ML20113C576
| ML20113C576 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/28/1985 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-85108, NUDOCS 8504110701 | |
| Download: ML20113C576 (9) | |
Text
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public Service Company P OnkedIo 16805 WCR 19 1/2, Platteville, Colorado 80651 March 28, 1985 Fort St. Vrain Unit No. 1 P-85108 M@EDWE N Regional Administrator j
t n-M. E. H. Johnson M
25 U. S. Nuclear Regulatory Commission J
611 Ryan Plaza Drive, Suite 1000
~
Arlington, Texas 76011 Docket No. 50-267
SUBJECT:
I&E Inspection Report 84-29
REFERENCE:
NRC Letter dated 02/26/85(G-85072)
Dear Mr. Johnson:
This letter is in response to the Notices of Violation received as a result of inspections conducted at Fort St. Vrain during the period October 1-31, 1984.
The following responses to the items contained in the Notices of Violation are hereby submitted:
1.
Failure to Follow Procedures a.
10 CFR 50, Appendix B, Criterion V,
- ststes,
" 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 Updated Safety Analysis Report, Section B.S.2,
" Quality Assurance Programs."
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.. Contrary to the above, MP 12-12, " Maintenance and Repair of Control Rod Drive," Section 4.4, for the assembly of the shim motor and brake subassembly on control rod drive 21, an activity affecting quality, had a hold point and procedural steps that were not
. signed off as required.
It was also determined that a
step -had been overlooked resulting in the subsequent determination by the workers and maintenance QC that the shim motor and brake subassembly had been incorrectly assembled.
This is a
Severity Level IV Violation.
(Supplement I.D.)
(50-267/8429-02)
. (1) The corrective steps which have been taken and the results achieved:
The problem which lead to the violation was investigated by t's Maintenance Supervisor and the Maintenance QC Supervisor.
The results of this investigation show that two Apprentice Mechanics were reassembling a radioactively contaminated control rod drive shim motor inside a newly constructed facility. Due to the contamination, and in the interests of maintaining personnel exposure as low as reasonably achievable, the Lead Mechanic and the 'QC Inspector were observing the reassembly from outside the facility.
The Apprentice Mechanics were checking off their working copy of the procedure inside the facility, whereas the
. Lead Mechanic and the QC Inspector were awaiting reassembly prior to signing the original procedure outside the facility.
During the reassembly, a procedural step which was applicable to Page 19 was inconspicuous 1y placed on Page 18.
Consequently, the Apprentice Mechanics missed this procedural step.
Subsequently, the Lead Mechanic noted that the step had been missed and disassembly would be required. Rather than signing off the original of the procedure, he left a note explaining the problem to the following shift.
Corrective Steps 1.
The Lead
- Mechanic, the QC Inspector, and the two Apprentice Mechanics received disciplinary action for failure to follow procedure.
2.
The procedure was revised to place the poorly placed procedure step on Page 19 of the procedure.
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,. 3.
Better coordination methods were discussed and implemented by the Maintenance Supervisor and the Maintenance QC Supervisor.
Essentially this resulted in the placement of
.the Lead Mechanic and the QC Inspector inside the work facility, with appropriate anti-contamination protection.
4.
Maintenance Supervisors have been instructed to include procedural adherence as part of job briefing sessions.
5.
The shim motor was disassembled and reassembled in accordance with the procedure.
(2) Corrective steps which will be taken to avoid further violations:
No further corrective steps are necessary to address this procedural problem or further actions with personnel involved.
(3) The date when full compliance will be achieved:
Compliance has been achieved.
The shim motor was' reassembled in accordance with the procedure on October 24, 1984.
The cited disciplinary action was taken on November 1, 1984.
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.. b.
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 Updated Safety Analysis Report, Section 8.5.2,
" Quality Assurance Programs."
Contrary to the above, requitements for controlling and documenting safety-related design changes as contained in Procedures ENG-1,
" Procedure for Control of Changes and Modifications," G-3,
" Design Control System,"
and G-9,
" Controlled Work Procedures," were not followed as indicated below:
(1)
The construction completion notification form for design change notice (CN) CN-1629/1629A did not reference the NCRs that were issued during the modification; (2)
The cover page for reissued design change CN-1444A did not indicate that the - design background information package had changed and the CN package contained documentation of work on two hangers that were not specifically authorized by the CN; (3)
No record of controlled work procedure CWP 82-58 used in design change CN-1436B was available; and (4)
Reissues of CN-1436 did not update information changed by.two field changes that were issued during the modification work.
This is a
Severity Level IV Violation.
(Supplement I.D.)
(50-267/8429-03)
L
T (1) The corrective steps which have been taken and the results achieved:
b(1) A new Construction Completion Notification form for Change Notice CN-1629 has been initiated to reflect the NCR',
that were issued during the modification. These NCR's (84-13, 84-51 and 84-58) have been filed with the clo.,ed out Controlled Work Procedure. CWP 83-150.
CN-1629A was a document update only change notice and no NCR's were issued against it. A review of the NCR log revealed that no other NCR's were written against CN-1629A.
Effective December 5,
- 1984, Issue 6 of procedure G-9 requires the preparation of a CWP DR/NCR Page Schedule prior to transmitting DR's and NCR's for implementation.
This document lists all DR's and NCR's applicable to the CWP and is kept current by the Nuclear Construction 1
Coordinator's office. The CWP DR/NCR Page Schedule is used to ensure accurate listing of these documents for CCN preparation.
The person involved in issuing the Construction Completion Notification form has been instructed on the importance of properly completing the CCN, as required by procedures ENG-1 and G-9.
b(2) The CN-1444A Reissue Cover Sheet was not marked properly to indicate the design package change. This is considered to be a " Clerical Type" error.
CN-1444A reissue did receive a Design Verification per procedure ENG-1,
" Procedure For Control Of Changes And Modifications" which is required for reissues that affect the content of the Design Package.
The reissue did inadvertently irclude documentation for hangers 90-HA-3076 and 90-HA-3077.
During the time subsequent to the construction, which was completed on 02/20/82, and prior to the
~as-built verification, performed on 10/04/82, CN-1283 via craft action 1886 on 09/30/82 modified the subject hangers to their current configuration.
The as-built verification process for CN-1444 erroneously documented the configuration of the modified structures since the modification had already been addressed by CN-1283.
CN-1283 authorized and documented the modification properly. The documentation activity of CN-1444A for these structures was redundant and was not required. The procedure violations have been' reviewed with the Change Notice Coordinator and the Design Verifier to ensure proper understanding of the procedural requirements.
b(3) CWP 82-58 was located in the possesion of Site Engineering's on-site contractor.
This CWP and others were involved in a review process during a transition period when the old site contractor left site and the new site contractor was moving on site.
CWP 82-58 was initially written in accordance with Issue 1 of procedure G-9.
This procedure has subsequently been revised to provide additional controls regarding the proper completion and routing of CWPs.
G-9, Issue 6,
which has been in effect since 12/5/84, provides additional administrative restraints to ensure proper documentation and accountability of CWPs.
b(4) Reissues of CN-143A did not update information changed by two field changes that were issued during the modification work.
The field changes identified as DR-82-19-1-B (incorrectly identified as DR-81-19-1 in NRC Inspection Report 84-29) and DR-82-45-1-C were incorporated into CN reissue 1436G,'
approved January 8,1985.
(2) Corrective steps whi<.h will be taken to avoid further violations:
b(1) No further corrective steps are required for this item, the above mentioned procedure revisions will prevent a reoccurrence.
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.b(2) Based upon a review of ENG-1, it is our position that the existing procedures are clea-in these areas and require no revisions.
b(3) No further corrective steps are required for this item.
b(4).To reduce the probability of DR's not being incorporated into documents, PSC will develop a DR tracking system to assure that every DR is reviewed, definitive action taken to determine if document updating is required and to acknowledge that the DR is incorporated into appropriate documents as required.
(3) The date when full' compliance will be achieved:
b(1) ~ Instruction has been given relative to ENG-1 and G-9 requirements.
Full compliance with procedures ENG-1 and G-9 will be achieved for CN-1629 upon receipt of the updated and approved CCN form by the Record Center.
This will be accomplished by April 1, 1985.
.. b(2) The controlled plant documentation for the two hangers has been reviewed and found to be correct.
Since no plant documentation changes are required and no procedure changes are required, we are in full compliance at this time.
b(3) Full compliance will be achieved specifically for CWP 82-58 documentation upon satisfactory verification of the CWP and upon its return to the Record Center. Full compliance to procedures ENG-1 and G-9 has been achieved.
Clarifications provided in Issue 6 of procedure G-9, relative to CWP completion and routing, has eliminated this problem.
b(4) The tracking system will be in place by September 1, 1985.
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.- 2.
Design Verification 10 CFR Appendix B, Criterion III, requires that designs be verified or checked for adequacy by design review, simplified calculations or suitable tests, and that these measures shall be similarly employed for design changes. This requirement is amplified in the licensee's approved quality assurance program, Updated Safety Analysis Report, Section B.S.19.11, which. adopts ANSI Standard N45.2.11-1974 to implement Criterion III.
Contrary to the above, the licensee issued design changes DR-83-150-1-I and DR-82-19-1-B to change notices CN-1629 and CN-1436, which authorized safety-related modifications, based on engineering judgement for which no design verification or checking was performed.
'This is a
Severity Level IV Violation.
(Supplement I.D.) (50-E67/8429-04)
(1) The corrective steps which have been taken and the results achieved:
DR-83-150-1-I dated January 24, 1984 was issued using an engineering judgement statement to justify the deviation.
A statement was also made on the DR that a CN reissue was required to provide " Structural re-evaluation of support for reactor IA."
CN-1629 reissue A was approved by Engineering on April 17, 1984 indicating that the changes made by the-DR were " conservative."
Reissue 1629A received an Independent Design Verification.
DR-82-19-1-0 dated February 10, 1982 was issued with the following statement:
"The new hanger configuration is more than adequate seismically by Engineering judgement.
Final seismic analysis will be performed and released under CN-1283." This DR occurred during the Piping Seismic Analysis project and CN-1283 was' that project.
Due to a change in plans, the final seismic analysis was completed and included as a part of CN reissue 1436G dated January 8, 1985.
IE Information Notice 84-54 dated July 5,1984 warned against using engineering judgement statements.
An internal memo dated August 6,'1984 referencing IE Information Notice'84-54 was sent to all design personnel concerning the use of engineering judgement rather than supporting calculations.
, Public Service Company was made aware of the concern that Independent Design Verification may be required on DR's, in mid-October 1984. As a result, Public Service Company issued a directive on October 23, 1984, effective immediately that all DR's effecting Safety Related components would receive an IDV prior to the effected system being placed in service.
~ Procedures are being changed to reflect this change.
(2) Corrective steps which will be taken to avoid further violations:
No further action is required.
(3) The date when full compliance will be achieved:
Public Service Company is currently in compliance. The formal procedures will be changed and in place by September 1, 1985.
Should you have any further questions, please contact Mr. Frank.J. Novachek, (303) 571-7436, ext. 201.
Sincerely, h
J. W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/djc L