ML20215N829

Notice of Violation from Insp on 860816-0930

ML20215N829
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/04/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215N821	List: IR 05000267/1986025 ML20215N820 ML20215N829
References
50-267-86-25, NUDOCS 8611070319
Download: ML20215N829 (3)

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APPENDIX A NOTICE OF VIOLATION w .

A Public Service > Company of~ Colorado Docket: 50-267/86-25 Fort St. Vrain Nuclear Generating Station License: DPR 34 During an NRC inspection conducted on August 16 through September 30, 1986, l violations of NRC requirements were identified. The violations involved violation of shift turnover procedure, failure to review modification control procedures, failure ~ to sufficiently document design verification, failure to periodically test flow orifice valve limit, and failure to implement corrective dT i k

action program. In accordance with the " General Statement of Polic R; Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix 1986),the C (y and violations are listed below

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tu A. , Violation of Shift Turnover Procedure t- r Criterion V of Appendix 8 to 10 CFR Part 50, and the licensee's approved i ,. -

. Quality Assurance plan require that activities 'affecting quality be "s

>" prescribed by documented procedures and be accomplished in accordance with

,these procedures. Procedure SMAP-8, Issue 6, " Plant Operations Shift 4, Turnover," requires turnover of vital area and critical valve keys.

I h Contrahytothe\cbove,on' September 9,1986,at8:00a.m.,theshift-t turnover has accomplished without the vital' area and critical' valve keys over toithe oncoming shift supervisor.

This is a Severity Level IV violation. '(SupplementI.E.)(267/8625-01)

>- B. Failure to Review Modification Control Procedures

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i s Technical Speciff ations, paragraph 7.4.b, requires that procedures and

^ administrative policies of Appendix A to Regulatory Guide 1.33,

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NHember 1972, which includes general procedures for control of i-' ,

.rpdification work, be reviewed by the plant operations review t-

^ comittee. (PORC).-

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• Contrary to the above, procedures ENGl (" Control of Modifications and Documentation"),ED100("CNPreparatienandDocumentControl"),andCWPM l

, \ (" Controlled Work-Procedure Manual"), which all provide administrative

Af golicies'of control of modification work, were not reviewed by PORC.

' This is a Severity Level IV violation. (Supplement I.D.)(267/8625-02)-

f C'.'FailurethSufficientlyDocumentDesignVerification

) Techn'ihel Specifications paragraph 7.4.a.1, requires that written procedures be established, implemented, and maintained for activities covded by Appendix A of Regulatory Guide 1.33, November:1972, which I )' includes general procedures for control of modification work.-

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Procedure ENG-1, " Control of Modifications and Docunentation," requires .

that the person performing the design verification process document their .

effort in sufficient detail to provide a record of their work.

Contrary to the above, the person performing the design verification for ,

change notice (CN) 1876 did not document the effort in sufficient detailf to provide a record of the work in that the " Check List of Design -

Verification Question for Design Review Method" was signed and dated on one date and was initialed aad dated on three subsequent dates with no details provided as to what was verified on each date, and no details were provided to record that the design sketches included in the CN package were checked by the design verifier.

This is a Severity Level IV violation. (SupplementI.D.)(267/8625-03)

D. Failure to Periodically Test Flow Orifice Valve Limit Criterion XI to 10 CFR Part 50, Appendix B, requires that testing required

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to demonstrate that structures, systems, and components will perform satisfactorily in service be performed in accordance with written test procedures which incorporate the requirements contained in applicable design documents.

The licensee's approved quality assurance program states thet testing activities are conducted on a continuing basis to satisfy Technical Specification requirements and, as appropriate, following mcdf fications when specified by the Change Notice package.

The safety evaluation for Change Notice (CN) 1876 states that the limit trip feature in the close position for the flow orifice valves is required to be tested on a periodic basis to verify the design function of preventing an orifice valve from reaching the full closed mechanical stop.

Contrary to the above, following modifications to the flow orifice valves control circuits, periodic testing of the flow orifice valve limit trip feature was not being accomplished as prescribed by the instructions contained in the safety evaluation for CN 1876.

This is a Severity Level IV violation. (Supplenent I.D.)(267/8625-04)

E. Failure to Implement Corrective Action Program l

Criterion XVI to 10 CFR Part 50, Appendix B, requires that measures be I established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, the installation instructions for CN 1876 noted that numerous discrepancies were identified with the existing vendor

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design documents and tne actual field installation, but.no corrective action was initiated to review other areas of the. vendor documents (not-affected by the change notice) for similar discrepancies.

/ This is a Severity Level IV violation. (SupplementI.D.)(267/8625-05) ,

Pursuant to the provisions of 10 CFR 2.201, Public Service Company of Colorado I' 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.

t Arlington, rexas Dateda%

this 1 day of k 1986 i

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