IR 05000267/1986009

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/86-09
ML20210S439
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 09/30/1986
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Robert Williams
PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 8610080138
Download: ML20210S439 (2)


Text

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C In Reply Refer To:

Decket: 50-267/86-09 ccn 3 0 W Public Service Company of Colorado ATTN: Robert O. Williams, Jr.

Vice President, Nuclear Operations P. O. Box 840 Denver, Colorado 80201-0840 Gentlemen:

Thank you for your letter of September 10, 1986, in response to our letter and Notice of Violation dated July 25, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, o3.icina SicMd D

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J. E. Gagliardo, Chief Reactor Projects Branch cc:

J. W. Gabm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 191 Platteville, Colorado 80651 L. Singleton, Manager, Quality Assurance Division (sameaddress)

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Companyof Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 September 10, 1986 Fort St. Vrain Unit No. 1 P-86543 Regional Administrator Region IV U. S. Nuclear Regulatory Commission Vggg/^M% .

611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 SEP 151986 Attention: Mr. J. E. Gagliardo, Chief .

N Reactor Projects Branch _

Docket No. 50-267 SUBJECT: I&E Inspection Report 86-09 REFERENCE: NRC Letter, Gagliardo to Walker, dated 7/25/86 (G-86407)

Dear Mr. Gagliardo:

This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period March 31 through April 4, 1986. The following response to the items contained in the Notice of Violation is hereby submitted:

During an NRC inspection conducted on March 31 through April 4, 1986, one violation of NRC requirements was identified. The violation involved failure to follow procedures and failure to control design changes. In accordance with the provisions of 10 CFR 2.201 the violation is responded to as follows:

Failure to Have Document Control 10 CFR Part 50, Criterion VI, and the Fort St. Vrain approved Quality Assurance Plan require that measures be established to control the issuance of documents such as drawings, including changes thereto, for all activities that affect quality.

Contrary to the above, two schematic drawings (E - drawings), used by a technician to determine control circuit logic in accomplishment of ph

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P-86543 -2- September 10, 1986 maintenance work on Station Service Request (SSR) 86503939, were not up to date.

This is a Severity Level IV violation. (SupplementI)(50-267/8609-01).

1. Reason For Violation The setpoint was changed via set point change report # 83-26 on 6/16/83 and the master setpoint list was changed to reflect the new setting. The E-1203 was not changed to reflect this new criteria (Nochangenoticewasissued).

2. Corrective Steps Taken and Results Achieved

. A Procedure Deviation Report will be written against Procedure Q-6, " Document Control" as an interim correction. This PDR specifies that the Master Setpoint List documents equipment setpoints and that all other documents which contain setpoint information may not reflect current setpoint values. This is consistent with the current practice utilized for the P&I drawings.

This action procedurally confirms that setpoint information may be obtained only from the Master Setpoint List and that any setpoint information contained in other documents is for information only. Resolution of conflicting setpoint information contained in other documents is thereby achieved on an interim basis.

Although this position is consistent with our past practices, a permanent solution is being prepared in the form of a revision to Procedure ENG-1. This will provide for documenting setpoint changes via the Change Notice system for those drawings which are subject to special handling documents, i.e. the E-1203 schematics, P&Is, IBs and ICs.

3. Corrective Steps To Avoid Further Violations Procedure ENG-1, " Control of Modifications and Documentation Changes", will be modified to specifically address documentation changes due to setpoint changes. This procedure change will provide for design engineering review and concurrence with the change, and initiate updating of the special handling documents. .

Upon establishment of this procedure change, the Master Setpoint List and special handling documents will be reviewed and the special handling documents will be brought current via the change notice process. This will require a significant effort, as there are approximately 2400 drawings involved.

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P-86543 -3- September 10, 1986 Upon completion of the drawing update program, the interim change to Q-6 will be rescinded for these drawings. Although the Master Setpoint List will continue to be designated as the controlling document, this long term solution will maintain current setpoint information on those designated special handling documents.

The applicability section of SMAP-6 will be revised to state that SMAP-6 is not applicable if the set point change constitutes an alteration to the design of the affected system, and to send the canary copy of the set point change report to NED-Site.

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4. Date When Compliance Will 8e Achieved The interim corrective action to revise Procedure Q-6 will be completed by September 15, 1986. Establishment of the setpoint change notice program will be complete by March 31, 1987. Review of the Master Setpoint List, updating of the special handling documents and revision of Procedure Q-6 will be complete by January 1988.

Should you have any further questions, please contact Mr. M. H.

Holmes,(303)480-6960

Sincerely,

/J . W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/RLC/gim