ML20244C130

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Insp Rept 50-267/89-07 on 890319-0430.Violations Noted.Major Areas Inspected:Previously Identified Insp Findings, Operational Safety Verification,Monthly Surveillance Observation & Monthly Maint Observation
ML20244C130
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 06/01/1989
From: Westerman T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20244C124 List:
References
50-267-89-07, 50-267-89-7, NUDOCS 8906140134
Download: ML20244C130 (12)


See also: IR 05000267/1989007

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APPENDIX B

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

HRC Inspection Report: 50-267/89-07

Operating License: DPR-34

Docket: 50-267

Licensee: Public Service Company of Colorado (PSC)

P.O. Box 840

Denver, Colorado 80201-0840

Facility Name: Fort St. Vrain (FSV) Nuclear Generating Station

Inspection At:

FSV Nuclear Generating Station, Platteville, Colorado

Inspection Conducted: March 19 through April 30, 1989

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Inspectors:

R. E. Farrell, Senior Resident Inspector (SRI)

P. W. Michaud, Resident Inspector (RI)

Approved:

IN

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T. F. Westerman, Chief. Project Section B

Date

Division of Reactor Projects

Inspection Summary

inspection Conoucted March 19 through April 30. 1989 (Report 50-267/89-07)

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Areas Inspected: Routine, unannounced inspection of licensee action on

previously identified inspection findings, operational safety verification,

monthly surveillance observation, and monthly maintenance observation.

Results: Within the areas inspected, two violations were identified-

(paragraphs 4 and 6).

The licensee successfully completed an evacuation of the prestressed concrete

reactor vessel (PCRV) during this report period. This was a somewhat unique

evolution and required the use of unusual equipment and system lineups, as well

as coordination and cooperation among all licensee departments (paragraph 2).

Two instances were identified where the licensee failed to satisfy the

requirements of TS,

These examples indicate a potential breakdown in TS

compliance, peinting to weaknesses in attention to TS requirements.

Two control rods which had been replaced in February during the reserve

shutdown outage developed problems (paragraph 4). Both had recently been

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refurbished, which brings into question the maintenance and quality assurance

aspects of the refurbishment.

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An incorrect part number was specified for a replacement part on one of the

emergency diesel generators (Section 6).

This demonstrates a continuing

problem with control of maintenance activities.

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DETAILS

1.

Persons Contacted

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D. Alps, Supervisor, Security

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  • F. Borst, Nuclear Training Manager

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  • L. Brey, Manager, Nuclear Licensing and Resources
  • M. Cappello, Central Planning and Scheduling Dept. Manager
  • R. Craun, Nuclear Site Engineering Manager
  • J. Eggebroten, Technical Projects Manager

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  • D. Evans, Operations Manager
  • M. Ferris, QA Operations Manager
  • C; Fuller, Manager, Nuclear Production

J. Gramling, Supervisor, Nuclear Licensing Operations

  • M. Holmes, Nuclear Licensing Manager
  • F. Novachek, Nuclear' Support Manager
  • H. O'Hagan. Outage Manager
  • J. Re'esy, Nuclear Support Engineering Manager
  • R. Sargent, Assistant to Vice President, Nuclear Operations
  • L. Scott, QA Services Manager
  • N. Snyder, Maintenance Dept. Manager
  • P. Tomlinson, Manager, Quality Assurance
  • D. Warembourg, Manager, Nuclear Engineering

The NRC inspectors also contacted other licensee and contractor

personnel during the inspection.

  • Denotes those attending the exit interview conducted May 2, 1989.

2.

Plant Status

Evacuation'of the PCRV was completed on March 19, 1989.

This evacuation,

to 24.6 in. Hg., removed 182 gallons of water from the FCRV in less than

8 days. . Utilizing the normal purification system would have taken 6 weeks

or more to remove this quantity of water.

The licensee subsequently made preparations for plant startup and the

reactor was made critical on March 26, 1989.

Continued moisture removal

via the purification system, surveillance testing, and equipment repairs

were made prior to increasing power.

The turbine generator war placed on

the line April 9.

Following a Loop 1 shutdown on April 21, the exact

cause of which was not determined, the licensee shut down the reactor for

operator licensing startup tests, which occurred on April 24.

The plant was restarted on April 24 and the turbine generator placed on

the line April 27.

During weekly surveillance testing on April 27, the

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control rod drive (CRD) for Region 3 failed to scram.

The reactor was

shut down and an outage was commenced to replace the CRDs for Regions 3

and 7, which had been running at higher than normal temperatures.

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3.

Licensee Action on Previously Identified Inspection Findings

(92701)

(Closed)OpenItem(267/8722-02):

Instructions to Shift Breathable

Air Compressor Suction Not in Emergency Procedures _ - During a review of

the control room breathable air system following the October 1987 fire,

the NRC inspectors found no instructions in emergency procedures to shift

the suction of the breathable air compressors under radiological or smoke

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conditions. Procedures to perform this evolution existed, but nothing in

emergency procedures keyed personnel to those operating procedures. The

licensee revised Procedure EP-1, " Discussion of Fire," to include

Step 3.19 and Procedure EP-HZ, " Abnormal Radioactive Gas Release From

Plant," to include Step 3.2, which provide instructions to swap the

suction of the breathing air compressors. This action sufficiently

addresses the concern and this item is closed.

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(Closed)UnresolvedItem(267/8826-01): Evaluate Inconsistencies

Between Plant Drawings and the FSAR to Determine Whether Loads are

Sequenced onto 480 VAC Bus 2 - Inconsfitencies were discovered between the

FSAR, electrical drawings, and a licensee evaluation (EE-92-0008) with

regard to 480 VAC Bus 2 load sequencing. The licensee evaluated these

inconsistencies and provided a response to the NRC in a letter dated

December 15, 1988 (P-88425). Although the load sequence programs include

480 VAC Bus 2, there are no loads associated with Bus 2 which are part of

the load sequencing process. The licensee's response concluded that FSV

design documents, licensing bases, and plant drawings do not contain

inconsistencies relative to 480 VAC Bus 2 load sequencing. The NRC

inspectors reviewed the licensee's evaluation in response to this

unresolved item and consider it an acceptable basis to close this item.

4.

Operational Safety Verification (71707)

A.

General

The NRC inspectors made daily tours of the control room during normal

working hours and at least once per week during backshift hours.

Control room staffing was verified to be at the proper level for the

plant conditions at all times.

Control room operators were observed

to be attentive and aware of plant status and reasons why

annunciators were lit. The NRC inspectors observed the operators

using and adhering to approved procedures in the performance of their

duties. A sampling of these procedures by the NRC inspectors

verified current revisions and legible copies. During control room

tours, the NRC inspectors verified that the required number of

nuclear instrumentation and plant protective system channels were

opereble. The operability of emergency AC and DC electrical power,

meteorological, and fire protection systems was also verified by the

NRC inspectors. The reactor operators' and shift supervisors' logs

were reviewed daily along with the TS compliance log, clearance log,

operations deviation report (ODR) log, temporary configuration

report (TCR) log, and operations order book. Shift turnovers were

observed at least once per week by the NRC inspectors.

Information

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flow was consistently good, with the shift supervisors seliciting

comments or concerns from the reactor operators, equipment operators,

auxiliary tenders, and health physics technicians. The licensee's

station manager, operations manager, and superintendent of operations

were observed to make routine tours of the control room.

The NRC inspectors made tours of all accessible areas of the plant to

assess the overall conditions and verify the adequacy of plant

equipment, radiological controls, and security. During these tours,

particular attention'was paid to the licensee's fire protection

program, including fire extinguishers, fire fighting equipment, fire

barriers, control of flammable materials, and other fire hazards.

A walkdown of the emergency feedwater, emergency condensate, gaseous

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waste, diesel generator cooling water, and service water systems was

performed by the NRC inspectors. Valve and breaker positions were

verified where possible. When affected by a clearance, the valves or

breakers were verified to be positioned in accordance with the

clearance requirements.

Power supplies for components in these

systems were verified, but were also subject to clearances in some

cases. During these system walkdowns, the NRC inspectors verified

the operability of standby or backup equipment when components or

portions of systems were inoperable due to clearances.

B.

Radiological Controls

The NRC inspectors observed health physics technicians performing

surveys and checking air samplers and area radiation monitors.

Contamination levels and exposure rates were posted at entrances to

radiologically controlled areas and in other appropriate areas and

were verified to be up to date by the NRC inspectors. Health physics

technicians were present to provide assistance when workers were

required to enter radiologically controlled areas. The NRC

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inspectors observed workers following the instructions on radiation

work permits concerning protective clothing and dosimetry, and

observed workers using proper procedures for contamination control,

including proper removal of protective clothing and whole body

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frisking upon exiting a radiologically controlled area.

C.

Security

T5e NRC inspectors randomly verified that the number of armed

security officers required by the security plan were present. A lead

security officer was on duty to direct security activities on each

shift. The NRC inspectors verified that search equipment, including

an x-ray machine, explosive detector, and metal detector, was

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operational or a 100 percent hands-on search was conducted.

The protected area barrier was surveyed by the NRC inspectors to

ensure it was not compromised by erosion or other objects. The NRC

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inspectors observed that vital area barriers were well maintained and

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not compromised. The NRC inspectors also observed that persons

granted access to the site were badged and visitors were properly

escorted.

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D.

Review of TS LCO Compliance

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The NRC inspectors reviewed the licensee's compliance with TS Interim

LCO 3.1.8, " Reserve Shutdown System - Operation," prior to plant

.startup. Action Statement A of this LCO refers to the capability of

making an inoperable reserve shutdown (RSD) hopper operable within

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14 days following a reactor shutdown. This requirement is based on

the need to insert all RSD material, assuming all control rods fail

to insert. The shutdown margin would initially be adequate with one

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RSD unit inoperable, but under a worst case scenario, the decay of-

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protactinium (Pa) would require insertion of the RSD material from

the inoperable region within 14 days. This would be accomplished by

removing the CRD with the inoperable RSD hopper and replacing it with

a spare CRD which has an operable RSD hopper. . Experience has shown-

this can be accomplished in 2 to 3 days; hence,.the 14-day

requirement can.be met.

In addition, the licensee has a spare CRD

with an operable RSD hopper available in an equipment storage well.

During this inspection period, there were two instances in which the

licensee failed to satisfy the requirements contained in TS prior to

changing plant conditions, which caused the TS to become applicable.

The requirements of LCO 4.2.7 were violated at 10:18 p.m. on March 23

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when the PCRV was pressurized to greater than 100 psia with the

purified helium supply to the Region 27 interspace isolated.

LCO 4.2.7 specifies the PCRV shall not be pressurized to more than

100 psia unless, among other things, the interspaces between the

primary and secondary penetration closures are maintained at a

pressure greater than primary system pressure with purified helium

gas.

The purified helium supply to the Region 27 interspace was isolated

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due to Clearance No. 27419, which was not returned prior to exceeding

.100 psia. This clearance was hung on February 21, but was never

accepted for work as another clearance, No. 27851, covered these

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components. Clearance No. 27851 was returned on March 22, prior to

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exceeding 100 psia. During the licensee's review of the clearance

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log prior to exceeding 100 psia, it was noted that a clearance for

Region 27 had been returned, but the existence of a second clearance

was not discovered until 1:02 a.m. on March 24 after a new shift

crew reviewed the clearance log. Upon identifying this condition,

Clearance No. 27419 was immediately returned and the Region 27

interspace was pressurized as required.

The second instance of failing to satisfy TS requirements prior to

changing plant conditions involved a TS surveillance which was not

perfonned as required. LC0 4.6.1 specifies that the reactor shall

not be operated at power, which is defined as the linear power

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instruments indicating more than 2 percent, unless both diesel

generator sets are operable. Reactor power was increased above

2 percent on March 27 at 8:21 p.m.

It was subsequently discovered

that TS SR 5.6.1d-M, " Diesel Engine Exhaust Temperature Functional

lest," had not been performed within the previous month as required.

Reactor power was reduced below 2 percent at 1:20 a.m. on March 29.

This surveillance procedure tests the emergency diesel generators'

exhaust temperature shutdown and declutch functions. This

surveillance test had last been-performed on March 8 but was

rescheduled due to ongoing maintenance on the diesel engines.

SR 5.6.1d-M was performed satisfactorily following the power

reduction to below 2 percent on March 29, and the plant rise to power

was resumed.

The licensee was informed that these two examples of a failure to

ensure compliance with a TS prior to changing plant conditions, which

resuli.s in the TS becoming applicable, is an apparent violation of NRC

regulations (267/8907-01).

On April 18, the shim motor temperature for the Region 7 control rod

drive exceeded 250 F.

TS Interim LC0 3.1.1.B requires a temperature

of less than or equal to 250 F in order for the control rod pair to be

considered operable. Action Statement B of Interim LC0 3.1.1 allows

continued operation under these conditions provided the' shutdown

margin requirement of Interim LC0 3.1.4 is verified to be met with

the rod pair considered inoperable in its present position (fully

withdrawn). A shutdown margin calculation was performed using

SR 4.1.1. A-W/5.1.4-W, " Core Reactivity Status Check During Power

Operation." The NRC inspectors reviewed this calculation of

shutdown margin, which assumed both the maximum worth rods were stuck

and the Region 7 rod was inoperable. An acceptable shutdown margin

,was calculated and operation was allowed to continue.

A Loop 1' shutdown (ESF actuation) and reactor runback occurred'on

April 21- when a clearar.ce was being hung on the "C" Inverter which

supplies noninterruptible 120 VAC Bus 3 and Instrument Bus 3.

During

this process, power to these buses was lost. The turbine generator

immediately tripped, both Loop I helium circulators tripped, and a

Loop 1-shutdown occurred. Single channel scrams on all Channel

"C"

instruments occurred due to the loss of power to those instruments.

Power was restored to'the deenergized 120 VAC buses in approximately

30 seconds when the equipment operator hanging the clearance restored

the "C" inverter to its normal lineup. The plant responded to this

event as expected.

The licensee was unable to repeat the event during the analysis of

it. The "C" Inverter was examined and operated as designed. The

clearance (No. 25950), which was being hung, was reviewed by the

licensee and the NRC inspectors and was found to be correct. The

System Operating Procedure, SOP-92-05, Section 4.2.2, " Transferring to

Alternate Power Source at an Inverter Using the Static Transfer

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~ Switch," was also reviewed by the licensee and the NRC inspectors -

and found-to be correct. The NRC inspectors verified through

interviews of onshift personnel that the procedure was reviewed and

was in use at the time of the occurrence. The equ t. lent operator

involved walked through his actions with an offduty shift supervisor

following the event. He described no actions which would have

initiated this event. Hence, the cause has not been determined and

can be attributed to either a nonrepeatable inverter malfunction or

an operator error.

The licensee had planned to shut down on April 22 for operator

licensing examination startups, so the reactor was shut down

following the April 21 Loop 1 shutdown. The plant was restarted

after completion of the licensing startups on April 24.

During the performance of weekly 10_ inch scram tests on April 27, the

control rods for Region 3 failed to scram. When power to the brake

was deenergized, the rods dropped 0.6 inch, the rod out limit light

extinguished, and the rods stopped. Troubleshooting verified power

to the brake was being removed and that the rods could be driven in,

though drawing higher than expected current. The licensee,

therefore, initially considered the Region 3 control rods to be

" movable" but not "scrammable." This condition is not specifically

addressed in the action statements for TS Interim LC0 3.1.1 and led

to some confusion in determining action to be taken. Action

Statement A of Interim LC0 3.1.1 addresses control rods being

" inoperable due to being immovable (i.e., not capable of being fully

inserted)." Because the licensee had demonstrated the rods movable,

though not scrammable, this action statement was deemed

inappropriate.

Action Statement B of Interim LC0 3.1.1 addresses "one rod pair

trippable but inoperable due to causes other than addressed by

Action A" and provides that operation may continue if the shutdown

margin is verified with the rod pair considered inoperable in its

present position. The rods were capable of being fully inserted.

The intent of the word "trippable" was in question.

Action Statements C and D were clearly not appropriate for this

condition. Because Action Statement A was also inappropriate, and

since Action Statement B addressed "causes other than addressed by

Action A," the licensee determined Action Statement B to be

applicable and performed a shutdown margin verification as it

required. The licensee contacted the NRC Region IV office. The

licensee's inte"pretation of the actions to be taken was discussed

and it was agreed that power would not be increased, but operation

coula continue pending NRC review of the TS. The NRC inspector

learned of the situation approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> later and went to the

site to review the status of the plant. Upon reviewing the

requirements of Interim LC0 3.1.1, it became apparent that the

licensee was not truly meeting the requirements of any action

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statements of Interim LCO 3.1.1, and that, therefore, the requirements

of Interim LC0 3.0.5 were applicable.

Interim LC0 3.0.5 addresses

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the inability to meet an LCO or its action statements and requires

the plant to be in the startup mode within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in shutdown

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within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The NRC inspector discussed this with

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the licensee's station manager who then ordered an orderly plant

shutdown. The reactor was shut down with all rods verified fully

inserted at 6:54 a.m. on April 28. The initial determination occurred

at 9:30 p.m. on April 27, and, thus, the shutdown was completed

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within the time required by the applicable TS.

The licensee then entered an outage to replace the CRDs for Regions 3

and 7, which had been operating at high temperature as discussed

above. At the end of this inspection period, the control rod for

Region 3 had been removed and the outage was proceeding on schedule.

It should be noted that the CRDs from Regions 3 and 7 had recently

been refurbished and installed during the reserve shutdown outage in

February 1989.

5.

Monthly Surveillance Observation (61726)

The NRC inspectors routinely monitored the control room surveillance log

to verify that TS surveillance were complete and up to date for the

current reactor status. Additionally, the NRC inspectors monitored

surveillance activity for reactor starts and mode changes. Special

attention was paid during this inspection period to alternate cooling

method (ACM) diesel generator load tests required by TS 5.2.20.

The NRC inspectors also observed performance of the weekly fuel storage

building entry per Procedure CMG-16, Issue 3, " Entry / Exit of the Fuel

Storage Building with Fuel Present in the Facility," and security

Procedure SR-SE-16-W, Issue 10, " Fuel Storage Building Alarm System and

Key / Core Inventory." The NRC inspectors also observed the health physics

technicians performing routine source checks on the fuel storage building

radiation monitors.

During performance of SR 4.1.8.C.1/2/3-Q, " Reserve Shutdown Hopper, ACM

Disconnect, and Low Pressure Alarm Functional Test," on March 25, the

Region 34 RSD hopper failed to depressurize. The portion of this test

being performed verifies the integrity of the RSD hopper rupture disc by

pressurizing the hopper to approximately 10 psi above reactor pressure. A

pressure switch actuates to give a high hopper pressure alarm, which

indicates the hopper's integrity. A small orifice then allows the hopper

pressure to equalize with reactor pressure. This did not occur on

Region 34, as the high hopper pressure alarm did not clear. The licensee

theorized that some small piece of carbon or corrosion products might have

been clogging the orifice. The surveillance procedure was performed

again, and the hopper depressurized within the required time.

Subsequent

tests have not shown any further problems.

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On March 25, 1989, during performance of control rod testing in accordance

with SR 4.1.1.D-X

" Full Stroke Scram Test," the Region 32 control rod in

limit light did not extinguish as required. Troubleshooting by the

licenseeconfirmedtheswitch(ZSL-1211-32) was stuck shut. Each control

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rod drive has two redundant installed limit switches. A temporary change

was prepared to jumper out the defective limit switch. The NRC inspectors

reviewed TCR 89-03-05 and the associated safety evaluation. Since the

redundant limit switch (ZSL-1232-32) was demonstrated to be operational,

disabling the defective limit switch did not present an unreviewed safety

question. Compliance with TS 3.1.2, " Rod Position Indication Systems -

Operation," was verified by the NRC inspectors.

On April 27, 1989, during the performance of SR 4.1.1.B.1/2-W,

SR 4.1.2. A.3-W and SR 5.1.1.6-M, " Power / Low Power /Startup 10 Inch Scram

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Test," the control rod pair. for Region 3 failed to scram. When power to

the CRD brake was deenergized, the rod moved in approximately 0.6 inch,

the rod out limit light extinguished, and the rod motion stopped.

Troubleshooting determined the rod was movable in both the in and out

directions with the drive motor but would not scram. Actions taken in

response to this are documented in paragraph 4 of this report. The

licensee entered an outage to replace this CRD, which was in progress at

the end of this inspection period.

No violations or deviations were identified in the review of this program

area.

6.

Monthly Maintenance Observation (62703)

Replacement of cylinder heads on the "A" Diesel Generator was completed on

March 24. This was performed in accordance with Station Service

Request (SSR) 89501207 and in response to a problem with coolant flow

directors as documented in NRC Inspection Report 50-267/89-03.

9' During posteaintenance testing by the vendor on March 24, it was

determined that the replacement heads were not performing satisfactorily.

Based on the results of cylinder leakdown tests, the vendor recommended

rebuilding all 12 heads on the "A" Diesel Generator. The heads were

removed, rebuilt, and reinstalled on March 27, 1989.

Postmaintenance

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testing demonstrated satisfactory performance, and the "A" Diesel

Generator was subsequently declared operable. The licensee's

investigation of the problem disclosed the replacement heads for the "A"

Diesel Generator came from a different source than those obtained for the

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"B" Diesel Generator. The "B" Diesel Generator had previously undergone

the same repairs and performed satisfactorily during postmaintenance

tests. Additional testing of the diesel generators per the weekly

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surveillance requirements has shown satisfactory operation of the engines,

with one exception as noted below.

On April 7,1989, the "D" Engine, which is part of the "B" Diesel

Generator set, tripped on high temperature during the weekly surveillance

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test. SSR 89501818 was issued to check the calibration of the "D" Engine

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water temperature switch (TSH-92272), since it appeared the engine tripped

at a temperature lower than the setpoint of 198 12 F.

On April 12,

during troubleshooting, the water temperature switch was found out of

calibration and was replaced. The instrument and control technician

ordering the replacement part specified the wrong part number. The part

number for the oil temperature switch (which is one line above the water

temperature switch on the parts list) was erroneously selected'and

purchased. The oil temperature switch is physically the same as the water

temperature switch, and the part numbers are consecutive (1730389 and

1730390, respectively). The oil temperature switch has a range of

200-360"F, and the water temperature switch has a 130-200 F range.

The incorrect temperature switch was procured, calibrated, installed, and

tested satisfactorily on April 12, 1989. On April 19, during the weekly

surveillance test,' the "D" Engine again tripped on high temperature.

During troubleshooting efforts, it was discovered the wrong temperature

switch had been installed. The correct temperature switch was

subsequently obtained, calibrated, and installed. The licensee verified

that the correct temperature switches were installed in the other three

diesel engines. The licensee was informed that the specification and use

of an incorrect part in safety-related equipment is an apparent violation

of HRC regulations (267/8907-02).

The NRC inspectors observed the installation and calibration of a new

valve positioner on Valve PCV-4256. This valve provides reduced pressure

firewater to the diesel generators and boiler feed pump heat exchangers as

a backup source of cooling water. The existing design had a 3-15 psi

controller supplying a direct air signal to the valve actuator. This was

insufficient to keep the valve closed under all operating conditions. A

changenotice(CN-2923)andassociatedcontrolledworkprocedure

(CWP 89-0027), " Add new valve positioner with regulator to use in

combination with existing PIC-4256 for the control of PCV-4256," were

prepared by the licensee. A positioner was added which supplies 40 psi to

the valve-actuator when the controller provides a 15 psi signal. The NRC

inspectors reviewed the change notice, controlled work procedure, and

associated safety evaluation; no discrepancies were noted.

The NRC inspectors observed maintenance activities performed on

Valve HV-21257, " Emergency Condensate to ' A' Helium Circulator Water

Turbine," which had been leaking through. Because of the plant's

configuration, one side of this valve had no isolation valve, and a freeze

seal had to be utilized. The NRC inspectors observed installation and use

of the freeze seal and maintenance on the valve per SSR 89501885 and

Clearance No. 25967.

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No violations or deviations were identified in the review of this program

area.

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7.

Exit Meeting (30703)

An exit meeting was conducted on May 2, 1989, and attended by those

identified in paragraph 1.

At this neeting, the NRC inspectors reviewed

the scope and findings of the inspection.

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