ML20137F536

Insp Rept 50-267/85-07 on 850301-0430.Violations Noted: Failure to Follow Procedures in Surveillance & Maint & Failure to Have Adequate Maint Procedure

ML20137F536
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/20/1985
From:	Ireland R, Plumlee G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137F337	List: IR 05000301/2004030 ML20137F332 ML20137F536
References
50-267-85-07, 50-267-85-7, NUDOCS 8508260246
Download: ML20137F536 (17)

See also: IR 05000267/1985007

Text

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APPENDIX B __

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/85-07 License: DPR-34

Docket: 50-267

Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840

Denver, Colorado 80201

Facility Name: Fort St. Vrain Nuclear Generating Station

Inspection At: Fort St. Vrain (FSV) Site, Platteville, Colorado

Inspection Conducted: March 1-31 and April 1-30, 1985

Inspectors: "

7/20 8

cpluG.L.PlumleeIII '

~

D$te

v Senior Resident Inspector (SRI)

Other Accompanying Personnel: Harold Miller, EG&G Consultant

Approved: [ n /rdu

R. 'E. Frelan3,' Chief

' ~ ~

//JO/[f

' Dhte

Special Projects and Enginee/ ring Section

Inspection Summary

Inspection Conducted March 1-31 and April 1-30, 1985 (Report 50-267/85-07)

.

Areas Inspected: Routine / reactive, unannounced inspection of the control rod

drive event, licensee action on previous inspection findings, licensee event

report, maintenance, operational safety verification, and periodic and special

reports. The inspection involved 154 inspector-hours onsite by one NRC

inspector and 263 inspector-hours by one NRC consultant.

-Results: Within the six areas inspected, seven violations (inadequate

maintenance QC, paragraph 2, inadequate maintenance procedures, paragraph 2,

and failure to follow procedures, paragraphs 5 and 6), and three open items

(design document update, paragraph 2, epoxy qualification, paragraph 2, and

procedure corrections, paragraph 6) were identified. Four of the above vio-

lations (inadequate maintenance QC) were issued prior to this report in an

NRC letter E. H. Johnson to 0. R. Lee, dated April 26, 1985.

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DETAILS

1. Persons Contacted

Principal Licensee Employees

D. Alps, Security Supervisor

L. Bishard, Maintenance Supervisor

• T. Borst, Support Services Manager

• B. Burchfield, Superintendent Nuclear Betterment Engineering

Craine, Superintendent of Maintenance

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• W.

• R. Craun', Supervisor Nuclear Site Engineering

M. Deniston, Shift Supervisor

J. Eggebroten, Technical Services Engineering Supervisor

• M. Ferris, QA Operations Manager

• W. Franek, Superintendent Operations

• C. Fuller, Station Manager

• J. Gahm, Manager Nuclear Production

• J. Gramling, Supervisor of Nuclear Licensing - Operations

• M. Holmes, Nuclear Licensing Manager

J. Jackson, QA/QC Supervisor

J. McCauley, Results Engineering Supervisor

• P. Moore, QA Technical. Support Supervisor

• M. Niehoff, Site Engineering Manager

• F. Novachek,. Technical / Administrative Services Manager

H. O'Hagen, Shift Supervisor

• T. Orlin, Superintendent QA Services

• J. Owen, Maintenance Supervisor

J. Petera, Electrical Supervisor

• T. Prenger, QA Engineering Coordinator

^G'. Redmond, MQC Supervisor

G. Reigel, Shift Supervisor

T. Schleiger, Health Physics Supervisor

^L. Singleton, Manager QA

J. Van Dyke, Shift Supervisor Administration

• D. Warembourg, Manager Nuclear Engineering

• S. Willford, Training Supervisor

The SRI also contacted other plant personnel including administrative,

electrical, maintenance, reactor operators, and technicians.

• Denotes those attending the exit interview.

2. Control Rod Drive (CRD) Event

During this report period, the licensee has continued their CRD

refurbishment program as outlined in the licensee's February 3,1985,

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letter (P-85046). This program has been monitored on a periodic basis by

both the SRI and an NRC consultant. Several problems with the methods of

inspection used by the PSC quality control (QC) department were

identified. Examples are as follows:

.

On March 18, 1985, the NRC inspectors determined that a QC hold point

in Step 14.15 of the fuel handling procedure work packet

(FHPWP-100-4) for the refurbishment of Control-Rod-Drive-and-Orifice

Assembly (CRD0A) 4 was not signed off by QC and work was allowed to

continue. Subsequent discussions with the licensee indicated that

bypassing QC hold points was orally authorized during CRD0A

refurbishment. The NRC inspectors noted previous examples where hold

points for. numbering electrical leads had been bypassed resulting in

disconnecting leads without numbering and subsequent incorrect

reconnection. The licensee assured the NRC inspectors that the

electrical lead problem was an isolated example, and that their

method of using hold points was satisfactory. However, the NRC

inspectors determined that this method of inspection was not

documented in the licensee's QA program and was contrary to the

definition of hold points as defined in Administrative Procedure G-1,

" Glossary of Abbreviations and Definitions," Issue 13, dated November

5, 1984, and Maintenance Quality Control Inspection Manual (MQCIM),

Issue 1, dated January 21, 1985. The licensee was informed that this

failure to comply with their QA program requirements is considered a

violation (8507-01).

.

On April 10, 1985, a problem was encountered during testing of CRD0A

18. The CRD0A was disassembled and the simplex second stage bearing

was found installed backwards. The inner and outer races had

separated allowing the ball bearings to fall out, which resulted in

the second stage gear moving towards and rubbing against the drum

support. On April 15, 1985, the NRC inspectors determined that Step

35.13 of Task 35, " Assemble Gear Box Housing and Gear Train," had

been signed off by both the workman and QC on March 28, 1985,

verifying that the second-stage simplex bearing (-200-32) with the

relieved side of outer race facing the second stage gear, had been

properly installed. Contrary to this procedural requirement, the

second-stage simplex bearing was installed backwards. The licensee

was informed that this is considered a procedural violation

(8507-02).

. During a review of nonconformance reports (NCR) addressing various

CR00A repairs, the NRC inspectors were unable to determine what QC

had verified as being acceptable since no acceptance criteria,

inspection requirements, or as-found/as-left data had been

identified. One example was NCR 85-130 (identified in NRC Inspection

Report 85-03) that addressed drilling bolt heads for lockwire holes.

A review of the sketch that had been subsequently added to the NCR,

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for which QC verified conformance, indicated that the hole was in the

wrong location and called for only one hole when four were required.

Therefore, a determination could not be made as to what QC's

signature on this NCR indicated. On March 5, 1985, the NRC

inspectors determined that Administrative Procedure Q-15, " Control of

Nonconforming Items," Issue 3, dated June 23, 1982, requires that as

part of the NCR disposition, the superintendent of QA services (SQAS)

was to determine and denote the appropriate inspections and

organization responsible for performing the inspections. The

licensee was informed that the failure to comply with this QA program

requirement is considered a violation (8507-03). The licensee's

immediate corrective action was to attach a QC general inspection

~ form to each subsequently dispositioned NCR. However, the NRC

inspectors determined this to be inadequate since: (1) QC was not

performing independent measurements; (2) no as-found/as-left data was

required to be entered on the form; and (3) the form did not require

documentation of inspection requirements / specifications.

. On April 8, 1985, the NRC inspectors determined that CRD0A-shaft-

l potentiometer drives drawn from the warehouse and taken to the

refueling deck for subsequent use, were found to have dimensional

discrepancies. The shafts were sent back to the machine shop under

Station Service Request SSR 85504838 to be reinspected and repaired

or scrapped. Of the eight inspected, two were scrapped and six

repaired. The NRC inspectors determined that six of the discrepant

shafts (Serial Nos. 13, 14, 15, 16, 17, and 19) were fabricated by

SSR 84500853, dated November 20, 1984, and inspected / approved by QC

on January 18, 1985, as conforming to Drawing SLR D1201-240, Revision

B. These shafts were subsequently placed in the warehouse as

conforming quality parts. The NRC inspectors also determined that

the licensee had identified the discrepant shafts to be nonconforming

material, but failed to initiate an NCR as required by Administrative

Procedure Q-15. Followup inspections led the NRC inspector to

conclude the following:

. QC does not make independent physical measurements. When

verifying tolerances within a thousandth of an inch, such as

during this refurbishment program, an independent measurement

program becomes a necessity to verify conformance.

. QC stated that NCRs are not commonly initiated on material

issued from the warehouse and subsequently found discrepant

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prior to use in a quality-related component. This is contrary

l to Procedure Q-15 requirements.

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The licensee was informed that the failure to follow QA program

requirements is considered a violation (8507-04).

.

The NRC inspectors subsequently determined that SSR 84500853 also

fabricated 144 slinger washers (-234-1, -2, and -4) of which 66 were

identified in NCR 85-554, dated April 26, 1985, to be

out-of-tolerence and dished. The slingers were returned to the PSC

machine shop for remachining and straightening.

The NRC inspectors discussed the above examples with PSC QA management /

supervisors and indicated the most probable cause for the above examples

of nonconforming material problems were:

.

Form MQC-1-1, "MQC General Inspection Procedure," is inadequate by

itself to inspect a part or assembly, as it does not give the

requirements for inspection or acceptance criteria.

.

QC does not make independent physical measurements when verifying

tolerances.

At a meeting on April 10, 1985, with PSC QA management / supervision, the

NRC inspectors discussed the requirements set forth by ANSI N45.2, 1971,

and 10 CFR 50, Appendix B, concerning quality inspection. The licensee

agreed to revamp the inspection department to do independent-hands-on

inspection, to purchase the necessary measuring tools and equipment, and

to start a training program as necessary to better qualify the inspectors

involved.

To date, new measuring tools were sent out to be calibrated, and many more

have been ordered. Several training programs are being evaluated and

justification for two new buildings is being written (one building for QC

and one for receiving inspection). A new form is being drafted to be

attached to or replace HQC-1-1 general inspection procedure. This form

will list the inspection requirements and acceptance criteria for the

l parts or assemblies being inspected.

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j As an immediate corrective action, a memo QAC-85-0353, dated April 29,

1985, was issued by the PSC QA department to all QC inspectors which

states,

"SUBJ: DOCUMENTATION OF DIMENSIONAL VERIFICATION BY QC INSPECTORS

"When an inspection is performed where a dimensional verification is

required or a dimensional verification occurs, this verification

shall be performed by the QC inspector on the job. The QC Inspector

shall record, on the appropriate inspection form, the acceptance

criteria and the as found dimensions. The QC Inspector shall include

the appropriate drawing number, the revision issue of the drawing or

the applicable document which identifies the acceptance criteria.

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"It is mandatory that the above data be entered on the appropriate

inspection form for each inspection performed."

An enforcement conference was conducted in the Region IV office on

April 24, 1985, to discuss the above QC problems related to CRD

refurbishment. The licensee's response to the concerns identified during

this enforcement conference is documented in P-85144, dated April 26,

1985. The NRC issued a Notice of Violation, dated April 26, 1985, in

advance of this report requiring immediate corrective action to assure

that QC requirements are met during all remaining refurbishment work.

During a review of previously dispositioned NCRs concerning CRD

refurbishment, the SRI determined that numerous NCR dispositions addressed

the need for forthcoming change notice (CN) reissues to document the field

changes authorized by the NCR. No apparent tracking system had been

established to ensure the incorporation of the needed document updates.

In a meeting with the PSC QA and site engineering (NED) representatives on

March 5,1985, the licensee agreed to incorporate the CN number on all

future NCRs and review all previously issued NCRs requiring document

updates to ensure that the field changes were being addressed in future CN

reissues.

While reviewing CRD refurbishment procedures, the NRC inspectors found it

very difficult to follow the documentation of rework. The writing of

findings, directions for rework, etc., in the margin, sometimes filled the

entire page making the sequence difficult to follow. All steps req" iring

signatures or check off, were signed or checked ~ three or four times and

often with no date. The NRC inspectors' concern regarding adequate

documentation was discussed with the licensee. The licensee's same

concerns resulted in development of a new rework procedure which has been

included as an attachment to the CRD refurbishment procedure. The rework

procedure calls out all the steps necessary to do the rework and provides

the necessary blanks for signatures / checks as required in the original

task. The rework exits the original procedure / task at the point the

problem is identified, corrects the problem, returns to the same point,

and then continues in the original procedure / task.

During this same procedure review effort, the NRC inspectors identified

and reported to the licensee numerous procedure problems. Some examples

are as follows:

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CRD 15 - No proper sign-off on tasks 33, 34, 36, 38, and 39.

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CRD 4 - No proper sign-off on tasks 9, 10, 12, 13, 14, 31, 32, 37,

40, and 43.

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. Stainless steel clevis bolts for CRD 6, 26, and 21 were not entered

in the parts replaced log (Attachment F).

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CRD 11 - Rework Task 1 authorization sheet not filled out or signed.

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CRD 13 - QC hold point not signed, Attachment E not signed as

complete, and Attachment N not signed in or complete.

. CRD 28 - Several tasks and steps were listed as N/A without

justification or signature, and in Step 11.28 the tool used had no

calibration date.

The licensee is continuing to improve their efforts in preventing /

minimizing these types of procedural problems.

On March 19, 1985, the NRC inspectors determined that a cable clamp

utilized during testing of the slack cable assembly was left installed

during subsequent testing of the CRD assembly resulting in the destruction

of a new CRD cable. Followup inspection indicated this to have been

caused by a procedural problem for which subsequent corrective action was

initiated to correct the procedure.

On March 20, 1985, the NRC inspectors determined that the procedure step

for disconnecting the orifice mechanism electrical connector

(D1201-400-43) in Fuel Handling Procedure Work Packet FHPWP-100-15 had not

been followed during rework of CRD 15. Subsequent raising of the 200

assembly resulted in damage to the male and female connections. The

development of the new rework procedure identified above should prevent a

recurrence of this type of error during rework. The SRI considered this

to be an isolated error for which adequate corrective action was initiated

by the licensee.

The NRC inspectors reviewed some of the controlled drawings used by PSC to

refurbish the CRDs. Some of the notes on these drawings appeared to be

inaccurate and some that might be needed were not included in the

procedure. Some examples are as follows:

. Note 6 on Drawing 01201-217E stated that the shim motor rotor and )

brake assembly must be balanced as a unit. The licensee was in the

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process of using the rotor from one shim motor interchangeably with

the brake assembly from another shim motor without complying with

this note. The NRC inspector brought this note to the licensee's

attention on March 20, 1985, and NED took immediate action to ensure

compliance with this note. -

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Note 3 on Drawing D1201-286B requires the stamping of a part number '

on the component. As identified below, this note was overlooked

during the design of the slack cable bushing caps (-286-2).

.

PSC QC identified a Note 2.f on Drawing D1201-401 as being applicable

and not complied with, resulting in issuance of NCR 85-553. The note

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had to do with the longevity of the orifice drive motor between

overhauls and implied an overhaul was needed every 6 years.

. Note 2.d on Drawing D1201-401 stated that the design duty of the

motor was 36,000 steps per year. The NRC inspectors determined one

full travel of the orifice valve (approximately 42,000 steps) is

required just to set the valve position limit switches. Therefore,

the yearly design duty, as indicated by note 2.d, would have been

exceeded during limit switch setting. Note 2.d appeared to be

inaccurate.

The licensee has stated that the CRD design drawings are used for

reference only (i.e. " visual aids"), and that the notes are not to be

taken seriously, since the procedure is the controlling document. The

licensee also stated that the drawing notes were not reviewed for possible

inclusion during development of the CRD refurbishment procedures.

However, as noted above, note 6 of Drawing D1201-217E did affect the

refurbishment program and should have been reviewed and incorporated

within the refurbishment procedure. This is an apparent violation of the

Technical Specification requirement to have adequate procedures for safety-

related activities, including CRD maintenance (8507-05).

At the end of this-reporting period, the licensee's QA department had

ccmmitted to perform an audit of the notes on design drawings utilized

during the refurbishment of the 200 assembly. Subsequent discussions with

the. licensee resulted in NED committing to a review of all notes on design

drawings utilized during the refurbishment. This review will consist of

comparing the drawing notes against the current refurbishment procedures

and CRD operations and maintenance manual to determine possible

deficiencies / inaccuracies in the refurbishment program, CRD operations and

maintenance manual, and/or design drawing notes.

PSC NED's current policy concerning CNs affecting drawings is to not~

change the drawing until the CN work is complete. Sometimes it has taken

over a year since work was complete and the revised drawing was issued.

In the interim a " caution" sticker is attached to a drawing affected by a

CN stating that this document has been changed by the CN. This " caution"

sticker may not show up on the drawing for 30 days or more after the CN is

approved. Therefore, the modified system / component may have even.been -

placed in service without having adequate drawings. This concern was

brought to the licensee's attention. PSC NED agreed to evaluate and

determine a way to shorten the time between the CN being issued and the

" caution" sticker showing up on the affected drawings. This is considered

an open item (8507-06) pending completion of the evaluation.

On March 29, 1985, the NRC inspectors determined that an NCR 85-378, dated

March 29, 1985, was issued documenting a disparity in the number of balls

in the new CRD bearings versus the design drawings and original

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specifications SLR D1201-2618, 265A, 2588, 2578, 2568, and 222E. The

possible reduction in cycles to failure of CRD bearings resulting in CRD

inoperability or inability of the CRDs to perform their design function

was the concern. The SRI reviewed the purchase orders (P0) and confirmed

that both the vendor (General Atomic Technologies) and manufacturer (ITI)

certifications verified compliance with the original specifications even

though modifications beyond the original specifications had been made. A

meeting was conducted in the NRC Region IV office on April 17, 1985, to

discuss this issue, and is documented in an NRC letter E. H. Johnson to 0.

R. Lee, dated April 30, 1985.

On April 8, 1985, the NRC inspector determined that the 54 slack cable

bushing caps made in the PSC machine shop and inspected by QC had been

placed in the warehouse under code no. 1504244 without any form of

identification stamped on the part. From a review of CN 1994 which

authorized the cap fabrication and subsequent modification to the CRD 200

assembly on April 15, 1984, the SRI determined that:

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The independent design verification form for CN 1994 indicated that

adequate identification requirements had been specified even though

there was no requirement to identify the part fabricated.

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Adequate identification requirements had not been specified in CN

1994 and subsequent drawings. (i.e. , The slack cable bushing caps

(-286-2) were fabricated from a sketch that did not have the

requirement to stamp the part number on the part. This sketch was

subsequently to be added to Drawing D120-286, Revision B, which does

require stamping the part number on the slack cable assembly bushing

l (-286-1).)

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Fabrication instructions for the slack cable bushing caps were not

incorporated in a control work procedure (CWP). (i.e., The slack

cable bushing caps were fabricated utilizing a Station Service

l Request (SSR) 85504388, dated March 28, 1985.)

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CN 1994 was classified as safety-related only because a

safety-related part SLR D1201-281 (slack cable assembly) had to have

two holes drilled and tapped in its side to attach the slack cable

bushing cap. The cap itself was identified as nonsafety-related.

The failures to incorporate adequate identification requirements during

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' the design review and to provide fabrication instructions utilizing a CWP

was contrary to licensee procedure G-9, and constitutes a second example

of inadequate procedures for CRD refurbishment (8507-05).

On March 20, 1985, the NRC inspector determined and informed the licensee

that the five minute epoxy (Devcon) being used to attach the resistance

temperature thermocouples (RTD) to the CRD assembly was only qualified to

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200 F, whereas, CRDM operating temperatures are expected to exceed 200 F.

Documentation of the qualification of the Devcon epoxy to 300 F is to be

provided to Region IV. This is an open item (8507-07).

The NRC inspectors had no further comments in this area.

3. Licensee Action on Previous Inspection Findings

(Closed) Unresolved Item (50-267/7714-01): Pulled Fuses (CAR-81-137). A

fuse data base report has been issued, Fuse List, FL-6-11, Issue A, dated

October 31, 1984. Fuses are now listed by component and by location.

This item is closed.

(Closed) Open Item (50-267/8209-02): Radiation Monitor Constant Record

ers (CAR-82-056). During periods of low radiation levels, multiple pens

trace over the same general area resulting in mixing of the recorder pen

colors. The licensee verified that when a monitor's radiation level

starts increasing, the associated pen starts to leave the area of over

lapping traces. Once the pen clears this area, the pen quickly produces

its color yielding the desired radiation monitor tracking. This item is

closed.

(Closed) Open Item (50-267/8218-03): Procedure to Minimize Backlog of

Safety-Related PTRs (CAR-82-086 and 82-113). As identified in NRC

Inspection Report 84-30, the licensee has implemented a new maintenance

documentation gathering system (PPMIS). This system provides a method for

tracking of open and in progress SSRs, previously designated PTRs. In

transition to this new system, the majority of backlogged safety-related

PTRs were resolved. Proper use of the PPMIS should eliminate the previous

backlog problem. This item is closed.

(Closed) Open Item (50-267/8315-01): Test of Load Shedding Relays

(CAR-83-086). As previously discussed in NRC Inspection Report 84-22,

this item was to remain open pending incorporation in Technical ,

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Specifications the requirement to periodically test load shedding relays.

This was a commitment made by the licensee during an electrical

specification meeting between the NRC and PSC on August 31, 1984. The

recently submitted draft Technical Specification did incorporate this

requirement on page 3/4.3-51 note (a6). This item is closed.

(0 pen) Open Item (50-267/8410-01): Control of Sealed / Critical Valves

Associated with 00Rs (CAR-84-040). Administrative Procedure P-2,

" Equipment Clearances and Operation Deviations," Issue ll, dated October

10, 1984, revised the 00R procedure to include critical / sealed valve l

controls, however, the ODR form was not changed in order to implement this

requirement. This item will remain open pending the necessary 00R form

revision.

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(Closed) Open Item (50-267/8414-08): Revision to Fire Fighting Mesponse

Guidelines and Specific Area Plan (CAR-84-066). FSP-11, Issue 2, dated

December 21, 1984, incorporated the necessary corrections. This item is

closed.

(Closed) Open Item (50-267/8414-09): Revision to CWPM-1A (CAR-84-067).

Control Work Procedure Manual, Issue 2, dated January 31, 1985, corrected

the problem. This item is closed.

(Closed) Open Item (50-267/8415-04): Procedural Updates for LN, System

(CAR-84-072). The control room alarm index and data logger prihtout were

corrected. This item is closed.

(Closed) Open Item (50-267/8415-07): Commitment Tracking (CAR-84-074).

Administrative Procedure G-2, "FSV Procedure Systems," Issue 14, dated

l December 31, 1984, was revised to include a " flagging" system in which

procedure commitments made to the NRC are set apart by the designator *#*

at the beginning and end of each commitment. These commitments are not to

be deleted unless comparable controls are utilized. This item is closed.

(Closed) Open Item (50-267/8418-01): Revision to MP 12-6 (CAR-84-088).

MP 12-6, Issue 17, dated August 13, 1984, corrected the problems

identified in NRC Inspection Report 84-18. This item is closed

(Closed) Open Item (50-267/8422-04): Revision to G-8 and Part 21 Report

(CAR-84-096). Administrative Procedure G-8, " Compliance with 10 CFR 21

Requirements," Issue 5, dated October 26, 1984, corrected the problems

identified in NRC Inspection Report 84-22.

The Part 21 Report forwarded by the licensee's letter P-84244 was

subsequently corrected by letter P-84342, dated September 6, 1984. This

item is closed.

(Closed) Open item (50-267/8426-01): Relabel Annunciators I-06C, Windows

1-2 and 2-3 (CAR-84-099). The windows have been corrected and the

temporary change request (TCR) closed. This item is closed.

4. Licensee-Event Report (LER)

The SRI reviewed licensee event reporting activities to verify that they

were in accordance with Technical specification, Section 7, including

identification details, corrective action, review, and evaluation of

aspects relative to operations and accuracy of reporting.

The following LERS were reviewed for adequacy:

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(0 pen)84-008, Revision 2

(0 pen)84-009, Revision 1

(0 pen)84-012, Revision 1

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(0 pen) 85-002-

(0 pen)85-003

-(0 pen)85-004

(0 pen)85-005

.( Open)85-006

During a review of LER 84-012, the SRI noted that the corrective action

did not identify the future installation of knock-out pots, moisture

elements, and backup helium source for the main CRD0A purge and reserve

shutdown purge. lines as committed in P-85032.

During a review of LER 85-004, the SRI noted that corrective actions for

the inadvertent isolation of the demineralizers were not addressed. This

is discussed in paragraph 6 of this inspection report.

During a review of LER 85-006, the SRI noted that the corrective action,

regarding Administrative Procedure'G-9 having been modified to include

requirements for surveillances to be included in the PITR and to be signed

off by the CWP work coordinator, was inaccurate. The SRI verified that

G-9 had not been revised as stated. The SRI also noted that a previous

LER 82-039 had addressed the same problem identified in'LER 85-006, and

that its corrective action was evaluated by the SRI, upon LER 82-039

closecut in NRC Inspection Report 83-25, to be adequate had the controlled

work procedure manual (CWPM) been followed. Failure to follow the CWPM

was subsequently identified as a violation in NRC Inspection Report 84-26.

Failure to incorporate SR 5.10.4b-X fire barrier requirements into CWPs,

as addressed in LCR 85-006 corrective actions, is now to be prevented by

the Technical Services Department. The SRI will verify implementation of

this requirement prior to closeout of LER 85-006.

The SRI discussed the above findings with the licensee. The licensee

agreed to make the appropriate LER revisions.

5. Maintenance (Monthly)

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The NRC inspectors reviewed records and observed work in progress to

ascertain that the following maintenance activities were being conducted

as required by approved procedures, Technical Specifications, and

appropriate Codes and Standards. The following maintenance activities

were reviewed and observed:

. SSR 85500761 HV-2253 Repair in 'accordance with MP 91-18,

" Maintenance and Repair of System 91 Hydraulic Valve

Actuators," and MP 22, " Maintenance and Repair of

Rockwell-Edwards Valves Pressure-Seal Type"

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. SSR 85500762 HV-2254 Repair in accordance with MP 91-18 and MP 22

. SSR 84501322 "A" Helium Circulator Removal and Replacement in

accordance with MP 21-15, " Helium Circulator Change

Out Procedure"

. SSR 85503703 "B" Helium Circulator Repair in accordance with

MP 21-18, " Helium Circulator Compressor Assembly

Retaining Bolt Replacement"

. CN 1886 Reorganization, Functional Grouping, Relabeling,

and Demarcation of Instrumentation Components and

Systems on I-01/-02

'During observation / review of the work on HV-2253/-2254 performed by

Rockwell in accordance with PSC proceduros, the NRC inspectors identified

and informed the licensee of the following problems:

.

Missing from the work package was the welder qualification record and

'

MP 100, " General Welding Procedure," which contains special

instructions on housekeeping and' sign-offs for the welder and

fire-watch. MP 100 was required by both MP 91-18 and MP 22.

.

The valve bodies were littered with debris from. valve body weld

repairs and no piping plugs were in place to maintain system

cleanliness.

.

An unapproved liquid not specified in the procedure was being used

(e.g., dye penetrant cleaner).

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Flammable liquids were not stored properly in safety containers.

.

New and used combustible materials were not stored properly in flame

proof containers.

.

Dirty rags and paper wipes on benches and on the floor.

.

Empty paper containers and boxes not removed from the area.

.

Several small sheets of unpainted plywood were in the area being used

as tables and walks, etc. Plywood must be painted with a fire

retardant paint to be in the building. i

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The. fire extinguisher required by MP 100 was not in the immediate

area.

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The licensee was informed that the above problems were considered an

[ apparent violation of MP 22 requirements (8507-08).

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During observation / review of the helium circulator changeout work, the NRC

inspector identified and informed the licensee of the following:

.

The direct charge (DC) and P0 numbers were not kept on a sheet

attached to the SSR as required by Step 3.11.2 of MP 21-15.

.

The Procedure MP 21-15 referenced use of drawing R 1100-100 which was

in use, but was an uncontrolled drawing.

.

The helium circulator was received from General Atomic Technologies,

upon overhaul completion, without the required documentation. NCR

85-326 allowed the work to start under an emergency disbursement.

.

One torque wrench was identified as being out of calibration.

The licensee immediately corrected the above concerns regarding the helium

circulator work.

During observation of the control room design review (CRDR) modifications

being made to Panel I-01, the SRI noted that the backside of the modified

sections of panels had not been painted (i.e., raw nonpreserved metal from

newly installed plate metal). This was discussed with the licensee and

the requirement to paint the backs of the modified panels was subsequently

incorporated into CN 1886. The SRI also noted that above average

cleanliness controls were being maintained during welding / grinding while

installing the plate metal pieces. No metal shavings were noted that

could create a hazard to electrical components.

The NRC inspectors had no further comments in this area.

6. Operational Safety Verification

The SRI reviewed licensee activities to ascertain that the facility is

being operated safely and in conformance with regulatory requirements and

that the licensee's management control system is effectively discharging

its responsibilities for continued safe operation.

The review was conducted by direct observation of activities, tours of the

facility, interviews and discussions with licensee personnel, independent

verifications of safety system status and limiting conditions for

operations, and review of facility records.

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Logs and records reviewed included: j

. Auxiliary Operator Logs

. Clearance Log

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. Equipment Operator Logs

. Operations Deviations Reports

. Operations Order-Book-

. Reactor Operator Logs

. Shift Supervisor Logs

. Shif t Turnover Checklists

. Station Service Requests (SSR)

. Technical Specification Compliance Logs

. Temporary Configuration Reports

During tours of accessible areas, particular attention was directed to the

following:

. Annunciators

. Clearance. Tags

. Control Room Manning

. Fire Hazards ,

o

. . Fluid Leaks

. Hanger / Seismic Restraints

. Housekeeping

. Monitoring Instrumentation

. Piping Vibrations

. Radiation Controls

Plant tours indicated the following types of deficiencies which were-

brought to the attention of the licensee.

.

Control room and auxiliary equipment room control panels

(I-04/I-70(6)) contained loose screws / electrical connectors.

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. Purification helium compressor M-G set panel "off" indicator light

burnt out.

. Fire hose not racked properly (RH1K3).

. Pipe in overhead had lagging soaked with oil (reactor. building -

level one).

. No safety rope utilized while grating was removed (reactor building -

level one).

. Sample line not properly supported upon completion of modification

(reactor building - Level 5'1/2 - I-9306).

On March 19, 1985, during a daily review of operations logs, the SRI

determined that the 480 volt' bus 1 to bus 2 tie breaker was found closed

on the graveyard shift and was suspected to have been left closed upon

completion of' Surveillance SR 5.6.lb-SA, " Loss of Outside Power and

Turbine Trip," during the previous dayshift on March 18, 1985. The SRI's

review of the completed SR 5.6.lb-SA indicated the following problems:

. Step 5.5.13, requiring the above tie breaker to be opened had been

signed off by the dayshift reactor operator, even though the breaker

was subsequently found closed.

. The time for helium circulator restoration was not entered in Step

5.5.15 as required.

. Step 5.5.23, for the return of all equipment to normal, was marked

N/A.

. Data Sheet 10 handswitch (HS) positions were not entered as required.

The SRI informed the licensee that the above failures to follow procedures

which are Technical Specification requirements is considered an apparent

violation (8507-09).

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On March 19, 1985, during efforts to identify the root cause of the

unplanned radioactive liquid waste release that occurred on March 17,

1985, the SRI determined the main contributor to the operator's

identification of this' event, was the failure to unisolate the liquid

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waste demineralizers. This resulted in blockage of the normal flow path

when recirculating through the liquid. waste effluent monitors. The

! effluent, therefore, took the path of least resistance, which in this case

happened to be a partially open discharge Valve V-6241 as identified in

LER 85-004. The licensee has initiated corrective action to ensure that

both the Radioactive Liquid Effluent Surveillance ESR 8.1.2bcd-M and

Operating Procedure 50P-62 for the liquid waste system are revised to

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ensure proper lineup of the demineralizers during recirculation through

the liquid effluent monitors. This is considered an open item (8507-10)

pending . incorporation of the necessary procedure revisions.

The SRI had no further' comments in this area.

7. Periodic-Special Report

The SRI reviewed the following reports for content,-reporting requirement,

and adequacy:

.

Monthly Operations Report for the months of February and March 1985

.

Thirty-fourth Startup report covering the period November 23, 1984,

through February 20, 1985

.

Semi-Annual Radioactive Effluent Release Report covering the period

July 1, 1984, through December 31, 1984

No violations or deviations were identified.

8. Exit Interview

Exit interviews were conducted at the end of various segments of this

inspection with Mr. J. W. Gahm, Manager Nuclear Production, and/or other

members of. the PSC staff as identified in paragraph 1. At the interviews,

the NRC inspectors discussed the findings indicated in the previous

paragraphs. The licensee acknowledged these findings.

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