill Loop 2 Hydraulic
M.P. 91.3*
Oil Reservoir
81-5-236
Remove and Replace
M.P. 21.15*
Helium Circulator
Preventive Maintenance
Quarterly Diesel
P.M. 92.10*
Generator Inspection
81-8-365
Repair Fire Damaged
CN 1405 & 1405A
Cables
CNP 81-224*
81-6-56
BFS 167E Snubber
M.P. 98.1*
Rebuilt
81-9-198
HV 2292 Relief Valve
M.P. 91.10
Replacement
81-9-137
Changeout of "D" Engine
P.M. 92.10
Injectors
- Procedure reviewed for adequacy
In addition to the above, the NRC inspector reviewed the following-
procedures for adequacy:
M.P. 12-1 (Revision 1), " Removal and Installation of Control
Rod Drive Assemblies in the Reactor Penetration"
M.P. 12-6 (Revision 10/30/81), " Maintenance and Repair of Control
Rod Drive and Orificing Assemblies"
M.P. 16-3 (Revision 7/20/81), " Maintenance and Repair of 1900 Series
Consolidated Safety Relief Valves"
M.P. 102-1 (Revision 4/30/81), " Verification and Qualification of
Micrometer Standards"
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The NRC inspector noted'that the licensee's staff is currently rewriting
many of the maintenance procedures to clarify instructions, incorporate
technical manual references and-inspection hold points.
This effort was
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apparent to the NRC inspector during his review.
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The inspection of maintenance activities also included a review of the
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number and type of outstanding maintenance items to determine if an
excessive backlog existed.
The NRC inspector was able to determine
that, on average, only about four or fiveLitems were marked as out-
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standing for each safety-related system or component. This backlog
generally included minor adjustment items and most appeared backlogged
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awaiting parts or appropriate plant conditions.
During review of the documentation for the Helium Circulator replace-
ment (PTR 81-5-236), the NRC inspector discovered that.the documentation
package did not.contain a weld data report for each weld data sheet.
'It was noted, however, that this package was still in the process of
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being finalized.
The NRC' inspector learned that the . responsibility for -
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ensuring that a work package was complete lay with thc assigned craft
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department.
Completed packages were sent to the PTR clerk who verified
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that the PTR was filled out correctly; but lacking a checklist of what
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supporting documents should be included, this clerk could not verify
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the completeness of the package.
Thus, an incomplete package could be
sent to the plant archives.
On many occasions, it was learned, after
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a package was forwarded to the archives,'the PTR clerk received addi-
_tional miscellaneous documents relating to maintenance activities.
If
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the documents could be crossed to a specific PTR, they would be filed
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with them; otherwise, a special-file would have to be created.
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NRC inspector expressed his concern that this system did notfallow for
easy retrieval' from storage of information.regarding completed mainte-
nance as might be needed when reviewing equipment problems.
With regard
to the completeness of documentation for PTR 81-5-236, the NRC inspector
indicated that this package would be reinspected at a later date.
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(0 pen Item 8125-05)
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No violations or deviations were noted in this-area of the inspection.
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4.
Unresolved Items
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Unresolved items are matters about which more information is required
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to determine if they are acceptable items, violations, or deviations.
Two new unresolved items are included in paragraph 2 of this report.
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Item
Description
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8125-02
Fire Protection Training Program
8125-03
Resolution of NFSC Fire Protection Audit Findings
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5.
Exit Interview
- An exit interview was conducted on November 20,1981, with members of
the licensee's staff as denoted in paragraph l.
The NRC Senior Resident
Reactor Inspector also attended.
The NRC inspector's observations and
findings noted in the foregoing paragaphs were discussed.
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