ML20086M886
| ML20086M886 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/24/1984 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-84032, NUDOCS 8402170133 | |
| Download: ML20086M886 (14) | |
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PUBLIC SERVICE COMPANY OF COLORADO (6
DENVER, COLORADO 80204 P.
O. BOX 840 OSCAR R. LEE January 24, 1984 v c c m. oe,.'
Fort St. Vrain Unit #1 p-ganu Mr. John T. Collins FEB - 6 m j{
Regional Administrator U. S. Nuclear Regulatory Commission bL 611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas 76012
SUBJECT:
Fort St. Vrain Unit No. 1 Systematic Assessment of Licensee Performance, 1983
REFERENCE:
NRC Inspection Report 83-30
Dear Mr. Collins:
As a followup to the above referenced report and on site meeting on January 17, 1934, we have the following comments.
Our comments, which are keyed to the major functional areas of the above referenced report, are made to address:
1.
The written report and areas within the report which we believe need clarification from the Licensee's point of view.
2.
Overall comments indicating actions which will be considered or evaluated to attain improvement.
A.
Plant Operations On Page 8
of the Inspection Report under subparagraph 2,
the report indicates that the majority of LER's applicable to plant operations involve procedural / personnel errors.
Of the twenty-one (21) LER's listed only eight (8) of the LER's involve procedure / personnel error.
On Page 9 of the Inspection Report, the'first paragraph indicates that violations received in 1983 were more serious in nature than those received in the 1982 SALP period.
O7 QO 8402170133 840124 1
PDR ADOCK 05000267 1 0 G
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, While we are not'in a position to question the SALP Bcard conclusion that a reduction in the. number of violations from 10 to 7 may not represent significant improvement, we do not feel the report ~
7 should infer that violations were more significant in the-1983 review period.
In our opinion,-.the violations in 1983:were less significant.than those of the 1982 review period.
Also' on Page 9 of the Inspection Report reference is made to LC0 4.6.1 and an snforcement. conference resulting from LCO 4.6.1.
The report indicates the basis for these matters.as being the. Licensee's
. lack of in depth knowledge of the Technical Specifications. While there was a difference o f.
interpretation of the Technical Specifications between the Licensee and the -Nuclear Regulatory Commission, that difference was ~ primarily the result of some poorly worded-sections and definitely not due to our -lack o f.
in : depth familiarity with the Technical Specifications. =The report also indicates that theLevent points out the need.for improved' licensee communications.
.We believe the record -should indicate -that the Licensee communicated with the_ Nuclear Regulatory Commission via LER'~s -on t least eighteen (18):
a different. occasions concerning LC0 4.6.1.
Regardless of
.the:
above corrections or clarifications:to the Inspection Report, we agree:
that plant operations requires. continued management attention.
We : continue--to
'be
-concerned by pers.onnel. errors.and the procedural errors.
As we.
have indicated to you, we'have been evaluating this area since the 1982 SALP review and_are' continuing-our efforts.
In ' August.Hof: 1983 we : took; some specific actions.
.;regarding.
. failure-to-follow procedu' e errors.
These steps.
r were, outlined in; our' letter (P-83285) to you and are reiterated oc Page 40 1of the' current.SALP
' report.
We ibelt ve 'we: are starting _to see'some positive results from these~ actions.
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We are;--committed :to continue.our efforts in'this area.
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. We are also planning an everall review of the Technical Specifications in 1984 in an effort to improve them. This is, however, a major task, and it is unlikely that improvements can be made in sufficient time to have a significant impact on 1984 operations. This overall review should be helpful for future operations and is indicative of management's efforts to improve operations.
B.
Radiological Controls 1.
Radiation Protection On Page 11 of the Inspection Report several open action items are listed.
The Licensee has closed all of these action items.
We did accomplish those actions that were setforth in P-82550 as a result of the 1982 SALP review, we have had no violations or deviations, and although we did not eliminate personnel turnover and the use of contract personnel, we did reduce it.
We believe that some improvement has been experienced in Radiation Protection since the 1982 SALP review.
We intend to maintain our level of performance.
Concerning the recommended action of closing open items in a timely manner, we will strive to meet that recommendation. As discussed at the SALP
- meeting, h' wever, the Nuclear o
Regulatory Commission must also improve their review and closecut of open items, or take into consideration that, at the present time, the policy that open items must be_ closed by the same inspector that opened them, may introduce delays.
2.
Confirmatory Measurements, Chemistry /
Radiochemistry While there were some minor problems in the analyses of charcoal cartridges, primarily due to technique, these areas were resolved.
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- Improvaments have been made in the Water Chemistry area.
We Selieve we have an excellent radiochemistry progran and we will continue management-atter. tion in the water chemistry program to ensure that the progress made to date continues.
This is the first SALP-review which has included water chemistry. As we recommended in the SALP meeting we would prefer, if possible, to have water chemistry and radiochemi stry considered.
as separate areas within the evaluation.
3.
Radwaste Systems, Effluent Release, Effluent Monitoring With reference to the open items listed in the Inspection Report the Reactor Building sump was addressed in the July, 1983, update of the Final Safety Analysis Report, the surveillance program for the Technical Support Center filters is in place, and the program for the Control. Room filters is awaiting completion of the filtration system as a part of Building 10 modifications.
The violation was the result of our inability to find test records for the initial filter installation.
The filters have been tested over the -subsequent years and have always been shown to be sati sfactory.
We' received this violation for something that-occurred years 4
'ago, and therefore, it-.is inappropriate to consider this. violation' as a
performance indication.for this'SALP review.
S Concerning recommended. licensee action, 'al l -
open items have been addressed.
4.
Transportation / Solid Radwaste.
Concerning recommended licensee action, we are reviewing the new requirements of :10CFR20.-311,.
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1 5.
Environmental Surveillance We have no specific comments in this area.
C.
Maintenance In general, we feel on an overall basis our performance in the maintenance pr' gram during the o
1983 SALP review period was equivalent to that of the previous year.
We share your concern for improving the backlog of Plant Trouble Reports and improving the preventive maintenance program.
As we have stated in the past, progress in these areas is highly dependent on plant operations.
For example, we had a good operational run since mid-July of 1983 and as a result the backlog of Plant Trouble Reports and preventive maintenance has-been significantly.
reduced.
Concerning the recommended licensee action of I
emphas's on " eliminating" procedural violations, we believe that' elimination of procedural violations is an unrealistic goal.
We believe 'that our present error rate in maintenance is about as good as we can'ever expect, and most certainly -we will strive to maintain this level of effort.
D.
Surveillance As we indicated to you during the SALP. meeting we have made a concerted effort to improve
.our surveillance test program
.and
' reduce failure-to-follow procedure / personnel type. errors.
We intend to continue our efforts in this area. We agree that in spite of our increased efforts our performance in ~1983. did not-improve over-the previous year. Given the number l of surveillance activities that must be performed, some. personnel turnover, and the human factors involved, ave may not be-able_ to significantly improve overall performance.
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l Concerning-recommended licensee action we' intend to continue with the high level of attention which is already-being devoted to this program. Again, we do' not believe it is possible to
" preclude" procedural violations.
It is our objective to at least maintain and hopefully-improve our performance level by continuing the high level of management involvement that has been placed in this area.
E.
Fire Protection As we indicated in the SALP meeting we feel that not providing a rating in this area because of 10CFR50, Appendix R,
involves the area over two distinct SALP review periods. This appears to be
-contrary to your normal practice.
F.
Emergency Preparedness We have devoted a great dealoof time and effort to the emergency preparedness program at Fort St.
Vrain and we appreciate your recognition.
We are working on correction of deficiencies noted and we do plan to maintain a high level -of effort in the continued development of emergency preparedness programs.
G.
Security and Safeguards On Page 25 of the. report we were charged with two violations in the area of security and safeguards.
We believe that violation 8320-01 was a highly.
questionable violation'in the first place.. We 'had discovered.the oversight of the audit.' distribution ourselves. We.also-explained to the inspector that-the audit report was : reviewed by the Nuclear.
Facility Safety Committee which is chaired -by :the-corporate management individual-responsible for-reviewing the audit.
Certainly the review. intent of-;the audit ~ distribution had been met and yet we-received an Level.IV violation.
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. We' recognize that violation 8320-01 falls into the functional area of security, but we must point out that distribution of the audit report was outside the purview of the security organization.
We have placed a great deal of effort as well as dollars into improvement of the security program and your. recognition of these efforts is appreciated.
We intend to maintain a
high performance level in this area.
H.
Refueling We have no specific comments in this area.
I.
Licensing Activities The report in this area -was critical of Public Service-Company as follows:
There is a perception that we have a tendency to take the position that new Nuclear Regulatory.
Commission.
requirements are applicable only for water cooled reactors and are not applicable to the HTGR.
Public Service Company's responses to Nuclear Regulatory Commission initiatives were delayed and when received, did not provide sufficient detail to permit licensing decision.
There were instances during this assessment in which management involvement was not as apparent as the Nuclear Regulatory Commission would like it to be.
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4 We share your concerns on these subjects, but believe that your assessment of the situation does us an injustice. Whenever a new Nuclear Regulatory Commission regulation is issued, we give the document a thorough review and make a conscientious effort to adopt its provisions to the unique character of the HTGR. This review and interpretive effort constitutes a special burden for Public Service Company, because many of the new Nuclear Regulatory Commission regulations
- are, in fact, water reactor oriented.
Given these circumstances, it is reasonable to expect the Nuclear Regulatory Commission and Public Service Company to hold different views from time to time on how to apply (or even whether to apply) certain new regulations to the HTGR.
It is also reasonable to expect delays to occur while such differences are being resolved, especially since the Nuclear Regulatory Commission often relies upon. third party organizations for technical support.
Such differences and/or delays should not be interpreted by the Nuclear Regulatory Commissian as a lack of responsiveness to Nuclear Reg'ilatory Commission initiatives or as a lack of management involvement. We'wish to reassure the Nuclear Regulatory Commission that management involvement in Nuclear Regulatory-Commission related matters has been and will continue to be a basic policy of this Company.
We consider it unfair for the Nuclear Regulatory Commission to censure us on this subject without' also acknowledging.that the Nuclear Regulatory Commission.is responsible for a portion of the problem.
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We note under the category of' reportable events inference to delays in submitting reports and also the causes of the reports.
The steam generator tube leak was a problem area in that the evaluation was being made outside of Public Service Company.
Every eff ort was made to keep the Nuclear Regulatory Cc.nmission informed, but given the nature of tb3 analyses it took some time.
In terms of the causes of events we believe we were already evaluated under other categories for the causes. We believe it is inappropriate for this same area to be included under Licensing.
Concerning recommended Licensee action, the possibility of establishing a central contact for all licensing activities as recommended on Page 31 of the SALP report is currently under study-by Public Service Company.
If our study confirms that a central contact will produce this desired result, then Public Service Company will implement this Nuclear Regulatory Commission recommendation without delay.
In terms of our responses we intend that all our responses be complete.
We will provide more attention to this area in the future.
We intend to assess staffing levels to determine whether the present licensing backlogs are due to manpower inadequacies.
In all candor, we are ooliged to mention that 'our records indicate that the number of outstanding licensing issues have actually been reduced during the past year. Of particular note is-the reduction in the number of licensing issues that were previously on hold pending a Nuclear Regulatory Commission _ response to a Public Service Company licensing submittal.
We attribute.this latter' improvement to the Nuclear Regulatory Commission Project Manager for Fort St.
Vrain.
His responsiveness to Public Service Company's corresponden'ce is appreciated.
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Training We have no specific comment in this area. As indicated under Recommended Licensee Actions we intend to continue our efforts in evaluating and upgrading the overall training program.
K.
Quality Assurance On Page 33 of the SALP Report, we have concerns regarding the criteria and selection method used for classifying ' Notices of Violation and the Licensee Event Report attributed to -quality assurance program activities. The Licensee Event Report and the Notice of Violation concerning the temperature log were identified through audits and monitoring activities prior to Nuclear Regulatory Commission findings.
The conclusions on Page 34 of the SALP Report, for the most part,- are correct, but they must_ be tempered by the fact that, in most cases, they were identified':by the -internal quality assurance program prior to Nuclear Regulatory Commission involvement. This indicates that Public. Service Company's internal quality assurance program is effective in identifying weak or problem areas and providing corrective action to preclude further problems.
A concern in this area is that the Nuclear Regulatory Commission issues Notices ~ of Violation for items previously identified by the licensee and have been or are in the process of being corrected.
These. violations are issued with no regard to actions taken by the licensee to. correct such' problems, thus _down playing the_ importance.and effectiveness of Quality Assurance audits and corrective action recommendations. A better method would be to give the licensee some credit for identifying and correcting its own' problems.
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e c. : Concerning recommended actions, we are committed to a strong, effective quality assurance program,- and as in the past, we will continue to implement the quality requirements with special emphasis on areas of concern.
L.
DesignChangesandModifications We acknowledge ~ that activities in'the functional area of design,. design changes and modifications do exhibit some weaknesses.
We have already taken certain actions in order to_ remedy this situation and. improve performance.
For example, Procedure G-
.9 (Controlled Work Procedures) has been - reissued with extensive changes. Controlled work procedures will not be released for actual modification / system tie-in work without all required' tests, setpoint changes and procedure. changes attached.
In addition, a controlled work procedure cannot be
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closed out until a responsible person (shift supervisor) signs the document to signify that all the required work, tests and inspections are complete and that any. required operating procedure revisionsL or deviations are issued.
- Finally, representation in the-Work Review Committee has been enlarged to improve internal coordination.
In Item L.1 on Page 36 of the report, the Nuclear-Regulatory Commission citas an alleged violation identified in IE Inspection 83-24 in which~we deleted a requirement from Specification-75-J-02,.
" Mixing and Delivering ' Concrete" 1without the imposition of alternate acceptance criteria.
We are' convinced that this issue does not constitute a violation, and-sent additional information to the Nuclear Regulatory - Commission.in support of-this position - (see _-letter P-84004 dated. January 6,
1984).
Under the circumstances, we consider this subject to be an open issue until' it is. finally.
resolved, and.believe it to be inappropriate.for.
the Nuclear Regulatory' Commission to make use; of.-
unresolved issues-lin formulating their' assessment
> of a. license's performance.
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Management Control-
.0n Page.39 of the SALP Report there is an inference that seven (7) LER's are directly related-to management control.
Five (5) of the LER's involve exceeding reactor coolant dew point limits. As we indicated' in the SALP meeting these LER's occur as a normal, routine result of-' moisture ingresses.
The only way-to remove moisture in any' reasonable period of time
.is. by reactor operation which results~ in operation in the limited acceptable-range of an LC0 for periods of time.
These LER's are not-the result,.however, of lack of management involvement.
Moisture ingress has and continues to be an area of extreme management involvement as-evidenced by the following:
1.
The Licensee undertook and installe'd the helium loop split to improve overall helium circulator performance and mitigate circulator transients which can result in moisture ingress.
2.
A special Moisture Ingress Review Committee chaired by the
- Manager, of Nuclear
. Production with membership and technical input-being provided from key Public Service Company personnel _as well as highly qualified individuals from General' Atomic and Proto Power was formed to investigate moisture ingress'and recommend corrective
-action.to mitigate moisture-ingress as well as recommend actions toi enhance moisture removal once
. i t -. has 1 occurred.
The Committee has1made'several. recommendations,1 some of which.have already beenLimplemented-andl-some of which require longer. term modification ' work.
.Those recommendations which-have been implemented appearLto 'have been effective-in the last halffof.1983.
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, 3.
The Licensee has commissioned General Atomic to perform an extensive and detailed evaluation of the existing Technical-Specification regarding moisture limitations.
Preliminary indications are that existing moisture limits are too restrictive.
4.
All of the above actions indicate on site management involvement in terms of direct participation and Corporate management involvement.in terms of millions of dollars of effort committed to mitigate the problems of moisture ingress.
In the general areas of reducing violations management has taken action as generally outlined on Page 40 of the SALP report.
In the functional area of licensing there were problems experienced, some related to. lack of thoroughness on our part, some related to a lack of understanding on the Nuclear Regulatory Commission's part, and some related to changes in our organization as well as changes in the Nuclear Regulatory Commission organization. We obviously had become accustomed to working with the Nuclear Reactor Regulation Project Manager in Bethesda. We are now working with a different individual on a regional basis.
We are also working with a new Site Resident Inspector.
In general, we believe the Nuclear Regulatory Commission review in this area was some. shat shallow with reference to overall management involvement.
We have, however, recognized many shortcomingr.
throughout the various categories of the SALP Report, and we intend. to make every effort to improve these shortcomirigs in terms of management involvement.
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General We had no specific comments on Sections I, II, III, and V of the SALP report. As indicated in the SALP meeting we request that the report be made available to us in a more timely fashion in the future.
With the very short time we had to review the report, we were not in a position to respond and discuss some of the areas of the report during the on site meeting. Now that the SALP meetings are open to the public this aspect carries more importance.
Overall we feel that the performance appraisal and the on site exchange of information and discussions were very beneficial.
We have a better understanding of our shortcomings as viewed by the Nuclear Regulatory Commission and perhaps we were able to convey some of our thoughts concerning shortcomings of the Nuclear Regulatory Commission as viewed by the Licensee.
We intend to continue our efforts to improve areas of weakness and hopefully we will be able to demonstrate improvement in those areas during the next SALP review period.
Sincerely, (ELl
- 0. R. Lee ORL/alk
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