IR 05000333/1981004
| ML20009B436 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 03/19/1981 |
| From: | Caphton D, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20009B431 | List: |
| References | |
| 50-333-81-04, 50-333-81-4, NUDOCS 8107150443 | |
| Download: ML20009B436 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-333/81-04 Docket No.
50-333 License No.
DPR-59 Priority Category C
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Licensee:
Power Authority of the State of New York
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P. O. Box 41 pcoming,NewYork 13093 Facility Name:
FitzPatrick Nuclear fower Plant Inspection at:
Oswego, New York Inspection conducted: January 26-30, 1981 5/lI/h Inspectors:
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'G./Napuda,ReactorInspector
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oate signed
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date signed Approved by:
b le G/ 6N D.L.Caphtdn,Chfef, Management a e signed Programs Section, Engineering Inspection Branch Inspection Summary:
Inspection on January 26-30, 1981 (Recort No. 50-333/91-04)
Area Inspected:
Routine, unannounced inspection of the QA~ Program implementation Tncluding Audits; Design Changes / Modifications; and, previously identified 'tems.
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The inspection involved 32 inspector-hours on site by one NRC region-based inspector.
Results: Of the three areas inspected, no items of noncompliant Lee identified Tii one area and two items of noncompliance were identified in two areas (Level IV Violation - inade graph 3.c(1); Level V Violation quate and ineffective corrective action, Para-
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Failure of drawings to reflect as-built / appropriate conditions, Paragraph 3.c.(2)). The latter violation is a r.,urring item.
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Region I Form 12 (Rev. April 77)
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0107150443 810325 PDR ADOCK 050003*3 J
C PDR
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DETAILS 1.
Persons Contacted P. Borozenick, Shift Supervisor
- V. Childs, Assistant Resident Manager
- R. Converse, Operations Superintendent
- M. Cosgrove, Site Quality Assurance Engineer
- B. Deist, Nuclear Operations Manager J. Erkan, Plant Engineer, Electrical
- W.~ Fernandez, Technical Services Superintencent 50. Holliday, Plant Engineer
- C. Oroguany, Reactor Analyst Supervisor
- R. Pasternak, Resident Manager P. Simpson, Shift Technical Advisor
- D. Tall, Training Coordinator
- D. Thomison, Training Manager NRC Personnel
- J. Linville, Senior Resident Inspector
- L. Doerflein, Resident Inspector
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The inspector 'also contacted other licensee employees during the course of the inspection including engineering, maintenance, office, operating plant technical support, quality assurance and stores personnel.
- denotes those present at the exit interview.
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Licensee Action on Previous Ins;;ection Findings (Closed) Deficiency (50-333/79-13-07):
Failure to notify the RI Office of 10 CFR 50.59 changes.
The licensee did send the NRC RI Office information
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on 10 CFR 50,59 changes.
.(Closed) Deficiency (50-333/79-13-08):
Drawings depicting the same systems showed differing as-built conditions.
This item is closed for record purposes because a recurrent item of noncompliance is discussed in Paragraph 3.c(1).
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The following items applied to both the FitzPatrick and Indian Point 3 facilities. They were addressed at PASNY~New York City corporate offices
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as described in IE Inspection Report 50-286/80-20 and are repeated here for record purposes (item numbers are identical).
(Closed) 'Inresolved Item (50-333/79-13-01):
Engineering Department Manuals do not adcress *,he requirements of ANSI N45.2.11 to necessary specificity.
The ifcensee st i.ed that safety related design work was not currently done
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by the corporate engineering staff, and that such procedures were presently not required since none of the activities specified in ANSI 45.2.11 are performed by corporate engineering personnel. The licensee stated that the
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corporate engineering staff may become involved in safety related design work in the future, and that corporate' policy statements were being prepared to cover this area. The inspector reviewed the draft Nuclear Administrative Policy Manual (NuAP) which the licensee representative stated would be completed and implemented prior to conducting safety related design work with the corporate engineering staff.
(Closed) Infraction (50-333/79-13-02):
Failure of Engineering Department to respond to Audit Report within 30 days.
The inspector reviewed an Engineering Department Memo (J. R. Schmeider, January 7,1980) which responded
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to each of the QA aucit findings, and stated that the Engineerirg Department understood and would comply with the thirty-day response requirements for audit findings.
(Closed) Unresolved Item (50-333/79-13-03):
Develop procedural controls i
for storage and maintenance of drawings at the corporate engineering offices.
The licensee stated that since no safety related design engineering was
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done in the New York office, there was no need for maintaining " controlled i
copy" drawings at the corporate office, and that controlled copies would continue to be maintained on-site, and by the cognizant Architect / Engineering Firms. The licensee representative also stated that in the near future, corporate engineering may be tasked with safety related design work, and
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that procedures would be developed for drawing and document control prior
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to cunducting these activities.
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(Closed) Unresolved Item (50-333/79-13-04):- Delete requirement for SRC to review Engineering Department Procedures from EDP-5.1 as this is not a licensee Program commitment. The inspector reviewed a draft Revision 2 to EDP-5.1 which was transmitted for internal review on 10/1/80.
This revision deletes the requirement for the SRC to review Engineering Department Procedures.
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(Closed) Infraction (50-333/79-13-05):
Failure to.obtain approval of a licensee amendment prior to implemerting an organizational change in viola-
tion of Technical Specifications.
The inspector reviewad Amendment No. 50
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to Facility Operating License No. DPR-59, and verified that the present
unit organization is in compliance with this amendment which was iss;;d September 5, 1980.
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3.
Design Changes / Modifications h
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References WACP 10.1.5, Control and Identification of' Purchased Materials
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and Services, Revision 3.
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. ACP 10.1.6, Control of Modifications, Revision 4.
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WACP 10.1.8,-Automated Records Management System, Revision 0.
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AP-1.2, Plant Operations Review Committee, Revision 2.
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AP-1.7, QA Program, Revision 0.
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AP-8.1, Collection, Storage, and Maintenance of Records, Revision
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QAP 10.1, Inspeuuton of Quality Related Activities, Revision N/A.
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QAP 11.1, Test Control, Revision N/A.
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QAP 7.3, Receiving Inspection, Revision N/A.
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PSC-5, Control of Drawings and Technical Manuals, Revision 0
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Review The modifications listed bslow were reviewed to verify that the follow-ing requirements have been implemented as applicable.
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10 CFR 50.59 reviews were performed and documented.
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Design changes / modifications were reviewed in accordance with the
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requirements of the Technical Specifications and the QA Program.
Design changes / modifications were accomplished in accordance with
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written procedures.
Acceptance testing was accomplished and deemed satisfactory.
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Procedures and drawings required to be changed or generated as a
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result of a design change / modification were updated or generated (a sample).
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The design change / modification package has been transmitted to
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the records ret.~1 eval department for incorporation as a plant record.
They were:
.75-262, Add Keep Full Instrumentation to Core Spray System.
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'if-90, CAD System Installation.
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1 78-30, Drywell Equipment Drain Sump.
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78-45, CAD System.
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78-48, Target Rock Safety Relief Valve Topworks Changeout.
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79-17, Target Rock Relief Valve Change (Topworks).
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Findings The inspector identified the following:
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(1) 75-262: Drawings OP-14-1, Revision 4 and FM-23A, Revision 13 depict the same system.
OP-14-1 shows valves 409 A an B, 411 A and B, and 711 A and 8 closed with the pipe beyond the 409 and 411 valves capped.
FM-23A shows the same valves open with the piping uncapped beyond valves 409 and 411.
Operating Procedure OP-14,-Revision 3 agrees with Drawing OP-14-1 and both appear to be accurate based on the modification package documents and plant operating conditions.
76-90:
Drawings 37-1A, Revision 2 and FM-18A, Revision 20 depict the same system. OP-37-1A shows valves AHB 190 and 191 cren while FM-18A shows chem closed.
Operating Procedure 37, Revision 4 and FM-18A agree and appear to be accurate based on the modification package documents and plant operating conditions.
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The above examples are identical or similar to the item of noncom-pliance (Deficiency D) brought to the attention of the licensee in a letter dated December 11.,1979. -That such conditions still exist is contrary to 10 CFR 50, Appendix B, Criterion XVI which requires that established measures "... assure that the cause of the condition is determined and corrective action taken to preclude repetition."; and to the Quality Assurance Program, Section 16, Paragraph 2.1, which states in part, " Major cnd recurring condi-tions, adverse to quality, such as... deficiencies...shall be identified, the main causes determined, and prom ~pt corrective action taken to preclude repetition.
These conditions include failures of the quality system." These two examples constitute an item of noncompliance (50-333/81-04-01).
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(2) 76-90: While reviewing drawings affected by this design change /
modification, the inspector identified that: Drawing FM-18A, Revision 20 Aperture Card was annotated that. Modification 76-61 affected the drawing but Controlled Copy No. 2 of the drawings
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had no such notation; Drawing FM-16B, Revision 12 (Controlled Copy No. 2) had the notation that Modification 75-142 affected the drawing crossed out, initialed and dated January 26, 1979, while the drawing Aperture Card was still so annotated.
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78-30:' - Drawing ESK-6 MAG, Revision 4 had neither the aperture
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.of the,_ drawing depicting "as-built" conditions.in. differing areas.
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The above examples are contrary to 10 CFR 50 Appendix B, Criterion V that requires that activities "...be prescribed by documented instructions, procedures...and shall be accomplished in accordance i
with these instructions, procedures..."; the Quality Assurance Manual, Section 5, Paragraph 2.2 which states in part, " Quality affecting activities shall be conducted in accordance with approved procedures..."; and, Plant Standing Order No. 5, Control of Drawings and Technical Manuals, Revision 0, Paragraph 7.1, which states in part, "The master drawing file...shall be maintained
...to reflect the as-built condition of the plant...This file may consist of microfilm aperture cards and/or hard copy prints...Upon completion of an addition, modification or correction to the plant requiring changes in drawings...shall-stamp the affected drawings with the following:
' Drawing is pending revision. This drawing has been changed.
See modification coordinator'." These examples constitute an' item of-noncompliance. '(50-333/81-04-021 (3) The inspector noted that approximately 100 modification packages are still maintained in an "open" status.
Included are at least one dated 1974, 15 dated 1975, 7 dated 1976 and 4 dated 1978.
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The inspector also determined that several appeared to qualify for close out.
Licensee Audit No. 339 (reference Paragraph 4) identified, among other unacceptable conditior.s, that a backlog of modification packages existed (i.e., not ciosed out).
The inspector discussed the following points with the licensee:
The initial rejection of the audit findings by the auditor.
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The auditor sustaining most of the findings in a May 5, 1980
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evaluation and May 6, 1980 memo.
An extension to December 1980 for corrective action comple-
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tion granted June 6, 1980.
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An internal memorandum dated January 27, 1981 stating an
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additional year would be needed to clear the backlog if the 1981 budget for additional manpower is approved.
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The acceptable processing of current modifications associated
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with Fire Protection / Prevention and post THI-2 requirements where each area has been assigned an engineer to act as modification coordinator.
A licensee representative stated it appeared that senior manage-ment would approve a budget request for the addition of two draftsmen and two Designers / Engineers who would be assigned to work full time on modification package closeout.
The inspector stated that his concerns about the backlog of open
- modification packages and their timely closecut would be communi-cated to RI management. The licensee acknowledged the inspector's statement.
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_ Audits The inspector reviewed PASNY standard Audit No. 339, Control of Modifications, WACP 10.1.6 completed 3/25-28/80. The inspector verified that this audit was conducted in accordance with written procedures and checklists; with audit findings documented and reviewed; with followup action ini'tated/
completed; and general audit conduct in accordance with established schedules and procedures. The inspector discussed the audit findings ar.d his concerns with the licensee (refer to Paragraph 3.c(3)).
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No unacceptable conditions were identified.
5.
Exit Interview Licensee management was periodically informed of inspection findings as
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Date Report Paragraphs January 26,-1981
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2, 3 Entrance Interview, 2 January 27, 1981 January.28, 1981 3, 4 January 29, 1981
January 30,_1981 2,3,4 A summary of inspection findings was provided to the senior licensee repre-sectatives at the conclusion of the inspection (denoted in Paragraph 1).
The licensee acknowledged the inspector's findings.
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