ML20212B236

Supercedes 870105 Response to Violations 2,3 & 5 Noted in Insp Rept 50-267/86-25 on 860816-0930.Corrective Actions: Procedure G-2 Revised to Require That All Future Revs to ENG-1 Be Reviewed by Plant Operations Review Committee

ML20212B236
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/20/1987
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20212B242	List: ML20212B236 ML20212B268 ML20212B285 ML20212B308
References
P-87070, NUDOCS 8703030504
Download: ML20212B236 (8)

Text

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company of colorado February 20, 1987 Fort St. Vrain Unit No. 1 P-87070 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Docket No. 50-267

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, as originally stated in Reference 3. These violations were the result of inspections conducted at Fort St. Vrain during the period August 16 thru September 30, 1986.

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P-87070 Page 2 February 20, 1987

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 committee (PORC).

Contrary to the above, procedures ENG-1 (" Control of Modifications and documentation"), and CWPM (" 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 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, 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.

P-87070 Page 3 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 I - 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 from 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 control. Engineering procedures, subordinate to Q-3 and G-9, do not govern plant operations and therefore do not require PORC 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 Committee (PORC). As the main controlling engineering i

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:

, ENG-1 will be reviewed by PORC.

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

Administrative Procedure G-2 will be revised to require that all future revisions to ENG-1 be reviewed by PORC.

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P-87070 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.

l 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 1 that the " Check List of Design Verification Questions for Design i

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.D.)(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 ED-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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A P-87070 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., IDV, 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.

The signature by the person doing the IDV on both the IDV 2 checklist page and on the coordination sheet for CN-1876 i (see Attachment 6) explicitly documents that the independent design verifier has performed functions on all appropriate 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 numbers was explicitly included on the CN coordination 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 performed all the requirements in the preparation and review of the subject Change Notice in accordance with procedures and regulations. However, the NRC has identified what PSC considers to be a weakness, in that several IDVs/ reviews / approvals have been performed without detailed documentation identifying why the several signatures were required.

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

On December 9, 1986 the Nuclear En an instructional memo (NDG-86-1647)gineering reiterating the Division design issued verification process and procedural requirements.

In addition, our engineering procedures have been changed and a new form created so that more explicit documentation will be required when a CN package receives more than one set of IDV/ review / approval. This procedural change was implemented on January 16, 1987.

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P-87070 Page 6 February 20, 1987 i

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

Corrective steps have been implemented see (2) above.

(4) The date full compliance will be achieved:

Full compliance was achieved on January 16, 1987.

5. Failure to Implement Corrective Actior. Program Criterion XVI to 10 CFR Part 50, Appendix B, requires that measures be established to assure that conditions adverse to quality, such as failures, mal functions , deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, the installation instructions for CN-1876 noted that numerous discrepancies were identified with the existing vendor design documents and the actual field installation, but no corrective action was initiated to review other areas of the vendor documents not affected by the change notice for similar discrepancies.

This is a Severity Level IV violation. (Supplement I.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 connon point terminations. These discrepancies were between the actual common points used to terminate circuit connections and the way they were represented on the wire lists. At this point in the design process the designer performed 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 applicable terminations prior to modification or removal.

Subsequent verification by construction personnel resulted in one additional common point discrepancy being identified.

Page 7 February 20, 1987 The CN was modified by a Deviation Request to document the deficiency.

In all cases where discrepancies were uncovered, either by the designer or construction personnel, only common point terminations were involved. The discrepancies uncovered during the verification process did not affect the functional integiity 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 common point terminations.

However, PSC commits 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.

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(2) The corrective st'eps which have been taken and the results achieved:

No action has been taken at this time, i

(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 i

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 Page 8 3 February 20, 1987 J

, Should you have any questions concerning this response, please contact Mr. M.H. Holmes at (303) 480-6960 for additional information.

Very truly yours, hEJnw&

D.W.Warembourg,Mahkger l

Nuclear Engineering Division DWW/ RAS:pa Attachments cc: Regional Administrator, Region IV Attention: Mr. J. E. Gagliardo, Chief j Reactor Projects Branch Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain i

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