ML20078A542

Responds to NRC Re Violations Noted in IE Insp Rept 50-267/83-19.Calculations in CN-1426A Redone During Seismic Audit Program & Employees Reprimanded for Allowing Computation Errors to Go Undetected

ML20078A542
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/19/1983
From:	Brey H PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-83286, NUDOCS 8309230317
Download: ML20078A542 (3)

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public Service Compan,y W Odonde 2420 W. 26th Avenue, Suite 1000 Denver, Colorado 80211 August 19, 1983 Fort St. Vrain Unit No. 1 P-83286 Mr. John T. Collins i}0 g@] b Regional Administrator J,I-U. S. Nuclear Regulatory Commission- SEP 2W .

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i i Region IV 611 Ryan Plaza Drive, Suite 1000 J_

Arlington, TX 76011 J

SUBJECT:

I & E Inspection Report 83-19

REFERENCE:

NRC Letter dtd August 4, 1983

Dear Mr. Collins:

This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period July 18-22, 1983. The following response to the items contained in the Notice of Violation is hereby submitted:

Failure to Perform Adequate Independent Design Verification Technical Specification 7.4.a, " Procedures, Administrative Controls," states, in part, that, "... written procedures shall be established, implemented, and maintained ... "

Licensee Procedure Q-3, " Design Control System," Issue 5, effective date June 13, 1983, states, in part, "4.4.4 Design outputs for safety-related modifications are subject to a design verification process performed by qualified individuals ..."

Licensee Procedure ENG-2, " Procedure for Change Notice Design Output Pacakges," Issue 4, effective date September 1, 1982, states, in

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P-83286 Page 2 "4.1.6 Design Verification "B) Acceptable verification methods include the following:

"1- Design Review - A review of design documents such as calculations ...

"2 Alternate Calculations ...

Minimum documentation requirements: A set of alternate calculations or analyses.

"3 Design qualification Testing ...

Minimum documentation requirements: A set of test results and a test evaluation."

Contrary to the above, the independent design verification performed on CN1426A failed to note computational errors and failed to contain alternate calculations or test results.

This is a Severity Level IV Vioistion. (Supplement 1) (50-267/8319-01)

PSC Response:

The Notice of Violation contains two parts, the first being PSC's failure to identify a computational error during the " independent design verification" PSC concurs in this finding.

PSC has taken the following steps to correct the error and to prevent reoccurence:

1. The calculations contained in CN-1426A were redone during the Seismic Audit program, CN-1140 and documented on October 18, 1982, nine months prior to the inspection which resulted in the subject violation.

2. The employee who performed the calculations in CN-1426A and the employee who nerformed the independent design verification were reprimanded for allowing the error to go undetected.

3. To avoid future occurrences, two training sessions were held for engineering personnel. One session was given to all Engineering Design Personnel to insist upon continued compliance with all procedures, to review and discuss the theory behind procedures and specifically to discuss the procedure for performing independent design verifications.

The second training session was held, for Engineering Design personnel who work with mechanical and structural systems,

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P-83286 Page 3 to review in detail the methods for calculation of loads due l to uniformly distributed and concentrated weights.

PSC considers the corrective actions adequate and plans no further action.

We believe PSC to be in full compliance as of August 10, 1983.

The second part of the " Notice of Violation" states "and failed to contain alternate calculations or test results." PSC takes exception to this. second part of the violation as our procedures define the three verification methods which are . acceptable and allow the individual doing the independent design review his option as to which one'of the methods he follows. This is in agreement with ANSI 45.2.11 and 10CFR50' requirements. The NRC inspector evidently interpreted the ENG-2 procedure paragraph 4.1.6B to mean that the person performing the independent design review must follow ar.d document each of the three acceptable verification methods.

The inspection report states "the absence of alternate sets of design calculations.or prototype test results represents a breakdown 'in design controls as required by 10CFR50, Appendix B, Criterion III.

The breakdown in design controls evidenced in CN-1426A constitutes violation 8319-02 for failure to follow procedures Q-3 and ENG-2."

PSC does not agree with this finding but feels the NRC inspector incorrectly interpreted the PSC procedural requirements.

PSC believes this item to be closed and no further action required.

Very truly yours, aww H, L. Brey, Manager l

Nuclear Engineering Division HLB /JRR:pa i

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