ML20248E026

Team Insp Rept 50-267/89-08 on 890522-26.Violations Noted. Major Areas Inspected:Maint Activities Re Reactor Water Cooling Sys (Sys 46)

ML20248E026
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/01/1989
From:	Gagliardo J, Hunter D, Vickrey R, Larry Wheeler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248E007	List: ML20248E004 ML20248E010 ML20248E026
References
50-267-89-08, 50-267-89-8, NUDOCS 8908110203
Download: ML20248E026 (17)

See also: IR 05000267/1989008

Text

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APPENDIX B

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U.S.. NUCLEAR REGULATORY COMMISSION

. REGION IV .I

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b ,NRC Inspection Report: 50-267/89-08 Operating License: -bPR-34

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Docket: 50-267- l

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1. ,' Licensee: -Public Service compan) of Colorado (PSC)

2420 W. 26th Avenue, Suite 15C

' Denver,' Colorado 80211 *

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

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9' . Inspection at: FSV. Site, Weld County, Colorado

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' Inspection Conducted: Ma'y 22-26, 1989 '

Inspectors 6 /A /) N

. E( G liardo, Ikam Eeader Date'

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/ . if. ' ter, Senior Reactor Inspector Date "

Opeu onal Programs Section

Divisi n of Reactor Safety

. d$f  %

1. B. Vickrey,' ReactorA nspector

Wi/ry

Date

Operational Programs Section

Division of Reactor Safety

Approved: t . .,

. Teeler, Acting Deputy Director Date

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Division of Reactor Safety

' Inspection Sumary

inspection Cnnducted May E2-26, 1989 (In,spection Report 50-267/89-08)

, Areas Inspected: .Special, announced team inspection of overall plant

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performance related to maintenance, management support of maintenance, and

maintenance irilementation. Specifically the inspection team evaluated the

maintenance activities related to the Reactor Water Cooling System (System 46).

8900130203 B?OB03 ' l

PDR ADOCK 05000267

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Results:

General: The material condition of System 46 was generally good, but the

overall routine operating conditions of System 46 were not well controlled by

the licentte. The system was operated in a manner to maintain the cooling

water temperature within limits. Cooling water flow rates for 14 of the 36

tubes were in excess of the high flow alarm. set points.

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InstrumentandControl-(18C): In'the area of IAC, the calibration, functional

testing, and maintenance of the individual system monitors appeared to be-

< acceptable. However, the inspection revealed that the licensee did not-

periodically assess the system functional requirements-(flows, temperatures,

levels, pressures, etc..) and ensure that all the functions were adequately

monitored and had been fully tested.and retested on a routine basis.

Mechanical: The licensee's. maintenance program did not include periodic

testing of relief vah e set pressures, operability of check valves, operability

of system cross-connect valves, surge tank. integrity, heat exchanger

performance, and other preventive maintenance items. Implementation of

existing programs had been adequate, but the work instructions were poor.

Electrical: The licensee's maintenance program did not include preventive

maintenance on System 46 motors other than vibration analysis and lubrication.

The licensee's lack of control of motor bearing shield status appears to have

created problems.with the lubrication programs as to which motors were to be-

lubricated. The electrical functional tests and vibration analysis program

appeared satisfactory.

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DETAILS

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1. Persons Contacted-

PSC-

'*R. Allen System Engineer ,

• M. Block, Manager System Engineering

• S; Chesnutt, Supervisor, Nuclear Licensing Compliance-

M. Denniston, Supervisor Operations

• D. Evans, Assistant Plant Manager.

• C. Fuller . Manager Nuclear Operations

'*D. Goss, Manager Nuclear Regulatory Affairs

D. Hackett, I&C-Technician

'*G. Lacasse, System Engineer

V. Lucero, Chemistry Supervisoc

J. McCauley,-Superintendent'I&C

J. Meisner, Nuclear Training Specialist

• R. Moler, Planning and Scheduling Engineer

R. Porter, I&C Technician

T. Sc' 41ger, Supervisor Chemistry and Radiation Protection

• G. Schreider, NED Engineer

E. Sheron Equipment Operator

• N._Snyder Maintenance Department Manager

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• P. Tomlison, Manager Quality Assurance

S.-Wilford, I&C Training

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l *P. Michaud, Resident Inspector ~

• Denotes those attending the exit interview on May 26, 1989.

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2. Maintenance Program Implervntation (62700)

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The inspectors reviewed and evaluated the maintenance programs ar.d tr.e

l. maintenance activities for selected systems. The inspection was perfortwo

h to deter.nine that the maintenance program and the irtplementatior. of the

l pmgram was adequate to maintain the selected systems in an operable

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condition consistent with tre design function of the. systems. The results

of this inspection effort are discussed in the follcwing paragraphs,

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a 2.1 Reactor Water Cooling System _

The reactor plant coeling' water system (System 46) was designed to cool

vital components of the reactor plant. One of the major functions nf the

system was the cooling-(and heating during cold shutdown) of the reactor i

vessel liner. This safety-related system must be operable during plant '

operations and during shutdowns. System 46 was one of the systems that

must be maintained operable during the extended defueling cutage being

planned. j

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2.1.1 Mechanical Maintenance

Areas Examined

The inspector toured the plant and examined the material condition  !

and the status of all' accessible portions of the liner cooling

system. The inspector also reviewed the licensee's preventive

maintenance program for the system, the records of selected

maintenance activities performed on the system, and the licensee's

program for controlling water chemistry in the system.

Findings

The inspector found that the material condition of the system to be

generally good. The inspector found that the manual valves, which

were closed to isolate the leaking tubes in the system, had not been

tagged and/or locked closed. The valve bodies had been spray painted

with an orange. colored paint to identify them as valves that should

not be opened. The inspector also noted that the motor for Reactor

Water Cooling Pump 4602C had a deficiency tag (No. 014888, dated July

1988) attached to it. Further review determined that the deficient

condition had been resolved, but the deficiency tag had not been

removed.

The inspector noted that the relief valve, located on the reactor side

of one of the isolated tubes (leaking tube), appeared to be new or

recently refurbished. The inspector asked to see the test records of

the relief valve. There were'no records to show that the relief

valve had ever been tested to verify its setpoint. The inspector

also found that the licensee had no program in place to test

periodically the numerous water, air, and steam relief valves in the

system.

The inspector also found thet the licensee had not tested the

bsckflow preventien feature of the check vMycs in the system. The

licensee had recently contntted a group to come to the plant and

test selected check valves with an accoustical monitoring device that

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would detect or predict disc failure due to flow induced fluttering

of the disc. A licensee representative stated that the vendor

claimed to have the ability to detect valves that have already 3

failed. The inspector was concerned that not all the check valves '

youid be tested by the vendor. Tr.e check valves to be tested were

selected based on the flow characteristks uf the system 6nd the

potential for f?utte' ir. the valve. The salety significance of the

l- check valve in the system was not considered in the selection

process. The licensee had also failed to define criteria for

expanding the semple size based on negative test results.

System 46 was provided with cross-connections to the firewater header

to provide cooling water to the liner cooling water system in the

event of a loss of all forced circulation in System 46. The

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inspector 1 reviewed the licensee's' program for periodically verifying

that the cross-connect valves between the.two systems were operable.

The inspector found that'the licensee.had an annual surveillance test

(SR 5.3.4c3-A) that cycled the cross-connect valves to verify their-

operability. It was noted, however, that two of.the cross-connect i

valves.(V-46121 end V-46122) were not included in the surveillance.

test. Valve V-46121.was found to have some packirg leakage.and had a

buildup of chemicals on the valve stem. This condition raised

questions regarding the operability of the valve in the event of an

emergency. The licensee's failure to periodically test all of the

cross-connect valves is an apparent violation-(267/8908-01) of

.TS SR 5.3.4, which requires that all safe shutdown cooling water. i

valves be tested annually.

.The two surge tanks in the system provide the suction head for the .

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circulating pumps. . The inspector attempted to review the records cf I

the periodic inspections of the. tanks. .The. system engineer for

System 46 stated that'the tank supports are inspected annually, but i

he was not aware of any inspection activities on the tanks. The

system engineer searched the maintenance history records and found no

records of internal' inspections or maintenance on the tanks. The

surge tanks receive the full loop flow of about 1500 gpm and the

. inlet water is sprayed into the void space of the tank through a l

sparger. The licensee's failure to inspect periodically the internals .j

of the tanks or to measure nondestructively the thickness of the tank  ;

walls is a poor practice.

The inspector reviewed the licensee's program for monitoring the

performance of the System 46 heat exchangers. The licensee had a

surveillance procedure (SR-RE-150-X) which was used to calculate the  !

overall heat transfer coefficient and the fouling factors for the

four heat exchangers. The records provided by the licensee indicated

that this annual surveillance was 'ast performed on March 8, 1988. ,

The inspector was told that the data . derived f rom this surveillance '

wes'used to trend the performance of the heat exchangers, but the

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inspector was shown no other trend data or the test dcta for tests  ;

other than that taken on' March 8, 1988. The review revealed that the  !

licensee had repaired Heat Exchangers-E-4E01 and E-4604 in 1986. The

importance of this system, and the fact that the licensee had

experienced some fouling in the pest, indicated that more vigor uts  !

warranted in the ' monitoring and trendirg of the heat exchcoger l

performance.

The inspector interviewed the individuals responsible for maintaining

the chemistry in the system. The inspector was provided with a

computer printout of the results of analyzed samples from the system

during November 2, 1988 through May 22, 1989. Samples had been taken

nearly every week and were analyzed for pH, dissolved oxygen, total

dissolved solids, sodium, and silica. The data indicated that the

licensee had effectively maintained the chemistry of the system. The

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three occasions (in which the pH was found to be slightly below the

acceptance criteria) were promptly corrected by chemical additions

and the system was resampled to verify that the coolant was within

specification.

-The inspector reviewed the preventive maintenance program for System 46.

A licensee representative provided him with a copy of the master

. lubrication list, which was the only preventive maintenance item

performed on System 46. This list included lubrication (greasing)

schedules for all of the pumps and pump motors (where applicable) in

the system. It also included lubrication sc;edules for many, but not

all, of the subheader isolation valves. The licensee needed to

review their preventive maintenance practices to assure that items

have not been overlooked that could eventually cause operability

problems for the system.

The inspector reviewed a number of station service requests (SSRs)

for maintenance that had been performed on System 46 over the past 2

years. The SSRs had received the appropriate levels of review, but

the work instructions were generally handwritten and provided very

generalized guidance _for the performance of the maintenance task.

Acceptance criteria were not well defined and were qualitative (not

quantitative) in nature. In general, the instructions relied heavily

on the skills and knowledge of the craftsmen. The licensee should

critically evaluate the adequacy of this. approach to providing

maintenance instructions.

Conclusions

The material condition of System 46 was generally good, and the

performance of the system had been acceptable. The success of the

system's performance did not eppear to be the result of strong

maintenance practices, with the possible exception of chemistry

control.

The licensce's maintenance program did not includt periodic check 1 or

tests of: (a) relief valve set pressures, (b) check velve

operability determinations (c) cross-cunnect valve operability

determinations, (d) surge tank integrity measurements, (e) heat ,

exchanger performance checks,. and nther preventive mainter,ance items.

Unless these prograni weaknesses are corrected and implemented, the l

licensee is likely to experience future problems in miinteining the

operability of the system.

2.1.2 Electrical Maintenance

Areas Inspected

The inspectors reviewed the maintenance activitics associated with i

the cooling water pump motors and their power rapplies. This review

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included a walkdown inspection of.the related equipment, a review of

related work documents, and interviews with several personnel

involved with the maintenance and operational activities of the

equipment.

Findinas

During the inspector's tour of System 46 components, several

' observations were made that raised questions about control and status

of the components. These observations included:

Pump Motor "A" was missing a nameplate;

Motors "B" and "C" were missing air screens;

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Motors "A", "B", and "C" had grease zirc fittings while "D" did

not;

Motor "C" had an eye bolt installed;

Transfer switches N-4877. N-4878, N-4879, and N-4880 were not

locked in position; and

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Breaker handling gear and a ladder wue not secured in the

essential switchgear room.

The inspt.ctor reviewed Surveillance Test Procedut. SR 5.2.21-5A, "ACM

Pneumatically and electrically operated valves ar.. asfer switch

functional test." This procedure was primarily reviewe i for the

transfer switch functional test. The procedure provided proper

precautions, prerequisites, authorization, and procedural steps.

The vibration analysis system and test d6ta was reviewed for Pump

Motors "B" and "C". Only one set of the test data had been taken for

these motors. Pump Motors "A" and "D" had ro baseline test data.

The inspector found that an adequate system was in plact to provide a i

good vibration and trending program. The vibration analysis program

had oniy been in operation for a short period of time. The

inspector's evaluation cf the program was made from data available on  !

other thsn System 46 components that had enough data taken to provide )

a history and a set of trending curves. l

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The inspector reviewed the wurk package for Station Service )

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Request 88502872, covering the repair of Cooling Water Pump "C." The l

l work package included the necessary portions of Procedures MP-2261, )

MPE-1904, and MPE-1001-EQ. Other documentation for the motor repair

included the bearing requisition card for this motor, which specified

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SKF double shielded bearings. The work package had no provisions for

removing any of the bearing shields, but a review of the post work

history on the liter.see's computer indicated that some of the cooling

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water pump motors had the bearing shields removed during

installaticri. e A review of the licensee's master lubrication list

indicated that Motors "A" and."C" were being lubricated once a' year

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,with grease, and Motors "B" and "D"~had sealed bearings and were not

to be greased. The inspectors informed the licensee that the

lubrication master list was not consistent with work history as to

which. motors had shielded bearings and which did not.

Conclusions

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The licensee.'did not appear to have an adequate systeia to control

equipment in seismically cualified areas, such as.the essential

switchgear room as indicated by the lack of requirements to. secure

the breaker handling equipment when not in use and the unsecured

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ladder. This lack of control presented additional risks to qualified-

equipment during the design basis seismic event.

The licensee appeared to have loi.t control of motor bearing statur

for lubrication purposes and may have modified the motor bearing from

what was the original design and qualification basis of the motors.

The licensee did not have a preventive maintenance program for the

motors, other than the. lubrication list, that would provide

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identification of deficiencies. None of the def v Mncies identified

l by the inspector had been identified by the license..

Although Procedure SR 5.2.21-SA provided satisfactory control of the

mctor transfer switches the inspector was concerned over the

switches not being locked in position.- The operation of these

i switches occurs only during an abnormal condition and was controlled

l- by procedure, There appeared to be no valid reason why the breakers

l were not protected against inadvertent opurations. The transfer

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switches oid have a warning tag on them which stLted that they were

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not to be opened when the motor was running, b:st the swf tch handle,

which was designed witn locking capab9ity, was not pedlocked or

otherwise restricted from unautncrazed operation. Ecth switches were

in the general vicinity of the motors and the irspector was concerned j

that in case of a fire or otner abnormel condition, an operator could i

open the transfer switch while the motor w6s running without

reali;:ing the consequences of opening a knife switch under load.

Although the licent,ce's vibration er.alysis systeni had teen in effect j

for a short period of time, the inspector was satisfied with the

L prooress the licensee had made to get this program ofi to a good  ;

l- start. 1he licensee's continued support of this program should help .

to improve their preventive maintenance program.

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2.1.3.1 Areas-Inspected ,

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1" The. inspector reviewed the ISC maintenance activities for System 46 - <

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System temperature monitoring

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• * System flow monitoring

V -" System pressure monitoriing

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System surge tank level monitoring

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Data acquisition system

2.1.3.2 Findirigs, <

m. -During the= inspector's review of System 46. maintenance, several

observations were mace that raised questions which impacted the

operability of the system. The observations are discussed in the

following sections.

2.1.3.2.1 System Temperature Monitoring

The inspector reviewed Procedure SR 5.4.4-M/5.4.4 A-1, "PCRV Cooling.

Water = Temperature Test and Subheader Temperature Indication

Calibration," (Issue 37), and observed the performance 'of the

procedure'during the-inspection period.

' The'I&C technician performed the appropriate parts of the procedure

and calibrated three temperature indicators (TI-46332. 11-46184, and-

TI-46330) in an oil bath. Two of the three tis were found to be

within 2 F of the standard; however, TI-46332 required minor

adjustments.

The calibrated tis were reinstalled in the cooling water subheader,

and the calculated subheader temperatures were compared to the

associated individual cooling tube exit temperature. The tis had an

acceptance criteria of plus or minus 6*F with the average exit

temperature, but a number of the temperature' channels did not meet

this criteria. The. test was forwarded to results engineering for

evaluation of such items as the actual system configuration (isoitted

cooling tubes) and known hot tubes (poor insulation).

The inspector reviewed Procedure SR 5.4.11-M, "PCRV Surface

Temperature Indicator Functional Test," (Issue IB), and observed the-

performance of the procedure during the inspection period.

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The I&C technician performed the appropriate perts of the procedure

and compared the two temperature elements (TE-733360-1 and  ;

TE-73336-2) with the calibrated temperature element, and verified the 1

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control room recorder (TR-4637 and TR-4638) to be indicating within

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allowable tolerances.v The inspector 'also observed the I&C technician-

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checkthePCRVsurfacetemperature'(TR-4637.and.TR-4638)tobewithin '

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50*F of the, outlet water temperature averaged' aver 24-hours .

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(TS:4.2.15). .The inspector also noted that this TS item was checked

' by the" operators ' daily on the night shift by rolling the strip chart

and. recording the check on a control room monthly log sheet.

The inspector reviewd selected records and procedures regarding the

j system calibrations.

SR 5.4.4-A3/M, "PCRV Area Core Support Floor, Bottom Section and

Penetration Cooling heter Thermocouple Calibration,"-(Issue 1),

performed between Marcn 1987 and April 1989.-

SR 5.4.4-A1, "PCRV Cooling Water Top Penetration Thermocouple.

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Calibration," (Issue 2), performed August 14, 1987. '

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2.1.3.2.2 System Flow Monitoring

The inspector reviewed the System 46 operating conditions during the

. inspection on May 23, 1989, including the field observation of

selected cooling water flow transmitters (Foxboro Model 82-turbine;

flowmeter / transmitter) and the data scan system e TM inspector

requested a data printout for review of the system flow data. b f

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review revealed that-14 of the 36 subheaders (8 in Loop 1 and 6-in-

Loop 2) were operating with cooling water flow rates in excess of the

high flow alarm setpoints. The high flow alarms.were indicated on

monitors located at the data scan equipment and also in the control:

room behind the control board. System 46, Subheader 46249-(FT-46160)

was operating in alarm at 43 gpm, with the high flow alarm set at 40

gpm. The low flow alarm was set at 15 gpm, substantially below the

normal (43 gpm) flow rate. Subheader 4623B (FT-46133) was operating

in alarm at 207 cpm, with the high flow alarm set at 100 gpm. The

, low flow alarm was set-at 72 gpm, substantially below the normal (207

gpm) flow rate. None of the System 46 subheaders (total of 367)

cooling water flow rates were at low flow alarm setpoints.

Discussions with licensee representatives and document reviews

revealed that the low flow alarms indicated locally, in the control

room (behind the control board), and also annunciated in the control

room. Discussions with the unit operators revealed that the full

capability of the remote mor.itors was not well understood by the

operators. This item was brought to the attention of the licensee

for review and evaluation.

The inspector reviewed select records and procedures regarding the

annual calibration' of 6 subheader flow meters and the calibration

check of each of the subheader flow channels.

The inspector also reviewed the maintenance, calibration, and

post-maintenance testing of a failed subheader flow transmitter

(FT-46137) for core support floor bottom cooling water (Loop 2). The

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workpackage.(SR 3858174), completed on April 24, 1989, also

contained the' parts and materials requisitions, a termination control

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form (TCF), the QC inspection report, and the inservice. leak test

L report. The work package included the completion of Procedures

SR 5.4.5AX2 and SR 5.4.5-AZ, "PCRV Cooling Water Flow Scan

Calibration," on April 23 and 24, 1989, associated with the flow

channel and low' flow alarm,setpoint (51 gpm)..

The inspector reviewed Procedurre SR 5.4.5-M, "PCRV Cooling Water Flow

Scan Functional Test," (Issue 31), and discussed the. system header

flow channels with licensee personnel. The PCRV cooling water

l subheader low flow alarms were~ functionally tested monthly; however,

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the scanner high flow alarms were not included in the monthly test,

nor tested utilizing other procedures. The inspector also reviewed

Procedure SR 5.4.5-A1, "PCRV Cooling Water Flow Scan Calibration,"

(Issue 20), and noted that the flow scanner and low flow alarms were

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calibrated annually; however, the scanner high flow alarms were not

calibrated. The inspector'noted"that the high flow alarms appeared

to be functional at the time of the inspection; but the failure to

functionally check tne high flow alarms each month and to calibrate

thehighflowalarmsannuallyisanapparentviolation(267/8908-0?)

of TS SR 53.r., whf G * equires that &c PCRV cooling water scanner

system alarms be tunuionally checked monthly and calibrated

annually.-

Document reviews and interviews of licensee representatives revealed

that low flow conditions were simulated periodically to check the low

flow alarms. Procedure SR 5.4.5-A1, Step 5.2.2 required that the

System 46 hand switches (HS46227 for Loop 1 ana HS-46228 for Loop 2)

were in the " normal mode" position. Therefore, during the

performance of the procedure calibrating the scanner flow channels,

the loop header isolation function was bypassed.

The System 46 isolation on low flow was discussed in the updated

FSAR Section 9.7.3.5. This section indicates that when the reactor

was depressurized, cooling water would leak into the reactor q

resulting in a low tiow condition. The affected subheader low flow

would alarm and the subheader would isolate to terminate the in

leakage of water into the reactor. This criteria was described in

the FSAR and was based on the flow system capability (3 percent

deviation from normal), at a maximum water volocity of 8tt/sec. and a

scanner cycle of 54 seconds. The TS SR 5.4.5 basis indicates that the

flow scanning acts as a backup to temperature scanning and initiates

no automatic protcetive actions, only an alarm.

The inspector asked to review documentation of the testing of the

subheader isoletion function in the " redistribute" mode (PCRV

depressurized) ~of operation. No such surveillance test data were

found.

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The aoparent dist:repancy between the updated FSAR and the Technical

Specification basis was brought to the attentien of the licensee for

review. The licensee' indicated that this item would be included in

the review and evaluation of System 46. This is an inspector

followup item (267/8908-03) and will be reviewed upon completion of

the licensee's evaluation.

The inspector had no further questions regarding this item.

2.1.3.2.3 System Pressure Monitoring

The inspector reviewed the System 46 pressure indication and control

system to assure that it was in accordance with the license

requirements, including the system isolation function resulting from

high wstem pressure caused by a cooling water tube rupture.

Document reviews and discussions with licensee representatives

indicated that the test of the system's automatic isolation on high

pressure had been performed; however, documentation of the completed l

test and test data could not be located. The licensee indicated that

this matter would be pursued. The NRC inspector reviewed the

approved procedure, SR-RE-57-X, "46 and 47 Systems Automatic

Isolation Functional Test " (Issue 2), (including changes to

PDR 87-1785, June 10, 1987; PDR 88-1163 December 8, 1988; PDR

89-0030, January 12, 1989; and PDR 89-0034, January 19,1989),which

was provided by the licensee. The procedure addressed the

calibration and functional tests of. the 46 and 47 systems.

Procedure Change PDR 89-0029 required that "during power operation

both 46 system loops must be operable." The system isolation at high

pressure condition was at 161 to 163 psig increasing (PDR-1785), for

Loop 1 Pressure Switch 46225 and Loop 2 Pressure Switch 46226. The

procedure required the isolation function to be verified by reading

the subheader flow rates (normal flow subheader isolation valve open,

zero flow-subheader isolation valve closed). The NRC inspector noted

that the procedure did not require verification of valve closing and

opening (valve travel and series isolation valves). This concern was

brought to the attention of the licensee for consideration. The NRC

inspector reviewed the I&C calibration data sheets dated July 1,

1987, associated with the System 46 pressure switches (PSH-46225,

Loop 1, set at 162 psig increasing and PSH-467226, Loop 2, set at 162

psigincreasing).

The System 46 isolation on high pressure was discussed in the updated

FSAR, Section 9.7.3.5, which indicated that a subheader isolation was

provided for a tube rupture (PCRV to System 46). Document review and

interviews with licensee representatives revealed that the function

appeared to be available; however, testing of the function, inclusive

of the ' loops, subheader isolation valves, subheader flow and flow

alarms, was not performed and appeared to be warranted.

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, 2.1.3.2.4 System Surge Tank Level Monitoring

The inspector reviewed the System 46 surge tank level itidication and

control systems. The document review and interviews revealed that

the level transmitters, LT 4605 (Loop 1) and LT 4606"(Loop 2), were

calibrated.in June 1987; however, the total level system function

(low level and high level alarms PCRV loop subheader 1501 tion, and

cooling water pump trips on surge tank low level) apparently had not

been tested. The isolation of the subeaders in the affected loop

when the level in the surge tank dropped by 300 gallons is discussed

in the Updated FSAR, Section 9.7.3. The surge tank level isolation

was described as a backup to the flow scanner system and is active in

the redistribution mode of operation. The TS do not specifically

address the surge tank level indication.and control system.

The concerns regarding the testing of the surge tank level

indication, alarm, and control system was brought to the attention of

tne licensee for consideration.

The inspector had no further questions in this area.

2.1.3.2.5 Data Acquisition System (ACUREX)

The inspector reviewed the ACUREX system to ensure that the system

provided adequate monitoring of the system and included the functions

described in the Updated FSAR, Section 9.7.3. The inspector reviewed

selected items associated with the ACUREX system. The following

findings were identified:

Document review and interviews revealed that the electrical

power for the ACUREX was supplied from either emergency diesel

generator through a voltage sensing automatic transfer switch or

from the ACM via a manual transfer switch;

Scanner (ACUREX) failure alarms were provided and annunciated in

the control room;

The ACUREX provided temperature monitoring for each cooling

water loop exit, subheader exits, and PCRV concrete lincr;

Temperature / alarms-cooling water tube exit to the calculated

subheeder average (temperature /(25*F alarm) and tube high

temperature alarm (119*F);

The ACUREX provided subheader flow monitoring (36 total,18 for

Loop 1 and 18 for Loop 2), low flow alarms, and high flow

alarms;

Manually operated checks (soitware) of the system functions;

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Two remote monitors in the control room, located behind the

control board; and

System 46 parameter input to the plant monitoring / annunciator

systems.

Document review interviews and field inspections revealed that the

ACUREX system was adequately maintained and was providing the system

monitoring locally and to the control room. The inspector noted that

the alarming conditions on the local and remote monitors were visual

only as indicated by an asterisk on the monitors. Interviews

revealed that the local audible alarm was disconnected to eliminate a

nuisance alarm. The alarms in the control room had been annunciated,

as appro-priate. The inspector had no further questions regarding

this item. Discussions with the system engineer revealed that when

individus1 cooling water tube exit temperatures increased above

normal (indicating)a

cooling water decrease

tube , the in the

tubes were flow through

flushed the individual

(flow increased above

normal) for a short period of time to improve the flow rate and heat

transfer capability. The system engineer identified a weekly

surveillance pm formed on the system to monitor overall operating

conditions. The surveillance procedure, SR-0P/RE-26-B&M, " System 46

System Flow and Temperature Scan Evaluation," (Issue 15) which was

reviewed with the system engineer. The surveillance required the

evaluation of the following data and conditions:

Tube exit temperatures (data sheet 1-36)

Several warm tubes (greater than or equal to 25'F temperature

rise);

Individual hot liner cooling tubes (data sheet 40)

Six known hot tubes were identified;

Subheader flows and flow changes (data sheet 38)

Several changes noted; j

Flow adjustments needed (data sheet 39-1 through 39-8)

Several flows needed adjustment to reduce the cooling water

exit temperatures to normal (14-20"F);

Temperature Channels greater than 18"F above the subheader inlet ,

temperature (data sheets 37-1 through 37-8); j

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Cooling water tube flushing;

Unexplained temperature rises; and

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General comments.

The inspector and the system engineer reviewed and compared selected

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stemparameters)recordeddurin <

surveillance data (sy(June 24), and mid-1989'(May

(March 4),mid-1988 17)gsimilar

during early 1988'

reactor conditions. 'The review was performed to note any adverse

trends associated with the PCRV cooling water performance over a long

period of time. The inspector noted that the system engineer had not '

perforned this type of trend review in the past. The inspectors were

concerned that the licensee had not compared recent operating

conditions to similar past conditions to detect any; degradation of

the system performance or PCRV insulation performance, resulting in

elevated concrete temperatures. It was noted by the inspector that,

no gross difference in the data existed. However, the inspector

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noted thatzthe plant staff could have provided much more attention to

the System 46 operating. conditions to ensure: (1)thesystemwas

operating within the system design requirements; (2) the prompt

identification of changes in. system parameters; and (3) the

identification'and correction of long term changes in system

, parameters. The review, evaluation, and comparison of System 46 data

and the need to provide more attention to System 46 appeared to be

,

, warranted by the licensee.

Discussions and records review revealed that the reason for operating

the system at the existing flow rates and temperatures was based on

attempting to maintain the system temperature rise across the

individual cooling water ~ tubes to less than 20*F. Certain cooling.

water tube flow velocities were at the maximum under the system '

conditions (valves full open); however, the maximum allowable flow

velocities.for the cooling water tubes had not been established or

checked by the licensee. The potential for erosion / corrosion e' Ge

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individual tubes because of high flow rate was presented to the 4

j ' licensee for review and evaluation.

During1 the inspection, the licensee performed a flow check on

selected cooling water tubes and the maximum flow rate was about

7 ft./sec. The licensee stated that degradation of System 46 would

occur at flow velocities greater than 10 ft./sec.

-The inspector noted that the 7 ft./sec, flow rate was less than the

flow rate. assumed in USAR (8.3 ft./sec.) regarding tube location and

water entering the PCRV due to a cooling water tube rupture.

The licensee stated that an evaluation of the routine operation of

System 46 would include the system subheader normal flow rates and

the subheader flow alarms. Setpoints (low and high) based on the

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detection of flow changes in excess of 10 gpm.

Discussions and document reviews indicated that one cooling water

tube to the lower core support floor was isolated. The NRC inspector

requested the safety evaluation (s) associated with the isolated

tube (s). At the conclusion of the inspection, the safety evaluations

had not been provided. This is considered an inspector followup item

(267/8908-04) pending NRC review of the safety evaluation.

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2.2 ' Repair of Leak'in Main Steam System

A

On May 19, 1989, a through wall' crack was discovered on the weld at-a '

1-inch weld-o-let to the 11-inch hot reheat steam piping from Steam

Generator B-2-1.- The licensee evaluated the leak and decided to have it

repaired by installing a special. clamp-on assembly over the piping and the

leak followed by the injection'of a sealant material into the cavity.

'between the pipe and the assembly.

The inspector. reviewed the documents.relat'ed to the repair effort,

including thel 10 CFR 50.59 safety evaluation, the seismic analysis of the

repaired piping configuration, the justification for continued operation

of the plant, the work instructions, and the. approved temporary

.

configuration report.. The only question that the inspector had, was in

regard to the third step of the work instructions. This step required

that after the? clamp-on' assembly was installed, a soap bubble test was to

be performed'on the. assembly to check for leaks. 'The inspector asked

licensee representatives if they really wanted to spray a soap-water

+

solution on the high temperature steam piping. 'The licensee

representatives promptly removea this step from the. instructions.

The inspector ob' served the. preparations for, and the initial' efforts to

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install the clamp-on assembly. Appropriate precautions had been taken and

the evolution was being monitored and supervised by senior management.

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

area.

3. Maintenance Program

During the course of reviewing the maintenance activities documented in

the previous paragraphs, the inspectors made a number of observations

regarding the licensee's overall maintenance process. These findings are

documented below.

The inspectors found that test procedures were generally good, but as

noted'above, the work instructions for corrective maintenance were weak at

best and relied heavily on the skills and knowledge of the craftsmen.

At the time of the inspection, the total backlog of corrective and

predictive maintenance items (SSRs) was about 1250. About 20 percent of

this total was classified as Priority 1 (the highest priority). The

licensee had been completing about 500 SSRs each month. Therefore, the

licensee's total backlog represented about 2.5 months of effort. The

inspector found that the fraction of overdue SSRs that were awaiting parts  ;

was quite smell. It appeared that the major bottleneck was engineering. 1

System engineers were heavily loaded with preparation efforts for the

upcoming defueling at.tivities which left insufficient time to be devoted

,

to reducing the maintenance backlog.

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The involvement of-the quality assurance organization (QA/0C) was evident,

but this was not reviewed in detail.

The licensee's operating experience program appeared to be functioning 1

satisfactorily. Licensee representatives were aware of issues and j

experiences that other plants had reported, but the NRC inspectors found i

that in cases such as check valve failures and pipe wall thinning, the

licensee had taken no action to determine the applicability of the issue

to Fort St. Vrain. The licensee needs to have a stronger followup effort

to assure that the information communicated by this syster,is cpplied to

Fort St. Vrain systems, components, and practices.

The inspector encountered great difficulty in obtaining information from l

the document control center for material cross-referenced in component '

specification sheets. Specifically, the inspector attempted to locate and

review the vendor manuals applicable to the actuators and the pressure

reducers for the air operated valves in System 46. The inspector had to

review the document control center's list of various manuals to determine

the appropriate manuals. One' manual was not located. This indicated that

either system engiacers and others were not reviewing the vendor manuals

when they plan maintenance activities, or they were finding the manuals by

the same search technique used by the inspector, but were not providing

the feedback'to have the system fixed.

This system was in need of management attention to facilitate cross-

referencing of specific components with all of the subcomponents related

to them. The current practices were very wasteful of valuable resources.

4. Exit Interview

The inspectors met with Mr. C. Fuller and other licensee representatives

denoted in paragraph 1 on May 26, 1989, and summarized the scope and

findings of this inspection. The licensee did not identify as proprietary

any of the information provided to, or reviewed by, the inspectors.

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