ML20034G397
| ML20034G397 | |
| Person / Time | |
|---|---|
| Site: | 07100346 |
| Issue date: | 03/03/1993 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-93020, NUDOCS 9303090453 | |
| Download: ML20034G397 (9) | |
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Public Service Public Service'
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P.o. Box 840 i
16805 WCR 191/2; Platteville, Colorado 80651 cenm co ano1-ose March 3,1993 Fort St. Vrain Unit No.1 P-93020 U. S. Nuclear Regulatory Commission KITN: Document Control Desk Washington, D. C. 20555 I
Docket No. 71-0346 i
SUBJECT:
Reply to a Notice of Violation and Notice of Nonconformance'
-i (NRC Inspection Report No. 710346/93-02)
REFERENCE:
NRC Ixtter, MacDonald to Crawford, dated February 1,1993 (G-i 93019)
L Gentlemen:
This provides Public Service Company of Colorado's (PSC's) response to the Notice of Violation and Notice of Nonconformance for the Fort St. Vrain (FSV) Nuclear Station, as described in the referenced letter.
During an NRC inspection conducted from December 1 through December 3,1992, one violation and two nonconformances were identified. In accordance with the " General i
Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2,-
Appendix C, the violation and nonconformances are addressed below-1.
Failure to Maintain 10 CFR Part 21 Records - Violation 10 CFR 21.51, " Maintenance and inspection of records," requires the licensee to assure that records are prepared and maintained to accomplish the purposes of 10 CFR Part 21.
Evaluations of all deviations and failures to comply should be retained for a minimum of 5 years after the date of evaluation.
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March 3,1993 Page 2 Contrary to the abc,ve, the inspector found that PSC could not locate documentation to establish the disposition of Fort St. Vrain Part 21 Report No. P21-0030. This report was recorded as being received on 6/21/88 and reviewed on 6/23/88, and was dee ibed as follows:
Certificate of Confirmation for specific Parker Seal shipment potentially.
falsified.
l O-Rings purchased for use in sealing the Model No. FSV-1 packaging were purchased from Parker Seals, and PSC could not produce documentation to confirm that these O-i Rings were not affected by the possible failure to comply.
1)
Admission of the Violation l
The violation is admitted. Part 21 Report No. P21-0030 was initiated by a PSC employee, for a condition observed at Fort St. Vrain that was considered to be potentially reportable in accordance with the requirements of 10 CFR 21. This report did not involve an issue that had been identified by the industry as a defect or failure to comply that could result in a substantial safety hazard in certain applications.
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Fort St. Vrain uses an evaluation team or committee to review reports initiated by individuals working at Fort St. Vrain for conditions that are potentially reportable in accordance with the requirements of 10 CFR 21. Required reports i
are prepared and submitted in accordance with the time requirements of 10 CFR
- 21. The majority of reports evaluated by this committee are determined not reportable.
Report P21-0030 was not available for review by the inspector. Furthermore,-
c this report has not been located as of this date.
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P 2)
Reason for the Violation 10 CFR Part 21 Report No. P21-0030 was not available in the Fort St. Vrain records storage facility, which is the official repository for these reports, because of a failure to follow procedure. The FSV procedure in effect in June of 1988, j
G-8, " Compliance with 10 CFR 21 Requirements," required that potential Part
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21 reports be evaluated and docum:.nted. The evaluation forms for conditions that were determined not reportable in accordance with 10 CFR 21 were required to be distributed to the Records Center and numerous other organizations. This '
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distribution was not completed.
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P-93020 March 3,1993 Page 3
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The inability to locate Part 21 Report No. P21-0030 at any other location is due to several organizational and downsizing changes that have occurred at Fort St.
Vrain since 1988. Responsibility for evaluation and processing of Part 21 reports has been transferred to different organizations. Also, durinF the transition to a decommissioning organization and the accompanying downsizing of departmental staffs, departmental and personal files have been consolidated to the extent that duplicate Part 21 files are no longer available.
3)
Corrective Steos Taken and Results Achieved PSC has searched through the departmental and personal files of individuals involved in reviewing Part.21 reports, and has been unable to' locate Part 21-Report P21-0030.
PSC has been unable to produce documentary evidence about this report, however we have contacted several individuals who were involved in the 10 CFR. 21 program at the time. These individuals unanimously indicated that Part 21 reports initiated within PSC were promptly reviewed and reported if required.
To the best recollection of the individuals who initiated the report, Part 21 Report P21-0030 involved a documentation problem with a local supplier. Since this condition was not reported to the NRC, PSC strongly considers that it was l
determined to not represent a substantial safety hazard and that it would not have affected the safe use of O-ring seals used in the FSV-1 packaging.
PSC reviewed the procedures for use of the FSV-1 packaging and determined that all seals are tested annually during a preventive maintenance pressure leak test of the cask internal volume. In addition, the seals on the lid are vacuum leak tested during each use of the cask, prior to shipment. The seals on the lid are the only seals that are normally disturbed during spent fuel loading and shipping operations. Thus, any defective seal would be identified and replaced prior to use i
of the FSV-1 packaging for transporting spent fuel.
All of Fort St. Vrain's spent nuclear fuel is currently located in carbon steel canisters in an on-site Independent Spent Fuel Storage Installation. These carbon -
steel canisters cannot be used with the FSV-1 spent fuel shipping casks, as' currently licensed, to transport spent fuel to an off-site location. Therefore, it is highly unlikely that the' FSV-1 shipping casks will be used for future fuel shipments. Prior to any future use of a Model No. FSV-1 package, the seals will be replaced, i
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P-93020 March 3,1993 Page 4 4)
Corrective Steos That Will Be Taken to Avoid Further Violations PSC personnel involved with Part 21 report evaluation have been reminded of the need to provide appropriate documentation to the records storage facility, and to adhere to all other requirements of the 10 CFR 21 reporting procedure.
PSC has reviewed the procedures and requirements for maintaining 10 CFR 21 records. Fort St. Vrain procedure DPP 2.2.9, "10 CFR 21 Process," currently includes requirements to transmit compbted 10 CFR 21 Reports to the Records Center for a retention period of five years. PSC has initiated a revision to this procedure to clarify that evaluations of defects and failures to comply, that have been determined not reportable in accordance with 10 CFR 21, shall also be maintained for a period of five years. This revision will be issued by March 12, 1993.
PSC has reviewed the report files for all other Part 21 reports identified in the Part 21 report log. An explanation for any missing documentation will be included in the files maintained in the records storage facility by March 12,1993.
5)
Date When Full Compliance Will Be Achieved Full compliance will be achieved by March 12,1993, when the revision to DPP 2.2.9 identified above is issued.
2.
Failure to Follow Procedures - Nonconformanc.c 10 CFR 71.111, " Instructions, procedures, and drawings," requires the licensee to establish procedures that include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. The licensee shall require that these procedures are followed.
Contrary to the above, the inspector found that the following activities were not conducted in accordance with established procedures:
1.
Procedure FHPWP-300-123 requires that a Quality Control (QC) person initial and date the acceptance or replacement of a set of " Heli-Coils" on the Model No.
FSV-1 packaging. The inspector found that during activities performed on 10/06/91, neither initials nor a date were documented to certify that this step had been completed.
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P-93020 March 3,1993 Page 5 '
2.
Procedure FHPWP-300-124 requires that the torquing value for the leveling studs on the Model No. FSV-1 packaging be verified and documented in the procedure.
The inspector found that on approximately 50 percent of the records reviewed, the torque value was not documented as required by the procedure.
The nonconformances for FHPWP-300-123 and FHPWP-300-124 are addressed individually, as follows:
FHPWP-300-123:
1)
Admission of the Nonconformance The nonconformance on Procedure FHPWP-300-123 is admitted.
" Heli-Coil" threaded inserts are used in the oversized holes in the top closure of the spent fuel 7'
shipping cask, Model No. FSV-1, for attachment of the lid. These inserts must be examined at each use to determine whether they need to be replaced.
2)
Reason for the Nonconformance The failure of the QC inspector to initial and date the status'of the " Heli-Coil" inserts during this use of the FSV-1 packaging was due to an oversight. The inspector did note on the procedure " Replaced with new Heli-Coils", as evidenced by his handwriting, but he did not initial and date his observation.
f 3)
Corrective Stens Taken and Results Achieved Procedure FHPWP-300-123 was reviewed to ensure that the " Heli-Coil" threaded inserts were installed as required. All bolting developed proper torque and the closure lid successfully mssed its leak test. These conditions indicate that 18 closure lid bolting was p.;perly installed.
4)
Corrective Steps Tnken to Avoid Further Nonconformances Fort St. Vrain Site QC inspectors were informed of this condition and were reminded of the need to properly initial and date inspections where required by procedures. This training was completed on March 2,1993.
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5)
Date When Full Comoliance Will Be Achieled Full compliance was achieved on March 2,1993.
FIIPWP-300-124:
1)
Admission of the Nonconformance The nonconformance on Procedure FHPWP-300-124 is admitted. The procedure specified that the Reactor Isolation Valve (RIV) leveling studs be torqued to 100 to 150 ft-lbs. and required that the final tcrque value be documented. The QC inspector initia'ed the step indicating that the torquing had been performed within the specified range, but the line for recording the final torque value was left blank.
2)
Reason for the Nonconformance The failure of the QC inspector to ensure that the actual torque.value was i
documented during this use of the FSV-1 packaging was due to an oversight.
It is common practice in many applications at Fort St. Vrain to require that bolts be torqued within a specified range, but that the final torque value need not be recorded.. This facilitates use of click-type torque wrenches that do not have dial indicators to show actual applied torque. In these cases, it is sufficient to'merely verify that the torque is within a given range. However, some applications, such as the RIV leveling studs cited by the NRC inspector, do provide a space for recording the final torque and do require that this value be recorded. The QC inspector signed the procedure step as his verification that the torque was within the acceptable range, but failed to record the final torque value.
3)
Corrective Steps Taken and Results Achieved i
Procedure FHPWP-300-124 was reviewed to ensure that all other aspects of the RIV installation were performed as required. The mechanic performing the leveling stud torquing indicated that final torques were within the specified range and no other documentation discrepancies were found.
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k P 93020 March 3,1993 Page 7 PSC reviewed a number of other FHPWP document packages and determined that torque values for RIV leveling studs were recorded as required by procedures.
PSC observed that torque values were not recorded in numerous other applications, as apparently noted by the inspector ("approximately 50 percent of the records reviewed"), where the procedure identified an allowable torque range but did not specifically require that the final torque be recorded. As discussed above, it is PSC's standard practice to specify a range of allowable torques so that click-type torque wrenches can be used, but to only require documentation of final torque values in a few specific instances.
4)
Corrective Steps Taken to Avoid Further Nonconformances Fort St. Vrain Site QC inspectors were informed of this condition and were reminded of the need to properly examine documentation at QC witness points.
This training was completed on March 2,1993.
5)
Date When Full Compliance Will Be Achieved Full compliance was achieved on March 2,1993.
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Failure to Identify Test Gauce - Nonconformance l
10 CFR 71.123, " Test Control," requires the licensee to establish procedures that include provisions to assure adequate test instrumentation is available and used. The licensee is required to assure that test requirements have been met.
Contrary to the above, the inspector found that a gauge used to perform leak testmg on the Model No. FSV-1 packaging was not identified by serial number and documented for future verification.
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P-93020 March 3,1993 Page 8 1)
Admission of the Nonconfonnance The nonconformance is admitted. PSC performs pressurized leak testing of the FSV-1 packaging during annual preventive maintenance inspections, and the NRC inspector observed that a gauge used during one of these annual leak tests was not properly identified and documented. In addition to annual preventive maintenance testing, the lid seals are verified by vacuum leak testing the void volume between the redundant 0-ring seals during each use of an FSV-1 package.
2)
Reason for the Nonconformance The failure to identify the serial number of the gauge used to perform leak testing on the Model No. FSV-1 packaging was due to an oversight on the part of the QC inspector documenting the use of this gauge.
3)
Corrective Steps Taken and Results Achieved t
During the first use of the FSV-1 cask after its preventive maintenance leak testing and during each use thereafter, the lid seals were vacuum leak tested.'
This testing confirmed acceptable package leak tightness, because the FSV-1 package would not have been released for use unless this leak test was acceptable.
4)
. Corrective Steps Taken to Avoid Further Nonconformances Fort St. Vrain Site QC inspectors were informed of this condition and were reminded of the need to properly examine documentation and ensure that test equipment is properly identified for future verification. This' training was completed on March 2,1993.
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Date When Full Compliance Will Be Achieved Full compliance was achieved on March 2,1993.
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l P-93020 March 3,1993 Page 9 Public Service Company of Colorado recognizes the need to ensure that all regulatory requirements and administrative controls are met during the use of radioactive material shipping packages, such as the Model No. FSV-1 packaging. We feel that the corrective actions identified above will heighten an awareness of these requirements and will ensure safe use of such packaging in the future.
P Based on various political restraints, PSC does not anticipate any future use of the FSV-1 casks for shipping spent fuel. We are presently under contract for the design, licensing, and fabrication of two new shipping casks that will be utilized for future spent fuel shipments from the Fort St. Vrain Independent Spent Fuel Storage Installation (ISFSI).
As we develop procedures for future spent fuel shipments, we will certainly incorporate the findings of this inspection to avoid similar shortcomings.
If you have any questions regarding this response, please contact Mr. M. H. Holmes at (303) 620-1701.
Sincerely, h$ W OStcd Don W. Warembourg Decommissioning Program Director l
DWW/SWC cc:
Branch Chief, Transportation Branch Office of Nuclear Material Safety and Safeguards (NMSS)
Regional Administrator, Region IV i
Mr. Ramon E. Hall, Director Uranium Recovery Field Office i
Mr. Robert M. Quillin, Director Radiation Control Division
- Colorado Department of Health l
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