ML20215D581

Responds to NRC Re Violations Noted in Insp Rept 50-267/86-23 on 860811-15.Corrective Actions:Info Re Validity of Utilizing Ga Technologies,Inc & Stat-A-Matrix Institute for Auditor Training Obtained

ML20215D581
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/26/1986
From:	Tomlinson P PUBLIC SERVICE CO. OF COLORADO
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-86646, NUDOCS 8612160412
Download: ML20215D581 (7)

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16805 WCR 19 1/2, Platteville, Colorado 80651 November 26, 1986 Fort St. Vrain Unit No. 1 P-86646 Regional Administrator Region IV O. S. Nuclear Regulatory Commission '

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Attention: Mr. J. E. Gagliardo, Chief Reactor 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 neriodic review of the Fort St. Vrain Generating Station audit program:

10CFR Part 50, 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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• 2 P-86646 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 within 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."

(NFSC 0-85-01) "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.5.19.15, the FSV QA Program is responsivo to for guidance.

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P-86646 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 a 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 0-87-01, 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 regardirg 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 November 26, 1986

2. Failure to have and to review examinations for lead auditors:

10CFR Part 50, Appendix B, Criterion XVIII, requires an audit program performed by appropriately trained personnel. To assure appropriate training, licensee UFSAR Section B5.18.2 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 exm nation 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 vioiation if admitted:

Fort St. Vrain has used two outside contractors to perform lead 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 Technologies, Inc. and Stat-A-Matrix Institute additional information on the type and content of examinations given to PSC Auditors. The information 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.

Vf c e, - . n P-86646 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 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, c________________

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P-86646 November 26, 1986 (4) The date when full compliance will be achieved:

Administrative Procedure Q-17 and RCM-2 will be revised 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 UFSAR 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 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-ID 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 QAdP-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 November 26, 1986 The list of audits given in the violation contains two types of audits, QA audits and NFSC audits. Tne 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.

l l (4) The date when full compliance will be achieved:

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Not applicable.

! Should you have ar.y further questions, please contact Mr. M. H. Holmes at (303) 480-6960.

1 s Sincerely, s J_ _'

P. , . Tomlinson 3

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Manager, Quality Assurance Division PFT/clk

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