ML19352A939

Responds to NRC 810408 Ltr Re Violations Noted in IE Insp Rept 50-267/81-05.Violation Disputed Since Mods to Masonry Walls Completed Before Insp.Sys Operability Review Based on Old Configuration Unnecessary

ML19352A939
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/06/1981
From:	Lee O PUBLIC SERVICE CO. OF COLORADO
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19352A935	List: ML19352A939
References
IEB-80-11, P-81139, NUDOCS 8106020374
Download: ML19352A939 (3)

Text

.

~

pubne service company te Cdendo May 6, 1981 Fort St. Vrain Unit No. 1 P-81139 Mr. W.C. Seidle Nuclear Regulatory Commission, Region IV Chief Engineering Inspection Branch 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

Subject:

Response to Violation IE Report 8105

Reference:

G-81069 Gentlemen:

This letter is in reply to the notice of violation, dated April 7, 1981, Docket No. 50-267 with regard to IE Bulletin 80-11 concerning masonry block walls. The notice of viola-tion states that no systeus were analyzed for operability nor was a report made to the NRC concerning results of such analysis.

As requested by IE Bulletin 80-11, a reevaluation of the design adequacy of the masonry block walls that had the potential of affecting Class I systems, was made. Upon com-pletion of the evaluation, a total of sixteen (16) masonry block walls were found to require additional reinforcing in order to withstand a seismic event. No system operability analysis was made at that time. To evaluate the operability of a Class I line, that is in the proximity of a masonry block wall, a number of hypothecial assumptions must be made in order to show failure of the system, auch as the wall f alling over to a horizontal distance equal to the height of the wall and the affects of imp;ct loadings on steel pipe.

It should be noted that we had no Class I pipe hangers at-tached directly to the masonry block walls. It was our decision that the best approach was to proceed directly with the required modifications. A change notice was prepared and the sixteen walls were reinforced within 120 days of our response to IE Bulletin 80-11.

8198020374

. ?-81139 -

Pzgo 11 April 6, 1981'

- All wall repairs were completed prior to ' the March 16-18, 1981 NRC site inspection. Since all modifications are com- q plate, it is fe lt that a system operability review at this time. based on the original wall configuration would serve no useful purpose.

The corrective action taken to those walls in which the analysis showed deficiencies, was to design reinforcement that was attached to the outside of the wall in order to prevent failure of the wall due to a seismic event. The result was that all masonry block walls are now seismically qualified.

The corrective action taken to avoid further violations of this type was that the employees to whom -the bulletin was assigned have been verbally instructed that in the future closer attention is to be made to answer each question ex-actly as outlined in the bulletin.

PSC is committing to a June 19, 1981 completion date for the additional items committed to during the March 16-18, 1991 NRC site inspection. Documentation of these items will be available' on cite for review by the IE inspector.

The date of full compliance of the masonry block walls with regard to IE Bulletin 90-11 is June 19, 1981.

Respectfully ,

$b &

O. R. Lee, Vice President Production ORL/ RAG:pa 4

e

_ - - - - - - _ _ _ _ _ _ _ _ _ _ __________m __ _ _ _ _ , -- ,_....y.. w-y--w , y --+-g-

a . . ,

STATE OF COLORADO )

ss.

. CITY AND COUNTY OF DENVER)

O. R. Lee being first duly sworn, deposes and says; .

That he is vice President of Production of Public Service Company of Colorado, the Licensee herein; that he has read the response to Notice of Violation and knows the contents thereof, and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

A O. R. Lee l

Subscribed and sworn to before me this 6th day of tiay, 1991.

Witness my hand and official seal.

15/C; :t3 2 n E.gfr:s/ug.13,1533 My commission expires: .

7 4 b" '

Notary Public