IR 05000267/1986008

Insp Rept 50-267/86-08 on 860303-07.Violations & Deviation Noted:Critical Exam of Documents by Plant Operations Review Committee Neglected,Design Changes Not Incorporated Into Change Notice 1798A & Annual Safety Rept Not Sent to NRC

ML20198D220
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/13/1986
From:	Bennett W, Jaudon J, Mcneill W, Skow M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198D195	List: ML20198D188 ML20198D197 ML20198D202 ML20198D220
References
50-267-86-08, 50-267-86-8, NUDOCS 8605230190
Download: ML20198D220 (6)

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APPENDIX C U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/86-08 License: DPR-34 Docket: 50-267 Licensee: Public Service Company of Colorado (PSC)

P. 0. Box 840 Denver, Colorado 80201-0804 Facility Name: Fort St. Vrain Nuclear Generating Station Inspection At: Fort St. Vrain Nuclear Generating Station, Platteville, Colorado Inspection Conducted: March 3-7, 1986

/ $!/3 8 Inspector:k M[ E.(Skpw, Project Engineer, ProjectDate Sectis A, Reactor Projects Branch (paragraphs 1, 2, 3, 4, 6, and 7)

Inspector: MA/ M [ 8d R.( Bfnnett, Project Engineer, Project

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Date Sectibn A, Reactor Projects Branch (paragraphs 1, 2, 4, 5, 6, and 7)

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Inspector: _

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y. cNeill, Project Engineer, Project Date L L Sec ion A, Reactor Projects Branch (p ragraphs 1, 2, 4, 5, 6, and 7)

Approved: _ ms -A 4~ 3 8

/). udon, Chief, Project Section A, Dat6 L Rea or Projects Branch

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-2-Inspection Summary Inspection Conducted March 3-7, 1986 (Report 50-267/86-08)

Areas Inspected: Routine, unannounced inspection of the Quality Assurance Program, Onsite Review Committee, Offsite Review Committee, Offsite Support Staff, and Tests and Experiments Progra Results: Within the areas inspected, four violations and one deviation were identified (paragraphs 3 and 5).

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-3-DETAILS 1. ' Persons Contacted PSC

• C H. Fuller, Station Manager

• L. W. Singleton, Manager, Quality Assurance

• M. J. Ferris, QA Operations Manager

• R. L. Craun, Nuclear Site Engineering Manager

• J. M. Gramling, Supervisor, Nuclear Licensing Operations

.D. Warembourg, Manager, Nuclear Engineering J. W. Gahm, Manager, Nuclear Production T. C. Prenger, QA Services Manager M. Lehr, QA Engineering Supervisor P. F. Moore, QA Technical Support Supervisor D. Frye, Nuclear Licensing Specialist J. Stufflebeam, Executive Secretary /NFSC Clerk M. Holmes, Nuclear Licensing Manager J. Johns, Supervisor, Nuclear Licensing Engineering 0. Clayton, Technical Services Engineer J. Eggebroten, Superintendent, Technical Services Engineering D.-Webber, Staff Assistant to Station Manager W. Crain, Superintendent of Maintenance T. Borst, Support Services Manager / Radiation Protection Manager P. Collins, PORC Clerk The NRC inspectors also contacted other licensee personnel including administrative, clerical, and operations personne * Denotes those attending the exit intervie . Quality Assurance Annual Review The purpose of this inspection was to ascertain whether the licensee is implementing a Quality Assurance (QA) program that is in conformance with regulatory requirements, commitments, and industry guides and standard This inspection objective was accomplished by inspection in the following areas: Tests and Experiments Program, Onsite Review Committee, Offsite Review Committee, and Offsite Support Staff. These areas are addressed in this report in paragraphs 3 through 6. The QA program was found to not have changed significantly since the last inspection of this area in regard to its organization, personnel and staffing. A number of QA program procedures have been revised and reformatted to improve QA effectiveness. Within this area, no violations, deviations, or unresolved items were identifie ,

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-4-3. Onsite Review Committee The purpose of this inspection was to provide a functional review of the Onsite Review Committee to determine that the safety-related responsibilities of the committee are being adequately performed. The Onsite Review Committee for Ft. St. Vrain is the Plant Operations Review Committee (PORC). The NRC inspector reviewed Technical Specification Section Number AC 7.1.2; the PORC Charter, Issue 1, dated November 23, 1983; and the minutes for several PORC meetings. In addition, the NRC inspector interviewed some PORC members, the PORC clerk and a staff assistant concerning POR The NRC inspector found that the PORC Charter appears to meet the requirements of the Technical Specifications. Those documents that required a PORC review were sent to PORC for review. It was noted that the minutes of the PORC meeting were prepared prior to the meeting by the PORC clerk; the minutes included a brief description of each item to be reviewed by PORC. The documents to be reviewed and copies of the draft minutes were provided at the PORC meeting. During discussions with PORC members, the NRC inspector found that documents requiring review by PORC were not provided to members prior to the PORC meeting. At the meeting attended by the NRC inspector, the PORC Chairman read the description of each item from the draft minutes to the PORC committee. If there were questions from the committee, the document undergoing review was read by the Chairman and/or one or more of the other members or alternates of the POR The NRC inspector observed that none of the documents were individually examined by all of the personnel in attendance. Also, he observed that several documents were not examined by any members of the committee during the meeting. If PORC took any actions, reached any conclusions, or made any other changes to the draft minutes, the PORC clerk retyped the minutes as change The PORC Charter defines review as a " deliberate, critical examination . . . ." The NRC inspector determined the those documents identified did not receive a deliberate, critical examinatio This is an apparent violation (50-267/8608-01).

The number of PORC meeting attendees was found to meet the minimum quorum required by the Technical Specifications. By memo dated October 18, 1985, the PORC Chairman designated four alternate chairmen. The memo also identified which members and designated alternate members would attend each daily PORC meeting. Each day of the week had a different chairman and four attendees. Only two members were scheduled to attend more than one meeting each week, and that was for only two meetings. Technical Specification AC 7.1.2, Section 2, discusses PORC alternate It states, in part, "An alternate chairman . . ,, if required, shall be appointed in writing by the PORC Chairman to serve in the absence of a chairman . . .

." The NRC inspector concluded that the designation of four alternate chairmen, each preassigned to a specific day of the week, is an apparent violation of the Technical Specification (50-267/8608-02).

Additionally, the licensee is committed in the Updated FSAR, Revision 3, to the provisions of ANSI N18.7-1972, Administrative Controls for Nuclear

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-5-Power Plant Section 4.5 of ANSI N18.7-1972 states that PORC ". . .

should provide . . . continuing review of the plant operation . ...

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The NRC inspector concluded that a committee whose personnel substantially change on a daily basis does not provide for a continuing review of plant operations. This is an apparent deviation from the above commitment (50-267/8608-03).

4. Offsite Support Staff The purpose of this inspection was to ascertain whether the offsite support staff functions are performed by qualified personnel in accordance with licensee approved administrative controls. The NRC inspectors reviewed the Nuclear Guidelines and Policies Manual, organization charts, and interviewed selected personnel. In regard to offsite support staff, there appeared to be a sufficient staff of qualifled personnel to perform their assigned functions. Personnel appeared to be aware of their functions and responsibilities. Administrative controls were found in place which describe the responsibilities, authorities, and lines of communication for the offsite support staf Those controls or procedures addressed design, quality assurance, procurement and interfaces between onsite and offsite staff No violations or deviations were note . Tests and Experiments Program The purpose of this inspection was to ascertain whether the licensee is implementing a QA program relating to the control of test and experiments that is in conformance with regulatory requirements. In this regard, the NRC inspectors reviewed Licensee Procedures Q-3, Q-11, TSP-21, and four of the most recent changes to Technical Specifications. The NRC inspectors reviewed the licensee's 10 CFR 50.59 Report Submittal, dated July 22, 1985. A sample of four Change Notices (CNs) and five tests were selected from that submittal for further review. The NRC inspectors review of those tests and CNs determined that adequate controls were in effect, safety evaluations were made, and that PORC and Nuclear Facilities Safety Committee (NFSC) reviews were performe However, one problem was found that related to Change Notices. Deviation Request DR-85-35-1-H was written against CN 1902 on March 25, 1985. It discussed a conflict in cable termination instructions with conditions found in the fiel The disposition provided for making the changes required in the field and stated, ". . . a document update will be incorporated in CN-1798A." A review by the NRC inspectors and the licensee of CN-1798A did not indicate that the document update had been accomplished. This is an apparent violation of 10 CFR 50, Appendix B, Criterion III (50-267/8608-04).

During review of the latest five 10 CFR 50.59 annual submittals, the NRC inspectors noted a variation of submittal dates. Procedure TSP-21, Issue 2, dated April 21, 1982, required that reports be submitted prior to March 1 of each year. The 1983 report was submitted on March 23, 1984, and the 1984 report was submitted on July 22, 1985. The 1985 report had

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-6-not been submitted as of this inspection. The licensee stated that the responsibility for preparing the report was shifted from Technical Services to Licensing for the 1984 report and that the decision was made to submit the report at the same time as the FSAR update in July. A change or deviation to TSP-21 was not made to support that decisio Additionally, the licensee stated that TSP-21 was deleted on March 30, 1985, and that a licensing procedure pertaining to the 10 CFR 50.59 report had not been issued as of this inspection. The failure to submit reports at the times required by the procedure is an apparent violation (50-267/8608-05).

6. Offsite Review Committee The purpose of this inspection was to determine if the functions of the offsite review are being performed in accordance with regulatory requirements. The licensee refers to the offsite review committee as the Nuclear Facilities Safety Committee (NFSC). In this regard, Technical Specification AC 7.1.3 and the NFSC Charter, Issue 4, dated January 2, 1984, were reviewed. The NRC inspectors reviewed the minutes of NFSC meetings numbered 94, 96, and 99 through 103, reviewed selected portions of the documents the NFSC reviewed, reviewed NFSC audit reports associated with meetings 101 and 103, and interviewed selected members of the NFSC and the NFSC clerk. In addition, items selected during the PORC and Tests and Experiments portions of this inspection were followed upon during the NFSC inspection. It was verified that NFSC reviewed PORC minutes and safety evaluations. The membership of NSFC was verified. The inspectors found that the NFSC appeared to function in an effective manner. For example, NSFC challenged the PORC evaluation of CN-1876 with regard to an unreviewed safety question. Subsequently, the new equipment was placed in an out-of-service status and an independent review was ordered to resolve the question. Documents for review by the committee were distributed to members with sufficient lead time that questions and comments could be solicited and returned to the NFSC clerk. These questions and comments were then directed to cognizant personnel. Those personnel in turn presented a discussion at the NFSC meeting. The questions and comments were normally resolved in this manner. The minutes were not used as an agenda as with PORC, but were taken at the meetings by the clerk. While the minutes of the NFSC meetings appeared to the more complete than the PORC minutes, the NRC inspectors suggested that the minutes include a brief explanation of the resolution of the comments and questions. This would document the position accepted by the NFSC. No violations or deviations were identified in this portion of the inspectio . Exit Interview An exit interview was held on March 7, 1986, with those personnel denoted in paragraph 1 of this report. The NRC senior resident inspector also attended this meeting. At the meeting, the scope of the inspection and findings were summarized.