ML20127E737

Insp Rept 50-267/85-06 on 850305-08.Violation Noted: Corrective Action Not Taken to Promptly Revise Administrative Procedure Q-15 & Q-16

ML20127E737
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/30/1985
From:	Ireland R, Skow M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20127E707	List: ML20127E703 ML20127E731 ML20127E737
References
50-267-85-06, 50-267-85-6, NUDOCS 8505200183
Download: ML20127E737 (5)

See also: IR 05000267/1985006

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APPENDIX B

U. S. NUCLEAR REGULATORY COPNISSION

REGION IV

NRC Inspection Report: 50-267/85-06 License: DPR-34

' Docket: 50-267

Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840

Denver, Colorado 80201

Facility Name: Fort St. Vrain Nuclear Station (FSV)

Inspection At: Platteville, Colorado

Inspection Conducted: March 5-8, 1985

Inspec' tor: M//h y/ya/.r

M. E. Skow, Reactor Inspector, Special Projects Date'

and. Engineering Section, Reactor Project

Branch 1

Approved: hf. W&wf

R. E. Ireland, Chief, Spec'al Projects and

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Engineering Section, Reactor Project Branch 1

Inspection Sumary

Inspection Conducted March 5-8, 1985 (Report 50-267/85-06)

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8505200183 850507

PDR ADOCK 05000267

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r' Areas Inspected: Rout'ine, unannounced inspection of receiving and maintenance

- with specific emphasis on the control rod refurbishment program. The

- inspection in these areas is-a continuation of NRC Inspection Report

50-267/85-01. -The inspection involved 33 inspector-hours onsite by.one NRC

- inspector.-

Results: ~ Within the two areas inspected,'one violation was identified (lack

of-QA independence, paragraph 2).

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, DETAILS

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' " 1. . Persons ContactedL

• C. Fuller, Station Manager -

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• F. iNovachek,' LTechnical/ Administrative Services Manager

/*L. Singleton J Manager,-Quality Assurance (QA)-

P 2*FJ Borst,. Support Services Manager

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L*T. Orlin,- QA Service Manager '

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1*R., Craun. Supervisor,iNuclear Site ' Engineering

. ~ R. Gappa,iRefurbishment: Shift Floor Manager

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*P. Moore, ~ Supervisor QA Technical Support

• S; Willford,iTraining Supervisor

JG.;Redmond, MQC Supervisor

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J. Jackson,' QA/QC Supervisor _-

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W. Parsons, QC ReceivingiInspector

, * Denotes those present at exit interview.

-2. Receiving

The NRCLinspector reviewed the following documents:

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,M MRIM-1~  : General Receiving Inspection 4

.P-5 Material Control 8

1Q-15 - Control'of Nonconforming Items 3

'G-2 FSV Procedure Systems 15

FSV Organization and Responsibilities

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Q-1 5 ,

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The. majority of the CRD0A refurbishment parts that had arrived on site had

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' completed receiving inspection. The receiving inspection packages for

.several parts were reviewed by the NRC inspector. The packages appeared

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? complete. The receiving 1 inspectors had up-to-date drawings and change

notices.available as well as the purchase orders.

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During discussions with QA/QC personnel, the NRC inspector was informed

L that corrective changes were being prepared to certain Administrative

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' Q procedures. Members of QA also stated that issuing changes to their

procedures took'a long time. The reason given was that organizations

outside QA which must approve the procedures'often delay approval action

or require revisions to the proposed changes. The approval signatures

that'are required on these Q procedures are specified in G-2. For 16 of

the 18 Q procedures, approval signatures are required from the managers

of the Nuclear' Production, Nuclear Engineering, and Quality Assurance

Divisions; and for 8 of those 16. procedures, the Executive Staff

- Assistant (now' Manager, Nuclear Licensing and Fuels) as well.

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An exenple referred to by QA personnel was -Q-15. _ They stated that current

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attempts to revise Q-15 began in-the first half of 1984.7 Three-major

- major revisions had been. drafted but.had not been approved outside of QA,~

ras of November 1984. ' Two complete rewrites have taken place thus far. in--

1985.- The latest was to have gone to Engineering the week of this

inspection. _ QA personnel stated that the Nuclear Engineering Division

causes most. of the delays in achieving approvals.

. Some documentation was found;in the corrective action request files which~

support the statements by QA personnel. The documents related to-a change

-to Q-16 " Corrective Action System."- CAR 84-093 was written to correct

-items identified by NFSC Audit.C-84-02. The two items referenced'in

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CAR 84-093 are CAAR's 633 and 712. CAR 84-093 points out that "the

requests were made over 'one year' ago." CAR-84-093 explains the

underlying cause for CAAR 633's delay as "the failure to obtain timely-

approval (or disapproval) of a procedure in order to get it revised and

issued.' CAAR 633 is~ dated June 20, 1983. The revision to Q-16 was

finall sued October-12, 1984.

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CAR _84-093 stated that the resolution to CAAR 712 "was a trivial change

and was-determined not to be a factor in the resolution of the CAAR.-. ...

The minor change requested in CAAR 712 is currently caught up in a' major

revision to Q-15. . . ." The change to Q-15 was expected to be completed

by February 1,1985, as stated cn CAR-84-093, " Action to Correct

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Discrepancy."

Corrective action timeliness was previously raised as an unresolved item,

'50-267/8123-01. It was' discussed further in inspection report 50-267/82-03-

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.and was .left open pending further-review of a revised corrective action

program. The item was closed in inspection report 50-267/82-18 after Q-16

had been' revised and the number of outstanding CAARs had been reduced.

However, tht examples cited above illustrate that the QA organization is

still having difficulty revising their Q procedures to resolve CARS as

required by 10 CFR 50, Appendix B.

The three managers of Nuclear Production, Nuclear Engineering, and

Nuclear Licensing and Fuels who must also approve Q procedures have each

-been QA managers. The NRC inspector felt this provides strong potential-

for constructive input to the QA program. However, the NRC inspector

noted that the requirement in G-2 for three or four of these managers to

all sign for approval could be cause for Q procedure revisions not being. ,

made in a prompt, timely manner. >

This is a violation. (8506-01)

3. Maintenance

The first rod, to be refurbished CRD0A 21, was discussed in the maintanance

section of NRC Inspection Report 85-01. During this inspection, CRD0A 21

.had already been-refurbished and installed in the core. CRD0As 26 and 2

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were nearly complete. and CRD0As 15 and 4 were earlier in their refurbish-

ment programs. CRD0A 6 was-removed from_ the core during' this period and

began to be refurbished.-

The number of procedure deviation reports being generated has diminished

since the previous inspection. This supports the observations by the NRC

inspector that the refurbishment program is now proceeding more smoothly.-

The: availability of' parts has. improved, as discussed in paragraph 2, and

the methods for dispensing them are continuing to evolve within procedural

constraints. The system is maintaining parts traceability. However, if a

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replaced part is inadvertently left out of the list in the procedure, it'-

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would be . difficult, after the fact, to find documentation during an audit.

No violations or deviations were noted in this area.

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Exit Interview

An exit interview was held March 8,1985, with Mr. Singleton, Manager -

. Qualtiy Assurance and other PSC personnel as denoted in paragraph 1.of

this report.' The NRC senior resident inspector and R. Farrell,-a senior

. resident inspector from another site in Region IV, also attended this

meeting. At this meeting the scope of the inspection and the findings

were summarized.

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