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Insp Rept 50-267/85-11 on 850415-19.Violation Noted:Failure to Follow Proper Procurement Procedures & Failure to Conduct QA Receipt Insps
	ML20129C560
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/21/1985
From:	Chaney H, Ireland R, Murray B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20129C552	List: ML20129C548; ML20129C554; ML20129C560;
References
	50-267-85-11, NUDOCS 8506050585
	Download: ML20129C560 (10)
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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/85-11 License: OPR-34

Docket: 50-267

Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840

Denver, Colorado 80201

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

Inspection At: FSV Site, Weld County, Platteville, Colorado

Inspection Conducted: April 15-19, 1985

Inspector: t

a 5-[9 /fC

H. D. Chaney,5 Radiation Spe alist Date

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Approved: BJt//N 7 b

IIlainbMurray,Xhief,facilitiesRadiological Dats

Protection Section

YLfL h. uwtA) 3fll15

R. E. Ireland, Chief, Special' Projects and Date

Engineering Section

Inspection Summary

Inspection Conducted April 15-19, 1985 (Report 50-267/85-11)

Areas Inspected: Routine, unannounced inspection of the licensee's radioactive

material transportation program, 10 CFR Part 61.55 and 61.56 low-level <

radioactive waste (LLRW) program, onsite LLRW storage program, and radiation

protection (RP) activities associated with the control rod drive and orifice

assembly (CRD&OA) refurbishment. The inspection involved 40 inspector-hours

onsite and 8 inspector-hours offsite by one NRC inspector.

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Results: Within the'four areas inspected, no violations or deviations were

tidentified in-three areas. Two violations were identified in one area (failure

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to follow procurement procedures, paragraph 2.e; and failure to perform quality

'assurtnce. receipt-inspections, paragraph 2.e).

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DETAILS

1. - Persons Contacted

PSC

J. Gahm, Manager, Nuclear Production

C. Fuller, Station Manager

F. Novachek, Technical Administrative Services Supervisor

- F. Borst, Support Services Manager / Radiation Protection Manager (SSM/ RPM)

L.. Singleton, Manager, Quality Assurance (QA)

T. Schleiger, Health Physics (HP) Supervisor

L. Bishard, Test Director

T. Orlin, QA Services Manager

M. Ferris, QA Operations Manager

J. Gramling, Nuclear Licensing Supervisor

M. Niehoff, Site Nuclear Engineering Manager

R. Craun, Site Nuclear Engineering Supervisor

P. Burck, QA Auditor Supervisor

G. Powers, Scheduling / Stores Supervisor

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T..Prenger, QA Engineering Supervisor

J. Jackson, QA/ Quality Control (QC) Supervisor

J. Sills, Senior Plant Engineer

M..McBride, Nuclear Fuels and Analysis Manager

Others

G. L. Plumlee, III, NRC Resident Inspector

M. E. Skow, NRC Inspector

R. C. Stewart, NRC Inspector

R. H. Odegaarden, NRC Headquarters

G. W. Matheney, Consultant to PSC

M. McCormick, Consultant to PSC

Denotes those present during the exit interview' held on April 19, 1985.

The NRC inspector also interviewed several other licensee employees

including QA/QC, warehouse and HP personnel.

2. ' Radioactive Material Transportation Program

The NRC inspector reviewed the licensee's radioactive material

transportation program for compliance with the requirements of

10 CFR Part 71, 49 CFR Parts 171 through 178, NRC Inspection and

Enforcement (I&E) Bulletin 79-19, the recommendations of NRC Regulatory

Guides (RGs) 7.1 through 7.10, and the guidance contained in NUREG-0923

and I&E Information Notices 83-10 and 84-14.

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a. Management Control's

'The NRC inspector reviewed the licensee's organization.within the

support services department that is responsible for activities

-associated with the shipment of radioactive materials, with.the

exception 'of.QA/QC activities and the shipment of spent reactor fuel,

which are the responsibility of the FSV QA and technical /

administrative services departments. Each department had implemented

procedures for the conduct of their specific activities. The

licensee's onsite organization is not as depicted in.the Technical

Specifications (TS) nor the Final Safety Analysis, Report (FSAR) for

.-the functional responsibilities of.the support services manager.

These discrepancies were previously discussed in NRC. Inspection

Report 50-267/85-02. The NRC inspector determined that the licensee

iad established job / task descriptions for key personnel responsible

for the transportation of radioactive materials.

The SSM/ RPM and HP supervisor are responsible for radioactive

material shipping activities, excluding spent fuel which is a dual

responsibility between technical services and the HP group. Licensee

procedures (SUSMAP-4 and Administrative P-3) assign the

aforementioned specific responsibilities. Procedures were found to

be prepared and approved in accordance with FSV administrative

instructions. The NRC inspector discussed with. licensee

representatives the content and scope of shipping procedures'and

found them adequate to implement the current radioactive material

shipping requirements.

No violations or deviations were identified.

b. Training and Qualifications

. The NRC inspector conducted interviews with several employees

responsible for training and shipment of radioactive materials and

spent fuel, and reviewed lesson plans, training records and licensee

qualification criteria. The NRC inspector noted that several staff

members have completed or are scheduled to attend retraining on FSV

transportation activities. The NRC inspector noted that the

technical services senior engineer responsible for development of

procedures and control'of spent fuel handling and loading for offsite

shipment was not among the personnel scheduled to receive training

.concerning transportation regulations. The NRC inspector noted that

most of the HP staff had received specialized training in

transportation activities by either an onsite training progran or

attendance in an offsite training course.

No violations or deviations were identified.

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c. Procedures and Program Implementation

The NRC inspector reviewed the licensee's procedures and checklists

used for shipment of radioactive materials, receipt of radioactive

materials, spent fuel shipments, spent fuel shipping cask repairs and

seal testing, packaging use and maintenance manuals. The licensee's

procedures provide instruction for evaluating and shipping

radioactive material to comply with DDT and NRC regulations. The

licensee was also noted to have implemented an approved QA program.

The licensee was noted to have used detailed checklists with QC

verifications for determination of shipment classification, package

selection, package (cask) opening, inspection, loading, and closure.

The NRC inspector also noted that the licensee maintains a burial

site license, cask user / owner maintenance manuals, letters of

authorization, maintenance records and procedures, and current DOT

and NRC shipping regulations.

No violations or deviations were identified.

d. Review and Audits

The NRC inspector reviewed the licensee's QA audit program for

radioactive material transportation activities. The review included

audit procedures and checklists, corrective action program, an

in progress audit, and discussions with auditors. The licensee was

noted to use outside technical assistance to supplement the auditors

experience level in DOT /NRC transportation regulations. An audit was

being conducted which appeared to be comprehensive and addressed the

applicable requirements of 49 CFR Parts 171 through 178 and

10 CFR Parts 71 and 73.

No violations or deviations were identified.

e. Procurement and Inspection of Packages

The NRC inspector reviewed the licensee's program for procurement and

reuse of radioactive material shipping packages. The licensee was

noted to have used both DOT and NRC certified packages. The

documentation of shipping packages used was detailed and involved the

use of checklists requiring signature verification of completed

steps / tasks.

The NRC inspector determired during a review of a licensee's

' submittal to NRC for the certification of modifications to a Type B -

shipping cask (FSV-1) that certain QA activities required by

Subpart H of 10 CFR Part 71 were not being complied with. These

activities involved QA review of orders for purchased materials

(10 CFR Part 71.109) and inspection of delivered products

(10 CFR Part 71.115).

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(1) Procurement Procedures i

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l The NRC inspector noted on April 18, 1985, that the licensee had --

received and stored on the refueling floor area components of

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the spent fuel shipping cask FSV-1 (NRC Certificate of

Compliance No. USA /6346/B). These shipping cask components

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include burial canisters which are an integral part of the FSV-1 -

cask. The burial canisters are separate, removal components

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that fit inside the primary shipping cask. After receipt at the E

burial site, the burial canisters are removed from the primary =,

cask and disposed along with the radioactive waste material. E

The FSV burial canisters are designated to hold control rod t

drive (CRD) components and used control rods. I

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The NRC inspector determined by discussions with licensee .

representatives and a review of purchase orders, memoranda / letters, g

and QA review checklist that certain components for use in

conjunction with disposal of used control rods were ordered to M

be designed and manufactured by a contractor Purchase Order.

(PO) No. N3931 issued on February 2, 1982, provided for contractor a

technical assistance related to the FSV reactor fluctuation "

corrective action program (work specification WS-ALL-Sc). This 2

P0 (N3931) and P0 (N4574) which superseded it had a QA review J

performed on them; however, the review was based on the contractor =

providing only " technical assistance," not design and manufacturing 2

services. By PSC letter PG-0941 dated October 8, 1982, PSC -

requested changes to the contra::t to design, fabricate and 4

supply burial cannisters for control rod disposal. No QA f

review was performed for this change in contract scope. FSV ?

procedure Q-4, paragraph 4.8.2, requires that only revisions to

P0s that do not affect the technical or quality requirements can

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be generated by memorandum. Discussions with licensee QA/QC -

personnel indicated that this method of procurement is not an

isolated case. The NRC inspector also noted by review of a ;

contractor's letter to PSC dated January 2, 1984, that other "

equipment involved in the disposal of CRD components was purchased

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and manufactured per PO N4574 which was found to also be only ;

for the providing of technical services per WS-ALL-5. The failure -

to follow proper procurement practices is considered a violation

of 10 CFR Part 71.109 and FSV QA Procedure Q-4 (267/8511-01). i

(2) Receipt Inspections

The NRC inspector determined on April 18, 1985, that the

licensee had onsite at least one special disposable burial -

canister to be used in the shipment of reactor control rods and a

CRD components in shipping cask FSV-1. The licensee estimated '

the onsite arrival time of the canisters to be January 6, 1984. 2

The NRC inspector determined that the canister (s) (described in :

PSC letter P-85122, from M. McBride (PSC), to C. E. Mcdonald ",

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(NRC), ' subject: Docket 71-6346, FSV-1 Certificate of Compliance

Revision, dated April 4, 1985) had not been provided a QA/QC receipt

inspection as required by 10 CFR Part 71.115 and FSV Procedure Q-7,

paragraph 4.4.1. This is considered an apparent violation

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(267/8511-02).

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This apparent failure to perform QA/QC receipt inspection on

purchased materials that affect quality is similar to the violation

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(267/8401-01) referenced in NRC Inspection Report 50-267/84-01. The

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NRC inspector noted to the licensee that it was evident that PSC's

corrective action in response to the above noted violation was

' ineffective in preventing a recurrence of the problem especially from

the point of ensuring that material existing onsite, prior to

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implementation of the corrective action resulting from the above

, inspection, had not received a QA/QC inspection. The licensee

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initiated on April 19, 1985, actions to have the canisters " hold

l tagged" pending further QA/QC actions.

f. Use of 00T Specification 7A Packages

The NRC inspector reviewed the licensee's engineering evaluations and

use o' 00T specification containers. The licensee had modified a

' helium circulator shipping cradle per a PSC nuclear engineering

dept.rtment evaluation (NDS-84-0295) to provide nonspecific

certification as a specification 7A shipping container. This

evaluation appears to satisfy the requirements set forth in

49 CFR Part 173.411 and 412. The licensee's engineering evaluation

i for the helium circulator cradle had been forwarded to NRC

headquarters staff for further review and comment.

No violations or deviations were identified. '

g. Radioactive Material Receipt and Shipment Records

The NRC inspector reviewed selected licensee records for receipt and

shipment of radioactise materials, including spent fuel, for the

i periods 1984 and 1985. The records reviewed indicated compliance

with the requirements of FSV Procedures HPP-23 and 30,

10 CFR Part 20.205 and 71.5 and 49 CFR Parts 172.200, 203, 173.421,

425, and 441. The NRC inspector noted that the licensee had made

approximately 43 shi,ments of radioactive material during 1984 of

which 17 shipments involved spent fuel. Eight shipments of

radioactive material have been made during 1985. These eight

shipments did not include spent fuel shipments. The NRC inspector

also noted that none of the shipments made in 1984 and 1985 involved

low-level radioactive waste. The NRC inspector found the licensee's

activities to be well documented. l

No violations or deviations were identified. ,

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h. Transportation Incidents

The NRC inspector reviewed the licensee's records and interviewed

personnel to determine compliance with D0T and NRC requirements

10 CFR Parts 20.205, 20.311, 71.95 and 40 CFR Part 175.31 related to

the transportation of radioactive material.

The NRC-inspector determined that licensee shipments had not" involved

any reportable incidents; however, the licensee informed the NRC

inspector and provided documentation on the receipt of some

contaminated CRD bearings in April 18, 1985, from GA Technologies of

San Diego, California. These bearings had been shipped by cargo

aircraft (GA Shipping Order 189646, dated April 16,1985) to PSC/FSV

as " Excepted Radioactive Material, Instruments and Articles, UN-2911,

per 40 CFR 173.421," when they were actually only " limited

quantity UN-2910." The licensee also noted that the required

" Radioactive" label specified in 40 CFR Part 173.421 was substituted

on seven interior packages with " Caution Radioactive Material" labels

and four packages did not have any labeling. The shipment was within

the limits for radiation and removable surface contamination upon

receipt inspection at FSV. The NRC inspector discussed with the

licensee their notification of the nearest Federal ~ Aviation

Administration office as required by 40 CFR Part 175.31 and the

forwarding of this information to the NRC Region V office.

No violations or deviations were identified.

3. Low-Level Radioactive Waste Management

The NRC inspector reviewed the licensee's proposed program for control,

classification, characterization, and shipment of low-level radioactive

waste as required by 10 CFR Part 61.55 and 61.56.

This area was previously discussed in NRC Inspection Reports 50-267/83-28

and 85-02, and is currently being tracked to completion by

OpenItem(267/8328-04). The NRC inspector reviewed the licensee's

accepted contractor proposal for establishing a program for meeting the -

requirements of 10 CFR Part 61.55 and 61.56 for low-level waste disposal.

The NRC inspector discussed with licensee representatives the contractor's '

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proposed scaling factor program, waste stream identification, and

radiochemistry analyses by both the licensee and a subcontractor to the

prime contractor for the program. The licensee expects to have the

program, including onsite training of key personnel, completed by June 1,

1985. The licensee's process control program (SUSMAP-3) was discussed

with licensee representatives and found to be in agreement with NRC staff

and NUREG-0472 guidance. The NRC inspector noted that the licensee had-

not made any shipments of low-level waste to a disposal contractor since

the effective date of the 10 CFR Part 61 requirements.

- No violations or deviations were identified.

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4. Onsite Radioactive Waste Storage ' g- '

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The licensee's onsite low-level radioactive waste storage facilities were d-

..' reviewed for compliance with the guidance provided in NRC Generic

Letter 81-38. This area was initially addressed in NRC Inspection- N

.-J . Report 50-267/83-28 and most recently in 50-267/85-02, and is currently i

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being tracked for corrective action per open item 267/8328-05. i;r

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U The NRC inspector reviewed current FSV operating procedures for low-level

radioactive waste management and storage (P-3, SUSMAP-4, HPP-1, and

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HPP-26), inspected waste compaction area and the four enclosed trailers

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being used for waste storage, and held discussions with licensee 3R

representatives. The NRC inspector noted that an additional trailer had ft

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been procured for storage purposes since the la.it inspection of this area y

(50-267/83-28) in December 1983. The licensee stated that a radiological : .l'

environmental assessment study is expected to be completed by April 19, Ui

e 1985, and should resolve the concerns regarding open item 267/8328-05. '

1 The licensee expects to start reducing inventory of solid dry active T.-

J. waste upon full implementation of their-10 CFR Part 61 low-level waste ?

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disposal program. The licensee's interim inventory and storage facility

surveillance programs were reviewed and found satisfactory. [T>

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? The NRC inspector reviewed the licensee's RP activities associated with

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'r the CRD&OA refurbishment program to determine compliance with -V

C -10 CFR Part 20, the TS and Procedures SUSMAP-4 and FHPWP-100.

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The NRC inspector reviewed work procedures and survey records, attended j.M

prework briefings, inspected RP personnel activities and specific task s.T

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operations involving control rod maintenance activities and held 9-

discussions with shift RP technicians. The NRC inspector discussed V

.i personnel dosimetry positioning and the use of radiological status boards Q: ,

with licensee representatives. The NRC inspector noted to licensee 3, .}A

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. representatives the fact that the status board on the elevation 10 of the

reactor building (where personnel dress out in protective clothing) was

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not being frequently updated. The licensee indicated that with more

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board will need to be assessed. Ei

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The NRC inspector met with the licensee representatives and the NRC fl

.. resident inspector identified in paragraph 1 at the conclusion of the ' .V ?

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inspection on March 19, 1985. The NRC inspector summarized the scope and gh-

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findings'of the inspection presented in this report. The licensee

acknowledged the' inspector's findings and stated that an investigation of

. the. findings would be initiated.

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