ML20043C898

Responds to NRC Re Violations Noted in Insp Rept 50-267/90-05.Corrective Actions:Mgt Will Continue to Stress Requirement for Procedural Compliance on Ongoing Basis

ML20043C898
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/25/1990
From:	Fuller C PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-90179, NUDOCS 9006060318
Download: ML20043C898 (5)

Text

I O Public Sery ce' c' :Pc 16805 WCR 19 1/2, Platteville, Colorado 80651 May 25, 1990 Fntt St. Vrain Unit No. 1 P-90179 V. S. Nuclear Regulatory Commission ATTN-Document Control Desk Washington, D. C. 20555 Docket No. 50-267

SUBJECT:

NRC INSPECTION REPORT 90-05

REFERENCE:

NRC Letter, Collins to Crawford, dated April 27, 1990 (G 90098)

Dear Sir:

During NRC inspections conducted by Mr. R. E. Farrell during the period of February 7 through March 29, 1990, two violations of NRC requirements were identified. The violations involved a failure to follow procedures and use of an improperly reviewed procedure, as described in the Reference.

In accordance with 10 CFR 2.201, Public Service Company of Colorado hereby submits the following response to y0ur Notice of Violation.

A.

Fa u re to Follow Procedures

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10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality...shall be accomplished in accordance with... instructions, procedures, or drawings," and the licensee's approved quality assurance program requires that safety-related activities be performed in accordance with appropriate drawings, procedures, or instructions.

Contrary to the above, on February 7, 1990, an equipment operator was instructed by the test director to skip Step 5.4.27c of Surveillance Procedure SR 5.2.21-SA, Issue 23

" Semi Annual Surveillance on ACM Diesel," as the operator had experienced diffP.ulty in performing this step and the rest of the test team ha.s been allowed to proceed beyond that step already without confirmation that this step had been completed by all test participants as required by the procedure.

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t P-90179 Page 2 May 25, 1990 This is a Severity Level IV violation.

(Supplement I.D)

(267/9005-01)

(1) The reason for the violation if admitted:

The violation is admitted.

Improper radio protocol was used during the surveillance testing. The equipment operator did not verify his instructions, and the test director did not confirm an acknowledgement. This resulted in the test director's mistaken conclusion that Step 5.4.27c was completed as he proceeded with the test. When it became apparent that step 5.4.27c had not been completed, the test director instructed the equipment operator to skip the step since it was not important for the performance of the.

test.

The test crew members had all participated in the performance of SR 5.2.21-SA several times in the past and were familiar with the test.

Due to this familiarity, the test was being performed at a pace that contributed to missing a step.

(2) The corrective steps which have been taken and the results achieved:

The test was

stopped, and the crew members met with the Superintendent of Operations ($00) and the Nuclear Licensing Compliance Supervisor (NLCS). The surveillance completed up to that point was discussed in detail.

The NLCS performed a compliance evaluation on the completed portion of the test, with emphasis on the missed step.

The evaluation concluded that this missed step had no adverse impact on demonstrating operability of the P-46025 ACM transfer switch, but did pose a potential personnel safety hazard.

The 500 emphasized management's commitment to both procedural adherence and personnel safety.

An Operations Order was issued that states, "When performing procedures that require the coordination of two or more people, the coordina;or must receive and acknowledge confirmation that a step is completei prior to starting the next step unless the procedure allows concurre it activities."

A Trairing Development Request was initiated to develop a formal communi.ation training module. The Training Department inserted an INPO grod practice communication videotape into the curriculum of the Licented Operator Requalification program, and prepared a lesson plan (LR-r98.01) for formal communication training.

Communication training was formally started in Licensed Operator Requalification Program on April 23, 1990, with the non-licensed operators also scheduled to attend.

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i P-90179 Page 3 May 25, 1990 (3) The corrective steps which will. be taken to avoid further viWations:

Management will continue to stress the requirement for procedural compliance on an on going basis. Also, improved communications is a primary objective of our recently formulated Service Excellence Program in Nuclear Operations.

(4) The date when full compliance will be achieved:

LR-098.01 training is scheduled to be completed May 25, 1990.

B.

Use of Improperly Reviewed Procedure The licensee's Technical Specification (TS) AC 7.1.2.5.a requires that the Plant Operations Review Committee review all procedures required by TS 7.4(a) and changes thereto. The licensee's TS AC 7.4(a) requires written procedures for refueling operations.

Contrary to the above, on March 1, 1990, licensee personnel lifted a spent fuel shipping cask full of spent fuel from its truck bed using a procedure, " Station Service Request (SSR) 90500781," which had not been reviewed and approved by the Plant Operations Review Committee.

This is a Severity Level IV violation.

(Supplement 1.0)

(267/9005-02)

(1) The reason for the violation if admitted:

The violation is admitted. On March 1,1990, a spent fuel shipping cask was removed from its truck trailer to facilitate corrective maintenance on the trailer.

This work was appropriately performed as a non-routine corrective maintenance activity governed by Controlled Work Instructions (CWl's) prepared in accordance with Station Manager Administrative Procedure 29 (SMAP 29).

Spent fuel shipping casks have infrequently been handled in the manner used for this evolution, However, in such previous cases, the cask has not been loaded with spent fuel.

Activities performed with CWl's in accordance with SMAP-29 are not typically individually reviewed by the Plant Operations Review Committee (PORC),

since the PORC has reviewed the SMAP-29 governing

document, However, in this case, the nature of the activity warranted PORC review prior to implementation since the shipping cask was loaded with spent fuel.

For this reason, Public Service Company admits to the violation.

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P-90179 Page 4 May 25, 1990 (2) The corrective steps which have been taken and the results-F achieved:

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The CWI's were reviewed for adequacy by the PORC Chairman immediately.

L following'the event.

The instructions were quite detailed and provided information appropriate to.the circumstances.

I Routine fuel handling activities are performed via Fuel Han'dling L

Procedure Work Packages (FHPWP's), which are individually reviewed by l

the PORC prior to implementation.- FHPWP's are written in accordance with a master manual, the Fuel Handling Procedure Manual.

This-document was reviewed to determine if changes should be made 1.o l

n address corrective maintenance. activities, it was determined thtt the FHP Manual was not the appropriate place to address corrective maintenance, Cctrective saintenance on equipment necessary for defue'ing will continue to be controlled in accordance with SMAP-29. This procedure provides for PORC review of CWI!s, as applicable.

i The Manager, Nuclear Production Division immediately instructed fuel deck management personnel that all non-routine CWl's involving the handling of spent fuel will be prepared in accordance with 5 MAP-29, and will be reviewed by the PORC prior to implementation, There have i

been no recurrences of this type of event-since the date of this incident.

(3) The corrective steps which will be taken to avoid further violations:

The Manager, Nuclear Production has-documented the requirements for review of CWl's involving the non-routine. handling of spent fuel via memo PPC-90-1304, dated May 22, 1990, This memo has been distributed to all personnel and management performing fuel deck activities ~.

(4) The date when full compliance will be achieved:.

Full compliance was achieved on March 1, 1990, with the instructions

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given by the Manager, Nuclear Production Division for the non-routine handling of spent fuel.

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~Page 5 May 25,:1990'

' If? you =have. any questions or : comments concerning this' response..-

'please contact Mr.-M. H. Holmes at (303)'480-6960'

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