ML20137F536
| ML20137F536 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/20/1985 |
| From: | Ireland R, Plumlee G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20137F337 | List: |
| References | |
| 50-267-85-07, 50-267-85-7, NUDOCS 8508260246 | |
| Download: ML20137F536 (17) | |
See also: IR 05000267/1985007
Text
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APPENDIX B
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U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-267/85-07
License:
Docket:
50-267
Licensee:
Public Service Company of Colorado (PSC)
P. O. Box 840
Denver, Colorado 80201
Facility Name:
Fort St. Vrain Nuclear Generating Station
Inspection At:
Fort St. Vrain (FSV) Site, Platteville, Colorado
Inspection Conducted:
March 1-31 and April 1-30, 1985
7/20
8
Inspectors:
"
cpluG.L.PlumleeIII
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D$te
v
Senior Resident Inspector (SRI)
Other Accompanying Personnel:
Harold Miller, EG&G Consultant
Approved:
[ n /rdu
//JO/[f
R. 'E.
Frelan3,' Chief
' ~ ~
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Dhte
Special Projects and Enginee/
ring Section
Inspection Summary
Inspection Conducted March 1-31 and April 1-30, 1985 (Report 50-267/85-07)
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Areas Inspected:
Routine / reactive, unannounced inspection of the control rod
drive event, licensee action on previous inspection findings, licensee event
report, maintenance, operational safety verification, and periodic and special
reports.
The inspection involved 154 inspector-hours onsite by one NRC
inspector and 263 inspector-hours by one NRC consultant.
-Results: Within the six areas inspected, seven violations (inadequate
maintenance QC, paragraph 2, inadequate maintenance procedures, paragraph 2,
and failure to follow procedures, paragraphs 5 and 6), and three open items
(design document update, paragraph 2, epoxy qualification, paragraph 2, and
procedure corrections, paragraph 6) were identified.
Four of the above vio-
lations (inadequate maintenance QC) were issued prior to this report in an
NRC letter E. H. Johnson to 0. R. Lee, dated April 26, 1985.
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DETAILS
1.
Persons Contacted
Principal Licensee Employees
D. Alps, Security Supervisor
L. Bishard, Maintenance Supervisor
- T. Borst, Support Services Manager
- B. Burchfield, Superintendent Nuclear Betterment Engineering
- W. Craine, Superintendent of Maintenance
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- R. Craun', Supervisor Nuclear Site Engineering
M. Deniston, Shift Supervisor
J. Eggebroten, Technical Services Engineering Supervisor
- M. Ferris, QA Operations Manager
- W. Franek, Superintendent Operations
- C. Fuller, Station Manager
- J. Gahm, Manager Nuclear Production
- J. Gramling, Supervisor of Nuclear Licensing - Operations
- M. Holmes, Nuclear Licensing Manager
J. Jackson, QA/QC Supervisor
J. McCauley, Results Engineering Supervisor
- P. Moore, QA Technical. Support Supervisor
- M. Niehoff, Site Engineering Manager
- F. Novachek,. Technical / Administrative Services Manager
H. O'Hagen, Shift Supervisor
- T. Orlin, Superintendent QA Services
- J. Owen, Maintenance Supervisor
J. Petera, Electrical Supervisor
- T. Prenger, QA Engineering Coordinator
^G'.
Redmond, MQC Supervisor
G. Reigel, Shift Supervisor
T. Schleiger, Health Physics Supervisor
^L. Singleton, Manager QA
J. Van Dyke, Shift Supervisor Administration
- D. Warembourg, Manager Nuclear Engineering
- S.
Willford, Training Supervisor
The SRI also contacted other plant personnel including administrative,
electrical, maintenance, reactor operators, and technicians.
- Denotes those attending the exit interview.
2.
Control Rod Drive (CRD) Event
During this report period, the licensee has continued their CRD
refurbishment program as outlined in the licensee's February 3,1985,
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letter (P-85046).
This program has been monitored on a periodic basis by
both the SRI and an NRC consultant.
Several problems with the methods of
inspection used by the PSC quality control (QC) department were
identified.
Examples are as follows:
On March 18, 1985, the NRC inspectors determined that a QC hold point
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in Step 14.15 of the fuel handling procedure work packet
(FHPWP-100-4) for the refurbishment of Control-Rod-Drive-and-Orifice
Assembly (CRD0A) 4 was not signed off by QC and work was allowed to
continue.
Subsequent discussions with the licensee indicated that
bypassing QC hold points was orally authorized during CRD0A
refurbishment. The NRC inspectors noted previous examples where hold
points for. numbering electrical leads had been bypassed resulting in
disconnecting leads without numbering and subsequent incorrect
reconnection.
The licensee assured the NRC inspectors that the
electrical lead problem was an isolated example, and that their
method of using hold points was satisfactory.
However, the NRC
inspectors determined that this method of inspection was not
documented in the licensee's QA program and was contrary to the
definition of hold points as defined in Administrative Procedure G-1,
" Glossary of Abbreviations and Definitions," Issue 13, dated November
5, 1984, and Maintenance Quality Control Inspection Manual (MQCIM),
Issue 1, dated January 21, 1985.
The licensee was informed that this
failure to comply with their QA program requirements is considered a
violation (8507-01).
On April 10, 1985, a problem was encountered during testing of CRD0A
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18.
The CRD0A was disassembled and the simplex second stage bearing
was found installed backwards.
The inner and outer races had
separated allowing the ball bearings to fall out, which resulted in
the second stage gear moving towards and rubbing against the drum
support.
On April 15, 1985, the NRC inspectors determined that Step
35.13 of Task 35, " Assemble Gear Box Housing and Gear Train," had
been signed off by both the workman and QC on March 28, 1985,
verifying that the second-stage simplex bearing (-200-32) with the
relieved side of outer race facing the second stage gear, had been
properly installed.
Contrary to this procedural requirement, the
second-stage simplex bearing was installed backwards.
The licensee
was informed that this is considered a procedural violation
(8507-02).
During a review of nonconformance reports (NCR) addressing various
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CR00A repairs, the NRC inspectors were unable to determine what QC
had verified as being acceptable since no acceptance criteria,
inspection requirements, or as-found/as-left data had been
identified.
One example was NCR 85-130 (identified in NRC Inspection
Report 85-03) that addressed drilling bolt heads for lockwire holes.
A review of the sketch that had been subsequently added to the NCR,
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for which QC verified conformance, indicated that the hole was in the
wrong location and called for only one hole when four were required.
Therefore, a determination could not be made as to what QC's
signature on this NCR indicated.
On March 5, 1985, the NRC
inspectors determined that Administrative Procedure Q-15, " Control of
Nonconforming Items," Issue 3, dated June 23, 1982, requires that as
part of the NCR disposition, the superintendent of QA services (SQAS)
was to determine and denote the appropriate inspections and
organization responsible for performing the inspections.
The
licensee was informed that the failure to comply with this QA program
requirement is considered a violation (8507-03).
The licensee's
immediate corrective action was to attach a QC general inspection
~ form to each subsequently dispositioned NCR.
However, the NRC
inspectors determined this to be inadequate since: (1) QC was not
performing independent measurements; (2) no as-found/as-left data was
required to be entered on the form; and (3) the form did not require
documentation of inspection requirements / specifications.
On April 8, 1985, the NRC inspectors determined that CRD0A-shaft-
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potentiometer drives drawn from the warehouse and taken to the
refueling deck for subsequent use, were found to have dimensional
discrepancies.
The shafts were sent back to the machine shop under
Station Service Request SSR 85504838 to be reinspected and repaired
or scrapped.
Of the eight inspected, two were scrapped and six
repaired.
The NRC inspectors determined that six of the discrepant
shafts (Serial Nos. 13, 14, 15, 16, 17, and 19) were fabricated by
SSR 84500853, dated November 20, 1984, and inspected / approved by QC
on January 18, 1985, as conforming to Drawing SLR D1201-240, Revision
B.
These shafts were subsequently placed in the warehouse as
conforming quality parts.
The NRC inspectors also determined that
the licensee had identified the discrepant shafts to be nonconforming
material, but failed to initiate an NCR as required by Administrative
Procedure Q-15.
Followup inspections led the NRC inspector to
conclude the following:
QC does not make independent physical measurements. When
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verifying tolerances within a thousandth of an inch, such as
during this refurbishment program, an independent measurement
program becomes a necessity to verify conformance.
QC stated that NCRs are not commonly initiated on material
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issued from the warehouse and subsequently found discrepant
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prior to use in a quality-related component.
This is contrary
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to Procedure Q-15 requirements.
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The licensee was informed that the failure to follow QA program
requirements is considered a violation (8507-04).
The NRC inspectors subsequently determined that SSR 84500853 also
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fabricated 144 slinger washers (-234-1,
-2, and -4) of which 66 were
identified in NCR 85-554, dated April 26, 1985, to be
out-of-tolerence and dished.
The slingers were returned to the PSC
machine shop for remachining and straightening.
The NRC inspectors discussed the above examples with PSC QA management /
supervisors and indicated the most probable cause for the above examples
of nonconforming material problems were:
Form MQC-1-1, "MQC General Inspection Procedure," is inadequate by
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itself to inspect a part or assembly, as it does not give the
requirements for inspection or acceptance criteria.
QC does not make independent physical measurements when verifying
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tolerances.
At a meeting on April 10, 1985, with PSC QA management / supervision, the
NRC inspectors discussed the requirements set forth by ANSI N45.2, 1971,
and 10 CFR 50, Appendix B, concerning quality inspection.
The licensee
agreed to revamp the inspection department to do independent-hands-on
inspection, to purchase the necessary measuring tools and equipment, and
to start a training program as necessary to better qualify the inspectors
involved.
To date, new measuring tools were sent out to be calibrated, and many more
have been ordered.
Several training programs are being evaluated and
justification for two new buildings is being written (one building for QC
and one for receiving inspection).
A new form is being drafted to be
attached to or replace HQC-1-1 general inspection procedure.
This form
will list the inspection requirements and acceptance criteria for the
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parts or assemblies being inspected.
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As an immediate corrective action, a memo QAC-85-0353, dated April 29,
1985, was issued by the PSC QA department to all QC inspectors which
states,
"SUBJ:
DOCUMENTATION OF DIMENSIONAL VERIFICATION BY QC INSPECTORS
"When an inspection is performed where a dimensional verification is
required or a dimensional verification occurs, this verification
shall be performed by the QC inspector on the job.
The QC Inspector
shall record, on the appropriate inspection form, the acceptance
criteria and the as found dimensions.
The QC Inspector shall include
the appropriate drawing number, the revision issue of the drawing or
the applicable document which identifies the acceptance criteria.
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"It is mandatory that the above data be entered on the appropriate
inspection form for each inspection performed."
An enforcement conference was conducted in the Region IV office on
April 24, 1985, to discuss the above QC problems related to CRD
refurbishment.
The licensee's response to the concerns identified during
this enforcement conference is documented in P-85144, dated April 26,
1985.
The NRC issued a Notice of Violation, dated April 26, 1985, in
advance of this report requiring immediate corrective action to assure
that QC requirements are met during all remaining refurbishment work.
During a review of previously dispositioned NCRs concerning CRD
refurbishment, the SRI determined that numerous NCR dispositions addressed
the need for forthcoming change notice (CN) reissues to document the field
changes authorized by the NCR.
No apparent tracking system had been
established to ensure the incorporation of the needed document updates.
In a meeting with the PSC QA and site engineering (NED) representatives on
March 5,1985, the licensee agreed to incorporate the CN number on all
future NCRs and review all previously issued NCRs requiring document
updates to ensure that the field changes were being addressed in future CN
reissues.
While reviewing CRD refurbishment procedures, the NRC inspectors found it
very difficult to follow the documentation of rework.
The writing of
findings, directions for rework, etc., in the margin, sometimes filled the
entire page making the sequence difficult to follow.
All steps req" iring
signatures or check off, were signed or checked ~ three or four times and
often with no date.
The NRC inspectors' concern regarding adequate
documentation was discussed with the licensee.
The licensee's same
concerns resulted in development of a new rework procedure which has been
included as an attachment to the CRD refurbishment procedure.
The rework
procedure calls out all the steps necessary to do the rework and provides
the necessary blanks for signatures / checks as required in the original
task.
The rework exits the original procedure / task at the point the
problem is identified, corrects the problem, returns to the same point,
and then continues in the original procedure / task.
During this same procedure review effort, the NRC inspectors identified
and reported to the licensee numerous procedure problems.
Some examples
are as follows:
CRD 15 - No proper sign-off on tasks 33, 34, 36, 38, and 39.
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CRD 4 - No proper sign-off on tasks 9, 10, 12, 13, 14, 31, 32, 37,
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40, and 43.
Stainless steel clevis bolts for CRD 6, 26, and 21 were not entered
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in the parts replaced log (Attachment F).
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CRD 11 - Rework Task 1 authorization sheet not filled out or signed.
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CRD 13 - QC hold point not signed, Attachment E not signed as
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complete, and Attachment N not signed in or complete.
CRD 28 - Several tasks and steps were listed as N/A without
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justification or signature, and in Step 11.28 the tool used had no
calibration date.
The licensee is continuing to improve their efforts in preventing /
minimizing these types of procedural problems.
On March 19, 1985, the NRC inspectors determined that a cable clamp
utilized during testing of the slack cable assembly was left installed
during subsequent testing of the CRD assembly resulting in the destruction
of a new CRD cable.
Followup inspection indicated this to have been
caused by a procedural problem for which subsequent corrective action was
initiated to correct the procedure.
On March 20, 1985, the NRC inspectors determined that the procedure step
for disconnecting the orifice mechanism electrical connector
(D1201-400-43) in Fuel Handling Procedure Work Packet FHPWP-100-15 had not
been followed during rework of CRD 15.
Subsequent raising of the 200
assembly resulted in damage to the male and female connections.
The
development of the new rework procedure identified above should prevent a
recurrence of this type of error during rework.
The SRI considered this
to be an isolated error for which adequate corrective action was initiated
by the licensee.
The NRC inspectors reviewed some of the controlled drawings used by PSC to
refurbish the CRDs.
Some of the notes on these drawings appeared to be
inaccurate and some that might be needed were not included in the
procedure.
Some examples are as follows:
)
Note 6 on Drawing 01201-217E stated that the shim motor rotor and
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brake assembly must be balanced as a unit.
The licensee was in the
process of using the rotor from one shim motor interchangeably with
the brake assembly from another shim motor without complying with
this note.
The NRC inspector brought this note to the licensee's
attention on March 20, 1985, and NED took immediate action to ensure
compliance with this note.
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Note 3 on Drawing D1201-286B requires the stamping of a part number
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on the component.
As identified below, this note was overlooked
during the design of the slack cable bushing caps (-286-2).
PSC QC identified a Note 2.f on Drawing D1201-401 as being applicable
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and not complied with, resulting in issuance of NCR 85-553.
The note
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had to do with the longevity of the orifice drive motor between
overhauls and implied an overhaul was needed every 6 years.
Note 2.d on Drawing D1201-401 stated that the design duty of the
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motor was 36,000 steps per year.
The NRC inspectors determined one
full travel of the orifice valve (approximately 42,000 steps) is
required just to set the valve position limit switches.
Therefore,
the yearly design duty, as indicated by note 2.d, would have been
exceeded during limit switch setting.
Note 2.d appeared to be
inaccurate.
The licensee has stated that the CRD design drawings are used for
reference only (i.e. " visual aids"), and that the notes are not to be
taken seriously, since the procedure is the controlling document.
The
licensee also stated that the drawing notes were not reviewed for possible
inclusion during development of the CRD refurbishment procedures.
However, as noted above, note 6 of Drawing D1201-217E did affect the
refurbishment program and should have been reviewed and incorporated
within the refurbishment procedure.
This is an apparent violation of the
Technical Specification requirement to have adequate procedures for safety-
related activities, including CRD maintenance (8507-05).
At the end of this-reporting period, the licensee's QA department had
ccmmitted to perform an audit of the notes on design drawings utilized
during the refurbishment of the 200 assembly.
Subsequent discussions with
the. licensee resulted in NED committing to a review of all notes on design
drawings utilized during the refurbishment.
This review will consist of
comparing the drawing notes against the current refurbishment procedures
and CRD operations and maintenance manual to determine possible
deficiencies / inaccuracies in the refurbishment program, CRD operations and
maintenance manual, and/or design drawing notes.
PSC NED's current policy concerning CNs affecting drawings is to not~
change the drawing until the CN work is complete.
Sometimes it has taken
over a year since work was complete and the revised drawing was issued.
In the interim a " caution" sticker is attached to a drawing affected by a
CN stating that this document has been changed by the CN.
This " caution"
sticker may not show up on the drawing for 30 days or more after the CN is
approved.
Therefore, the modified system / component may have even.been -
placed in service without having adequate drawings.
This concern was
brought to the licensee's attention.
PSC NED agreed to evaluate and
determine a way to shorten the time between the CN being issued and the
" caution" sticker showing up on the affected drawings.
This is considered
an open item (8507-06) pending completion of the evaluation.
On March 29, 1985, the NRC inspectors determined that an NCR 85-378, dated
March 29, 1985, was issued documenting a disparity in the number of balls
in the new CRD bearings versus the design drawings and original
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specifications SLR D1201-2618, 265A, 2588, 2578, 2568, and 222E.
The
possible reduction in cycles to failure of CRD bearings resulting in CRD
inoperability or inability of the CRDs to perform their design function
was the concern.
The SRI reviewed the purchase orders (P0) and confirmed
that both the vendor (General Atomic Technologies) and manufacturer (ITI)
certifications verified compliance with the original specifications even
though modifications beyond the original specifications had been made.
A
meeting was conducted in the NRC Region IV office on April 17, 1985, to
discuss this issue, and is documented in an NRC letter E. H. Johnson to 0.
R. Lee, dated April 30, 1985.
On April 8, 1985, the NRC inspector determined that the 54 slack cable
bushing caps made in the PSC machine shop and inspected by QC had been
placed in the warehouse under code no. 1504244 without any form of
identification stamped on the part.
From a review of CN 1994 which
authorized the cap fabrication and subsequent modification to the CRD 200
assembly on April 15, 1984, the SRI determined that:
The independent design verification form for CN 1994 indicated that
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adequate identification requirements had been specified even though
there was no requirement to identify the part fabricated.
Adequate identification requirements had not been specified in CN
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1994 and subsequent drawings.
(i.e. , The slack cable bushing caps
(-286-2) were fabricated from a sketch that did not have the
requirement to stamp the part number on the part.
This sketch was
subsequently to be added to Drawing D120-286, Revision B, which does
require stamping the part number on the slack cable assembly bushing
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(-286-1).)
Fabrication instructions for the slack cable bushing caps were not
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incorporated in a control work procedure (CWP).
(i.e., The slack
cable bushing caps were fabricated utilizing a Station Service
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Request (SSR) 85504388, dated March 28, 1985.)
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CN 1994 was classified as safety-related only because a
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safety-related part SLR D1201-281 (slack cable assembly) had to have
two holes drilled and tapped in its side to attach the slack cable
bushing cap.
The cap itself was identified as nonsafety-related.
The failures to incorporate adequate identification requirements during
the design review and to provide fabrication instructions utilizing a CWP
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was contrary to licensee procedure G-9, and constitutes a second example
of inadequate procedures for CRD refurbishment (8507-05).
On March 20, 1985, the NRC inspector determined and informed the licensee
that the five minute epoxy (Devcon) being used to attach the resistance
temperature thermocouples (RTD) to the CRD assembly was only qualified to
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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200 F, whereas, CRDM operating temperatures are expected to exceed 200 F.
Documentation of the qualification of the Devcon epoxy to 300 F is to be
provided to Region IV.
This is an open item (8507-07).
The NRC inspectors had no further comments in this area.
3.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item (50-267/7714-01):
Pulled Fuses (CAR-81-137).
A
fuse data base report has been issued, Fuse List, FL-6-11, Issue A, dated
October 31, 1984.
Fuses are now listed by component and by location.
This item is closed.
(Closed) Open Item (50-267/8209-02):
Radiation Monitor Constant Record
ers (CAR-82-056).
During periods of low radiation levels, multiple pens
trace over the same general area resulting in mixing of the recorder pen
colors.
The licensee verified that when a monitor's radiation level
starts increasing, the associated pen starts to leave the area of over
lapping traces.
Once the pen clears this area, the pen quickly produces
its color yielding the desired radiation monitor tracking.
This item is
closed.
(Closed) Open Item (50-267/8218-03):
Procedure to Minimize Backlog of
Safety-Related PTRs (CAR-82-086 and 82-113).
As identified in NRC
Inspection Report 84-30, the licensee has implemented a new maintenance
documentation gathering system (PPMIS).
This system provides a method for
tracking of open and in progress SSRs, previously designated PTRs.
In
transition to this new system, the majority of backlogged safety-related
PTRs were resolved.
Proper use of the PPMIS should eliminate the previous
backlog problem.
This item is closed.
(Closed) Open Item (50-267/8315-01):
Test of Load Shedding Relays
(CAR-83-086).
As previously discussed in NRC Inspection Report 84-22,
this item was to remain open pending incorporation in Technical
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Specifications the requirement to periodically test load shedding relays.
This was a commitment made by the licensee during an electrical
specification meeting between the NRC and PSC on August 31, 1984.
The
recently submitted draft Technical Specification did incorporate this
requirement on page 3/4.3-51 note (a6).
This item is closed.
(0 pen) Open Item (50-267/8410-01):
Control of Sealed / Critical Valves
Associated with 00Rs (CAR-84-040).
Administrative Procedure P-2,
" Equipment Clearances and Operation Deviations," Issue ll, dated October
10, 1984, revised the 00R procedure to include critical / sealed valve
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controls, however, the ODR form was not changed in order to implement this
requirement.
This item will remain open pending the necessary 00R form
revision.
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(Closed) Open Item (50-267/8414-08):
Revision to Fire Fighting Mesponse
Guidelines and Specific Area Plan (CAR-84-066).
FSP-11, Issue 2, dated
December 21, 1984, incorporated the necessary corrections.
This item is
closed.
(Closed) Open Item (50-267/8414-09):
Revision to CWPM-1A (CAR-84-067).
Control Work Procedure Manual, Issue 2, dated January 31, 1985, corrected
the problem.
This item is closed.
(Closed) Open Item (50-267/8415-04):
Procedural Updates for LN, System
(CAR-84-072).
The control room alarm index and data logger prihtout were
corrected.
This item is closed.
(Closed) Open Item (50-267/8415-07):
Commitment Tracking (CAR-84-074).
Administrative Procedure G-2, "FSV Procedure Systems," Issue 14, dated
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December 31, 1984, was revised to include a " flagging" system in which
procedure commitments made to the NRC are set apart by the designator *#*
at the beginning and end of each commitment.
These commitments are not to
be deleted unless comparable controls are utilized.
This item is closed.
(Closed) Open Item (50-267/8418-01):
Revision to MP 12-6 (CAR-84-088).
MP 12-6, Issue 17, dated August 13, 1984, corrected the problems
identified in NRC Inspection Report 84-18.
This item is closed
(Closed) Open Item (50-267/8422-04):
Revision to G-8 and Part 21 Report
(CAR-84-096).
Administrative Procedure G-8, " Compliance with 10 CFR 21
Requirements,"
Issue 5, dated October 26, 1984, corrected the problems
identified in NRC Inspection Report 84-22.
The Part 21 Report forwarded by the licensee's letter P-84244 was
subsequently corrected by letter P-84342, dated September 6, 1984.
This
item is closed.
(Closed) Open item (50-267/8426-01):
Relabel Annunciators I-06C, Windows
1-2 and 2-3 (CAR-84-099).
The windows have been corrected and the
temporary change request (TCR) closed.
This item is closed.
4.
Licensee-Event Report (LER)
The SRI 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 LERS were reviewed for adequacy:
(0 pen)84-008, Revision 2
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(0 pen)84-009, Revision 1
(0 pen)84-012, Revision 1
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(0 pen) 85-002-
(0 pen)85-003
-(0 pen)85-004
(0 pen)85-005
(. Open)85-006
During a review of LER 84-012, the SRI noted that the corrective action
did not identify the future installation of knock-out pots, moisture
elements, and backup helium source for the main CRD0A purge and reserve
shutdown purge. lines as committed in P-85032.
During a review of LER 85-004, the SRI noted that corrective actions for
the inadvertent isolation of the demineralizers were not addressed.
This
is discussed in paragraph 6 of this inspection report.
During a review of LER 85-006, the SRI noted that the corrective action,
regarding Administrative Procedure'G-9 having been modified to include
requirements for surveillances to be included in the PITR and to be signed
off by the CWP work coordinator, was inaccurate.
The SRI verified that
G-9 had not been revised as stated.
The SRI also noted that a previous
LER 82-039 had addressed the same problem identified in'LER 85-006, and
that its corrective action was evaluated by the SRI, upon LER 82-039
closecut in NRC Inspection Report 83-25, to be adequate had the controlled
work procedure manual (CWPM) been followed.
Failure to follow the CWPM
was subsequently identified as a violation in NRC Inspection Report 84-26.
Failure to incorporate SR 5.10.4b-X fire barrier requirements into CWPs,
as addressed in LCR 85-006 corrective actions, is now to be prevented by
the Technical Services Department.
The SRI will verify implementation of
this requirement prior to closeout of LER 85-006.
The SRI discussed the above findings with the licensee.
The licensee
agreed to make the appropriate LER revisions.
5.
Maintenance (Monthly)
The NRC inspectors reviewed records and observed work in progress to
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ascertain that the following maintenance activities were being conducted
as required by approved procedures, Technical Specifications, and
appropriate Codes and Standards.
The following maintenance activities
were reviewed and observed:
SSR 85500761
HV-2253 Repair in 'accordance with MP 91-18,
.
" Maintenance and Repair of System 91 Hydraulic Valve
Actuators," and MP 22, " Maintenance and Repair of
Rockwell-Edwards Valves Pressure-Seal Type"
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SSR 85500762
HV-2254 Repair in accordance with MP 91-18 and MP 22
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SSR 84501322
"A" Helium Circulator Removal and Replacement in
.
accordance with MP 21-15, " Helium Circulator Change
Out Procedure"
SSR 85503703
"B" Helium Circulator Repair in accordance with
.
MP 21-18, " Helium Circulator Compressor Assembly
Retaining Bolt Replacement"
CN 1886
Reorganization, Functional Grouping, Relabeling,
.
and Demarcation of Instrumentation Components and
Systems on I-01/-02
'During observation / review of the work on HV-2253/-2254 performed by
Rockwell in accordance with PSC proceduros, the NRC inspectors identified
and informed the licensee of the following problems:
Missing from the work package was the welder qualification record and
.
MP 100, " General Welding Procedure," which contains special
'
instructions on housekeeping and' sign-offs for the welder and
fire-watch.
MP 100 was required by both MP 91-18 and MP 22.
The valve bodies were littered with debris from. valve body weld
.
repairs and no piping plugs were in place to maintain system
cleanliness.
An unapproved liquid not specified in the procedure was being used
.
(e.g., dye penetrant cleaner).
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Flammable liquids were not stored properly in safety containers.
.
New and used combustible materials were not stored properly in flame
.
proof containers.
Dirty rags and paper wipes on benches and on the floor.
.
Empty paper containers and boxes not removed from the area.
.
Several small sheets of unpainted plywood were in the area being used
.
as tables and walks, etc.
Plywood must be painted with a fire
retardant paint to be in the building.
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The. fire extinguisher required by MP 100 was not in the immediate
.
area.
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The licensee was informed that the above problems were considered an
[
apparent violation of MP 22 requirements (8507-08).
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During observation / review of the helium circulator changeout work, the NRC
inspector identified and informed the licensee of the following:
The direct charge (DC) and P0 numbers were not kept on a sheet
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attached to the SSR as required by Step 3.11.2 of MP 21-15.
The Procedure MP 21-15 referenced use of drawing R 1100-100 which was
.
in use, but was an uncontrolled drawing.
The helium circulator was received from General Atomic Technologies,
.
upon overhaul completion, without the required documentation.
85-326 allowed the work to start under an emergency disbursement.
One torque wrench was identified as being out of calibration.
.
The licensee immediately corrected the above concerns regarding the helium
circulator work.
During observation of the control room design review (CRDR) modifications
being made to Panel I-01, the SRI noted that the backside of the modified
sections of panels had not been painted (i.e., raw nonpreserved metal from
newly installed plate metal).
This was discussed with the licensee and
the requirement to paint the backs of the modified panels was subsequently
incorporated into CN 1886.
The SRI also noted that above average
cleanliness controls were being maintained during welding / grinding while
installing the plate metal pieces.
No metal shavings were noted that
could create a hazard to electrical components.
The NRC inspectors had no further comments in this area.
6.
Operational Safety Verification
The SRI reviewed licensee activities to ascertain that the facility is
being operated safely and in conformance with regulatory requirements and
that the licensee's management control system is effectively discharging
its responsibilities for continued safe operation.
The review was conducted by direct observation of activities, tours of the
facility, interviews and discussions with licensee personnel, independent
verifications of safety system status and limiting conditions for
operations, and review of facility records.
Logs and records reviewed included:
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Auxiliary Operator Logs
.
Clearance Log
.
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Equipment Operator Logs
.
Operations Deviations Reports
.
Operations Order-Book-
.
Reactor Operator Logs
.
Shift Supervisor Logs
.
Shif t Turnover Checklists
.
Station Service Requests (SSR)
.
Technical Specification Compliance Logs
.
Temporary Configuration Reports
.
During tours of accessible areas, particular attention was directed to the
following:
.
Clearance. Tags
.
Control Room Manning
.
Fire Hazards
.
,
o
. Fluid Leaks
.
Hanger / Seismic Restraints
.
Housekeeping
.
Monitoring Instrumentation
.
Piping Vibrations
.
Radiation Controls
.
Plant tours indicated the following types of deficiencies which were-
brought to the attention of the licensee.
Control room and auxiliary equipment room control panels
.
(I-04/I-70(6)) contained loose screws / electrical connectors.
)
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Purification helium compressor M-G set panel "off" indicator light
.
burnt out.
Fire hose not racked properly (RH1K3).
.
Pipe in overhead had lagging soaked with oil (reactor. building -
.
level one).
No safety rope utilized while grating was removed (reactor building -
.
level one).
Sample line not properly supported upon completion of modification
.
(reactor building - Level 5'1/2 - I-9306).
On March 19, 1985, during a daily review of operations logs, the SRI
determined that the 480 volt' bus 1 to bus 2 tie breaker was found closed
on the graveyard shift and was suspected to have been left closed upon
completion of' Surveillance SR 5.6.lb-SA, " Loss of Outside Power and
Turbine Trip," during the previous dayshift on March 18, 1985.
The SRI's
review of the completed SR 5.6.lb-SA indicated the following problems:
Step 5.5.13, requiring the above tie breaker to be opened had been
.
signed off by the dayshift reactor operator, even though the breaker
was subsequently found closed.
The time for helium circulator restoration was not entered in Step
.
5.5.15 as required.
Step 5.5.23, for the return of all equipment to normal, was marked
.
N/A.
Data Sheet 10 handswitch (HS) positions were not entered as required.
.
The SRI informed the licensee that the above failures to follow procedures
which are Technical Specification requirements is considered an apparent
violation (8507-09).
l
On March 19, 1985, during efforts to identify the root cause of the
'
unplanned radioactive liquid waste release that occurred on March 17,
1985, the SRI determined the main contributor to the operator's
identification of this' event, was the failure to unisolate the liquid
waste demineralizers.
This resulted in blockage of the normal flow path
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when recirculating through the liquid. waste effluent monitors.
The
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effluent, therefore, took the path of least resistance, which in this case
happened to be a partially open discharge Valve V-6241 as identified in
LER 85-004.
The licensee has initiated corrective action to ensure that
both the Radioactive Liquid Effluent Surveillance ESR 8.1.2bcd-M and
Operating Procedure 50P-62 for the liquid waste system are revised to
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ensure proper lineup of the demineralizers during recirculation through
the liquid effluent monitors.
This is considered an open item (8507-10)
pending . incorporation of the necessary procedure revisions.
The SRI had no further' comments in this area.
7.
Periodic-Special Report
The SRI reviewed the following reports for content,-reporting requirement,
and adequacy:
Monthly Operations Report for the months of February and March 1985
.
Thirty-fourth Startup report covering the period November 23, 1984,
.
through February 20, 1985
Semi-Annual Radioactive Effluent Release Report covering the period
.
July 1, 1984, through December 31, 1984
No violations or deviations were identified.
8.
Exit Interview
Exit interviews were conducted at the end of various segments of this
inspection with Mr. J. W. Gahm, Manager Nuclear Production, and/or other
members of. the PSC staff as identified in paragraph 1.
At the interviews,
the NRC inspectors discussed the findings indicated in the previous
paragraphs.
The licensee acknowledged these findings.
,