ML20133G059
| ML20133G059 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/04/1985 |
| From: | Dyer J, Mckee P, Larry Wheeler, Whitney L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20133G047 | List: |
| References | |
| TASK-1.C.6, TASK-TM 50-267-85-26, NUDOCS 8510150146 | |
| Download: ML20133G059 (13) | |
See also: IR 05000267/1985026
Text
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OFFICE OF INSPECTION AND ENFORCEMENT
DIVISION OF INSPECTION PROGRAMS
PERFORMANCE APPRAISAL SECTION (PAS)
Report:
50-267/85-26
Docket:
50-267
Licensee Nos. DPR-34
Licensee: Public Service Company of Colorado (PSC)
P. 0. Box 840
Denver, Colorado 80201
Facility Name: Fort St. Vrain Nuclear Generating Station
Inspection At: Fort St. Vrain (FSV) Site, Platteville, Colorado
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Inspection Conducted:
August 19-28, 1985
Inspectors:
/0 - 2. -ff'
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L. L. Wheeler, ORPB, IE, Team Leader
Date
h CV
/0 -2.- Br
J. E. Ofer, ORPB, IE
Date
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/0 -1,-b'
L. E. Whitn p RPB, IE
Date
Approved by:
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/b/MA
/c -V-4T
. F. McKee, Chief, Operating Reactors
Date
Programs Branch
Inspection Sunnary
Areas Inspected:
This routine safety inspection involved 152 inspection
hours on site in the areas of plant operations, sur-
veillance programs, and maintenance.
Results:
Three potential enforcement findings, referred to as un-
resolved items in the report and three open items were
identified during the inspection.
These items will be
followed up by the NRC Region IV office.
8510150146 851004
DR
ADOCK 050
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DETAILS
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1.
Persons Contacted
Licensee
B. Barta, Nuclear Engineer
- F. Borst, Manager, Support Services
- B. Burchfield, Superintendent, Nuclear Betterment Engineering
O. Clayton, Technical Services Engineer
- W. Craine, Maintenance Superintendent
D. Decatoire, Plant Operations
T. Dice, Plant Operations
- D. Evans, Operations Superintendent
- M. Ferris, QA Operations Manager
W. Franek, Plant Scheduling and Stores Superintendent
- C. Fuller, Station Manager
- J. Gahm, Nuclear Production Managar
- J. Gramling, Nuclear Licensing
R. Heller, Senior Plant Engineer
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D. Horshan, Plant Scheduling and Stores
J. Jackson, QA/QC Supervisor
C. Kasten, QA Computer Specialist
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R. Kevan, Plant Operations
S. Koleski, Plant Operations
J. McCauley, Results Engineering Supervisor
- F. Novachek, Technical / Administrative Services Manager
J. Petera, Maintenance Supervisor
G. Redmond, QC Supervisor _
C. Schmidt, Results Supervisor
- L. Singleton, QA Manager
H. Starner, Nuclear Site Construction Coordinator
J. Vandyke, Plant Operations
- D. Warembourg, Nuclear Engineering Manager
R. Webb, Maintenance Supervisor
J. Weller, Plant Operations
J. Wojtisek, Technical Services Engineer
Other licensee employees contacted included technician, operators, and
office personnel.
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NRC
R. Farrell, Senior Resident Inspector
- M. Skow, Region IV Project Inspector
- Attended exit interview.
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2.
Review of Plant Operations
a.
Operational Safety Verification
The control room was inspected daily to verify compliance with minimum
staffing requirements, access control, adherence to approved operating
procedures, and compliance with limiting conditions for operation (LCOs).
Reviews were made of logs, tagging requests, night orders, bypass logs,
and incident reports.
Two shift turnovers were also observed.
General housekeeping and professional demeanor in the control room were
satisfactory.
Normal background noise levels did not appear to have
an adverse effect on operator performance.
There were no unnecessary
personnel observed in the control room.
The following concerns were identified:
(1) The licensee's equipment control procedures did not comply
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with the requirements of THI Item I.C 6.
Procedure P-2,
Equipment Clearances and Operation Deviations, Issue 13, did
not require a second qualified person to verify the correct
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implementation of tagging activities.
On May 22, 1985,
NRC Region IV had requested a response within 120 days to
a similar finding that had been discussed at a Management
Conference on November 14, 1984.
Clearance control form
revisions were noted to be in progress during this inspec-
tion.
The licensee's compliance with the requirements of
TMI Item I.C.6 will remain an open item pending Region IV
acceptance of the licensee's response to their finding
(50-267/85-26-01).
(2) Procedure P-1, Plant Operations, did not provide adequate
control of temporary plant modifications.
Specifically,
Section 4.9, Control of Temporary Configuration, contained
no provisions for ensuring the temporary nature of modifi-
cations made under that procedure. At the time of the
inspection, 37 Temporary Configuration Requests (TCR) were
open from two to nine years.
The licensee had initiated
permanent design change notices (DCN) for several of these
TCRs, however at least 11 of these DCNs had been in prepara-
tion for over 2 years.
This lack of control of temporary
changes resulted in permanent changes being made to the
station without the necessary reviews being conducted.
The
failure to establish and implement procedures to adequately
control temporary plant modifications was discussed with the
licensee and will be incorporated into unresolved item
50-267/85-26-02 for followup by the Region IV Office.
b.
Corrective Action Systems
The system for performing trend analyses and management review of
Corrective Action Requests (CARS) was considered a strength.
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rective Action Effectiveness Summary Reports were issued monthly
with trend analyses and a current review of CARS by type (failure
to follow procedures, lack of training, etc.).
Monthly reports
are also issued to responsible departments identifying responses
due in the near future and overdue responses.
Overdue responses
received adequate management attention.
c.
Station Tours
The inspectors toured accessible areas of the plant.
During these
tours, observations were made of equipment condition, fire and safety
hazards, use of procedures, radiological controls and conditions,
housekeeping, and surveillance activities.
It was evident that a significant effort had been made to upgrade
the general housekeeping conditions of the plant.
Several major
portions of the plant were clean and free of clutter, debris, etc.
Maintenance personnel were observed making a deliberate effort to
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clean up the work site after performing repairs.
The licensee
had developed an extensive list of insulation repair requirements.
However, several safety hazards and basic housekeeping deficiencies
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were noted. These included a fire hazard from oil in overhead cable
trays, poor lighting in some areas, an open door on the back of an
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electrical cabinet, graffitti on the walls, some plant components
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in need of cleaning and repainting, a valve leaking onto exposed
insulation repair work in progress, damaged operating instructions
posted on an ammonia injection tank, chains for operating overhead
valves hanging down into passageways, and a safety seal missing from
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a relief valve.
Some of these deficiencies had been identified in past Region IV
inspection reports.
The region had made housekeeping an open item
twice in previous inspection reports (8325-03 and 8415-03), and
the latest SALP report (May 7, 1985) noted that housekeeping had
continued to be a problem.
Procedure SMAP-13, General Housekeeping
Program, specified inspection requirements, assigned responsibility
for designated plant zones, and provided directions for reporting
deficiencies.
However, the procedure had no provisions for tracking
specific deficiencies to ensure appropriate corrective action and
management review.
The apparent failure to develop and implement
adequate procedures for correcting housekeeping deficiencies will
remain an open item pending followup by Region IV (50-267/85-26-03).
d.
System Walkdown
The inspector conducted a walkdown and performed a valve lineup of
the "B" diesel generator to observe equipment conditions and system
lineups.
No valves were found in improper positions, but one valve
was not in accordance with the lineup sheet due to maintenance.
Deficiencies were noted in that the lineup procedure did not include
verification of the position of the following:
diesel engine cooling
water temperature control valves (TCVs), air valves on the TCV
regulators, lube oil drain valves, and lube oil drain plugs.
The
misposition of these items had the potential for causing damage to
the diesel engines to the extent that they could fail to operate.
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The lube oil heater inlet and outlet valves were not on the lineup
sheets, and they were not labeled.
The failure to provide adequate
procedures to ensure the operability of the diesel generators will
remain an open item pending followup by Region IV (50-267/85-26-04).
3.
Surveillance Activities
The inspectors reviewed recent surveillance test results for the
a.
station and power plant systems (PPS) batteries, and the recently
issued interim Technical Specifications (TS) for reactivity control.
The following documents, tests and records were reviewed:
Document Number
Topic
SR 4.1.1.B. 1/2-W
Control Rod Ope * ability
through 4.1.1.F.lb-R
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SR 4.1.2.A.3-W
Rod Position Indication Systems-
through 4.1.2.c x
Operation
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SR 4.1.3.B-R
Rod Position Indication Systems-
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through 4.1.3.D-W/R
Shutdown
SR 4.1.4.A-W/
SR 4.1.4-8-P-X
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SR 4.1.6.C/D-X
Control Rod Position Requirements-
Shutdown
SR 4.1.8.A/8-W
Reserve Shutdown System-Operation
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through 4.1.8.0-A
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SR 4.1.9.A/B-W
Reserve Shutdown System-Shutdown
through 4.1.9.D.1-R
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SR 5.4.5-M
PCRV Cooling Water Flow Scan
Functional Test
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SR 5.4.1.3.2.b-M
Feedwater Flow Test
SR 5.6.2a-W, Issue 23
Station and PPS Battery Check
for weeks #29, 30, 31
(Weekly)
SR 5.6.2b-M, Issue 1,
Station and PPS Battery Check
for week #27
(Monthly)
SR 5.6.2b-Q, Issue 20,
Station and PPS Battery Check
for week #31
(Quarterly)
SR 5.6.2c-A, Issue 17,
Station and PPS Battery Check
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for week #9
(Annual)
TCR 85-04-01
Request to jumper cell 35 out of
Battery 1A (N9242)
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Change Notice (CN) 1391
Replace Station Batteries IA and
IB.
The inspectors found that the interim TS for reactivity control
appeared to have been properly implemented by the surveillance
procedures.
The surveillance procedures for the feedwater flow
test and control rod operability also appeared adequate.
Procedure SR 5.4.5-M allowed the potential for errors in PCRV Cooling
Water Flow alarm setpoint restoration.
The licensee had previously
identified this deficiency and was processing a procedure change to
correct this weakness.
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The inspector reviewed the TS compliance log maintained by control
room personnel and the daily surveillance status printouts provided
by the licensee's scheduling organization.
These documents appeared
thorough, concise and effective.
No missed surveillances were
identified in this review.
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b.
The licensee failed to establish procedures that complied with TS
requirements in the following instances:
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(1) The weekly battery surveillance test, 5.6.2a-W, did not
measure the temperature of cells adjacent to the pilot
cell as required by TS 5.6.2a.
(2) Neither the monthly nor quarterly surveillance tests, SR 5.6.2b-M and SR 5.6.2b-Q, measured the height of the
electrolyte in the sampled cells as required by TS 5.6.2b.
SR 5.6.2b-M verified that all cell electrolyte levels were
within the vendor specified operating band, but this was
recorded by a single check mark on the data sheet and there
were no cell measurements taken or recorded.
(3) The licensee modified the configuration of a station battery
and returned the battery to an operable status without adequa-
tely considering whether the modified battery would meet the
requirements of TS 5.6.2c.
The annual discharge test of
battery IB conducted in April 1985 was performed with a spare
cell connected to the battery (59 cells total).
On the basis
of the performance of this 59 cell battery during the discharge,
the licensee determined that battery capacity was acceptable
in accordance with TS 5.6.2c and the battery was operable.
Subsequently, the spare cell was removed from battery IB, but
there was apparently no discharge test ur evaluation conducted
to determine that the resulting 58 cell battery would meet the
necessary operability requirements of the TS.
The apparent failure by the licensee to develop procedures to ade-
quately implement TS surveillance requirements for determining
battery operability was discussed with the licensee and will be
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incorporated into unresolved item 50-267/85-26-02 for followup by
the NRC Region-IV Office.
TS 4.6.1 requires that the station and
PPS batteries be operable before the reactor is operated at power.
The surveillance test results reviewed by the inspectors were for
a period when the reactor was shutdown and therefore the violation
of a limiting condition for operation (LCO) was not involved.
c.
The licensee failed to follow procedure SR 5.6.2c-A for the annual
battery partial discharge test.
The results from this discharge
test satisfied the TS 5.6.2c requirements, however, the following
implementation deficiencies were identified:
(1) Procedure Deviation Request (PDR) 85-1032 revised the procedure
to discharge the station batteries (IA, IB) at 85 amps for 24
hours and the PPS battery at 79 amps for 12 hrs or until the
battery terminal voltage reached 101.5 volts.
Battery IB was
discharged at 35 amps for only 19.2 hrs and the PPS battery _was
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discharged at 79 amps for only 9.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> without either battery
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reaching.its minimum terminal voltage.
Interviews revealed that
these discharges were terminated by the personnel performing the
tests without prior management approval.
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(2) The end of discharge specific gravities for each cell of battery
1A and 18 were all recorded at 1.100 and 1.160, respectively.
In-
terviews with maintenance personnel revealed that these readings
were the minimum detectable values of the hydrometers used to
record the end of discharge data.
The actual battery cell specific
gravities were lower than the recorded values and this information
was not recorded on the surveillance data sheet.
(3) Although cell 35 was jumpered from battery 1A and did not participate
in the discharge test, the final individual cell voltage ICV and
specific gravity readings decreased from 2.07 VDC to 1.88 VDC and
1.210 to 1.100, respectively.
These post discharge readings were
indicative of the cell participating in the battery discharge test.
The apparent failure by the licensee to follow procedure SR 5.6.2c-A
for the annual discharge test of the station and PPS batteries was
discussed with the licensee and will be incorporated into unresolved
item 50-267/85-26-02 for followup by the NRC Region IV Office.
4.
Maintenance Activities
The inspectors observed the material condition of and reviewed completed
maintenance actions and procedures for batteries and motor operated
valves (MOV).
The helium circulator turbine steam inlet isolation
valves (HV-2245, HV-2246, HV-2247 HV-2248) were the MOVs of interest
during this inspection.
Additionally, replacement parts used for
safety-related maintenance actions were traced to their origin to
determine their acceptability.
The following documents were reviewed:
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Document Number
Topic
Station Operating Procedure
Electrical Distribution - AC System
(SOP) 92-06, Issue 7
Station Service Request (SSR)
Replace Frequency Meter for Battery
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84500238 P.O. 53476
1C Inveter
SSR 84500283/287,
Rebuild Snubbers
P.O. N4585
SSR 84501102
Repair Motor For HV-2248
NCR 85-563
EMP 45,
Disconnecting, Reconnecting and
Issue 1
Testing of Limitorque or Rotork
Values
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MP 39.3,
Maintenance and Repair of Rotork
Issue 3
Valve Controllers
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PM 92.10,
Inspection and Preventive Main-
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Issue 24
tenance of Caterpillar Diesel -
Emergency Generator Units
SMAP-21,
Post Maintenance Testing Require-
Issues 1
ments in Maintenance Related
Procedures
P-5,
Material Control
Issue 8
Q-4,
Procurement Document Control
Issue 6
91-M-1-28-5
Rotork Instruction Handbook for
Synchroset Electric Valve Actuators
The inspectors reviewed three safety related station service requests
a.
(SSR) to determine the suitability of replacement parts being used
for maintenance.
Deficiencies were identified with each SSR as
identified below:
(1) The safety-related frequency meter replaced by SSR 84500238 was
procured under a non-safety related purchase order without any
of the required certifications and no attempt was made to qualify
the meter for safety related use.
The installation of this meter
was approved by Maintenance Quality Control (MQC).
(2) Safety-related snubber 0-Rings, replaced by SSR 84500283/287,
were purchased via a parts distributor from a manufacturer not
on the qualified vendors list.
A certification of conformance
was provided from the parts distributor to the licensee without
supporting documentation from the man ~ufacturer.
This document
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was used as the basis for the receipt inspection acceptance,
even though the certificate was not traceable to the original
manufacturer and the original manufacturer did not have an
approved QA program.
(3) The motor installed on valve HV-2248 by SSR 84501102 was rewound
by a vendor not on the approved vendors list.
The licensee
identified this deficiency with NCR 85-563 and had performed a
component qualification test to upgrade the motor for safety-
related applications.
The qualification test consisted of
meggering the motor windings to confirm proper electrical
refurbishment and a post installation vibration test to verify
correct bearing installation.
The only documentation of test
performance was the statement " Valve test cks okay:
Valve is
electrically okay".
There was no record of the measured test
results or the instruments utilized to obtain the vibration
and resistance measurements.
The licensee did not review the
vendor's process or materials used for rewinding the motor.
The inspectors concluded that the tests and documentation were
inadequate to ensure that the replacement motor was equal to
or better than the original construction phase component.
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(4) Gearcase oil used for MOV applications differed from that
recommended by the vendor manual and may not have been suitable
for the environment of all plant MOVs.
Procedure MP 39-3 and
the vendor manual specify the use of SAE 80 EP oil in the
gearcase of motor operated valves.
Discussions with maintenance
personnel revealed that Mobil 629 oil was being used for all
MOV applications.
The licensee had not performed an engineering
evaluation to determine that the Mobil 629 oil sas suitable for
all MOV applications or compatible with residual oil that may
have been in the gearcase.
The inspector also noted that SAE 80 EP oil was rated for
operation only to 180 F and this was significantly below the
737 F helium circulator inlet steam temperature listed in the
updated FSAR, Fig 10.2-3, for 100% power operations.
During
the inspection, the licensee measured the gearcase temperature
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of HV-2247 at approximately 140 F with lower temperature steam
being supplied from the auxiliary boilers.
The suitability of
both Mobil 629 and SAE 80 EP oil under these high temperature
operating conditions is questionable.
The Ft. St. Vrain Quality Assurance (QA) Plan, Appendix 8 to
the FSAR, requires that safety-related items be purchased from
approved suppliers, receipt inspected and, if procured sole
source, procured to standards that will assure an equal to or
better than original condition.
The apparent failure to procure
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safety-related replacement items in accordance with their QA
Plan was discussed with the licensee and will remain unresolved
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pending followup by the NRC Region IV Office (50-267/85-26-05).
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b.
The inspectors reviewed the material condition of the four helium
circulator turbine inlet steam isolation valves (HV-2245, HV-2246,
HV-2247 and HV-2248).
In addition to the improperly qualified motor
installed in HV-2248 (see section 4.a.(3) of this report), valves
HV-2247 and HV-2248 were leaking oil from their gearcase, and
valves HV-2246 and HV-2248 local position indicators differed from
their remote indication.
Both valves indicated in the mid position
locally, while valve HV-2246 indicated shut remotely and valve
HV-2248 indicated open remotely.
The licensee verified the remote
positions to be correct.
Contributing to these material deficien-
cies were the following procedure and implementation problems with
the MOV maintenance program:
(1) The electrical maintenance procedure for MOV motor installation,
testing and documentation was inadequate.
Procedure EMP 45
provided for verifying proper motor rotation by momentarily
touching the motor leads to an energized terminal and jogging
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the motor in the closed direction.
This appears contrary to
the vendor manual which directs that the motor be energized
from the operating switch to verify rotation.
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Paragraph 3.9 of procedure EMP-45 provided general guidance for
documenting the as found/as lef t condition of the valve but
there was no requirement to record the torque or limit switch
settings when adjusting these setpoints.
A review of two com-
pleted SSR packages revealed that these setpoint values were
not recorded.
The post installation testing for MOV motors consisted of cycling
the valve to verify proper operation, circuit integrity and posi-
tion indication.
However, there were no quantitative acceptance
criteria for determining proper valve operation even though
nominal valve operating speeds were provided in the vendor
manual.
MQC was not required to observe the test and the
determination of proper valve operation was left to the
judgement of the workman performing the maintenance.
(2) The torque values listed for use in the MOV mechanical repair
procedure had an inadequate technical basis and their use was
optional.
Procedure MP 39-3 had a table of MOV torque values
that were based on bolt size.
The table was identical to one
in procedure PM 92.10 for diesel generator maintenance and was
based on values in the diesel generator vendor manual.
Addi-
tionally, a note at the bottom of the table made torque wrench
use optional by stating that:
An average man on a 12 inch wrench can develop about
100 ft. Ib. of torque.
Therefore, if a torque wrench
is not available, or cannot be used, use the following
wrench-bolt combinations:
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Bolt Sizes, Inches 1/2
9/16
5/8
3/4
7/8
1-1/8
Wrench Sizes, Inches 6
9
12
18
24
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For larger bolting where specific torque values are
not stated and/or configuration precludes the use of
torque equipment, standard striking wrenches may be
used by qualified mechanics working to industrial
journeyman standards.
The technical basis for this note was a vendor valve manual
notation applying to stud nuts and cap screws.
The licensee
had applied the torque values for diesel generators and other
valves to MOVs without any apparent engineering justification.
(3) The post maintenance testing of valve HV-2246 was signed off by
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MQC as being complete when plant conditions would not support
the operational test.
Procedure MP 39.3, section 6.1, stated
that the post maintenance testing acceptance criteria was " Valve
Stroke and limit switch settings are acceptable for system re-
quirements at operating pressure and temperature".
There were
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no quantitative acceptance limits provided in the procedure to
determine this acceptability and MQC signed off this part of
the procedure on February 23, 1985 for SSR 84500240. At this
time the reactor was shutdown and steam was being supplied to
the helium circulators from the auxiliary boilers which are not
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capable of producing steam at operating temperatures and pressures.
There was no outstanding action item to test this valve when the
plant was at normal operating temperatures and pressures.
The
licensee had no assurance that this valve would operate as designed
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under expected operation conditions,
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Station battery maintenance and surveillance procedures were incon-
c.
sistent with the guidance provided by the battery vendoe manual.
The following inconsistencies were identified:
(1) The battery ventilation low flow monitor was alarming in the
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control room and exhaust air flow from battery rooms 1A and 1B
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appeared to be insufficient to meet the vendor manual recommen-
dations for removing hydrogen gas during charging evolutions.
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(2) The upper temperature limit specified on the surveillance
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procedures for a battery receiving a float charge was 110*F.
This was contrary to the vendor manual which recommended
maximum allowable battery temperatures of 110 F during
equalizing charge evolutions and only 90 F for float charge
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conditions.
The inspecter observed a pilot cell temperature
of 92*F in battery 1A on August 22, 1985.
The battery vendor
manual stated that continued operation at this elevated tem-
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perature could degrade the battery capacity and life.
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(3) Battery specific gravity and individual cell voltage (ICV)
measurements were not analyzed to determine whether an equali-
zing charge should be performed.
The battery vendor manual
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recommended that an equalizing charge be conducted when the
specific gravity of any cell dropped .010 from an initial
standard value or any cell ICV was below 2.13 VDC.
Instead,
the licensee performed an equalizing charge monthly in accor-
dance with 50P 92-06.
There was no in progress monitoring
of these charges and the end of charge parameters were not
measured to verify improved battery conditions.
(4) There were no procedures for periodically checking battery
intercell resistances and connector tightness, adding water
to individual cells, or cleaning the battery with approved
solvents.
The apparent failure to establish, implement and maintain adequate battery, and
MOV maintenance and testing procedures was discussed with the licensee and will
be incorporated into unresolved item 50-267/85-26-02 for followup by the
NRC Region IV Office.
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5.
Post-Modification Testing
The licensee did not ensure that all required post-modification tests
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were developed as part of modification work packages.
The NRC inspector
reviewed Change Notices (CN's) 1798 and 1798-A and their associated
Controlled Work Procedures (CWP's) 84-92, 84-93, 84-94, 84-95 and 85-560
wnich replaced Emergency Water Booster Pumps (Fire Water Booster Pumps)
P-2109 and P-2110 with pumps having a higher output head.
These pumps
could be used to drive the helium circulator turbine to achieve adequate
core cooling in the event of the failure of three feedwater pumps.
The
CWP's for this modification did not contain post-installation flow tests
for the new emergency water booster pumps.
The failure to develop adequate
controls to ensure that all required post-modification testing was conducted
was discussed with the licensee and will remain an unresolved item pending
review by Region IV (50-267/85-26-06).
6.
Unresolved and Open Items:
Unresolved items are matters about which more information is required to
determine whether it is an acceptable item, a deviation, or a violation.
A open item is a matter that requires further review and evaluation by
the inspectors. The following unresolved and open items will be followed
by the NRC Region IV office.
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(50-267/85-26-01) (0 pen Item) The revision of equipment control procedures
to establish compliance with TMI Item I.C.6.
This item will remain open
pending NRC Region IV acceptance of the revised procedures (Item 2.a(1)).
(50-267/85-26-02) (Unresolved) The failure to establish adequate procedures
for control of temporary plant modifications, station battery maintenance
and surveillance tests, and motor operated valve maintenance.
Also, the
apparent failure to comply with procedures for battery surveillances and
motor operated valve maintenance (Items 2.a(2), 3b, 3c, 4b, and 4c).
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(50-267/85-16-03) (0 pen Item) The revision of housekeeping procedures to
provide a means for ensuring specific deficiencies are corrected.
This
item will remain open pending NRC Region IV acceptance of the revised
procedures (Item 2.c).
l
(50-267/85-16-04) (0 pen Item) The adequacy of the diesel generator valve
'
lineup procedure to ensure the availability of the system.
The item
will remain open pending NRC Region IV followup of potential weaknesses
in the lineup procedure (Item 2.d).
(50-267/85-26-05) (Unresolved) The failure to procure safety-related
replacement items in accordance with the QA plan requirements (Item
,
4.a).
(50-267/85-26-06) (Unresolved) The failure to establish adequate
controls to ensure the performance of required post-modification
4
testing (Item 5).
>
7.
The findings of this inspection were discussed with those persons indicated
in paragraph 1 on August 29, 1985.
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON. D. C. 20555
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October 8,1933
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Docket No. 50-267/85-26
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Public Service Company of Colorado
ATTN: Mr. O. R. Lee, Vice President
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Electric Production
P. O. Box 840
!
Denver, Colorado 80201
Gentlemen:
i
This refers to the routine safety inspection conducted by L. L. Wheeler,
'
J. E. Dyer and L. E. Whitney of this office on August 19-28, 1985 of
activities at the Fort St. Vrain Nuclear Generating Station authorized by
'
NRC Operating License DPR-34.
The inspection findings were discussed with
J. Gahm and others of your staff during and at the conclusion of the
4
inspection.
The enclosed inspection report includes findings of significant weaknesses
in several maintenance-related areas (maintenance of station batteries and
t
motor operated valves, post-modification testing, and the safety-related
qualification of replacement parts).
3
The most recent SALP report (May 7,
l
1925) considered your maintenance activities to be minimally satisfactory
with respect to operational safety.
The findings of this inspection confirm
that assessment and indicate that your corrective action has not been effective.
The NRC will focus increased inspection attention on your maintenance and main-
i
tenance-related activities until improved performance is achieved.
The enclosed report includes findings that may result in enforcement actions.
Disposition of these potential enforcement findings, referred to as unresolved
i
items in the report, will be made by the NRC Region IV office.
In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of
this letter and the enclosed inspection report will be placed in the NRC's
Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
4
Sincerely,
4
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James G. Partiow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
Enclosure:
Inspection Report No. 50-267/85-26
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L. L. Wheeler, IE
L. J. Callan, IE
P. F. McKee, IE
R. L. Spessard, IE
J. G. Partlow, IE
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J. M. Taylor, IE
R. P. Denise, Region IV
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0FFICE OF INSPECTION AND ENFORCEMENT
DIVISION OF INSPECTION PROGRAMS
PERFORMANCE APPRAISAL SECTION (PAS)
,
Report:
50-267/85-26
Docket:
50-267
Licensee Nos. DPR-34
Licensee: Public Service Company of Colorado (PSC)
,
P. O. Box 840
,
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Denver, Colorado 80201
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Facility Name: Fort St. Vrain Nuclear Generating Station
Inspection At: Fort St. Vrain (FSV) Site, Platteville, Colorado
Inspection Conducted:
August 19-28, 1985
>
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Inspectors:
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L. L. Wheeler, ORPB, IE, Team Leader
Date
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J. E. Ofer, ORPB, IE
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L. E. WhitnegRP8, IE
Date
Approved by:
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F. McKee, Chief, Operating Reactors
Date
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Programs Branch
Inspection Sumary
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Areas inspected:
This routine safety inspection involved 152 inspection
i
hours on site in the areas of plant operations, sur-
veillance prograns, and maintenance.
Results:
Three potential enforcement findings, referred to as un-
resolved items in the report and three open items were
identified during the inspection.
These items will be
followed up by the NRC Region IV office.
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DETAILS
l.
1.
Persons Contacted
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Licensee
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B. Barta, Nuclear Engineer
- F. Borst, Manager, Support Services
- B. Burchfield, Superintendent, Nuclear Betterment Engineering
0. Clayton, Technical Services Engineer
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- W. Craine, Maintenance Superintendent
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D. Decatoire, Plant Operations
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T. Dice, Plant Operations
- D. Evans, Operations Superintendent
- M. Ferris, QA Operations Manager
W. Franek, Plant Scheduling and Stores Superintendent
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- C. Fuller, Station Manager
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- J. Gahm, Nuclear Production Manager
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- J. Gramling, Nuclear Licensing
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R. Heller, Senior Plant Engineer
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D. Horshan, Plant Scheduling and Stores
J. Jackson, QA/QC Supervisor
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C. Kasten, QA Computer Specialist
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R. Kevan, Plant Operations
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S. Koleski, Plant Operations
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J. McCauley, Results Engineering Supervisor
- F. Novachek, Technical / Administrative Services Manager
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J. Detera, Maintenance Supervisor
G. Redmond, QC Supervisor
C. Schmidt, Results Supervisor
- L. Singleton, QA Manager
4
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H. Starner, Nuclear Site Construction Coordinator
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J. Vandyke, Plant Operations
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- D. Warembourg, Nuclear Engineering Manager
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R. Webb, Maintenance Supervisor
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J. Weller, Plant Operations
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J. Wojtisek, Technical Services Engineer
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Other licensee employees contacted included technicia.n, operators, and
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office personnel.
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NRC
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R. Farrell, Senior Resident Inspector
,
- M. Skow, Region IV Project Inspector
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Attended exit interview.
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2.
Review of Plant Operations
a.
Operational Safety Verification
The control room was inspected daily to verify compliance with minimum
staffing requirements, access control, adherence to approved operating
procedures, and compliance with limiting conditions for operation (LCOs).
Reviews were made of logs, tagging requests, night orders, bypass logs,
and incident reports.
Two shift turnovers were also observed.
General housekeeping and professional demeanor in the control room were
satisfactory.
Normal background noise levels did not appear to have
an adverse effect on operator performance.
There were no unnecessary
personnel observed in the control room.
The following concerns were identified:
,
(1) The licensee's equipment control procedures did not comply
'
with the requirements of TMI Item I.C.6.
Proceoure P-2,
Equipment Clearances and Operation Deviations, Issue 13, did
not require a second qualified person to verify the correct
,,
implementation of tagging activities.
On May 22, 1985,
NRC Region IV had requested a response within 120 days to
a similar finding that had been discussed at a Management
Conference on November 14, 1984.
Clearance control form
revisions were noted to be in progress during this inspec-
tion.
The licensee's compliance with the requirements of
TMI Item I.C.6 will remain an open item pending Region IV
acceptance of the licensee's response to their finding
(50-267/85-26-01).
(2) Procedure P-1, Plant Operations, did not provide adequate
control of temporary plant modifications.
Specifically,
Section 4.9, Control of Tempcrary Configuration, contained
no provisions for ensuring the temporary nature of modifi-
cations made under that procedure.
At the time of the
inspection, 37 Temporary Configuration Requests (TCR) were
open from two to nine years.
The licensee had initiated
permanent design change notices (DCN) for several of these
TCRs, however at least 11 of these DCNs had been in prepara-
tion for over 2 years.
This lack of control of temporary
changes resulted in permanent changes being made to the
station without the necessary reviews being conducted.
The
failure to establish and implement procedures to adequately
control temporary plant modifications was discussed with the
licensee and will be incorporated into unresolved item
50-267/85-26-02 for followup by the Region IV Office,
b.
Corrective Action Systems
The system for performing trend analyses and management review of
Corrective Action Requests (CARS) was considered a strength.
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rective Action Effectiveness Summary Reports were issued monthly
with trend analyses and a current review of CARS by type (failure
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to follow procedures, lack of training, etc.).
Monthly reports
are also issued to responsible departments identifying responses
due in the near future and overdue responses.
Overdue responses
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received adequate management attention.
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c.
Station Tours
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The inspectors toured accessible areas of the plant.
During these
tours, observations were made of equipment condition, fire and safety
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hazards, use of procedures, radiological controls and conditions,
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housekeeping, and surveillance activities.
It was evident that a significant effort had been made to upgrade
the general housekeeping conditions of the plant.
Several major
portions of the plant were clean and free of clutter, debris, etc.
Maintenance personnel were observed making a deliberate effort to
>
clean up the work site after performing repairs.
The licensee
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had developed an extensive list of insulation repair requirements.
!
However, several safety hazards and basic housekeeping deficiencies
"
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were noted.
These included a fire hazard from oil in overhead cable
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trays, poor lighting in some areas, an open door on the back of an
1
electrical cabinet, graffitti on the walls, some plant components
in need of cleaning and repainting, a valve leaking onto exposed
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insulation repair work in progress, damaged operating instructions
posted on an ammonia injection tank, chains for operating overhead
valves hanging down into passageways, and a safety seal missing from
a relief valve.
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Some of these deficiencies had been identified in past Region IV
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inspection reports.
The region had made housekeeping an open item
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twice in previous inspection reports (8325-03 and 8415-03), and
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the latest SALP report (May 7,1985) noted that housekeeping had
continued to be a problem.
Procedure SMAP-13, General Housekeeping
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Program, specified inspection requirements, assigned responsibility
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for designated plant zones, and provided directions for reporting
deficiencies.
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However, the procedure had no provisions for tracking
specific deficiencies to ensure appropriate corrective action and
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management review.
The apparent failure to develop and implement
adequate procedures for correcting housekeeping deficiencies will
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remain an open item pending followup by Region IV (50-267/85-26-03).
d.
System Walkdown
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The inspector conducted a walkdown and performed a valve lineup of.
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the "B" diesel generator to observe equipment conditions and system
lineups.
No valves were found in improper positions, but one valve
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was not in accordance with the lineup sheet due to maintenance.
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Deficiencies were noted in that the lineup procedure did not include
verification of the position of the following:
diesel engine cooling
water temperature control valves (TCVs), air valves on the TCV
regula~ tors, lube oil drain valves, and lube oil drain plugs.
The
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misposition of these items had the potential for causing damage to
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the diesel engines to the extent that they could fail to operate.
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The lube oil heater inlet and outlet valves were not on the lineup
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sheets, and they were not labeled.
The failure to provide adequate
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procedures to ensure the operability of the diesel generators will
remain an open item pending followup by Region IV (50-267/85-26-04).
3.
Surveillance Activities
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The inspectors reviewed recent surveillance test results for the
a.
station and power plant systems (PPS) batteries, and the recently
issued interim Technical Specifications (TS) for reactivity control.
The following documents, tests and records were reviewed:
Document Number
Topic
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SR 4.1.1.B. 1/2-W
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Control Rod Operability
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through 4.1.1.F.1b-R
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SR 4.1.2.A.3-W
Rod Position Indication Systems-
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through 4.1.2.c-x
Operation
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SR 4.1.3.B-R
Rod Position Indication Systems-
through 4.1.3.D-W/R
Shutdown
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SR 4.1.4.A-W/
SR 4.1.4-8-P-X
SR 4.1.6.C/D-X
Control Rod Position Requirements-
Shutdown
3
SR 4.1.8.A/8-W
through 4.1.8.0-A
Reserve Shutdown System-Operation
SR 4.1.9.A/B-W
through 4.1.9.D.1-R
Reserve Shutdown System-Shutdown
SR 5.4.5-M
PCRV Cooling Water Flow Scan
Functional Test
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SR 5.4.1.3.2.b-M
Feedwater Flow Test
SR 5.6.2a-W, Issue 23
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for weeks #29, 30, 31
Station and PPS Battery Check
(Weekly)
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SR 5.6.2b-M, Issue 1,
Station and PPS Battery Check
for week #27
4
(Monthly)
)
SR 5.6.2b-Q, Issue 20,
Station and PPS Battery Check
for week #31
(Quarterly)
SR 5.6.2c-A, Issue 17,
Station and PPS Battery Check
for week #9
(Annual)
TCR 85-04-01
Request to jumper cell 35 out of
Battery 1A (N9242)
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Change Notice (CN) 1391
Replace Station Batteries IA and
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18.
The inspectors found that the interim TS for reactivity control
appeared to have been properly implemented by the surveillance
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procedures.
The surveillance procedures for the feedwater flow
test and control rod operability also appeared adequate.
I
Procedure SR 5.4.5-M allowed the potential for errors in PCRV Cooling
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Water Flow alarm setpoint restoration.
The licensee had previously
identified this deficiency and was processing a procedure change to
correct this weakness.
i
The inspector reviewed the TS compliance log maintained by control
room personnel and the daily surveillance status printouts provided '
by the licensee's scheduling organization.
These documents appeared
thorough, concise and effective.
No missed surveillances were
i
identified in this review.
>
b.
The licensee failed to establish procedures that complied with TS
j
requirements in the following instances:
,,
(1) The weekly battery surveillance test, 5.6.2a-W, did not
measure the temperature of cells adjacent to the pilot
cell as required by TS 5.6.2a.
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(2) Neither the monthly nor quarterly surveillance tests, SR
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5.6.2b-M and SR 5.6 2b-Q, measured the height of the
electrolyte in the sampled cells as required by TS 5.6.2b.
SR 5.6.2b-M verified that all cell electrolyte levels were
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within the vendor specified operating band, but this was
recorded by a single check mark on the data sheet and there
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were no cell measurements taken or recorded.
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(3) The licensee modified the configuration of a station battery
and returned the battery to an operable status without adequa-
tely considering whether the modified battery would meet the
requirements of TS 5.6.2c.
The annual discharge test of
battery IB conducted in April 1985 was performed with a spare
cell connected to the battery (59 cells total). On the basis
of the performance of this 59 cell battery during the discharge,
i
the licensee determined that battery capacity was acceptable
i
in accordance with TS 5.6.2c and the battery was operable.
i
Subsequently, the spare cell was removed from battery 1B, but
there was apparently no discharge test or evaluation conducted
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to determine that the resulting 58 cell battery would meet the
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necessary operability requirements of the TS.
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The apparent failure by the licensee to develop procedures to ade-
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quately implement TS survelliance requirements for determining
battery operability was discussed with the licensee and will be
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incorporated into unresolved item 50-267/85-26-02 for followup by
the NRC Region IV Office.
TS 4.6.1 requires that the station and
PPS batteries be operable before the reactor is operated at power.
The surveillance test results reviewed by the inspectors were for
a period when the reactor was shutdown and therefore the violation
of a limiting condition for operation (LCO) was not involved.
c.
The licensee failed to follow procedure SR 5.6.2c-A for the annual
battery partial discharge test.
The results from this discharge
test satisfied the TS 5.6.2c requirements, however, the following
implementation deficiencies were identified:
(1) Procedure Deviation Request (PDR) 85-1032 revised the procedure
to discharge the station batteries (IA, IB) at 85 amps for 24
hours and the PPS battery at 79 amps for 12 hrs or until the
battery terminal voltage reached 101.5 volts.
Battery IB was
discharged at 85 amps for only 19.2 hrs and the PPS battery was
discharged at 79 amps for only 9.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> without either battery
>
reaching its minimum terminal voltage.
Interviews revealed that
these discharges were terminated by the personnel performing the
tests without prior management approval.
,,
(2) The end of discharge specific gravities for each cell of battery
1A and IB were all recorded at 1.100 and 1.160, respectively.
In-
terviews with maintenance personnel revealed that these readings
were the minimum detectable values of the hydrometers used to
record the end of discharge data.
The actual battery cell specific
gravities were lower than the recorded values and this information
was not recorded on the surveillance data sheet.
(3) Although cell 35 was jumpered from battery 1A and did not participate
in the discharge test, the final individual cell voltage ICV and
specific gravity readings decreased from 2.07 VOC to 1.88 VDC and
1.210 to 1.100, respectively.
These post discharge readings were
indicative of the cell participating in the battery discharge test.
The apparent failure by the licensee to follow procedure SR 5.6.2c-A
for the annual discharge test of the station and PPS batteries was
discussed with the licensee and will be incorporated into unresolved
item 50-267/85-26-02 for followup by the NRC Region IV Office.
4.
Maintenance Activities
The inspectors observed the material condition of and reviewed completed
maintenance actions and procedures for batteries and motor operated
valves (MOV).
The helium circulator turbine steam inlet isolation
valves (HV-2245, HV-2246, HV-2247, HV-2248) were the MOVs of interest
during this inspection.
Additionally, replacement parts used for
safety-related maintenance actions were traced to their origin to
determine their acceptability.- The following documents were reviewed:
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Document Number
Topic
Station Operating Procedure
Electrical Distribution - AC System
(SOP) 92-06, Issue 7
Station Service Request (SSR)
Replace Frequency Meter for Battery
84500238 P.O. 53476
1C Inveter
SSR 84500283/287,
Rebuild Snubbers
P.O. N4585
SSR 84501102
Repair Motor For HV-2248
NCR 85-563
EMP 45,
Disconnecting, Reconnecting and
Issue 1
Testing of Limitorque or Rotork
Values
MP 39.3,
Maintenance and Repair of Rotork
Issue 3
Valve Controllers
E
PM 92.10,
Inspection and Preventive Main-
Issue 24
tenance of Caterpillar Diesel -
Emergency Generator Units
SMAP-21,
Post Maintenance Testing Require-
Issues 1
ments in Maintenance Related
Procedures
P-5,
Material Control
Issue 8
Q-4,
Procurement Document Control
Issue 6
91-M-1-28-5
Rotork Instruction Handbook for
Synchroset Electric Valve Actuators
The inspectors reviewed three safety-related station service requests
a.
(SSR) to determine the suitability of replacement parts being used
for maintenance.
Deficiencies were identified with each SSR as
identified below:
(1) The safety-related frequency meter replaced by SSR 84500238 was
procured under a non-safety related purchase order without any
of the required certifications and no attempt was made to qualify
the meter for safety related use.
The installation of this meter
was approved by Maintenance Quality Control (MQC).
(2) Safety-related snubber 0-Rings, replaced by SSR 84500283/287,
were purchased via a parts distributor from a manufacturer not
on the qualified vendors list.
A certification of conformance
was provided from the parts distributor to the licensee without
supporting documentation from the manufacturer.
This document
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was used as the basis for the receipt inspection acceptance,
even though the certificate was not traceable to the original
manufacturer and the original manufacturer did not have an
,
approved QA program.
(3) The motor installed on valve HV-2248 by SSR 84501102 was rewound
by a vendor not on the approved vendors list.
The licensee
i
identified this deficiency with NCR 85-563 and had performed a
component qualification test to upgrade the motor for safety-
i
related applications.
The qualification test consisted of
meggering the motor windings to confirm proper electrical
refurbishment and a post installation vibration test to verify
correct bearing installation.
The only documentation of test
performance was the statement " Valve test cks okay: Valve is
electrically okay".
There was no record of the measured test
results or the instruments utilized to obtain the vibration
and resistance measurements.
The licensee did not review the
vendor's process or materials used for rewinding the motor.
j
The inspectors concluded that the tests and documentation were
inadequate to ensure that the replacement motor was equal to
or better than the original construction phase component.
..
(4) Gearcase oil used for MOV applications differed from that
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recommended by the vendor manual and may not have been suitable
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for the environment of all plant MOVs.
Procedure MP 39-3 and
the vendor manual specify the use of SAE 80 EP oil in the
gearcase of motor operated valves.
Discussions with maintenance
personnel revealed that Mobil 629 oil was being used for all
4
MOV applications.
The licensee had not performed an engineering
evaluation to determine that the Mobil 629 oil was suitable for
all MOV applications or compatible with residual oil that may
i
have been in the gearcase.
The inspector also noted that SAE 80 EP oil was rated for
operation only to 180 F and this was significantly below the
,
737'F helium circulator inlet steam temperature listed in the
updated FSAR, Fig 10.2-3, for 100% power operations.
During
the inspection, the licensee measured the gearcase temperature
,
of HV-2247 at approximately 140*F with lower temperature steam
'
being supplied from the auxiliary boilers.
The suitability of
i
both Mobil 629 and SAE 80 EP oil under these high temperature
operating conditions is questionable.
The Ft. St. Vrain Quality Assurance (QA) Plan, Appendix B to
the FSAR, requires that safety-related items be purchased from
i
approved suppliers, receipt inspected and, if procured sole
source, procured to standards that will assure an equal to or
,
better than original condition.
The apparent failure to procure
i
safety-related replacement items in accordance with their QA
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Plan was discussed with the licensee and will remain unresolved
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pending followup by the NRC Region IV Office (50-267/85-26-05).
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b.
The inspectors reviewed the material condition of the four helium
circulator turbine inlet steam isolation valves (HV-2245, HV-2246,
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HV-2247 and HV-2248).
In addition to the improperly qualified motor
installed in HV-2248 (see section 4.a.(3) of this report), valves
HV-2247 and HV-2248 were leaking oil from their gearcase, and
valves HV-2246 and HV-2248 local position indicators differed from
their remote indication.
Both valves indicated in the mid position
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locally, while valve HV-2246 indicated shut remotely and valve
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HV-2248 indicated open remotely.
The licensee verified the remote
positions to be correct.
Contributing to these material deficien-
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cies were the following procedure and implementation problems with
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the MOV maintenance program:
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(1) The electrical maintenance procedure for MOV motor installation,
testing and documentation was inadequate.
Procedure EMP 45
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provided for verifying proper motor rotation by momentarily
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touching the motor leads to an energized terminal and jogging-
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the motor in the closed direction.
This appears contrary to
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the vendor manual which directs that the motor be energized
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from the operating switch to verify rotation.
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Paragraph 3.9 of procedure EMP-45 provided general guidance for
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documenting the as found/as left condition of the valve but
there was no requirement to record the torque or limit switch
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settings when adjusting these setpoints. A review of two com-
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pleted SSR packages revealed that these setpoint values were
not recorded.
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The post installation testing for MOV motors consisted of cycling
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the valve to verify proper operation, circuit integrity and posi-
,
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tion indication.
However, there were no quantitative acceptance
criteria for determining proper valve operation even though
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nominal valve operating speeds were provided in the vendor
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manual.
MQC was not required to observe the test and the
determination of proper valve operation was left to the
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judgement of the workman performing the maintenance.
(2) The torque values listed for use in the MOV mechanical repair
procedure had an inadequate technical basis and their use was
optional.
Procedure MP 39-3 had a table of MOV torque values
'that were based on bolt size.
The table was identical to one
in procedure PM 92.10 for diesel generator maintenance and was
based on values in the diesel generator vendor manual.
Addi-
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tionally, a note at the bottom of the table made torque wrench
use optional by stating that:
An average man on a 12 inch wrench can develop about
100 ft. Ib. of torque.
Therefore, if a torque wrench
is not available, or cannot be used, use the following
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wrench-bolt combinations:
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_
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_.
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Bolt Sizes, Inches 1/2
9/16
5/8
3/4
7/8
1-1/8
Wrench Sizes, Inches 6
9
12
18
24
36
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For larger bolting where specific torque values are
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2
not stated and/or configuration precludes the use of
torque equipment, standard striking wrenches may be
used by qualified mechanics working to industrial
journeyman standards.
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The technical basis for this note was a vendor valve manual
notation applying to stud nuts and cap screws.
The licensee
had applied the torque values for diesel generators and other
valves to MOVs without any apparent engineering justification.
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(3) The post maintenance testing of valve HV-2246 was signed off by
MQC as being complete when plant conditions would not support
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the operational test.
Procedure MP 39.3, section 6.1, stated
that the post maintenance testing acceptance criteria was " Valve
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Stroke and limit switch settings are acceptable for system re-
quirements at operating pressure and temperature".
There were
no quantitative acceptance limits provided in the procedure to
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determine this acceptability and MQC signed off this part of
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the procedure on February 23, 1985 for SSR 84500240.
At this
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time the reactor was shutdown and steam was being supplied to
the helium circulators from the auxiliary boilers which are not
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capable of producing steam at operating temperatures and pressures.
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There was no outstanding action item to test this valve when the
plant was at normal operating temperatures and pressures.
The
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licensee had no assurance that this valve would operate as designed
under expected operation conditions.
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c.
Station battery maintenance and surveillance procedures were incon-
sistent with the guidance provided by the battery vendor manual.
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The following inconsistencies were identified:
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(1) The battery ventilation low flow monitor was alarming in the
control room and exhaust air flow from battery rooms 1A and 18
appeared to be insufficient to meet the vendor manual recommen-
dations for removing hydrogen gas during charging evolutions.
(2) The upper temperature limit specified on the surveillance
procedures for a battery receiving a float charge was 110*F.
.
This was contrary to the vendor manual which recommended
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maximum allowable battery temperatures of 110 F during
equalizing charge evolutions and only 90*F for float charge
conditions.
The inspector observed a pilot cell temperature
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of 92*F in battery 1A on August 22, 1985.
The battery vendor
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manual stated that continued operation at this elevated tem-
perature could degrade the battery capacity and life.
(3) Battery specific gravity and individual cell voltage (ICV)
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measurements were not analyzed to determine whether an equali-
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zing charge should be performed.
The battery vendor manual
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recommended that an equalizing charge be conducted when the
specific gravity of any cell dropped .010 from an initial
standard value or any cell ICV was below 2.13 VDC.
Instead,
the licensee performed an equalizing charge monthly in accor-
dance with 50P 92-06.
There was no in progress monitoring
of these charges and the end of charge parameters were not
measured to verify improved battery conditions.
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(4) There were no procedures for periodically checking battery
intercell resistances and connector tightness, adding water
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to individual cells, or cleaning the battery with approved
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solvents.
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The apparent failure to establish, implement and maintain adequate battery, and
MOV maintenance and testing procedures was discussed with the licensee and will
be incorporated into unresolved item 50-267/85-26-02 for followup by the
NRC Region IV Office.
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5.
Post-Modification Testing
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The licensee did not ensure that all required post modification tests
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were developed as part of modification work packages.
T!o NRC inspector
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reviewed Change Notices (CN's) 1798 and 1798-A and their associated
Controlled Work Procedures (CWP's) 84-92, 84-93, 84-94, 84-95 and 85-560
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which replaced Emergency Water Booster Pumps (Fire Water Booster Pumps)
P-2109 and P-2110 with pumps having a higher output head.
These pumps
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could be used to drive the helium circulator turbine to achieve adequate
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core cooling in the event of the failure of three feedwater pumps.
The
CWP's for this modification did not contain post-installation flow tests
for the new emergency water booster pumps.
The failure to develop adequate
controls to ensure that all required post-modification testing was conducted
was discussed with the licensee and will remain an unresolved item pending
review by Region IV (50-267/85-26-06).
6.
Unresolved and Open Items:
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Unresolved items are matters about which more information is required to
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determine whether it is an acceptable item, a deviation, or a violation.
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A open item is a matter that requires further review and evaluation by
the inspectors.
The following unresolved and open items will be followed
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by the NRC Region IV office.
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(50-267/85-26-01) (0 pen Item) The revision of equipment control procedures
to establish compliance with TMI Item I.C.6.
This item will remain open
pending NRC Region IV acceptance of the revised procedures (Item 2.a(1)).
(50-267/85-26-02) (Unresolved) The failure to establish adequate procedures
for control of temporary plant modifications, station battery maintenance
and surveillance tests, and motor operated valve maintenance.
Also, the
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apparent failure to comply with procedures for battery surveillances and
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motor operated valve maintenance (Items 2.a(2), 3b, 3c, 4b, and 4c).
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(50-267/85-16-03) (0 pen Item) The revision of housekeeping procedures to
provide a means for ensuring specific deficiencies are corrected.
This
item will remain open pending NRC Region IV acceptance of the revised
procedures (Item 2.c).
(50-267/85-16-04) (0 pen Item) The adequacy of the diesel generator valve
lineup procedure to ensure the availability of the system.
The item
will remain open pending NRC Region IV followup of potential weaknesses
in the lineup procedure (Item 2.d).
(50-267/85-26-05) (Unresolved) The failure to procure safety-related
replacement items in accordance with the QA plan requirements (Item
4.a).
(50-267/85-26-06) (Unresolved) The failure to establish adequate
controls to ensure the performance of required post-modification
testing (Item 5).
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7.
The findings of this inspection were discussed with those persons indicated
in paragraph 1 on August 29, 1985.
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Docket No. 50-267/85-26
,
Public Service Company of Colorado
ATTN: Mr. O. R. Lee, Vice President
Electric Production
P. O. Box 840
Denver, Colorado 80201
Gentlemen:
This refers to the routine safety inspection conducted by L. L. Wheeler,
J. E. Dyer and L. E. Whitney of this office on August 19-28, 1985 of
activities at the Fort St. Vrain Nuclear Generating Station authorized by
NRC Operating License DPR-34. The inspection findings were discussed with
J. Gahm and others of your staff during and at the conclusion of the
inspection.
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The enclosed inspection report includes findings of significant weaknesses
in several maintenance-related areas (maintenance of station batteries and
motor operated valves, post-modification testing, and the safety-related
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qualification of replacement parts). The most recent SALP report (May 7,
1985) considered your maintenance activities to be minimally satisfactory
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with respect to operational safety. The findings of this inspection confirm
that assessment and indicate that your corrective action has not been effective.
The NRC will f?cus increased inspection attention on your maintenance and main-
tenance-related activities until improved performance is achieved.
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The enclosed report includes findings that may result in enforcement actions.
Disposition of these potential enforcement findings, referred to as unresolved
items in the report, will be made by the NRC Region IV office.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
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this letter and the enclosed inspection report will be placed in the NRC's
Public Document Room.
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We will gladly discuss any questions you have concerning this inspection.
Sincerely,
James G. Partlow, Of rector
Division of Inspection Programs
Office of Inspection and Enforcement
Enclosure:
Inspection Report No. 50-267/85-26
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