ML20115A790

Supplemental Response to Violations Noted in Insp Rept 50-267/96-02.No Corrective Actions Planned

ML20115A790
Person / Time
Site:	Fort Saint Vrain
Issue date:	07/03/1996
From:	Borst F PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-96052, NUDOCS 9607080443
Download: ML20115A790 (3)

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G rubiic 16805 WCRservice-191/2; Platteville, Colorado 80651

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July 3,1996 Fort St. Vrain P-96052 U.S. Nuclear Regulatory Commission A'ITN: Document Control Desk Washington, D.C. 20555 Docket No. 50-267

SUBJECT:

Suppleinental Reply to a Notice of Violation (NRC Inspection Report No. 50-267/96-02)

REFERENCES:

1. PSCo Ietter, Borst to Document Control Desk, dated May 29,1996 (P-96043)

2. NRC Letter, Scarano to Crawford, dated April 29, 1996 (G-96066)

Gentlemen:

This letter provides supplemental information for Public Service Company of Colorado's (PSCo) original response (see Reference 1) to the Notice of Violation transmitted by the Reference 2 letter. This information is based on discussions with members of the NRC's NMSS Staff and Region IV Staff on July 1 and 2,1996. l The violation transmitted by Reference 2 involved failure to adhere to the Decommissioning Plan's quality assurance procedures, particularly regarding the final survey program. The NRC cited four examples of procedure noncompliances observed during their site visit of March 18-21, 1996. In our original response (Reference 1),

PSCo admitted Examples 2 and 3. After further consideration, PSCo would like to amend our response as follows:

Example 1: Failure to Use OA Accentance Tap 4 The violation is admitted. PSCo and the Westinghouse Team (WT), which includes the Scientific Ecology Group (SEG), acknowledge that the procedural requirements in SEG/QA-10.1, " Inspection," regarding use of QA acceptance tags are not sufficiently clear, and that SEG/QA-10.1 does not state that Receipt Inspections (which do not require acceptance tags) are appropriate for inspecting g' l quality services such as instrument calibrations performed by vendors.

9607000443 960703 i/Q PDR ADOCK 05000267 G PDR [

P-96052 July 3,1996  ;

Page 2 We continue to believe that Receipt Inspections should be used to document i receipt of instruments from calibration vendors, in lieu of Acceptance Inspections (which would require QA Acceptance Tags). Therefore, we will revise QAP-122, the WT Fort St. Vrain (FSV) Quality Assurance Plan for the Radiation Protection Program and Final Site Survey, to clarify use of SEG/QA-10.1, as follows: )

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• QAP-122 will be revised to state that Receipt Inspections are to be performed for items and services, such as for instruments received back from calibration vendors. 1

• In addition, as stated in the Reference 1 letter, QAP-122 will be revised to require that receipt inspection reports be provided to the SEG Instrumentation Group along with vendor calibration documentation, as confirmation that QA has completed their receipt inspection and l determined the instrument's acceptability. l

• QAP-122 will be revised to reflect these changes by July 22,1996.

No further corrective actions are planned.

Example 4: Failure to Adequately Implement the Audit Program This violation is admitted. PSCo and the WT acknowledge that SEG internal audits did not address all applicable criteria at least once per 18 months, as required.

PSCo and the WT corrected this condition with SEG Audit 96-03(I). After the NRC's site inspection in March 1996, SEG reviewed the plan for audit 96-03(I) and made appropriate revisions to ensure that the audit addressed all quality criteria applicable to the decommissioning project. SEG Audit 96-03(I) was performed from April 1-4, 1996. This audit was observed by PSCo QA personnel and was confirmed acceptable, as documented in PSCo QA Monitoring 96-031. Also, PSCo's independent QA auditor, Nuclear Energy Consultants, Inc.  ;

(NEC), reviewed SEG Audit 96-03(I) during NEC's QA audit in April and May, i 1996, and confirmed its acceptability. PSCo considers that we have been in full )

compliance with the Audit Program requirements since the report for SEG Audit  !

96-03(I) was issued on April 25,1996.

No further corrective actions are p:anned.

P-96052 July 3,1996 Page 3 PSCo, SEG, and the rest of the Westinghouse Team appreciate this opportunity to clarify the issues involved in this violation. If you have any questions regarding this .

I information, please contact Mr. M. H. Holmes at (303) 620-1701.

Sincerely, hdLN Y Frederi J. Borst Decommissioning Program Director FJB/SWC c: Regional Administrator, Region IV Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Public Health and Environment 1

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