ML20137K982
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I 4 From: David Teraoj M20
- To
Date:
ATD1.ATP1.JLC2 ( T dr> I 4j 9/4/96 9:00am 4 20)
Subject:
St. Lucie Inspection Report on PDI Test Specimens Jim, l l
i We reviewed your draft inspection report on PDl's test specimens in which one-sided weld access examinations were performed on blocks without a weld joint. We also i consulted with Steve Doctor at PNNL. Our conclusion is that we agree with EPRI. The effects of ferritic welds are small. Sound waves passing through thick welds and base material of similar chemistry seem to be the same. When you think about it, subsequent weld passes will heat treat earlier ones, creating a heat treatment similar to the reactor vessel material. Therefore, we have no concern in closing out this open inspection report item as written.
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David Terao CC: DGN, TKM l
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'9 9704070132 970325 PDR FOIA BINDER 96-485 PDR , ,,-
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- I ST LUCIE INSPECTION INPUT i
A. Inspector: M. Thomas Branch Chief Concurrence:
C. Casto Report No. 50-335. 389/96-04 Inspection Dates: February 24-29. 1996 Inspection Scope:
Reactive inspection to follow up on licensee actions to address equipment problems identified during Unit 1 shutdown / trip on February 22. 1996.
Results:
There were weaknesses noted in the licensee's maintenahce program relative to the Steam Bypass Control System (SBCS) valves and Ma.in Feedwater Regulating Valves (MFRV).
The licensee has recognized these weaknesses in their maintenance program and has implemented initiatives to improve maintenance in these areas.
The licensee's initial investigation of the MFRV FCV-9011 failure and the SBCS valve problems lacked thoroughness.
, B. Persons Contacted Licensee Employees -
- E. Benken. Licensing Engineer I W. Bladow. Site Quality Manager W. Bohlke. Site Vice President K. Craig. Vice President. Engineering and Licensing
- R. Dawson. Business Services Manager W. Green. Engineer. Systems and Component Engineering S. Lavelle. Licensing Engineer G. Madden. Licensing Engineer
- J. Marchese. Maintenance Manager
- K. Mohindroo. Chief Site Engineer
- L. Neely. Supervisor. Instrumentation and Control Maintenance
- R. Olson. Department Head. Instrumentation and Control Maintenance
- J. Porter. Lead Engineer. Systems and Component Engineering J. Scarola. Plant General Manager D. Stewart. Engineer. Systems and Component Engineering
- E. Weinkam. Licensing Manager
- M. Wolaver. Engineer. Systems and Component Engineering D. Wolfe. Manager. St. Lucle Production. Engineering Group
- C. Wood. Manager. System and Component Engineering J. Zudans. Mechanical Lead Engineer. Production Engineering Group I
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Other licensee employees contacted included operations. maintenance. 1 engineering, security. and corporate personnel.
NRC Personnel
- M. Miller Senior Resident inspector. St. Lucie
- S. Sandin. Senior Operations Officer. AE00
- Attended pre-exit meeting C. Input for the Appropriate Inspection Area XX. Steam Bypass Control System (SBCS) Valve Problems '
(1) PCV-8801 Erratic Operation I The SBCS is used at low power. Normally. PCV-8801. which is rated for five l
percent steam flow, modulated to control secondary pressure and temperature. l The other SBCS valves (PCV-8802 through PCV-8805 are rated for 10 percent I steam flow and quick-open on a reactor trip) remained closed during low power operation. During the Unit I shutdown / trip on February 22. 1996, the SBCS was being used to dump steam to the condenser. The control room operators noted that SBCS valve PCV-8801 was not modulating properly. The valve controller '
was placed in manual by operators. The modulation problem was investigated by I&C personnel who backed out the adjusting screw on the booster relay for the valve until the booster was no longer involved in operation of the valve. The booster relay was adjusted under WO 96002418. This corrected the erratic l operation. The valve controller was returned to automatic operation and no other problems were experienced. l The inspectors reviewed WO 96002418 and noted that the WO also verified that the booster relay adjusting screw was backed all the way out on PCV-8802. PCV-8803 and PCV-8805. The inspectors reviewed the two previous post trip packages for Unit 1. including the operator logs for the shutdowns and restarts and found no indication of previous erratic SBCS valve operation.
(2) PCV-8802 Failure PCV-8802 failed to stroke during testing following the reactor trip. This test was performed to verify operation after the instrument air system was checked during followup to the problems identified (discussed below) for PCV-8804. Troubleshooting revealed that the seal around the manual operator stem dnd the diaphragm cover was leaking by so that there was not enough air pressure on the diaohragm to stroke the valve. The seal was replaced by I&C personnel and the valve stroked satisfactorily.
The inspectors ' examined the failed seal. reviewed the work order package and concluded that this failure was unique and unrelated to the problems identified for PCV-8801 and PCV-8804. The inspectors questioned whether this valve would have actuated if called upon.
(3) PCV-8804 Output Pressure Signal
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l While checking the other Unit 1 SBCS valves for problems similar to that found for PCV-8801. I&C personnel found that PCV-8804 had a closed input air signal to the positioner but indicated a pressure increase on the output air signal line to the valve actuator. I&C personnel removed the positioner to determine the cause of the increased output signal and noted the following: l l
I&C found a black powdery substance in the tubing connection after removing the positioner. This substance was also found to a much lesser degree in valves PCV-8802. PCV-8803, and PCV-8805. PCV-8801 had not yet :
been examined. Finding the black powdery substance caused the licensee to perform a check. of the instrument air system. i An attempt to calibrate the positioner ori the bench was unsuccessful due to excessive wear 01 an internal spool valve. The wear appeared to b6 from normal in service usage. The positioner was disassembled and the licensee found the black powdery substance and a ferrou-s and rubber-like material inside the positioner. However. laboratory analysis was not possible due to the small quantity.(less than 1 gram) of the substance that was available. The licensee indicated during discussions that they believed the source of the rubber-like material and the black powdery substance was the actuator diaphragm. This was based on a microscopic '
comparison of a sample of the diaphragm with the substance collected from the positioner.
The licensee concluded that these conditions would not cause a failure and believed that PCV-8804 would have opened upon demand. This was later confirmed when a similar output demand condition (discussed below) was found on a Unit 2 SBCS valve.
The inspectors examined the material collected from the Unit 1 SBCS valves, reviewed the chemistry reports for the monthly routine sampling performed on l the IA system reviewed several annual particulate reports and concluded that !
the IA system was not the source of the black powdery substance or the ferrous !
and rutber-like material.
I The inspcctors questioned the licensee as to whether.the Unit 2 SBCS valves !
had been examined for conditions similar to those found in PCV-8804 The :
licensee indicated that the Unit 2 valves had not been examined because they believed that. Since all the SBCS actuators and positioners had been replaced (under PCM 047-295. Steam Bypass Control System Actuator Modification) during the Unit 2 refueling outage in the fall of 1995 there was no need to perform this examination.
The inspectors reviewed the PCM package. completed work 1mplementing I documents, performed field inspections. and verified that the actuators and positioners for the Unit 2 SBCS valves had been replaced. During the field verification. 'the inspectors observed that the Unit 2 PCV-8803 output demand signal read 85 psig. which was similar to Unit 1 PCV-8804 condition.
The licensee initiated STAR 960359 to evaluate the condition for Unit 2 valve PCV-8803. The evaluation concluded that- a build up of positioner output pressure while the valve was in standby had no effect on valve operation. The l
4 l licensee verified this conclusion by isolating PCV-8803 and capturing as-found l positioner settings and valve movement. inspecting the internal positioner filters for debris. and performing a calibration check on the positioner.
PCV-8803 was stroked on February 28. 1996. All pressures and strokes were '
normal and no movement of the valve was produced. The filters internal to the ;
positioner were inspected and found to be clean. The licensee concluded that the cause of the positive output pressure from the positioner while the valve I was in standby was an indication of leakage of the spool valve inside the ;
positioner. Spool valve leakage could be caused by failure of the spool valve i to seat or miscalibration of the spool valve signal. Spool miscalibration may i be caused by calibration' drift or a very small original setting discrepancy. !
The licensee indicated that a review of the vendor recommended steam bypass valve. actuator and positioner PM guidance was in progress for both units and the results of the review would be documented in In-House Event Report No. 96-l 020.
l The inspectors concluded that the licensee's investigation into the SBCS valve problems lacked thoroughness in that the extent of condition did not include examining the Unit i SBCS valves for similar conditions. Also not all of the
! vendor PM guidance for the posit ener was incorporated into the licensee's PM i
orogram for the SBCS valves, and these PMs had not been performed.
(4) SBCS Flow Capability During further review of the SBCS valves. the inspectors noted that the licensee had initiated STAR 960348 for Unit 1 and STAR 951419 for Unit 2.
These STARS were written to identify that the modifications to the SBCS valves
- may not allow the steam bypass flow capacity for the SBCS that was specified j j in the FSAR. The STARS indicated that the modifications resulted in a i
! reduction of the SBCS's ability to accommodate load rejection from up to 45 l l percent of full steam flow as specified in the FSAR to up to 39 percent of !
full steam flow. as indicated in licensee calculation PSL-2FSM-95-015. :
Revisions 0 and 1. The licensee concluded that no potential operability I concern existed in any mode of plant operation. This conclusion was based on the SBCS not being required for plant safety (FSAR Section 7.7) and there was no credit taken in any Chapter 15 Accident Analyses for the steam dump and ,
bypass system. The steam dump and bypass valves were classified as non-seismic and non nuclear safety related. The FSAR stated that if the bypass valves failed to open on comm6nd. the atmospheric dump valves provided a means for controlled cooldown of the RCS and the main steam safety valves provided i the safety related over pressure protection for the steam generators.
l l The inspectors reviewed FSAR Sections 7.7. 10.4.4. 15: STARS 960348 and 951419: ano calculation PSL-2FSM-95-015. Rev. O and Rev.1: and concluded that-
! the licensee's operability evaluations were satisfactory and adequate
- technical just)fication was provided.
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l XX. Main Feedwater Regulating Valve (MFRV) Failure (1) FCV-9011, which is the 1A MFRV. failed to properly responc and control !
S/G water level during shutdown. This resulted in the licensee having to trip the reactor from approximately 26 percent power. FCV-9011 operated erratically due to a leaking air line between the lockup l regulator and the actuator upper air chamber. The air leak was i discovered to be a failure of the IA copper tubing at the swaged j fitting. The failure occurred within the ferrule which created the -
swaged joint. The failure caused excessive air leakage from the i l actuator which resulted in unstable control of the valve and an 1ncrease l l in the 1A S/G water level. The inspectors reviewed the licensee,s ,
actions to resolve the failure of FCV-9011 and noted that the licensee's I investigation lacked thoroughness in the following areas:
The post trip position of this valve was not verified in that the l licensee did not determine if the valve had locked up (fail-as is) .
as designed on a loss of IA. or if the valve had closed as l designed on a turbine trip. ;
l l The laboratory report did not discuss the condition of the non- J failed joints, nor was the laboratory made aware that additional mechanical stress had been applied to the failed air line prior to analysis. 1 The cause for the MFRV air supply regulator responding slowly l during PMT after the IA line tubing replacement was not
- identified. The air regulator was replaced and the valve operated properly. The licensee concluded that the sluggish response of the air regulator was not a contributing factor to FCV-9011 l
unstable response.
(2) Backup IA Supply Removed From Service i During further review of the MFRV problem. the inspectors noted that the l backup IA supply to the 1A MFRV had been removed from service. Discussions i with licensee personnel revealed that the backup IA suppiy had been removed '
from service for several years. However. Annunciator E-41. FW REG VLV BACK-UP l AIR SUPPLY PRESS LOW alarm and Off-normal Procedure ONOP 1-0030131 had not ,
been revised to reflect the current configuration of the system. The !
! inspectors questioned licensee personnel as to whether the backup air supply I had been removed from service under the licensee's equipment abandonment i process. Licensee personnel indicated that the backup IA supply had not been '
formally abandoned. but a PCM was Deing prepared to address abandonment of the equipment. The insoectors noted that a, clearance to isolate the MFRVs from the backup IA, supply was not issued until February 24. 1996.
The inspectors concluded that the system configuration did not contribute to the MFRV failure. However. not revising the annunciator or the ONOP were considered to be a weakness.
i (3) MFRV Air Supply Regulator Failure l
6 During stroking of the 1A MFRV following IA line replacement. the FW REG VLV SUPPLY AIR PRESS LOW alarm was received in the control room. The licensee replaced the degraded air regulator and successfully stroked the valve with no IA alarms. The inspectors examined the replacement regulator in the field and noted that the regulator setting was approximately 100 psig. The inspectors questioned this setting since the manufacturer's label on the regulator established the service range as35-100 psig. During their follow up to this question. the licensee discovered inconsistencies in the documents specifying the pressure at the regulator. The licensee changed the pressure setting at the regulator and indicated that the various documents were being reviewed to correct the inconsistencies.
XX. Maintenance During review of the SBCS and MFRV problems, the inspectors noted that not all of the vendor PM recommendations had been incorporated into the licensee's maintenance program and the licensee indicated that some of these PMs had not been performed. The licensee acknowledged that there were some weaknesses in the maintenance program with regard to BOP equipment in general and A0Vs in particular. Several initiatives have been implemented to improve maintenance in these areas. These initiatives include the PM Basis Program and the A0V Reconstitution Program. The licensee also initiated inspections of the turbine building A0Vs every six months under a PM procedure.
The inspectors reviewed several completed turbine building A0V inspections and the ADV Reconstitution Program. The turbine building A0V inspections were being performed to identify and correct visual material deficiencies rather than performing PMs. The inspectors noted that these PMs have resulted in the identification ano correction of material deficiencies involving the turbine building ADVs.
The inspectors also reviewed the A0V Reconstitution Program. This program has been under development for several years and was still in draft form. The A0V program was owned by the St. Lucie PEG in the corporate office and the maintenance department at the plant was the primary customer. The A0V Program ;
was being developed similar to the MOV Program and the Check Valve Program. I The licensee estaDl'ished four categories to evaluate ADVs in the program.
These categories included (1) A0Vs with high. medium, and low PRA values: (2)
Safety related A0Vs with an active safety function: (3) A0Vs affecting plant availability or tnermal performance: and (4) A0Vs with high maintenance histories. The licensee indicated the effort has been focused primarily on the ADVs with hign maintenance histories. Prior to the upcoming Unit 1 refueling outage. Ine PEG and the maintenance department identified problem valves to be worked on during the outage. The inspectors reviewed the list which included the following valves:
1 V3661. Safety Injection Tank Outlet Drain to 1A Reactor Drain Tank '
PCV-1100E. Nessurizer Spray Control Valve From 1B2 Reactor Coolant Loop PCV-1100F. Nessurizer Spray Control Valve From 1B1 Reactor Coolant Loop i i
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7 V5200, lA Hot Leg Loop Sample Isolation !
FCV-07-1A. lA Containment Spray Header FCV-07-18. 1B Containment Spray Header After reviewing the above initiatives and the actions implemented by the licensee. the inspectors concluded that not all vendor maintenance l recommendations (e.g.. A0V positioners) were incorporated into the licensee's' maintenance program. The licensee has recognized some woaknesses in the maintenance of B0P equipment and was taking actions to improve maintenance in this area The A0V Reconstitution _ Program was considered to be a positive i example of an initiative by the licensee that should improve the performance l of ADVs in the program.
Violations or deviations were not identified in the areas inspected.
Review of UFSAR Commitments l
A recent discovery of a licensee operating their facility in a manner contrary I to the Updated Final Safety Anal, sis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR descriptions. While performing the inspections discussed in this report. the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspectors verified that the UFSAR wording was consistent with the observed plant i practices, procedures and/or parameters. I 1
D. 7.0 Exit l The inspection pre-exit was held on February 29. 1996. Dissenting comments were not received from the licensee.
E. 8.0 Acronyms A0V Air Operated Valve BOP Balance of Plant ,
FCV Flow Control Valve l IA Instrument Air I&C Instrumentation and Control ,
MFRV Main Feedwater Reculating Valve MOV Motor Operated Valve ONDP Off-Normal Operating Procedure PCV Pressure Control Valve PM Preventative Maintenance psig '
Pounds per square inch gauge SBCS Steam Bypass Control System SCE Systems and Component Engineering
W Results:
Maintenance e Review of overall maintenance activities associated with the Unit 1 and Unit 2 Rod Control Systems indicated licensee's maintenance program is well planned and coordinated. Licensee personnel responsible for supervision of preventive and corrective maintenance on the Rod Control Systems were qualified and knowledgeable of system requirements. Various licensee improvements in the area of predictive maintenance for this i system has resulted in a reduction of rod drop events. I o Review of selected completed corrective maintenance activities performed on the Rod Control Systems indicated activities were conducted in i accordance with licensee requirements. No discrepancies were identified. I 1
II. Maintenance M1 Rod Control System Maintenance -
M1.1 Scope of Review The licensee has experienced a series of recent CEA drop events due to various Control Element Drive Mechanism and related control and instrumentation failures. The inspector reviewed the licensee's maintenance program for the Rod Control Systems to determine adequacy of preventive and corrective maintenance activities performed on the systems.
Due to significant differences in system design between Unit 1 and Unit 2 each unit Rod Control System is assigned to separate System Supervisors and separate maintenance crews. Additionally. the inspector determined that the licensee conducts an extensive preventive maintenance program on these systems. Routine maintenance includes periodic performance of CEA coil current traces. Circuit and coil insulation resistance checks and power supply breaker testing.
M1.2 Current Traces The licensee performs routine coil current traces of each CEDM. These traces are normally scheduled concurrent with planned CEA motion.
Additionally current traces are often performed for individual CEAs during troubleshooting activities. In this case an evaluation of the trace can be used as an aid in diagnosing circuit or rod motion problems. Coil current traces represent a signatyre record for actual current loading on each of the colls throughout the complete withdrawal or insertion sequence and serve as the best available indication of CEDM and CEDMCS performance.
Traces are evaluated for indications of potential CEDM and CEDMCS problems such as CEDM coil grounds or faulty CEDMCS components. Evaluation of traces is performed by one of the two system supervisors. Ecth personnel have cons 1cerable exoerlence in this area and Gemonstrated good working knowledge of expected current traces ano system performance. This l
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information serves ~ as the basis for licensee decisions in planning of troubleshooting and repairs during refueling outages. The licensee had previously performed this testing in conjunction with scheduled CEA motion prior to and following each refueling outage. However the inspector was informed that the licensee had recently changed their program to perform this testing every 90 days.
M1.3 Circuit and Insulation Resistance Checks The licensee routinely performs circuit and insulation resistance checks on the CEDMs. These resistance checks are performed from the rod control cabinets and provide the licensee information about the condition of the CEDM coil stacks and CEDM cables.
M1.4 Circuit Breaker Testina The licensee performs periodic testing of Rod Control System power supply circuit breakers to verify proper operation along with correct overcurrent and undervoltage protection settings. The inspector determined that the licensee tests 25% of these circuit breakers each outage.
M1.5 Test Stand The inspector toured the licensee's maintenance training facilities.
During this tour the inspector observed the licensee's CEDMCS test stand.
This test stand is constructed from additional Rod Control System cabinets and other components procured for this purpose. The test stand consists of a single CEA coil stack with a modified / shortened CEDM. power supply, and complete set of CEDMCS components to allow moving the shortened CEDM through the withdrawal and insertion sequences. This equipment is located outside the plant with other training facilities and was originally setup for training operations and maintenance personnel. However. it is also used by I&C maintenance personnel as an aid in troubleshooting problems with rod control components. CEDMCS modules suspected of causing problems can be removed from the plant cabinets and installed in the test stand to determine actual source of the problem.
M1.6 Corroctive Maintenance i
The inspector requested that the licensee provide a list of all corrective maintenance cerformed on the Rod Control Systems for both units for the previous two years. The inspector reviewed the list and noted that the list incluoed a few W0s which specifically addressed dropped CEAs. some failure of CEAs to move. position indication problems. and various component failures. Additicnally, numerous W0s had been issued to correct problems identified during predictive maintenance (current traces and l resistance cnecks).
The insp'ector selected several completed Work Orders from this list for
- review. Tne /.ork Orders were revieweo to determine the adequacy of the licensee's corrective maintenance. and if the maintenance was successfully performed within required Tecnnical SDecification allowed time limits.
- Additionally tne work cocuments . sere reviewed to cetermine if the licensee identified liny adverse equipment cerformance trenos for the Rod Control I
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System and initiated appropriate actions to assess the cause of the <
trends. The following W0s were reviewed: I l
WO 96005094-01 This WO was issued by the licensee on February 22. j 1996, to investigate the cause of CEA No. 20 dropping while Unit 1 was operating at power. During troubleshooting licensee personnel i determined that a Power Switch SCR for the CEA upper gripper had i shorted causing a blown fuse. Since the shorted SCR could not be replaced within the time allowed by Technical Specifications the unit was shutdown and the defective SCR was replaced.
WO 96005779-01 This WO was issued by the licensee on March 1.1996.
due to apparent rapid movement of CEA No.1 on Unit 1. Operators i had noted indication of excessive CEA movement between 129 and 133 1 inches with only slight deflection of the control stick The I&C technician removed the timer module and lift power switch for CEA I No. 1 and tested them on the test bench. The components tested as l acceptable. The components were reinstalled and a current trace performed during rod motion. The current trace did not show any problems with the CEDMCS. However the CEA continued to indicate rapid motion between 129 and 133 inches. The problem was subsequently found to be an indication problem due to a faulty position indication reed switch rather than a problem with actual ,
rod motion. The faulty reed switch was scheduled to be replaced '
during the next outage. The inspector verified that the reed switch had subsequently been replaced under PWO 3690.
WO 96011024-01 This WO was issued t- N licensee on April 28. l 1996, due to problems with moving CEA No. . on Unit 1. This CEA was experiencing unreliable rod motion with both withdrawal and insertion commands. The licensee determined that the timer. 1 pulldown power switch, and lift power switch modules were defective. ~
The modules were replaced and functionally tested satisfactorily.
WO 96012576-01 This WO was issued by the licensee on May 13. 1996.
due to out of specification resistance readings on the lower gripper coil and cable for CEA No. 2 on Unit 1. During routine coil l resistance checks the licensee determined that the CEA had higher than expected coil resistance. The licensee cleaned the pins on -
both ends of the CEDM cable and reterminated the cable 6nd rechecked !
the resistance. After cleaning the coll cable resistance was found l to be acceptable.
WO 95004938-01 This WO was issued by the licensee on February 16.
1995. due to CEA No. 79 not stepping out smoothly on Unit 2. 1 Licensee personnel identified a faulty ACTM board associated with j the CEA. The ACTM boara was replaced and FLECA rod testing )
performed including monitored CEDM coil current traces while j operations withdrew and inserted the CEA with satisfactory results.
WO 95033292-01 This WO was issued by the licensee on November 25.
1995. to replace a defective cennector socket on Controi Cabinet 2 on bnit 2. The connector socket was replaced en December 4. 1995.
and satisfactorily testeo on December 14. 1995. ,
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l WO 96012752-01 This WO was issued by the licensee on May 16. 1996.
to investigate and repair a reported defect with loss of phase for CEA No. 49 on Unit 2. Licensee personnel removed various CEDMCS Power Switch components for the CEA and tested them in the test
- stand. The licensee determined that optical isolator board had
- failed. The board was replaced and satisfactorily tested.
M1.7 Vendor Bulletins The inspector reviewed the status of the licensee's program for evaluation and implementation of vendor recommendations related to the Control Rod Drive System. As part of this review the inspector held discussions with l the St. Lucie ABB-Combustion Engineering Site Representative. During these discussions the inspector was informed that vendo'r recommendations
, are provided to sites through a series of ABB-CE Technotes and ABB-CE l Infobulletins. The inspector reviewed the listing of all Technotes and Infobulletins issued by ABB-CE since 1979 and determined that only a few related to the Control Rod Drive System. The inspector identified a single item. Infobulletin 89-02. which described a potentially I significant problem related to multiple dropped GEAs at another site.
l Infobulletin 89-02 was issued to inform plants of a multiple CEA drop / slip i event that had occurred at Palo Verde Unit 1 on December 10. 1988.
l Additionally the Infobulletin recommended that licensee management l evaluate the potential for CEA slip or drop at their site due to a single ,
fault intermittent ground of a CEDM coil lead during CEA stepping. The I specific problem at Palo Verde had been due to a break in insulation in a l
, CEDM lower lift coil electrical lead which permitted intermittent arcing j between the coil lead and an adjacent nipple assembly during CEA stepping.
During a subsequent meeting with licensee personnel the inspector was j informed that ABB-CE vendor recommendations were included within the scope l of the licensee's Nuclear Experience Review program. The inspector requested that licensee personnel provide documentation to demonstrate
, satisfactory disposition of ABB-CE Infobulletin 89-02. The inspector was j provided a documentation package for this issue. This documentation
! package was reviewed by the inspector. The inspector determined that the licensee had evaluated the Palo Verde event and determined that the issue was not applicable to St. Lucie due to significant differnt designs and operational history. This determination was based on the CEDMCS utilized at both St. Lucie units differing from the unique design utilized at .Palo l Verde while neither unit at St. Lucie has the additional lower lift coils.
l Additionally Unit 2 had operated through it's first fuel cycle with l multiple grounded CEDM co11 circuits due to faulty coil field cable
! cesign. No multiple CEA drops were experienced. The faulty CEDM coil field cables were subsequently replaced. The inspector determined that the licensee had an adequate program for addressing vendor recommendations ;
for the Control Rod Drive System. )
M1.8 Walkdown of Svstem Components
! The inspector performed a walkdown of portions of the Saint Lucle Rod Control Systems. Incluaed in the walkdown were the Reactor Trip Breakers. 1 CEDMCS power supplys. and roa control cabinets for unit 1 and Unit 2. No significant problems nere noted during this tour ano housekeeping within ,
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cabinets was acceptable. .
M1.9 Conclusions The licensee's preventive maintenance program for the Rod Control Systems ,
was adequate. Corrective maintenance activities reviewed by the inspector l were acceptable. Additionally, the licensee's decision to increase the amount of predictive maintenance on these systems has contributed toward ;
a reduction in the number of CEA drop events and less failures of system l components during reactor operation. '
1 ACTM Automatic CEDM Timer Module CEA Control Element Assembly CEDM Control Element Drive Mechanism CEDMCS Control Element Drive System FLCEA Full Length Control Element Assembly PWO Plant Work Order SCR Silicon Controlled Rectifier WO Work Order i
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,'V ST LUCIE REPORT 96-01 Inspector: B. R. CROWLEY Branch Chief Concurrence:
1.0 Persons Contacted
- R. Ball. Mechanical Maintenance Supervisor
- E. Benken. Licensing
- W. Bladow. Site Quality Manager
- J. Marchese. Maintenance Manager
- A. Menocal. Maintenance Programs
- N. Motley. Maintenance Supervisor
- R. Olson. Instrument and Control Maintenance Supervisor
- G. Rodgers. Welding Supervisor
- D. Sager. St. Lucie Plant Vice President
- J. Scarola. Plant Manager
- E.' Weinkam. Licensing Manager 3.0 Maintenance and Surveillance 3.1 Maintenance (62703)
The inspectors observed / reviewed portions of selected maintenance activities as detailed below to determine if these activities were conducted in accordance with TS approved procedures, and appropriate industry codes and standards. In addition to verification that procedures were followed and TS requirements were met, the inspectors verified that personnel were !
knowledgeable and qualified, that post maintenance testing (PMT) was performed and was appropriate. that required clearance requirements were met. and that calibrated measuring and testing equipment was used. The inspectors also evaluated interface between Maintenance and Operations personnel.
3.1.1 WO 95035434 - HPSI Flow Header Loop Calibration. The inspectors observed the periodic calibration for Unit 1 Loops 1Al and 1A2.
3.1.2 WO 95025353 - CCW Pump Motor Bearing Temperature Calibration. The inspectors observed per Jic calibration for Unit 2 temperature indicators TIS-14-29-1C1 and 1C2 (Pump Motor 2C) and indicators TIS l 28-1A1 and 1A2 (Pump Motor 2A). I 3.1.3 WO 9503206- HPSI Discharge Header Pressure Loop Calibrations. The l inspectors coservea periodic calibration of Pressure Loops P-3305 ;
(Transmitter PT-3305 and Recorder PR-3305) and P-3306 (Transmitter PT-3306 and Recoraer PR-3306).
l 3.1.4 WO 96002265 - Shutdown Heat Exchanger 2A Outlet Pressure Switch l Replacement. The inspectors observed replacement and PMT of the top portion of Versatile Pressure Indicator ~PIS-07-3A.
3.1.5 Lubrication FMs - The inspectors observed periodic luorication PMs of the fol1owing equipment. -
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WO 96000013 - Equipment Drain Pump 2C for Aerated Waste Storage Tank WO 96000015 - Waste Condensate Pump 2B WO 95035941 - N2 Compressor 1A
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Although the above equipment is none safety-related. the same lubrication PM program is used for safety-related and none safety- )
related equipment. Therefore, work activities on the above equipment '
were used to evaluate how lubrication PMs are performed and controlled.
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31.6'WO 950?8215 - Unit 2 Service Air (SA) Compressor Instrument Calibrations. The inspectors observed calibration of the following I temperature and pressure instruments: TI-18-37 (Temperature Indicator i for SA After Cooler outlet). PS-18-14 (Pressure Indicator for SA l Receiver Lo/Hi Annunciator). TS-18-5 (Tem Compressor Outlet Temperature HI Alarm), andperature TS-13-42Switch for SA (Temperature j Switch for SA Compressor Jacket Outlet).
I 3.1.7 WO95030607 - Replacement of Main Steam Drain Valve ST-08-6. The l inspectors observed welding activities associated with replacement of the valve (welds 2010 and 2011 on line MS-48). Although the valve is a ,
none safety-related valve. the welding and testing of the welds was I accomplished under the same program as for . safety-related welds. The l inspectors verified use of the correct welding procedure. compliance ;
with welding procedure. welder knowledge and qualification use of the !
correct welding material, welding material certification records.
l welding material control, and general appearance of the welds. In l
- aodition. the inspectors observed OC inspection (visual and liquid !
!. penetrant) of the welds, including verification of procedure compliance. ,
OC inspector qualification. and certification of penetrant materials.
l l 3.1.8 Inspection Results During the above observations, the following weaknesses were identified:
I As noted. a number of the jobs observed were periodic calibrations ;
of various plant instrumentation by I&C personnel. Most of these jobs were accomolished in accorcance with a generic calibration i procecure. 1400065. This procecure covered both safety-related and none safety-related instruments and was general in nature, requiring the technician and his supervisor to determine and I specify the specific calibration parameter values for any j particular instrument loco. For the particular calibrations l l
observea. no proDiems were identified. However it appeared that ,
j at wouic have been more appropriate for the safety-related i instrument loops. especially tne ones identified in Taole 7.5.2.
of the Unit 1 FSAR. to nave. Deen included in the more oetalled ,
sa'fety-related procedure. 1400064 Procedure 1400064 provides the technician all of the cailoration parameters and values for a i particular instrument and snould preclude inconsistencies between technic ans that magnt cccur g gneric ;rocecure 1200065. HPSI distnarge pressure recorcers y ;ous ana PR-3506 are examples of instruments listed in Tacle /.o.2 of the unit 1 FSAR nat were
h calibrated under procedure 1400065 (see paragraph 3.1.3 above) in lieu of 1400064.
The licensee is presently in a Maintenance Procedure upgrade program. Procedure 1400065 is one of.the procedures identified as needing upgrade. The licensee indicated that during this upgrade, j the scope of the procedure would be reviewed to determine if all !
instrument loops are in the correct procedure, j During observation of calibration of the temperature indicators l for the CCW pump bearings, the inspector noted that the accuracy' i specified on the calibration sheet was 2.4 C. The temperature j indicator was graduated in narrow 5 C increments. The inspector '
pointed out that specifying a tolerance to one tenth of a degree is not practical for an instrument graduated in 5 degree increments. The licensee agreed and stated that this problem ;
would be looked at during procedure upgrades. This was not a i problem for the calibrations witnessed since the instruments were re-calibrated if they were found to be near the allowable tolerance limits. 1 For welder qualification. the inspector found that the list of qualified welders issued to the field had the potential for l allowing a welder to weld outside his qualification limits. The !
list, used by the foreman to assign qualified welders to a job.
only specified one qualified thickness for procedures covering a l combination of SMAW/GTAW processes. By Code, each process requires thickness qualification. Based on the type welds normally made by maintenance, i.e.. small diameter socket welds, the deficient qualification list probably has not caused a problem. However, there is a potential for a problem, if something other than the norm is welded. The welding group is in the process of re-organization and a new Welding Engineer is in place. The welding control procedures were in process of complete revision to implement a computerized program for control of welder qualification and welding material. The problem with the existing >
list of qualified welders had been recognized by the Welding Engineer and was in the process of being corrected for the interim until the new computerized process can be implemented.
3.1.9 (Closed) VIO 389/94-10-01. Failure to Meet Weld Prep Dimensional Tolerances on Pressurizer Instrument Nozzle Welds.
This violation involved non-conformance of J-Weld prep bevel angles with drawing reauirements. Licensee response to the violation. dated May 27.
1994 has been reviewed and found acceptable. The cause of the violation was attributed human error and inadeouate oversignt of the contractor by FP&L. , Corrective actions included re-training of inspection and production eersonnel, revising the engineering drawing to provide a more reasonaole tolerance for ground weld prep bevels. changing the templates for grinding the weld preps. and correcting the non-conforming weld preos. The c:rrective actions were documented in Corrective Action Recuest (CAR) N-94-020. Most of tne corrective actions were accomplishea curing the 94-10 inspection and were reviewed at that time.
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During the current inspection the inspectors reviewed the completed l CAR. evidence of retraining of inspection and production personnel, and '
the changes to procedure 017-PR/PSL-1 to provide for OC holdpoints on ;
contractor OC activities. The inspectors concluded that corrective !
actions were adequate for the specific problem identified and to !
preclude future similar violations.
This item is closed.
l Conclusion Overall for the maintenance activities observed, the inspectors concluded l that the maintenance and surveillance programs were being effectively 1 implemented. The activities observed were planned and conscientiously executed. Personnel appeared to be well qualified for the task performed.
The inspectors also noted good interface between the technicians and Operations personnel.
No violations or deviations were identified.
Weaknesses were identified as detailed in paragraph 3.1.8.
'7. 0 Exit i The inspection scope and findings were summarized on February 2, 1996. with those persons indicated by an asterisk in paragraph 1.0. The areas described the areas inspected and discussed in detail the inspection results.
Dissenting comments were not received from the licensee.
Inspection Findings
! (Closed) VIO 389/94-10-01. Failure to Meet Weld Prep Dimensional Tolerances on Pressurizer Instrument Nozzle Welds - paragraph 3.1.9 l 8. 0, Acronyms l
l CAR -
Corrective Action Request CCW -
Component Cooling Water GTAW - Gas Tungsten Arc Welding HPSI -
High Pressure Safety Injection I&C -
Instrumentation and Control PM -
Preventive Maintenance PMT -
Post Maintenance SA. -
Service Air SMAW - Shieiced Metal Arc helding i TS -
Technical Specification l VIO -
Violation 4
SUMMARY
STATEMENT
NW jr-Scope:
This routine announced inspecticn was conducted in the area of maintenance. l l l Results: I i
No violations or deviations were identified. I The maintenance activities observed were planned and conscientiously performed. Personnel were well qualified for activities observed. Good interface between the Maintenance and Operations personnel was noted. ;
Weaknesses were identified relative to details provided to the I&C technician I for calibration of safdty-related instruments and the list identifying welder qualification limits.
Overall, for the maintenance activities observed. the maintenance program was being effectively implemented.
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St. Lucie Inspection' Report 50-33S/96-09 Date: 06/15-24/96 ,
A. Inspector: M. Miller Branch Chief Concurrence:
B. 1.0 Persons Contacted:
i J. Barbieri, Design Engineering W. Bladow, Quality Manager D. Denver, Engineering Manager i L. Hiegel, I&C Supervisor K. Mohindroo, Chief Site Engineer R. Olson, I&C Department Head J. Scarola, olant General Manager E. Weinkam, Licensing Manager
-D. Wolf, Production Engineering Group Manager III Encineerine ;
El Conduct of Engineering l El.1 Nuclear Instrumentation Modification
- a. Insoection Scone (37550) ,
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The inspector reviewed the concerns listed in the six '
Quality Assurance reports (CR) related to the l implementation of plant change / modification PC/M 009- 1 195 for the Nuclear Instrumentation System. I Backaround One specific report, CR 96-1358, "Possible Loss of Design Control", for the NI System, dated June 12, 1996 indicated there were-significant problems. CR 96-1358 stated there have been problems encountered-during implementation which have required design changes, numerous deviations from the approved test procedure, and key individuals are no longer on the project. In addition, the work package had become voluminous and unwieldy with trouble shooting activities. There were 13 work package scope changes and approximately 40 deviations to the test procedure.
Trouble shooting was further complicated by not having vendor engineering support on-site. CR 96-1358 is discussed'below in the section Conditions Reports.
The' inspector's work scope included an examination of all aspects of the NI System modification including a j rdview of the design package, design changes, '
deviations, testing procedures, test procedure changes, logs, drawings, work orders, equipment specifications, memorandums, design procedures, administrative procedures, FSAR Chapter 7.2.1, and Technical Specification 3.3.1.1. and 3.9.2. The inspector g i{}
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initiated walkdowns and observed ongoing work. In addition, discussions were held with vendor engineering personnel concerning the ongoing problems. The items in the' work scope were performed to verify that the modification was being performed within the requirements of the licensee's program and NRC requirements.
- b. Qbservations and Findinas Plant Chance Modification (PC/M)009-195 Nuclear Engineering completed the design as REA/ Project
- SLN-94-025-11, "RPS NI Drawer Replacement", dated February 27, 1996. It was released as plant change / modification PC/M 009-195, Revision 0,
" Replacement Of The Neutron Flux Monitoring And Protective System (NI Drawers) For The RPS System".
The PC/M's purpose was to upgrade the Unit 1 NI System with similar instrumentation that was installed in Unit 2 NI System during the last Unit 2 outage. The design change included the following modification for the four NI channels A, B, C, and D:
- 1) Replace the four existing Gamma-Metric wide range excore detectors and cables with improved dual fission chamber assemblies.
- 2) Replace the four existing amplifiers located in containment with new assemblies.
- 3) Replace the eight existing RPS NI drawers located in the Control Room with the new NI instrumentation.
PC/M 009-195 was being irplemented under work order WO No. 96007751. The work order package consisted of PL\M 09-1950 and the Pre-Operation (Pre-Op) Test Procedure Number 1-1400280, " Functional Testing of PC/M 009-195 Safety Channel". The inspector verified that the WO was being implemented under administrative procedure ADM-0010432, Revision 3, " Control of Plant Work Orders". In addition, PC/M 009-195 met the requirements in the following Quality Instructions (procedures) for Nuclear Engineering and the equipment ;
soecification:
l lf ENG-QI 1.0, Revision 3, " Design Control" l
- 2) ENG-QI 1.1, Revision 0, " Engineering Packages"
- 3) Eng-QI 1.2, Revision 1, " Minor Engineering Package" l l
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- 4) ENG-Q1 1.3, Revision 1, " Drawing Change Requests"
- 5) SPEC-IC-004, Revision 0, " Equipment Specification For The RPS Nuclear Instrumentation System" The inspector reviewed and verified that the factory acceptance test procedure, GAMMA-METRICS Test Procedure :
RMSP Assy No. 201663 agreed with Pre-Op 1-1400280 Test Procedure. Drawings JPN-009-195-001 to 017, "Out-of-Core Neutron Detectors" and " Nuclear Instrumentation &
Reactor Protection System, were reviewed and verified that the modification was being implemented according to design drawings. ,
Sconino Chances Thirteen scoping changes were reviewed to determine if the changes were controlled and within the requirements of the modification program and procedures. The scoping changes [ Change Request Notice (CRN)] reviewed are listed below:
- 1) CRN-6100 - Enhanced installation instructions and details for using existing c
- 2) CRN-6155 - Corrected a vendor drawing error.
- 3) CRN-6170 . Vendor approved voltage adjustment change from 15 VDC to 15.5 VDC for 18 gauge cable. ;
- 4) CRN-6193 - Changed relay operating position.
- 5) CRN-6104 - Minor installation change to eliminate '
interference between new drawers.
- 6) CRN-6094 - Changed length of rope used for pulling detector cables.
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- 7) CRN-6132 - Revised connector clamp for triaxial cable. Superseded CRN-6130
- 8) CRN-6130 - Provided tolerance for connectc* clamp-.
- 9) CRN-6091 - Modified mounting tabs for amplifier boxes. (Note - The inspector verified we'. der ,
qualification for this change).
- 10) CRN-6254 - Provided additional wide range calibration data.
- 11) CRN-6196 - Provided new data to change recorder's scale and FSAR Table 7.2-1.
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- 12) CRN-6078 - Removed hold points to allow implementation of work order.
- 13) CRN-6342 - Provided instructions to install "C" channel drawer connector J6.
The inspector did not have any safety concerns with the scoping changes and did not consider the number excessive.
Deviations From Pre-On Test Procedure The inspector reviewed 52 " deviations" from the pre-operational test procedure. The inspector verified all ,
52 deviations were approved by the Facility Review l Group (FRG) which was the licensee's independent safety evaluation board. Most of the deviations were minor in nature and had no safety significance. All the deviations concerning design had been approved by Gamma-Metrics or Engineering. More than several deviations resulted as the consequence of a minor i modification where "B and D" detectors were connected
! to "A and C" NI drawers to facilitate fuel loading. !
l This minor modification was implemented at the request )
of Fuel Engineering. The inspector did not consider i the problems encountered or the number of deviations to l be excessive in this area as long as they were reviewed l by FRG. However, the inspector determined the method i l of implementing deviations was cumbersome.
l Wide Rance NI Temocrary System Alternation The inspector reviewed the minor modification package and safety evaluation JPN-PSL-SEIS-96-028, " Wide Range NI Temporary System Alteration" approved May 24, 1996.
The purpose of this minor modification was to provide for the temporary installation of coaxial jumpers cables to allow the connections of wide range NI l detectors No. 2 (channel B) and No.'4 (channel D) to the preamplifiers inputs for channels A and B respectively.
l This modification accommodated the fuel loading analysis which required that the fuel locations adjacent to detectors "B" and "D" be loaded first for fuel shuffling and to meet Technical Specifications (TS).
TS 3.3.1.1. provides the requirement for reactor protective instrumentation and TS 3.9.2 provides the requirement for refueling. This minor modification required several " deviations" to the Pre-op testing.
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- The inspector reviewed this minor modification to l verify it met the requirements in procedure ENG-QI 1.2, l " Minor Engineering Package" (modification) including l the safety evaluation. No concerns were identi'fied in this area, l i
l Condition Reports l Six Condition Reports (CR) were initiated by Quality l Assurance identifying concerns, problems, and non-conforming conditions with the Unit 1 NI Instrumentation System modification. The seventh CR l
was initiated as the result of it being identified by l the inspector during a walkdown of the control room NI ,
cabinets and work observation. Each CR was reviewed by !
the inspector to determine if the concern or condition '
l was properly evaluated and appropriate corrective l
action initiated. The seven CRs are listed as follows:
- 1) CR 96-1358 - This is discussed above in E1.1.a i
" Work Scope". It is also discussed below in l
- detail since it was considered significant. J l 2) CR 96-711 - The amplifiers boxes had their l mounting tabs welded without removing the electronics. Gamma-Metrics stated no damage was 4
. expected due to the design of mounting the printed
! circuit board on standoffs.
l l 3) CR 96-1443 - The 120 VAC power wire was damaged
! during removal of the "C" channel wide range l drawer. Wire needs to be repaired.
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- 4) CR 96-1480 - The triaxial cable for connector J6 l
on "C" channel drawer is very stiff and causes connector to break. The connector cable assembly was rebuilt using CRN 96-6342 twice. The work for the first rebuild not satisfactory and the connector had to be redone.
- 5) CR 96-1434 - Several instances of non-compliance with requirements in specification SPEC-IC-004 have not been met. The preamplifier power cable (J3) was 18 gage instead of 16 gauge. This required the actions in CRN 96-6170 (listed below). The existing wide range. signal' cables between the amplifiers and containment penetrations was listed as coaxial cable on drawing 8770-6390. Instead it was found to be triaxial for the original installation. CRN 96-6342 was initiated to install new connectors.
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- 6) CR 96-1464 - Data from ECAD concerning "C" channel source range detector indicated low impedance ;
during testing. Gamma-Metrics was consulted for j an evaluation and solution for corrective action. "
- 7) CR 96-1481 - The inspector identified that cable j support clamps were missing from four connector on ;
each NI drawer in the control room. A long term j solution for corrective action was being initiated 1 by the licensee.
The inspector reviewed each CR and discussed its concern with engineering for their evaluation and the I corrective action. The inspector verified that 1 problems did exit. However, the problems were not }
considered significant and no safety concerns were )
identified. l 1
CR 96-1358 !
l The conditions listed in CR 96-1358 (CR) and the )
inspector findings .(IF) are listed below:
- 1) CR - There was possible loss of design control.
IF - The inspector did not identify any loss of design control. However, coordination between design engineering and I&C was initially weak. '
The initial design engineer assigned to the NI System project left the site. He was later replaced with a design engineering manager to coordinate the project.
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- 2) CR - Key individuals who had been involved with j the design and implementation are no longer 1 available.
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- F - Two of the three individuals initially assigned to the NI project were no longer available. One individual left the site and the other suffered a serious illness. However, both engineering and :&C had a sufficient number of qualified engineers capable of completing the modification. The problem was not considered a loss of key personnel, it was more a lack of .
coordination since the I&C supervisors were performing more than function. The : LC crouo in the Maintenance Department performs several ~ !
- unctions that are unique to it. First level l supervisor's duties include being a craft foreman, system engineer, installation engineer, test engineer, trouble shooter and etc. :n several j
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2 I instances, the I&C supervisors were overwhelmed with work due to the refueling outage.
- 3) CR - There have been problems encountered during l implementation which have required changes to
" design" as well as numerous " deviations" from the FRG approved Pre-Cp Test Procedure and vendor technical specifications manual.
IF - The inspector verified there have been problems encountered during implementation and testing. The problems encountered were mostly with cables and connectors during work implementation. The " deviations" were reviewed by the inspector'and approved by FRG (safety review group) for the Pre-Op Testing.
Many of the " deviation" and " scoping changes" ,
were written to incorporate corrective action and I post maintenance testing after trouble shooting installation problems. This was identified by the inspector as a work control implementation weakness. This problem was corrected later by the ,
licensee when new work orders (WO) were written I with the appropriate post maintenance testing.
F.or example, instead of initiating a " scope change" and " deviation" for trouble shooting, implementing corrective action, and testing, three new WOs 96016391, 96016395, and 96016397, all dated June 21, 1996, were written to " Repair MB NI Drawer". All three WOs had one specific task with !
appropriate post maintenance testing. All three l WOs were approved by FRG. This method of using additional WOs improved control and implementation of the modification.
- 4) CR - The work package had become voluminous and unwieldy.
F - The inspector agreed. The licensee initiated corrective action by implementing an " engineering implementation / test log" and using additional WOs to control the work as discussed above.
- 5) CR - Trouble shooting was further complicated by l
not having vendor engineering support on-site.
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, :F - A Gamma-Metric's design engineer and a, field engineer were on-site to support the modification.
The field engineer was scheduled to remain cn-site until the modification was completed and turned over to Operations.
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- c. Conclusion The inspector concluded that there was justification for the comments stated in_CR 96-1358. I&C personnel were sometimes overwhelmed with problems and work.
However, there was no loss of design control. The I&C supervisors and technicians were knowledgeable and technically capable of implementing the NI modification. The inspector considered the capabilities of I&C personnel to be a strength in the l Maintenance Department.
The inspector verified that FRG (safety review group) reviewed all changes and deviations to ensure plant safety. Design engineering was made aware that I&C needed additional support and was in the process of ;
providing it. Program weaknesses for implementing '
changes and trouble shooting were identified and l corrected using new work orders. The vendor, Gamma- ;
Metrics, provided good engineering and field support
. with knowledgeable personnel. The inspector concluded .
the NI System modification was being completed in a )
satisfactory manner to ensure plant safety. 1 D. Exit The Exit was conducted Monday 24, 1996. There were no dissenting comments.
E. NA F. Summary Statement The I&C group, with engineering support, was satisfactorily implementing the Unit 1 NI modification after overcomming initial implementation and coordination problems due to the outage work load.
G. Acronyms CR -
Condition Report CRN -
Change Request Notice FRG -
Facility Review Group I&C -
Instrumentation and Control NI -
Nuclear Instrumentation PC\M - Plant Change / Modification Pre-Op' Preoperational test RPS -
Reactor Protection System TS -
Technical Specifications VAC -
Volts Alternating Current VDC -
Volts Direct Current WO -
Work Order
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o INSPECTOR'S INPUT I INPUT FOR ST LUCIE INSPECTION REPORT No. 50 335,338/96-04 i DATES OF INSPECTION: MARCH 25-29, 1996 A. Inspector Concurrence:
J. L. Coley. Jr. Reactor Inspector Branch Chief Concurrence:
D. M. Verrell1 Acting Brarch Chief !
Special Inspection Branch B. 1.0 Persons Contacted
- R. Ball. Supervisor. Maintenance
- E. Benkeh. Licensing
- D. English. Supervisor. Maintenance
- H. Jacobs. Supervisor. Maintenance
- G. Madden. Acting Licensing Manager
- A. Menocal. Supervisor Maintenance Programs and Planning
- L. Motley. Supervisor. Maintenance
- J. Scarola. Plant General Manager
- S. Valdes. Information Services i Other licensee employees contacted during this inspection included i craftsmen technician, and engineers.
l C. Input for appropriate inspection area.
3.0 Maintenance - (62703) 3.1 Observation of In-process Corrective Maintenance Activities -
Units 1 and 2 4 Portions of the mechanical maintenance for the equipment listed below . ere observed by the inspectors to verify that corrective maintenance activities for systems and components are conducted in a manner which results in reliable safe operation of the plant and plant ecu1pment. Specific elements verified during this assessment included the following: applicable tools were properly calibrated; correct parts and tools were used: personnel were quallfled and knowleogesble: supervision and OC (unere applicable) I were acecuate: proper approvals were obtained before work began:
safety and radiation controls were in place: and approved procecures/ instructions were followed. Drocedures used to control tnis .. ort consisted of the following: ADM-08.02 Revision B.
"C'nduc o of Maintenance" GMP-05. Revision 3. " Control of Welding Specla: Processes". STD-A-C12. Revision 1. " Examination Reau1rements for Welds". General Maintenance Procedure No. M-0043.
Revis cn 15. and General Maintenance Procedure No. 2-M-0041.
Revis1:n 29.
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Replacement of Valve No. V23113 on Unit 2 was observed. l This is the 4 inch isolation valve for the Steam Generator i
- Closed Blowdown to the Heat Exchanger 2A-1 Inlet. Work was !
conducted in accordance with Master Work Order Task No. 95- !
028027-1A. The inspector observed welding preparations and l fitup. In addition. the inspectors verified that work was performed in accordance with written instructions proper i revisions of procedures were used. welder certification, welding procedure parameters and weld filler material controls and certifications were satisfactory. .
l Welding activities for ACC-3B were observed. This is the l Unit 1 air cooled condensing unit for the control room !
ventilation system. Work was conducted in accordance with Work Order Task No. 96-0065401. Welder certification.
welding procedure parameters. and weld filler material 4 controls and certifications were verified satisfactory.
Liquid penetrant examination activities were observed for a new pipe / valve assembly on the Unit 2 Steam Generator Closed Blowdown system. Work was conducted in accordance with Work Order Task No. 96003894 and Traveler Nos.96-373. 4. 5. and
- 6. Examination of welds No. 2001. 2002. 2003 and 2004 for valves No. V23139 and V23140 were observed. The inspector verified that the examinations were conducted in accordance with approved procedure No. PT-1. Method 1. Technique sheet 9.5. Rev. 5. Welding filier materials, welder certification and welding procedure parameters were also verified.
Portions of maintenance activities involving the replacement l of packing for Unit 2 Charging Pump No. PP2B were observed.
This work was performed in accordance with Master Work Order Task No. 96006925-01 and General Maintenance Procedure No.
2-M-0041. Revision 29. The inspectors verified that work was conducted in accordance with the approved procedure.
craftsmen were knowledgeable of the work process. and the proper revision of the work procedure had been verified.
Corrective maintenance for Unit 2 Steam Generator Closed Blowdown system Valve No. V23139B was observed. This is a 3/4 inch root valve for the 2B1 heat exchanger which had developed a steam leak in the valve's bonnet to body connection. Maste Work Order Task No. 96003894-01 and General Maintenance Procecure No. M-0043 was used to performed this maintenance activity. However. corrective maintenance was ineffective due to valve's state of
- eterioration. A determination was subseouen'ly made to replace the valve.
Portions of the tube cleaning activities in the 1A2 In.let
.saterbox on the Unit 1 Condenser (1A) was observed. This
.. ort was conducted in accordance with Master <ork Order Task
- 10. 9600612101. *
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l During the above work activities the inspectors noted that the !
- craftsmen would go verify that the procedure they were using was J
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the appropriate revision in accordance with the requirements of '
paragraph 4.5 in Procedure No. 016-PR/PSL-1 (Document Control).
One occasion when the inspectors accompanied the craftsmen to l
perform this verification the craftsmen found that Revision 14 of Procedure No. M-0043 which the planner had furnished in the maintenance package was not the current revision when compared with the maintenance control copy in the North Service Building. l Further review by the inspectors also revealed that the procedures !
index was not being' updated when new procedure revisions were i received as the cover sheet of the index stated. The inspectors also questioned whether the control procedures were available to backshifts since the doors of the room had locks on them.
Discussions held with appropriate management personnel reg;1rding the above procedure control concerns. The discussion revealed I
that document control only considered the procedure index correct l on the date indicated on the index cover sheet. In accordance '
with procedure this is a dated once every three months when control copies of the procedures are audited against an up to date l
index. The inspector was also informed that the craft know to verify their procedures against the control copies of the j
' documents verses the index. Since the index is a memorandum and j by procedure does not supersede the requirements of a control !
document. Based on observations of craftsmen audited this )
inspection, procedures in the maintenance package are verified l against the control copy of the procedure. In addition, the craftsmen audited followed the document control procedure and used the correct revision of the procedure in each case. The apparent discrepancy of the planner issuing the incorrect revision of l General Maintenance Procedure No. M-0043 resulted because the
. planner had entries to made in the procedure and on the date he
! made these entries he had verified revision as the correct i revision on that date. This therefore, was not a discrepancy but i one of the reason the craftsmen are required to verify the procedure before use.
As a result of above findings and questions raised by the inspector. two STAR Action Reports were written (Nos. 960456 S.7) )
- to evaluated the effectiveness of document control. Management's attention focused on corrective actions in response to these
- reports and during the week the inspector was on site (March 25-l
- 29. 1996, the following cbrrective measures were established.
^11 maintenance groups now will use only one new centralized I library in the North Service Building. This library has an attendant manning it and updating control procedures 10 Hrs. ,
a day. The room where the library is located has also had l Ine locks removed from the coors in oraer that no Dackshift I personnel are excluded from using the facility. l Tne cocument index cover sneet has Deen revised to insure Inat this uncontrolled document is not used for procecure 1
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status except on the date indicated on the cover sheet.
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When planners now verify procedure revisions during the planning stage they will double stamp the procedure and only sign one verification blocks. This will require the user to also verify the procedure.
An up to date procedure index will be established on all on-line computers by approximately August 1996. When this enhancement is fully implemented the index will supersede l all documents for establishing procedure status. All plant personnel will have access to the index at that time.
The inspectors considered the steps taken or in the process of l being taken by the licensee to be substantial improvements in document control. All actions observed during the above corrective maintenance were also found to be satisfactory.
D. 7.0 Exit Meeting The inspection scope and results were summarized on March 29, 1996 during a pre-exit meeting with the licensee. The inspectors described the areas inspected and discussed in detail the l inspection results. Proprietary information is not contained in
! this report. Dissenting comments were not received from the l licensee.
l l E. 8.0 Review of UFSAR Commitments l
l A recent discovery of a licensee operating their facility in a .
manner contrary to the UFSAR description highlighted the need for additional verification that licensees were complying with the
! UFSAR commitments. During an approximate two month time period all reactor inspections will provide additional attention to UFSAR commitments and their incorporation into plant practices, procedures, and/or parameters.
While performing the inspections which are discussed in this
! report the inspectors reviewed the applicaDle portions.of the l Updated Final Safety Analysis Report (UFSAR_) that related to the l areas inspected. The inspectors verified that the UFSAR wording was consistent with the observed plant practices procedures, and parameters.
l F. 9.0 Summary Statement l
l Plant corrective maintenance was conducted in accordance with the l applicable approved instructions by knowledgeable craftsmen.
Cofrective actions taken by the licensee to improve the control of i documents were considered appropriate for the situation.
H. IFS Forms -
Attachea to hara copy I. Comoleted NOV -
None File S:\DRS\ SIB \STL9604.JC l
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