ML20073J787
| ML20073J787 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/24/1983 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-83118, NUDOCS 8304190407 | |
| Download: ML20073J787 (4) | |
Text
,
.e PUBLIC SERVICE COMPANY OF. COLORADO P.
O.
BOX 840 DENVER, COLORADO 80203 OSCAR R. LEE
. March 24, 1983 Fort St. Vrain v'c e "*5 =
Unit No. 1 P-83118 e
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is Mr. John T. Collins, Regional Administrator NR 81983 U. S. Nuclear Regulatory Commission L
611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76011 f
SUBJECT:
I & E Inspection Report 82-31
Dear Mr. Collins:
The following is a change in our response to Item 3 of the attached letter, P-83073.
3.
Technical Specification 7.4.a,
" Procedures, Administrative Controls," states, in part,
- that,
... written procedures shall be established, implemented, and maintained covering the activities referenced below:
"1.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972."
Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," states in part, "I.
Procedures for Performing Maintenance 1.
Maintenance that can affect the performance of safety-related equipment should be properly pree planned and performed in accordance with written procedures...."
Administrative Procedure P-7,
" Work Control - Maintenance 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,...
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8304190407 830324 DR ADOCK 05000267 PDR
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-9'- Contrary to the above, on December 27', 1982, the'NRC inspector determined that-a.section of the. safety-related piping 2"'
L1171-32 had been removed and-replaced without using documented instructions or a procedure.
.This is
- a. Severity Level IV iViolation (Supplement I.E.)
-(50-267/8231-06)
(1) The corrective steps which.have been taken and the results achieved:
PTR- #12-312 was issued with instructions. for. removal and>
replacement of line 2" L1171-D32. Although the PTR was issued.
after.the completion of replacing the line, it seems to tie the-welding documentation to-the assigned ' work.
Welding documentation was concurrent with the work progress and indicated that all work performed -was in 'accordance with applicable piping codes,
. elding procedures, inspections and w
acceptance criteria addressed in the violation, was pipe hanger 90-HA-4359 ' not being reconnected to the 3/4 sensing line. The removal of this hanger was not done as part of -the. removal.of L-1171-D32 and -therefore not addressed by the' supervisor assigning the work.
The hanger was reconnected by the Maintenance Department.
(2) Corrective steps wh'ich will be taken to avoid further violations:
To avoid future violations, a training class for all Maintenance Personnel will be conducted to review the procedure process required to handle situations of this type as they occur, additionally, the personnel directly involved were in discussion with supervisors that reviewed the work that led to this l
violation and were instructed as to correct methods of handling p
future situations.
1l e
. ~(3) The date when full compliance will be achieved:
Training classes to review the procedure process required.to handle future occurrences of like situations were conducted prior to the commitment date for full compliance by March 15, 1983, however, due to vacations, absence due to illness, and apprentice training classes off site, several of the Maintenance personnel were unable to attend.
Additional training sessions will be scheduled to pick up these people during the month of April.
Therefore, I am revising the commitment date to April 30, 1983.
Should you have any further questions, please contact Mr. Edwin D. Hill, (303) 571-7436, ext. 201.
Very truly yours,
[0p+
L Oscar R. Lee ORL/skr Attachment l
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PL3LIC SERVICE COMPANY OF COLORADO-
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BOA SeC' D E N v t R.
COLORADC'SC2OI f
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. Fecrea ry 18, 1933
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Fort St..Vrain-Unit No. I p-.
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d Mr. John T. Collins, Regicnal Administrator
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U. - S. Nuclear Regulatory Cc=mi ssion f
611 Ryan Piara Dr., Suite 1000 Arlington, TX 76012 I
SU3 JECT:
I & E InspectionfRecort 82-31 RE.::RENCE:
NRC Letter dated January 21, 1953
Dear Mr. Collins:
This letter is in resconse to' the Notice of Violation received as a result of ins:ections conducted at Fort St. Vrain curing tne ceriod Dece.ter 1-31, 982.
The follcwing resocnse to the items contained
}
in the Notice of Violation is hereby submittec:
1.
Technical Scecification 7.4.a,
" Procedures, Administrative Controls," states,
.i n part,
- that,
. written procecures shall be established, icolemented, and maintained...."
Administrative Procecure P-1, " Plant 0:erations," Issue 7,- dated July 22,1982, states, in part, that, "4.7 EOU1FMENT CEARANCES AND OPERATIONS DEVIATIONS l
Procedure P-2 cescribes the system for issuing and controlling ecuisment clearances anc coeration caviations to a ssure tnat:
"c.7.2 Coerations eersonnel are knowledgeable of eouicment which is tagged ano not available under clearance or off-normal oceration condition."
Contrary to the ab:ve, on December 30, 1982, the NRC inspector deta rmi n ed that Valve HV-6314-6 was shut isolating. Radiation Transmi t.a rs RT 6311-1 and RT 631?-2 clacing the system in an off-normal condition without c arations personnel knowledge and without the issuince cf a cl?arance or o;erations deviation.
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u 2 CX u tN o m s m J m
f This is a
Severity Level V Violation.
(Supoiement I.E.)
(50-257/8231-02)
(1) The corrective stens which have been taken and the results achieved:
I::ediately u::on being notified by the NRC insoector of tne situation, it was corrected which placed the system into the corre:: cperating configura.icn.
(2) Corrective steos which will be t2 ken to avoid furtner violations:
All of the su ervisory cersennel charged with the. cay to day administration of F-1 were advised to discharge their duties, such that adherence to F-1 and all other such procedures is attained.
(3)
The date w.nen full cecoliance will be achieved:
Full cc::liance was achievec ::erationally en December 30, 1932.
C:r re::i v e steos t a i.e n te avoic further violations were cc: leted On January 7,1932.
2.
Te:hnical Specification 7.4.a,
" Procedures, Administrative Controi s," states, in part,
- that,
"... written procedures shall be e.stablished, implemented, and maintained...."
Admini stra ti ve Proce ure F-4,
" Surveillance Testing Frograc,"
Issue 3, cated OctoDer 26, 1951, states, in part, "4.1.4.
The terson (s) assigned to conduct the Surveillance Test (Test Ccaductor(s)) are rescensible for:...."
"d)
Assembling test ecuic ent, scecial tools and other items s ecified by the Test Procedure, and identifying tham in Section 3.0.
Surv eill a nc e SR 5.t. 10-SA/BiA,
" Seismic Instrumentation Functional and Calibration Test," issued June 11, 1982, states, "5.2.1 C:n r.nct a voltmeter to Pins A and 3 of the cannon plug cn the SM.A-1 ca se.
'4hil e the SP.A-1 is running in 5 f EP 5. 7.. P., vari fy the vol ta gs >110.0 volts."
1
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_3_
Contrary to the above, on Dece=ber'4, 1982, tne NRC insoector cetermined that the - test ecuioment used in Ster 5.2.1 -had not been entered in Section 3.0 and that the voltage verification
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reouired in. Step 5.2.1 had not been taken' across Pins A and B as required.
This is a
Severity Level V Violation.
(Supoiement I.E. ) -
(50-257/3231-03)
(1)
The corrective steps which have been' taken and the results achieved:
A deviation was written per the Administrative Procedures to add-the test equioment that was necessary, and to -indicate the voltage verification method used for Step 5.2.-l.
(2) Corrective steos which will be taken to avoid further violations:
Pers:nnel i r.vol ved i r.
the test-were reminded of tne correct rethod ;c ad:
es e;ui omer.: to this test and in addition that surveillances are to be performec as written unless modified by a deviation in accorcance with the Administrative Procedures.
In addition a memo will be sent out to all Results personnel to indicate the cm ruct me:hocs concerning the above.
The test will be revised to indicate the procer test equipment recuired.
(3) The date when full ccmoliance will be achieved:
March 18, 1983.
3.
Technical Soecification 7.4.a,
" Procedures, Administrative Controls," states, in part,
- that,
... written procedures shall be established, imolemented, and maintained covering the activities referanced below:
"1.
The applicable procedures recommended in.'poendix A of Regulatory Guide 1.33, November 1972."
Regulatory Guide 1.33, " Quality Assurance Program Requirements
. (C;:aration)," states in part,
-am-r--
r
,_4 "I.
. Procedures for Performing Maintenance
~'
1.
Maintenance.that can: affect the performance of safety related. e::uipment should;. be' properly pre planned and performed in accordance.with written procedures..
Admini str a ti v e. Frecedure P-7,
" Work Control - Maintenance on Sa f e ty-Re l a t ed Ecui; rent,"
Issue 4,
cated March 26, 1932, states,. in.part, "3.2 All Safety-Related Maintenance and recair work must be cerformed according.
to cocumented instructions, p rocedures,...."
~
Contrary to the above,.cn December 27, 1932, the-NRC inscector determined that a section of the safety-related-piping 2"
L1171-32 had been. removed a'nd replaced without using documented instructions or a procedure.
This is a
Severity Level IV Violation.
(Supo'.ement I.E.)
(50-257/5231-06)
(1)
The corrective steps which have been taken and the results achieved:
PTR #12-312 was issued ith instructions for removal anc reolacament of line 2" L1171-032.
Although the PTR was issued after the comoletion of replacing the line, it seems to tie the welding documentation to the.
assigned work.
Welding documenta ti on was concurrent with the work progress and
. indicated that ali work performed was in accordance witn apolicible piping codes, welding procedures, insoections and accectince criteria addressed in the violation, was pipe hanger 90-MA-a359 not being reconnected to the 3/4" seasing line.
the removal of this hanger was not done as part of the removal of L-1171-032 and therefore not addressed by the supervisor assigning the work.
The hanger was reconnected by the Maintenance Decartment.
O e
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1,.,..;
O A
_5 (2) Corrective steps
-Which will be taken 'to ' avoid further violations:
To avoid future violations, a. training class for all Maintenance Personnel will be conducted 'to review.the procedure process-reouired to handle' situations of this-type as they occur, addi onally, the personnel directly involved were in discussion.
witn su:ervisors tha: -reviewed' the work that ied to this violation anc were instruc.ec as to correct methocs of - handling future situations.
(3) The date when full concliance will be achieved:
Full c:maliance will be' achieved by March 15, 1933.
Should
-you have any further cuestions, please contact Mr. Edsin D. Hill, (303) 571-7436, ext. 201.
~
Very truly yours, hou I.'
Oscar R. Lee GRL/skr e
4 4
e em
R4 IE 01
Title:
INSPECTION REPORT / NOTICE OF VIOLATION
'b/
Date of Document Docket 50-267 h-63/ /
Date Received N ~
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Document Control Desk Rids Code H005 (Region copy, NRC, PDR, LPDR, NSIC, NTIS)
-Region IV Internal:
Region IV External:
Region IV Supense Copy State: Colorado
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Enforcement Coordinator
/
RRI
/
P. Wagr.er O'ridiAabsenftEDMB*5 ~
REGION IV ROUTING:
NRR OVERSIGHT:
J. Gagliardo NRR / ORB 3 / BC - R.A. Clark
/
J. Collins NRR / ORB 3 / PM - C.Trammell
/
P. Check NRR / DL / ORAB
/
R. Bangart NRR/
G. Madsen NRR Section Chief NRR NRR NRR NRR Copies Required
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Copies Received
/
Other Letter only
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AEOD s-
- File Copy ELD IE DRP/ORPB
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ACRS (2) /
- One copy distributed unless otherwise indicated ( )
- Original file copy will be returned to RIV M