ML20028F241
| ML20028F241 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/19/1983 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-83026, NUDOCS 8301310297 | |
| Download: ML20028F241 (6) | |
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PUBLIC SERVICE COMPANY OF COLORADO su-X]
P. O. BOX 840 . DENVER, COLORADO 80201 OSCAR R. L.EE January 19, 1983 vu , ac=re Fort St. Vrain Unit No. 1 q P-8302 _:
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W 261983 0 Mr. John T. Collins, Regional Administrator U. S. Nuclear Regalatory Commission iJ g 611 Ryan Plaza ') rive, Suite 1000 {- a Arlington, TX 76011 u
SUBJECT:
I & E Inspection Report 82-27
REFERENCE:
NRC tetter Dated Dec. 22, 1982
Dear Mr. Collins:
This letter is in response to the Notice of Violation receivec as a result of inspections conducted at Fort St. Vrain during the period November 1, 198? to November 30, 1982. The following response to the items contained in the Notice of Violation is hereby submitted:
- 1. Technical Specification 7.4.a, " Procedures, Administrative Controls," states, in part, that, ". . written procedures shall be established, implemented, and maintained . ..
Administrative Procedure P-4, " Surveillance Testing Program,"
Issue 3, dated October 26, 1981, states, in part, "4.1.4. The person (s) assigned to conduct the Surveillance Test (Test Conductor (s)) are responsible for: . .
"d) Assembling test equipment, special tools and other items specified by the Test Procedure, and identifying them in Section 3.0 (Attachment P-4C) of the test, verifying each has been properly calibrated, if required."
O 8301310297 830119
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"e) . . . In addition each page of the procedure Section 5.0 shall be signed and dated by a Test Conductor . . . at the bottom of each page.
A Test Conductor's initials or signature is verification that:
- 1) Each step so marked has been completed satisfactorily.
- 2) The page signed has Leen completed with all required data entered.'
"f) Performing the test, in a functionally sequential order, anc ffiling in the appropriate blanks proviced upon step completien."
l Administrative Procedure P-7, " Work Control - Maincenance on Safety-Related Equipment," Issue 4, dated March 26, 1982, states, in part, "3.2 All Safety-Related maintenance and repair work must be performed according to documented instructions, procedures, or drawings of a type appropriate to the circumstances . . ."
Cc.a tra ry to the above, on November 30, 1982, the NRC inspector determined the following:
. Test equipment in use during performance of Surveillances SR 5.6.1cda-A and SR 5.6.lcdb-A had not been identified in Section 3.0 as required.
. The blank space at the bottom of the completed pages of the surveillances referenced above had not been signed / dated by the test conductor.
. Safety-related maintenance was performed without the use of documented instructions during performance of the above surveillances.
This is a Severity Level V Violation. (Supplement I.E.) (50-267/8227-01)
(1) The corrective steps which have been.taken and the results achieved:
. The test equicment used during Surveillances SR 5.6.leda-A and .S R 5.6.1cdb-A has' been identified in Section 3.0 as required.
. The blank space at the bottom of the completed pages of the . surveillance referenced above, has been signed / dated by the test conductor.
. A PTR was generated to cover the safety-related maintenance that was necessary to complete the surveillance.
(2) Corrective steps, which will be taken to avoid further violations:
. A memo was given to all Results personnel. This memo established guidelines which will be followed when using test equipment during a surveillance.'
. A memo was given to all Results personnel. This memo established guidelines, which will ~be followed when signing / dating a surveillance.
. A memo 'was given to all Results personnel. This memo established guidelines which will be followed when performing maintenance on safety-related equipment that is' necessary to complete- the surveillance.
(3) Date when full compliance will be achieved: 02/15/83
- 2. Technical Specification 7.4.a,- " Procedures, Administrative Control s," states, in part, that, ". . . written procedures shall be established,. implemented, and maintained. . . ."
Maintenance Procedure MP 12-6, " Maintenance and Repair of Control Rod Drive and Orificing Assemblies," Issue 10, dated September 14, 1982, states in part, "4.11 RAISING OR LOWERING THE 200 ASSY"
"4.11.14 At tacnr.;e n t dynamometer between lifting plate and sling attached to crane."
"4.24.4 Disconnect slack cable switch subassembly (-280) as follows:"
"d) Disconnect slack cable subassembly from closure housing (-275) by removing two 3/8 In. sockethaad scress (-200-88). Once screws a.e removed, weight of mechanism will tend to pull entire slack cable housing down until dowel pin (-280-13) and register on housing become disengaged. When this is done, assembly can be pulled off gear box housing spindle . . .
" Workman "
l Contra ry to the above, on November 17, 1982, the NRC inspector !
determined, during the installation of the slack cable subassembly with the 200 assembly raised, that a dynamometer was not attached as required by step 4.11.14 and the procedure i section 4.24.4 for removal of the subassembly had not been signed off as required by MP 12-6.
This is a Severity Level V Violation. (Supplement I.E.) (50-267/8227-02)
(1) The corrective steps which have been taken and the results achieved:
The workman was informed that when he must deviate from this procedure he must obtain a procedure deviation report and that blanket deviations do not exist. It is not anticipated that this problem will occur in the future.
The procedure, 4.24.4 has been signed off as required by MP 12-6.
(2) Corrective steps, which will be taken to avoid further violations:
MP 12-6, step 4.11.14, will be revised to reflect the optional use of a dynamometer.
A memo will be given to all Maintenance personnel.
This memo will establish guidlines which will be followed when signing / dating Maintenance Procedures.
(3) Date when full co,tpliance will ce achieved; 02/15/83 Very truly yours, N-scar R. Lee ORL/pib
i s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter ')
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Public Service Company of Colorado ) Docket No.. 267 Fort St. Vrain Unit No. 1 )
i l AFFIDAVIT l
l . . . . being duly sworn, hereby deposes and says'that he is Vice President of Electrical Production of Public Service Company of Colorado; that he is duly authorized' to sign the file with the.
Nuclear Regulatory Commission the atteched response to the Notice of Violation identified in NRC Inscection Report 82-27; that he.is-familiar with the content thereof; and that the matters' set forth therein are true and correct to the best of his knowledge, information and belief.
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- 0. R. Lee 1
Vice President-of Electrical Production STATE OF hm6A00 )
) ss COUNTY OF 96N t/cT- )
Subscribed and sworn to before me, a Notary Public in.and for..
on this lo d day of TANVillL/ ,19h l
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CLEO.E Notary Puolic '~
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I My commission expires GT 06 CO2- 7,1923 4
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