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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-333/85-13,including Status of Actions in Response to Insp Rept 50-333/82-24. Continued Tracking of All Corrective Actions Requested
	ML20137U699
Person / Time
Site:	FitzPatrick
Issue date:	11/25/1985
From:	Ebneter S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Radford Converse; POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
	NUDOCS 8512090377
	Download: ML20137U699 (2)
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NOV 2 5 1985

Docket No. 50-333

,

Power Authority of the State of New York

James A. FitzPatrick Nuclear Power Plant

ATTN: Mr. Radford J. Converse

Resident Manager

P. O. Box 41

Lycoming, New York 13093

Gentlemen:

Subject:

Inspection No. 50-333/85-13

This refers to your letker dated October 1,1985, in response to our letter

dated August 14, 1985.

Thank you for informing of the status of the actions you have initiated in

response to the assessment conducted during NRC Inspection No. 50-333/82-24.

We found this status generally acceptable and responsive to our concerns.

While you have completed a majority of the actions associated with (1) Compre-

hensive Planned Maintenance Program, (2) Review of Records in the Vault for

Retention, (3) Indoctrination and Training Program Development for Technical

Services Personnel and (4) Qualification Standards for Maintenance Personnel,

we notice that these actions will not be fully completed until 1986 or there-

after. We expect that you would track and complete these actions as stated.

Should it become apparent that any of these actions cannot be completed as

stated, please inform us immediately of (1) the reasons for not completing

these actions as stated, (2) detailed milestones for completion of the actions

,

and (3) management controls established to complete future quality affecting

activities in a timely and an acceptable manner.

Your cooperation with us is appreciated.

.

Sincerely,

9risinal 51sne W:

A J[!

4 Stewart D. Ebneter, Director

Division of Reactor Safety

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Power Authority of the

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cc:

L. W. Sinclair, President

J. P. Bayne, First Executive Vice President and Chief Operations Officer

A. Klausmann, Vice President - Quality Assurance and Reliability

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R. L. Patch, Quality Assurance Superintendent

George M. Wilverding, Chairman, Safety Review Committee

Gerald C. Goldstein, Assistant General Counsel

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NRC Licensing Project Manager

De'pt. of Public Service, State of New York

Public Document Room (PDR)

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Local Public Document Room (LPDR)

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Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of New York

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Region I Docket Room (with concurrences)

Management Assistant, DRMA

Section Chief, DRP

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4# Authority

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October 1, 1985

JAFP 85-0781

Mr. Stewart D. Ebneter, Director

Division of Reactor Safety

U. S. Nuclear Regulatory Commission

Region i

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631 Park Avenue

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King of Prussia, PA 19406

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Subject :

James A. FitzPatrick Nuclear Power Plant

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Docket No. 50-333

Inspection Report No. 50-333/85-13

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Reference:

NRC Operational Assessment Team inspection

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(No. 50-333/82-24)

,

Dear Sir:

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In response to your request in the subject inspection, the Authority

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is providing a status of the actions initiated in response to

i

concerns identified in the referenced NRC Assessment. As noted in

Item 4.4 of Inspection 85-13, a Quality Assurance Department Audit

was performed to review each action item. This audit (Surveillance

Audit No. 1029, dated July 22, 1985) provided a status of all

responses to concerns identified in the referenced inspection and

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,

provided management with an updated status and recommendations to

complete any open items. A copy of the QA Audit was also provided

,

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to the NRC Resident inspector.

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Attachment I of this letter shows the current status of all items

which were identified in Appendix B of the referenced inspection.

Detailed observations which were utilized to derive the status shown

in Attachment I are contained in QA Surveillance Audit No. 1029

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In addition to items specifically identified in Appendix B of the

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referenced inspection, this response also addresses the status of two

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other concerns addressed in open item 85-13-02 of the subject

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Inspection. These items were also addressed in QA Surveillance Audit

No. 1029

The present status of these items is addressed in

Attachment 11 of this letter.

Very truly yours,

tw

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RADFORD J. CONVERSE

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Mr. Stewart D. Ebneter, Director

October 1, 1985

-

_U. S. Nuclear Regulatory Commission

JAFP 85-0781

From:

Radford J. Converse

Page 2 of 2

Subject: -Inspection Report 50-333/85-13

Distribution:

J. C. Brons: NYPA: WPO

R. A. Burns: NYPA: WP0

R. E. Beedle: NYPA: WP0

J. Gray: NYPA: WP0

G. Wilverding: NYPA: WPO

A. Klausmann: NYPA: WPO

W. Fernandez: NYPA: JAF

R. Patch: NYPA: JAF

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NRC Resident inspector

NRCI 85-13 File

Document Control Center

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CERTIFIED NAll - RETURN RECEIPT REQUESTED

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ATTACHMENT l

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INSPECTION

NO.

FINDING

ITEM

STATUS

1

A.I.a

Revise D&A procedures 3.11

Complete

and 3.18.

2

A.I.b

Provide design verification

Complete

for modification F1-31-2G.

3

A.I b

Issue new set of Revision 1

Conplete

4

calculations as required

by EDP-2.

4

A.I.b

Provide training to PE

Complete

section on 10 CFR 50 App. B

and ANSI 45.2.11.

5Property "ANSI code" (as page type) with input value "ANSI 45.2.11.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.

A.I.c

Provide correct design

Complete

verification for modification

<

F1-80-20.

6

A.I.d

Provide forms and procedures

Complete

'

for recording phone calls

and meetings.

7

A.1.d

issue procedures to cover

Complete

. activities of Project

'

Engineering - BWR.

8

B

Review and mark up NuAPs

Complete

and NGPs.

9

B

Issue final revised NuAPs,

Complete

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NGPs and new procedures.

10

C.I.a

Write Maintenance Department

Closed in

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procedures and policies, and

Inspeccion

issue administrative manual.

84-08.

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11

C.I.b

Complete Maintenance

Closed in

Department hiring to fill

Inspection

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open positions.

84-08.

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12

C.I.c

issue and implement ITP

Closed in

.

procedure for training of

Inspection

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maintenance contractor

84-08.

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personnel.

13

C.I.d

Hire Contract Services Engr.

Closed in

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Inspection

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84-08.

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14

C.2.a

Obtain or create computerized

Complete

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PM scheduling program.

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ATTACHMENT I

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INSPECTION

NO.

FINDING

ITEM

STATUS

15

C.2.b

Develop a procedure to

Complete

administer PM program.

16

C.2.c

Incorporate plant components

See Response

into PM program.

Update A.

17

C.2.d

Assure that 40% of Maintenance

See Response

activities are preventive.

Update A.

18

D.I.a

Supplement present site QA

Complete

audit program.

19

D.I.b

Coordinate audit of site fire

Complete

protection activities.

20

D.I.b

Expand utilization of

Complete

technical expertise from

other organizations.

21

D.2

Revise QA procedures manual.

Complete

22

D.2

Develop and implement QA

Complete

procedures for Design Control .

23

D.3

Develop internal audit

Complete

schedule.

24

E.1, E.2

Revise plant and HQ

Complete

administrative records

management procedures.

25

E.2

Complete records retention

Complete

index for HQ and plant.

26

E.2

issue final version of nuclear

Complete

records retention schedule.

27

E.3

Complete archival records

Complete

vault.

28

E.3

Complete archival records

See Response

retention program.

Update B.

29

F.1

Develop lesson plan for

See Response

Tech. Services personnel.

Update C.

30

F.1

Revise l&T procedures to

Closed in

meet INP0 guidelines.

Inspection

84-12.

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ATTACHMENT I

INSPECTION

NO.

FINDING

ITEM

STATUS

31

F.1

Revise training procedure

Closed in

for HQ personnel .

Inspection

84-12.

32

F.1

Complete qualification

See Response

standards and cards for

Update D.

maintenance personnel.

33

F.1

Commence skill and

Closed in

plant-specific training.

Inspection

84-12.

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ATTACHMENT I

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RESPONSE UPDATE - A

4

As noted in C.2.a and C.2.b of this attachment, a computerized P.M.

Scheduling Program has been developed and an administrative P.M.

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program procedure has been approved and implemented,

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in 1984 a Task Force, including site and corporate personnel, was

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constituted to develop the basis for a comprehensive planned

maintenance program. This effort was completed and a short term

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and long term p;an has been developed for implementation. Currently,

plant procedures are being upgraded to provide detailed direction for

the maintenance of safety-related components.

Formalized preventive

maintenance is currently scheduled and being performed on safety-related

breakers, motor control centers, switchgear and safety-related

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limitorque operators which can be taken out of service during plant

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operation. A schedule for the maintenance of safety-related limitorques

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requiring an outage is being developed. When completed, an estimate of

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resources necessary to support that schedule will be made and action

taken to procuse these resources. A program and schedule for repacking

important safety-related valves is also being developed for completion

,

by the end of the year. The formalization of the lubrication program

!

will be completed by 1/31/86 for important plant equipment. The PM

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program will be expanded from this scope in accordance with our lo'ng

term plan and budgetary restraints.

l

A contract award to institute a computerized vibration monitoring

program has just recently been issued, and implementation is scheduled

throughout 1986,

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While the goals established in C.2.c and C.2.d have not been completely

met, the Authority believes that sufficient progress has been made to

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close out these i tems of Inspection 84-24.

i

RESPONSE UPDATE - B

The records storage facility has been complete and is in full operation.

However, at the present time, the records being maintained in the vault

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are being reviewed to determine which records can be purged and what

the proper retention schedule is for the remaining records. A contractor

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has been hired to assist in this effort.

i

,

RESPONSE UPDATE - C

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Formal training in the areas of design verification, technical review of

procurement documents, equipment qualification and other technical areas

has been provided. .The Authority, however, does recognize the need for

,

a structured-program which addresses the continuing training of Technical

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Services' Engineers and a JAF Indoctrination and Training Procedure for

Technical _ Services Department personnel (ITP-17) will be implemented by

January 1, 1986,

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RESPONSE UPDATE - D

Implementation of the last phase of the apprentice program will commence

by February, 1986. All phases with the exception of on-the-job training

are presently being implemented.

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ATTACHMENT ll

4

Concern:

NRC inspection 85-13, open item 85-13-02, states "In

response to another 0AT concern, the licensee provided a draft

revision to the Plant Standing Order (P50) No. 5 fci the NRC

review. This draft revision contained measures to provide better

on-site control for the drawings and records.

However, this draf t

was never formally issued."

Response:

Two plant procedures will be issued to replace PS0 No. 5

These procedures for Plant Drawing Control and for the Control of

Vendor Technical Manuals, will be issued by October 31, 1985

Concern:

Page 8 of Inspection 85-13, item 85-13-02 states:

The inspector verified the status of resolution for the drawing

revision back log reported in NRC Operational Assessment Team (OAT)

Inspection Report (No. 50-333/82-24). The IIsensee's corrective

action was to reduce the back log using a plan reported in JAFP

Letter 82-0869 dated August 6, 1982.

However, as of May 3,1985,

the licensee has completed less than sixty percent of the drawings

scheduled for update in 1984.

If the present trend continues, the

licensee will not be able to meet the 1985 schedule. This back log

is further increased by the 1985 outage, which required more than

three thousand drawings to be revised. The White Plains Office

Support to the drawing revision efforts appeared to have lost the

initial level of attention. Additional corporate management

attention is required to meet the drawing revision goal.

Response: A meeting was held on site between Design & Analysis,

Project Engineering and the Site Technical Services Department to

address the noted problem. The drawing opdate procedure has been

modified to remove delays and to reduce .'ime to update a revised

drawing.

The attached list represents the status of the Drawing Update

Program as of 8/31/85

A review of all modifications by the Site

Technical Services Department shows that as of 9/16/85, approximately

82% of all installed modifications have completed drawing updates.

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ATTACHMENT ll

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DRAWING UPDATE PROGRAM SCOPE

MODS WITH

DWG UPDATE

NO. OF

MODS SCHEDUL-

COMPLETED OR

DRAWINGS

NO. OF

ED FOR DWG.

VERIFIED AS

SCHEDULED

DRAWINGS

UPDATE

NOT INSTALLED

FOR UPDATE

COMPLETED

1983

130

1694

1984

70

1086

1985

35

25

724

480

TOTAL:

235

225

3504

3260

% Complete:

95%

% Complete:

93_t

ADDITIONAL WORK NOT IN ORIGINAL DRAWING UPDATE PROGRAM

MODS WITH

DWG UPDATE

NO. OF

MODS SCHEDUL-

COMPLETED OR

DRAWINGS

NO. OF

ED FOR DWG.

VERIFIED AS

SCHEDULED

DRAWINGS

UPDATE

NOT INSTALLED

FOR UPDATE

COMPLETED

1983

0

1984

27

82

1985

108

60

1439

754

TOTAL:

135

87

1521

836

MODS WITH

DWG. UPDATE

NO. OF

MODS SCHEDUL-

COMPLETED OR

DRAWINGS

NO. OF

ED FOR DWG.

VERIFIED AS

SCHEDULED

DRAWINGS

UPDATE

NOT INSTALLED

FOR UPDATE

~ COMPLETED

GRAND

TOTALS:

370

312

5025

4096

% Complete:

84%

% Complete:

81%

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ML20137U699

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