ML20010B230
| ML20010B230 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/28/1981 |
| From: | Doerflein L, Kister H, Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010B222 | List: |
| References | |
| 50-333-81-07, 50-333-81-7, NUDOCS 8108140248 | |
| Download: ML20010B230 (12) | |
See also: IR 05000333/1981007
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DCS NUMBERS
U.S. NUCLEAR REGULATORY COMMISSION
50333-810117
0FFICE OF INSPECTION AND ENFORCEMENT
50333-810209
50333-810210
Region I
50333-810213
50333-810219
Report No.
81-07
50333-810220
50333-810225
Docket No.
50-333
License No. DPR-59
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Priority
Category
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Licensee: Power Authority of the State of New York
P. O. Box 41
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Lyconi.ng, New York
13093.
James A. FitzPatrick Nuclear Power Station
Facility Name:
Inspection at: Scriba, New York
Inspection conducted:
arch 1,1981 - March 31,1981
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Inspectors:
/N
(LinVi'lle Res"~nt Inspector
date sitjned
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L.Doerflyin,ResidentInspector
date signed
date signed
Approved by: If
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KisterMhief, Reactor Projects
date s'igned
Section 1C
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Inspection Summary:
Inspection on March 1,1981-March 31,1981 (Report No. 50-333/81-07)
Areas Inspected:
Routine inspection by the Resident Inspectors (108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br />) of licensee
action on previous inspection items; review of Licensee Event Reports; licensee action
on TMI Task Action Plan Items; licensee action on IE Bulletins and Circulars; control
room inspections; Log and Record review; plant tours; witnessing surveillance tests
and observation cf Maintenance activities.
Results: Of the nine areas inspected no items of noncompliance were noted in eight
areas. 1-our items of noncompliance were identified in one area.
(Failure to get prior
NRC approval when making a change involving Technical Specifica'. ions, Failure to develop
a written nuclear safety evaluation as required by 10CFR50.59(b), Failure of PORC to
review a change in a plant system affecting nuclear safety, Failure to document the
basis for accepting a condition adverse to quality). One Deviation from a licensee
commitment was identified in one area (Failure to install an isolation valve capable
of remote manual isolation frcm the control room on the RBCLCW system effluent lines
from containment).
Region I Form 12
(Rev. April 77)
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0108140248 810731
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DETAILS
1.
Persons Contacted
- J. Bayne, Senior Vice President, Nuclear Generation
- A. Klausmann, Vice President, Quality Assurance
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- B. Diest, Manager-Nuclear Operations
- R. Baker, Superintendent of Power
N. Brosce, Maintenance Superintendent
- R. Burns, Assistant to Superintendent of Power
- V. Childs, Assistant to Resident Manager
- R. Converse, Operations Superintendent
- M. Cosgrove, Site Quality Assurance Engineer
W. Fernandez, Technical Services Superintendent
H. Kieth, Instrument and Control Superintendent
E. Mulcahey, Radiological'and Environmental Services Superintendent
C. Orogvany, Reactor Analyst Supervisor
- R. Pasternak, Resident Manager-
D. Tall, Training Coordinator
The inspectors also interviewed other licensee personnel during this
inspection including Shift Supervisors, Administrative, Operators,
Health Physics, Security, Instrument and Control, Maintenance and
Contractor Personnel.
- Denotes those present at an' exit interview.
2.
Licensee Action On Previous Inspection Findings
(Closed) UNRESOLVED ITEM (333/80-08-02)
In-response to NUREG 0737,
Item I.C.6, the licensee issued Work Activities Control Procedure 10.1.2,
Equipment and Personnel Protective Tagging, Revision 3, dated December 18,
1980. This requires that tags be second checked and should provide added
assurance that tagouts are adequate for.the scope of work.
(Closed) UNRESOLVED ITEM (333/80-12-01) The licensee :ssued Operations
Department Standing Order No. 4, Shift Relief and. Log Keeping, Revision 7,
dated October 28, 1980, to change the title of the Equipment Status Log to
the' Auxiliary Operator's Log.
(Closed) UNRESOLVED ITEM (333/80-15-05) The licensee submitted a followup
report to LER 80-050 which provided the general results of the Type P and C
tests conducted during the 1980 refueling outage. The inspector reviewed
the results of the Type B and C tests and had no further questions.
(Closed) UNRESOLVED ITEM (333/80-21-03) Since the licensee transferred
the seventh STA who did not hold a bachelor's degree to another department,
it is no longer necessary to define the equivalency.
(Closed) UNRESOLVED ITEM (333/80-21-04) The licensee issued 0perations
Department Standing Order No. 4, Shift Relief and Log Keeping, Revision 7,
dated October 28, 1980, which changed the title of the Equipment Status Log
to the Auxiliary Operator's Log.
In addition, the licensee issued
Instrument and Control Department Standing Order No. 6, Instrument and
Control ~ Work Activities Control Log Book, Revision 0, dated December 1980,
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and Radiolcgical and Environmental Services Department Si.anding Order
No. 2, Maintenance of Radiation Protection Records, Revision 1, dated
December 19, 1980, which provide departmental equipment status logs for
shift turnover purposes.
(Closed) UNRESOLVED ITEM (333/80-21-05) The licensee issued Revision 5
to Operations Department Standing Order (0DS0) No.1, Operating Staff
Responsibilities and Authorities, dated December 9,1980, deleting the
ambiguity regarding the authority of the person in the control room
during emergency conditions.
(Closed) UNRESOLVED ITEM (333/83-21-06) The licensee revised the
Emergency Plan and Procedures, Revision 6, dated December 12, 1980 and
issued procedure no. CLI-20, MSA Portable Combustible Gas Indicator,
Revision 0, dated December 19, 1980 to make interim provisions for
drawing a containment atmosphere sample during accident conditions
assuming that the secondary containment is accessible for some period
of time.
(Closed) Severity Level V Violation (Supplement 1) (333/80-21-07) The
licensee revised Preop 02A, Revision 0, dated December 10, 1980, deleting
the requirement for a test of the SRV acoustic tronitors at 100 percent
power.
In addition, the licensee will revise the Work Activities Control
Procedure for the Control of Modifications by April 1,1981.
(Closed) UNRESOLVED ITEM (333/80-21-09) The licensee made provisions
for moving essential personnel to the control room if the technical
support center becomes uninhabitable during accident conditions. This
change is documented in the Emergency Plan and Procedures, Revision 6,
dated December 12, 1980.
(Closed) UNRESOLVED ITEM (333/80-21-10) The licensee issued Emergency
Plan and Procedures, Revision 6, dated December 12, 1980, which describes
the Operational Support Center and its use.
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(0 pen) UNRESOLVED ITEM (333/80-21-11) The licensee is making provisions
to perform a helium leak test of the sample system and the standby gas
treatment system during the October 1981 refueling outage. The licensee
issued work request 10516 and purchase requisition 22412 to provide for
the completion of this work. This item will remain open pending the result
of these tests and their subsequent incorporation into the leak reduction
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program.
(0 pen) UNRESOLVED ITEM (333/80-BC-01) This item which was identified in
inspection report 80-15 remains open pending completion of modification of
the containment vent and purge valve logic such that at least one of the
automatic safety injection actuation signals is uninhibited and crerable to
initiate valve closure when any other isolation signal may be blocked, reset
or overridden. The licensee stated in their January 9,1981 letter to NRR
that this modification will be completed by the ena of the next refueling
outage scheduled for October 1981.
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(0 pen) UNRESOLVED ITEM (333/81-02-04) The licensee completed modification
no. F1-81-02 which prevents the outside containment- isolation valves for the
drywell floor and equipment drain sump lines from automatically opening upon
reset of a containment isolation signal if their control switches are-not in
the closed position.
In addition, the licensee revised his response to
NUREG 0578, item 2.1.4 to indicate that it -is his position that it is not
necessary that automatic isolation be provided for non-essential systems
which are closed within the reactor containment like the Reactor Building
Closed Loop Cooling Water System. This item remains unresolved pending
NRR's response to the licensee's letter.
3.
In Office Review Of Licensee Event Reports (LER's)
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The inspector reviewed LER's to verify that the details of the events were
clearly reported. The inspector determined that reporting requirements had
been met, the report was adequate to assess the event, the cause appeared
accurate and was supported by details, corrective actions appeared
appropriate to correct the cause, the form was complete and generic
applicability to other plants was not in question.
LER's81-018, 81-019*, 81-020*,81-021, 81-022, and 81-023 were reviewed.
- Reports selected for onsite followup.
No items of noncompliance were identified.
4.
Licensee Action On TMI Task Action Plan Items
Item I.A.l.3 STA Trained Per LL CAT B
The licensee response to these requirements dated January 8, 1981 indicates'
that the STA's received the training required by the NRR staff's October 30,
1979 letter. The program. correlates well with the proposed INP0 program
found in Appendix C, paragraph 6.2 to 6.4 and 6.6 to 6.8 to NUREG 0737.
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However, the licensee's response also indicated that the STA's had completed
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200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of programmed on the job training. Through interviews with four
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STA's the inspector determined that two STA's almost completed and the other
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four STA's had just started when the program was curtailed because of outage
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demands during the summer of 1980. The licensee had already identified this
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error and had taken action to revise his response in a letter dated March-13,
1981 to indicate that'this training was only partially completed.
Item I.A.l.3.1 Shift Manning
License Plant Standing Order No. 26, Revision 1, Overtime Policy, Correlates
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well with the criterii in NUREG 0737, pages 3-6-and 3-7.
Revision 0 of the
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procedure was issued on October. 22, 1980 compared to an implementation date
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of November 1,1980.
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Item I.A.2.1.4 Immediate Upgrading of R0 and SR0 Training and Qualifications
The licensee issued Revision 1 of Indoctrination and Training Procedure No. 4,
Licensed Operator / Senior Operator Replacement Training, dated August 8,1980.
The procedure includes the subject areas listed in paragraph A.2.C of
Enclosure 1 to Harold Denton's letter dated March 28, 1980.. The procedure
was approved September 10, 1980 compared to the implementation date of
August 1, 1980. To date, the licensee has not developed the lesson plans
on the use of installed plant systems to mitigate accidents involving a
sevently damaged core which should have been completed by January 1,1981
according to item II.B.4.1 of NUREG 0737. The licensee requested a waiver
of this training requirement for the last R0 and SR0 which received licenses
in February 1981, and stated in that request that the training would be
completed by February 1981.
In a letter dated March 13, 1981 the licensee
requested that development of this training be delayed until April 1, 1981
and that implementation be delayed until after completion of the current
simulator phase of the requalification training in late April 1981. -This
item will remain unresolved until the licensee has developed his training
program on this subject area.
Item I.C.5 Feedback Of Operating Experience
Licensee Plant Standing Order No. 28, Revision 0, Operating Experience
Feedback, identifies responsibilities for review, feedback, and incorporation
into training programs of operating experience information.
It also requires
audits of the program by the Quality Assurance department. The procedure
was dated December 29, 1980 compared to an implementation date of January 1,1981.
Item I.C.6 Verify Correct Performance Of Operating Activities
Licensee Work Activities Control Procedure No.10.1.2, Revision 3, Equipment
and Personnel Protective Tagging, provides the required assurance that
equipment is properly released for maintenance and returned-to-service from
maintenance. However, the licensee did not address the' requirement for
providing similar verification for surveillance testing or jumper / bypass
control. Consequently, the licensee prepared, issued and implemented Operations
Department Standing Order No. 16, Verification of Correct Performance of
Operating Activities, Revision 0, dated March 26, 1981 to cover these areas.
Item II.K.3.22. A RCIC Suction
Licensee Operating Procedure 19, Revision 5, Reactor Core Isolation Cooling
System (RCIC), provides clear guidance for manual shift of RCIC suction from
the condensat storage tank to the suppression pool. The procedure was dated
December 18,
30 compared to an implementation date of January 1, _1981.
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5.
Licensee Action On IE Bulletins and Circulars
a.
The inspector verified that for the IE Bulletins listed below the
licensee's written response was provided within the time period stated
in the Bulletin, included the information required to t'.: reported,
included adequate corrective action commitments based on information
presented in the Bulletin and was accurate. The inspector further
verified that any corrective action taken by the licensee was as
described in the response.
The following Bulletins were closed out:
IEB 80-02, Inadequate Quality Assurance For Nuclear Supplied
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Equipment
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IEB 80-13, Cracking In Core Spray Spargers
The following Bulletins will remain open for the reasons indicated below:
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IEB 80-08, Examination Of Containment Liner Penetration Welds
The licensee committed to update his response dated July 3, 1980
within thirty days. This submittal was not made. The licensee
stated that the update will be submitted by May 1, 1981.
IEB 80-25, Operating Problems With Target Rock Safety - Relief
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Valves at BWR's
This Bulletin remains open pending completion of the modification
to the pneumatic supply system during the 1981 refueling outage as
committed in the licensee response.
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IEB 81-01, Surveillance of Mechanical Snubbers
This Bulletin will remain open pending completion of the inspection
program for the 15 Pacific Scientific mechanical snubbers during
the 1981 refueling outage and submission of the report within
60 days of its completion.
6.
Reactor Building Closed Loop Cooling Water System Containment Isolation Valves
During followup on IE Bulletin 80-24, Prevention of Damage Due to Water
Leakage Inside Containment (October 17, 1980 Indian Point 2 Event) in
January 1981 the inspector noted that the five Reactor Building Closed Loop
Cooling Water System containment effluent lines have only single manual
isolation valves outside containment. Since this is not consistent with the
requirements of General Design Criterion 57 which requires that containment
penetrations of this type have a single isolation valve outside containment
capable of ren.ote manual isolation, the inspector reviewed the licensee's
FSAR commitments on this matter.
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Paragraph 5.2.3.5, Primary Containment Isolation, on page 5.2-9 of
Supplement 5 to the FSAR states in part, " Valves on lines that penetrate
the primary containment but do not communicate with the reactor vessel,
with the primary containment free space, or with the environs require
only one valve which closes automatically by process action (i.e., reverse
flow) or by remote manual operation from the control room." Page 5.2-10
of Supplement 5 further states, " Lines, such as those of the Reactor
Building Closed Loop Cooling Water System, which do not connect to the
Reactor Coolant Pressure Boundary or open into the primary containment
air space are provided with at least one a-c powered valve on the effluent
line and a check valve on the influent line."
Paragraph 7.3.4.3, Physical Arrangement, on pages 73-75 of Supplement 13
states in part, " Process lines that penetrate the primary containment but
do not communicate directly with the reactor vessel, the primary containment
free space or the environs have at least one Group C isolation valve located
outside the primary containment which may close either by process action
(reverse flow) or by remote manual operation.
The failure to provide isolation valves capable of remote manual operation
from the control room on the Reactor Building Closed Loop Cooling Water
System effluent lines from the containment is considered to be a deviation
from the 11~see's commitments to the NRC in the FSAR (333/81-07-01).
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7.
Replacement of G Safety Relief Valve (SRV)
After reviewing the licensee's response to IE Bulletin 80-25, the inspector
asked the licensee why the response did not address the replacement of G SRV
which occurred after it failed to lift in response to a manual open signal
following a scram on January 17, 1981
The licensee stated that this was not
necessary since he determined that the failure was caused by the excessive
use of Loc-tite on the soltnoid assembly as described in IE Inspection Report
50-333/81-02.
In order to verify that there were no other contributors to
the failure of G SRV the inspector reviewed work request package no. 12301
associated with the failure of the G SRV. During this review the inspector
determined that the licensee had removed SRV serial no.1012 set at 1140
psig and installed SRV serial no.1013 set at 1090 psig. Work Tracking Form
(WTF) No. 4 and Quality Control Inspection Report (QCIR) No. F 81-0021,
step 2.6.5 clearly indicated that this had been done. However, step 2.F.2 of
QCIR F 81-0021 indicated that the required setpoint for the G SRV was 1140
psig. Although the QCIR gave no indication of the reason for this discrepancy
the Quality Control Supervisor stated that it was his understanding that the
discrepancy had been reviewed and approved by the Plant Operations Review
Committee (PORC). The inspector was unable to fiad any reference to this
in the 1981 PORC minutes.
Paragraph 6.3.(E)4 of Technical Specification
states that it is a responsibility of the PORC to " Review proposed changes
or modifications to plant systems or equipment that affect nuclear safety."
Failure to review the G SRV setpoint change is an item of noncompliance.
(333/81-07-02).
The inspector reviewed the Target Rock Quality Control Data for SRV's with
serial no's.1012 and 1013 and determined that their setpoints were 1140
psig and 1090 psig respectively.
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Paragraph 2.2.B of Technical Specifications states that " Reactor Coolant
System safety / relief valve nominal settings shall be as follows:
Safety / Relief Valves
2 valves at 1090 psig
2 valves at 1105 psig
7 valves at 1140 psig
The allowable setpoint error for each safety / relief valve shall be i 1
percent." By replacing G SRV which had been set at 1140 psig with an
SRV set at 1090 psig, the licensee was no longer in compliance with the
combination required by this specified Limiting Safety System setting.
In subsequent discussions the licensee stated that they considered that
this change was safe because the lower setpoint was more conservative.
Since the licensee had purchased only one spare SRV they chose the lowest
pressure setting under the impression that it could be used conservatively
in plact of a valve with any of the three settings.
Consequently, the SRV
was replaced without any formal safety evaluation. A review of the safety
evaluation for Amendment 43 to the license indicated in paragraph 4 that
the specified combination of SRV setpoints "will assure that the analysis
of the containment structure for the effects of multiple consecutive relief
valve actuations satisfies the structural acceptance criteria set forth
in the Mark I Short Term Program." 10CFR50.59 (a) (1) states in part,
"The holder of a license authorizing operation of a production or utilization
facility may (i) make changes in the facility as described in the safety
analysis report, ... without prior Commission approval unless the proposed
change, test or experiment involves a change in the technical specifications
incorporated in the license or an unreviewed safety question." Based on
the discussion above, it appears that the change in the setpoint for G SRV
involved a change in the_ technical specifications. This is an item of
noncompliance (333/81-07-03).
Although the licensee stated that the change in setpoint of G SRV was
discussed in meetings identified as outage or PORC or department head
meetings, there is no written record of these discussions. Licensee
Quality Control personnel stated that these undocumented discussions
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described above were the basis for accepting the change in G SRV setpoint
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without question. They also did not document this basis on QCIR F1-81-0021.
10CFR50, Appendix B, Criterion XVI, states in part, "The identification of
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the significant condition adverse to quality, the cause of the condition,
and the corrective action taken shall be documented and reported to
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appropriate levels of management." The Quality Assurance Program, Section
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16, paragraph 2.5, states in part, " Records shall be maintained to show
objective evidence that when conditions adverse to quality have been
identified, action has been taken to correct the existing conditions ...
These records shall document the instructions for corrective action and
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the verification that corrective measures have been satisfactorily
accomplished." Quality Assurance Procedure 10.1 states in part:
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"6.7 If a deficiency is found. anytime during an activity, the QC
inspector shall fill out a Deficiency and Corrective Action
Report and submit it to the QCS or his designee for approval
and processing...
the Deficiency and Corrective Action Report
shall be referenced in the applicable QCIR.
6.8 When a process on a safety-related system fails to meet established
criteria due to noncompliance with specifications, procedures ~or
drawings,-unsatisfactory workmanship or deviation from cperational
standards, the QC inspector shall immediately notify the QCS or
his designee.
6.9 The QCS or his designee shall notify the supervisor responsible for
the activity being performed.
If the deficiency cannot be resolved
at this level the SQAE or his designee shall initiate stop work action...."
Failure.to initiate a Deficiency and Corrective Action Report and failure
of the Quality Control Supervisor to_ document his basis for accepting
this condition adverse to quality on QCIR No. F81-0021 is an item of
noncompliance (333/81-07-04).
In addition, the licensee maintenance supervisor stated that the undocumented
discussions discussed above were the basis for his conclusion which he
documented on WTF No. 4 that the change in G SRV setpoint was not a
modification and therefore required no safety evaluation.
After discussions between the inspector, NRC IE Region I Management, and
the Licensee en March 25, 1981, the Licensee' perfonned a safety evaluation
of the change in G SRV setpoint and submitted a proposed change in the
technical specification SRV setpoint combination.
Based on the completion
status of torus modifications, the Licensee action and NRC NRR concurrence,
NRC IE Management concluded that continued operation of the facility was.
justified.
8.
Control Room Observations
a.
Using a plant specific checklist, the inspectors verified selected plant :
parameters and equipment availability to ensure compliance with the
limiting conditions of operations of the plant Technical Specifications.
Items checked included:
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Power distribution limits
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Availability and proper valve lineup of ESF systen;s
Availability and proper alignment of onsite and offsite emergency
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power sources
Reactor Control panel indications
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Primary Containment temperature and pressure
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Drywell to suppression chamber differential pressure-
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Standby Liquid Control-Tank level and concentration
Stack monitor recorder traces
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b.
The inspectors directly observed the following plant operations to
ensure adherence to-approved procedures:
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Routine power operations-
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Issuance _of RWP's and Work Request / Event / Deficiency Forms
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Surveillance Tests
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Maintenance Activities
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c.
Selected lit annunciators were discussed with control room operators
to verify that the reasons for them were understood and corrective
action, if required, was being taken.
The inspector had discussions with the licensee on reducing the number
of lit annunciators in the control room. On a day to day basis, there
are approximately twenty lit annunciators in the control room.
Some of
these alarms are normal for the. existing plant . conditions and therefore,
provide little information or have no naaning. Although the licensee
has shown some improvement in this area, the inspector will continue to
review and evaluate the licensee's efforts during_ future inspections.
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Shift turnovers were observed weekly to ensure proper control room-
and. shift manning on both day and back shifts. Shift turnover checklists
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and log review by the oncoming and offgoing shifts were also observed
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by,the inspector.
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Shift Logs and Operating Records
(1) Selected shift logs and operating records were reviewed to:
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Obtain inf'onnation on plarit problems and operations
Detect changes and trends in performance
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Detect possible conflicts with Technical -Specifications
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or regulatory requirements
Determine that records are being maintained and reviewed
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as required
Assess the effectiveness of the communications provided
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by the logs
(2) The following logs and records were reviewed:
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Shift Supervisor Log
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Nuclear Control Operator I.og
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Night Orders
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Shift Turnover Check Sheet
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Protective Tag Record Log
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Daily Instrument Checks.
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Daily Core Surveillance Checks
Liquid Radwaste Discharge Log
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Gaseous and Particulate Sample Logs
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Weekly Chemistry Status Log
No items of noncompliance were identified.
9.
Plant Tours
.(a) During the inspection period, the inspector made observations and
conducted tours of plant areas-including '.he following:
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Relay Room
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Reactor Building
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Turbine Building-
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Diesel Generator Rooms
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Electric Bays
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Pumphouse - Screenwell
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Standby Gas Treatment Building
Battery Rooms
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Radwaste Building
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Stack
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Cable Spreading Room
Refuel Floor
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Crescent rooms
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Torus Room
Cable Tunnel
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Drywell Entrance Area
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(b) During the plant tours the inspector-conducted a visual inspection of
selected piping between containment and the isolation valves for-
leakage or leakage paths. This included verification that manual
valves were shut, capped and locked when required and that motor
operated or air operated valves were not mechanically blocked.
Other items verified durint the plant tours included:
Proper completion and use of selected radiation work permits
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Proper use of protectivt. clcthing and respirators
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Proper personnel monitoring practices
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Proper control of ignition sources and flammable material
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Equipment tag outs in conformance with controls for removal of
equipment from service
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Normal security practices are being followed
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Plant housekeeping and cleanliness practices are in conformance
with approved licensee programs
No items of noncompliance were identified.
10. Surveillance Observations
The inspector observed portions of the surveillance procedures listed below
to verify that the test instrumentation was properly calibrated, the
redundant system or component was available for service, approved procedures-
were used, and the work was perfonned by qualified personnel.
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F-ST 34B, Reactor Building Logic System,-Functional Test, Revision 2,
dated' February 28, 1980, conducted on March 5, 1981
F-ST-4C, HPCI Pump Operability Test, Revision 7, dated March 11, 1980,
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conducted on March 13, 1981
F-ISP-77, Reactor Shroud Level Calibration, Revision 8, dated July 1979,
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conducted on March 31, 1981
No items of noncompliance were identified.
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11. Maintenance Observations
The inspector observed portions of the maintenance activities listed below
to verify that the redundant train was available for service, approved
procedures were used, and the work was performed by qualified personnel.
WR 11-821, Repair HPCI Steam Trap T-3 and RCIC Steam Trip T-6 performed
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on March 24, 1981
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WR 03-8907, Replacement of Select Switch For Rod 2603 performed
March 31, 1981
The inspector determined that the HPCI and Pfic r/:tsm:, were capable of
performing their intended functions in the intended manner while these
traps were removed from service for repairs. However, the inspector
questioned the licensee's basis for classifying them as QA Category II.
Licensee QC Personnel produced system equipment listed with a handwritten
column identifying the QA classification and system drawings with
handuritten markings identifying the QA classification bourbries.
In addition, they produced component data sheets prepared by General
Physics Corporation identifying the QA classification. However, the
equipment list for the HPCI and RCIC system did not list the traps in
question and the boundary markings on the system drawing were unclear.
Since the List of Safety-Related Structures, Systems and Components
in QAP2.1, Quality Assurance Program Scope, Revision 5, dated March 28,
1980 indicates that the HPCI and RCIC systems are safety-related and
the equipment list does not specify othemise for the traps in question,
it appears that the traps should have been classified as QA Category I.
In addition, paragraph 5.5.2 of QAP 2.1 requires that technical reviews
using the Equipment List and the original specification be used to determine
the classification of components in safety-related structures and systems.
The licensee's practice of classifying components in safety-related systems
and of documenting this classification is unresolved pending further review
by the inspector (333/81-07-07).
12. Unresolved Items
Unresolved items are~ matters about which more information is required in
order to ascertain whether they are acceptable items, items of noncompliance,
or deviations. The unresolved item identified during this inspection is
discussed in paragraph 11.
13. Exit Interview
At periodic intervals during the course of this inspection, meetings were
held with senior facility management to discuss inspection scope end findings.
On March 17, 1981, and April 6, 1981, the inspectors met with licensee
representatives (denoted in paragraph 1) and summarized the scope and findings
of the inspection as they are detailed in this report. During the latter
meeting the unresolved item was discussed.