ML20198D220

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)

See also: IR 05000267/1986008

Text

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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

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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. p. 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

/). f. udon, Chief, Project Section A, Dat6

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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 Program.

Results: Within the areas inspected, four violations and one deviation were

identified (paragraphs 3 and 5).

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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 personnel.

• Denotes those attending the exit interview.

2. 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 standards.

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 identified.

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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 PORC.

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

PORC. 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 changed.

The PORC Charter defines review as a " deliberate, critical

examination . . . ." The NRC inspector determined the those documents

identified did not receive a deliberate, critical examination. 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 alternates. 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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Power Plants. Section 4.5 of ANSI N18.7-1972 states that PORC ". . .

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

"

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 staff. Those controls or procedures

addressed design, quality assurance, procurement and interfaces between

onsite and offsite staffs. No violations or deviations were noted.

5. 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 performed.

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 field. 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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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 decision.

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 inspection.

7. 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.