ML20100F484
| ML20100F484 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/21/1984 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-84494, NUDOCS 8412060607 | |
| Download: ML20100F484 (4) | |
Text
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r Public Service Company *f Odedo November 21, 1984 y
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Fort St. Vrain Unit No. 1 P-84494 Regional Administrator b
Region IV U. S. Nuclear Regulatory Commissien
! $ 2,6M 3
611 Ryan Plaza Drive, Suite 10C0 t
Arlington, Texas 76011 3
Attention: Mr. E. H. Johnson
SUBJECT:
I & E Inspection Report 84-26
REFERENCE:
NRC Letter dated October 24, 1984
Dear Mr. Johnson:
This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period September 1-30, 1984. The following response to the items contained in the Notice of Violation is hereby submitted:
Failure to Follow Procedures 10 CFR 50, Appendix B, Criterion V, states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or
- drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
This requirement is implemented by the licensee's Final Safety Analysis Report, Section B.5.2,
" Quality Assurance Programs," and Technical Specification 7.4, " Procedures - Administrative Controls."
Administrative Procedure G-9, " Controlled Work Procedures," Issue 5, dated August 8, 1984, requires Controlled Work Procedures (CWP) to be prepared in accordance with the CWP Manual.
Controlled Work Procedure Manual, Issue 1,
dated October 16,
- 1981, Attachment CWPM-1C,
" General Mechanical Planning Considerations and Mechanical Planning Checklist," requires that for installed systems and components that should be cleaned, flushed, and conditioned in accordance with ANSI N45.2.1-1973,
" Cleaning of Fluid Systems and associated Components during the Construction Phase of Nuclear Power Plants," specific steps should be specified in the CWP to accomplish this.
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.g 2-L Contrary to the above, the NRC inspector determined that the CWPM was not being used during the preparation of CWPs. Specifically, the NRC
. inspector. determined that the required flushing requirements had not been incorporated into CWP 84-113 for the modification to the high pressure separator piping on Lcop 2.
This is a Severity Level IV Violation.
(Supplement I.D.)
(50-267/8426-02)
As a means of clarification of the statements listed in the " Failure to Follow Procedures" the following points are presented:
The statement, "...The NRC inspector determined that the CWPM was not being used during the preparation of CWPs,"
is a
generalization of the case cited. Although some oversight in the incorporation of appropriate CWP Planning Considerations did occur, the CWPM was strictly adhered to for requirements of procedural format, installation instructions, testing, etc. CWPs for other :ctivities, in addition to the case cited, are prepared in accordance with the CWPM and Administrative Procedure G-9 requirements.
The statement, "Specifically, the NRC inspector determined that the required flushing requirements had not been incorporated into CWP 84-113 for the modification to the high pressure separater piping on loop 2" is a presumptive disposition of the cleanliness requirements.
Although ANSI N45.2.1-1973 is referenced in the FSAR, Section B.5.19.2, it is not invoked in it's entirety.
Several exceptions are taken to this specification in this section of the FSAR.
Preoperational flushing-of system modifications and maintenance work is not required in all cases, and as such, is invoked, as necessary, by Public Service Company of Colorado.
In many cases, system flushing is impractical or would be ineffective and other cleanliness practices provide the required control of foreign matter.
(1) The corrective steps which have been taken and the results achieved:
Action CWP 84-113 was reviewed for appropriate cleanliness requirements.
Due to the scope of the modification and the accessibility of piping tie-ins, system flushing was determined to be desirable and practical.
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W Other open CWPs were reviewed for the incorporation of appropriate planning requirements.
System flushing requirements were also determined to be appropriate for,CWP 84-112,. loop 1 high pressure separator piping modification, and ~ were incorporated in accordance with established procedures.
Result Preoperational flushing of the system piping for CWP 84-112 and CWP 84-113 was satisfactorily performed.
Action Site Engineering issued a memorandum, dated September 27, 1984,
Subject:
. CWP Writing, to the Coordinator, Nuclear Site Construction.
The memo stressed the importance of using the
" Planning Consideration Checklists" contained in the CWP Manual.
Distribution was made to the CWP preparation group and the subject of the memo discussed with the personnel involved.
Result CWP Planning Checklists are
- reviewed, filled out for applicability and incorporated into the review process for all CWPs. As an interim measure until formal procedure revision, all CWPs are independently reviewed, after initial preparation, to ensure that appropriate, special instructions are included.
(2) Corrective steps which will be taken to avoid further violations:
Administrative Procedure G-9 and the CWP Manual are being revised. At this time, G-9 has been revised and submitted for approval.
The CWP Manual is currently undergoing revision.
Additional emphasis on CWP Planning Considerations is being incorporated into this change.
(3) The date when full compliance will be achieved:
At this time, co:npliance has been achieved by the emphasis on inclusion of appropriate Planning Considerations during CWP presentation.
This emphasis will be formally documented in the pending revisions to Administrative Procedure G-9 and the CWP Manual.
b.
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. Should-you have any further questions, please contact Mr. Frank J. Novachek at (303) 571-7436,; extension 201.
Sincerely, a/l~
J. W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/kss 15
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