ML20199E602
| ML20199E602 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/09/1986 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20199E585 | List: |
| References | |
| P-86353, NUDOCS 8606230334 | |
| Download: ML20199E602 (4) | |
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'*d 16805 WCR 19 1/2, Platteville, Colorado 80651 May 9, 1986 Fort St. Vrain Unit No. 1 P-86353 Regional Administrator Attn: Mr. J. E. Gagliardo, Chief Reactor Projects Branch MI4E Region IV p
U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Docket No. 50-267
SUBJECT:
I&E Inspection Report 86-06
REFERENCE:
NRC Letter, Gagliardo to Walker, dated 04/09/86 (G-86180)
Dear Mr. Gagliardo:
This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period February 1-28, 1986. The following response to the items contained in the Notice of Violation is hereby submitted:
A.
Failure to Maintain Records of Changes 10 CFR Part 50.59 allows the licensee to make changes in the facility provided that the change does not involve an unreviewed safety question. The licensee shall maintain records of changes to the facility, which includes a written safety evaluation which provides the basis for the determination that the change did not involve an unreviewed safety question.
Contrary to the above, the licensee made a change to a instrument piping support in that a seismic hanger was replaced by a rope without maintaining a record of a safety evaluation showing that this change did not involve an unreviewed safety question.
This is Severity Level IV violation (Supplement I.D)
(50-267/8606-01).
0606230334 060618 PDR O
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-. (1) The reason for.the_ violation if admitted:
After review _ of documentation, (Change Notices, Controlled Work Procedures, etc.) no_ definite reason can be attributed--for the missing support..
It is believed that during. construction activities modifying the - Bearing -Water System (CN-1707) this particular' support was removed and the. temporary _ rope support was used, although no documentation exists to support this.
It should also be noted that construction activities to CN-1707 were stopped in progress due to unforeseen circumstances.
This stop in work could have contributed to the missing support.
(2) The corrective steps which have been taken and the results achieved:
.A. new _ support-was designed and installed in accordance with-
. existing PSC Procedures. This support provides adequate -seismic and dead weight support for the junction box to allow for operation of LC-21303 and LC-21305.
(3) Corrective steps which will be taken to avoid further violations:
-This ~is an. isolated case in that all modification and/or Lmaintenance work requires either a Controlled Work Procedure with specific work steps, or a Station Service Request.
In addition, a review as performed of the area,- which is very
-congested, to ensure that the. removal of this equipment support was an isolated case.
During this walk down miscellaneous corrective maintenance items were identified, none of which resulted in inoperable equipment. Based upon the walk down and the unusual events surrounding CN-1707,'it is our position that sited condition is an isolated situation.
(4) The date when full compliance will be achieved:
Full compliance was achieved on. February 24, 1986 when CN-2149/CWP 85-1001 installed an engineered support on junction box in question. No further corrective steps are planned.
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Failure to Take Prompt Corrective Action 10 CFR Part 50, Appendix B, Criterion XVI requires that measures be established to promptly identify and correct conditions adverse to quality. The licensee's approved quality assurance plan, Section 8.5.16 implements this by requiring corrective action forms be originated and responded to within 15 days.
Contrary to the above, the replacement of a seismic support with a rope was identified by a licensee inspection in November 1985.
On February 20 and again February 24, 1986, it was determined that no correcttse action request had been initiated, that the adverse condition had not been corrected, nor had any corrective action been started.
This is Severity Level IV violation (Supplement I.0)
(50-267/8606-02).
-(1) The reason for the violation if admitted:
The Nuclear Production Division Shift Supervisor, referred to concerning the original notification of the deficiency in November, was one of four Engineers from the Results Engineering group and the Technical Services Plant Engineering group who were assigned to supervise the 3 shifts of Technicians, Engineers and Electricians performing the Environmental Qualification walk downs. The report was a notation in the C.A.D. package that the rope support situation should be looked at concerning seismic considerations but that as far as any concern from an Electrical or Environmental Qualification stand points there was no action required. Personnel processing this information apparently were not aware of the immediate need to establish an investigation that would lead to initiation of Corrective Action should any be required. Since no Electrical or Environmental Qualification action resulted form the walk down package, the comment referring to the rope support was not addressed. On February 20, 1985, the rope support was reported to an Operations Shift Supervisor.
Since the conduit that was affected concerned Air System Tubing, the Shift Supervisor reported the situation to a Results Department Supervisor who responded by telling the Shift Supervisor that he would take care of the situation. The Results Supervisor went to the area to investigate the problem and could not find the described rope hanger. Deciding that he either did not have the correct location or that someone had already corrected the situation, returned to other matters and the incident was forgotten. On February 24, 1986, when it was again brought to the Operations Shift Supervisor, the Superintendent of Operations was notif.ied who in turn contacted the Superintendent of Maintenance and the NED Site Engineering Manager to initiate necessary actions.
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, (2) The corrective steps which have been taken and the results achieved:
Engineers determined the necessary Corrective Action to restore the Conduit Support to design specification and PSC Maintenance Department Personnel worked on an overtime basis until the work, inspection and acceptance was complete.
(3) Corrective steps which will be taken to avoid further violations:
At the present time a deficiency tagging procedure is being developed. This program will provide a method of identification and tracking that should ensure that identified deficiencies are addressed in a timely manner.
(4) The date when full compliance will be achieved:
July 31, 1986.
Should you have any further questions, please contact Mr. Frank J. Novachek, (303) 571-7436, ext. 201.
Sincerely, JLVf1Altm by dpSC J. W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/kls L.