ML20148N367
| ML20148N367 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/29/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8804060482 | |
| Download: ML20148N367 (2) | |
See also: IR 05000267/1987034
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In Reply Refer To:
Docket: 50-267/87-34
Public Service Company of Colorado
ATTN: Robert O. Williams, Jr.
Vice President, Nuclear Operations
2420 W. 26th Avenue, Suite 15c
Denver, Colorado 80211
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Gentlemen:-
Thank you for your letter of March 11, 1988, in response to our letter
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and Hotice of Violation dated February 3,1988. We have reviewed your reply
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and find it responsive to the concerns raised in our Notice of Violation. We
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will review the implementation of your corrective actions during a future
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inspection to determine that full compliance has been achieved and will be
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maintained.
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Sincerely.
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L. J. Callan, Director
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Division of Reactor Projects
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CC.
Fort St. Vrain Nuclear Station
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Manager Nuclear Production Division
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16805 WCR 19)
Platteville, Colorario 80651
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Fort St. Vrain Nuclear Station
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P. Tomlinson, Manager Quality
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Assurarce Divisicn
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(same address)
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Colorado Radiation Control Program Director
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Colorado Public Utilities Comission
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DISTRIBUTION:
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R. D. Martin, RA
- Section Chief (DRP/B)
- Project Engineer DRP/B
- RPSB-DRSS
Lisa Shea, RM/ALF
- MIS System
- RSTS Operator
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- RIV File
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D. Powers
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o.nSUcImotawo
R O WILLIAMS. JR
March 11, 1988
veg ens are
Fort St. Vrain
NucLEia onaa'cu
Unit No. I
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P-88083
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U. S. Nuclear Regulatory Commission
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ATTN:
Document Control Desk
F~~
Washington, D.C.
20555
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Docket No. 50-267
SUBJECT:
NRC Inspection Report 87-34
REFERENCES:
(1) NRC
letter, Callan to
Williams, dated February
3, 1988 (G-88026)
(2) PSC letter. Williams to
Document Control
Desk,
dated
January
6, 1988
(P-88006)
(3)
PSC lettsr. Williams to
Document Control
Desk,
dated
January
6, 1988
(P-88007)
Gentlemen:
This
letter is in response to the Notice of Violation (Reference 1)
received as a result of the inspection conducted by Messrs.
R.
E.
Farrell
and
P.
W.
Michaud during the period November 22 through
December 31, 1987.
As discussed with Mr. T. F. Westerman on March 2,
1988, an extension of this response was granted until March 11, 1988
in order to address any hRC concerns discussed at the PSC/NRC
management meeting on March 3, 1988.
The following response to the
item contained in the Notice of Violation is hereby submitted:
Inadequate Procedural Controls
Criterion V of Appendix B to 10 CFR Part 50 states, in part,
"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."
The licensee's quality assurance program as documented in FSAR,
9
Appendix B, Section B.5.5.2, states, in part,
"Each Change Notice
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package
authorizing
a
modification
or
selected non-routine
$ '5
Q<
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P-88083
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March 11, 1988
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maintenance to the Plant, or any part therenf, requires
the
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development of a Controlled Work Procedure," and "All maintenance,
inspection, and surveillance activities are performed tc procedures
duthorized
under
controls
imposed by the FSV Administra tive
Procedures Manual."
Contrary to the above:
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On December
7,
1987, a wire was incorrectly teminated
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following maintenance,
in violation of the
procedural
recuirements of Clearance
17895, causing a reactor scrcm
signal and equipment damage,
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Also, on December 7, 1987, a wire to be '.ifted during a test
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was incorrectly specified by Station
Service
Request
87509817 resulting in a loss of offsite power.
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On December 21,
1987, emergency lighting batterics were
damaged beyond repair due to the failure to establish proper
installation requirements
in Control Work Procedure (CWP)
87-47 through 56, 182, and 183.
This is a Severity Level IV violation.
(SupplementI)(267/8734-01)
(1) The reason for violation if admitted:
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The
violation
is admitted.
Licensee Event Report 87-029
(Reference 3) described the first instance
of
inadequate
procedural controls cited in the Notice of Violation. The
identified cause of the incorrect termination of the cable 7487
wire was the inattentiveness on the part of both the electrician
and the
individual who performed the subsequent independent
verification and functional test.
The identified cause of the second instance of inadequate
procedural control, described in Licensee Event Report 87-028
(Reference 2), was failure of the test procedure preparer to
properly incorporate precautions that would ensure that the
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Reserve Auxiliary Transformer (RAT) would not trip during the
test. A contributing factor was a deficiency in Station Manager
Administrative Procedure 23 (SMAP-23) which does not require that
an independent review be performed on Post Maintenance Tests.
In the third instance cited of inadequate procedural controls the
damage to the new emergency lighting systern was caused when a
,
portion
of the manufacturer's
installation precautions was
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omitted from the work instructions.
The actual installation and
,
wiring was done properly; however, the precautions related to
battery storage and re-charging when not in service were not
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included in the work instructions by the designer and therefore
not performed by maintenance personnel. When the pre-operational
test was performed, the batteries were already discharged,
resulting in boiling several
batteries dry when the charging
circuitry was energized.
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P-08083
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March 11, 1988
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PSC recognizes that although the instances cited had variable
conditions (i.e. plant status, personnel involved, work activity
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in progress, etc.), personnel error or procedural inadequacy were
present in each case.
In further discussing the cited instances
with plant personnel, PSC has determined that a primary factor in
all
three instarees was a perception by performance level
personnel
that management was emphasizing the need for plant
operation, without an adequate and simultaneous emphasis on the
need for quality work performance.
Additional
contributing
factors included the use of personnel new to Fort St. Vrain who,
although qualified to perform the work, are still becoming
familiar with new prograns, procedures, and are still
gaining
experience with Fort St. Vrain plant systems.
(2) Corrective steps which have been taken and the results
achieved:
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In the first instance,
the Superintendent of Maintenance and
Station Manager discussed this event in detail
with
the
individuals who returned the clearance on cable 7487. The
results of mislanding the lead,
including personnel
safety,
equipment damage, and associated costs were covered.
It was
emphasized that work must be performed correctly above all other
considerations.
In
the second instance- the deficient test procedure was
corrected and the affected relay was successfully tested and
verified to be operable.
Following the test, all systems and
components involved were returned to their normal configuration.
To
ensure an independent review of Post Maintenance Test
Procedures, a revision to SMAP-23 has been initiated.
in the third
instance, new replacement batteries have been
received,
installed and successfully tested.
Emnhasis
on
preparing better work instructions is an essential element being
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incorporated into PSC's overall enhancement to the design control
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program.
recognizes the need to carefully plan all
modification activities, including post modification testing, as
part of the design control process.
PSC executive management has met with instrument and control
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technicians, plant electricians and all
intermediate
levels of
supervision to discuss the importance of controlled maintenance
activities.
Proper troubleshooting techniques and the need to
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ensure accurate configuration management were also emphasized.
Executive management has also impressed upon these personnel that
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many areas of support activities
(and the quality of these
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Ictivities) have the potential
to directly impact maintenance
tasks.
PSC has a goal
of zero defects
in all maintenance
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activities which is shared by maintenance, support and management
personnel alike.
Discussions have been held with all levels of
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management to emphasize the
importance
of
quality
work
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performance as a fundamental factor in meeting plant operational
schedules. All levels of management are involved
in ensuring
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Nuclear Operations personnel are aware of the direct relationship
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P-88083
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March 11, 1908
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of quality to all activities supporting plant operations, and the
need for feedback when conditions appear suspect.
(3) Corrective steps which will
be taken to avoid further
violations:
To address the condition related to lifted leads, an interim
policy snd administrative process concerning lifted leads
has been implemented on a pilot basis. A final policy and
supporting administrative procedures are being developed
using extensive contributions from personnel who actually
perform maintenance and testing activities related to lifted
Additionally,
improvements in the post maintenance
testing program are being formulated.
Executive management
will meet with mechanical maintenance personnel to emphasize
the importance of quality work, configuration msnagement and
proper troubleshooting techniques.
Management personnel
will also be cautioned to pay particular attention to work
perfomed by newer Fort St. Vrain personnel who, although
they may be cualified by training and experience, may still
not be ccmpletely familiar with specific Fort St. Vrain
programs, procedures, equipment of systems.
(4) The date when full compliance will be achieved:
The fomal
policy and supporting administrctive procedures
related to lifted leads will be issued by May 31, 1988. The
revision to SMAP - 23 concerning an independent review of
post maintena9ce test procedures will be issued by April 30,
1988.
Executive meetings with mechanical maintenance and
management personnel will be complete by March 31, 1988.
Should
have any further questions, please contact Mr. M. H.
Holmes (you303) 480-6960.
Very truly yours.
AW4wl-
R. O. Williams Jr.
Vice President, Nuclear Operations
R0W:DG/dd
cc: Regional Administration, Region IV
ATTN:
Mr. T. F. Westerrran, Chief
Projects Section B
Mr. Robert Farrell
Senior Resident Inspector
Fort St. Vrain
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