IR 05000267/1989005

Insp Rept 50-267/89-05 on 890306-10 & 13-17.No Violations Noted.Major Areas Inspected:Previously Identified Insp Items,Surveillance Procedures & Records,Allegation Followup & Preparations for Refueling

ML20245A496
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/12/1989
From:	Ray Azua, Ireland R, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20245A488	List: IR 05000267/1989005 ML20245A486
References
50-267-89-05, 50-267-89-5, NUDOCS 8904250237
Download: ML20245A496 (12)

Text

- - _ _ _ - - _ _ - _ _ - - - . - - - _ . - _ - _ _ _ _ _ _ _

, Y

'

x

..< 4 APPENDIX U.S..NUCLENRREGULATORYCOMMISSION

REGION IV

'NRC Inspection Report: 50-267/89-05 Operating License: DPR-34

'

' Docket:. 50-267-Licensee: 'Public Service Company of Colorado 2420 W. 26th Avenue, Suite 15C Denver, Colorado 80211

' Facility Name: Fort St'. Vrain Nuclear Generating Station Inspection At: Fort-St. Vrain Site Platteville, Colorado Inspection Conducted: March 10, 198 ite and March 13-17, 1989, in-office Inspectors: - 24-r 5 C-1 - t/[/ 8F

. E. Ar' eland . Technical Assistant Date Division of Reactor Safety EM .

R.mrua+.leactordfrpector, Test Programs .

, r-Date /

Y //df -

Section, Division of Reactor Safety Approved - /. - - V//t/Vf W. C. Seidlgp Chief, Test Programs Section Date Division of Reactor Safety Inspection Summary Inspection Conducted March 6-10. 1989, Onsite and March 13-17, 1989, In-Office (Report 50-267/89-05)

Areas Inspected: Routine, unannounced inspection of previously identified inspection items, surveillance procedures and records, allegation followup, and preparations for defueling, i

,

8904250237 890417  ?

PDR ADOCK 05000267-j' G PNU.-

l-

,

_h______.____.-_ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ ___ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _

_ _ _ _ _ _ _ _ - _ _ _ _ _ _ . _

,

.

.

-

-2-

Results: In general, the licensee's approach to the resolution of the technical issues reviewed was sound and thorough. The surveillance procedures and records were found to be complete and adequate. The NRC inspector noted that the planning and scheduling program for surveillance testing required by the. licensee's Technical Specifications was more than adequate. The effort put forth by the personnel in this area was found to be noteworthy. A number of open items were closed. The licensee is taking steps to improve the ;

reliability of the fuel handling cask and associated equipment in preparation for defueling the reacto i

)

.

1

l

1

i

.

!

-

,

l

!

.

_ _ - _ - -

.

, -

l

-3-DETAILS Persons Contacted l

PSC

• E. Deniston, Superintendent of Operations

• P. F. Tomlinson, Manager, Quality Assurance (QA)

• C. Fuller, Manager, Nuclear Production

• M. E. Niehoff, Manager, Nuclear Design

• M. H. Holmes, Manager, Nuclear Licensing

• G. D. Schmalz, Manager, Fire Protection ,

• N. Snyder, Manager, Maintenance Department

• M. J. Ferris, Manager, QA Operations

• L. D. Scott, Manager, QA Services

• F. Novachek, Manager, Nuclear Support

• M. Cappello, Manager, Central Planning and Scheduling

• D. Warembourg, Manager, Nuclear Engineering

• H. O'Hagan, Outage Manager

• K. Owens. Supervisor, Planning and Scheduling

• B. Rutt, Scheduling Technician, Planning and Scheduling

• P. Anderson, Nuclear Regulatory Affairs

• W..D. Rodgers, Nuclear Computer Services

• J. P. Hak, Nuclear Production  !

• G. Redmond, System Engineering S. Chesnut, Licensing, Nuclear Engineering Department (NED)

Onsite, Maintenance R. Craun, Licensing, NED Onsite, Maintenance L. Bishard, Licensing, NED Onsite, Maintenance NRC

• R. E. Farrell, Senior Resident Inspector P. W. Michaud, Resident Inspector

• Denotes those individuals attending the exit interview conducted on March 10, 198 . Followup on Previously Identified Inspection Findings (92701)

2.1 Violations 2. (Closed) Violation (267/88200-10): Failure to Perform Technical Specification Inservice Testing - The violation resulted when several valves were exempted from the formal surveillance test procedures because the performance and operability of these valves were demonstrated through either plant operations or by the performance of testing on other aspects of their associated system The NRC inspector reviewed the licensee's response to the violation and verified the corrective steps taken to preclude recurrenc _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _ -_ ___- __- _ __ _-_____ _ _ _ -

__- - - _ _

- - - . _ _ _ _ .

.

.

, c.

[

l

'

-4--

l '

.

~

'*

Valves HV-2153-1, -2153-2, -2154-1, and -2154-2 were tested and l found to be operabl *

PSC has evaluated available test data and determined that the performance and operability of Valve V-22371 has been adequately

-

demonstrated.-

Other surveillance procedures were reviewed to determine if they contained similar inappropriate exemption *

Surveillance Procedures SR 5.2.7s1-A/5.3.4al-A, SR 5.3.4bl-A, and SR 5.3.4b2-A'have been revised to formally test and documen the operability and performan:e of the noted valve In addition, the NRC inspector reviewed a. random selection'of procedures, which had been performed following the implementation of the corrective actions listed above. No exemptions, errors, or omissions were detecte This violation is considered close . (Closed) Violation (267/88200-08; 267/88200-12; 267/88200-13):

Inadeouate Procedure for Presetting a Valve Position, Controlling Stop 76?li~and Controlling Nonconformances - The violation was due to inadequate procedures.-

The NRC inspector reviewed the licensee's response to the violation and verified the corrective steps taken to preclude recurrenc *

Management attention hai been directed to the issues of procedure adequacy and procedural compliance. These areas were addressed during a recent maintenance self assessment (MSA)

performed under INP0 guidelines. Specific, ongoing actions to address these deficiencies were developed as a result of the MSA. Actions included: ongoing reviews and procedure enhancement; verification and validation efforts for revised procedures; and development of craft ownership of procedure adequac * Procedures MQCIM-1, " Maintenance Quality Control Inspection Manual," Issue 8, and QCIM-7, "0uality Assurance Inspection Manual," Issue 5, have been revised to provide specific guidance and criteria for maintenance quality control (MQC) personnel and quality' assurance /ouality control (QA/QC) inspectors to exercise

"stop work" authorit * Administrative Procedure Q-10. " Inspection," Issue 9, now provides adequate authority to QA personnel to "stop work."

Additionally, Administrative Procedure P-12. " Plant Maintenance," Issue 5, has been revised to provide general guidelines for the stop work proces . . _ _ . _ _ _ _ - __

__ - - _-__ _ _

.

,

, ,

)

~

-5-i Administrative Procedure Q-16. " Corrective Action System," was revised to establish responsibility for data evaluation and corrective actio i

'

"

' Revisions to Administrative Procedure Q-15, " Quality Assurance Operations Procedure," were performed. A new Level II procedure is being developed to provide additional guidance to QA personnel for the evaluation and documentation of NCR cause(s)

and actions taken to preclude recurrenc This item is considered close l 2.1.3 (Closed) Violation (267/88200-01): Inadequate Emergency Operating Procedures'- The violation resulted from failure to adeauately update i or correct procedures following initial walkdowns, maintenance activity, and identification of tool The NRC inspector reviewed the licensee's response to the violation and the corrective actions taken. Review of Procedures SSC-03,

" Recovering From a Noncongested Cable Area Fire Resulting In An Interruption of Forced Circulation," Issue 3, and SSC-04, " Recovery From SLRDIS," Issue 3, confirmed that all of the deficiencies identified in Issue 1 of these procedures had been corrected as of October 21, 1988. The NRC inspector also verified that the missing tag on Drain Valve V-45947 had been replaced. This valve is j identified in SSC-04 as one of those which needs to be manipulated to enable cross-connection of the firewater system with the emergency feedwater heade i To assure maintenance of SSC procedures in a correct and updated )

status, the licensee has assigned direct responsibility for them to {

personnel in the emergency operating procedure rewrite program and )

has established an interface with operations personnel. As ,

deficiencies are identified, they will initiate procedure revision l This item is considered close ;

i 2.1.4 (Closed) Violation (267/88200-06): Failure to Control Special l

'

Processes - This violation occurred because a qualified procedure was not used to retrieve broken drill parts from a thermowell by fusing a welding rod to the part The licensee's response identified the cause of the violation to be failure of maintenance personnel to involve engineering personnel to assure proper review and documentation of the work activit To prevent recurrence, the licensee has discussed this issue in detail with maintenance supervisors, emphasizing the need for  ;

'

documentation of work plans and the need for engineering assistanc All maintenance personnel were given training in work control and work documentation in light of this violation. In addition, " Plan of

r

'

! .

1 , .

-6-l l

l

the Day" meetings, coordinated by the central planning and scheduling organization, now bring key supervisors together to review current l work activities and to assure good communications at all levels of l management regarding support of maintenance activities. Review of I SMAP-29. " Station Service Request Work Planning," Issue 3, confirmed that this procedure was revised to emphasize requirements for documentation when plans are changed during the course of wor This item is considered closed.

l 2. (Closed) Violation (267/88200-09): Failure to Implement Cleanliness l and Material Control Procedures. - During repair of Valve HV-21243, maintenance people left debris from removed lagging for several days while the system was open and failed to tag and protect valve internals, which were left in the vicinit The NRC inspector reviewed the licensee's corrective actions, which included training for all maintenance personnel and revision of Procedure MAP-7, " Parts Identification and Control," to provide clarification for tagging and protection of parts during maintenance activities. This procedural revision was issued as MAP-7, Issue 2 effective January 5, 1989. Review of this procedure confirmed that the revised procedure contained specific instructions on parts identification and protection for various categories of equipmen The licensee determined that the administrative controls contained in Procedure MAP-8 were already sufficient but that workmen had not met its requirements. Accordingly, training was scheduled with regarri to cleanliness, controlling work processes and parts control for all ;

maintenance personnel, including supervisors. Review of the l associated trainiao records confirmed that this training was completed Februar3 13, 198 This item is considered close .2 Unresolved Items 2. (Closed) Unresolved Item (267/88200-04): Licensee Action to Ensure Correctness of the TCR Log and Reduce the Backlog of Old Open TCRs -

A backlog of 48 TCRs was identifie j The NRC inspector reviewed the actions taken by the licensee to l

'

reduce the backlog of temporary configuration reports (TCRs). One such action was the incorporation of a checklist, for the control room TCR book, into the Station Managers' Administrative Procedure SMAP-18, ;

" Processing of Temporary Configuration Reports." The purpose of this !

checklist is to improve the methodology by which the TCR index is l maintained. The new checklist will provide additional assurance that ;

the required update of the TCR index will occur whenever a TCR is initiate i

-_ ._ -_ - _ _ _ - _ -_-___ _ _ _ _-

.

.

-

?

-

-7-L The licensee has incorporated str'icter administrative control on new TCRs. They must receive'an additional review by the station manager and a formal engineering evaluation, including review by the Manager, Nuclear Engineering Division, if they are to remain installed for more than 90 days. Additional approval by the Senior Vice President of Nuclear Operations is required if the TCR is to remain in service for more than 180 day Administrative controls have been established, which ensure that the implementation.of new TCRs are kept to an absolute minimum and that existing TCRs are constantly monitored for necessit This item is considered close .2.2 (Closed)UnresolvedItem(267/88200-02): Investigate Provisions for Control of Checklists for Complex Activities - It was noted that several system operating procedures (50Ps) contained valve lineup changes and activities without associated checklist The licensee stated to the NRC inspector that plant management routinely initiates complete integrated valve lineup walkdowns, with independent verifications, for systems affected by significant maintenance or construction activities. The need for these walkdown is determined by the superintendent of operation Certain critical operations activities are performed in accordance with formal procedures, which do include checklists. Overall plant operating procedures (0 POPS) include checklists for the performance i of critical integrated operations of plant systems. They have been divided into categories including: Plant Startup, Technical l Specifications, and Shutdow l The NRC inspector also noted that checklists have been incorporated into procedures governing prncesses where the operating experience at Fort St. Vrain has warranted tht it be done. One such procedure that was reviewed by the NRC inspector was the Nuclear Production Administrative Procedure NPAP-19, " Radioactive Gaseous Effluent Releases." It was revised to include checklists to document and coordinate complicated activities performed interdepartmentally i during the process of making gas waste releases at Fort St. Vrai The NRC inspector determined that the licensee's actions are  ;

acceptable following a review of other OPOP '

This item is considered close l I

2. (Closed) Unresolved item (267/88200-03): Develop a Lesson Plan on Valve Ooerations for Auxiliary Tender Trainees - A new lesson plan, AT-105.00 " Valve Operation and Valve Position Indicators," was developed by the licensee and put into use for training auxiliary tenders on May 8, 1988. The NRC inspector reviewed this lesson plan and determined that it contains adequate coverage for the types of

____ - _

.

.

.

.

-8-valves used in the plant. It also covers reference material concerning malfunction of valves caused by instances such as binding, locking, and mispositionin '

This item is considered close ,

2.2.4 (Closed)UnresolvedItem(267/88200-07): Correct Weaknesses In the Control of Maintenance Activities - In connection with work on removal of damaged thermocouple, described in paragraph 2.2.3.1 of NRC Inspection Report 50-267/88-200, a number of deficiencies were noted in documentation related to the work in hand. These related to absence of thermowell dimensions, assessment of materials, compatibility of tools, hydrostatic test requirements and procedures, QC requirements, and postmaintenance test requirements. This work also related to Violation 267/88200-06 described in Section 2. abov The weaknesses identified relate to the cause of this violation, in that maintenance personnel failed to involve engineering personnel to assure proper review and documentation of work activities. The corrective action for these weaknesses is also essentially the same as that described for the violation; namely, the training in work control and documentation given to all maintenance personnel, the i institution of " Plan of the Day" meetings and the issuance of SMAP-2, Issue This item is considered close I 2.2.5 (Closed) Unresolved Item (267/88200-11): Improve and Ensure Continuing Effectiveness of Operations Information Assessment ,

'

Group (OIAG) - As the result of a reorganization, in May 1988, the licensee made the nuclear regulatory affairs department responsible for the operating experience program. The OIAG, which had been the responsibility of technical services, was renamed the Operating j Experience Board (OEB). The functions of the OEB were defined in '

Procedures G-24, " Operating Experience Program," and NLR-13

" Operating Experience Program." The OEB membership includes representatives from operations, training, systems engineering, maintenance, and regulatory affairs. The NRC inspector verified that meetings are held weekly and that documentation is distributed to all leve; of management in nuclear operations. The OEB routinely scre m documents from NRC and INP0. Thus, the weaknesses concerning mer23er aip, scope of review, and distribution of results have been cD Y,C A This i mm is considered close , - _ _ - _ - _ - _ - _ - . _ _ _ - - _ _ _ _ __ _ _ - - _ _ _ - _ _ _ _ _ - _ _ _ _ - _ - _ _ _ _ _ _ - _ .

,

'

' . ,

-9 2.3 Deviations 2. (Closed) Deviation (267/8814-02): Failure to Inform NRC of Change In Commitment - In response to Deviation 267/8516-01, concerning a fire door rating in the records center, the licensee stated that a new records storage center would be built. Construction of that center was indefinitely postponed in October 1986, but NRC was not informe By letter dated August 18, 1988, the licensee informed NRC of the -

change, and proposed a resolution of the fire door rating. This proposal was accepted by NRC as confirmed in a letter dated September 20, 198 This item is considered close . (Closed) Deviation (267/8821-02): Upgrading of Fire Barrier Penetration Seals - Two penetration seals in the auxiliary boiler room had not been upgraded to a 3-hour ratin The NRC inspector verified by direct field inspection and thorough review of SSR-88 506378, CN-2616-A, CWP-88-276B, and associated QC records that work on the two penetration seals had been properly completed. One of the seals was repaired by use of RTV silicone foam; the other penetration was removed and replaced by cinder block, since it was not in us This item is considered close . Surveillance Procedures and Records (61700)

The purpose of this inspection was to ascertain whether the surveillance of safety-related systems and components was being conducted in accordance with approved procedures as required by the Technical Specificatio Pursuant to this objective, the NRC inspector reviewed the following licensee documents:

• Administrative Procedure SMAP-1, Revision 7. " Technical Specifications Surveillance Testing Program" Surveillance Test Scheduling and Tracking System Schedule Log,

" Report No. 7728: Surveillance Past Scheduled Date and Approaching Late Date" (Printed on March 9, 1989)

The NRC inspector then selected certain Technical Specification surveillance requirements and reviewed the associated licensee surveillance test procedures and an appropriate number of test result records for each procedure. Also, selected test personnel were verified to have appropriate certification.

L

_ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -_-_ _ --____ _ __ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ . - _ -

'

.

. .

'

,

- 10 -

The NRC inspector determined that the required tests were being scheduled and performed as required in accordance with approved procedures. Acceptance criteria were specified in the procedures and the records showed satisfaction of acceptance criteria. Appropriate instructions for returning equipment to service following testing, were given. There was evidence that surveillance j tests were being properly evaluated and documente The NRC inspector noted that the " Technical Specifications Surveillance Testing Program" was quite thorough and that the efforts put forth by the personnel in the scheduling and planning department toward the success of this program was found to be noteworth No violations or deviations were identified in the review of this program are . Preparations for Defueling The licensee has initiated planning for permanent shutdown and defueling of the Fort St. Vrain reactor. Once defueling commences, it is expected that about 21/2 years will elapse before the last fuel element is removed from the reactor vessel. Because of the very large number of fuel movements that will be involved, the licensee intends to do whatever is necesscry to assure that the fuel handling equipment is in good condition and will operate reliably. The basic handling equipment consists of a fuel handling machine (FHM), un auxiliary cask, associated valves, and the reactor building cran The FHM will be subjected to a major upgrade of its control system. In addition, certain mechanical components will be refurbished, replaced, or improved to reduce problems that have occasionally occurred in the pas The control system for the FHM was designed and built in the 1960's. It consists of a hybrid computer system, which is obsolete and can no longer be serviced or modified easily. This system automatically orients and controls a grappling mechanism and hoist, which removes elements from the reactor one at a time for temporary storage inside the machine, and movement of elements, after FHM relocation, to another designated location. This control system will be replaced by a modern computer control system that will be reliable, can be maintained, and can be programmed for unique operations. Specification No. 13-N-08, dated February 1989, has been prepared to define t.he requirements for the new control system. If current schedules are met, the FHM will be ready in January 1990. Comparatively speaking, changes to the auxiliary cask and the floor valves will be mino Since all of the components used in fuel movement are routinely located through use of the reactor building crane, the crane must be in good operating condition for safe load handling. The heaviest load routinely handled by the crane consists of the FHM, which is approximately 165 ton In connection with the reactor building crane, the NRC inspector reviewed

.__- -_ ___ . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -

_ - - _ _ _ - - _ _ - _ _ - - _ . -_ _ _ _ ._ _ __ - _ - _ _ - _ - - _

. 1

.. .. l

- 11 - ,

M0P-101, Issue 5. " Reactor Building Crane Operating Procedure," MP-2252(A).

Issue 4, " Reactor Building Overhead Crane," and MP-2252M, Issue 2. " Reactor Building Overhead Crane." Principal focus of this review was on daily, monthly, and annual inspection procedures contained therein. The NRC inspector verified that these inspection procedures incorporate the essential inspection elements of ANSI B 30.2, " Overhead and Gantry Crane," l and PSC Predecessor Procedures MP 104-2. Issue 5, and MP-104-6. Issue It was also determined that a monthly inspection of the crane was completed on February 16, 1989. The last annual inspection was completed on July 13, 1987. The annual inspection scheduled for 1988 was deferred because of time constraints of other activities. The mor thly inspection conducted in February 1989, did not include all elements of an annual inspection. This was discussed with licensee personnel, and it was acknowledged that an " annual" inspection should be completed prior to routine handling of the FHM and other heavy load During review of the reactor building crane, the NRC inspector reviewed Licensee Event Report (LER) 88-017-00, which had been reported to NRC on January 13, 1989. This LER stated that structural analyses had determined that the bridge girder locking system could potentially fail during a design basis tornado. This was based on a determination made on December 14, 1988. The circumstances leading to this determination were reviewed through internal PSC correspondence and associated records.

In July 1987, CN-2374 was initiated to relocate the locking system to the west end of the building to permit easier access to the crane. In October 1987, it appeared, based on preliminary calculations, that the locking pins might fail during a design basis tornado. Sargent & Lundy was asked by PSC for a cost estimate for an analysis and a purchase order for the analysis was issued on March 7, 1988. It was verified, at that period of time, that the original specifications for the crane had specified requirements for withstanding a tornado. The Sargent & Lundy analysis was transmitted to PSC by letter dated December 9, 198 PSC determined on December 14, 1988, t!.at the potential for restraint system failure was reportable as an unanalyzed condition pursuant to 10 CFR 50.7 Review of the analyses summarized in the LER and inspection of the locations of equipment on Level 11 of the reactor building indicates that PSC has accounted for all reasonable ways the crane could fall from the support system and damage equipment. The most serious consequences would be damage to the PCRV liner cooling system surge tanks. Although the core could be cooled down without this system, loss of the system would only be temporary, since it is designed to operate without the surge tanks on firewater backu As a corrective action, PSC will complete modifications to the locking system no later than May 31, 198 No violetions or deviations were identified in the review of this program are _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _

. -_____-_- _ - - -

,.

. - - - . ___

/*

,,e .

'

.

- 12 -

i

. 5. -Exit Interview The NRC inspectors conducted an exit interview on March 10, 1989, with the licensee personnel denoted in paragraph 1. At this meeting, the scope and i findings of-the inspection were summarized. The licensee did not identify l as proprietary any of the materials provided to, or reviewed by, the NRC-inspectors during the inspectio >

l d