IR 05000267/1981002
| ML20003G286 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/11/1981 |
| From: | Boardman J, Gagliardo J, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20003G284 | List: |
| References | |
| 50-267-81-02, 50-267-81-2, NUDOCS 8104280684 | |
| Download: ML20003G286 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
IE Inspection Report No. 50-267/81-02 Docket No. 50-267 License No. DPR-34 Licensee:
Public Service Company of Colorado
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P. O. Box 840 Denver, Colorado 80201 Facility Name:
Fort St. Vrain Nuclear Generating Station Inspection at:
Fort St. Vrain Site, Platteville, Colorado Inspection conducted:
January 26-30, 1981 Inspectors:
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J./ R! Boardman, Reactor Inspector Date (/
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P. Jaudon, Reactor Inspector Date Reviewed by b
N J.(i.Gagli rdo, Chief, Nuclear Support Section f Date Approved by:
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TY F! W4sterman,JChief,f rojects Section No. 1 Oste P
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Inspection Summary Inspection conducted during period of January 26-30, 1981 (Report No. 50-267/81-02)
Areas Inspected:
Routine, unannounced inspection including Procurement Program, Personnel Qualification Program, Organization and Administration and Onsite Review Committee.
The inspection involved 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> on-site by two NRC inspectors.
Results:
Of the four areas inspected, two apparent violations (failure to follow procedural requirements in procurement - and failure to establish adequate measures for procurement, paragraph 2) were identified in one area.
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DETAILS SECTION 1.
Persons Contacted Public Service Company of Colorado
- J. Bissett, Supervisor QA/QC
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- L. Brey, QA Manager T. Chrisler, Training Instructor W. Franek, Results Supervisor W. Hillyard, Administrative Services Manager A. Kitzman, Clerical Supervisor F. Mathie, Operations Manager
- L. McInroe, Supervisor, QA Services J. Van Dyke, Shift Supervisor R. Wadas, Training Supervisor
- D. Warembourg, Manager, Nuclear Production
- Indicates presence at exit interview.
The inspectors also contacted other plant personnel including administrative and QA personnel.
2.
Quality Assurance Program for Procurement a.
The inspectors reviewed the licensee's implementation of the Fort St.
Vrain Quality Assurance Program for material procurement to verify conformance with regulatory requirements as defined by 10 CFR Part 50 Appendix B; Fort St. Vrain (FSV) Nuclear Generating Station FSAR Appendix B, Quality Assurance; and implementing procedures and instructions.
b.
The inspectors noted and discussed with licensee representatives the following cases of apparent violations of their regulatory require-ments and with their approved procedures and instructions:
(1) The inspector reviewed selected licensee files of completed Quality Related purchase orders from 1977 through 1980.
It was noted that licensee standard forms "N", (purchase order attachments relating to requirements for cleanliness, packaging, marking, handling, storage and shipping) were not included with the applicable official purchase orders, even though the licensee's attached Checklists For The Review of Quality Related Purchase Order Files were signed off verifying that the Purchase Order record file was complete.
The signature signified that the file contained as a minimum a copy of the purchase order with all Quality and Documentation requirements and attachments.
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Licensee Procedure Q-7, Attachment Q-7G, requires utilization of the subject checklist "when assembling completed PO files prior to transmittal to permanent storage." This procedure implements the requirement of 10 CFR Part 50, Appendix B, Criterion V, for establishment of procedures affecting quality.
The failure of licensee personnel to comply with Attachment Q-7G of Licensee Procedure Q 'l constitutes a violation of the
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10 CFR Part 50, Appendix B, Criterion V requirement of adhering to documented instructions affecting quality.
(8102-01)
(2)
In discussions with licensee personnel concerning the apparent violation cited above, the inspector questioned if the licensee's receiving inspections were verifying accomplishment of the purchase order attachments forms "N" as applicable.
Licensee personnel stated that these forms had been sent only to suppliers as attachments to purchase orders, but were not included on internal distribution.
As a result, licensee receiving inspections had not been verifying the requirements of Forms "N".
This problem area had been identified by the licensee in licensee Action Request CAAR-19, dated September 26, 1980.
A licensee repre-sentative stated that corrective action had been initiated and was scheduled for completion in December 1980, but had not yet been completed.
Licensee FSAR, Appendix B, Section B.57 states, " Procurement documents will be available at the point of receipt for use in carrying out receiving inspections." Also, Licensee Procedure Q-7 Control of Procured Materials and Devices, Section 4.6 QA/QC Receiving Inspection requires performance of receiving inspection utilizing a copy of the purchase order.
This procedure implements
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10 CFR Part 50 Appendix B Criterion V relative to documented
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instructions for activities affecting quality.
Failure of the licensee to provide attachments to procurement documents (Forms ";?), i.e., a complete purchase order, for accomplishment of receiving inspections constitutes another example of the apparent violation of the 10 CFR Part 50 Appendix B, Criterion V requirement cited in paragraph 2.b.(1)
above.
(8102-02)
(3) As a part of the review of purchase order files in permanent storage the inspector reviewed completed Procurement Reouisition Review Record forms, Attachment Q-4F of Licensee Proceoure Q-4.
l Licensee personnel had not been recording on the form the
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specific criterion, document number, or description in the
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" comment" column.
Attachment Q-4F requires inclusion of "the specified criterion or document number or description in the
' comments' column, e.g. ' Appendix B, X, XV & XVII.'"
The above violation of Procedure Q-4 constitutes another example of the apparent violation of the 10 CFR Part 50, Appendix B, Criterion V requirement cited in paragraph 2.b.(1) above.
(8102-03)
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(4) The inspector reviewed purchase order N3222 for a 3/4-inch stain-less steel composition B16 socket weld valve with hydrostatic and seat leak tests specified to verify that the requirements of licensee procedure Q-4 Procurement Document Control, Section 4.3 QA Review had been met.
Attribute d) 6) of Section 4.3 outlines
" Handling, Packaging, Shipping and Storage per FSV-STD-1" Note:
FSV-STD-1 Cleanliness, Packaging, Shipping, Receiving Storage and Handling Associated with Quality Related Procurement was issued in Response to ANSI N45.2.2 and Regulatory Guide 1.38 and approved by the Nuclear Project Manager.
The subject purchase order was for a stainless steel valve and licensee standard form N110 had been selected and used as the purchase order attachment in accordance with Attachment 7.1 of FSV-STD-1.
The inspector then reviewed the purchase order against Attachments 7.2 through 7.8 of FSV-STD-1 to see if there were other standard paragraphs which were applicable to this purchase order and should have been utilized.
The following paragraphs in FSV-STD-1 were considered applicable to this purchase order but were not used:
G0007 Requires a vendor instrument calibration program.
i G0008 Requires vendor documentation of inspection and test l
results. "It should be used whenever inspections or tests are expected."
G0010 Requires the vendor to prepare and maintain record copies of software and "... should be used where... records, etc. will be generated by the vendor and where PSC anticipates that these might be required to satisfy traceability, production or other activities."
P0016 Establishes special restrictions on wrap and vapor barrier materials used in conjunction with stainless steel.
(The use of wrap or vapor barrier was not prohibited in the order).
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P0019 Establishes special restrictions on desiccant when used in conjuction with stainless steel.
(The use of desiccant was not prohibited in the order.)
P0037 Provides directions for applying nameplates "Use whenever nameplates are required or may be used."
P0038 Specifies minimum information to appear on nameplates.
"Use whenever nameplates are required or may be used."
Note:
FSV-STD-1 does not contain prohibitions in the section on Marking of Items against marking critical or machined surfaces.
R0002
"PSC Receiving:
This statement provides general directions for PSC receiving activities and should be used for all items.
(Applicable to all levels.)
(PSC ONLY.)"
Licensee Procedure Q-4 requires incorporation of the require-ments of FSV-STD-1 in purchase requisitions.
Procedures Q-4 and FSV-STD-1 are issued to implement the requirements of 10 CFR Part 50, Appendix B, Criterion V, for prescribing by documented procedures activities affecting quality.
The above item is a violation of Licensee Procedure Q-4 since it fails to include applicable paragraphs of FSV-STD-1 in purchase orders and this constitutes another example of the apparent violation of Criterion V of 10 CFR Part 50, Appendix B as cited in paragraph 2.b.(1).
(8102-04)
(5) As part of the review of licensee procurement practices the inspector reviewed licensee procedure Q-4 Procurement Document Control.
Section 4.1 of this procedure entitled Material Requests states:
"The individual other than NPD personnel identifying the need for procurement of an item or service is required to obtain and fill out a Material Request Form (Attachment Q-4A).
The initiator determines and indicates, by reference to the Quality Related Item List (Attachment Q-48), whether the item is ' quality-related. '
He obtains his supervisor's approval signature and forwards the MR to the Plant Store-keeper."
The Quality Related Items List under Part I includes in part
" Included Items
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"4.
Electronic Parts - To Specifically Include:
a) (later)
"5.
Fuel a) (later)"
A review of the licensee procedures showed that documented procedures have not existed showing electronic parts as Quality
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Related Items or fuel for the emergency diesel generator as a quality related item for procurement.
Failure to have documented procedures for inclusion of electronic parts for safety-related systems or fuel as Quality Related Items for procurement constitutes a violation of 10 CFR Part 50, Appendix B, Criterion II, which requires the licensee to identify the structures, systems and components to be covered by the Quality Assurance Program.
(8102-05)
As part of the review of procurement, the inspector reviewed the licensee's instructions for supplier approval contained in Procedures Q-7 Control of Procured Materials and Services and SSIM-1 Supplier Source Inspection Manual.
These proce-dures indicate licensee approval of suppliers based on the
" supplier approved by NRC" or "... the results of the latest NRC audit as represented in NUREG-0040 have been reviewed and found acceptable.... "
The or~
approvals shown in Section III of NUREG-0040 consist of Art.
-t Engineering firms.
No other information in NUREG-0040 indicates supplier acceptability.
Approval of suppliers based on NUREG-0040 would constitute a violation of 10 CFR Part 50, Appendix 8, since NUREG-0040 states not only (1) that the infor-mation contained therein is neither adequate or intended to standby itself as a source of information concerning qualified suppliers, but also (2) that the Region IV inspections will not relieve the licensees or applicants from any inspection / verification responsibilities required by Criterion VII.
This is an open item (8102-05) and will be reviewed during a j
subsequent inspection.
3.
Personnel Qualification Prooram The inspector reviewed the licensee's documentation for personnel selection and qualification.
The inspector found that this documentation established training, educational and experience requirements consistent with Technical Specification requirements and licensee commitments.
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The inspector reviewed training and other records to verify that selected personnel met or exceeded the minimum experience and qualification requirements for positions held within the licensee's organization.
The inspector noted that the detailed description of requirements for
" Technical Advisor," which, at Fort St. Vrain is the equivalent of
" Shift Technical Advisor," was maintained in a separate file.
Licensee representatives told the inspector that this was done pending final
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approval of Fort St. Vrain's implementation of the (shift) Technical Advisor concept.
There were no violations or deviations noted in this area of the inspection.
4.
Organization and Administration The inspector compared the licensee's organization with that delineated in Technical Specifications (Amendment 22).
The inspector also reviewed the licensee's implementation of Technical Specification requirements for personnel qualification, authority and training.
Shift crew manning was also checked and found to be in accordance with Technical Specification requirements.
Additionally, the inspector found that the composition of both on site and offsite review committees was as delineated in the Technical Specifications.
There were no violations or deviations found in this area of the inspection.
5.
Onsite Review Committee The inspector reviewed the licensee's program for the Onsite Review Committee.
The inspector attended a meeting of the Onsite Review Com-mittee.
The meeting was conducted by the assigned chairman and a quorum of members was present.
An agenda was provided.
This agenda was a draft copy of the proposed minutes.
In th+ agenda there was a description of each change to be reviewed and a statement of conclusion as to whether or not the change to be reviewed constituted an unreviewed safety question.
The chairman had all changes ard backup material at the meeting, and these were passed to the members present as each item was reviewed.
There was i
only limited discussion of the items reviewed.
The meeting lasted approxi-
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mately 20 minutes.
The inspector also determined the following:
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The Onsite Review Committee normally meets several times a week, an
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average of three times per week for a period of seven weeks for which the minutes were reviewed.
Minutes are published weekly; these minutes cover all meetings held
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during the week.
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The average length of a meeting for the seven week period reviewed
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was seventeen minutes (i.e., 58 minutes per week).
Attendence at individual meetings is rotated among the designated
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members so that there is always a quorum of members but seldom more in attendence.
The Committee Chairman and the Health Physics Supervisor attend all meetings, if they are on site.
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There were no violations or deviations found in this area of the inspection.
6.
Exit Interview An exit interview was conducted January 30, 1981, with those PSC of Colorado personnel denoted in paragraph 1 of this report.
At this meeting, the scope of the inspectiun and the findings were summarized.
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