ML20207N036
| ML20207N036 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/06/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8701130411 | |
| Download: ML20207N036 (2) | |
See also: IR 05000267/1986023
Text
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JAN
61987
In Reply Refer To:
Docket: 50-267/86-23
Public Service Company of Colorado
ATTN: Robert O. Williams, Jr.
Vice President, Nuclear Operations
P. O. Box 840
Denver, Colorado
80201-0840
Gentlemen:
Thank you for your letter of November 26, 1986, in response to our letter and
Notice of Violation dated October 28, 1986. We have reviewed your reply and
find the following:
Violation 1: Since our inspector did not review the audits cited in your
response, we withdraw this violation and will carry it as an unresolved
item, pending our review of these cited audits during a future
inspection.
Violations 2 and 3: We find your reply responsive to the concerns raised
in the Notice of Violation. We will review the implementation of your
corrective actions during a future inspection to determine that full
compliance has been achieved and will be maintained.
Violation 4: We understand that the violation, as stated, is correct
with regard to the paragraph of Procedure QAAP-1 used in the violation;
we also understand that in the context of Procedure QAAP-1, taken as a
whole, no violation exists. Therefore, we conclude that Procedure QAAP-1
requires clarification.
Since you have connitted to revise
Procedure QAAP-1 (per telecon between your Mr. Tomlinson and our
Mr. Jaudon on January 5,1987), the violation is withdrawn,-and the
revised Procedure QAAP-1 will be reviewed during a future inspection.
Sincerely,
ognM sMned By
J. E. GcLliardo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
J. W. Gahm, Manager, Nuclear
Production Division
Fort St. Vrain Nuclear Station
16805 WCR 191
Platteville, Colorado
80651
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16805 WCR 19 1/2, Platteville, Colorado 80651
November'26, 1986
Fort St. Vrain
Unit No. 1
P-86646
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Regional Administrator
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Region IV
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U. S. Nuclear Regulatory Commission
DEC 3 -M
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Arlington, Texas 76011
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Attention: Mr. J. E. Gagliardo, Chief
Reactcr Projects Branch
Docket No. 50-267
SUBJECT:
I&E Inspection Report 86-23
REFERENCE: NRC Letter, Gagliardo to Williams,
dated 10-28-86 (G-86565)
Dear Mr. Gagliardo:
This letter is in response to the Notice of Violations received as a
result of inspections conducted at Fort St. Vrain during the period
August 11 - 15, 1986.
The following response to the items contained
- in the Notice of Violations is hereby submitted:
1.
Failure to perform periodic review of the Fort St.
Vrain
Generating Station audit program:
Appendix B,
Criterion XVIII,
requires
a
comprehensive system of audits to be performed. As part of this
audit program, the approved Fort St. Vrain Quality Assurance
Program, Updated
Final
Safety
Analysis
Report
(UFSAR),
Revision 3,
Section B.5.19.15,
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.
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-P-86646
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November 26, 1986
Contrary to this, the licensee failed to perform such reviews,
which was confirmed by a licensee Quality Assurance audit person.
This
is a Severity Level IV violation.
(Supplement I)(50-
267/8623-01)
(1) The reason for the violation if admitted:
This
violation
is
not
admitted.
A review of the
Fort St. Vrain QA Audit Program is conducted biennially
during the performance of the Nuclear Facility Safety
Committee (NFSC) Audit of the FSV QA Program.
The audits
were reviewed by QA and the following excerpts from the
audits are provided:
(NFSC D-81-01) "FSV has an audit program which
__
is committed to
auditing
all
areas
and
activities once every two (2) years. A schedule
has been developed to implement this commitment.
The audits currently being conducted do not
address the systemic (sic) requirements for the
criterion being audited.
Rather, the audits are
addressing only specific activities wit.in that
criterion for procedure compliance . . ."
(NFSC D-83-01) " Reviewed the Audit Report file
to verify that an audit report is prepared for
each audit,
that it assesses the effectiveness
of the audit program . . . "
" Reviewed the audit schedule to verify all
elements of the QA Program are being audited."
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.
(NFSC D-85-01)
"A review of the implementation
of the audit program was performed to verify
compliance with the FSAR, the QA Program, and
the
implementing
procedures.
The
review
encompassed the planning, scheduling, conduct,
reporting, and follow-up activities relating to
auditing and monitoring."
These
reviews
by
the
NFSC
meet
the
intent
of
ANSI N18.7 - 1972, Section 4.1, for periodic review of the
audit
program which,
as stated in the updated FSAR,
'
Section B.S.19.15, the FSV QA Program is responsive to for
guidance.
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P-86646
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November 26, 1986
We recognized from discussions with the staff during this
inspection, that the audit program review process needs to
.
-be strengthened and have initiated measures to do so. These
'
measures include implementation of e new audit to review the
Nuclear Facility Safety Committee (NFSC) activities and a
.
commitment to provide an in-depth review of the QA Audit
Program in NFSC D-87-01, QA Program Audit. This commitment
was made in response to NRC open
item
8619-02
in
September, 1986.
The QA Audit of NFSC activities is
currently in progress. These audits, conducted alternately,
will
provide a formal review of the audit functions on an
annual basis.
,
A question also arose during this inspection as to the
interpretation of Technical Specification AC 7.1.3.
PSC has
interpreted
this
section as regarding the collective
~~
competence of the NFSC membership required to
review
problems in certain areas.
We recognize the Technical
Specification as written is subject to mis-interpretation
and
have
submitted a change to AC 7.1.3 which more
accurately reflects the ANSI N18.7 - 1972 requirement. This
change
is
currently in for Plant
Operations Review
Committee and NFSC reviews prior to NRC submittal.
Fort St. Vrain is in compliance with 10CFR50, Appendix B,
Criterion XVIII and ANSI N18.7 - 1972, Section 4.1, as they
relate to owner organization review of the Licensee Audit
program.
(2) The corrective steps which have been taken and the results
achieved:
.
,
Not applicable.
(3) Corrective steps which will
be taken to avoid further
violations:
'
Not applicable.
(4) The date when full compliance will be achieved:
Not applicable.
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P-86646
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November 26, 1986
2.
Failure to have and to review examinations for lead auditors:
Criterion XVIII,
requires an audit
program performed by appropriately trained personnel. To assure
appropriate training, licensee UFSAR Section 85.18.2 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 of
the types and content of examinations used for qualification of
lead auditors shall be retained, and that the employer shall be
responsible
for
the
conformance
of
the examination to
N45.2.23-1978.
Contrary
to the above, the licensee had utilized outside
contractors for qualification training of Public Service Company
of Colorado (PSC) employees as lead auditors at Fort St. Vrain,
- _,
and licensee did not have copies of examinations for lead
auditors, nor documentation of review of examinations used for
conformance to ANSI N45.2.23-1978.
This is a Severity Level IV violation.
(Supplement I) (50-
267/8623-02)
(1) The reason for the violation if admitted:
Fort St.
Vrain has used two outside contractors to perform
auditor
training - GA
Technologies,
Inc.
and
Stat-A-Matrix Institute.
Fort St.
Vrain interpreted the
requirement for " objective evidence of type and content of
examinations" to be satisfied by the course outline and
certificates of completion provided by these two companies.
.
. (2) The corrective steps which have been taken and the results
achieved:
On August 26, 1986, QA requested and has received from
GA Tec56niagic , Inc. and Stat-A-Matrix Institute additional
inforna,,t1 -
the type and content of examinations given to
PSC Auditors.
The informatio.n provided substantiated the
validity of utilizing these two organizations for lead
auditor training.
(3) Corrective steps which will be taken to avoid further
,
violations:
A commitment has been entered in the QA Commitment System to
require that during the annual
review of lead auditor
qualifications, verification that " objective evidence of the
type and content of examinations"
is on file for the
calendar year involved.
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P-86646
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November 26, 1986
(4) The date when full compliance will be achieved:
Full compliance will be achieved by December 31, 1986.
3.
Failure to have records checklist for designating required
records:
10CFR Part 50, Appendix B, Criterion XVII requires retention of
records for activities affecting quality.
In the accomplishment
of this requirement, licensee UFSAR Section B5.19.9 contains the
licensee commitment to ANSI Standard N45.2.9-1974 and Regulatory
Guide 1.88.
Section 4.2 of ANSI N45.2.9-1974 specifies that, as
a minimum,
records receipt control
shall
include a records
checklist designating the required records.
Contrary to the above,
the licensee was not using a records
__
checklist.
This
is a Severity Level IV violation.
(Supplement'I)(50-
267/8623-03)
(1) The reason for the violation if admitted:
Fort St. Vrain has been using a records transmittal form to
satisfy the ANSI N45.2.9-1974 requirements for a records
" checklist" designating the required records.
During a
review of transmittal
practices in response
to
this
violation,
it was determined that the transmittal form, as
currently used, did not verify that records
packages
submitted to the Records Center were complete.
(2) The corrective steps which have been taken and the results
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.
achieved:
None
(3) Corrective steps which will
be taken to avoid further
violations:
Administrative Procedure Q-17,
Quality Records, will be
revised to require that the total number of pages submitted
to the Records Center be entered on the transmittal form.
Records Center Procedure RCM-2, Receipt, Review, and Control
of Records, will be revised to require that the records be
checked to verify the number of pages listed on the
transmittal
form has been received by the Records Center
prior to filing the records.
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P-86646
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November 26, 1986
(4) The date when full compliance will be achieved:
Administrative Procedure Q-17 and RCM-2 will be .'evised by
January 31, 1987.
4.
Failure to provide notices for audits:
10CFR Part 50, Appendix B, Criterion V, requires that activities
affecting quality shall be prescribed and accomplished
in
accordance
with
documented
procedures.
Licensee
Section B.5.5.1
contains the licensee
commitment
to
ANSI
Standard N18.7-1972,
which
in
Section 5.1.2, ' requires the
licensee to have and to follow procedures.
Licensee procedure QAAP-1,
Issue 3,
" Guidelines for Quality
Assurance and Nuclear Facility Safety Committee Audits,"
states
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in Section 4.2.2 that a matrix which defines the applicability of
the 18 criteria of 10CFR50, Appendix B, to each of the QA Audits
is contained in Attachment QAAP-10 and is to be a major element
in the development of audit plans and checklists.
Contrary to the above, based on a list of audits provided by the
licensee audit group, the following audits did not have matrices
in Attachment QAAP-10:
QAA-502
QA 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
NFSC-C
Corrective Action
NFSC-D
QA Program
This
is a Severity Level V violation.
(Supplement I)(50-
267/8623-04)
(1) The reason for the violation if admitted:
This violation is not admitted. Attachment ID to QAAP-1 is
a matrix used to provide assistance to audit ' teams in the
preparation of audit plans and checklists. This matrix does
nothing more than list the pertinent 10CFR50, Appendix B
criteria for regularly scheduled QA audits.
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P-86646
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November 26, 1986
The list of audits given in the violation contains two types
of audits, QA audits and NFSC audits. The QA audits listed
were performed for the first time within the last two years
with the exception of the QAA-3000 miscellaneous audit,
which does not have a defined scope. Contained within the
'
scope of each audit plan and report was a listing of the
applicable Appendix B criteria. There is no requirement in
QAAP-1 for the development of an Attachment ID matrix for
all QAA audits prior to the audit, nor are restrictions
imposed on the addition of audits to the program prior to
initiation or performance of such audits.
NFSC audits are performed under the direction of the Nuclear
Facility Safety Committee (NFSC) by NFSC members.
Although
QA supports the NFSC in the performance of these audits by
-
developing schedules and providing clerical
support, NFSC
lead auditors are responsible for the conduct of the audits.
NFSC audits are prepared using the same format as the QAA
audits,
including
the listing of applicable 10CFR50,
Appendix B criteria in the scope of the audits.
QA will
revise QAAP-1 to clarify the requirements for
10CFR50, Appendix B criteria in the audit scopes.
Fort St.
Vrain is in compliance with 10CFR50, Appendix B,
Criterion V and ANSI N18.7-1972, Section 5.1.2 as
they
relate to the auditing program.
(2) The corrective steps which have been taken and the results
achieved:
Not applicable.
~
(3) Corrective steps which will be taken to avoid further
violations:
Not applicable.
(4) The date when full compliance will be achieved:
Not applicable.
Should
you
have
any
further
questions,
please
contact
Mr. M. H. Holmes at (303) 480-6960.
Sincerely,.h.
.
P.
. Tomlinson
Manager, Quality Assurance Division
PFT/clk