ML20207J892
| ML20207J892 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/17/1986 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20207J881 | List: |
| References | |
| P-86427, NUDOCS 8607290286 | |
| Download: ML20207J892 (9) | |
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Public Service company of colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 June 17, 1986 Fort St. Vrain Unit No. 1 P-86427 Regional Administrator
.4 F Attn: Mr. J. E. Gagliardo, Chief i
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Reactor Projects Branch
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i U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 g
Arlington, Texas 76011 Docket No. 50-267
SUBJECT:
I&E Inspection Report 86-08
REFERENCE:
NRC Letter, Gagliardo to Walker, dated 05/19/86 (G-86265)
Dear Mr. Gagliardo:
This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period March 3-7, 1986.
The following response to the items contained in the Notice of Violation is hereby submitted:
During the NRC inspection conducted on March 3-7, 1986, four violations of NRC requirements were identified.
The violations involved failure to follow procedures, failure to control design changes, and failure to follow Technical Specification requirements.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2,
Appendix C (1985), the violations are listed below:
A.
Failure to Follow Procedures Technical Specification AC 7.1.2, " Plant Operations Review Committee (PORC), Administrative Controls," requires PORC review of certain documents and change thereto.
The PORC Charter, Issue 1, dated November 23, 1983, defines " review" as a " deliberate critical examination..."
B607290286 860723ADOCK 05000267 PDR PDR G
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. Contrary to the above, the NRC inspector attended the PORC meeting on March 3, 1986, and observed that the PORC members did not perform a deliberate critical examination of documents presented to them for review during the meeting but rather did a cursory and superficial review of documents presented.
This is a Severity Level IV violation (Supplement I) (50-267/8608-1).
(1) The reason for the violation if admitted:
Section 1.0,
" Introduction" of the Charter For Plant Operations Review Committee For the Fort St. Vrain Plant states in part that
"... the personnel assigned to the Committee are senior members of the onsite staff who as a group are thoroughly familiar with the safety implications of the day-to-day operations activities and the administrative controls and procedures governing these activities."
Section 6.9,
" Meeting" states that "At least one member, or his/her alternate attending the meeting shall have expertise in the subjects and/or activities to be reviewed."
Specific personnel are assigned to participate in PORC by the Station Manager.
The nature of the regular duties performed by these individuals is part of the criteria which qualifies them for consideration for inclusion in the Committee membership.
Through performance of their regular
- duties, members or alternates are normally aware of the items offered for committee consideration prior to their submittal.
Section 4.0, " Method of Fulfilling Responsibilities" of the Charter, " includes a discussion of how PORC receives or is made aware of activities that must be reviewed, the action by PORC and the specific documentation, where applicable, that shall be reviewed and/or approved to assist in assuring that the plant activities are conducted safely and in accordance with administrative controls."
A number of programs have been implemented since the issuance of the original PORC charter which ensure that a detailed review of the majority of PORC - approved documents takes place prior to submittal to PORC.
For example, the activities of the Work Review Committee have been enhanced for the review of design modification.
Technically oriented procedures are reviewed against the criteria established by Station Manager Administrative Procedure
- Eleven, (SMAP-11)
" Departmental Procedure Reviews." Independent reviews of these procedures are performed by the Quality Assurance Organization.
Special sub-commitees of the PORC have been established for non-routine activities, such as Technical Specification changes.
- Finally, Committee members are often a part of the approval process for the above described activities prior to submittal to PORC.
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o e The intent if these programs is not to diminish the review responsibility of PORC. However, they do significantly improve the overall quality of the review and the ability of PORC to act on submittals in a more timely manner.
At the time of the inspection, the cited deficiency in the PORC charter had already been identified.
A revision to the PORC charter is in the approval process and is further described below.
(2) The corrective steps which have been taken and the results achieved:
Corrective actions to relative problems with Fort St. Vrain PORC were underway prior to this violation.
The PORC charter was rewritten and will be issued as a Nuclear Production Administrative Procedure (NPAP-2), in the near future. Committee members were polled for input into the revision effort. They were specifically requested to address problems they believed should be addressed. The revised charter includes more complete definitions of items to be considered.
The techniques for performing PORC examinations have been expanded and developed. A program for development of "PORC Member Orientation" was initiated with the Fort St.
Vrain Training Section.
This orientation will specifically address the processing of PORC reviewed documents.
(3) Corrective steps which will be taken to avoid further violations:
The new PORC Charter will be issued; all present and future PORC members and alternates will be required to review this document.
All current PORC members and alternates will be required to attend "PORC Member Orientation".
All future members and alternates will be required to attend this training before assuming their responsibilities on PORC. All present and future Committee members and alternates will be required to attend an approximately annual review through this training program.
(4) The date when full compliance will be achieved:
NPAP-2, Charter For Plant Operations Review Committee For Fort St. Vrain Nuclear Generating Station will be issued in the near future.
"PORC Member Orientation" will be developed and all current Committee Members will receive this training by July 31, 1986.
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B.
Failure to Control Design Changes 10 CFR, Appendix B, Criteria III, requires that design changes will be subject to design control measures commensurate with those applied to the original design.
Contrary to the above, design changes were not subject to measures commensurate with the original design as evidenced by the failure to incorporate design changes to Change Notice CN-1798A as directed by the disposition of Deviation Request DR 85-35-1-H.
This is a
Severity Level IV violation (Supplement I)
(50-267/8608-04).
(1) The reason for the violation if admitted:
Administrative Procedure G-9, Issue 6, titled " Controlled Work Procedures", requires that a CN/CN reissue be prepared if design documents or design output information was affected the Deviation Request (DR).
The most commonly used method by which documentation affected by a DR is updated is a reissue to the CN that performed the change.
Procedure G-9, however, does not require you to use a reissue of the original CN as this allows some flexibility in which CN package will perform the document update. To flag the "As Built Verification" process that a CN/CN reissue is required, the DR form has boxes to indicate that this activity is required. Since the CN/CN reissue required box was incorrectly checked "No", subsequent reviews which occur during
.i the "As Built Verification" process would not have found that a CN/CN reissue was required.
If, however, the CN/CN reissue box had been checked "Yes", the "As Built Verification" process would have verified that CN-1798A had or had not done the updating and initiated to apporpriate corrective action.
Since this is an unusual and infrequently used document updating method, it is considered an isolated case.
(2) The corrective steps which have been taken and the results achieved:
Upon being informed of this problem, a Non-Conformance Report (NCR) (NCR-86-108) was written to document the problem with DR 85-35-1-H.
After reviewing the NCR, CN-1920C was prepared and forwarded for approvals on March 7,1986 to correct the problem.
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, (3) Corrective steps which will be taken to avoid further violations:
A memo (NFG-86-0436) has been written to all DR approvers to clarify how they should review the CN/CN reissue required boxes.
(4) The date when full compliance will be achieved:
June 17, 1986.
C.
Failure to Follow Technical Specifications i
Technical Specification AC 7.1.2, " Plant Operations Review Committee (PORC), Administrative Controls," states that "An alternate chairman
.. shall be appointed in writing by the PORC Chairman to serve in the absence of a chairman..."
Contrary to the above, in a memo dated October 18, 1985, the PORC Chairman appointed four alternate chairmen, one to automatically serve on each of the four working days that the chairman would not be required to attend.
This is Severity Level V violation (Supplement I) (50-267/8608-02).
(1) The reason for the violation if admitted:
The practice of having individuals assigned responsibility as Alternate Chairman for each day of the week has been in effect for quite some time.
ANSI Standard N 18.7-1972, section 4.5, "On-Site Review" was used as a basis for development of the Charter For Plant Operations Review Committee For the Fort St.
Vrain Plant. The Standard states, in part, that, " Reviews should be performed periodically, and as situations demand to evaluate plant operations and to plan future activities."
The PORC
- Charter, section 2.0 " Responsibility of PORC" states that, "The broad responsibility of PORC is to provide timely and continuing monitoring of operating activities to assist the Station Manager in keeping abreast of general plant conditions, and to verify that the day-to-day operating activities are conducted safely and in accordance with administrative controls and procedures."
In accordance with our understanding of ANSI N 18.7, the assignment of an Alternato Chairman each day of the week provided the i
Station Manager with assurance that qualified personnel would be available on a day-to-day basis to fulfill PORC responsibilities as situations demand.
Apparently, this is not an acceptable understanding, and corrective steps have been undertaken as stated below.
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. (2) The corrective steps which have been taken and the results achieved:
Memo PPC-86-2497, "PORC QUORUM" was issued by the Station Manager effective May 30, 1986.
This document provides for plant personnel assignments, generally by name, to the Plant Operations Review Committee. A Chairman and a single Alternate Chairman are specified in the present PORC quorum.
It should be noted that the memo also provides for an Alternate Chairman who may act in that capacity in the absence of either the Station Manager or the specified Alternate.
The use of this third person as an Alternate Chairman is intended to address situations such as unforeseen operational conditions, vacations, etc.
This person is not routinely scheduled as an Alternate. Chairman.
(3) Corrective steps which will be taken to avoid further violations:
PORC-ralevant Technical Specification requirements will be incorporated into "PORC Member Orientation" which was under development by the Fort St. Vrain Training Section prior to this violation. All designated members of PORC will be required to attend this training. Memoers will be made aware of the content of Technical Specification AC 7.1.2,
" Plant Operations Review Ccmmittee (PORC), Administrative Controls" as a part of that program.
(4) The date when full compliance will be achieved:
Full compliance was achieved effective May 30, 1986.
D.
Failure to Follow Procedures 10 CFR Part 50, Appendix B, Criterion V, requires that procedures be written and implemented for safety-related activities.
10 CFR Part 50.59b requires that the licensee shall maintain records of changes in the facility and of changes in procedures and that the licensee shall furnish to the NRC Regional Office annually a report containing a brief description of such changes, tests, and experiments.
Procedure TSP-21, Issue 2,
dated April 21, 1982, is the approved procedure which implements the above requirements. Procedure TSP-21, paragraph 3.1, states that the annual report shall be submitted prior to March 1 of each year.
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. Contrary to the above, the annual 10 CFR 50.59 reports for the calendar years 1983 (submitted March 23, 1984),
1984 (submitted June 22, 1985), and 1985 (not submitted as of the dates of this inspection) were not submitted prior to March I for each year.
This is a
Severity Level IV violation (supplement I)
(50-267/8608-05).
(1) The reason for the violation if admitted:
At the time the 1983 10CFR50.59 report was submitted, the Nuclear Licensing Department was negotiating with the Technical Service Department to revise the anniversary dates for the 10CFR50.59 report to coincide with update submittal of the Fort St.
Vrain Final Safety Analysis Report (FSAR). As the reporting dates for the FSAR update submittal are January 23 through January 22 of the years affected, it was decided (per General Services Action Request, GSAR-559 dated March 20, 1984, and PSC memo, NDS-84-0267 dated April 2, 1984) to revise the 10CFR50.59 report anniversary dates accordingly. Subsequently, PSC letter dated July 20, 1984, Warembourg to Johnson (P-84224), submitted the 10CFR50.59 report for the period January, 1984 through January 22, 1984, and informed the NRC of the revised anniversary dates. Technical Service Procedure, TSP-21, 10CFR50.59 Report, was not reissued to reflect these ongoing changes.
Prior to submittal of the following 10CFR50.59 report the responsibility changed from the TecSnical Services Department to the Nuclear Licensing Department.
Subsequently, TSP-21 was deleted April 30, 1985.
Nuclear Licensing submitted the 10CFR50.59 report for the period January 23, 1984 through January 22, 1985, per PSC letter dated July 22, 1985, Brey to Regional Administrator, Region IV (P-85251). A new Nuclear Licensing procedure was not yet in place to govern this submittal.
The 1985 10CFR50.59 Report has not yet been submitted.
(2) The corrective steps which have been taken and the results achieved:
Prior to this NRC inspection a new Nuclear Licensing and Fuels Division (NFL) Procedure governing the 10CFR50.59 Annual Report was drafted for review and comment.
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. (3) Corrective steps which will be taken to avoid further violations:
!!uclear Licensing and Fuels Division procedure NLF-8, Procedure for 10CFR50.59 Annual Report, will be approved and implemented prior to submittal of the 1985 report.
(4) The date when full compliance will be achieved:
July 22, 1986.
Appendix B Notice of Deviation Based on the results of an NRC inspection conducted during the period of March 3-7, 1986, and in accordance with NRC Enforcement Policy (10 CFR Part 2,
Appendix C), 49 CFR 8583, dated March 8, 1984, the following deviation was identified.
The Updated FSAR, Revision 3,
states that the licensee is committed to the provision of ANSI N18.7-1972,
" Administrative Controls for Nuclear Power Plants." ANSI N18.7-1972, Section 4.5, states that the onsite review committee, PORC, "should provide... continuing review of plant operation...."
In deviation from the above, by memo dated October 18, 1985, five different individuals were assigned to attend PORC meetings each day of the week. Only two persons were scheduled to attend PORC meetings more than once each week; and in those cases, were scheduled to attend meetings only twice. (50-267/8608-03).
(1) The corrective steps which have been taken and the results achieved.
Memo PPC-86-2497, "PORC QUORUM" was issued by the Station Manager effective May 30, 1986.
This document provides for plant personnel assignments, generally by name, to the Plant Operations Review Committee.
The previous PORC QUORUM consisted of individuals assigned to daily groups who were to be available for the accomplishment of PORC review responsibilities. The updated listing of PORC members and alternates consists of nine permanent members and three alternates assigned to two groups for accomplishment of those responsibilities.
The memo also specifies two permanent committee members and five designated alternates as "Available Substitutes" who are to be used, if necessary, to guarantee a QUORUM consistent with the Technical Specifications.
The memo also directs
- that, "The Chairman / Alternate Chairman will make reasonable attempts to obtain the designated quorum by name" and that "It is intended that all five designated personnel be in attendance." Fewer PORC
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members and alternates assigned to two PORC quorum groups will serve to provide the " continuing review of plant operation" specified by ANSI N18.7-1972, Section 4.5.
(2) The corrective steps which will be taken to avoid further deviation from commitments made to the Commission.
Items subject to PORC consideration and review will be scheduled for submittal to one of the two designated quorum groups in a timely manner consistent with the requirements of plant administrative procedures and as situations demand.
(3) The date when full compliance will be achieved:
Full compliance was achieved effective May'30, 1986.
Should you have any further questions, please contact Mr. M. H. Holmes, (303) 480-6960.
Sincerely, TLLYbn J. W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/kis l
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