ML20215M725

Notice of Violation from Insp on 860811-15

ML20215M725
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/28/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215M724	List: IR 05000267/1986023 ML20215M723 ML20215M725
References
50-267-86-23, NUDOCS 8611030201
Download: ML20215M725 (3)

Text

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t APPENDIX A NOTICE OF VIOLATION Public Service Company of Colorado Docket: 50-267/86-23 Fort St. Vrain Nuclear Generating Station License: DRP-34 During an NRC inspection conducted on August 11-15, 1986, four violations of HRC requirements were identified. The violations involved failure to perform periodic review 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. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below: .,

1. Failure to perform periodic review of the Fort St. Vrain Generating Station audit-program: -

10 CFR 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.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.

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Contrary to the above, the licensee failed to perform such reviews, which was confirmed by a licensee Quality Assurance audit' person.

This is a Severity Level IV violation. (SupplementI)(50-267/8623-01)

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

10 CFR Part 50, Appendix B, Criterion XVIII, requires an audit program performed by appropriately trained personnel. To assure appropriate training, licensee 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 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 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. (SupplementI)(50-267/8623-02) 8611030201 861028 PDR ADOCK 05000267 G PDR

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3. . Failure to' have records checklist for designating required records:

10 CFR Part 50, Appendix B, Criterion XVII requires retention of records for activities affecting quality. In the accomplishment of this reauirement, licensee USAR Section B.5.19.9 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)

4. Failure to provide notices for audits:

10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed and accomplished in accordance with documented procedures. Licensee USAR Section B.5.5.1, contains the licensee commitment to ANSI Standard N18.7 - 1972, which in 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 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.

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 NSFC-C Corrective Action NSFC-D QA Program This is a Severity Level V violation. (Supplement I)(50-267/8623-04)

3 Pursuant to the provisions of 10 CFR 2.201, Public Service Company of Colorado is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas

• this 28th day of October 1986 J

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