ML20214F659
| ML20214F659 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/18/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8611250384 | |
| Download: ML20214F659 (3) | |
See also: IR 05000267/1986019
Text
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Docket:
50-267/86-19
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In Reply Refer To:
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 letter of October 27, 1986, in response to our letter
and Notice of Violation dated September 11, 1986. We have reviewed your reply
and find it responsive to the concerns raised in our Notice of Violation. We
will review the implementation of your corrective actions during a future
inspection to determine that full compliance has been achieved and will be
maintained.
Sincerely,
/ S/
M Mall
,
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
J. W. Gahm, Manager, Nuclear
Production Division
Fort St. Vrain Nuclear Station
16805 WCR 191
Platteville, Colorado
80651
L. Singleton, Manager, Quality
Assurance Division
(sameaddress)
Colorado Radiation Control Program Director
Colorado Public Utilities Commission
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ATTACHMENT
SUPPLEMENTAL NDE VAN INFORMATION
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. 1.
NDE Van Support Requirements
We request that the NRC-NDE van be positioned as near as practicable to
the containment area entrance to facilitate the performance of
4
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inspections.
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a.
The van requires the following connections while sited at your
facility:
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Site water _with a garden hose connection - this water is for
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film rinse,
Requirement for film rinse water drain (continual). No
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chemical disposal will occur from the van without prior
concurrence from appropriate licensee personnel. At the end of
the independent inspection, the NRC needs to dispose of the
film developing chemicals prior to moving the van from the
site.
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Two 30 amp, 110 volt circuits are required for operation of the
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van.
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b.
The van will contain PT and MT approved materials. The team will
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need two rolls of your chemically approved tape and two approved
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markers for identifying welds and marking weld areas.
c.
It will be necessary for you to remove the paint, rust, or other
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material that could interfere with PT and MT on the selected welds.
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Also, we will need scaffolding erected and insulation removed for
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access.
2.
Administrative Information
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a.
We-request that you hold a mini-radiation safety training course for
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the NRC-NDE personnel. This course should familiarize the personnel
with your facility and procedures and should not excaed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in
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length,
b.
A camera site pass will be needed for a Canon AE-1, 35 mm, camera,
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Serial No. 1969401.
c.
The NDE personnel will be using 5 watt Motorola radios on the site;
the frequency used by the NRC is 165.6625 MHz.
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Company of Colorado
16805 WCR 19 1/2, Platteville, Colorado 80651
October 27, 1986
Fort St. Vrain
Unit No. 1
P-86578
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Region IV
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Regional Administrator
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U. S. Nuclear Regulatory Commission
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611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas 76011
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Attention:
Mr. J. E. Gagliarde, Chief
T
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Reactor Projects Branch
Docket No. 50-267
SUBJECT:
I&E Inspection Report 86-19
REFERENCE: NRC Letter, Gagliardo to Williams,
dated 9-11-86 (G-86506)
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
June 23 to 27, 1986. The following response to the items contained
in the Notice of Violation is hereby submitted:
Prompt and Effective Corrective Action
Criterion XVI of Appendix B of 10CFR Part 50 and the licensee's
approved Quality Assurance Program require that
conditions
adverse to quality be promptly identified and corrected.
Contrary to the above, certain conditions, adverse to quality,
which had been identified, had not been corrected.
Examples are:
Nonconformance Reports 37, 38, and 40, issued as a result of
the 1983 bienn'ai
review of Quality Assurance, were not
documented as being resolved.
Corrective action report (CAR)81-204, dated June 28, 1981,
remained unresolved and unclosed.
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P-86578
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October 27, 1986
CAR-83-082 was closed without the response addressing the
deficiency stated therein.
This is a Severity Level IV violation.
(Supplement I.D.) (8619-
03)
(1) The reason for the violation if admitted:
The root cause of these examples was a general avoidance by
upper management to address particularly difficult problems
coupled
with the fact that executive management was not
exclusively dedicated to nuclear production concerns.
The first example is the result of inadequate quality controls
to ensure documentation was in place or referenced to document
resolution of Nonconformance Reports 37, 38, and 40.
The second example is the result of the inability to achieve
corrective action in a timely manner due to the complexity of
the problem, divisional interfaces, and discovery of additional
problems during the course of resolution.
The third example is not symptomatic of the stated violation.
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(2) The corrective steps which have been taken and the results
achieved:
The corrective action system is being upgraded to include
specific requirements relative to time frames for completion of
corrective actions, elaboration on CAR disposition requirements
for programmatic applicability, root cause evaluation, "look
back" review process, and programmatic analysis.
In addition,
an NFSC Audit of the corrective action program originally
scheduled to begin in September,1986, was deferred and rescoped
to conduct an in-depth,
self-appraisal
of corrective action
prcgress.
This audit began October 9, 1986, and includes a
review of the corrective action program as a whole to determine
the existence of any other areas symptomatic of this problem.
Due to the early stage of development of the corrective steps
taken, it is too soon to quantify the results achieved.
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In order to provide senior management with frequent assessments
of corrective action program performance and progress, a status
update is regularly given at the Senior Planning Team Meetings
which are directed by the Vice President, Nuclear Operations.
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P-86578
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October 27, 1986
Example #1
NCR's 35, 36, 37,
and 38 were grouped as examples for Torrey
Pines Audit Finding #3; however,
the PSC Corrective Action
Request (CAR) for this finding specifically referenced only
NCR 35. The corrective action for Torrey Pines Audit Finding #3
consisted of a revision to APM Q-16, Corrective Action System,
which specifically addressed NCR's 35 and 36 and included
measures regarding changing scheduled CAR completion dates,
which is the subject of NCR 38.
The subject of NCR 37,
timeliness of corrective action, was not addressed as it was
felt to be a senior management issue.
NCR 40,
concerning deficiencies in the Master Calibration
Schedule, documented in Torrey Pines Audit Finding #1, was not
addressed in a CAR.
No documentation can be found to indicate why this was not
addressed.
It is believed a new CAR was not issued due to a
virtually identical CAR (CAR-81-219) which was open at the same
time; however, this was not documented on that CAR or in the
Torrey Pines Audit historical file.
CAR-81-219 was subsequently
closed July 21,1983, based upon revision of
the
Master
Calibration Schedule and development of a new data base by the
Results Department.
Example #2
CAR-81-204 was initiated in June of 1981 as a result of
deficiencies identified in QA Audit 2201-80-01.
The CAR identified that there were significant discrepancies and
apparent inconsistencies between the Technical Specifications,
Master Setpoint List, Master Instrument Calibration Schedule,
and the Safety Related Lists.
After much correspondence, QA received in February and March of
1984, a two part response which identified the corrective
actions taken by Nuclear Production Division (NPD) to resolve
the CAR. After evaluation by QA and completion of additional
corrective
actions
requested
by
QA, Nuclear Production
responsibilities, which constituted the majority of this CAR,
were judged as complete. However, additional discrepancies were
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uncovered during this time which were the responsibility of the
Nuclear Engineering Division (NED).
Subsequently, following the
completion of NPD responsibilities, the CAR was transferred to
NED in July, 1984.
Five action items were required to be
completed by NED, all of which were assigned to Change Notices
(CN).
Four of these Change Notices are completed, and the last,
CN-2188, has been completed and approved in NED and is presently
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P-86578
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October 27, 1986
in Technical Services for review and approval. QA is currently
evaluating CN-2188 in regard to CAR-81-204 closure.
Example #3
In evaluating CAR-83-082, the Training Unit was unable to obtain
any information relative to deficiencies in the Fire Brigade
Training Program other than that presented by the "for example"
of Nonconformance Report 13, which, in fact, is a requirement of
the overall Fire Brigade Program, not the training program. The
response to the CAR specifically addressed that deficiency.
The
FSV
Fire
Brigade
Training Program was revised in
March, 1981, to conform to Appendix R to 10CFR50, which is much
more detailed than the requirements of Section 27 of NFPA
Code-1975.
(3) Corrective
steps
which
will be taken to avoid further
violations:
Quality Assurance has initiated a program to upgrade the
corrective action system and other quality issues.
The program
includes:
1.
Revise
Administrative Procedure (APM) Q-16,
Corrective
Action System to include:
a) Specific requirements for actions relative to time
frames for completion of required actions.
CAR's open
in excess of 180 days will be evaluated by management to
improve resolution time.
b) Elaboration
on
disposition
requirements for
programmatic applicability, root cause evaluation, "look
back" review process, and programmatic analysis,
c) Establishment
of
a
corrective action performance
tracking system for review by the Fort St. Vrain Senior
Planning Team and senior management.
2.
Complete the NFSC Audit of the corrective action program and
develop an action plan to address identified problem areas.
3.
It is recognized that procedural controls alone will not
resolve the corrective action problems.
To this end, the
Vice President, Nuclear Operations is personally involved to
provide the management direction and support needed for the
improvement of quality programs and administrative controls
affecting quality.
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P-86578
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October 27, 1986
(4) The date when full compliance will be achieved:
1.
Review of open Corrective Action Requests by the Senior
Planning Team has been in progress since September, 1986.
2.
Administrative
Procedure
Q-16
will
be
revised
by
December 31, 1986.
3.
The NFSC Audit of the corrective action program will be
completed by December 31, 1986.
4.
Based on results of the NFSC Audit, an action plan will be
formulated
to
address
specifics
identified
by
January 30, 1987.
Compliance with the Corrective Action System is an ongoing process.
This process is examined regularly in audits of the Corrective Action
System and, to a lesser extent in each audit performed, the results
of which are reported to management.
Should
you
have
any
further
quertions,
please
contact
Mr. M. H. Holmes at (303) 480-6960.
Sincerely,
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P. F. Tomlinson
Manager, Quality Assurance Division
PFT/c1k
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