IR 05000267/1986023

Insp Rept 50-267/86-23 on 860811-15.Violation Noted:Failure to Perform Periodic Reviews of Audit Program,Failure to Have & Review Exams for Lead Auditors,Failure to Have Records Checklist & Failure to Have Notices for Audits

ML20215M730
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/15/1986
From:	Boardman J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215M724	List: IR 05000267/1986023 ML20215M723 ML20215M725
References
50-267-86-23, NUDOCS 8611030207
Download: ML20215M730 (5)

Text

_ _ _ . _ _ _ _ _ _ _ - _ _ . __ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - -

.,

. .

. .

,

i APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/86-23 License: DPR-34 Docket: 50-267 Licensee: Public Service Company'of Colorado Platteville, Colorado Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection At: Platteville, Colorado Inspection Conducted: August 11-15, 1986 Inspector: lO!I N J. oarrdman, Reactor Inspector, Operations Date Sec 'on, Reactor Safety Branch Approved: ( &n2f6~ /Q//5YT$ l D. M. Hunnicutt, Chief, Operations Section, Date #

l Reactor Safety Branch '

Inspection Summary Inspection Conducted August 11-15, 1986 (Report 50-267/86-23)

Area Inspected: Licensee Audit Program Results: Within the area inspected, four violations were identified (failure to perform periodic reviews of the Fort St. Vrain Generating Station audit program, failure to have and to review examinations for lead auditors, failure to have a records checklist for required records, and failure to have notices for audits as required by procedure, paragraph 2).

8611030207 DR 861028 ADOCK 05000267 PDR

.

z_ _ _ _ _ _ _ _ _ . . _ . . _ _

\

.

. .

- 2 DETAILS 1.- Persons Contacted

• D. Warembourg, Manager, Nuclear Engineering

• C Fuller,-Station Manager

• L. W. Singleton, Manager QA

• R. L. Craun, Nuclear Site Engineering Manager

• A. L. Greenwood, Supervisor, QA Auditing

• M. J. Farris, QA Operations Manager

• F. J. Novachek, Technical / Administrative Services Manager

• T. E. Schleiger, HP Supervisor

• J. Gahm, Manager, Nuclear Production The NRC inspector also interviewed other licensee personne * Denotes those present at the exit intervie . Licensee Audit Program The NRC inspector reviewed the licensee audit program with the following findings: Failure to Perform Periodic Review of Licensee Audit Program 10 CFR 50, Appendix B, Criterion XVIII, requires a comprehensive system of audits to be performed. To accomplish such an audit program, the approved Fort St. Vrain Quality Assurance Program, Updated Final Safety Analysis Report (UFSAR), Revision 3, Section B.S.19.15, contains the licensee commitment to ANSI Standard N18.7-1972. This standard, in Section 4.1, requires periodic reviews by the owner organization of the licensee audit program. The licensee had no documentation of such reviews, and licensee personnel stated that these reviews had not been performe Failure to violation.(perform reviews of the audit program is an apparent 50-267/8623-01). Failure to Have and Review Examinations for Lead Auditors 10 CFR 50, Appendix B, Criterion XVIII, requires an audit program performed by appropriately trained personnel. To implement appropriate training, UFSAR Section B.5.18.2 states that auditors and lead auditors are selected and qualified in accordance with ANSI Standard N45.2.23-1978. ANSI N45.2.23-1978, Section 4.2, requires that copies of the objective evidence regarding the type (s) and contentofexamination(s)usedforqualificationofleadauditors

, .__ - __

_

, .. .

shall be retrained by the employer. The licensee had utilized outside training for qualifying PSC employees as lead auditors and did not have copies of the examinations used, or documentation of review of the examinations for conformance to ANSI N45.2.23-197 Failure to have copies of-examinations for lead auditors and to have reviewed them for conformance is an apparent violation (50-267/8623-02). Failure to Have a Records Checklist for Designating Required Records 10 CFR 50, Appendix B, Criterion XVII requires retention of records for activities affecting qualit Implementing this regulatory requirement, UFSAR Section B.5.19.9 contains the licensee commitment to ANSI Standard N45.2.9-1974, Regulatory Guide 1.88. Section 4.2 of the ANSI Standard specifies that, as a minimum, records receipt control shall include a records checklist designating the required record '

License Corrective Action-Action Report (CA-AR 406) dated October 18, 1981, resulting from audit QAA-1901-81-01, identified that the Fort St. Vrain records center did not have and use such a list as required

~

by FSAR B.5.17, " Records." The response to the CAR, which was accepted and approved, was to delete the requirement from FSAR B.5.17, which has been done. The licensee apparently did not i recognize that the requirement for a records checklist was to implement N45.2.9-1974, Section 4.2. The NRC inspector verified with the records center that such a checklist was not required by licensee procedure, or used by licensee personne Failure to use a records checklist as required by ANSI Standard N45.2.9-1974, Section 4.2 is an apparent violation (50-267/8623-03).

4 Failure to Provide Required Notices for Audits 10 CFR 50, Appendix B, Criterion V, requires activities affecting quality to be prescribed in, and accomplished in accordance with, documented procedure Licensee USAR Section B.5.5.1 contains the licensee commitment to ANSI Standard N18.7-1972. N18.17-1972, Section 5.1.2 requires the licensee to have and to follow procedures.

.

License Procedura QAAP-1, Issue 3, " Guidelines for Quality Assurance and Nuclear Facility Safety Committee Audits," effective November 27,

.

1985, states in Section 4.2.2 that a matrix which defines the applicability of the 18 criteria of 10 CFR 50, Appendix B, to each of

the QA audits is contained in Attachment QAAP-1D and is to be a major element in the development of audit plans and checklists.

j

. , . . ,. -. . - - _ . - . . _ _ . - _ _ - - , , , _. . . - . _ , - . - - - . _ . _ -

. ..

Based on a list provided to the NRC inspector of audits performed under the auspices of the QA Division, the following licensee audits did not have matrices in Attachment QAAP-ID:

QAA-502 M Program for Radioactive Waste Packages QAA-503 Spent Fuel and Radioactive Waste Shipping QAA-1003 Procurement QAA-1004 Maintenance QC & QA/QC QAA-1301 Results QAA-1402 Environmental Qualification

'

QAA-1404 Nuclear Licensing and Fuels QAA-1703 Unescorted Access Qualifications QAA-1802 Commitment Review QAA-3000 Miscellaneous

'

NSFC-C Corrective Action NSFC-D QA Program failure to have required notices is an apparent violation (50-267/8623-04).

e. Unresolved Items Resulting From Review of Licensee Audit Finding CARS As stated in Section 2.c above:

USAR Section B.5.19.9 contains the licensee's commitment to ANSI Standard N45.2.9-1974, Regulatory Guide 1.88. The ANSI Standard addressed such records system requirements as:

(1) Single record storage (Section 5.6). Licensee CAR 86-013 addresses this attribute for NED Document Contro (2) Safekeeping (Section 5.5). Security of the records storage area is discussed in CAR 86-01 The NRC inspector had concerns of record system adequacy in these areas, based on review of closed licensee audits, which are an unresolveditem(8623-05) pending further review during a subsequent inspectio The NRC inspector noted that a formal Stone and Webster assessment of the Fort St. Vrain records center, dated June 13, 1986, contained a number of findings, including identification of a remote records storage area identified as the " Rocky Mountain Records Center" that had never been audited for compliance with ANSI N45.2.9-1974, Regulatory Guide 1.88. The review of these findings is an unresolved item (8623-06) to be accomplished during a subsequent inspectio Licensee audit finding QAR 86-012 identified deterioration of records. Though recommended corrective action was to build a new records center, no action was identified to assess overall record deterioration and to preclude further deterioration prior to

,

, . - - . . _ . . - --

---______- -_ ___ ____- __-___ _ _ _ _ _ _ _

.

, .. -

J

.5 completion of the new facility. This will remain an unresolved item j (8623-07) pending review by the NRC inspector during a subsequent inspectio . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Three unresolved items identified during the inspection are discussed in paragraph . Exit Interview J The NRC inspector met with the licensee representatives denoted in paragraph 1 and the NRC resident inspector at.the conclusion of the inspection on August 15, 1986. The NRC inspector summarized the purpose, scope, and findings of the inspection.

!

l l

l

.. . .

- - _ _ _ _ _ _ _ _ _ .