ML20245J579

Insp Rept 50-267/89-17 on 890717-21.Violations Noted.Major Areas Inspected:Licensee Programs for Instrument Calibr & Functional Testing of Diesel Fuel Oil Quality & Storage & Actions on Previously Identified Insp Findings

ML20245J579
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/10/1989
From:	Boardman J, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20245J570	List: ML20245J565 ML20245J572 ML20245J579
References
50-267-89-17, IEIN-87-004, IEIN-87-4, NUDOCS 8908180075
Download: ML20245J579 (10)

See also: IR 05000267/1989017

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-APPENDIX B

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Mi' .U.S. NUCLEAR REGULATORY. COMMISSION'

1 , REGION IV

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NRC Inspection Report:, . 50-267/89_-17 Operating License: DPR-34

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. Docket:- '50-267

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Licensee: ;Public Service Company of Colorado (PSC)

P.O. Box 840 -

Denver, Colorado' 80201-0840

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

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LInspection'At: FSV Nuclear Generating Station, Platteville, Colorado

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Inspection Conducted: July 17-21, 1989-  ;

f fins'pector:' a

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- 7. p/. ; Boardman, Reactor ' Inspector, Plant

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Sfstems'Section.Divisionof;ReactorSafety

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> - 1 Approved: _ 6//d/e9

T. F.~5tetka, Chief, Plant Systems Section Date;

Division of Reactor Safety.

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Inspection' Summary

iInspection Conducted Jdly 17-21, 1989 (Report 50-267/89-17)

Areas Inspected: Routine, unannounced inspection of the licensee's programs

x ~ for instrument calibration and functional testing, for diesel fuel oil (FO)

. quality and storage, and~ action on previously identified inspection findings.

, iResbitsi' Within the areas inspected' , one apparent violation of NRC requirements- *

was identified (paragraph 3).. The apparent violation involved three examples

where procedures did not exist for the calibration or functional testing of

instrumentation and controls needed to verify equipment operability or needed

for operation of equipment as_specified in the licensee's procedures. Except

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for this. violation, the licensee's calibration program ~ appeared to meet

regulatory requirements.

, " The licens.ee's program for assuring FO quality appeared to be acceptable, but

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weak because of the limited scope.of F0 sampling performed. The difference in

-design requirements for this plant, and the high F0 usage which prevented

,g significant F0 aging, kept the F0 program from appearing flawed.

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DETAILS

1. Persons Contacted

PSC

• M. Denniston, Superintendent of Operations

D. Evans, Operations Manager

• C, Fuller, Manager, Nuclear Production

• F. Novachek, Nuclear Support Manager

• P. Tomlinson, Manager Quality' Assurance

• N. Snyder, Maintenance Department Manager

• L. Scott, Quality Assurance Services Manager-

• M. Ferris.. Quality Assurance Operations Manager

• F. Borst, Nuclear Training Manager

.*D. Weber, Staff Assistant

• J. Gramling, Supervisor, . Nuclear Licensing-Operations

• D. Such, Instrumentation and Controls Supervisor

• T. McIntire, Superintendent, Materials Management

H. O'Hagan,: Outage Manager

.M. Block. Systems Engineering Manager-

D. Brown, Nuclear Engineering Supervisor:

P. Burk, Supervisor, Quality Assurance Engineering

D.-Fetterolf, Water Chemistry

J. Brungardt, Water Chemistry

NRC

• T. Stetka, Chief, Plant Systems Section

• R. Farrell, Senior Resident Inspector

• Denotes those persons attending the exit meeting on July 21, 1989.

The inspector also contacted.Other licensee personnel during the

inspection.

2. Followup of Previous Inspection Findinos (93701)

(Closed) Open Item (267/8821-01): This item dealt with a concern about

circuit breaker coordination for the Alternate Cooling Method (ACM)

emergency lighting. The licensee reissued Change Notice (CN) CN-2867 to

resolve this concern.

(Closed) Open Item (267/8826-02): This item concerned the lack of

procedures providing guidance to operators on load shedding and

-sequencing of 480 volt electrical busses. The licensee revised

emergency operating Procedure E0P-6, Issue 2, on June 30, 1989, to provide

a permanent solution to this concern. This item is considered closed

based on a review of E0P-6.

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3. Calibration (56700)~

The purpose of this inspection was to ascertain that the licensee had

developed, and implemented an instrumentation calibration program in

conformance with regulatory requirements, commitments, and industry

standards,

a. The inspector reviewed the frequency of calibrations and functional tests

required by Technical Specifications (TS) for selected components

that are part of the following systems:

Reactor Protection

Reactivity Control

Plant Auxiliary

Liner Cooling

Containment

Electrical Distribution

Selected completed calibration and functional testing (surveillance)

procedures were reviewed. In addition, the inspector observed the

perfortnance of the setpoint calibration for the main steam electromatic

relief valve. The inspector did not note any apparent backlog of

safety-related surve111arces including calibrations. The accuracy of

the calibrations reviewed appeared adequate. The reviewed procedures are i

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listed in Attachment 2. i

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During the review of the completed surveillance procedure for the monthly i

linear power channel scram test, the inspector noted numerous steps

marked as "Not Applicable" (N/A). These steps were for testing the

fixed low-power trip and alarm setpoints for the Startup Channel and

Linear Power Channel. Discussions with licensee representatives

indicated that system design prevented testing these trips at power

levels above their low-power setpoints. Since the channels could not

be tested with the plant at high power levels, these steps were

marked "N/A" during plant operation at these levels. k' hen plant .

power level was decreased to the point where the fixed low-power

trips were required, and the functional test was not scheduled to be

performed, the trips would not be tested for periods of up to one

month beyond the required surveillance due date. This occurred )

because'the licensee failed to have a procedure that required the i

fixed low-power trips to be tested immediately after the plant  !

power level was decreased below the trip setpoint levels. Therefore, '

there were instances where the plant operated with untested fixed

low-power level trips for up to one month.

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T Failure to have adequate procedures to perform functional tests as  %

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.tequired by TS 7.4.a 1s considered to be an apparent. violation.

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Violation-(267/8917-01):. Failure to have adequate: procedures to test

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the ' fixed low-power level! trip setpoints. '

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b' x 'b. The inspector. reviewed the calibration and functional' testing of

components. not .specifically addressed in the TS as' requiring calibration or-

functional . testing. . During plant walk-downs, the inspector, selected . ,

- instruments 'and controls and verified their inclusion in the calibration

,. . program. ' As.the result of these walk-downs, the inspector identified:

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the.followingLinstrumentsandcontrolswhich"requiredeithercalibration(

• " ,or a functional test, but were not. included in the licensee's' . -

q calibration program:

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(calibration of the diesel fire' pump (DFP): associated instruments &

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4 land controls.. The overspeed trip on the DFP is one of these -

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- associated' controls. TS 7.4.a requires procedures for'the'.

surveillance and test activities'of safety-related equipment.

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'The_overspeed trip was not in the licensee's"calibraticC and

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' functional; test programs and therefore was not calibrated norf

functionally, tested.

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Each' EDG' engine has a coolant water-temperature gauge. These- A

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gauges <are specified in the~ licensee's operating and surveillance

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procedures for the EDG to determine engine operating temperature.

The inspector verified with a licensee. EDG operator that these

c gauges were.the only gauges;used to determine engine temperature._ '

These gauges were not in the licensee's calibration program.-

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Failure to.have procedures to test and calibrate the DFP overspeed trip

'and failure to calibrate the EDG engine temeprature gauges is considered

to be an apparent-violation of TS 7.4.a. This apparent violation will be

a considered as' additional example of the apparent violation identified in

previous paragraph 3.a.

4. Storage and Handling of Fuel 011' for Safety-Related Diesels (25100) 4

The purpose of this inspection was to verify that the licensee had an-

E ' adequate quality. control program for emergency diesel generator (EDG) fuel

oil (FO) maintained on site. Because of the plant's unique design, this

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site has two additional safety-related diesel powered components. These-

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are a: diesel fire pump and a diesel Alternate Cooling Method (ACM)' generator.

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The F0 for these components was included in the scope of this inspection.

The specific attributes reviewed included the following for which the

. responses. are' contained in Attachment 1:

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The scope of the license's review of NRC Information Notice'(IN) 87-04, 1

" Diesel Generator Fails Test Because of Degraded Fuel;  !

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The existence of a permanent EDG F0 storage tank recirculating ,

filtration system;

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The periodic cleaning of EDG F0 tanks;

" * ~The use of F0 antioxidation and bacteriostatic additives;

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The tests performed for such contamination as presence of water,

.  :. oxidation products, and bacterial growth;

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The prompt removal of identified water contamination;

The periodic cleaning of strainers and filters;

The monitoring of fouling and contamination;

The sampling and testing of EDG F0;

The use of duplex.. filters and strainers;~and

.The use of differential pressure indication for determination of

filter and strainer fouling.

Based on'the responses to Attachment 1, the licensee's program is

considered'to be weak, because of the limited scope of F0 sampling

performed. The program is in compliance with NRC regulations and

commitments.

No violations or deviations were identified.

5. Diesel Generator Fuel Oil Quality Assurance (25593)

Because of the planned decommissioning of FSV, the requirements for this

inspection are encompassed by the inspection discussed in paragraph 4 of

this report. Inspection activity in this one area is considered to be

complete.

6. Exit Meeting (30703)

An exit meeting was held on July 21, 1989, with those individuals denoted

in paragraph 1 of this report. At this meeting, the scope of the

inspection and the findings were suunarized. The licensee did not

identify as proprietary any of the information provided to, or reviewed

by, the inspector.

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, . ATTACHMENT 1 )

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SURVEY OF LICENSEE'S RESULTS TO

SELECTED EMERGENCY DIESEL GENERATOR (EDG) FUEL OIL (F0) ISSUES

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Plant Name: Fort St. Vrain (FSV) q

Docket Number: 50-267

Inspector: J. R. Boardman f

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1.' Has the licensee adequately reviewed and evaluated NRC Information Notice

(IN) 87-04, issued on January 16, 1987, as a result of the ANO Unit 2 EDG

F0 starvation event which occurred on June 27, 1986?

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The licensee had reviewed this IN. See Item 3 for the licensee's response

to the IN.

2.- Does the licensee have a permanent F0 storage tank recirculation system

which allows for complete F0 inventory cleaning by filtering each refueling

outage to remove accumulated particulate?

Discussions with licensee personnel indicated that for.the EDG such

recirculation could be accomplished. FSV is different from other sites.

'There are three sets of safety-related diesels. In addition to the EDGs,

there is an Alternate Cooling Method (ACM) diesel generator and a diesel

fire. pump (DFP). All safety-related diesels are covered in the TS.

Additionally, F0 usage is relatively high at FSV. Licensee personnel

indicated that F0 usage from the day tanks of all safety-related diesels

is greater than 100% per month. The DFP has only a day tank. The storage i

tanks for the EDGs and ACM diesel have an average usage of 100% per month. l

This.is because the diesel fuel tanks also supply the station auxiliary

boiler. As a result,.F0 aging with its attendant problems of fuel degradation

does not appear to be a concern at FSV.

3. Are all F0 storage tanks being cleaned and inspected at a minimum of

10-year intervals in accordance with Regulatory Guide 1.1377

Licensee personnel-indicated that tanks were cleaned in response to  ;

IN 87-04. Future cleaning is not projected based on the present plant j

decommissioning schedule.

4. Does the licensee's F0 program include a regular analysis of F0 samples  !

and bottom testing for accumulated water, at the lowest point in the F0

day tanks and F0 storage tanks?

TS 5.2.10 requires that the DFP F0 be sampled and tested quarterly. No

ASTM standard is referenced. No attributes are specified in the TS. The

DFP F0 is tested for viscosity at 40'F, for water content, and for sediment.

Neither the EDG or the ACM diesels have any requirement for testing. With

the rapid turnover in stored fuel, periodic sampling and testing is less

meaningful than at sites having large storage capacities and low usage.

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5. Is a' fuel additive being used as a fuel stabilizer which will function to

! prevent oxidation 'and bacterial growth?

No.

, 6. Does the licensee effectively ensure that periodic F0 bottom sampling and

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analysis are being performed to detect high particulate concentrations in

i. the F0 supply which occurs over long-term storage due to the effects of

l oxidation, and biological contamination in accordance with ASTM D270-1975?

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As stated in 2 and 4 above, there is no long-term storage of fuel on

site, and no ASTM standard is required by TS, or identified.in site

l' procedures.

7. Are day tanks and integral tanks being checked for water monthly, as a

minimum, and after each operation of the diesel where the period of *

operation was 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or longer?

There is no TS or procedural requirement for this. See the responses to 2

and 4.

8. Is accumulated water removed immediately if it is determined that water is-

present in the storage,-integral, or day tanks?

'The lic'nsee's

e personnel stated'that if water is found, it is promptly

removed from the tanks.

Is the licensee replacing F0 in a short period of time (about a week) if

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it is determined that the F0 does not meet the applicable specifications?

The licensee's personnel stated that F0 determined to be nonconforming

would be replaced immediately. The only F0 tests perfomed are for

viscosity at 40 F, water content, and sediment. These are the only

identified bases for F0 replacement.

10. Are F0 components which may be prone to fouling being routinely monitored

for indications of fouling?

Yes, through the preventive maintenance program.

11. Are F0 filters and strainers being cleaned and inspected on a periodic

basis per the vendor recommendations?

Per licensee personnel, filters and strainers are clear.ed and inspected to

periodicities which meet vendor recommendations as part of the preventive

maintenance program.

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12. -Does the F0' system utilize dual element filters and strainers which l

l  : permits on line cleaning of the elements, in the event of fouling, to

allow continuous operation of the EDG7

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.The EDG F0 transfer system filters and the ACM diesel F0 filters are.

duplex ~.. The EDG and DFP filters are simplex. j

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13. Isithere a differential pressure indicator'for each duplex filter strainer '

L r ' for indication 'of fouling in accordance with ANSI 195-19767

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There is a flow indicator for the EDG FO. There is no other indication.

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.14. lAre'F0 alarms annunciated in the main control room orl incorporated into'a

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. general' control' room trouble alarm with local individual alarms, in

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accordance with ANSI N195-1976?

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The EDG F0. day tank alarms locally and in the control- room.

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The'ACM F0 alarms locally.

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The DFP has no F0 alarms.

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115. : Are any, of the instruments that perform a control function and provide an

alarm seismically qualified in accordance with the IEEE Recommended-'

Practices for Seismic Qualification of Class IE Equipment for Nuclear.

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Power Generating Stations, IEEE-344-1975?

The licensee's~ personnel indicated the EDG'and.ACM are seismic.and that

-the DFP is not required to be'.

Note:- The ASTM, ANSI, and.IEEE standards' referenced in this survey

did"not appear to be applicable lto FSV.

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ATTACHMENT 2

LICENSEE PROCEDURES REVIEWED DURING THE INSPECTION

DESIGNATOR TITLE ISSUE DATE

SR 5.3.3-AIX Main Steam Electromatic 3 June 2, 1989 )

Relief Valve Functional

Test and Setpoint ' Calibration

.SR 5.6.lb-SA4 Standby Generator IB 1 July 15, 1988-

Auto Start Test

SR 5.4.1.1.4.b-M/ Linear Power Channel 47 February 12, 1988

SR 5.4.1.4.2.b-M- Scram Test and 48 July 21, 1989

SR 5.4.1.1.4.d-R/ Linear Power Channel 22 August 9, 1985

SR 5.4.1.4.2.d-R Calibration

OPOP.I General _ Plant Requirements 66 January 6, 1988

RP-A-01 General' Maintenance 4 February 3, 1989

Requirements Governing

Procedures For The

Calibration and Maintenance

of Plant Instrumentation

RP-A-02 NBD Instrument and Maintenance 3 November 25, 1987

Program

RP-A-03 Calibration Data Base 7 November 28, 1988

MAP-2 Maintenance Department 4 April 26, 1989

Program for Measuring and

Test Equipment

SR 5.2.10.a.1-M/ Fire Pump and Instrumentation 12 July 1, 1988

SR 5.2.10.a.2-M Functional Test

SR 5.2.10.a.1-A Fire Pump Instrumentation 14 April 15, 1988

Calibration

SMAP-1 Technical Specifications 7 February 1, 1988

Surveillance Testing Program

SMAP-2 Non-Technical Specification 4 February 1, 1988

Surveillance Testing Program

MP-7090 Standby Diesel Generator 3 May 17, 1989

SMAP-5 Scheduling Program for 6 October 12, 1988

Surveillance

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June 17,L1988

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50P 92-04 Emergency Diesel Generators 19 ,

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SR.5.6.la-W Standby Diesel Generator 46' June.23, 1989

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Test [ weekly]'

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<Y SR 5.6.lb-SA3 .StandbfGenerator1A 'l July 15, 1988 :r -

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c  ;-Auto' Start Test (Semiannual)

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"" . ; SR.5.6. led-A10 Standby Diesel Generator 1 May 12, 1989 >

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Calibration: Set.1A ,

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Alternate. Cooling Method System .17 September 21.-1988

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MP-7110 ACM Diese1' Preventative 1 July 14, 1987

. Maintenance

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t * ;, . ~ JSR-RE-80-X. .ACM Instruments Calibration 5 June 2, 1989

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L- SR 5.2.20ab-W ACM Generator Load Test 8 Sept' ember 30, 1988

+.. SR-RE-146-R Calibration of. Circulator 3 August-24, 1988

Differential Pressure

Instrumentation .n

SR 5.4.1.1.5.c-M/ Wide Range Heat Balance .25 May 6, 1988

SR 5.4.1.4.3.c-M Calibration:

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RP.-164 , Calibration and Maintenance of 4 June 19 1986~

Foxboro E11GM/E11GH Pressure

Transmitters ,

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fF SR-RE-161-A- Steam Pipe Rupture Temperature

Calibration

2 May 6, 1988

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E0P-6 Restoration of Essential 2 June 30, 1989

Electric Power

SR 5.6.le-1.5Y loss of Outside Power with 1 March 9,-1988

the, Main Turbine Generator

Tripped

WCP-314 Chemistry Specifications 4 November 11.,1987.

Oil Systems

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