ML20080M585

Responds to NRC 830824 Ltr Re Violations Noted in IE Insp Rept 50-267/83-22.Corrective Actions:Welder Received Documented,Verbal Reprimand Re Failure to Follow Proper Procedures for Welding in Elevated Area

ML20080M585
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/19/1983
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-83317, NUDOCS 8310040210
Download: ML20080M585 (6)

Text

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i huhliOMrVICO Company Of?CEbMdD q 16805 WCR 19 1/2, Platteville, Colorado 80651 f N' September 19, 1983

! E i Fort St. Vrain i $I U Unit No. 1

! ( $P 2 gggg3 'I P-83317 i .

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Mr. John T. Collins, Regional Administrator U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76011

SUBJECT:

I & E Inspection Report 83-22

REFERENCE:

NRC Letter dated August 24, 1983

Dear Mr. Collins:

This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period July 1-31,1983. The following response to the items contained in the Notice of Violation is hereby submitted:

1. Technical Specification 7.4.a, " Procedures, Administrative Controls," states, in part, that, ". . . written procedures shall be established, implemented, and maintained . . . ."

Administrative Procedure P-8, " Fire Prevention and Fire Fighting," Issue 8, dated February 3, 1983, states, in part, "4.4.1 Fach employee whose assignment involves the use of combustibles'and/or ignition sources is required to employ appropriate safeguards and precautions as prescribed by the PSCo Manual of Safe Practices.

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"4.4.2 Welding - The foreman assigning a welding job is responsible for ensuring that:

"c) The welder is assisted by another man who shall watch for sparks, hot metal particles or problems while welding is in progress" PSCo Manual of Safe Practices, Section 112.03, states, in part,

"(b) When cutting or welding in elevated positions, proper precautions must be taken to see that sparks or hot metal do not fall on-people or inflammable material."

Contrary to the above, on July 26, 1983, the NRC inspector determined that a :Public Service Company welder was welding in an elevated area without the assistance of a fire watch and without taking the proper precautions to prevent hot metal from falling on people or inflammable material.

This is a Severisy Level V Violation. (Supplement I.E.)

(50-267/8322-01)

(1) The corrective steps which have been taken and the results achieved:

The violation was discussed with the employee. The importance of taking precautions to prevent molten metal and sparks from falling to lower elevations was emphasized, as well as the importance of fire watch job briefings. ,

The employee received a documented, verbal reprimand for his failure to follow procedure. The employee was informs that future violations of this type would result in more severe disciplinary actions.

(2) Corrective steps which will be taken to avoid further violations:

A training program for Maintenance welders will be completed, to include a review of Administrative Procedure P-8, and the importance of providing a thorough job briefing for personnel acting as a fire watch.

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4 (3) The date when full compliance will be achieved:

The training program will be completed by October 14, 1983. No other actions are anticipated.

2. Technical Specification 7.4.a, " Procedures, Administrative Controls," states, in part, that, ". . . written procedures shall be established, implemented, and maintained . . . ."

Surveillance SR 5.8.2bc-M, " Radioactive Liquid Effluent System Instrumentation Functional Test," Issue 51, dated March 3, 1983, Section 5.4, " Test Procedure - Release from 62 System Tank / Receiver," states, in part, "5.4.9 START P-6202 or P-6202S then adjust release rate to a value less 'han or equal to the value recommended on the release form using HV-6212."

Administrative Procedure P-4, " Surveillance Testing Program," Issue 3, dated October 26, 1981, Section 4.2.3 states, in part, "e) If a Surveillance Test cannot be run in normal sequence or changes must be made to the procedure,

, a Procedure Deviation Report must be filled out.

Changes to the procedure, which do not change the intent of the original procedure, may be made with I the concurrence of two members of the Plant

( Management Staff, at least one of whom holds a senior reactor operator license prior to running

the revised test."

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Contrary to the above, on July 18, 1983, the NRC inspector determined that the licensee was not using HV-6212 to l adjust the release rate and no procedure deviation report had been issued.

This is a Severity Level V Violation. (Supplement I.E.)

(50-267/8322-02) 1

(1) The corrective steps which have been taken and the results achieved:

The valve lineup in the subject surveillance has been revised to

.give the operator an option in performing the flow control, if required.

(2) Corrective steps which will be taken to avoid further violations:

Our letter P-83285 states the corrective actions to be followed to reduce failure to follow procedure errsrs.

The full implementation of P-83285 is viewed as a portion of the corrective steps for this violation.

(3) The date when full compliance will be achieved:

Full compliance was achieved prior to September 10, 1983.

3. Technical Specification 7.4.a, " Procedures, Administrative Controls," states, in part, that, . . . written procedures shall be established, implemented, and maintained . . . ."

Administrative Procedure P-1, " Plant Operations,"

Issue 10, dated July 14, 1983, states, in part, that, "4.4.1 A Station Log is maintained for each day with all  ;

entries made on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> clock basis. The Log i assures communication of information necessary to j maintain continuity between shift changes of operating personnel. The Station Log serves as the official record of plant operaticns and j

conditions. It consists of:

I l "b) The Operator's Log in which the appropriate operators document:

"2) A logged chronological listing and description of events occurring during the shift that may be of concern to operating and supervising personnel; including:

"iii) Any Plant condition that could possibly affect compliance with Technical Specifications. The Shift Supervisor must be notified of any such conditions."

Surveillance SR-0P-20-W, " Technical Specification Compliance Log," Issue 11, dated December 29, 1982, states, in part, "5.2 TEST PROCEDURE - UPDATING REQUIREMENTS TO UPDATE THE LC0 DISPLAYS UNDER THE FOLLOWING CONDITIONS:

"5.2.3 Whenever plant conditions change such that you begin using an- LCO grace period."

Contrary to the above, on July 28, 1983, the NRC inspector determined that the operator's log did not document entrance into or removal from the grace period of LCO 4.2.17 nor was the LCO display updated to reflect using the LCO 4.2.17 grace period.'

This is a Severity Level IV Violation. (Supplement I.D.)

(50-267/8322-04)

(1) The corrective steps which have been taken and the results achieved:

The operators involved were notified of the requirement for improvement in log-keeping. A memo (PPC-83-2321) has been written to all Operations personnel to emphasize the importance of accurate logs. This memo also provides guidelines on required log entries.

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(2) Corrective steps which will be taken to avoid further violations:

Our letter P-83285 states the corrective actions to be followed in an attempt to reduce failure to follow procedure errors.

The full implementation of P-83285 is viewed as a portion of the corrective steps for this violation.

.(3) The date when full compliance Mill be achieved:

9-19-83.

Should you have any further questions, please contact Mr. L. Milton McBride, (303) 571-7436, ext. 201. ,

Very truly yours,

~ W Wisu n A Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DW/djc l

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