ML20205G187
| ML20205G187 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 07/16/1986 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20205G158 | List: |
| References | |
| P-86464, NUDOCS 8608190423 | |
| Download: ML20205G187 (3) | |
Text
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a h Public Sevice
,o 16805 WCR h :/2, P1atteville, Colorado 80651 connpany of colorado j
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July 16, 1986 Fort St. Vrain N2 IE v Unit No. I Q
P-86464 l
Regional Administrator Attn: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Region IV 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 06/18/86 (G-86315)
Dear Mr. Gagliardo:
This letter is in response to your referenced request for additional information. The information concerns both aspects of the Notice of Violation received as a result of inspections conducted at Fort St.
Vrain during the period February 1-28, 1986.
The following supplemental information concerning violations A and B is hereby submitted.
A. Failure to Maintain Records of Changes.
The NRC requested supplemental information to support PSC's conclusion that the condition which resulted in the violation represented an isolated case. The NRC's concern is that other open design changes and other CN's may have beer affected by a problem similar to that identified in this violation.
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. In response, and as indicated in our May 9, 1986 letter, P-86353, it is PSC's conclusion that this non-compliance can be attributed to either of the following probable causes:
1.
The interruption of the construction activity associated with the Change Notice (CN).
2.
The physical congestion of the area in question (i.e.,
snubberdeckarea).
Subsequent to your June 18, 1986 letter, our records have been reviewed to identify CNs, in construction, which have been stopped prior to completion. These CNs have been walked down. The walkdowns confirm that similar problems which resulted in the violation do not exist for other open design changes. Therefore, it is believed that the primary cause of the problem was the congestion in the area. The original walk down of this area, as indicated in our May 9 submittal, ensures the uniqueness of this situation.
In order to mitigate the occurrence of this situation in the future, a Procedure Deviation Report has been prepared to revise the Controlled Work Procedure (CWP) Manual.
The revision will include provisions which prohibit the closing (release for system operation) of a CWP before the associated construction activities are complete.
Based on the original walk down information and this supplemental CN
- review, it is PSC's conclusion that this is an isolated non-compliance.
B.
Failure to Take Prompt Corrective Action.
The NRC requested supplemental information concerning the incorporation of requirements in the company's deficiency tagging procedure.
The requirements should provide for evaluation of identified deficiencies against LCO requirements for operability.
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, PSC responds that SMAP-33,
" Plant Material Deficiency Identification / Work Orders",
will incorporate provisions for evaluating an identified deficiency against LC0 requirements. The procedure will include steps which delineate a Reactor Operator's responsibilities with regards to the processing of a Deficiency Report Tag (DRT). The Reactor Operator will be required to review a DRT for effect on equipment operability, Technical Specification compliance and plant requirements. The DRT form and the procedure will also include a provision for the Reactor Operator to enter a required completion date if the condition represents a Technical Specification encumbrance. SMAP-33 is currently in use on an interim basis. The finalized procedure is in our review / approval cycle.
It will be issued and in effect by August 15, 1986.
Should you have any further questions, please contact Mr. Michael H. Holmes, (303) 480-6960.
Sincerely, M
J.
. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/kls I
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