ML20138M149

Responds to NRC Re Violations Noted in Insp Rept 50-267/85-07.Corrective actions:SMAP-1 Revised to Direct Operators on How to Correctly Fill Out Surveillance Procedures & Work Packages Reviewed

ML20138M149
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/23/1985
From:	Gahm J PUBLIC SERVICE CO. OF COLORADO
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20138L936	List: IR 05000267/1985007 ML20138M149
References
P-85335, NUDOCS 8510310532
Download: ML20138M149 (10)

Text

Oeus'icservice~

16805 WCR 19 1/2, Platteville

, Colorado 80651 corne -...

ny of color.4 September 23, 1985 Fort St. Vrain Unit No. 1 P-85335 Regional Administrator Attn:

Region IVMr. E. H. Johnson i

i 611 Ryan Plaza Drive, Suite 1000U. S. Nuclear

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{ l SFP 2 5198 Arlington, Texas 76011 y

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Docket No. 50-267

SUBJECT:

I&E Inspection Report 85-07

REFERENCE:

NRC Letter, Johason to Lee, dated 08/21/85 (G-85352)

PSC Letter, Warembourg to Johnson, dated

Dear Mr. Johnson:

(P-85239) 08/16/85 This letter result of inspections conducted at Fo t Sis in respons March 1-31 April 1-30, 1985.

t. Vrain duringation received as a and r

items contained in the Notices of Vi l The the period following Failure to Follow Surveillance Proo ation are h 1

cedure Fort St.

Vrain Technical Specifications, Sectio that written procedures be mainta ined n 7.4 require

.for established, implemented Licensee Surve surveillance Offsite Power,"illance Procedure and and test requires SR 5.51b-SA, activities.

tie breakers be opened afterthat the 480 volt bus 1 to bus 2

" Loss of helium return of equipment tocirculator restoration be entered,

testing, that the time for switch positions be entered.

normal be entered and that hand e time for 8510310532 851025 h(

PDR G

ADOCK 05000267 0

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~2-l Contrary to the above, it i

surveillance procedure SR 5.51b-SA on Marchwas found after com i

i 18, 1985 that:

i The 480 volt bus 1 to bus 2 breaker was closed t

j Helium circulator restoration was not entered 1

i The time for equipment return to normal was not entered.

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Handswitch positions were no entered on Data Sheet 10.

I This 15 S*V'Tity t,ye)

Iy violation i

(8507-09).

(Supplement 1.0.)

i (1) The reason for the violation if admitted:

i The Operator opened the bus tie, HS-9237, and did not j

receive the green light.

changed the li At this time he closed back in and 4

at this time. ght bulb.

The on comingThe Operator changed the light bulb shift was in and ready to relieve personnel.

In the course of shift relief the j

Operator forgot to mention this problem with shift.

the i

01-coming Helium circulator Operator entered the PSC restoration Clearancewas not entered because the pertain to this circulator.

The number which did not enter the Clearance number in the wrongOperator inadvertently I

I was noted when the space.

The error i

corrected.

surveillance was verified and it was The time for equipaent return to normal was not entered i

i Data I

Sheet 10 handswitch position i

j instead of recording actual handswitch positionblanks were mark t

I (2) The corrective steps which have been taken 1

achieved:

and the results t

This to normal on the 4-12 shift. situation was discussed and th i

A formal reprimand for failure to fill out correct data was issued to the effected personnel.

the correct procedures to follow.All Operations personnel h informed of SMAP-1 has been revised to direct Operators how to co fill out surveillance procedures.

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y has been eliminated.

Unnecessary use of 'N/A' i

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(3) Corrective steps which will be taken to avoid further violations:

Shift Turnover by QA on a continuing basis. policies are being reviewed administrat frequently by These policies will be monitored information is occurring. plant management to ensure the proper e (4) The date when full compliance will be achieved:

June 1, 1985.

2.

_ Failure to Follow Maintenance Procedures Fort St.

Vrain Technical Specifications, and maintained for safety related maintenance implemented Maintenance Procedure MP-22 requires that:

The welder the work package. qualification record and MP-100 be in Cleanliness be maintained.

Approved solvents by used.

Flammable liquids be stored in safety containers.

A fire extinguisher be available.

Contrary HV-2254 thatto the above, it was found for work or. HV-2253 and An MP-100 and welder qualification record were not in the work package.

Cleanliness was not maintained.

An unapproved solvent was used.

Flammable itquids were not stored in sa fety t

containers.

A fire extinguisher was not in the immediate area.

This is a Severity Level (8507-08).

IV Violation (Supplement I.D.)

4 i

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T i (1) The reason for the violation if admitt d e:

Welder the work package of repair to HV-2253 qualifi i

work was u ed in assigned to The valve repair manpower and supervision to complete the neca mainte 1

When the a s-found condition of the essary repairs.

indicated that major repairs by a qualifi d

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would be valve body and seat Valve Company Field Service Repairman whore e

occasions, c well performed similar

, upon two previous valves.

The contractor supervision assumed that repairs to Fort St. Vrain Rockwell repairman had since the accordance with Fort St. Vrain Procedures performed similar not repairs in be any problems.

The Rockwell repairman proceeded w the repairs called for in using the Controlled Work Procedure, Rockwell Procedures required to initiate all Maintenance Depforgetting that MP-and procedures

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in the Work Package.or to include a copy of his welder q 4

artment weld repair briefing.

This resulted from an on inadequate job Cleanliness was not maintained. - Neith i

repairman or the contractor felt that 100%er the Rockwell i

upstream repairman would place aand downstream piping was necessa dam like The Rockwell retardant cloth in the piping to prevent migration of m arrangement using fire grindings and slag during the periods of 1

grinding.

At the ea

+

the 16" valve and clean out the cavitend of the shift, a labore welding or 2

and remove the y and inspector noted the infractionfire retardant cloth dam. adjacent piping i

At the time the but due to an ingress of, the dams had been i

cleaned in accordance with procedural requirwater, th removed An ements.

unapproved solvent solvent that was frequently used by QCused. - A can of dy was the and was apparently the unapproved solvent personnel to clean i

lack of job briefing resulted in the use of t e job site referred to.

The penetrant solvent rather than the alcohol at the job site when solvent repair area of the the Rockwell repairman cleaned the provided i

valve.

approved cleaner per QC test Dye penetrant solvent is an 4

an approved solvent in MP-22. procedures but is not listed as

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Flammable liquids not in approved safety containers. -

Contract personnel were not i

supervisory personnel and allowed alcohol properly briefed by their brought to the job site in the solvent to be were shipping containers.

They Turbine Building. required in the Reactor i

i re necessary in the Fire extinguisher was not in the immediate Contractor supervision did not feel that a area.

necessary the 3 foot deep valve body that prevented allb fire watch was i,

metal slag from being a hazard to the plant n

sparks and hot 4

(2) Tne corre:tive i

achieved:

steps which have been taken and the results 1)

When apprised of Supervisor was immediately sent to meet with thth j

Superintendent and the e Contractor corrective actions were initiated:Rockwell repairman.

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The following a)

The Work Package that performed the repairs wa 4

reviewed with the Rockwell i

i procedures, documents and records were added.

The repairman and the proper of Controlled Work Procedures and W l

e use

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b)

The Contract

ures, on the valve. Superintendent was instructed to stop wo and installeduntil adequate pipe plugs were to prevent fabricated slag into system piping.

migration of grindings and i

c)

The dye penetrant solvent site and workmen were advised thatwas removed fro could use that only QC personnel 4

solvent to clean the valve because it i

was called for in their procedures but not in the procedures that I

doing.

controlled the work that they were d)

Flammable liquids that were not containers were removed from the work site to be p I

approved containers Workmen n

safety containers wer.

were instructed that e required for flammable liquids S

any where within the plant area, e)

The Contractor Superintendent was instructed to assi i

a qualified fire watch with gn i

extinguisher in

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a portable fire accordance with when the work resumed.

MP-100 instructions i

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2)

After implementation of this corrective acti resumed and was completed without incidenton, the work was compliance of applicable procedures.

and in full (3) Corrective steps which will be taken to avoid further violations:

1)

A number noted infractions but addressed other areaso that were identified e

of Those that address the noted infract maintenance improvement.

a)

Because of an are:

identified weakness in the supervisory structure of the maintenance contributed heavily to this situation and proble contractor that during the previous outage, placed in effect with a new maintena the maintenance contract has ract was assured management that they will provide a ractor that supervisory staff that is superior to the previous contractor.

b)

A

program, through the Training Department, initiated that provided contractors with the specific familiarize training to was personnel must adhere to while performing procedures that all maintenance.

This any type of training was given to all contract trade staff. personnel and to the This contractor personnel within one weekprogram is now given to all new co General Employee Training class. completing the initial of c)

A Fire Prevention Work Permit developed that will better define fire protectio procedure is being requirements and controls.

d)

A procedure that will provide instructions for the guidelines and tool / material purpose of process of being developed.and system safeguards is in thei control (4) The date when full compliance will be achieved:

1)

The change in contractor has been complet d 2) e.

completed on August 7, 1985.The procedure train onnel on site was 3)

The Fire Prevention Work Permit will be in e

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January 1,1986.

4)

The procedure to safeguards will be in place by March 1 provide too Full compliance will be achieved b

, 1986.

s em y March 1, 1986.

3 Inadequate Maintenance Procedures Fort St.

Vrain 1

require that writtenTechnical Spacifications, and maintained for.. procedures be established, Section 7.4,

. safety related maintenance,plemented im a.

Licensee P Drawings," rocedure Q-5, " Instructions, Procedure Issue 3, dated that the licensee August documents from the AE/NSSSmaintain 31, 1983,

, and requires and employ technical Contrary to the above, technical for control rod drives were not notes on NSSS d instructions for control rod dri reflected in the work b.

ves.

Licensee Procedure Issue 6, dated December 5, 1984Q-9, " Controlle controlled work procedure, requires the use of Notice 1994, " Fabrication and In t lreq that a

reflects job s ructions.

Change Cable Bushing Cap", dated March 28 s a lation of the Slack check list that all material was pr, ope l 1985, stated in the were stored in theContrary to the above, bushing r y id?ntified.

other warehouse manufactured by PSC without under code No. 1504244 traceability records. identificationand without This is a Severity Level V Violati material on (Supplement I.E.) (8507-05).

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8-j (1) The reason for the violation if admitted:

l a.

The Fuel Handling Procedure Work Packets (FHPWP's) control rod drives were based operation and maintenance (0&M) manual and the PSC upon the NSSS supplied maintenance procedure.

These documents rated i

incorpora ted those drawing notes associated with the t

generally maintenance of the control rod drive and

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assemblies the 0&M manu(al.CRD0A's) based on a review of CRDO orificing 1

However, not all I

were specifically addressed in the procedures. drawing notes pertinent i

b.

Slack related bar stock from Stockcable bushing caps were i

due Code No. 1509244.

This was done that the caps were to be used for.to an erroneous interp i

was indeed safety related.

The actual application As CRD0A's were checked out of the parts distribution centerworked, the s j

Stock Code No.

1509244, identified by i

j Fuel Handling Procedureand installed in acco,rdanc e

e with the Work Packet and CN-1994 The installation of each slack cable bushing cap was v 1

Quality Control.

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y (2) The corrective achieved:

steps which have been taken i

and the results v

I a.

When is was

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all maintenance notes ondiscovered that the FHP the NSSS supplied

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drawings, an 362 CRDOA assembly drawings and the applicab A total of the O&M manual were reviewed.

sections of were found to contain requirements which would applA j

installation, i

procurement, and y to the components.

the refurbishmentA total of 26 requirements, manufacture of CRDOA i

which related to program, were found not to be fully

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implemented into the FHPWP. Seven requirements not to be fully implemented in the purchase order were found j

requirements.

transmitted to the NRC by letter P-85239Each of thes g

the independent review g

The conclusion of was that all essential technical j

engineering requirements Furthermore, none of the had been included in the FHPWP's.

omissions, additions constituted a CRD0A's.

condition which would require rework of thechanges or t

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-- b.

The material used to construct the slack cable bushing was traced to PSC Purchase Order 32839 a i

chemical aps The tensile strength of this aluminum is 68 yield strength is 47,000 psi.

and the CN-1994 Aluminum 2011-T3.

The material specified in was tensile strength of 55,000 psi Aluminum 2011-T3 has a

43,000 psi.

The material used is a higher grade than and a yield strength of specified in CN-1944 and is thus acceptable for this application.

NCR 85-935 documents this evaluation.

To provide proper material traceability an internal order was generated to provide the slack cable bus purchase Stock Code No. 1722322and associated material tra caps ceability.

The slack accordance with FSV Administrativecable bushing caps identification Procedure P-5, and the was maintained until the time they were Quality Control. installed on the CRDOA and the insta r

ed by (3) Corrective steps which will be taken to avoid f i

urther violations:

a.

The Maintenance Administrative Procedure 1 i

that:

states "The the reference documentation is aProcedure Auth latest information available.. ppropriate and a

is the program to rewrite all maintenance proce e current b.

No further corrective action is required (4) The date when full compliance will be achiev d e:

a.

PSC plans to have completed its maintenance procedures by January 1, 1987 in acco dprog the Nuclear Performance Enhancement Program r ance with b.

September 23, 1985.

1 Should you have any further questions, please contact Mr. M. H. Holmes, (303) 571-8409, ext. 201.

Sincerely,

/AY

/ J. W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/djc l

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