Difference between revisions of "ML20136J114"

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#REDIRECT [[IR 05000267/1985026]]
 
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{{Adams
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| number = ML20136J114
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| issue date = 11/04/1985
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| title = Forwards Insp Rept 50-267/85-26 on 850819-28.No Violation Noted.Nrc Will Conduct Followup Insps to Address Items Identified as Potential Enforcement Actions
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| author name = Martin L
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| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
  +
| addressee name = Lee O
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| addressee affiliation = PUBLIC SERVICE CO. OF COLORADO
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| docket = 05000267
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| license number =
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| contact person =
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| document report number = NUDOCS 8511250283
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| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
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| page count = 2
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}}
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See also: [[see also::IR 05000267/1985026]]
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=Text=
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NOV 0 41985
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,
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-In Reply Refer To:
  +
.
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.
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Docket:- 50-267/85-26
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-
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Public Serv' ice ~ Company of Colorado
  +
: ATTN: 0. R.l Lee, Vice President-
  +
. Electric Production;
  +
m IP. O. Box 840
  +
Denver, Colorado 80201-0840
  +
:t
  +
Gentlemen: ,
  +
This refers to the inspection conducted by Messrs. L.- L.' Wheeler, J. E. Dyer,
  +
.
  +
and L. E.4 Whitney of the NRC's 0ffice of. Inspection and Enforcement during the
  +
-
  +
:- period . August 19-28,,1985, of. activities authorized by NRC Operating
  +
License DPR-34 for the Fort St. Vrain Nuclear Generating Station, and to
  +
discussion of our findings with Mr. J. Gahm and other members .of your staff at
  +
,
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'
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,
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the conclusion of.the inspection.
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,
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Arease$amined'duringthe.inspectionincludedplantoperations,surveilla~nce
  +
l _ program, and maintenance. .Within these areas, the inspection consisted of-
  +
zselective' examination of procedures and representative records,' interviews
  +
, with personnel', and observations by.the inspectors. These-findings ~are
  +
documented in the enclosed inspection' report.
  +
~ As a result of this Linspection, Region IV willi con' duct- followup inspections to
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'
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address those: items identified as potential enforcement actions, identified as
  +
unresolved items, and~as open. items, s
  +
y
  +
An unresolved item is an item about which more information is needed in. order
  +
L
  +
to determine if the item is_ a1 violation,' a deviatio_n, or acceptable.
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.
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;
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0511250283 851104 '
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gDR ADOCK 05000267
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: Public Service Company of Colorado' -2-
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- Should you have any questions concerning this inspection, we will be pleased
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to' discuss'them with you.
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Sincerely,
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-
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" Original Signed By!
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'
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L E. MARTIN"
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L. E. Martin, Acting Chief
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,
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Reactor Projects Branch
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- Enclosure:
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NRC Inspection Report 50-267/85-26
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cc w/ enclosure:
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J. .W. Gahm, Manager, . Nuclear
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Production Division
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'
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- Fort St. Vrain3 Nuclear-Station
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16805 WCR 191 -
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Platteville, Colorado 80651
  +
_
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- L. Singleton. Managert Quality
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Assurance Division '
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r-
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- (sameaddress)
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~
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: Colnrado Radiation ~ Co'ntrol Program Director'
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, - .
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v.
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bcc~to DMB (IE01) <
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-
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_
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bec distrib. by RIV:
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'RPB R. P. Denise, DRSP
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: Resident Inspector .~
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R. D. Martin, RA
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Section Chief (RPB/A) . RSB
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SectionChief(RSB/ES);.'
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'
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' R&SPB
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- MIS System RSTS Ope'rator
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RIV File .
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J. G. Partlow, IE
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L. L. Wheeler,' IE
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.
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OFFICE OF INSPECTION AND ENFORCEMENT
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DIVISION OF INSPECTION PROGRAMS
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PERFORMANCE APPRAISAL SECTION (PAS)
  +
Report: 50-267/85-26
  +
Docket: 50-267
  +
Licensee Nos. DPR-34
  +
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: August 19-28, 1985
  +
Inspectors: -
  +
/0 -2. -75~
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L. L. Wheeler, ORPB, iE, Team Leader Date
  +
GV /0 -2 - BC'
  +
J. E. Ofer, ORPB, IE Date
  +
$W) /0 -1,-6
  +
L. E. Whitn p RPB, IE Date
  +
Approved by: / 4 -/[ N Jh /c-y JT
  +
g. F. McKee, Chief, Operating Peactors Date
  +
Programs Branch
  +
Inspection Summary
  +
Areas Inspected: This routine safety inspection involved 152 inspection
  +
hours on site in the areas of plant operations, sur-
  +
veillance programs, and maintenance.
  +
Results: Three potential enforcement findings, referred to as un-
  +
resolved items in the report and three open items were
  +
identified during the inspection. These items will be
  +
followed up by the NRC Region IV office,
  +
fiffD f I
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  +
'
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.
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..
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DETAILS
  +
1. Persons Contacted
  +
Licensee
  +
B. Barta, Nuclear Engineer
  +
*F. Borst, Manager, Support Services
  +
*B. Burchfield, Superintendent, Nuclear Betterment Engineering
  +
0. Clayton, Technical Services Engineer
  +
*W. Craine, Maintenance Superintendent
  +
D. Decatoire, Plant Operations
  +
T. Dice, Plant Operations
  +
*D. Evans, Operations Superintendent
  +
*M. Farris, QA Operations Manager
  +
W. Franek, Plant Scheduling and Stores Superintendent
  +
*C. Fuller, Station Manager
  +
*J. Gahm, Nuclear Production Manager
  +
*J. Gramling, Nuclear Licensing
  +
R. Heller, Senior Plant Engineer
  +
D. Horshan, Plant Scheduling and Stores
  +
J. Jackson, QA/QC Supervisor
  +
C. Kasten, QA Computer Specialist
  +
R. Kevan, Plant Operations
  +
S. Koleski, Plant Operations
  +
J. McCauley, Results Engineering Supervisor
  +
*F. Novachek, Technical / Administrative Services Manager
  +
J. Petera, Maintenance Supervisor
  +
G. Redmond, QC Supervisor
  +
C. Schmidt, Results Supervisor
  +
*L. Singleton, QA Manager
  +
H. Starner, Nuclear Site Construction Coordinator
  +
J. Vandyke, Plant Operations
  +
*D. Warembourg, Nuclear Engineering Manager
  +
R. Webb, Maintenance Supervisor
  +
J. Weller, Plant Operations
  +
J. Wojtisek, Technical Services Engineer
  +
Other licensee employees contacted included technician, operators, and
  +
office personnel.
  +
NRC
  +
R. Farrell, Senior Resident Inspector
  +
*M. Skow, Region IV Project Inspector
  +
* Attended exit interview.
  +
.,
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5 s 2. iReview of Plant Operations
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-
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A
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[[ a. Operational Safety' Verification
  +
The control room was inspected daily to verify compliance with minimum
  +
! staffing requirements, access control, adherence to approved operating
  +
i . procedures, and compliance with limiting conditions for operation (LCOs),
  +
i_ Reviews were made of logs, tagging requests, night orders, bypass logs,
  +
4
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s
  +
-
  +
s
  +
and incident reports. Two shift turnovers were also observed.
  +
.
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General housekeeping'and professional demeanor in the control room were
  +
satisfactory. Normal background noise levels did not appear to have
  +
ansadverse effect on operator performance. There were no unnecessary
  +
pers'onnel ods9rved in the control room.
  +
.A ,
  +
a The following concerns were identified:
  +
~
  +
aq
  +
9 -(1) The licensee's equipment control procedures did not comply -
  +
s - with +he requirements of TMI Item I.C.6. Procedure P-2,
  +
Equipment Clearances and Operation Deviations, Issue 13, did
  +
.
  +
not require a second qualified person to verify the correct
  +
I
  +
implementation of tagging activities. On May 22, 1985,
  +
NRC Region IV had requested a response within 120 days to
  +
a similar finding that had been discussed at a Management
  +
'
  +
l ,,
  +
Conferenceonpovember 14, 1984. Clearance control form
  +
, revisions were noted to be in progress during this inspec-
  +
>
  +
tion. The lfcensee's compliance with the requirements of
  +
TMI Item I.C.6 will remain an open item pending Region IV
  +
acceptance of the licensee's response to their finding
  +
, (50-267/85-26-01).
  +
. (2) Procedure P-1, Plant Operatiores, did not provide adequate '
  +
control of temporary plant modifications. Specifically,
  +
.' Section 4.9, Control of Temporary Configuration, contained
  +
no provisions for ensuring the temporary nature of modifi-
  +
! cations made under that procedure. At the time of the i
  +
'
  +
inspection, 37 Temporary Configuration Requests (TCR) were
  +
> open.from two to nine years. The licensee had initiated
  +
-
  +
permanent design change notices (DCN) for several of these
  +
TCRs, however at least 11 of these DCNs had been in prepara-
  +
: tion for over 2 years. This lack of control of temporary
  +
changes resulted in permanent changes being made to the
  +
: station without the necessary reviews being conducted. The
  +
4 failure to establish and implement procedures to adequately
  +
control temporary plant modifications was discussed with the
  +
licensee and will be incorporated into unresolved item
  +
50-267/85-26-02 for followup by the Region IV Office.
  +
; b. Corrective Action Systems
  +
>
  +
The system for performing trend analyses and management review of
  +
l' Corrective Action Requests (CARS) was considered a strength. Cor-
  +
-
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- -_ - - - _ - _ _. . -- - -- ._. . - - . . - _ - . - . _
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..
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_7
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-
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3-
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I
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rective Action Effectiveness Summary Reports were issued monthly
  +
with trend analyses and a current review of CARS by type (failure
  +
to follow procedures, lack of training, etc.). Monthly reports
  +
are also issued to responsible departments identifying responses
  +
due in _the near future and overdue responses. Overdue responses
  +
received adequate management attention.
  +
c. Station Tours
  +
The inspectors toured accessible areas of the plant. During d,ese
  +
tours, observations were made of equipment condition, fire and safety
  +
hazards,.use of procedures, radiological controls and conditions,
  +
housekeeping, and surveillance activities.
  +
It was evident that a significant effort had been made to upgrade
  +
the general housekeeping conditions of the plant. Several major
  +
portions of the plant were clean and free of clutter, debris, etc. '
  +
Maintenance personnel were observed making a deliberate effort to
  +
clean up the work site after performing repairs. The licensee
  +
had developed an extensive list of insulation repair requirements.
  +
However, several safety hazards and basic housekeeping deficiencies ,
  +
were noted. These included a fire hazard from oil in overhead cable
  +
trays, poor lighting in some areas, an open door on the back of an
  +
electrical cabinet, graffitti on the walls, some plant components
  +
in need of cleaning and repainting, a valve leaking onto exposed
  +
insulation repair work in progress, damaged operating instructions
  +
posted on an ammonia injection tank, chains for operating overhead
  +
valves hanging down into passageways, and a safety seal missing from
  +
a relief valve.
  +
Some of these deficiencies had been identified in past Region IV
  +
inspection reports. The region had made housekeeping an open item
  +
twice in previous inspection reports (8325-03 and 8415-03), and
  +
the latest SALP report (May 7, 1985) noted that housekeeping had
  +
- continued to be a problem. Procedure SMAP-13, General Housekeeping
  +
Program, specified inspection requirements, assigned responsibility ,
  +
for designated plant zones, and provided directions for reporting
  +
deficiencies. However, the procedure had no provisions for tracking
  +
,
  +
specific deficiencies to ensure appropriate corrective action and
  +
I management review. The apparent failure to develop and implement
  +
adequate procedures for correcting housekeeping deficiencies will
  +
;_ remain an open item pending followup by Region IV (50-267/85-26-03).
  +
d. System Walkdown
  +
-
  +
The. inspector conducted a walkdown and performed a valve lineup of
  +
the "B" diesel generator to observe equipment conditions and system
  +
- lineups. No valves were found in improper positions, but one valve
  +
was not in accordance with the lineup sheet due to maintenance.
  +
; Deficiencies were noted in that the lineup procedure did not include
  +
-
  +
'
  +
verification of the position of the following: diesel engine cooling
  +
water. temperature control valves (TCVs), air valves on the TCV
  +
i- - regulators, lube oil' drain valves, and lube oil drain plugs. The
  +
, misposition of these items had the potential for causing damage to
  +
,
  +
the diesel engines to the extent that they could fail to operate.
  +
4
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w w - , - - - , , -,--e -,
  +
  +
.
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.-
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,
  +
-4-
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The lube oil heater inlet and outlet valves were not on the lineup
  +
sheets, and they were not labeled. The failure to provide adequate
  +
procedures to ensure the operability of the diesel generators will
  +
remain an open item pending followup by Region IV (50-267/85-26-04).
  +
3. Surveillance Activities
  +
a. The inspectors reviewed recent surveillance test results for the
  +
station and power plant systems (PPS) batteries, and the recently
  +
issued interim Technical Specifications (TS) for reactivity control.
  +
The following documents, tests and records were reviewed:
  +
Document Number Topic
  +
SR 4.1.1.B. 1/2-W Control Rod Operability
  +
through 4.1.1.F.lb-R
  +
SR 4.1.2.A.3-W RodPositionindicationSystems-
  +
through 4.1.2.c x Operation .
  +
SR 4.1.3.B-R Rod Position Indication Systems-
  +
through 4.1.3.D-W/R Shutdown
  +
SR 4.1.4.A-W/ Shutdown Margin
  +
SR 4.1.4-B-P-X
  +
SR 4.1.6.C/D-X Control Rod Position Requirements-
  +
Shutdown
  +
SR 4.1.8.A/B-W Reserve Shutdown System-Operation
  +
through 4.1.8.D-A
  +
SR 4.1.9.A/B-W Reserve Shutdown System-Shutdown
  +
through 4.1.9.D.1-R
  +
SR 5.4.5-M PCRV Cooling Water Flow Scan
  +
Functional Test
  +
SR 5.4.1.3.2.b-M Feedwater Flow Test
  +
SR 5.6.2a-W, Issue 23 Station and PPS Battery Check
  +
for weeks #29, 30, 31 (Weekly)
  +
SR 5.6.2b-M, Issue 1, Station and PPS Battery Check
  +
for week #27 (Monthly)
  +
SR 5.6.2b-Q, Issue 20, Station and PPS Battery Check
  +
for week #31 (Quarterly)
  +
SR 5.6.2c-A, Issue 17, Station and PPS Battery Check
  +
for week #9 (Annual)
  +
TCR 85-04-01 Request to jumper cell 35 out of
  +
<
  +
Battery 1A (N9242)
  +
  +
____-
  +
.
  +
.,.
  +
-5-
  +
Change Notice (CN) 1391 Replace Station Batteries 1A and
  +
18. Replace PPS Battery 1C.
  +
The inspectors found that the interim TS for reactivity control
  +
appeared to have been properly implemented by the surveillance
  +
procedures. The surveillance procedures for the feedwater flow
  +
test and control rod operability also appeared adequate.
  +
Procedure SR 5.4.5-M allowed the potential for errors in PCRV Cooling
  +
Water Flow alarm setpoint restoration. The licensee had previously
  +
identified this deficiency and was processing a procedure change to
  +
correct this weakness.
  +
The inspector reviewed the TS compliance log maintained by control
  +
room personnel and the daily surveillance status printouts provided
  +
by the licensee's scheduling organization. These documents appeared
  +
thorough, concise and effective. No missed surveillances were
  +
identified in this review.
  +
b. The licensee failed to establish procedures that complied with TS
  +
requirements in the following instances:
  +
(1) The weekly battery surveillance test, 5.6.2a-W, did not
  +
measure the temperature of cells adjacent to the pilot
  +
cell as required by TS 5.6.2a.
  +
(2) Neither the monthly nor quarterly surveillance tests, SR
  +
5.6.2b-M and SR 5.G.2b-Q, measured the height of the
  +
electrolyte in the sampled cells as required by TS 5.6.2b.
  +
SR 5.6.2b-M verified that all cell electrolyte levels were
  +
within the vendor specified operating band, but this was
  +
recorded by a single check mark on the data sheet and there
  +
were no cell measurements taken or recorded.
  +
(3) The licensee modified the configuration of a station battery
  +
and returned the battery to an operable status without adequa-
  +
tely considering whether the modified battery would meet the
  +
requirements of TS 5.6.2c. The annual discharge test of
  +
battery 1B conducted in April 1985 was performed with a spare
  +
cell connected to the battery (59 cells total). On the basis
  +
of the performance of this 59 cell battery during the discharge,
  +
the licensee determined that battery capacity was acceptable
  +
in accordance with TS 5.6.2c and the battery was operable.
  +
Subsequently, the spare cell was removed from battery 1B, but
  +
there was apparently no discharge test or evaluation conducted
  +
to determine that the resulting 58 cell battery would meet t.he
  +
necessary operability requirements of the TS.
  +
The apparent failure by the licensee to develop procedures to ade-
  +
quately implement TS surveillance requirements for determining
  +
battery operability was discussed with the licensee and will be
  +
__ _ _ _
  +
_
  +
  +
.
  +
,.
  +
-6-
  +
incorporated into unresolved item 50-267/85-26-02 for followup by ;
  +
the NRC Region IV Office. TS 4.6.1 requires that the station and '
  +
PPS batteries be operable before the reactor is operated at power.
  +
The surveillance test results reviewed by the inspectors were for
  +
a period when the reactor was shutdown and therefore the violation
  +
of a limiting condition for operation (LCO) was not involved.
  +
c. The licensee failed to follow procedure SR 5.6.2c-A for the annual
  +
battery partial discharge test. The results from this discharge
  +
test satisfied the TS 5.6.2c requirements, however, the following
  +
implementation deficiencies were identified:
  +
(1) Procedure Deviation Request (PDR) 85-1032 revised the procedure
  +
to discharge the station batteries (1A, IB) at 85 amps for 24
  +
hours and the PPS battery at 79 amps for 12 hrs or until the
  +
battery terminal voltage reached 101.5 volts. Battery 1B was
  +
discharged at 35 amps for only 19.2 hrs and the PPS battery was
  +
discharged at 79 amps for only 9.6 hours without either battery
  +
reaching its minimum terminal voltage. Interviews revealed that
  +
these discharges were terminated by the personnel performing the
  +
tests without prior management approval.
  +
(2) The end of discharge specific gravities for each cell of battery
  +
1A and IB were all recorded at 1.100 and 1.160, respectively. In-
  +
terviews with maintenance personnel revealed that these readings
  +
were the minimum detectable values of the hydrometers used to
  +
record the end of discharge data. The actual battery cell specific
  +
gravities were lower than the recorded values and this information
  +
was not recorded on the surveillance data sheet.
  +
(3) Alt. hough cell 35 was jumpered from battery 1A and did not participate
  +
in the discharge test, the final individual cell voltage ICV and
  +
specific gravity readings decreased from 2.07 VDC to 1.88 VDC and
  +
1.210 to 1.100, respectively. These post discharge readings were
  +
indicative of the cell participating in the battery discharge test.
  +
-
  +
The apparent failure by the licensee to follow procedure SR 5.6.2c-A
  +
for the annual discharge test of the station and PPS batteries was
  +
discussed with the licensee and will be incorporated into unresolved
  +
item 50-267/85-26-02 for followup by the NRC Region IV Office.
  +
4. ' Maintenance Activities
  +
The inspectors observed the material condition of and reviewed completed
  +
maintenance actions and procedures for batteries and motor operated
  +
valves (MOV). The helium circulator turbine steam inlet isolation
  +
valves (HV-2245, HV-2246, HV-2247, HV-2248) were the MOVs of interest
  +
during this inspection. Additionally, replacement parts used for
  +
safety-related maintenance actions were traced to their origin to
  +
determine their acceptability. The following documents were reviewed:
  +
_ --. __ _ __ _ - . _ ,
  +
  +
- - _ - _ . - _ _ _ _ _ _ _ _ _ _ -
  +
. ..
  +
-7-
  +
Document Number Topic
  +
Station Operating Procedure Electrical Distribution - AC System
  +
(SOP) 92-06, Issue 7
  +
Station Service Request (SSR) Replace Frequency Meter for Battery
  +
84500238 P.O. 53476 1C Inveter
  +
SSR 84500283/287, Rebuild Snubbers
  +
P.O. N4585
  +
SSR 84501102 Repair Motor For HV-2248
  +
NCR 85-563
  +
EMP 45, Disconnecting, Reconnecting and
  +
Issue 1 Testing of Limitorque or Rotork
  +
Values
  +
MP 39.3, Maintenance and Repair of Rotork
  +
Issue 3 Valve Controllers
  +
PM 92.10, Inspection and Preventive Main-
  +
Issue 24 tenance of Caterpillar Diesel -
  +
Emergency Generator Units
  +
SMAP-21, Post Maintenanry Testing Require-
  +
Issues 1 ments in Maintt unce Related
  +
Procedures
  +
P-5, Material Control
  +
Issue 8
  +
Q-4, Procurement Document Control
  +
Issue 6
  +
91-M-1-28-5 Rotork Instruction Handbook for
  +
Synchroset Electric Valve Actuators
  +
a. The inspectors reviewed three safety-related station service requests
  +
(SSR) to determine the suitability of replacement parts being used
  +
for maintenance. Deficiencies were identified with each SSR as
  +
identified below:
  +
(1) The safety-related frequency meter replaced by SSR 84500238 was
  +
procured under a non-safety related purchase order without any
  +
of the required certifications and no attempt was made to qualify
  +
the meter for safety related use. The installation of this meter
  +
was approved by Maintenance Quality Control (MQC).
  +
(2) Safety-related snubber 0-Rings, replaced by SSR 84500283/287,
  +
were purchased via a parts distributor from a manufacturer not
  +
on the qualified vendors list. A certification of conforraance
  +
was provided from the parts distributor to the licensee without
  +
supporting documentation from the manufacturer. This document
  +
- - . . - . ._ . _ , ._,
  +
  +
..
  +
;
  +
-8-
  +
was used as the basis for the receipt inspection acceptance,
  +
even though the certificate was not traceable to the original
  +
manufacturer and the original manufacturer did not have an
  +
approved QA program.
  +
(3) The motor installed on valve HV-2248 by SSR 84501102 was rewound
  +
by a vendor not on the approved vendors list. The licensee
  +
identified this deficiency with NCR 85-563 and had performed a
  +
component qualification test to upgrade the motor for safety-
  +
related applications. The qualification test consisted of
  +
meggering the motor windings to confirm proper electrical
  +
refurbishment and a post installation vibration test to verify
  +
correct bearing installation. The only documentation of test
  +
performance was the statement " Valve test eks okay: Valve is
  +
electrically okay". There was no record of the measured test
  +
results or the instruments utilized to obtain the vibration
  +
and resistance measurements. The licensee did not review the
  +
vendor's process or materials used for rewinding the motor.
  +
The inspectors concluded that the tests and documentation were
  +
inadequate to ensure that the replacement motor was equal to
  +
or better than the original construction phase component.
  +
(4) Gearcase oil used for MOV applications differed from that
  +
recommended by the vendor manual and may not have been suitable
  +
for the environment of all plant MOVs. Procedure MP 39-3 and
  +
the vendor. manual specify the use of SAE 80 EP oil in the
  +
gearcase of motor operated valves. Discussions with maintenance
  +
personnel revealed that Mobil 629 oil was being used for all
  +
MOV applications. The licensee had not performed an engineering
  +
evaluation to determine that the Mobil 629 oil was suitable for
  +
all MOV applications or compatible with residual oil that may
  +
have been in the gearcase
  +
The inspector also noted that SAE 80 EP oil was rated for
  +
operation only to 180 F and this was significantly below the
  +
737 F helium circulator inlet steam temperature listed in the
  +
updated FSAR, Fig 10.2-3, for 100% power operations. During
  +
the inspection, the licensee measured the gearcase temperature
  +
.
  +
'
  +
of HV-2247 at approximately 140*F with lower temperature steam
  +
being supplied from the auxiliary boilers. The suitability of
  +
both Mobil 629 and SAE 80 EP oil under.these high temperature
  +
operating conditions is questionable.
  +
The Ft. St. Vrain Quality Assurance (QA) Plan, Appendix B to
  +
the FSAR, requires that safety-related items be purchased from
  +
approved suppliers, receipt inspected and, if procured sole
  +
source, procured to standards that will assure an equal to or
  +
better than original condition. The apparent failure to procure
  +
safety-related replacement items in accordance with their QA
  +
Plan was discussed with the licensee and will remain unresolved
  +
pending followup by the NRC Region IV Office (50-267/85-26-05).
  +
  +
. . . -. . - . . - ._
  +
-
  +
..
  +
-9-
  +
4
  +
b. -The inspectors reviewed the material condition of the four helium
  +
circulator turbine inlet steam isolation valves (HV-2245, HV-2246,
  +
HV-2247 and HV-2248). In addition to the improperly qualified motor
  +
installed in HV-2248 (see section 4.a.(3) of this report), valves
  +
HV-2247 and HV-2248 were leaking oil from their gearcue, -and
  +
valves HV-2246 and HV-2248 local position indicators differed from
  +
their remote indication. Both valves indicated in the mid position
  +
locally, while valve HV-2246 indicated shut remotely and valve
  +
4
  +
HV-2248 indicated open remotely. The licensee verified the remote
  +
. positions to be correct. Contributing to these material deficien-
  +
cies were the following procedure and implementation problems with
  +
<
  +
the MOV maintenance program:
  +
(1) The electrical maintenance procedure for MOV motor installation,
  +
,
  +
testing and documentation was inadequate. Procedure EMP 45 i
  +
'
  +
provided for verifying proper motor rotation by momentarily
  +
touching the motor leads to an energized terminal and jogging
  +
the motor in the closed direction. This appears contrary to
  +
the vendor manual which directs that the motor be energized
  +
from the operating switch to verify rotation.
  +
Paragraph 3.9 of procedure EMP-45 provided general guidance for
  +
documenting the as found/as left condition of the valve but i
  +
there was no requirement to record the torque or limit switch
  +
settings when adjusting these setpoints. A review of two com-
  +
. pleted SSR packages revealed that these setpoint values were
  +
not recorded.
  +
The post installation testing for MOV motors consisted of cycling
  +
the valve to verify proper operation, circuit integrity and posi-
  +
i tion indication. However, there were no quantitative acceptance
  +
4
  +
criteria for determining proper valve operation even though
  +
nominal valve operating speeds were provided in the vendor
  +
manual. MQC was not required to observe the test and the
  +
determination of proper valve operation was left to the
  +
judgement of the workman performing tne maintenance.
  +
, (2) The torque values listed for use in the MOV mechanical repair
  +
i procedure had an inadequate technical basis and their use was
  +
; optional. -Procedure MP 39-3 had a table of MOV torque values
  +
that were based on bolt size. The table was identical to one
  +
in procedure PM 92.10 for diesel generator maintenance and was
  +
1
  +
- based on values in the diesel generator vendor manual. Addi-
  +
tionally, a note at the bottom of the table made torque wrench
  +
use optional by stating that:
  +
1
  +
i An average man on a 12 inch wrench can develop about
  +
i 100 ft. lb. of torque. Therefore, if a torque wrench
  +
i is not available, or cannot be used, use the following
  +
wrench-bolt combinations:
  +
.
  +
,*we' .-.-.,-r. - . . . ,
  +
-
  +
.,...,,%v.-n,- . - . - . , - - - - , - - - . , , . - - - - - - - - , - . - . . _- - - - - -
  +
  +
; ..
  +
- 10 -
  +
Bolt Sizes, Inches 1/2 9/16 5/8 3/4 7/8 1-1/8
  +
Wrench Sizes, Inches 6 9 12 18 24 36
  +
For larger bolting where specific torque values are
  +
not stated and/or configuration precludes the use of
  +
torque equipment, standard striking wrenches may be
  +
used by qualified mechanics working to industrial
  +
journeyman standards.
  +
The technical basis for this note was a vendor valve manual
  +
notation aoplying to stud n'uts and cap screws. The licensee
  +
had applied the torque values for diesel generators and other
  +
valves to MOVs without any apparent engineering justification.
  +
(3) The post maintenance testing of valve HV-2246 was signed off by
  +
MQC as being complete when plant conditions would not support
  +
the operational test. Procedure MP 39.3, section 6.1, stated
  +
that the post maintenance testing acceptance criteria was " Valve
  +
Stroke and limit switch settings are acceptable for system re-
  +
quirements at operating pressure and temperature". There were
  +
no quantitative acceptance limits provided in the procedure to
  +
determine this acceptability and MQC signed off this part of
  +
the procedure on February 23, 1985 for SSR 84500240. At this
  +
time the reactor was shutdown and steam was being supplied to
  +
the helium circulators from the auxiliary boilers which are not
  +
capable of producing steam at operating temperatures and pressures.
  +
There was no outstanding action item to test this valve when the
  +
plant was at normal operating temperatures and pressures. The
  +
licensee had no assurance that this valve would operate as designed
  +
under expected operation conditions.
  +
c. Station battery maintenance and surveillance procedures were incon-
  +
sistent with the guidance provided by the battery verJor manual.
  +
The following inconsistencies were identified:
  +
(1) The battery ventilation low flow monitor was alarming in the
  +
control room and exhaust air flow from battery rooms IA and 18
  +
appeared to be insufficient to meet the vendor manual recommen-
  +
dations for removing hydrogen gas during charging evolutions.
  +
(2) The upper temperature limit specified on the surveillance
  +
procedures for a battery receiving a float charge was 110 F.
  +
This was contrary to the vendor manual which recommended
  +
maximum allowable battery tempera',ures of 110 F during
  +
equalizing charge evolutions and only 90*F for float charge
  +
conditions. The inspector observed a pilot cell temperature
  +
of 92 F in battery 1A on August 22, 1985. The battery vendor
  +
manual stated that continued operation at this el_evated tem-
  +
perature could degrade the battery capacity and life.
  +
(3) Battery specific gravity and individual cell voltage (ICV)
  +
measurements were not analyzed to determine whether an equali-
  +
zing charge should be performed. The battery vendor manual
  +
  +
.
  +
, . . .
  +
- 11 -
  +
recommended that an equalizing charge be conducted when the
  +
specific gravity of any cell dropped .010 from an initial
  +
standard value or any cell ICV was below 2.13 VDC. Instead,
  +
the licensee performed an equalizing charge monthly in accor-
  +
dance with S0P 92-06. There was no in progress monitoring
  +
of these charges and the end of charge parameters were not
  +
measured to verify improved battery conditions.
  +
(4) There were no procedures for periodically checking battery
  +
intercell resistances and connector tightness, adding water
  +
to individual cells, or cleaning the battery with approved
  +
solvents.
  +
The apparent failure to establish, implement and maintain adequate battery, and
  +
MOV maintenance and testing procedures was discussed with the licensee and will
  +
be incorporated into unresolved item 50-267/85-26-02 for followup by the
  +
NRC Region IV Office.
  +
5. Post-Modification Testing
  +
The licensee did not ensure that all required post-modification tests
  +
were developed as part of modification work packages. The NRC inspector
  +
reviewed Change Notices (CN's) 1798 and 1798-A and their associated
  +
Controlled Work Procedures (CWP's) 84-92, 84-93, 84-94, 84-95 and 85-560
  +
which replaced Emergency Water Booster Pumps (Fire Water Booster Pumps)
  +
P-2109 and P-2110 with pumps having a higher output head. These pumps
  +
could be used to drive the helium circulator turbine to achieve adequate
  +
core cooling in the event of the failure of three feedwater pumps. The
  +
CWP's for this modification did not contain post-installation flow tests
  +
for the new emergency water booster pumps. The failure to develop adequate
  +
controls to ensure that all required post-modification testing was conducted
  +
was discussed with the licensee and will remain an unresolved item pending
  +
review by Region IV (50-267/85-26-06).
  +
6. Unresolved and Open Items:
  +
Unresolved items are matters about which more information is required to
  +
determine whether it is an acceptable item, a deviation, or a violation.
  +
A open item is a matter that requires further review and evaluation by
  +
the inspectors. The following unresolved and open items will be followed
  +
by the NRC Region IV office.
  +
(50-267/85-26-01) (0 pen Item) Tha revision of equipment control procedures
  +
to establish compliance with TMI Item I.C.6. This item will remain open
  +
pending NRC Region IV acceptance of the revised procedures (Item 2.a(1)).
  +
(50-267/85-26-02) (Unresolved) The failure to establish adequate procedures
  +
for control of temporary plant modifications, station battery maintenance
  +
and surveillance tests, and motor operated valve maintenance. Also, the
  +
apparent failure to comply with procedures for battery surveillances and
  +
motor operated valve maintenance (Items 2.a(2), 3b, 3c, 4b, and 4c).
  +
. - - - _ - - - -
  +
,, - . .- - . - - . _
  +
  +
.
  +
, . *
  +
_ 12 -
  +
(50-267/85-16-03) (0 pen Item) The revision of housekeeping procedures to
  +
provide a means for ensuring specific deficiencies are corrected. This
  +
item will remain open pending NRC Region IV acceptance of the revised
  +
procedures (Item 2.c).
  +
(50-267/85-16-04) (0 pen Item) The adequacy of the diesel generator valve
  +
lineup procedure to ensure the availability of the system. The item
  +
will remain open pending NRC Region IV followup of potential weaknesses
  +
in the lineup procedure (Item 2.d).
  +
(50-267/85-26-05) (Unresolved) The failure to procure safety-related
  +
replacement items in accordance with the QA plan requirements (Item
  +
4.a).
  +
(50-267/85-26-06) (Unresolved) The failure to establish adequate
  +
controls to ensure the performance of required post-modification
  +
testing (Item 5).
  +
7. The findings of this inspection were discussed with those persons indicated
  +
in paragraph 1 on August 29, 1985.
  +
- _ _ . . _
  +
-
  +
. -__ -.. . - . _ _ .
  +
}}

Latest revision as of 02:25, 1 July 2020

Forwards Insp Rept 50-267/85-26 on 850819-28.No Violation Noted.Nrc Will Conduct Followup Insps to Address Items Identified as Potential Enforcement Actions
ML20136J114
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 11/04/1985
From: Martin L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Lee O
PUBLIC SERVICE CO. OF COLORADO
References
Download: ML20136J114 (2)


See also: IR 05000267/1985026

Text

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                    '
                                                                       NOV 0 41985
         ,
                          -In Reply Refer To:
                           .
              .
                             Docket:- 50-267/85-26
                                     -
                             Public Serv' ice ~ Company of Colorado
                         : ATTN:          0. R.l Lee, Vice President-
                                       . Electric Production;
 m                        IP. O. Box 840
                             Denver, Colorado 80201-0840
         :t
                             Gentlemen:              ,
                             This refers to the inspection conducted by Messrs. L.- L.' Wheeler, J. E. Dyer,
                                                                                          .
                             and L. E.4 Whitney of the NRC's 0ffice of. Inspection and Enforcement during the
       -
                          :- period . August 19-28,,1985, of. activities authorized by NRC Operating
                             License DPR-34 for the Fort St. Vrain Nuclear Generating Station, and to
                             discussion of our findings with Mr. J. Gahm and other members .of your staff at

, '

     ,
                             the conclusion of.the inspection.

,

                             Arease$amined'duringthe.inspectionincludedplantoperations,surveilla~nce

l _ program, and maintenance. .Within these areas, the inspection consisted of-

                          zselective' examination of procedures and representative records,' interviews
     ,                       with personnel', and observations by.the inspectors. These-findings ~are
                              documented in the enclosed inspection' report.
                          ~ As a result of this Linspection, Region IV willi con' duct- followup inspections to
   '
                              address those: items identified as potential enforcement actions, identified as
                              unresolved items, and~as open. items,                                 s
                                                                                                         y
                              An unresolved item is an item about which more information is needed in. order

L

                              to determine if the item is_ a1 violation,' a deviatio_n, or acceptable.
                                                                                            .
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                              :  Public Service Company of Colorado'             -2-
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                                - Should you have any questions concerning this inspection, we will be pleased
                                 to' discuss'them with you.
                                                                                 Sincerely,
            -
                                                                                     " Original Signed By!
                    '
                                                                                      L E. MARTIN"
                                                                                 L. E. Martin, Acting Chief
                                         ,
                                                                                 Reactor Projects Branch
                              - Enclosure:
                                 NRC Inspection Report 50-267/85-26
                                 cc w/ enclosure:
                                 J. .W. Gahm, Manager, . Nuclear
                                    Production Division

'

                              - Fort St. Vrain3 Nuclear-Station
                                 16805 WCR 191 -
                                 Platteville, Colorado 80651
                      _
                                - L. Singleton. Managert Quality
                                    Assurance Division             '
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                                - (sameaddress)
                                                                 ~
                              :  Colnrado Radiation ~ Co'ntrol Program Director'
              ,                                -     .
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                                 bec distrib. by RIV:
                                  'RPB                                     R. P. Denise, DRSP
                                 : Resident Inspector                .~
                                                                           R. D. Martin, RA
                                   Section Chief (RPB/A)                . RSB
                                   SectionChief(RSB/ES);.'
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                          -        MIS System                              RSTS Ope'rator
                                   RIV File        .
                                                                           J. G. Partlow, IE
                                 L. L. Wheeler,' IE
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                            OFFICE OF INSPECTION AND ENFORCEMENT
                                 DIVISION OF INSPECTION PROGRAMS
                              PERFORMANCE APPRAISAL SECTION (PAS)
    Report:    50-267/85-26
    Docket:    50-267
    Licensee Nos.    DPR-34
    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:         August 19-28, 1985
    Inspectors:                                -
                                                                          /0 -2. -75~
                     L. L. Wheeler, ORPB, iE, Team Leader                    Date
                                GV                                        /0 -2 - BC'
                     J. E. Ofer, ORPB, IE                                    Date
                        $W)                                               /0 -1,-6
                     L. E. Whitn p RPB, IE                                   Date
    Approved by: /             4       -/[ N Jh                             /c-y JT
                  g. F. McKee, Chief, Operating Peactors                     Date
                     Programs Branch
    Inspection Summary
    Areas Inspected:       This routine safety inspection involved 152 inspection
                           hours on site in the areas of plant operations, sur-
                           veillance programs, and maintenance.
    Results:               Three potential enforcement findings, referred to as un-
                           resolved items in the report and three open items were
                           identified during the inspection. These items will be
                           followed up by the NRC Region IV office,
                                 fiffD f             I
  '
    .

..

                                            DETAILS
      1.     Persons Contacted
             Licensee
             B. Barta, Nuclear Engineer
            *F. Borst, Manager, Support Services
            *B. Burchfield, Superintendent, Nuclear Betterment Engineering
             0. Clayton, Technical Services Engineer
            *W.  Craine, Maintenance Superintendent
             D. Decatoire, Plant Operations
             T. Dice, Plant Operations
            *D. Evans, Operations Superintendent
            *M.  Farris, QA Operations Manager
             W. Franek, Plant Scheduling and Stores Superintendent
            *C. Fuller, Station Manager
            *J. Gahm, Nuclear Production Manager
            *J. Gramling, Nuclear Licensing
             R. Heller, Senior Plant Engineer
             D. Horshan, Plant Scheduling and Stores
             J. Jackson, QA/QC Supervisor
             C. Kasten, QA Computer Specialist
             R. Kevan, Plant Operations
             S. Koleski, Plant Operations
             J. McCauley, Results Engineering Supervisor
            *F. Novachek, Technical / Administrative Services Manager
             J. Petera, Maintenance Supervisor
             G. Redmond, QC Supervisor
             C. Schmidt, Results Supervisor
            *L. Singleton, QA Manager
             H. Starner, Nuclear Site Construction Coordinator
             J. Vandyke, Plant Operations
            *D. Warembourg, Nuclear Engineering Manager
             R. Webb, Maintenance Supervisor
             J. Weller, Plant Operations
             J. Wojtisek, Technical Services Engineer
           Other licensee employees contacted included technician, operators, and
           office personnel.
             NRC
             R. Farrell, Senior Resident Inspector
            *M. Skow, Region IV Project Inspector
      * Attended exit interview.
                                      .,
                                         --
                                              - . - . . - - + - , - . , - - , , e - .- .
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                                        +

5 s 2. iReview of Plant Operations

                      -

4, y w A

        [[              a.          Operational Safety' Verification
                                    The control room was inspected daily to verify compliance with minimum

! staffing requirements, access control, adherence to approved operating i . procedures, and compliance with limiting conditions for operation (LCOs), i_ Reviews were made of logs, tagging requests, night orders, bypass logs, 4

                s
                  -
                           s
                                    and incident reports. Two shift turnovers were also observed.
                                                                              .
                                    General housekeeping'and professional demeanor in the control room were
                                    satisfactory. Normal background noise levels did not appear to have
                                    ansadverse effect on operator performance. There were no unnecessary
                                    pers'onnel ods9rved in the control room.
                                                          .A                                                                                           ,
                    a               The following concerns were identified:

~

                        aq
                              9 -(1) The licensee's equipment control procedures did not comply                                                        -
                      s               -          with +he requirements of TMI Item I.C.6. Procedure P-2,
                                                 Equipment Clearances and Operation Deviations, Issue 13, did
.
                                                 not require a second qualified person to verify the correct

I

                                                 implementation of tagging activities.                    On May 22, 1985,
                                                 NRC Region IV had requested a response within 120 days to
                                                 a similar finding that had been discussed at a Management
 '

l ,,

                                                 Conferenceonpovember 14, 1984. Clearance control form
                                           ,     revisions were noted to be in progress during this inspec-
                                         >
                                                 tion. The lfcensee's compliance with the requirements of
                                                 TMI Item I.C.6 will remain an open item pending Region IV
                                                 acceptance of the licensee's response to their finding
                             ,                   (50-267/85-26-01).

. (2) Procedure P-1, Plant Operatiores, did not provide adequate '

                                                 control of temporary plant modifications.                   Specifically,
                                             .' Section 4.9, Control of Temporary Configuration, contained
                                                 no provisions for ensuring the temporary nature of modifi-

! cations made under that procedure. At the time of the i

                                                                                                                                                       '
                                                 inspection, 37 Temporary Configuration Requests (TCR) were

> open.from two to nine years. The licensee had initiated -

                                                 permanent design change notices (DCN) for several of these
                                                 TCRs, however at least 11 of these DCNs had been in prepara-
tion for over 2 years. This lack of control of temporary
                                                 changes resulted in permanent changes being made to the
station without the necessary reviews being conducted. The

4 failure to establish and implement procedures to adequately

                                                 control temporary plant modifications was discussed with the
                                                 licensee and will be incorporated into unresolved item
                                                 50-267/85-26-02 for followup by the Region IV Office.
b. Corrective Action Systems

>

                                    The system for performing trend analyses and management review of

l' Corrective Action Requests (CARS) was considered a strength. Cor-

   -
                                  - -_ -                   - - _ - _           _. .           --     - --       ._. .   - - . . - _ - . - .          _
     ..
  _7
                                            -
                                              3-
                                                                                       I
               rective Action Effectiveness Summary Reports were issued monthly
               with trend analyses and a current review of CARS by type (failure
               to follow procedures, lack of training, etc.). Monthly reports
               are also issued to responsible departments identifying responses
               due in _the near future and overdue responses.    Overdue responses
               received adequate management attention.
         c.    Station Tours
              The inspectors toured accessible areas of the plant. During d,ese
              tours, observations were made of equipment condition, fire and safety
              hazards,.use of procedures, radiological controls and conditions,
              housekeeping, and surveillance activities.
              It was evident that a significant effort had been made to upgrade
              the general housekeeping conditions of the plant. Several major
              portions of the plant were clean and free of clutter, debris, etc.      '
              Maintenance personnel were observed making a deliberate effort to
              clean up the work site after performing repairs. The licensee
              had developed an extensive list of insulation repair requirements.
              However, several safety hazards and basic housekeeping deficiencies     ,
             were noted. These included a fire hazard from oil in overhead cable
              trays, poor lighting in some areas, an open door on the back of an
              electrical cabinet, graffitti on the walls, some plant components
              in need of cleaning and repainting, a valve leaking onto exposed
              insulation repair work in progress, damaged operating instructions
             posted on an ammonia injection tank, chains for operating overhead
              valves hanging down into passageways, and a safety seal missing from
             a relief valve.
             Some of these deficiencies had been identified in past Region IV
              inspection reports. The region had made housekeeping an open item
             twice in previous inspection reports (8325-03 and 8415-03), and
             the latest SALP report (May 7, 1985) noted that housekeeping had
            - continued to be a problem.      Procedure SMAP-13, General Housekeeping
             Program, specified inspection requirements, assigned responsibility      ,
             for designated plant zones, and provided directions for reporting
             deficiencies. However, the procedure had no provisions for tracking

,

             specific deficiencies to ensure appropriate corrective action and

I management review. The apparent failure to develop and implement

             adequate procedures for correcting housekeeping deficiencies will
_ remain an open item pending followup by Region IV (50-267/85-26-03).
        d.   System Walkdown

-

             The. inspector conducted a walkdown and performed a valve lineup of
             the "B" diesel generator to observe equipment conditions and system
            - lineups. No valves were found in improper positions, but one valve
             was not in accordance with the lineup sheet due to maintenance.
Deficiencies were noted in that the lineup procedure did not include

- '

             verification of the position of the following: diesel engine cooling
             water. temperature control valves (TCVs), air valves on the TCV

i- - regulators, lube oil' drain valves, and lube oil drain plugs. The , misposition of these items had the potential for causing damage to ,

             the diesel engines to the extent that they could fail to operate.

4

  w      w              - , - - - , , -,--e     -,
   .
     .-
 ,
                                          -4-
               The lube oil heater inlet and outlet valves were not on the lineup
               sheets, and they were not labeled. The failure to provide adequate
               procedures to ensure the operability of the diesel generators will
               remain an open item pending followup by Region IV (50-267/85-26-04).
        3. Surveillance Activities
           a.  The inspectors reviewed recent surveillance test results for the
               station and power plant systems (PPS) batteries, and the recently
               issued interim Technical Specifications (TS) for reactivity control.
               The following documents, tests and records were reviewed:
                     Document Number                             Topic
                     SR 4.1.1.B. 1/2-W                  Control Rod Operability
                     through 4.1.1.F.lb-R
                     SR 4.1.2.A.3-W                     RodPositionindicationSystems-
                     through 4.1.2.c x                  Operation     .
                     SR 4.1.3.B-R                       Rod Position Indication Systems-
                     through 4.1.3.D-W/R                Shutdown
                     SR 4.1.4.A-W/                      Shutdown Margin
                     SR 4.1.4-B-P-X
                     SR 4.1.6.C/D-X                     Control Rod Position Requirements-
                                                        Shutdown
                     SR 4.1.8.A/B-W                     Reserve Shutdown System-Operation
                     through 4.1.8.D-A
                     SR 4.1.9.A/B-W                     Reserve Shutdown System-Shutdown
                     through 4.1.9.D.1-R
                     SR 5.4.5-M                         PCRV Cooling Water Flow Scan
                                                        Functional Test
                     SR 5.4.1.3.2.b-M                   Feedwater Flow Test
                     SR 5.6.2a-W, Issue 23              Station and PPS Battery Check
                     for weeks #29, 30, 31              (Weekly)
                     SR 5.6.2b-M, Issue 1,              Station and PPS Battery Check
                     for week #27                       (Monthly)
                     SR 5.6.2b-Q, Issue 20,             Station and PPS Battery Check
                     for week #31                       (Quarterly)
                     SR 5.6.2c-A, Issue 17,             Station and PPS Battery Check
                     for week #9                        (Annual)
                     TCR 85-04-01                       Request to jumper cell 35 out of

<

                                                        Battery 1A (N9242)
                                                                                 ____-
   .

.,.

                                     -5-
                Change Notice (CN) 1391             Replace Station Batteries 1A and
                                                    18.  Replace PPS Battery 1C.
         The inspectors found that the interim TS for reactivity control
         appeared to have been properly implemented by the surveillance
         procedures.    The surveillance procedures for the feedwater flow
          test and control rod operability also appeared adequate.
         Procedure SR 5.4.5-M allowed the potential for errors in PCRV Cooling
         Water Flow alarm setpoint restoration. The licensee had previously
         identified this deficiency and was processing a procedure change to
         correct this weakness.
         The inspector reviewed the TS compliance log maintained by control
         room personnel and the daily surveillance status printouts provided
         by the licensee's scheduling organization. These documents appeared
         thorough, concise and effective.     No missed surveillances were
         identified in this review.
     b.  The licensee failed to establish procedures that complied with TS
         requirements in the following instances:
         (1) The weekly battery surveillance test, 5.6.2a-W, did not
               measure the temperature of cells adjacent to the pilot
               cell as required by TS 5.6.2a.
         (2) Neither the monthly nor quarterly surveillance tests, SR
               5.6.2b-M and SR 5.G.2b-Q, measured the height of the
               electrolyte in the sampled cells as required by TS 5.6.2b.
               SR 5.6.2b-M verified that all cell electrolyte levels were
               within the vendor specified operating band, but this was
               recorded by a single check mark on the data sheet and there
               were no cell measurements taken or recorded.
         (3) The licensee modified the configuration of a station battery
               and returned the battery to an operable status without adequa-
               tely considering whether the modified battery would meet the
               requirements of TS 5.6.2c. The annual discharge test of
               battery 1B conducted in April 1985 was performed with a spare
               cell connected to the battery (59 cells total).    On the basis
               of the performance of this 59 cell battery during the discharge,
               the licensee determined that battery capacity was acceptable
               in accordance with TS 5.6.2c and the battery was operable.
               Subsequently, the spare cell was removed from battery 1B, but
               there was apparently no discharge test or evaluation conducted
               to determine that the resulting 58 cell battery would meet t.he
               necessary operability requirements of the TS.
         The apparent failure by the licensee to develop procedures to ade-
         quately implement TS surveillance requirements for determining
         battery operability was discussed with the licensee and will be
      __                 _   _    _
                                     _
  .

,.

                                               -6-
                  incorporated into unresolved item 50-267/85-26-02 for followup by          ;
                  the NRC Region IV Office.     TS 4.6.1 requires that the station and       '
                  PPS batteries be operable before the reactor is operated at power.
                 The surveillance test results reviewed by the inspectors were for
                  a period when the reactor was shutdown and therefore the violation
                 of a limiting condition for operation (LCO) was not involved.
           c.    The licensee failed to follow procedure SR 5.6.2c-A for the annual
                 battery partial discharge test.      The results from this discharge
                 test satisfied the TS 5.6.2c requirements, however, the following
                  implementation deficiencies were identified:
                 (1) Procedure Deviation Request (PDR) 85-1032 revised the procedure
                        to discharge the station batteries (1A, IB) at 85 amps for 24
                        hours and the PPS battery at 79 amps for 12 hrs or until the
                        battery terminal voltage reached 101.5 volts. Battery 1B was
                        discharged at 35 amps for only 19.2 hrs and the PPS battery was
                        discharged at 79 amps for only 9.6 hours without either battery
                        reaching its minimum terminal voltage. Interviews revealed that
                        these discharges were terminated by the personnel performing the
                        tests without prior management approval.
                 (2) The end of discharge specific gravities for each cell of battery
                        1A and IB were all recorded at 1.100 and 1.160, respectively. In-
                        terviews with maintenance personnel revealed that these readings
                        were the minimum detectable values of the hydrometers used to
                        record the end of discharge data. The actual battery cell specific
                        gravities were lower than the recorded values and this information
                        was not recorded on the surveillance data sheet.
                 (3) Alt. hough cell 35 was jumpered from battery 1A and did not participate
                        in the discharge test, the final individual cell voltage ICV and
                        specific gravity readings decreased from 2.07 VDC to 1.88 VDC and
                        1.210 to 1.100, respectively. These post discharge readings were
                        indicative of the cell participating in the battery discharge test.
       -
                The apparent failure by the licensee to follow procedure SR 5.6.2c-A
                 for the annual discharge test of the station and PPS batteries was
                discussed with the licensee and will be incorporated into unresolved
                 item 50-267/85-26-02 for followup by the NRC Region IV Office.
    4.   ' Maintenance Activities
           The inspectors observed the material condition of and reviewed completed
           maintenance actions and procedures for batteries and motor operated
           valves (MOV).     The helium circulator turbine steam inlet isolation
           valves (HV-2245, HV-2246, HV-2247, HV-2248) were the MOVs of interest
           during this inspection. Additionally, replacement parts used for
           safety-related maintenance actions were traced to their origin to
           determine their acceptability. The following documents were reviewed:
    _               --.  __                                _ __  _                 - . _ ,
                                                                                   - - _ - _ . - _ _ _ _ _ _ _ _ _ _ -

. ..

                                          -7-
           Document Number                                  Topic
     Station Operating Procedure               Electrical Distribution - AC System
      (SOP) 92-06, Issue 7
     Station Service Request (SSR)            Replace Frequency Meter for Battery
     84500238 P.O. 53476                      1C Inveter
     SSR 84500283/287,                        Rebuild Snubbers
     P.O. N4585
     SSR 84501102                             Repair Motor For HV-2248
    NCR 85-563
    EMP 45,                                   Disconnecting, Reconnecting and
     Issue 1                                  Testing of Limitorque or Rotork
                                              Values
    MP 39.3,                                  Maintenance and Repair of Rotork
    Issue 3                                   Valve Controllers
    PM 92.10,                                 Inspection and Preventive Main-
    Issue 24                                  tenance of Caterpillar Diesel -
                                              Emergency Generator Units
    SMAP-21,                                  Post Maintenanry Testing Require-
    Issues 1                                  ments in Maintt unce Related
                                              Procedures
    P-5,                                      Material Control
    Issue 8
    Q-4,                                      Procurement Document Control
    Issue 6
    91-M-1-28-5                               Rotork Instruction Handbook for
                                              Synchroset Electric Valve Actuators
    a.    The inspectors reviewed three safety-related station service requests
          (SSR) to determine the suitability of replacement parts being used
          for maintenance. Deficiencies were identified with each SSR as
          identified below:
          (1) The safety-related frequency meter replaced by SSR 84500238 was
               procured under a non-safety related purchase order without any
               of the required certifications and no attempt was made to qualify
               the meter for safety related use.           The installation of this meter
               was approved by Maintenance Quality Control (MQC).
          (2) Safety-related snubber 0-Rings, replaced by SSR 84500283/287,
               were purchased via a parts distributor from a manufacturer not
               on the qualified vendors list.        A certification of conforraance
               was provided from the parts distributor to the licensee without
               supporting documentation from the manufacturer.            This document
                            -     - . . -         .     ._        .        _ , ._,
 ..
                                  -8-
          was used as the basis for the receipt inspection acceptance,
           even though the certificate was not traceable to the original
          manufacturer and the original manufacturer did not have an
           approved QA program.
     (3) The motor installed on valve HV-2248 by SSR 84501102 was rewound
          by a vendor not on the approved vendors list. The licensee
           identified this deficiency with NCR 85-563 and had performed a
          component qualification test to upgrade the motor for safety-
           related applications. The qualification test consisted of
          meggering the motor windings to confirm proper electrical
           refurbishment and a post installation vibration test to verify
          correct bearing installation.      The only documentation of test
          performance was the statement " Valve test eks okay: Valve is
          electrically okay".      There was no record of the measured test
          results or the instruments utilized to obtain the vibration
          and resistance measurements.      The licensee did not review the
          vendor's process or materials used for rewinding the motor.
          The inspectors concluded that the tests and documentation were
          inadequate to ensure that the replacement motor was equal to
          or better than the original construction phase component.
    (4) Gearcase oil used for MOV applications differed from that
          recommended by the vendor manual and may not have been suitable
          for the environment of all plant MOVs. Procedure MP 39-3 and
          the vendor. manual specify the use of SAE 80 EP oil in the
          gearcase of motor operated valves. Discussions with maintenance
          personnel revealed that Mobil 629 oil was being used for all
          MOV applications. The licensee had not performed an engineering
          evaluation to determine that the Mobil 629 oil was suitable for
          all MOV applications or compatible with residual oil that may
          have been in the gearcase
          The inspector also noted that SAE 80 EP oil was rated for
          operation only to 180 F and this was significantly below the
          737 F helium circulator inlet steam temperature listed in the
          updated FSAR, Fig 10.2-3, for 100% power operations. During
          the inspection, the licensee measured the gearcase temperature
                                                                             .
                                                                             '
          of HV-2247 at approximately 140*F with lower temperature steam
          being supplied from the auxiliary boilers.      The suitability of
          both Mobil 629 and SAE 80 EP oil under.these high temperature
          operating conditions is questionable.
    The Ft. St. Vrain Quality Assurance (QA) Plan, Appendix B to
    the FSAR, requires that safety-related items be purchased from
    approved suppliers, receipt inspected and, if procured sole
    source, procured to standards that will assure an equal to or
    better than original condition.       The apparent failure to procure
    safety-related replacement items in accordance with their QA
    Plan was discussed with the licensee and will remain unresolved
    pending followup by the NRC Region IV Office (50-267/85-26-05).
                                                  .  .        .                                               -.                       . - . .            -              ._
      -
  ..
                                                            -9-

4

           b. -The inspectors reviewed the material condition of the four helium
                circulator turbine inlet steam isolation valves (HV-2245, HV-2246,
               HV-2247 and HV-2248). In addition to the improperly qualified motor
                installed in HV-2248 (see section 4.a.(3) of this report), valves
               HV-2247 and HV-2248 were leaking oil from their gearcue, -and
               valves HV-2246 and HV-2248 local position indicators differed from
               their remote indication. Both valves indicated in the mid position
                locally, while valve HV-2246 indicated shut remotely and valve

4

               HV-2248 indicated open remotely. The licensee verified the remote
              . positions to be correct.                     Contributing to these material deficien-
               cies were the following procedure and implementation problems with

<

               the MOV maintenance program:
               (1) The electrical maintenance procedure for MOV motor installation,

,

                              testing and documentation was inadequate.                                    Procedure EMP 45                                                  i
'
                              provided for verifying proper motor rotation by momentarily
                              touching the motor leads to an energized terminal and jogging
                              the motor in the closed direction. This appears contrary to
                              the vendor manual which directs that the motor be energized
                              from the operating switch to verify rotation.
                              Paragraph 3.9 of procedure EMP-45 provided general guidance for
                              documenting the as found/as left condition of the valve but                                                                                   i
                              there was no requirement to record the torque or limit switch
                              settings when adjusting these setpoints. A review of two com-

. pleted SSR packages revealed that these setpoint values were

                              not recorded.
                              The post installation testing for MOV motors consisted of cycling
                              the valve to verify proper operation, circuit integrity and posi-

i tion indication. However, there were no quantitative acceptance 4

                              criteria for determining proper valve operation even though
                              nominal valve operating speeds were provided in the vendor
                             manual. MQC was not required to observe the test and the
                             determination of proper valve operation was left to the
                             judgement of the workman performing tne maintenance.

, (2) The torque values listed for use in the MOV mechanical repair i procedure had an inadequate technical basis and their use was

optional. -Procedure MP 39-3 had a table of MOV torque values
                             that were based on bolt size. The table was identical to one
                              in procedure PM 92.10 for diesel generator maintenance and was

1

                            - based on values in the diesel generator vendor manual. Addi-
                             tionally, a note at the bottom of the table made torque wrench
                             use optional by stating that:

1 i An average man on a 12 inch wrench can develop about i 100 ft. lb. of torque. Therefore, if a torque wrench

i                                          is not available, or cannot be used, use the following
                                           wrench-bolt combinations:

.

     ,*we'        .-.-.,-r.      - . . . ,
                                                                     -
                                                                .,...,,%v.-n,-            . - . - . , - - - - , - - - . , , . - - - - - - - - , - . - . .   _- - - - - -
..
                                   - 10 -
                   Bolt Sizes, Inches 1/2     9/16    5/8  3/4    7/8   1-1/8
                   Wrench Sizes, Inches 6       9      12   18     24     36
                   For larger bolting where specific torque values are
                   not stated and/or configuration precludes the use of
                   torque equipment, standard striking wrenches may be
                   used by qualified mechanics working to industrial
                   journeyman standards.
             The technical basis for this note was a vendor valve manual
             notation aoplying to stud n'uts and cap screws. The licensee
             had applied the torque values for diesel generators and other
             valves to MOVs without any apparent engineering justification.
       (3) The post maintenance testing of valve HV-2246 was signed off by
             MQC as being complete when plant conditions would not support
             the operational test. Procedure MP 39.3, section 6.1, stated
             that the post maintenance testing acceptance criteria was " Valve
             Stroke and limit switch settings are acceptable for system re-
             quirements at operating pressure and temperature".    There were
             no quantitative acceptance limits provided in the procedure to
             determine this acceptability and MQC signed off this part of
             the procedure on February 23, 1985 for SSR 84500240. At this
             time the reactor was shutdown and steam was being supplied to
             the helium circulators from the auxiliary boilers which are not
             capable of producing steam at operating temperatures and pressures.
            There was no outstanding action item to test this valve when the
             plant was at normal operating temperatures and pressures. The
             licensee had no assurance that this valve would operate as designed
             under expected operation conditions.
    c. Station battery maintenance and surveillance procedures were incon-
       sistent with the guidance provided by the battery verJor manual.
       The following inconsistencies were identified:
       (1) The battery ventilation low flow monitor was alarming in the
            control room and exhaust air flow from battery rooms IA and 18
            appeared to be insufficient to meet the vendor manual recommen-
            dations for removing hydrogen gas during charging evolutions.
       (2) The upper temperature limit specified on the surveillance
            procedures for a battery receiving a float charge was 110 F.
            This was contrary to the vendor manual which recommended
            maximum allowable battery tempera',ures of 110 F during
            equalizing charge evolutions and only 90*F for float charge
            conditions. The inspector observed a pilot cell temperature
            of 92 F in battery 1A on August 22, 1985. The battery vendor
            manual stated that continued operation at this el_evated tem-
            perature could degrade the battery capacity and life.
       (3) Battery specific gravity and individual cell voltage (ICV)
            measurements were not analyzed to determine whether an equali-
            zing charge should be performed. The battery vendor manual
                                .

, . . .

                                            - 11 -
                      recommended that an equalizing charge be conducted when the
                      specific gravity of any cell dropped .010 from an initial
                      standard value or any cell ICV was below 2.13 VDC. Instead,
                      the licensee performed an equalizing charge monthly in accor-
                      dance with S0P 92-06. There was no in progress monitoring
                      of these charges and the end of charge parameters were not
                      measured to verify improved battery conditions.
                 (4) There were no procedures for periodically checking battery
                      intercell resistances and connector tightness, adding water
                      to individual cells, or cleaning the battery with approved
                      solvents.
           The apparent failure to establish, implement and maintain adequate battery, and
           MOV maintenance and testing procedures was discussed with the licensee and will
           be incorporated into unresolved item 50-267/85-26-02 for followup by the
           NRC Region IV Office.
       5.  Post-Modification Testing
          The licensee did not ensure that all required post-modification tests
          were developed as part of modification work packages. The NRC inspector
           reviewed Change Notices (CN's) 1798 and 1798-A and their associated
          Controlled Work Procedures (CWP's) 84-92, 84-93, 84-94, 84-95 and 85-560
          which replaced Emergency Water Booster Pumps (Fire Water Booster Pumps)
          P-2109 and P-2110 with pumps having a higher output head. These pumps
          could be used to drive the helium circulator turbine to achieve adequate
          core cooling in the event of the failure of three feedwater pumps. The
          CWP's for this modification did not contain post-installation flow tests
          for the new emergency water booster pumps. The failure to develop adequate
          controls to ensure that all required post-modification testing was conducted
          was discussed with the licensee and will remain an unresolved item pending
          review by Region IV (50-267/85-26-06).
       6. Unresolved and Open Items:
          Unresolved items are matters about which more information is required to
          determine whether it is an acceptable item, a deviation, or a violation.
          A open item is a matter that requires further review and evaluation by
          the inspectors. The following unresolved and open items will be followed
          by the NRC Region IV office.
          (50-267/85-26-01) (0 pen Item) Tha revision of equipment control procedures
          to establish compliance with TMI Item I.C.6. This item will remain open
          pending NRC Region IV acceptance of the revised procedures (Item 2.a(1)).
          (50-267/85-26-02) (Unresolved) The failure to establish adequate procedures
          for control of temporary plant modifications, station battery maintenance
          and surveillance tests, and motor operated valve maintenance. Also, the
          apparent failure to comply with procedures for battery surveillances and
          motor operated valve maintenance (Items 2.a(2), 3b, 3c, 4b, and 4c).
                                                                    . - -               - _ - - - -
                       ,,     -        .           .-   - . - - . _
                                                                                    .

, . *

                                             _ 12 -
        (50-267/85-16-03) (0 pen Item) The revision of housekeeping procedures to
        provide a means for ensuring specific deficiencies are corrected.   This
         item will remain open pending NRC Region IV acceptance of the revised
        procedures (Item 2.c).
        (50-267/85-16-04) (0 pen Item) The adequacy of the diesel generator valve
        lineup procedure to ensure the availability of the system. The item
        will remain open pending NRC Region IV followup of potential weaknesses
        in the lineup procedure (Item 2.d).
        (50-267/85-26-05) (Unresolved) The failure to procure safety-related
        replacement items in accordance with the QA plan requirements (Item
        4.a).
        (50-267/85-26-06) (Unresolved) The failure to establish adequate
        controls to ensure the performance of required post-modification
        testing (Item 5).
     7. The findings of this inspection were discussed with those persons indicated
        in paragraph 1 on August 29, 1985.
                                 - _ _ . . _
                                                  -
                                                    . -__ -..     .                   - . _ _ .

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