ML20235T519
| ML20235T519 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/06/1987 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| EA-87-167, NUDOCS 8710130116 | |
| Download: ML20235T519 (19) | |
Text
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i OCT 6 - 1987 In Reply Refer To:
3 Docket: 50-267/87-17
{
EA 87-167 1
k Public Service Company of Colorado l
ATTN: Robert 0. Williams, Jr.
Vice President, Nuclear Operations P. O. Box 840_
l Denver, Colorado 80201-0840
]
1 Gentlemen:
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i This refers to the meeting conducted at the NRC's request in the NRC Region IV office on September 10, 1987. This meeting related to activities authorized by NRC License No. DPR-34 for Fort St. Vrain and was attended by those persons 4
denoted on the Attendance List.
I The subjects discussed at this meeting are described in the enclosed Meeting 1
Summary.
It is our opinion that this meeting was beneficial and has provided for a better understanding of control of temporary configuration reports.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
(
Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Should you have any questions concerning this matter, we will be pleased to discuss them with you.
Sincerely, 2,/Y) M esTecm2ff B71013011b B71006 PDR ADOCK 05000267 G
PDR f R. D. Martin Regional Administrator
Enclosure:
Meeting Summary l
cc w/ enclosure:
Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 191 Platteville, Colorado 80651 (cc cont'd. next pa
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1 Public_ Service Company
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of Colorado cc cont'd:
P. 'Tomlinson, Manager Quality Assurance Division (sameaddress).
Colorado Radiation Control Program Director -
Colorado Public Utilities Commission' 4
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scc distrib. by RIV:
RPB DRSP RRI R. D. Martin, RA SectionChief(RPB/A)
RSB SectionChief(RSB/ES)
Project Inspector, RPB J
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RPSB D., Weiss, RM/ALF MIS System R. Hall RSTS Operator K. Heitner, NRR Project Manager
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RIV File D. Powers
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4 ENFORCEMENT' CONFERENCE'
SUMMARY
. Licensee:
Public-Service Company of Col'orado j
P. O.-Box 840
- Denver, Colorado -80201.-
Facility:
Fort St. Vrain Nuclear Generating Stationf 4 l
License:
DPR-34 i
' Docket:
.50-267/87-17' EA 87-167
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Subject:
Control of Temporary Configuration Reports 1
On September 10 1987, representatives.of Public Service Company of Colorado.L, (PSC) met with Region IV personnel in Arlington, Texas..to discuss the control
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of temporary configuration. reports (TCRs).
This condition was. reported in NRC i
7 Inspection Report 50-267/87-17 as.an apparent violations The. enforcement conference was held at the request of NRC Region IV. The attendance. list-is-a attached to this summary.
The NRC presented one apparent violation.of NRC requirements, and' acknowledged.
that while the inspection report noted three.other apparent violations, only-the TCR issue was expected to be'the subject of the meeting. -The'NRC expressed concern that several TCRs appeared to.be permanent' design changes.
The licensee then gave a slide presen_tation;-copies of the. slides are attached ~
~
to this sumary. The presentation included historical background that ' led to -
the violation. The licensee also discussed recent actions and the present TCR status. The licensee then presented a program to reduce the TCR backlog.. This included their programs for TCR closure and for the review of, existing'TCRs.
The future handling of TCRs was discussed; including the licensee's. plans for both short-and long-term action.
As a result of discussions held during the meeting, the licensee committed to the following:
1.
Prepare a justification for continued operation (JCO) for all outstanding safety-related TCRs and obtain concurrence of the senior resident inspector.
2.
Provide PSC's classification / evaluation' of. all; nonsafety-related TCRs to the senior resident. inspector-for review.
3.
Flag' documents in the control room and shift supervisor's office to indicate TCR involvement.
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^ The licensee committed to have completed the above items prior.to exceeding 35 percent reactor power.
The NRC staff explained the enforcement policy and stated that a decision would be made as to the appropriate enforcement action and that the licensee would then be notified, f
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Q. E.
gliardo, Chief Reacto Projects Branch Attachments:
Attendance List PSC Presentation Slides
r ATTENDANCE Fort St. Vrain Enforcement Conference September 10, 1987 NRC RT Hall, Deputy Director, Division of Reactor Safety and Projects J. Gagliardo, Chief,' Reactor Projects Branch J. Jaudon, Chief,. Project Section A R. Ireland, Chief, Engineering Section D. Powers, Enforcement Officer R. Farrell, Senior Resident Inspector M. Skow, Project Engineer-R. Keaton, Enforcement Specialist PSC RT hilliams, Vice President, Nuclear Operations D. Warembourg, Manager, Nuclear Engineering M. Niehoff, Nuclear Design Manager J. Reesy, Staff Assistant t
E. Pitchkolan, Engineer R. Craun, Nuclear Site Engineering Manager.
J. Eggebroten, Superintendent, Technical Services Engineering:
P. Tomlinson, Manager, Quality Assurance H. Brey, Manager, Nuclear Licensing and Fuels C. Fuller, Station Manager M. Holmes, Nuclear Licensing Manager 1
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NUCLEAR REGULATORY COMMISSION PUBLIC SERVICE COMPANY OF COLORADO ENFORCEMENT CONFERENCE ARLINGTON, TEXAS SEPTEMBER 10, 1987 t
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D VIOLATIONS REPORT PERIOD JULY 1-31, 1987 NRC REPORT NO. 87-17 OPERATIONAL SAFETY IMPROPER SECURING OF GAS BOTTLES OPERATOR OVERTIME, TECH SPEC 7.1.1.2.1 ESF SYSTEM WALKDOWN ELECTRIC DISTRIBUTION BREAKER IDENTIFICATION
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DESIGN CONTROL TEMPORARY CONFIGURATION REPORTS i
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TCR HISTORY r
e ORIGINAL (EARLY 1970'S) CONTROL GREW INTO A SYSTEM FOR TEMPORARY MODIFICATIONS TO BE MADE PERMANENT AFTER-THE FACT.
OLD ADM-22 FORM 1 DID NOT' REQUIRE SAFETY EVALUATIONS AS SUCH, AND DID NOT INCLUDE' SPECIFIC DESIGN CONTROL. ELEMENTS.
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THE B-0 STARTUP TEST PROGRAM REQUIRED THAT-SEVERAL PARAMETERS BE MONITORED FOR SPECIFIC ACCEPTANCE CRITERIA.
MANY OF THESE PARAMETERS WERE NOT A PART OF THE PERMANENT SYSTEM S0 TEMPORARY INSTALLATIONS WERE MADE.
-N0 ONE COULD PREDICT
)
AT THAT TIME THAT B-0 TESTS WOULD BE STRUNG OUT OVER SEVERAL
]
YEARS AND IN FACT ARE STILL NOT DONE.
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e IN THE EARLY OPERATIONAL DAYS OF FORT ST. VRAIN, TEMPORARY a
CHANGES WERE OFTEN MADE UNDER THE AUSPICES OF A "T" TEST.
IF THE TESTS WERE SUCCESSFUL, THE TEMPORARY CHANGES WERE LEFT IN PLACE TO BE COVERED BY A TCR AND LATER MADE 4
PERMANENT BY CN'S, 1
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INITIALLY, THE DESIGN CHANGE SYSTEM WAS SIMPLE AND STRAIGHT FORWARD.
AS TIME MARCHED ON, COMPLEXITIES WERE CONSTANTLY l
INTRODUCED, LAYERED REVIEWS AND SIGNATURES WERE REQUIRED AND THE SYSTEM BECAME VERY CUMBERSOME.
AS A RESULT, WHEN QUICK CHANGES WERE NEEDED THERE WAS A TENDENCY TO USE A i
TCR.
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RESULT-1 y
e A SIGNIFICANT BACKLOG 0F TCR'S WAS' CREATED, lALTHOUGH 1
SOME TCR'S WERE REMOVED.AND SOME WERE MADE PERMANENT; THE TCR BACKLOG CONTINUED TO-GROW DUE T0- A' CONSTANT INFLUX OF NEW WORK AND THE SQUEAKY WHEEL.GETS THE
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ACTIONS e
IN 1985 AND=1986, ALL TCR'S WERE REEVALUATED AND A. SAFETY.
EVALUATION WAS DEVELOPED FOR EACH TCR.
MORE RIGID CONTROLS.
WERE DEVELOPED IN. TERMS OF.USE, METHOD OF DEVELOPMENT, DESIGN CONSIDERATIONS, CONTROL AND INSTALLATION e
IN EARLY 1985, ENGINEERING WAS DEVELOPING A' PROGRAM.T0 EVALUATE AND REDUCE BACKLOGS.
THE E0 PROGRAM USURPED THOSE EFFORTS.
e FOLLOWING THE EQ OUTAGE (APRIL 1987) ENGINEERING BEGAN' REASSESSING THE BACKLOG.
TCR'S WERE SCHEDULED WITHIN THE DESIGN PROCESS UTILIZING A' GRADED APPROACH OF' TREATING TECHNICAL SPECIFICATIONS, SAFETY RELATED AND NON-SAFETY RELATED TCR'S, o
MET WITH SENIOR SITE RESIDENT INSPECTOR IN EARLY JUNE 1987, TO DISCUSS APPROACH, PLANS AND-SCHEDULE. -AS-A RESULT OF FEEDBACK FROM THE SENIOR SITE RESIDENT INSPECTOR, THE TCR SCHEDULE WAS REVISED AND REISSUED IN JULY TO INCORPORATE OVERALL CN APPROVALS.
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PRESENT-STATUS' e
IN THE RECENT PAST, THE TCR PHILOSOPHY HASLBEEN IMPROVED.
THE TCR PROCESS HAS.NOT BEEN ABUSED-'(I.E.,-NO PERMANENT-CHANGES HAVE BEEN.MADE VIA THE-TCR PROCESS),
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AN INTERIM.TCR PROGRAM HAS BEEN DEVELOPED WHICH INCLUDESi PROGRAM TO REDUCE BACKLOG COMPLETE REVIEW 0F'ALL EXISTING TCR'S IMPROVED HANDLING 0F FUTURE TCR'S i
e AN IMPROVED TCR PROGRAM WILL BE INCORPORATED ^INTO THE-OVERALL REVISED DESIGN CHANGE SYSTEM.
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PROGRAM TO REDUCE BACKLOG l
e DEFINE PERMANENT AND TEMPORARY TCR 1
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DETERMINE CLASSIFICATION NON-SR, SR, TS IMPACT e
ASSIGN DESIGN RESPONSIBILITY e
SCHEDULE DESIGN ACTIVITIES e
PREPARE CWP
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e DEVELOP PLANNING AND SCHEDULING ACTIVITIES
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SCHEDULE CONSTRUCTION e
PERFORM CONSTRUCTION e
RETURN SYSTEM TO SERVICE AND TCR CLOSURE i
e FINAL DOCUMENT CLOSURE E
TCR DESIGN COMPLETION SCHEDULE SR-TS POPULATION N-SR POPULATION DATE SCHEDULE DATE SCHEDULE CN APPROVAL NUMBER COMPLETE CN APPROVAL NUMBER COMPLETE PRIOR TO PRIOR TO SEPTEMBER 1
1 SEPTEMBER 7
6 SEPTEMBER SEPTEMBER 1987 10 1987 10 OCTOBER OCTOBER 1987 5
1987 2
NOVEMBER NOVEMBER 1987 1
1987 4
1 DECEMBER DECEMBER 1987 1987 3
JANUARY JANUARY 1988 6
1988 6
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FEBRUARY FEBRUARY 1988 5
1988 20 988 988 isgi' 1/
issa' MAY MAY 1988 1988 2
TOTAL 28 TOTAL 54 TO REMAIN TEMPORARY 16 TO REMAIN TEMPORARY 5
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-TCR CLOSURE PROGRAM e
TCR TASK TEAM lT) BE UTILIZED FOR MONITORING OVERALL PROGRAM PROGRESS WITH MONTHLY STATUS REPORTS ISSUED FOR MANAGEMENT ASSESSMENT.
e THE MONTHLY STATUS REPORTS WILL~BE FORWARDED TO THE NRC SENIOR SITE RESIDENT INSPECTOR, e
MONTHLY REPORT WILL INCLUDE STATUS OF:
- SCHEDULE OF DESIGN ACTIVITIES-
- PREPARATION OF CWP (30-45 DAYS AFTER CN APPROVAL)
- PLANNING AND SCHEDULING-(15-30 DAYS AFTER CWP)
PRIORITY MATERIAL DELIVERY SCHEDULE PLANT CONDITION SCHEDULE CONSTRUCTION PROCEDURES TRAINING
- MATERIAL DELIVERY
- PERFORMANCE OF CONSTRUCTION
- TCR CLOSURE CONSTRUCTION COMPLETE TESTING COMPLETE j
SHIFT SUPERVISOR-ACCEPTANCE (RETURN SYSTEM TO SERVICE)
- FINAL DOCUMENT CLOSURE i
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lu REVIEW EXISTING:TCR e
. DETERMINE IF CLASSIFICATION IS _ CORRECT.
e.
ANALYZE 50.59 REPORT TO CONFIRM ADEQUACYJ 1
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ANALYZE.TCR MODIFICATIONS.FOR TECHNICAL l SPECIFICATION IMPACT e
' ANALYZE TCR MODIFICATIONS FOR SAFETY RELATED: IMPACT i
e ANALYZE PLANT' MODIFICATION'FORLOPERABILITY CONSIDERATIONS TAKE APPROPRIATE' ACTION, REWORK, REMOVE 1
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CLASSIFICATION REVIEW RESULTS 7/17/87 9/10/87 SR-TS.................
34 28 NSR 54 54-TEMPORARY,..............
11 21 i
COMPLETED.........
3 11**
TOTAL 102 114*
INCLUDES TCR'S WRITTEN IN 1987 INCLUDES TCR 86-06-03 NOT REPORTED PREVIOUSLY
-2 OPERABILITY CONSIDERATIONS.
o REVIEWED-TCR'S TO DETERMINE IF ANY NEGATIVE'OPERABIL TY CONSIDERATIONS WERE-PRESENT.
1
.FOUR TCR'S'WERE IDENTIFIED 9I V.
e TCR 85-11-06 N-SR
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INSTALLED PDC-11380 IN PANEL'I-36A
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INSTRUMENT NOT MOUNTED.PER GOOD DESIGN l PRACTICE WILL BE REMOVED PRIOR TO EXCEEDING 2% POWER y
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e TCR 85-12-16 N-SR INSTALLED FUSE BLOCKS-IN I -
CHANNELFORM0lfNTINGFUSEBLOCKSNOTMOUNTEDPERGOOD DESIGN PRACTICE MOUNTING TO BE CORRECTED PRI.OR TO EXCEEDING 2% POWER s
TCR 86-01-29 sR-TS INSTALLED FILTERS ON M0ISTURE MONITORS INSTALLATION IS CORRECT.
HOWEVER, NO MATER'I AL' TRACEABILITY
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NEW MATERIAL PROCURED AND REPLACEMENT IN PROGRESS,
i COMPLETE INSTALLATION OF QUALIFIED FILTERSqAND. FITTINGS
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N
E WITHIN 30 DAYS s'
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TCR 86-04-04 SR-TS INSTALLED CONTROLLERS ON LN VALVES 2
CN-1932 REPLACES CONTROLLERS WITH QUALIFIED EQUIPMENT:
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WORK WILL BE COMPLETE PRIOR TO EXCEEDING 2% POWER '
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FUTURE HANDLING:0F TCR iSHORT TERM ACTION 1
REWRITE PROCEDURES TO e." INITIATE A TCR T'
LIMIT USEAGE 0F.TCR-ESTABLISH 90 DAY LIFE ESTABLISH REVIEW /50,59/ APPROVALS e
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EXTENSION BEYOND 90 DAYS ENGINEERING REVIEW AND APPROVAL DETERMINATION TO MAKE PERMANENT SCHEDULE OF CN AND CONSTRUCTION e
EXTENSION BEYOND 180 DAYS ANALYSES, JUSTIFICATION AND SCHEDULE ENGINEERING REVIEW AND APPROVAL VICE PRESIDENT NUCLEAR OPERATIONS APPROVAL LONG TERM ACTION e
INCORPORATE TCR PROCESS INTO OVERALL DESIGN CHANGE TROCESSIMPROVEMENTS.
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SUMMARY
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,. 4 PROGRAM T0. REDUCE BACKLOG OF TCR'S'HAS'BEEN ESTABLISHED 3
AND PSC IS AGGRESSIVELY. PURSUING CLOSURE OF TCR'S UTIl.IZING.
A GRADED A 9 ROACH..
y AN' ONGOING MONITORING EFFORT.HAS BEEN ESTABLISHED FOR' 4'
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. MANAGEMENT ASSESSMENT OF THE-PROGRAM.-
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EXISTING TCR'S HAVE BEEN REEVALUATED FOR OPERABILITY p
ASSESSMENT.
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INTERIM CONTROL OF TCR'S TO BE ESTABLISHED TO ENSURE' e
PROPER USE AND CONTROL OF THE TCRJROCESS.
A LONG TERM CONTROL 0F TCR'S TO BE INCORPORATED.INTO REVISEDDESIONCHANGEPRbCESS.
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