ML20207S697
| ML20207S697 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/17/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8703200187 | |
| Download: ML20207S697 (2) | |
See also: IR 05000267/1986025
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In Reply Refer To:
E 17 E7
Docket: 50-267/86-25
Public Service Company of Colorado
ATTN: Robert 0. Williams, Jr.
' Vice President, Nuclear Operations
P. O. Box 840
Denver, Colorado
80201-0840
Gentlemen:
Thank you for your letters, dated January 5, (P-87001) and February 20, 1987,
(P-87070) in response to our letters, dated November 4,1986, and January 23,
1987. With regard to the original Violation 267/8625-02, it should be noted
that Safety Guide 33, dated November 3,1972, which is invoked by your
Technical Specifications, states:
" Appendix A lists typical safety-related activities which should be
[
covered by written procedures. Appendix A does not provide a complete
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listing of needed procedures since many other activities that are carried
out during the operation phase of a nuclear power plant require written
procedures that are not included in Appendix A."
Procedures for actual control of activities which encompass a major quality
area, such as design control, are clearly required. The violation was written
because effective control of the design change process was being accomplished
through procedures which were not reviewed by the onsite consnittee. Your
coninitment to have the onsite consnittee review ENG-1 resolves our concern
that the actual adatnistrative procedure controlling the design change process
was not a reviewed procedure.
We have no further questions at this time, and will review your corrective
actions during a future inspection.
Sincerely,
% w ua :;,m n,a t,n
n. c w.u,
VJ.E.Gagliardo, Chief
Reactor Projects Branch
cc:
(seenextpage)
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Public Service Company of Colorado
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cc:
Manager. . Nuclear Production Division
Fort St. Vrain Nuclear Station
16805 WCR 191
Platteville, Colorado
80651
P. Tomlinson, Manager, Quality
Assurance Division
(same address)
Colorado Radiation Control Program Director
Colorado Public Utilities Commission
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February 20, 1987
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Fort St. Vrain
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Unit No. 1
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P-87070
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U. S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
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Washington, D.C.
20555
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Docket No. 50-267
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SUBJECT: I & E Inspection 86-25
REFERENCES: 1) NRC Letter, Gagliardo
to Williams dated
November 4, 1986
(G-86584)
2) PSC Letter Brey to
Gagliardo dated.
December 4, 1986
(P-86656)
3) PSC Letter Brey to
Gagliardo dated
January 5, 1987
(P-87001)
4) NRC Letter, Gagliardo
to Williams dated
January 23, 1987
(G-87022)
Gentlemen:
This letter supercedes our response to violations number 2, 3 and 5,
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as originally stated in Reference
3.
These violations were the
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resul t of inspections conducted at Fort St. Vrain during the period
August 16 thru September 30, 1986.
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P-87070
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February 20, 1987
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2.
Failure to Review Modification Control Procedures:
Technical
Specifications,
Paragraph
7.4.b,
requires that
procedures and administrative policies of
Appendix
A
to
Regulatory Guide 1.33, November 1972, which includes general
procedures for control of modification work, be reviewed by the-
plant operations review comittee (PORC).
Contrary
to
the
above,
procedures
ENG-1
(" Control of-
Modifications and documentation"), and CWPH
(" Controlled Work
Procedure Manual"), which all provide administrative policies of
control of modification work, were not reviewed by PORC.
This is a Severity Level
IV violation.
(Supplement I.D.)
(267/8625-02)
(1) The reason for violation if admitted:
In December,1980, PSC explicitly considered whether or not
Paragraph 7.4 of the Technical specifications applied to
Nuclear Engineering procedures.
At that time, it was
determined (as documented in Procedure G-2 " Fort St. Vrain
Procedure
Systems,"
Issue
3,
Paragraph 4.3.3
see
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Attachment 1) that the review by PORC of Level 2 engineering
procedures,
which
provide
detailed
internal Nuclear
Engineering Division requirements and are subordinate to
Level
1 administrative procedures, was not necessary. The
basis for this determination was that adherence to Level
1
procedures is mandatory (FSAR, Appendix B.5.2.2.2)
and
therefore, Nuclear Engineering procedures cannot conflict
with Level 1 administrative procedures. This determination
is also documented in the current issue
of
Nuclear
Engineering Procedure ENG-6 "NED Procedure System," Section
4.3.3 b.
.
To implement the cited Technical Specification paragraph,
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Level
1 administrative procedures Q-3 " Design
Control
System" (Attachment 2), and G-9 " Controlled Work Procedures"
(Attachment 3), are reviewed by PORC.
In addition, each
safety related Controlled Work Procedure (and the associated
safety related Change Notice, which are
prepared
in
accordance with the detailed Level
2 internal Nuclear
Engineering procedures), is individually
reviewed
and
approved by PORC prior to implementation.
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P-87070
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February 20, 1987
The
applicability
statement of Paragraph .7.4
of the
Technical Specifications states that it is applicable to
administrative procedures which govern plant operation.
Administrative Procedure G-1 " Definitions" further defines
plant operating procedures as written instructions defining
the normal methods, means, and limits of operations of a
nuclear power plant.
Safety Guide 33, dated November 3,
1972 provides the following guidance:
(Excerpt from Appendix
A,
Paragraph ! - Procedures for
Performing Maintenance)
" General
procedures for the control of maintenance,
repair, replacement, and modification work should be
prepared before reactor operation is begun."
The above statement froin Safety Guide 33 is the only
explicit reference to modification procedures in
this
guidance document.
As described above, PSC considers that
Procedures Q-3 and G-9 provides for the implementation of
regulatory requirements related to modifications and design
centrol. Engineering procedures, subordinate to Q-3 and
G-
9,
do not govern plant operations and therefore do not
require
review
in
accordance
with
Technical
Specification Paragraph 7.4.
Upon further review, PSC feels that perhaps Procedure Q-3 lacks
sufficient specificity concerning the control of modifications.
In
this respect, PSC will commit to requiring a review of ENG-1 (Control
of Modifications and Documentation Changes), by the Plant Operations
Review
Comittee (PORC).
As the main controlling engineering
document for design and modification activities the current issue of
ENG-1 and all future revisions of ENG-1 will henceforth be subject to
PORC review.
(2) The corrective steps which have been taken and the results
achieved:
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ENG-1 will be reviewed by PORC.
(3) Corrective steps which will be taken to avoid further
violations:
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Administrative Procedure G-2 will be revised to require that
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all future revisions to ENG-1 be reviewed by PORC.
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P-87070
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Page 4
February 20, 1987
(4) The date when full compliance will be achieved:
Full compliance will be achieved by May 15, 1987.
3.
Failure to Sufficiently Document Design Verification:
Technical Specifications Paragraph 7.4.a.1, requires that written
procedures be established,
implemented, and maintained
for
activities covered by Appendix A of Regulatory Guide 1.33,
November 1972, which includes general procedures for control of
modification work.
Procedure ENG-1, " Control of Modifications and Documentation,"
requires that the person performing the design verification
process document their effort in sufficient detail to provide a
record of their work.
Contrary
to
the above, the person performing the design
verification for change notice (CN) 1876 did not document the
effort in sufficient detail to provide a record of the work in
that the " Check List of Design Verification Questions for Design
Review Method" was signed and dated on one date and was initialed
and dated on three subsequent dates with no details provided as
to what was verified on each date, and no details were provided
to record that the design sketches included in the CN package
were checked by the design verifier.
This
is
a
Severity
Level
IV
violation.
(Supplement
I.0.)(267/8625-03)
(1) The reason for violation if admitted:
The violation is admitted.
As cited in the violation,
engineering procedure ENG-1 prescribes the
independent
design verification (IDV) process for change notices (CNs).
Procedure ED-100 further
describes
the
process
for
preparation, assembly, review and approval of change notice
packages.
Paragraph 4.5.2 of E0-100 states that
the
coordination
sheet of a CN document the Coordinator,
interface reviewers, page schedule, new pages, substituted
pages and NED approval. This CN coordination sheet serves
as a cover page for the three design packages comprising a
CN.
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P-87070
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Page 5
February 20, 1987
The coordination sheet provides two things:
1) an index
identifying all the Change Notice pages and their issue that
comprise the change notice package; and, 2) a record of the
person /date performing the various duties,
i.e.,
IOV,
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interface review, and approval of the CN package. The
signatures indicate they have reviewed / approved the package.
as required to fulfill their specific responsibilities as
defined in the engineering procedures,
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'The signature by the person doing the IOV on both the IOV
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checklist page and on.the coordination sheet for CN-1876
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(see Attachment 6) explicitly documents that the independent
design verifier has perfonned functions on all appropriate
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pages of the CN package, not just on the checklist pages.
In particular, each of the four design sketches in CN-1876
were assigned a CN page number, and each of those CN page
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numbers was explicitly included on the CN coordination
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sheets signed by the independent design verifier.
To
provide a signature on each individual
sketch would then
place doubt in ones mind that any of the other pages of the
CN package were reviewed.
PSC believes that we have perfomed all the requirements in
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the preparation and review of the subject Change Notice in
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accordance with procedures and regulations. However, the
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NRC has identified what PSC considers to be a weakness, in
that several
10Vs/ reviews / approvals have been performed
without detailed documentation identifying why the several
s!gnatures were required.
(2) The corrective steps which have been taken and the results
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achieved:
On December 9, 1986 the Nuclear En
an instructional memo (NOG-86-1647)gineering Olvision issued
reiterating the design
verification process and procedural requirements.
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In addition, our engineering procedures have been changed
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and a new fom created so that more explicit documentation
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will be required when a CN package receives more than one
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set of IOV/ review / approval.
This procedural change was
implemented on January 16, 1987.
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P-87070
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Page 6
February 20, 1987
(3) Corrective steps which will
be,taken to avoid further
violations:
Correctivestepshavebeer,implementedsee(2)above.
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(4) The date full compliance will be achieved:
Full compliance was achieved on January 16, 1987.
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5.
Failure to Implement Corrective Action Program
Criterion XVI to 10 CFR Part 50, Appendix B, requires that
measures be established to assure that conditions adverse to
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quality,
such
as
failures,
mal functions,
deficiencies,
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deviations, defective material and equipment, and nonconformances
are promptly identified and corrected.
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Contrary to the above, the installation instructions for CN-1876
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noted that numerous discrepancies were identified with the
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existing
vendor
design
documents
and
the actual
field
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installation, but no corrective action was initiated to review
other areas of the vendor documents not affected by the change
notice for similar discrepancies.
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This
is
a
Severity
Level
IV
violation.
(Supplement
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1.D.)(267/8625-05)
(1) The reason for the violation if admitted:
The
violation
is admitted.
At the time the design
modification was being prepared minor discrepancies were
discovered
in
comon
point
teminations.
These
,
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discrepancies were between the actual comon points used to
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tenninate
circuit
connections and the way they were
represented on the wire lists. At this point in the design
process the designer perfomed a verification of wiring
connections within the applicable portions of the system.
Certain areas could not be verified due to inaccessibility
of equipment or the hazard of inadvertently
tripping
operating circuits. The inability to verify all applicable
connections prompted the note in the CN
package
to
construction
personnel
requesting verification of all
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applicable terminations prior to modification or removal.
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Subsequent verification by construction personnel resulted
in one additional comon point discrepancy being identified.
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February 20, 1987
The CN was modified by a Deviation Request to document the
deficiency.
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In all cases where discrepancies were uncovered, either by
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the designer or construction personnel, only comon point
terminations were involved.
The discrepancies uncovered
during the verification process did
not
affect
the
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functional
integrity
of
the electrical circuits and
therefore, PSC maintains its position that the electrical
design -was not compromised by the discovery of the minor
discrepancies in comon point terminations.
However,
PSC comits to a field verification of all
remaining electrical connections associated with the orifice
valve control relays and associated wiring which are located
in instrument panel I-9327. This is the area where the
deficiencies
were
discovered
during
the design and
construction operation.
The field verification will
be
confined to this
instrument panel as the circuitry was
designed and fabricated by the same vendor at his facility
and then shipped to FSV for installation as a unit.
(2) The corrective steps which have been taken and the
results achieved:
No action has been taken at this time.
(3) Corrective steps which will be taken to avoid further
violations:
A memo will be distributed to NED design personnel
detailing
this
violation
and
reiterating
the
requirements of Criterion XVI to 10 CFR Part 50,
Appendix B.
(4) The date full compliance will be achieved:
The memo to NED design personnel will be issued by
March 16, 1987. Field verification of the remaining
electrical connections associated with the orifice
valve circuitry will be completed by May 15, 1987.
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P-87070
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Page 8
February 20,'1987
Should you have any . questions concerning this response, please
contact Mr. M.H. Holmes at (303) 480-6960 for additional information.
Very truly yours,
h E /Y
D. W. Warembourg, Manger
Nuclear Engineering Division
DW/ RAS:pa
Attachments
cc: Regional Administrator, Region IV
Attention: Mr. J. E. Gagliardo, Chief
Reactor Projects Branch
Mr. R. E. Farrell
Senior Resident Inspector
Fort St. Vrain
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