ML20082U297

Responds to NRC Re Violations Noted in IE Insp Rept 50-267/83-24.Corrective Actions:Necessary Administrative Procedures Revised to Account for Weaknesses in QA Monitoring Program

ML20082U297
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/10/1983
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20082U290	List: ML20082U297
References
P-83368, NUDOCS 8312160296
Download: ML20082U297 (7)

Text

-

4 TC NI.,

16805 WCR 19 1/2, Plattevi11e, Colorado 80651 November 10, 1983 Fort'St. Vrain Unit No. 1 P-83368 Mr. John T., Collins, Regional Administrator U. S. Nuclear Regulatory Commission NOV I 4 IS%L) 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76011 l

i

SUBJECT:

I & E Inspection Report 83-24

REFERENCE:

NRC Letter dated October 12, 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 August 1-31, 1983. The following response to'the items contained in

~

the Notice of Violation is hereby submitted:

1. Failure to Follow Technical Specification Requirements t

Technical Specification 7.4.a,~" Procedures, Administrative Controls," states, . 'in part, that, " .. .. written

procedures shall' ~be established, implemented,- and

! maintained . . . ."

Administrative ~ Procedure 'G-9, " Controlled -Work

. Procedures," Issue 1, dated August 27, 1982, Section 4.1,

~

"CWP Processing, Controlling and Implementation," states, in.part,

" SHIFT SUPERVISOR 11. Coordinates CCT's and FT's to.

plant conditions"and signs.the CWP' original at'the completion offthe;

. work and-related activities."'

831216029a 831207: .

. PDR ADOCK 0500026"I

.@ .PDR

~ ~ = _ ~

1

~

i

, . , l 4 l of, Control' "NED-SITE 13. Coor'dinates update Room / forwards CWP to QA/QC."

Contrary to the_ above, on August = 10, 1983, the NRC

. inspector determined 'that. .

Control Work Permit (CWP)82-255, which ' modified a plant. system, had beenL surrendered .due_ to work completion: on

' January- 13, 1983, with the system subsequently returned.to service _without having a written procedure to operate the 4

newly modified _ system,- without having the shift supervisor's signature on the CWP_ original verifying work-

completion, and without.having updated control room / shift ,

i supervisor design documents (piping and instrumentation drawings). The NRC inspector-. also determined-that the 4

following CWP work was. completed and the; modified system-returned to service without_ meeting .the above requirements:

CWP WORK COMPLETED 82-48 ' December. 27, 1982

• 82-83 April.6, 1983 82-173 July 22, 1983 This .fs a Severity: Level.IV Violation' .(Supplement I.D.)-

(50-267/8324-01)-

.(1) The_ corrective. steps -which have ~been taken;and the results

~

achieved:

All Cont' rolled Work-Procedures (CWP!s)_ cited have been: completed i

as required except; for- CWP '82-48' which is expected :to be .

completed- ~by November 18, '1983. In . addition, La' Qualityi

. Assurance monitoring program was: initiated to. study the. current CWP. process. . 'The. results of~ this program' presented; on-

, November 9, 1983,'in:-the presence of:::the. Resident: Inspector,

-identified : a number- of' weaknesses. Further' corrective. mea'sures; will take'these findings'into account.-

~

s.

+

4 _ en C

7 8 F

, > A a , . ]

~

7: , , - ,

.g N v . , .' ,

l l

. l t

"(2) Corrective steps which will be taken to avoid further

. violations: --

Administrative Procedures will be revised as necessary to .

account for the weaknesses identified through the Quality Assurance monitoring program complet'ed on November 9, 1983, as well as those identified in the Notice of Violation. These revisions will, as a minimum, concentrate on'the control of modification work to ensure that necessary . procedures are in effect prior to placing a newly modified system into service and that the update of control room / shift - supervisor design documents is completed as expeditiously as possible following .

the completion of the CWP.

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

e The above referenced Administrative Procedu'res will'be revised-by December 31, 1983.

2. Failure to Follow-Desion: Control Reauirements Code of Federal Regulations 10 CFR 50, Appendix'B:

Criterion III, " Design Control," -Sentence 1, states, in part,

" Measures shall be established toi assure: that' I

applicable regulatory requirements 1 and 'the design.

basis, 'as defined in Part_50.2 and'as'specified in the licensi- application, for thoseL

~ '

structures, systems, and components to which this ; appendix,

. applies- are. ' correctly ~ translated into specifications,- drawings,. procedures,. _andj l instructions. . . ."

p

Technical L Speci fication 7.4.r,

" Procedures',TAdri1 n.i strative

4 Controls," states,; in;;part,-'that, ~". -

. . , . written;

' procedures .shall' be' established, 3 implemented, ~and:

maintained. . . .": .-

~ '

l A

" ~

t a-

. . - . _ _ . . _ _ . . . _ ._ - ~

. . i l i Administrative ProcedureLP-6, " Controlled- Work

. Procedures," Issue 2, dated -August 4, 1980, Section 3.0, states, in part, "3.8 A Work Review Committee (WRC) reviews all CWP's to:"

i "b) Evaluate the effect on other plant systems, conditions or operations so _that the work can be accomplished without . compromising plant safety margins, _ violating Technical .

Specifications, administrative -procedures or endangering plant personnel protection."

Contrary to the above, the NRC inspector determined that for Change Notice / Control Work Permit CN 1295/CWP 82-122 no measures had been established to- provide updated l written procedures that would- . reflect- this plant '

modification apparently. due to the failure of-the WRC to.

evaluate the effect of this CVP on other plant systems, conditions _or operations.

This is a Severity Level. IV Violation. (Supplement I.D.). '

(50-267/8324-02)

(1) The corrective -steps whichJhave been taken and-the results

, achieved:

Written procedures ~ 1mpacted'.by. Change Notice / Controlled Work

. Precedure CN 1295/CWP 82-122 have been updated to;-reflect' - the 4

' plant modification. In addition,-the'-Quality Assurance monitoring program referenced: -in the response ito Notice:. of-

. Violation 50-267/8324-01 above addressed the activities of the.

Work Review Committee. Further corrective measures will' take

the associated findings into account.

.(2) Corrective . steps whichL will'.be~ taken 'to ' avoid :furtherf violations:

In addition to the Administrative Procedure. revisions which will, be.made in. response to-Notice of Violation 50-267/8324-02 above, an : implementing procedure will be . developed to specifically~-

^

. govern the activities ~ of .the Work 7 Review' Committeei EThis.

procedure. will provide a . formal: mechanism by which the' impact- of

, plant modifiestions on departmental procedures:can :be; identified :

'and the necessary. procedural / revisions lcan_be.made.

.+ ,

t i

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

p ,

The above referenced implementing ~ procedure will be developed by- ~

January 31, 1984.

3. Inadequate Procedure / Specification Criterion V to . Appendix B of- 10 CFR 50 states, .

" Instructions, procedures, or drawings shall include appropriate . quantitative acceptance criteria for determining that important activities have been

. satisfactorily accomplished."

Fort St. Vrian FSAR . commitments to ANSI 745.2.5 1974, Section 4.3 states, in part, " Inspections .shall be performed prior to and during the production of. concrete to verify the adequacy and proper operation of . measuring...

mixing, and transporting equipment in accordance with ACI 304, ASTM C-94, . . . ."'

ASTM C-94 states, -in part,. "When a truc'k mixer. or truck agitator is used for transporting . concrete,- discharge of-r the concrete' shall be completed within~1 1/2 hour, or-4 before the drum has revolved 300: revolutions, whichever comes first."

Contrary to ;the-.above, Deviation Report (DR)~82-206-1-H deleted this requirement .from 1 specification 75-J-02,

" Mixing and. : Deliver.ing Concrete," without. imposition-of-alternative-acceptance criteria.. .Even; though ASTM-C-947 permits relaxation of these limits, partially.as'a result of deletion of 'these~ requirements,. ' pl acements'. ~ of Building;10-W-4800-6-015 indicated :honeycom> areas, rock'-

pockets and cold joints.

This is a4 Severity Level;IV Violation.

(Suppl ement :I'.D.-)' '

(50-267/8324-05) t 3

e ~

t

_ ^' i m-

[ w 4

~~

'u, s q.,

<. y 4 ?aL ' <3 e s -

.(1) The corrective steps which have been taken and the,results ,

achieved:

ASTM C-94 permits the purchaser to waive the 1-1/2 hour discharge time and 300 drum revolutions limitation if the concrete is of such a condition-that it can be placed without the addition of water. PSC-deleted this requirement from the concrete specification (as permitted by ASTM C-94 para.10.7) in order to allow adequate time for the. concrete truck to travel from the batch plant to the plant site, to clear through' plant security, to perform the required sampling tests, and to place the concrete. It should be noted that the deletion of these .

requirements was made ay means of Deviation Report (DR) 82-206-1-D and not DR 82-206-1-H as mentioned in the NRC letter of Notice of Violation. PSC did determire that the concrete for this particular wall pour did meet. 11 of the receiving inspections and tests and was placeable, but due to other problems such as limited vibration, poor lighting,- and. delays in clearing the concrete trucks through security onto the plant site', the voids and honeycomb.in the-concrete did occur.

Prior to the next concrete placement for Building 10, PSC, undertook the necessary corrective measures as discussed with the NRC Site Inspector.to resolyn the problem with the~ voids and honeycombs. The corrective measures . included such items as-providing additional concrete vibration, better_ lighting and-work scaffold areas, and a reduction in .the amount of time required to clear the concrete trucks through plant security.

Full compliance with these items was achieved on August 5, 1983.

Upon. . implementing the- corrective measures, all remaining concrete placements on Building 10 were made without incident.

In summary, PSC does.not believe that a violation occurred when the 1-1/2 hour and the 300 drum revolution requirements _'were properly waived in accordance with ASTM C-94. It should be noted that once the voids in the-concrete were _ discovered, PSC-

took action'and stopped construction;on.the Building 10 project until the corrective actions as previously discussed .were put into- 'effect. However,. in. order oto comply with -the NRC-inspector's request, the 1-1/2 hour and~ 300! drum revolution

. requirements were . reinstated forfall of-the remaining-concrete placements. associated with Building 10. ',

l a

l%. . _ A-

3

~7-

~

(2) Corrective steps which will be taken to avoid further violations: -'

We believe this item is closed and no further action.is required.

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

Full compliance is currently met.

4 Should _ you have any further questions,. please contact Mr. L. Milton McBride, (303) 571-7436, ext. 201.

Very truly yours,-

!: ,; w. tc.,, a. l.. < , Vy *"l W * f Don W. Warembourg Manager, Nuclear _~ Production Fort-St. Vrain Nuclear

- Generating Station DW/dje 1

t

.. '-f e

1 L

E *