ML19352B000
| ML19352B000 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 04/01/1981 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19352A997 | List: |
| References | |
| P-81111, NUDOCS 8106020531 | |
| Download: ML19352B000 (8) | |
Text
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e PUBLIC SERVICE COMPANY OF COLORADO 6
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8CX 8*O DENVER COLomACC SC101 OSCAR R.1.EE Acril i, 1981
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Fort St. Vrain Unit No. 1 P-81111 Mr. G. L. Madsen, Chief Reactor Projects Branch l4uclear Regulatory Commiscion Region IV, Regulatory Operations P. O. Box 5039 Arlington, Texas 76012 Docket flo. 50-267/81-02
Reference:
I & E Inspection 50-267/81-02
Dear Mr. Madsen:
This letter is in response to the Notice of Violation received as a result of inspections at this facility during the period January 26-30, 1981. The numbering of this letter is consistent with that in the flotice of Violation l
and pertains to tne two violations cited (A and B).
A.l.
Uoon notification, the Purchasing Department was advised to include the standard forms "M" with tne receiving inspector's copy of i
the Purcnase Order. After receipt of the material this copy of the P.O. and its attachments will become the rc,rd for perma-nent storage. This action resolves item I and we are now in compliance with P.ocedure Q-7.
A.2.
Attachment of the standard forms "It" to the receiving inspector's copy of the P.O. provides for availability of the Procurement Documents At tne point of receipt for carrying out receiving inspections.
Inis item is resolved by action taken in item 1.
In accition, a controlled ccoy of FSV-STD-1 pertaining to Receiving, Storage and Handling associated with Quality-Related Procurement has been placed in the receiving warehouse.
A.3.
The intent of the Procurement Requisition Review Record (PRRR) is to provice a checklist for review to ensure that the appropriate i
Quality recuirements are specified in the Purchase Reouisition.
i Statement i of the PRRR requires that an appropriate Quality l
Program BE specified. A "yes" answer to this statement indicates tne requirement has been incorporated into the requisition and no cormients are required. A "no" answer requires explanation for exclusion of the requirement. The instructions in Attachment Q-4F i
810602cg3j
0 Mr. G. L. tiadsen P-81111 to Procedure Q 4 will be revised to clarify that the specified criterion or document numoer or description of the Quality Program is not required to be stated on the PRRR wnen Statement 1 is answered "yes" and tne requirement is specified in the Purchase Requisition.
Action has been initiated to revise Attachment Q-4F and will be completed by April 30, 1981.
A4 The procedures established by PSC to prepare the purchasing docu-ments and proper review of these documents by tne Quality Assur-ance personnel and others were followed. The notice of v,iolation so indicates.
The NRC I&E position is that form N110 was attached to the pur-chase order N3222 however, N110 is not adequate and additional paragraphs from FSV-STD-1 should have also been imposed.
PSC response to the individual FSV-STD-1 paragraphs follows:
G0007, G0008, G0010:
The quotations in the violation is a guidance statement from FSV-STD-1.
The Standard Packaging Statements from FSV-STD-1 are as follows:
G0007
" Inspection examination and. testing equipment util-ized to implement the requirements of this purchase order shall have an accuracy and tolerance suffi-cient to determine conformance to specified re-qui rements. As appropriate, measuring and test eouipment shall be adjusted and calibrated at prescribed intervals against certified equipment having known valid relationships to nationally recognized standards.
If no national standards ex-ist, the basis for calibration shall be documented.
Records shall be maintained and equipment suitably marked to indicate calibration status."
GOODS
" Inspection and test results shall be occumented in a suitable test report or data sheet.
Each report shall identify the item to which it applies, the procedures or instructions followed in performing the task, and at least identify the conditions en-countered which were not anticipated (including nonconformance), the identity of inspector or tester, and the completion date.
Test reports and data sneets shall include an evaluation of the ac-ceptability of inspection and test results and provide for identifying the individual who per-formed the evaluation."
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Mr. G. L. Madsen G0010
" Record copies of completed procedures, reports, personnel qualification records, test equipment y
calibration records, test deviation or exception records, and inspection and examination records required by this purcnase order shall be prepared, maintained and made available to PSC when requested."
The purchase order prepared by PSC included the following statements:
A manufacturer's certificate of comoliance with material speci-I fication grade class and heat treatment condition, as applic-able are required for valve body and bonnet supplied on this order.
All valve bodies on tnis order shall be hydrostatically tested in accordance witn the manufacturer's specification. Hy dro-static test water shall have a maximum chloride content of 1 ppm and a Ph of 5.8 to 8.0.
Substitutions - The manufacturer or model number of material specified on this P.O. may "not" be substituted without the prior approval of PSC.
Quality Records - Two (2) (Microfilm Quality) conies of all required certifications and documentation scecified by this P. O. Shall be supplied as follows:
one (1) copy shall be included with the material when shipped.
one (1) copy shall be mailed to the OA/0C Supervisor, Public Service Company of Coloraco,16805 Road 191/2, Platteville, Colorado 80651.
e Manufacturer QA Program - Material supplied on this P.O. must be produced in accordance with the material manufacturer's cuality &ssurance program which conforms to the requirements i
of 10CFR50, Appendix B, and ANSI N45.2, latest issue.
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Hydrostatic Tests - Hydrostatic test records shall be fur-nisned for the material supplied.
i Nonconformances - The Seller shall report to PSC, in writing (include any dispositioned nonconformance reports), any non-conformances whicn have been dispositioned ** REPAIR **,
- REWORK **, or ** ACCEPT-AS-I3** written against material /
i equipment on this P.O. sucn material / equipment shall not be shipped until written approval / disposition is obtained from i
PSC. All nonconformance reports and written approval to ship l
l shal'. be included as part of the ** QUALITY RECORDS ** package.
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O Mr. G. L. Madsen P-81111 PSC, by imposing tne above paragraohs required the supplier to furnish equipment documents etc. which meet or exceed the requirements of FSV-STD-1 paragrapns G0007, G0008 and G0010.
G0016 The quotation in tne violation is a guidance state-ment from FSV-STD-1.
The Standard Packaging State-ment from FSV-STD-1 is " Barrier and wrap materials shall be nonbalogenated when used in direct contact with austenitic stainless steel and nickel alloy material."
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This item was covered in the standard form N110 attached to pur-chase order N3222 which states: " Cover, plugs and caps used in cun-tact with austenitic stainless steel shall be made from nonhalo-genated materials or stainless steel."
P0019 The quotation in :ne violation is a guidance state-ment frcm FSV-STD-1.
The Standard Packaging State-ment from FSV-STD-1 is:
"Cesiccants and the materials for the desiccant bags, when used with austenitic stainless steel or nickel alloy materials, shall not be compounded from or treated with chemical com-counds containing elements in such quantities that harmful concentrations could be leached or be released by breakdown of tne compouncs under expected environment conditions (e.g.,
by radiation).
Examples of sucn compounds are tnose contain-ing fluorides, chlorides, sulfur, lead, zinc, copper and me rcu ry."
The use of desiccants was not specified in the purchase order by PSC.
The ANSI level for packaging, shipping and storage was designated by PSC as Level C.
The Vendor at his option may or may not use the desiccant to fulfill the requirement.s providino he complies with form N110 which specifies ' stainless steel materials shall be protected at all times (prior to, during and after manufacture or fabrication) from contact with other materials containing deleterious com ounds such as fluorides, chlorides, sulfur, lead, zinc, copper and mercury.
P0037 & P0038 The quotations in the violation are guidance state-ments from FSV-STD-1. The Standard Packaging Statements from FSV-STD-1 are:
l P0037 "This item shall be orovided with a nameplate marked with the information specified elsewhere in this purchase order.
The nameplate shall be in a location which is in plain unobstructed view, but not directly applied to bare austenitic stainless steel and nickel alloy metal surfaces of the item."
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Mr. G. L. Macsen P-81111 P0038 "The nameplate shall identify the following in-formation in 1/4 inch cnaracters clearly stamped on the nameplate:
Manufacturer Model Number PSC Equipment Numoer PSC P. O. Number" Form N110 attached to the purchase order specified:
" Items and packages shall be marked as follows:"
" Individual iters or pack-ages of individual items shall be identified with the following information: Manufacturer, part number, PSC P.O. number and qua nti ty. "
Form N110 states:
"each item shall be marked in ac-cordance with applicable codes and stancards for such items."
Form Nil 0 states " Identification and marking shall not be celeterious to the material and shall be designed to preclude loss due to handling, storage, shipping or as a result of en-vironmental conditions." Form N110 also states:
"This item shall be identified by marking to preserve identity.
The information
shall be stamped, etened, stenciled or otnerwise marked on the item or on tags to be affixed securely to the item in plain, unobstructed view.
The violation has a note which states:
"FSV-STD-1 does not con-tain prohibitions in :ne section on markinc of items against marking on macnii;ed surfaces."
Severti statements are made in Form N110 which prevent damage to critical or machine surfaces.
They are in brief form:
Packaging shall ---- prevent damage, deterioration or contami-nation ---.
Identification and marking shall not be deleterious to the material ---.
Storage shall ---- crevent damage, deterioration or contamina-tion ---.
Nonmetallic cover, caps ---- to protect flanged faces, threads and weld end preparations against corrosion and physical damage.
Covers, plugs ---- shall be made from nonna;ogena ec ---.
R0002 The cuotation in the violation is a guidance state-ment from FSV-STD-1.
The Standard Receiving State-ment from FSV-STD-1 is:
" Receiving and receiving inspection activities shall start i
l immediately upon arrival of items at the destination speci-fied on the purchase order and shall be performed in accord-ance with requirements of applicable PSC procedures."
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Mr. G. L. Madsen P-81111 The purchase order is a means of impoting restrictions, require-ments and contractural arrangements on the equipment and inanu-facturer.. Any requirement on the purchaser to perform work does not belong on the agreement between a Buyer and the Seller.
PSC believes that P.O. N3222 and attached from N110 fulfills the requirements of FSV-STD-1 and that the additional paragraphs as specified in tne violation need not be included as stipulated by NRC-I&E.
1 B.
Electronic parts are considered standard convercial grade compo-nents for use at Fort St. Vrain and are purchased as non-quality related items to commercial standards except for parts which are specially designed and built for Fort St. Vrain applications.
In this case, wnere a commercial standard does not establisn the necessary design requirements, the parts are ordered as Quality-Related items to referenced manufacturers specifications or other standa rds.
Action has been initiated to revise Attachment 0-4B, Item 4 to Procedure Q-4 to specify that electronic parts specially designed and built for Fort St. Vrain are considered Quality-Related.
The revision to the procedure will be completed by April 30, 1981.
The only fuel considered Quality-Related at Fort St. Vrain is the Nuclear Fuel Element Assembly which consists of the following:
a) Graphite Dowel b)
Fuel Element Grapnite Block c)
Fuel and Poison Hole Plugs Burnable Poi,uel Rod Fuel Stack /F d
son Rods e
Fuel oil used in the Standby Emergency Diesel Generator, the Emergency i
Diesel Firewater Pump and tne Auxiliary Boiler are not considered Quality-Related.
The Standby Emergency Diesel Generator and the Auxiliary Boiler fuel is sampled monthly for percent moisture and i
sediment content under Water Chemistry Fuel Sampling Procedure, WCP-12.
The Standby Emergency Diesel Generator Fuel is sampled 1
quarterly for viscosity and percent moisture and sediment content as required by Tech. Soec. Surveillance SR 5.2.10.a.2-0 The exist-ing requirements for sampling of fuel oil are considered acceptable to ensure fuel quality and operability of the referenced equipment.
l Action his been initiated to revise Attachment Q-48, Item 5 to Procedure Q-4 to specify that the Nuclear Fuel Element Assemblies
- are Quality-Related. This activity will be completed by April 30, 1981.
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Mr. G. L. Madsen P-51111 Comoliance with Criterion II and V of 10CFR Part 50, Apoendix B requirements will be accomplished by completion of the above corrective actions.
Very Truly Yours,
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OscIr'R. Lee Vice President ORL/HL3/vh t
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STATE OF COLORADO
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CITY AfID COUflTY OF DErlVER )
- 0. R. Lee, being first duly sworn, deposes and says; That he is Vice President of Production of Public Service Company of Colorado, the Licensee berein; that he has read the foregoing 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.
- 0. R. Lee i
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4 Subscribed and sworn to before me this 2nd day of April, 1981.
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Witness my hand and official seal.
My commission expires:
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