ML20235T610
| ML20235T610 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 04/18/1985 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-85133, NUDOCS 8710130147 | |
| Download: ML20235T610 (4) | |
Text
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h PublicService e.,
16805 WCR 19 1/2, Platteville, Colorado 80651 company of colorado April 18, 1985 Fort St. Vrain Unit No. 1 P-85133 1
[H@lHOWlH @
Regional Administrator l
Attn: Mr. E. H. Johnson H 24 E l
Region IV l
U. S. Nuclear Regulatory Commission p
611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 1
Docket No. 50-267
SUBJECT:
I&E Inspection Report 84-30 i
REFERENCE:
NRC Letter, Johnson to Lee, dated 03/22/85 l'
(G-85110)
Dear Mr. Johnson:
This letter is in response to the Notice of Violation and Notice of Deviation received as a result of inspections conducted at Fort St.
Vrain during the period November 1-30 and December 1-7, 1984. The following responses to the items contained in the Notice of Violation and Notice of Deviation are hereby submitted:
Notice of Violation:
Failure to Document QA Program Title 10 Code of Federal Regulation Part 50, Appendix B.
Criterion II, requires the licensee's quality assurance (QA) program to be documented by written policies, procedures, or instructions.
Contrary to the above, the NRC inspector determined that applicable portions of-the licensee's QA program, as defined in their Final Safety Analysis Report, Revision 2, for the alternate cooling method (ACM) equipment, the fire protection system, and the plant security system, were not documented by written policies, procedures, or instructions.
This is a Severity Level IV Violation.
(Supplement I.D.)
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(50-267/8430-02)
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(1)The corrective steps which have beer. *. ta ken and the nsults achieved:
l In January, 1985, a memo was issued within Nuclear Engineering Division (NED) providing guidance in applying the QA Program. to-the ACM, Fire Protection and Security Systems.
Instructions for treatment of these systems are provided in accordance with the following table:
l SEISMIC I.D.V.
QUALIFIED
- ENVIR, SYSTEM CLASSIFICATION REQ'D*
PROCUREMENT VENDOR QUAL.
ACM Safety Related Yes N-Order Yes No Security Non-Safety Yes N-Order No No-Related Fire Pro-tection 'Non-Safety Yes N-Order No No Relaten!(Except (Except Existing Existing Class 1 Class 1 Portions)
Portions)
Independent Design Verification on all CNs and DRs (affecting equipment 'n these systems)
A draft of Administrative Procedure Q-2, Quality Aswrance Program, hes been prepared to include QA criteria for tSe 4ACM, Fire Protection and Security Systems.
Definitive results to date on these measures cannot be quantified.
(2) Corrective steps wn'ich +ill be taken to avoid further violations:
NED will develop three chenge notices (CN's).
CN-1962 will address the ACM system, and will be issued by NED in October, 1985, CN-1963 will address the Fife Protection system,, and will be issued by'NED in August, 1985.
CN-1964 will address the Security System, and will be' issued by NED in September, 1985.
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The three CN's will establish the following:
l l
a)
Incorporation of ACM components into the plant component' l
data base as safety-related items.
l b)
Creation of an identifier in the plant component data base to identify fire.
protection
-(other than existing safety-related fire protection components) and Security components.
Administrative Procedure Q-2 will be revised as required to reflect the contents of the three CN's.
(3) The date when full ccmpliance will be achieved:
Full compliance will be echieved by January 15, 1986 based on issuance, approval, and implementation of the provisions of the three Change Notices and attendant Administrative Procedures.
Notice of Deviation:
Public Service Company of Colorado committed, in letter P-84194, dated July 6, 1984, from Lee to. Collins, that CN-846C,
" Install six zones of fire detection equipment and an oil mist detection system," would be completed by October 1984.
In deviation from the above, CN-846C had not been completed as of December 7, 1984, and a request for change in schedule had not been received by the NRC.
(50-267/8430-04)
(1) The corrective steps which have been taken and the results achieved:
The installation and operation of six zones of fire detection and the oil mist detection above each hydraulic power unit is complete and in service.
Construction of six zones of fire detection was completed in the first week of November.
In addition to the six zones of fire detection, CN-846C included a modification to add an alarm point within the Control Room Fire Panel (Pyrotronics System) that will provide an alarm from the Building 10 Fire Panel (Kidde System).
Functional testing found unexpected problems with the operation of the Control Room Fire Panel Alarm.
Corrective steps taken at the time were initiated to resolve ur, expected design deficiencies with the Control Room Fire Panel.
The system was placed in service on January 29, 1985.
e
_ As a result of the ties'between the two Fire Panels, the_six-l zones of fire detection could not be placed in service at an j
earlier date.
The 011 Mist Detection System placed above the Hydraulic Power Unit, as discussed in our December 14, 1984 letter (P-84528),
experienced operability-problems.
The Oil Detection Unit was inoperable as received from the manufacturer.
PSC, along with the manufacturer and supplier, worked until January 29, 1985 to make the unit functional. With each attempted repair,
- a. period of from several days to a week was required to see if'the unit would remain functional.
These test periods revealed continuing problems and resulted in delays of the inservice date.
(2) Corrective steps which will be taken'to avoid further violations:
Due to various' problems, PSC experienced delays, which at the time, were anticipated to be of short duration.
PSC feels that this is an isolated case.
PSC notified the NRC on December 14,1985 (P-84528, Warembourg to Johnson) of the delays.
In the fututre, PSC will provide a more timely notification to the NRC of delays in commitment dates.
(3) The date when full compliance will be achieved:
Full compliance to install six zones of fire detection and oil mist detection above each Hydraulic Power Unit was completed on January 29, 1985.
PSC is in full compliance at this time.
Should you have any further questions, please contact Mr. Frank J. Novachek, (303) 571-7436, ext. 201.
Sincerely,
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[J.W.Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/djc t1 a