IR 05000267/1987020

Insp Rept 50-267/87-20 on 870803-07.Violations Noted.Major Areas Inspected:Design Mod Changes

ML20238B541
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/27/1987
From:	Jaudon J, Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20238B528	List: IR 05000267/1987020 ML20238B525 ML20238B534
References
50-267-87-20, NUDOCS 8709010271
Download: ML20238B541 (6)

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APPENDIX 8 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/87-20 License: DPR-34 Docket: 50-267 Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840 3 Denver, Colorado 80201-0840 Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection At: FSV Site, Platteville, Colorado, and PSC Offices, Denver, Colorado Inspection Conducted: August 3-7, 1987 l

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Inspector: 1 /b 2N ruit< cum pdm 77 yu G. L. Madsen, Reactor Inspector, Operations Ddte

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Section, Reactor Safety Branch

- ! /Y Approved: (

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l udon, Chief, Project Section A qJgP.3jProjectsBranch Reactoi Da4e [

Inspection Summary i Inspection Conducted August 3-7, 1987 (Report 50-267/87-20) l

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Areas Inspected: Routine, unannounced inspection of design modification change Results: Within the areas inspected, one violation was identified (failure to closecut reviews of CWP packages prior to filing in the Records Center).

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DETAILS 1 Persons Contacted 1 I

Principal Licensee Employees i

• L. Brey, Manager, Nuclear Licensing and Fuels

• R. Craun, Manager, Nuclear Site Engineering M. Ferris, Manager, QA Operations j

• C. Fuller, Station Manager ~

• D. Goss, Coordinator, Nuclear Licensing and Fuels  !

• J. Gramling, Supervisor, Nuclear Licensing Operations

• M. Holmes, Manager, Nuclear Licensing D. Johnson, Supervisor, Site Engineering T. McIntire, Supervisor, Site Engineering

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• P. Moore, Supervisor, QA Technical Support

• F. Novachek, Manager, Technical / Administrative Services

• K. Owens, Commitment Analyst, Nuclear Licensing and Fuels

• T. Prenger, Manager, QA Service G. Reigel, Supervisor, Scheduling and Construction

• D. Seymour, QA Engineer, Operations

• P. Tomlinson, Manager, QA

• R. Walker, Chairman of the Board and CEO

• D. Warembourg, Manager, Nuclear Engineering

• R. Williams, Jr. , Vice President, Nuclear Operations The NRC inspector also contacted other licensee and contractor personnel during the inspectio J

• Denotes those attending the exit interview conducted August 7,198 R. E. Farrell, Senior Resident Inspector, attended the exit interview conducted on August 7, 198 . Design Changes and Modifications The purpose of this inspection was to ascertain that design changes and modifications that were determined by the licensee to not require approval by the NRC were in conformance with the requirements of the Technical Specifications and 10 CFR Part 50.5 The NRC inspector reviewed the following licensee procedures and documents:

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i Procedure Issue Date Title ENG-1 12 01/23/87 Control of Modifications and Document Changes ED-100 3 01/23/87 CN Preparation and Document Control G-1 16 01/07/87 Definitions G-9 7 02/15/87 Controlled Work Procedures Q-3 11 07/29/87 Design Control System SMAPP-18 3 12/11/86 Processing of Temporary Configuration Reports TASMAP-7 5 04/02/87 Fort St. Vrain Review Committee Guidelines Change Notices Controlled Work Procedures 1937 0246 1945A 85-0065 1945B 85-0066 1960 85-0302 2178 85-0354 2396 86-0131 86-0132 86-0133

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86-0134 86-0353 Tests Field Change Notice T-304 4143 T-308 The NRC inspector reviewed the selected Change Notices (CNs), Field Change q Notices (FCNs), and tests to _ verify that they had been reviewed and  ;

approved in accordance with regu " +1ons. Technical Specifications, and procedures. The safety evaluations were also reviewed to ensure that the licensee examined consequences in accordance with the requirements of 10 CFR Part 50.59. Controlled Work Procedures (CWPs) are the licensee's means of controlling the actual installation and testing for CNs and FCN The NRC inspector included the associated CWPs in the CN review. The review included post-modification tests and records, as-built drawings, and control of the work process. The review revealed one apparent violation and certain areas where the licensee should strengthen their program. The apparent violation was as follows:

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Procedure G-9, Section 4.10, " Controlled Work Procedures," requires CWP closecut reviews by Technical Service Engineering, the Work Review Committee, Nuclear Licensing and Fuels, Nuclear Site Construction, and Quality Assurance prior to forwarding of the l completed packages to the Records Cente During the review of CWP 86-0131, the NRC inspector found that three of the eight applicable results packages had not been signed by the j I&C supervisor on page 25 of Results Procedure RP-EQ-1. Upon further

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questioning, the NRC inspector was informed that CWP 86-0131 had not received a closeout review as required by Section 4.10 of Procedure G-9. Additional followup revealed that CWPs 86-0132, 86-0133, and 86-0134 had been handled in the same manner. These four j CWPs (86-0131, 86-0132, 86-0133, and 86-0134) are associated with a '

common Change Notice (CN-2178). The filing of the results packaoes in the records center prior to completion of the CWP closecut review required by Procedure G-9 was identified by the NRC inspector as an apparent violation (267/8720-01).

During the inspection, the licensee withdrew the results package for CWPs 86-0131, 86-0132, 86-0133, and 86-0134 from the records center and merged them with the appropriate CWP packages for closecut review In addition to the above violation, the NRC inspector noted conditions

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where the licensee should strengthen their program. The following was ,

included:

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The procedural coverage is complex and procedural inconsistencies I exist. As an example, Procedure ENG-1 contains a flow chart which indicates that safety significant changes are to receive review by 4 the Plant Operation Review Committee (PORC). However, this step is l not being accomplished during the CN process, but is handled during i the CWP process.

i The individual groups involved in the CN and CWP process seem to know their duties and responsibilities, but the awareness of the involvement of others is lackin Work was completed on FCN 4143 and the associated CWP-246 in 1978; however, this item was not reported to the NRC until July 198 Additionally, CN-2396 and the associated CWP 86-0353 were completed in November 1986; however, the CWP package final review had not been performed until August 6, 1987. The NRC inspector determined that the CWP package had arrived in quality assurance in April 198 These are examples which indicate a need for better control of the stepwise process, the establishment of priorities, and the completion of activities in a more timely manner. Work Packages 246 and 86-0353 were both classified as safety significant by the licensee review proces _ - - _ -

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The NRC inspector's review of the Temporary Modification Program, as presented in Procedure SMAPP-18, revealed the absence of testing of temporary modifications at the time of installation or remova Additionally, Procedure SMAPP-18 does not specify a restrictive length of time that a temporary modification can be utilize PSC initiated a quality assurance audit of the design modification activities which was performed during May and June 198 The NRC inspector reviewed the subject audit report and noted that the audit findings and recommendation encapsulated the above NRC inspector's findings where the licensee should strengthen their progra Conclusions and Recommendations Although some problems and improvement areas were identified with the plant modification programs, the NRC inspector's review indicated that the licensee's safety evaluations were in conformance with 10 CFR Part 50.5 Additionally, the inspector's review indicated that the existing procedures covered the various requirements; however, the complexity of the procedures makes accomplishment of the activities in a timely manner difficult. The May through June 1987 QA audit report in the area of design control was considered comprehensiv . Exit Interview

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An exit interview was held on August 7, 1987, with those indicated in paragraph 1 of this report. The NRC senior resident inspector attended the meeting. At the meeting, the scope of the inspection findings were summarize ;

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