ML20197F381
| ML20197F381 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/31/1988 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| P-88187, NUDOCS 8806130084 | |
| Download: ML20197F381 (7) | |
Text
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' dr7cEso201<mo on R.O. WILLIAMS, JR.
?ubt??$5?Nmons May 31, 1988 Fort St. Vrain Unit No. 1 P-88187 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Docket No. 50-267
SUBJECT:
NRC Inspection Report 88-08
REFERENCE:
NRC letter Callan to Williams dated April 27, 1988 (G-88136)
Gentlemen:
This letter is in response to the Notice of Violation received as a result of the inspection conducted by Messrs. L.E. Ellershaw and I. Barnes during the period March 21-25, 1988.
By phone, on May 27, 1988, Mr. T.F. Westerman agreed that the response to this inspection could be delayed until June 3, 1988.
Therefore, the following responses to the items contained in the Notice of Violation are hereby submitted:
A.
Failure to Control Design Document Distribution Criterion VI of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance plan require measures to be established which control the issuance of drawings and that these measures shall assure that the drawings and their changes are approved and distributed to the prescribed locations.
Issue 13 of Procedure ENG-1 requires distribution of controlled design documents in accordance with the Document Distribution Handbook.
This handbook further requires that all applicable controlled design documents be stamped, and the appropriate Change Notice or Document Change Notice numbers be inserted into the blank space.
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8806130084 880531 PDR ADOCK 05000267 j
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P-88187 Page 2 4
May 31, 1988 Contrary to the above, the following conditions were identified:
1.
'The latest revised drawing had not been distributed in one instance to any of the specified locations.
2.
Several instances were noted where all designated distribution locations were not updated with the latest revised drawings.
3.
Drawings with the same revision letters had different Change Notice or Document Change Notice numbers entered.
-This is a Severity Level IV violation.
(SupplementI)(267/8808-01)
(1) The Reason For Violation If Admitted:
The violation is admitted. As explained in our meeting in Arlington with the NRC's Region IV on April 6, 1988, there was some joint I
misinterpretation by the inspector and PSC personnel responding to 3
his questions concerning the drawing control system, particularly with reference to the "Special Handling" sets versus the "Controlled Distribution" sets. The April 6, 1988 presentation served to clarify the drawing control system.
Irrespective of the misinterpretation of the system, however, an overall review of the drawing control system was conducted and the following areas were identified as problem areas:
1.
There was an overall lack of understanding of the drawing control system by some PSC individuals.
The purpose and reason for Special Handling drawings versus Controlled Distribution drawings were not well understood by our people.
1 2.
A new procedure describing Special Handling drawings was in draft form and had not been issued.
3.
In the interest of timeliness of document update, a practice of starting document update in parallel with and prior to completion
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of modification / construction activities had been in use for some time. This practice, while attempting to resolve timeliness i
- issues, introduced the possibility of error, created duplication l
of efforts, and could create additional work, a
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P-88187 Page 3 May 31, 1988 4.
The "Caution Stamping" system is human resource intensive, and, as such, introduces the possibility of error, and introduces a i
built-in lag time in drawing update just due to the physical nature of the stamping system.
In addition, "Caution Stamping" l
was carried forth into the Special Handling drawings when, in fact, stamping of these drawings in the same fashion as the Controlled Distribution drawings served no useful
- purpose, i
Special Handling drawings actually incorporated information from the CN packages which were identified by the "Caution Stamp."
5.
The date that appeared on the Special Handling drawings was the date of drafting completion. This date would not reflect the l
time required for design / engineering review and engineering release. As a result, the drawing date is misleading and could indicate a date which is two (2) to four (4) weeks prior to actual release.
6.
The Records Storage Center did not have a set of Special Handling drawings. Requests for drawings from Records Storage would result in the issuance of a Controlled Distribution drawing rather than a Special Handling set.
PSC considers that the six problem areas identified above encompass i
the three specific conditions identified by the NRC inspectors in this violation.
PSC believes the corrective actions described below fully resolve the three specific conditions identified by the NRC inspectors.
(2) Corrective Actions Taken To Date On March 28,
- 1988, imediately following the NRC exit from the
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previous Friday, Engineering and QA personnel conducted an audit of the Special Handling drawing sets.
The results of our audit in comparison with your findings are available for NRC review, if desired.
Basically, our audit revealed three (3) stamping errors, identified some lag time in getting drawings filed at the various locations, and identified some lag time in getting all locations "Caution Stamped". We must point out that our person assigned to inspect the Control Room drawings during the audit only looked for the revision number and did not note the Caution Stamps, i
The following actions are keyed to the above PSC identified reasons for the violation:
1.
On April 21, 1988 two training sessions were conducted for supervisors and managers (one session at Denver and one session at the site) wherein the drawing control system was described and
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the use and control of Special Handling drawings were emphasized.
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P-88187 Page 4 May 31,_1988 i
2.
The procedure (SEMAP-15) utilized for Special Handling drawings was finalized and has been issued.
3.
The practice of document update prior to construction completion has been discontinued.
l 4.
A PDR to the Engineering Procedures has been written and is in the review cycle.
This PDR revises the "Caution Stamping" system to incorporate the use of the Design Document Status Index (DDSI) at those designated stations for controlled drawings.
The DDSI lists all drawings along with the number of any. approved modification not yet completed which impacts each drawing.
This listing will provide the same information as the "Caution Stamp" provided in the past, provide consistency for all sets, eliminate the potential for number transposition errors and reduce the lag time for updating controlled drawings at all locations.
This PDR also eliminates the need for "Caution Stamping" all Special Handling drawings in the same manner as_ Controlled Distribution drawings.
Special Handling drawings will be stamped to identify active Temporary Configuration Reports (TCR's) only.
5.
In the future, dates on drawing revisions will reflect the engineering release date rather than the drafting completion date.
l 6.
A set of Special Hant'.ng drawings is now located in the Site Document Control office adjacent to the Record Storage Center.
7.
Procedures ED-100 and SMAP-18 both now identify TCR's as Temporary Configuration Reports.
(3) Corrective Step Which Will Be Taken To Prevent Recurrence
)
PSC will continue evaluating the drawing control system with reference to the proposed changes in the design control process (see meeting minutes of April 6, 1988, PSC and NRC Region IV, Arlingten).
As PSC indicated to the NRC on April 6, 1988, PSC is working on getting all the Special Handling drawings on a CAD System as a key element in reducing document updating efforts. As a follow-up to the proposed changes listed above, PSC will meet with key employees in August to get feecNek and evaluate the effectiveness of the changes.
(4) Date When Full Compliance Will Be Achieved Corrective actions associated with Items 1, 2, 3, 5, 6, and 7 have been completed.
The PDR associated with Item 4 will be incorporated into a revision of Procedure ENG-1, to be issued by June 30, 1988, i
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P-88187 Page 5 May 31, 1988 B.
Failure to Specify QA Requirements in Procurement Document Criterion IV of Appendix B to 10 CFR Part 50 states, in part, "Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by the applicant or by its contractors or subcontractors...."
Paragraph 3.1 of Administrative Procedure Manual Procedure Q-4, "Procurement System," Issue 9, Effective Date October 24,
- 1986, states, in part, "A
procurement document shall include the technical requirements, limitations for use of the item, Quality Assurance (QA) requirements, and other requirements necessary for establishing and/or maintaining the quality of the procured material, equipment and services...." Paragraph 3.4 of this procedure states, in part, "Changes and/or revisions to technical or QA requirements contained in procurement documents are accomplished by a revision to the document...."
By letter, P-88019, Public Service Company of Colorado comitted to implement these requirements in fastener procurement.
Contrary to the
- above, Purchase Order NS446 dated December 4, 1987, to GA Technologies was noted on March 24, 1988, to have not been revised to include or reference applicable detailed QA requirements as comitted to in the Public Service Company of Coloradc letter P-88019 dated January 22, 1988.
This is a Severity Level IV violation.
(SupplementI)(267/8808-02)
(1) The Reason For Violation If Admitted:
The violation is admitted.
In reviewing this violation, PSC has identified two conditions contributing to this issue.
Due to oversight by the Helium Circulator Program Manager, Purchase Order N8446 was not revised to reflect fastener procurement requirements contained in PSC letter dated January 22, 1988 (P-88019).
- Secondly, the identification of the need for this purchase order revision was not placed into PSC's regulatory action tracking system (NRC Comitment Log) in a timely manner.
PSC does not consider this violation to be a programatic breakdown, but rather an isolated example of failure to adhere to the approved Quality Assurance Program.
Augmented Purchase Order requirements identified by letter P-88019 needed to be included into those purchase orders covering circulator fasteners.
Five purchase orders, in addition to N8446, include circulator fasteners and are therefore affected by this corrective action.
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P-88187
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Page 6 May 31, 1988 On March 31, 1988, PSC identified as NRC Comitment Log Item 1844 T, the need to revise Purchase Oraer N8446.
Letter P-88019 had not been completely reviewed prior to that date and therefore, this lack of timeliness of review prevented the Helium Circulator Program Manager from receiving a reminder to revise the purchase order.
PSC recognizes that independent of the regulatory action tracking system, Purchase Order N8446 should have been revised, but was not.
(2) Corrective Actions Taken To Date Purchase Order N8446 was revised on April 11, 1988. Additionally, the following purchase orders related to the same circulator fastener requirements discussed in letter P-88019 were revised to_ include supplemental information:
N-6694 N-6290 N-8157 N-8548 N-8194 NRC Comitment Log Item 1844 T has been closed based upon issuance of-the supplement to N8446.
A review of all 1988 government correspondence has been conducted to ensure other letters have been properly processed to identify needed comitments.
No other examples of lack of timeliness or inadequate processing were identified.
Individuals involved have been cautioned concerning seriousness of not having timely reviews or thorough follow up on open action items.
(3) Corrective Steps Which Will Be Taken To Prevent Recurrence
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No further actior, is planned as P' considers this to be an isolated example rather than a programmatic weakness.
L Sate When Full Compliance Will Be Achieved Purchase Order N8446 was revised on April 11, 1988. The review of 1988 government correspondence was completed on May 25, 1988.
Should you have any further questions, please contact Mr. M. H.
Holmes at (303) 480-6960, i
Very truly yours,
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R. 0. Williams, Jr.
Vice Precident Nuclear jerations R0W/IL/DG/pa
I, P-88187 Ma 31, 1988 rm$n ef c.
es Projects Section B eni r esid nt rupector Fort St. Vrain P
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