IR 05000333/1985098
| ML20236D608 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/27/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236D594 | List: |
| References | |
| 50-333-85-98, NUDOCS 8707300547 | |
| Download: ML20236D608 (51) | |
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ENCLOSURE 3 SALP BOARD REPORT U.S. NUCLEAR PEGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SALP REPORT 50-333/85-98 . NEW YORK POWER AUTHORITY JAMES A. FITZPATRICi' NUCLEAR POWER PLANT ASSESSMENT PERIOD: DECEMBER 1, 1985 - NOVEMBEP. 30, 1986 BOARD MEETING DATE, FEBRUARY 13, 1987 i 8707300547 870730~~ PDR ADOCK 05000333 G PDR _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - - _ _ - _ _ _ _ - _ _ _ - _ _ _ _ _ .
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SUMMARY OF RESULTS Overall Facility Evaluation Management attention has resulted in noticeable improvement through-out the facility and in particular the areas of plant operations and assurance of quality. Although the functional area ratings have remained the same, this doer, not reflect the general, overell improve-ment observed in site activities. The number of operational events has significantly decreased during this assessment period with two reactor trips from power. Neither was caused by operator erro Plant management, and in particular the Resident Manager and Quality Assurance Superintendent, have demonstrated a philosophy oriented toward nuclear safety and have been influential _in improving the overall plant performance. The New York Power Authority (NYPA) has been effective in fostering an improved attitude towards safety, accountability, and pride in workmanship. Plant personnel now dis-play a greater degree of attention to detail in day-to-day activities. With the exceptions discussed in the licensing area, plant management is cooperative and responsive to NRC concerns and initiative Although an overall improving trend was evident, several areas previ-ously noted as deficient warrant additional management attentio These include, procedural adherence, follow-up of commitments, and instilling a questioning attitude within the organizatio I
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B. Facility Performance CATEGORY CATEGORY LAST THIS RECENT FUNCTIONAL AREA PERIOD * PERIOD ** TREND Plant Operations 2 2 Improving Radiological Controls 2 2 Maintenance 2 2 Surveillance 2 2 Fire Protection 1 N/A Emergency Preparedness 1 1 Security & Safeguards 1 1 Outage Management and 2 2 Engineering Support Licensing Activities 2 2 Declining 10. Training and Qualification 2 2 Effectiveness 11. Assurance af Quality 2 2 Improving
* July 1, 1984 to November 30, 1985 (17 months) ** December 1, 1985 to November 30, 1986 (12 months)
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. j IV. PERFORMANCE ANALYSIS ,
A, Plant Operations (773 Hours, 40.3%) i Analysis During the previous assessment period, this functional area was j rated as Category 2 with an overall decline in performance. A I number of personnel errors and inconsistent review of opera-
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l tional events and root cause analysis were noted as deficiencies.- During this assessment period, the plant operators were deter- l mined to be knowledgeable and conducted themselves in a profes- ., sional manner. They exhibit a positive attitude toward-
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operating the plant in a safe manner. During operational events and routine evolution, the operators' demonstrated their ability to respond quickly and efficiently. Also, their ability to con-duct three normal reactor shutdowns and five reactor startups in-a controlled manner without causing a reactor trip is commend - able. Several isolated cases occurred where uperators did not fully investigate or were.not aware of off-normal condition These included annunciators, control room ventilation fan operability, tripping of overloads on a motor operated valve, and systems affected by a level switch failure. Although these conditions were of minor safety significance, continued emphasis should be placed on understanding and identifying off-normal condition One noteworthy improvement.during this assessment period was the absence of a significant number of personnel errors. Two plant , trips occurred from power and neither was directly attributed to personnel error. One of r.ine trips which took place while the plant was shut down was. attributed to operator error; however, this occurred while the operator was taking necessary actions to isolate a leak in the feedwater system while in the process of lowering reactor vessel leve In addition, no plant transient or equipment inoperability occurred as a result of personnel erro As a result of the unusually large number of trips which oc-curred during the previous assessment period, a Scram Review Team L conducted a comprehensive evaluation of the trips and the cir-cumstances surrounding.them. As a result of that review, about 66 recommendations were given to improve overall' plant performance and reduce the number of trips. These recommenda- 1 tions, their resolution, and their implementation are tracked by , the licensee using a formal system. Although no single signifi- )' cant root cause existed for the reactor trips,'each recommenda-tion improved the way plant managgment conducts operation In l _-- - _ .____--__--____ _.___ _ _ _ _ - j
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the short term, the management' continues to work to instill a
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v j positive attitude and pride in workmanship among its employees' ' which has resulted in a reduction of personnel errors and the._ ability to correct deficiencies quickly and correctly. 'Further-assessment of the long term recommendations is require Administrative controls, procedures and procedural adherence.are generally strong, but minor exceptions have been' noted that re- 1 quire plant management attention. Exceptions ' include not comply-ing with.the procedure for securing the high pressure coolant injection turbine during surveillance testing, using data sheets to perform testing instead of the procedure,' and skipping steps of a procedure during testing. These examples are not of majo ; significance and are considered isolated events. Plant manage- 1 ment is aware of this concern and is. stressing improvement in this are i s; Plant management continues to stress professionalism and to improve the control room environment, as noted by the removal of- j the Secondary Alarm Station from the control room, installation ; of curtains to limit traffic in the control room, and continued improvements in establi3hing an effective work control cente In addition, plant management has placed emphasis on reducing tne . number of continuously lighted annunciators. Although plant , management has made progress in this area, continued attention ' is warranted. The Operations Superintendent conducts weekly meetings with each shift to review events and stress the need for improvements. Additional improvements noted were the in- ] creased use of formal critiques to review events and a more com- J prehensive post-trip review procedure. Senior plant management takes an active role in the plant operations area as indicated by daily control room reviews, which ir.clude log reviews, panel walkdowns and discussions with operators. Plant management
- stresses safety and emphasizes a methodical approach to plant evolutions. There is consistent evidence of a commitment to plant betterment and timely, effective corrective action Corrective actions for a violation for a failure to comply with 1 10 CFR 50.72 reporting retirements did not preyent a second i violation. The second instance occurred nine months after the j first occurrence. Plant management failed to take adequate j measures to prevent recurrence, in addition, the licensee had i
, not implemented-all of the corrective actions committed to fol- j lowing the first occurrence, even though they had exceeded the ' commitment date by several months. At the time of the secord instance, a formal tracking program was in the process of being i implemented. The tracking program follows items on which action is scheduled and highlights those which are commitment Although improvements were noted in the review of operational j ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
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l' [ events and root cause analysis, some deficiencies have been not-- ,. ed.as discussed in Section C, Maintenance. A marked improvement.
I has been noted in the FitzPatrick Licensee Event Report (LER) submittal ] The LERs presented a clear understanding of the event, its j cause, and corrective action taken or committed to be take Further improvement can still be made by consistently discussing the safety implication of-the event and identifying the manufac- ) turer and model of failed component l Housekeeping at the' facility has improved. Senior plant manage-
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i ment makes weekly tours of,the freility to review cleanliness j conditions and continues to emphesize plant cleanliness. Al-though cleanliness has generally been good, occasional lapses . have occurred in material storage, such as ladders 'left stand- l ing gas bottles improperly stored, and small items adrif j
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In summary, plant' operations is a strength as indicated by the' high unit availability and significant improvements. Plant nanagement attention has resulted in a significant reduction in operator related event . Conclusion Rating: 2 Trend: Improving 3. Board Recommendations None j i
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B. Radiological Controls (392' Hours,20.4%) Analysis-During the previous SALP period this area was rated as Category Weaknesse.s included delayed responses to NRC findings and lack of management attention relative to conforming to radiation protection procedures. This functional. area will be discussed in terms of radiological protection, radioactive waste transpor-- ! tation, and effluent monitoring and control. There were six inspections conducted by radiation specialists in this area, two in. radiological protection, one in radioactive waste transporta - 1 tion, and three in effluent monitoring and control. The resi-l dent inspector also monitored the implementation of the ]e radiation protection progra ]r RADIOLOGICAL PROTECTION fq t i The licensee showed consistent perforarance relative to the pre- '
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vious assessment period, with no major weakness identified and no major program improvements. Several minor instances of per- ; sonnel failing to follow procedures occurred during this assess-ment period as in the previous assessment perio ! The Radiological Protection Program is staffed with qualified personnel. However, it should be noted that the Health Physics
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i General Supervisor left FitzPartick in the last month of the I assessment period and that the station Radiation Protection 1 Manager has been temporarily acting in this position. When a new General Supervisor is selected, increased management atten-tion will be needed to assure a smooth transitio The ALARA program is strong and effective with good management support and represents a program strength. ALARA reviews for planned work, completed work, and continuous evaluation of work in progress are good. During the course of several inspections in this rating period, the ALARA program was examined and found to be of consistently high qualit The licensee's ALARA person-rem goal for the site.was 600 per-son-rem for 1986, a non-refueling year, based on a calculated exposure estimate of 575 person-rem. ,With the accumulated ex-posure at the end of the assessment period, the exposure for 1986 was not expected to exceed 400 person-rem. While this ex-posure reflects well on the ALARA program, it shows the goal set for the 1986 calendar year was not ambitiou The program for external and internal exposure control reflects an adequate commitment to' safet In this.SALP assessment peri-
od, as in the previous assessment period,' no overexposure oc-curred and no individuals received an uptake that required __ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -
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o assessment or any further actions. Radiation Work Permits were effectively used to control work within the Restricted Area. As 1 in past years, NYPA is implementing an adequate whole body counting progra However, there are areas where improvement is necessary_ in the internal and external exposure control program. . Minor problems include failure to follow procedures and insufficient middle ! management attention to. detail to provide oversight in the area i of external exposure contro Instances of failure to follow ! procedures included failure to maintain survey instrument cali-bration' records and failure to perform alpha surveys on arriving-new fuel shipments. Additional. middle management attention to ; the supervision and assessment of day-to-day radiological con- l trols activities is needed to improve self-identification and ; correction of program weaknesse J The respiratory protection program is of state-of-the-art quality. The licensee has placed a high priority on this pro-gram as evidenced by effective respirator selection, issue, use, and maintenance practices.
' Radiological survey instrument controls were wea Specifical-l ly, the storage, maintenance, and calibration facilities for { portable survey instruments needed improvement. Furthermore, , survey equipment availability during the October 1986 outage was ' limited, which indicated poor control of equipment inventor Personnel frisking practices were inferior to industry stan- 1 l dards, in that high background count rates potentially precluded effective detection of personnel contamination; Compounding this problem were poor frisking techniques by station personne Regarding both the survey instrument control and frisking prob-lems, middle management within the radiological controls group appeared unaware of these problems until informed by the NRC, despite the seemingly obvious nature of the problems. It was unclear whether the lack of awareness was due to the failure to personally inspect field activities, poor communications with personnel in the field, or low standards of we i l Corporate management is frequently involved in the activities j providing guidance and consultation to FitzPatrick Station man-agemen For example, Corporate and Standard Audits were per-formed of the Radiation Protection Program. However, most ] Standard Audits, while timely, were superficial and of limited { scope due to a lack of audit personnel qualified or trained in I health physics and chemistry. This weakness was identified by corporate management late in the SALP assessment period. Corpo - ; rate management indicated that their audit personnel, qualified ' i
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in HP and Chemistry, would be made available to augment the Standard Audit progra , RADI0 ACTIVE WASTE-TRANSPORTATION An inspection of radioactive waste transportation found this area to be generally good. While a concern was identified-regarding the circumvention of the receipt inspection system for transport packages, the corrective actions were timely and thorough. In addition, when concerns were. identified regarding the adequacy and effectiveness of the audit program for trans-port packages, QA/QC involvement in this area was promptly in-crease EFFLUENT MONITORING AND CONTROL During the previous assessment period the Radiological Effluent Technical Specifications (RETS) were implemented. Inspections during this period found no significant problems in RETS imple-' ; mentation, and the licensee was effective in correcting the , minor problems which occurred. An inspection of the environ-l mental monitoring program found a problem with implementation of a calibration procedure. However, this problem appeared to be an isolated instance due to a lack of attention to detail rather than a programmatic breakdown. With this exception, the erai ronmental monitoring program was effectively implemented with respect to Technical Specification requirements for sampling , ' frequencies, types of measurements, analytical sensitivity, and reporting schedules, i An inspection of the nonradiological chemistry program found it to be generally effective. Minor deficiencies were identified l in several of the chemical analysis procedures, but the licensee response was prompt and thorough. With a few exceptions, all of ' the analyses of chemical standards agreed with the analyses of ; the split samples. The reasons for the few disagreements were determined and resolve An inspection of effluent and process radiation monitor calibra-tion and surveillance testing,.and in place filter testing found these areas to be acceptabl , Summary l The established programs for radiological protection,.radioac-tive waste transportation, environmental monitoring, and nonradiological chemistry are sound and effective. The day-to-day implementation of these programs must be managed and super-vised to achieve the results of which the programs are capable and to prevent the minor problems' experienced during this peri-od. A.more probing and effective quality assurance review of these programs would aid in assuring proper implementatio !
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2. Conclusion Rating: Category 2 3. Board Recommendations . I None i I
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C. Ma'intenance (159 Hours, 8.3%)- .
:I Analysis
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During the previous assesstaent period, this functional area was l{. rated as Category 2. Although FitzPatrick management. continued
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to implement several improvement programs, progress was slow and '{" ) had loosely defined completion schedules. -Also, several per- ! sonnel errors resulted in reactor trips or plant shutdown During this period, this area was frequently reviewed by the resident inspecto In addition, specialist inspections re- i J viewed the maintenance of the recirculation pump trip system an l{ the equipment qualification of Limitorque valve operators. .No
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l programmatic inspection of maintenance was conducted dur'ing th .; I current assessment perio i Du' ring this assessment period, plant management became more ac-tively involved in implement'ng the improvement programs,-and progress was generally good. A program to' control vendor tech-- nical manuals was begun by developing a computerized index and reviewing the manuals maintained by each department. However, there have been delays in implementing the program in the Main-- i tenance Departmen Implementation of the Planned Maintenance Program continued with some minor delays. The development of ] l the Master Equipment List progressed with component classifica-' ' tion Improvements were made in tool control, and a vibration analysis test program bega .l Improvements were noted in the maintenance area during this pe-riod. Most noteworthy was the absence of a significant number of personnel errors. Maintenance personnel were well qualified and conscientious, and exhibited a proper safety perspective concerning their potential impact on plant operations. The ad-ministrative control of preventive and corrective maintenance work was good. Based.on this, it appeared that maintenance training programs were effective. Also, personnel turnover rate i was low. Supervisory involvement was evident and effective in the timely resolution of equipment problem During this assessment period, nine reactor trips occurred while the plant was shutdown with all rods fully' inserted. Six of these trips were caused by spiking of.the "G" IRM during under vessel work. A broken connector was later found on the IRM, and it was determined that minimal contact by maintenance personnel < caused the spike. Based on the nature of under-vessel work and ; an abnormal condition of one channel of RPS deenergized for ' other modifications, these trips are of minimal concern, The three remaining trips while shut down were unrelated and are discussed in Table 6.
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Regarding the Recirculation Pump Trip System, preventive mainte-nance was properly controlled and documented, and corrective maintenance was timely and adequate. In addition, the engineers and supervisors were technically competent and knowledgeable of past system problems. Management involvement was evident in the effort to modify a failed breaker and to pursue modifications : for the same breakers in other application A concern was identified regarding examples of personnel not j following maintenance procedures. These involved not applying 4 j thread sealant during assembly of a pressure transmitter conduit ! connection as required by the technical manual, missing a step ! during assembly of a control rod drive mechanism, and incorrect torque setting for pressure transmitter mounting bolt The last two examples were identified by Quality Control personnel observing these activities. These are considered to be individ-ual errors and are not indicative of a widespread disregard for procedures. Although these examples are of minor safety signif-icance, plant management attention to prevent more significant problems is warrante The licensee has taken a more aggressive approach to correct . several recurring equipment problems, including the Low Pressure ! Coolant Injection Independent Power Supplies, the Containment ! Atmosphere Analyzer, and the transmitters in the Analog Trans-mitter Trip System. However, plant management failed to estab-lish the root cause of other problems such as the Main Steam Isolation Valve liniit switch failures, recirculation loop bypass valve packing leakage, and the Turbine Stop Valve Limit Switch failur Specifically, failure to establish the root cause of a limit switch failure on a Turbine Stop Valve subsequently contributed to a reactor trip during surveillance testing. The limit switch had malfunctioned numerous times in the six months prior to the ? trip but was not properly evaluated and repaire Following the ' determination that the limit switch was involved in the reactor trip, plant management conducted extensive testing to determine j the exact cause of the failure. However, maintenance managers neglected to review the past failures of the limit switch, which indicated that a change in the valve stroke was occurring. In addition, during the reactor startup following the trip, when maintenance managers identified that the valve stroke had ! changed, no detailed review of the cause of the stroke change was considered until several days after the startup. Subsequent inspection found that loose bolts had allowed the valve stroke to change. Apparently, the bolts became loose due to a failure to apply proper torqu The environmental qualification (EQ) program for Limitorque valve operators was generally effective. Management involvement
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I was evident by the number of management personnel who actively participated in the EQ program, the high degree of organization of EQ documents, and the prompt performance of EQ related activ- l itie Further evidence of commendable performance included the ' thorough response to NRC Information Notice 86-03, including a 100% inspection of Limitorque valve operators requiring EQ and the licensee's decision to upgrade the Limitorque valve control . wiring, even though qualification data was available for the
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i existing control wires. However, some implementation problems were identified within the general EQ program, which will be ; evaluated during the pending inspection of the plant EQ progra Overall, the plant maintenance program has improved from the i previous assessment period. The absence of significant per-sonnel errors and the proficiency in properly completing work is noteworthy. Continued emphasis should be placed on timely com-pletion of improvement programs, procedure compliance, and root cause analysis to prevent recurring problem .l 2. Conclusion J l Rating: 2 1 3. Board Recommendation 3s j None l _ _ - _ _ _ _ . - _ - _ _ _ _ - _ _ - _ _ _ _ - - - _ _ _ _ - . _ _ _ _ _ - _ - _ _
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D. Surveillance (194 Hours, 10.1's) Analysis-During the previous assessment period, this functional area was rated as Category 2, primarily due to repeated problems in es-tablishing an_ effective Inservice Testing-(IST) Progra During the current' assessment period, the surveillance, calibra-tion, and IST programs.were reviewed. The resident inspector also examined surveillance testing during the routine inspection progra The licensee improved-the IST Program by including all. required valves, rewriting procedures to include acceptable values, and assuring that the operators do a thorough review of data follow-ing the. tests. However, the previous SALP_ Report noted problems regarding the review of test data by operations and plant per-formance personnel. During this period, operations department reviews of the data were adequate and timely, but the subsequent review of the data by plant performance personnel was,.at times, excessively slow (up to several weeks). This review is relied upon to determine trends and notify Operations to increase test frequency when components exhibit undesirable trend Surveillance tests are performed by the responsible department, with the majority of testing completed by the following depart-ments: Instrument and Control, Operations, Maintenance, and Radiological and Environmental Services. Each department maintains its own system for scheduling, tracking and performing surveillance. The completed surveillance tests were well docu-monted utilizing detailed procedures, data forms ~, and acceptance ' criteria. Overall, personnel performing the tests were knowl-edgeable, responsible, and well trained. Procedure use and ad- , herence was good in general with exceptions noted in Section A, ) Operations. No plant trips or shutdowns were the direct result of testing error I However, three surveillance tests were either performed late or
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missed as follows: ,
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A monthly test of the ApRM flow bias network was missed for 3 l eight months when it was not placed on the schedule follow- ! ing a shutdown perio )
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A quarterly test of the diesel fire pump was performed 18 { days oeyond the grace period due to a lack of management 1 oversight of the maintenance department surveillance i progra '
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A chemistry sample during startup was~ about one hour late due to personnel error.
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l NYPA took prompt actions to strengthen its administrative re-quirements associated with the surveillance test program to pre-vent recurrence. No surveillance tests were missed in the last six months of the perio Although no surveillance tests were missed during the previous assessment period, there had been numerous missed surveillance tests in the period preceding i It appears that the recurring problem of missed surveillance tests is symptomatic of the unco-ordinated approach that the surveillance program has taken. The lack of an overall responsibility for surveillance testing be-yond the individual departments and the minimal coordination between departments appear to ham,ner the long term resolution of surveillance testing problem The NRC identified that not all safety-related instruments were being periodically calibrated, nor was there an adequate sur-veillance test to verify that they are functioning within the required ranges. The licensee immediately calibrated those instruments identified and was further evaluating the remaining safety-related instruments for periodic calibration. Also, the delayed implementation of calibration program improvemen,ts recommended by a 1983 QA appraisal reflected poorly on manage-ment's interest in implementation of a high quality progra ) Improvements were made in the storage and control of measuring and test equipment, including a computerized system for tracking the location, status, and restrictions regarding all measuring and test equipmen In summary, the surveillance test program'is adequate. One l strength noted was in the area of conduct of the surveillance ' tests, as evidenced by the lack of personnel errors during test-ing. However, increased management attention is warranted in the area of program administration and coordinatio . Conclusion ' Rating: 2 l
3. Board Recommendations None l
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E. Emergency Preparedness (110 Hours, 5.7%) Analysis During the previous assessment period this functional area was rated as Category 1. This assessment was based upon a good dem-onstration of emergency response capability during two annual exercises, responsiveness to weaknesses identified in these ex-ercises and a clear management commitment to the emergency pre-paredness progra The current assessment period included observation of one partial-scale exercise conducted in June 1986. The exercise i demonstrated a high degree of proficiency which appears to re- , sult from a strong training program. Emergency response person-nel are quite knowledgeable and dedicated. Only one minor deficiency was identified during the exercise. This exercise > showed improvement from the previous year's exercise, which had only minor discrepancie l The licensee staff is active in maintaining and improving the emergency response progra Program weaknesses are promptly identified and corrected. NYPA and others have taken the init-iative to jointly study the local effects of Lake Ontario on atmospheric dispersion. The information gained will help quan-tify the local lake effect and improve capabilities overall in protective action decision making for the central New York lake region. The licensee recently incorporated the use of a " Lag-rangian Puff" model for dose assessment.
l The emergency preparedness training and qualification program - continues to make a positive contribution to plant safety, com- ) mensurate with procedures and staffing which have been consis- ? tently goo The licensee has developed and maintains a good rapport with the I local government (Oswego County) and the State (New York) regard- l ing emergency preparedness. They met on a regular basis (quar-terly) to discuss, plan and address issues related to emergency response. Also, in a joint initiative with Niagara Mohawk Power Corp., NYPA plans to install a siren verification syste In summary, continued commitment to a high quality emergency preparedness program was demonstrated by excellent performance during the exercise, thorough preparation in procedures and training, and improvements in program and facilitie . Conclusion Rating: Category 1 _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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3. Board Recommendations None
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1 Security and Safeguards (140 Hours, 7.3%) 1, Analysis During this assessment period, only one physical security in-spection was conducted because the licensee's performance during the two previous assessment periods was rated as Category Routine resident inspections.of the security program were per-formed throughout the assessment period. One material control a and accounting inspection was conducte .] The licensee continued to review the effectiveness of the secu-rity program and the adequacy of related facilities during the " period. As a result, the licensee plans to move the security administrative offices ir.to'new office facilities and has al- ) ready moved the secondary alarm station (SAS) into new facili- ) ties that provide more space and efficiency of operatio Additionally, as a result of recommendations resulting from sur-veys of the security program performed by outside contractors, a , new computerized security system and new card readers were in- J stalled, along with the new search equipment that was installed h at the end of the last assessment period. The licensee's com-- I mitment to a high quality security program is. evident by the continued support, in terms of capital resources for program upgrades, and the continued excellent interface among security and other corporate and site function l The supervisory staff is well experienced and continued to dem- i onstrate their knowledge of and ability to meet NRC security performance objective The security training program is now managed by one full-time training instructor with assistance from several part-time in- ; structors who have expertise in specific areas. While this is a i reduction of one full-time instructor frou the previous assess-ment period, the assistance of the part-time instructors has compensated for the reduction and no adverse impact on the training program has thus far been apparent. The licensee has excellent training facilities that,.in addition to modern class-rooms and physical fitness facilities, include an indoor firing range. Contingency plan drills are conducted regularly as ' supplement to the training program. Critiques of the drills are ' conducted and documented, with feedback into the training pro-gram. This has proven to be a very effective training aid. The effectiveness of the training program is apparent by the lack of- : performance related. events during the assessment period, and this performance, as'well as the. appearance and morale of the security force, reflect favorably on both the training program and security managemen ! _ - - . _ - _ - _ _ _ _ _ _ _ _ - _ - _ _ _ - - _ _ _ _ - _ _ - - __
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Staffing of the security force appears to be adequate with occa-sional overtime being used to meet unforeseen operational need This use of overtime has had no adverse effects on the perfor-mance of the force. In preparation for an upcoming outage that has the potential for taxing the existing force, security man-agement developed and implemented a training program to qualify additional watch persons to supplement the force. This advance planning is characteristic of the licensee's security management and is further evidence of their desire to implement an effec-tive and high quality progra Security management is actively involved in the Region I Nuclear Security Organization and other organizations involved in nucle-ar power plant security. The licensee maintains an excellent relationship with law enforcement agencies and periodically in-vites key members of these agencies to the site for orientation in response procedures, plant layout and other matters involved with the protection of a nuclear power plant, and to discuss recent developments and innovations, in general. This is fur-ther evidence of the licensee's interest in providing an effec-tive security progra There were no security events that required reporting under 10 CFR 73.71 during the assessment perio This is attributed to the effective training program that resulted in excellent per-formance from the members of the security force and to the pro-gram implemented by the licensee to maintain its security systems and equipment in good working order, which includes mon-itoring of and planning to replace aging equipment and replace-ment of equipment before it became a source of problem During the assessment period, the licensee submitted two changes to the NRC approved Security Plan in accordance with the provi-stons of 10 CFR 50.54(p). These plan changes were reviewed and considered acceptable. The changes were clearly described and the plan pages were marked to f acilitate review. The changes were made to accommodate modifications to existing site facili-ties and, as with plans for similar r 'ifications since that time, the licensee discussed its plan. ceforehand with regional personnel to ensure a clear understanding of NRC security pro-gram objectives. This demonstrated the licensee's interest in maintaining a high quality progra A material control and accounting inspection identified that two neutron fission detectors had not been physically accounted for during a 1985 inventory of special nuclear material (SNM). The inventory was promptly reconciled. However, the failure to physically account for all SNM during an inventory and a misin-terpretation of an NRC requirement regarding the conduct of physical inventories of SNM, also raised during that inspection,
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demonstrate the need for increased management attention to the accounting of SN ; In summary, the continued good performance of the security force, coupled with the associated attention to facilities and equipment, training, staffing, and involvement with other secu- , rity organizations, demonstrated the security area to be a strength within the FitzPatrick organizatio . Conclusion Rating: Category 1 3. Board Recommendations None l
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G. Outage Management and Engineering Support (152 Hours, 7.9%) Analysis During the previous assessment period, this functional area was rated as Category 2. Performance had dec1%ed due to inadequate planning, poor control of' activities, and personnel error During this period, no refueling. outage took place, but two short scheduled maintenance outages, totaling 24 days, occurre During'these outages major work included replacement of control rod drive mechanisms, installation of several modifications, and preventive and corrective maintenance. The resident inspector reviewed these activities, and a specialist inspector reviewed radiological controls during one of the outage In January, 1986, the licensee established a new Planning and Contract Services Department to plan, schedule, and manage out-age and' contractor activities. In addition to a full time plann-ing department, this action provided more. direct plant manage-ment control of outage activities by replacing the contractor supervisors with licensee supervisors and eliminating the con-tractor During both maintenance outages the licensee exhibited good con-trol of outage activities. Daily meetings brought problems to the appropriate level of attention and led to timely resolut- 4 ions. The newly organized Work Control Center also contributed by better controlling work activities. Detailed critiques of both outages examined methods of improving future outage activit-tes. Despite an ambitious' schedule and unforeseen required main-tenance, the licensee was able to complete the outages with only a day delay for each outage. Based on the above, both.the Planning and Contract Services Department and the Work Control Center improved the control of the outages that were conducte The plant Technical Services Department supplied engineering support for the review and design of modifications,. resolved plant engineering problems, administered the environmental qual-ification program onsite, and reviewed all safety-related pur-chase order Significant modifications included installation of a new plant computer system including SPDS, Appendix R modi-fications, inst allation of a second level of undervoltage pro-tection, and installation of new drywell sump level trans-mitters. The engineers were knowledgeable and competent, and were actively involved throughout the installation and testing of the modifications. However, due to the significance of their functions, the depart' ment's potential to impact other plant-departments and the fluctuating work loads between modifications and plant engineering problems, the Technical Services Depart- I ment will require continuing plant management review to assure- 'l I i
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. , proper oversight of the department's activities. It appeared that this oversight was inadequate on occasion based on the following examples: --
The ongoing program to inspect all safety-related pipe sup-ports was placed on hold in November 1985 following. funding shortages which prevented the Architect Engineer.(AE) from performing further evaluations. The licensee believed at the time that the fifty items waiting evaluation by the AE did not affect support or system operabilit In April; 1986 after the funding became available, the AE determined a support in the Core Spray system identified on November 7,1985 as having a discrepancy was inoperable. Subsequent , evaluation concluded the inoperable support did not affect l' the system operability. The delay in recognizing the inop- , erable support was caused by the Pipe Support Field Engi-neer's (PSFE), a contract engineer, failure to make the
~
operability determination upon discovering the.discrepan-cies as expected. On November 15, 1985, when the'PSFE left the site permanently, the Pipe. Support Program Manager was not informed of the problem by the PSFE, and no formal re-view of the support packages was conducted when the PSFE departe An installation deficiency caused by inadequate design change review on a valve motor operator resulted in a Re-circulation Loop Discharge Bypass Valve being inoperable 1 due to mechanical interference following piping thermal l expansion. During installation of the new operator, the orientation of the operator had been changed due to dif-ferent clearance requirements. This event resulted in'a i plant shutdown required by Technical Specification '
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In summary, outage management was well organized and effective . in planning and managing the two short outages. The dedicated l outage planning staff has been instrumental in upgrading the ! planning for the upcoming refueling outage. With the exception ! j. I
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i noted, the engineering support group performed well in assuring the technical adequacy of modifications, but upper plant and i corporate management review of their activities should be in ' l ' crease ]
! Conclusion Rating: 2 - Board Recommendations None l
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j k Licensing Activities ' Analysis During the previous assessment period, this functional area was rated as Category 2. Performance had improved as evidenced by 1 the reduction in the backlog of licensing action l I A reorganization of the headquarters staff took effect at the l beginning of this rating period. In'the new configuration, the i licensing staffs for both FitzPatrick and Indian Point 3 report i to the same Vice-President. Notwithstanding the differences in
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the respective reactor designs, this change has resulted in an improved exchange of information between the two licensing i staffs and should result in more uniform interactions with NR )l Interaction between headquarters management and NRR was at a comparatively reduced level during this rating period due to l elimination of a large backlog of licensing actions during the previous rating period and the absence of any major outage Nevertheless, management interest and involvement in licensing activities was evident. A case in point was the attendance of licensee senior level management at a counterparts working meet-ing between BWR Project Directorate #2 staff and licensing man- , agers of utilities assigned to that directorate, held in April 1 198 Increased management attention to the quality of Sholly evaluations and licensing correspondence has also been evident during this rating period and is responsive to a recommendation made in the previous SALP evaluatio Licensee management, however, has not directed sufficient atten- , tion towards correcting and revising the Technical Specifica-L tions (TS) to ensure that the current, as-built configuration of the plant is reflected, that errors are eliminated, and that wording clearly reflects the intent of the TS. A case in point is Table 3.7-1 regarding containment isolation valves. Inaccu-racies have existed in this table for years, and the table does not reflect the current configuration of the plant, yet the licensee has not, to date, proposed revisions. The TS pertain-ing to recirculation bypass valves illustrates.a case where wording is not consistent with intent. Although this TS was subsequently deleted, no effort was made to revise the wording during a 6-month nriod from the tima this TS led to a plant shutdown to the time the deletion was requested.
l Licensee efforts towards the resolution of safety issues is evi-dent by its active participation and close contact with various industry groups involved in the identification and resolution of safety issues. These groups include the BWR Owners Group, the
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Institute for Nuclear Power Operations, the Seismic Qualifica-tion Utility Group, the Nuclear Utilities Fire Protection Group,
\'. s - - _ _ _ . - _ - - _ _ - - - - - - - _ _ - _ _ _ - - - _ - - - - . _ . _ _ - - _ - - - _ - . _ _ _ _ _ _ - _ _ _ _ . . - . . - _ _ _ . - _ _ _ - _ - _ _ _ _ _ - - - _ _ _ _ _ _
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the Nuclear Utility Group on Station Blackout, IDCOR, the Nucle- , ar Utility Management and Resource Committee, the Atomic Indus- ! trial Forum, and the American Nuclear Societ ) i With a few exceptions, safety evaluations submitted by the J licensee in support of proposed TS changes or to resolve techni- l cal issues have been clear and substantive. One exception was j the documentation (a contractor report) submitted to support a 4 TS revision to lower the MSIV isolation water level setpoin I Better screening of contractor outputs, for clarity as well as technical content, will reduce the NRR resources required for review, with attendant reduction in cost to the license Licensee responsiveness to NRC initiatives was noted in the pre-vious two SALP evaluations as an attribute for which improved { performance was sought. No improvement in the licensee's over-all spirit of cooperation, however, was evident during this {
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rating period. Encompassed here is the licensee's responsive- I ness to requests for information, both verbal and written, de- j lays in submittal or resubmittal of documentation (often of a ; routine or simple nature), and the general reluctance to provide defir.itive schedules. All of these factors represent impedi-ments to conducting day-to-day business. Examples include poor ! responsiveness to requests for additional information concerning j l the following reviews: SPDS (isolation devices), Salem ATWS j Item 1.2, an Appendix R exemption related to safe shutdown, and the ISI program review. In addition, delays were experienced in l the resubmittal of amendment requests concerning NUREG-0737 TS j (a problem area identified in the previous SALP evaluation) and l transfer of reserve power (returned to the licensee because of 1 l ' an inadequate Sholly analysis). Delays in the submittal of TS needed to support plant modifications, in accordance with 10 CFR 50.59, have also been evident. Cases in point are the TS re-lated to second level undervoltage protection modifications, the analog transmitter trip system installation, and containment isolation valve addition In view of the previous elimination of a large backlog of li-censing actions, and the increase in size of the licensing staff, improvement was possible during this rating period but was not achieve In summary, the licensee needs to improve communications as well as its spirit of cooperation with the NRC in the area of licensing activitie . Conclusion Rating: 2 Trend: Declining _ _ _ _ _ - _ _ _ _ _ _ - - - _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ - - _ - - _ _ _ _ _ _ - _ - - - - _ - _ _ _ _ _ _ _ _ . _
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3. Board Recommendations None i
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I. Training and Qualification Effectiveness (NA) * j Analysis , The various aspects of this functional area have been considered f 1 and discussed as an integral part of other functional areas an ] the respective inspection hours'have.been. included in each on I Consequently, this discussion;is a synopsis of the assessments I related to training conducted'in other areas. Training effec- J tiveness-has been measured primarily by the observed performance ) of licensee personne1'and, to ~a lesser degree, as a review of ,, program adequacy. The discussion below addresses three princi- j pie areas: licensed operator training, nonlicensed staff
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training, and the status of INPO training accreditatio ;
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In the previous assessment period, this functional area:was rat- ' ed as' Category FitzPatrick management displayed a strong i commitment to training, shown by several programs for the im- ,' , provement of the technical knowledge of both licensed and non-licensed personnel. A declining trend had been noted in lic-
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ensed operator examination results. This was attributed to in- l adequate screening of the candidate During this assessment period, one set of replacement operator licensing examinations was administered, and a requalification training program inspection was also conducted by NRC Region ' A total of six candidates were given written and oral-examina- ! tions for initial licenses in July 1986. The two (2)-Senior Reactor Operators (SRO) candidates and the Instructor Certifi-
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l; cation candidate passed the examination.. Of the three (3) Reac- J ter Operators (RO) candidates, one passed,.one failed the oral examination, and one failed both the oral and written examination During this assessment period, several deficiencies were noted i in the administration of the licensed operator training progra J As noted above, two of the three Reactor' Operator license candi-dates failed the examination given this period. Over.the past ~ two years, four of six Reactor Operator candidates have failed the examination. This poor performance has been attributed to inadequate screening of NRC examination candidates and not poor 1 , ' training practices. This conclusion is based on the performance i of the Reactor Operator and Senior Reactor Operators who have J passed the examinations and the fact that both the' Senior Reac- l l tor Operators and Reactor Operators are trained together in one i ! classroo An inspection of the FitzPatrick requalification training pro-gram identified significant weaknesses. The utility training i l
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z . lr h staff submitted 20% of both the SR0 and RO written requalift-cation examinations given, including the answer keys, to the NRC for parallel grading. A comparison of results revealed signifi-cant differences between the licensee and the NRC grading, with the NRC grades being lower.in all cases. A review of the grad-ing techniques revealed that many questions were not graded strictly to the answer key, and grading between the examinations was inconsisten Other weaknesses identified during the requalification training program inspection included poor lectures, poor attendance, missed required reading assignments, missed oral examinations, and overall weak program supervision. Some of these problems c can be attributed to the temporary reassignment of the requalifi-cation program administrator, who attended advanced technical training for eight inonths. In his absence, the assigned program administrator did not adequately implement the requalification program and the licensee management failed to properly oversee the program. However, many of these weaknesses existed before the reassignment and are attributed to overall poor management oversight of the progra Although wee.knesses were noted in the administration of the requalification program, these weaknesses did not appear to have a direct impact on the day-to-day operations of the plant, as evidenced by the small number of personnel errors and opera-tional events. A positive initiative, which was begun during this assessment period by the Operations Department, was an on shif t operator training program. This program, implemented to improve operator knowledge, includes a'uxiliary operator walkthroughs, scenario walkthroughs with the entire shif t, written examinations, and incident discussion The training programs for nonlicensed personnel continue to be strong and effective as evidenced by the absence of personnel errors and improvement in performanc The state atcredited training program has been implemented and well received. Con-tinued improvements are being made in the area of nonlicensed operator training program as evidenced by the implementation of a formal remediation progra In addition FitzPatrick main-tained strong and effective training programs,for maintenance, radiation protection, and security personne Fitzpatrick received training program accreditation from INP0 in the areas of Reactor Operators, Senior Reactor Operators and auxiliary operators. The self-evaluation reports for the remain-ing seven programs have been submitted and the Accreditation Team 1987. visit to review these programs is scheduled for February completion Theinsimulator mid-19R8.and new training facility are scheduled for __ _ _ _._ L
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In summary, the training programs for nonlicensed operators, '. . maintenance workers, radiation protection technicians, and
security' personnel were strong and effective. Problems' occurred in the screening of initial operator license candidates and the' { administration of the requalification training of. licensed oper-
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j ators, but FitzPatrick management belatedly found the problems ; 1 (concurrently with NRC inspections) and corrective action is ! being taken regarding the requalification program. In spite of the problems there is no evidence that they adversely affected - plant operation ! Conclusions
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Rating: 2 l Board Recommendations I
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J Assurance of Quality
! Analysis Assurance of Quality is a summary assessment of management over- i sight and effectiveness in implementation of the quality assur-ance program and administrative controls affecting qualit .
Activities affecting the assurance of quality as they apply spe- l cifically to a functional area are addressed under each of the i separate functional areas. Further, this functional area is not j merely an assessment of the Quality Assurance Department alone, ! but is an overall evaluation of management's initiatives, pro-grams, and policies which affect or assure qualit l During the previous assessment period, this functional area was rated as a Category 2. The Quality Assurance (QA) Department was actively involved in startup testing, maintenance and modi-fication activities. Weaknesses noted were in the scope of au-dits and involvement in surveillance testin ; i During this assessment period, the weaknesses noted above have ! been corrected. With the exception of Radiation Protection Pro-grams, audits were found generally to be of sufficient dept The QA department also utilizes surveillance to review activi-ties in progress. The QA department expanded their involvement ' in the surveillance test are j l A review of the quality assurance program found the QA depart- I ment to be adequately staffed. The QA personnel receive train- 1 ing in the department and at the Training Center. The QA depart-nent is part of the corporate organization, but frequent meet- l ings of the QA Superintendent, the Resident Manager and the l Superintendent of Power are held to discuss QA/QC concern ! Thus QA issues are brought to the attention of appropriate plant i management in a timely fashio ' A maintenance program for items in storage was lacking and re-suited in a pump being improperly maintained. The lack of such a program was brought to the licensee's attention in 1983, 1984 and during the course of inspection 86-11. The licensee has ! initiated corrective action in the form of a material equipment I list which is scheduled for completion in January 1987 and for full implementation by late 1988. The list is intended to identify all the maintenance requirements for each item. Cor- ' rective actions in this area have been slo The licensee has recognized a need for improvement in the per-formance of receipt inspections by QC inspectors and is develop-ing an upgraded receipt inspection instruction. The instruction will delineate receipt inspection requirements, and provide l l
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l l guidance to inspectors. Without the instruction, inspectors must rely on their experience, which can result in inconsistent inspection result The Quality Assurance Department plays an active role in assur-ing quality at the plant. There are excellent lines of communi-cation between the QA department, plant management and each department. The OA department has also contributed significantly by their involvement in the Scram Reduction Program, Technical Specification Matrix, Master Equipment List, procedural reviews, and surveillance of plant activities. The QA Superintendent emphasizes quality on the front-end and not after-the-fact. He accomplishes this by making sure that in process inspections and evaluations receive high priority and paperwork audits are placed in proper perspective. In addition, the QA department conducted a review of vendor QA programs and facilities when problems arose with Containment Atmosphere Analyzes and Rosemount transmitter Corporate and station management are actively involved in plant activities. Senior plant management exhibits an excellent attitude toward plant safety and have focused their efforts on reducing personnel errors and instilling a pride of workmanshi These efforts appeared to be effective, based upon the small number of personnel errors and high plant availability. First line supervision is actively involved in monitoring work activ-ities to assure a quality produc NYPA's work force is stable, experienced, knowledgeable, and dedicated, and represents a strength. NiPA has demonstrated a quality attitude by imple-menting the Scram Reduction Program, newly organized work con-trol center, and revised work activity control procedures. They also maintain an effective program of establishing and tracking management goals and objectives. The goals provide an extensive data base of information for monitoring NYPA's performance and, I in many cases, are compared to a management goa Improvements have been noted in the Plant Operations Review Com-mittee (PORC). The PORC has generally displayed a more inquisi-tive nature in reviewing events. One exception was the review following a reactor trip discussed in Section C, Maintenanc The PORC utilizes a formal system to track resolution of issues or questions and corrective action One overall weakness noted was the slow or ineffective resolu-tion to previously identified problems which included: mainten-ance of stored items, calibration program weaknesses identified in a 1983 audit, and failures to make required Emergency Notifi-cation System reports discussed in Section A, Operations.
In summary, the Quality Assurance Department plays an active role in assuring quality at FitzPatric The plant management _ _ _ - - _ _ - _ _ -
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generally displays an aggressive attitude for improvement of i quality at the ~.~acility, as evidenced by er.tablishing and imple- l menting improvement programs noted above. However, some pro-grams are still slow in developing and lapses have occurred in ) implementing some corrective actions, performing root cause
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- analysis, implementation of the requalification training pro-I gram, and procedural adherence. These issues require continued management attentio . Conclusions Rating
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Trend: Improving I 3. Board Recommendations l ' None
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V. SUPPORTING DATA AND SUMMARIES Investigation and Allegation l None Escalated Enforcement Acttons None Management Conferences Two management meetings were held during the assessment period. One was held April 25, 1986, to discuss the last SALP report. The second was held August 5, 1986, this was to discuss NYPA's progress on the Scram Reduction Program as recommended in the last SAL Licensee Event Reports Twenty LERs were submitted during this assessment period. The LERs are listed in Table 3. The following is a tabular listing of the results of the causal analysis of the LER Personnel Error.................. 5 Design / Man./Construc./ Install.... 6 External Cause.................... O Defective Procedures............. 3 Component Failure............... 3 ther.............................3 Total ED Causal Analysis The following sets of common mode events were identified: Inadvertent RPS Actuations Five LERs (86-04, 86-06, 86-10, 86-13, and 86-17) reported reactor trips. The analysis of these events is delineated in Table Inadvertent ESF Actuations Three LERs (85-28, 86-05, and 86-15) reported isolations of either the High Pressure Coolant Injection System or Reactor Core Isolation Cooling Injection System. These were due to different causes includ- , ing component failure, design de'iciencies and inadequate procedures.
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1 l Inoperable ESF Sys g . -) Three LERs (86-03, 86-12, and 86-14) report the High Pressure Coolant' Injection System inoperable. The causes varied but all were due to inoperable motor operated valves. In one case, the failure was due f
l to corrosion. caused by a steam leak, another due to procedural inade-l quacies, and the third, design deficiencie Surveillance Testing Three LERs (86-01, 86-02, and 86-09) reported missed or late surveil-lance tests. Two were caused by inadequate program administration and the third due to personnel erro E. Licensing Activities NRC/ Licensee Meetings / Site Visits Site Visits: March 18, May 16, June 26-27, October 22, 1986 Meetings: February 10, 1986: Discussed licensing action status' March 18, 1986: Discussed Sholly preparation April 10, 1986: Licensing counterparts meeting (BWD#2) April 25, 1986: SALP management meeting May 16, 1986: Discussed licens'ng action status July 31, 1986: Discussed Technical Specifications related to control room habitability September 11, 1986: Discussed licensing action status Commission Briefings ; i None-
] Schedular Extensions Granted None Relief Granted April 18, 1986; Certain inservice inspection requirements Exerrptions Granted
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i April 30, 1986; certain requirements of Appendix R September 15, 1986; certain requirements of Appendix R l l l !icense Amendments Issued j Amendment No. 98, issued May 6, 1986; revises TS regarding sin-gle loop operation s ____._________._________________.__.___.______m___.m _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _____.______,__.__ .
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Amendment No. 99, issued June 20, 1986; revises TS to clarify responsibility of Plant Operating Review Consittee Amendment No.100, issued June 20, 1986; revises TS regarding composition of Safety Review Committee Amendment No. 101, issued October 24, 1986; revises TS regarding enriched bundles stored in spent fuel poo Amendment No. 102, issued October 31, 1986; revises TS to impose more restrictive leakage limit and increased surveillance re-quirements (NUREG-0313) 7. Emergency / Exigent Technical Specifications l
None 8. Orders Issued None 9. NRR/ Licensee Management Conferences l
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l TABLE 1 INSPECTION REPORT ACTIVITIES Report / Dates Inspector Hours Area Inspected 85-31 Resident 76 Routine Resident 12/1/85 - 1/17/86 Inspection 86-01 Resident 109 Routine Resident 1/18/86 - 3/10/86 Inspection i 86-02 Specialist 26 Routine Security 1/13/86 - 1/16/86 86-03 Specialist 47 Routine Transportation , 1/28/86 - 1/31/86 l 86-04 Resident 227 Routine Resident 3/11/86 - 5/9/86 Inspection l 86-05 Resident 128 Routine Resident 5/10/86 - 6/20/86 Inspection I 86-06 Specialist 74 Routine Dosimetry 5/19/86 - 5/23/86 Program
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i l 86-07 Specialist 110 Emergency Preparedness j l 6/17/86 - 6/19/86 and Observation of Emergency Exercise _ 86-08 Specialist 72 Surveillance Program l 6/2/86 - 6/6/86 l 86-09 Specialist N/A Operator Examination 7/28/86 - 7/31/86 Report
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86-10 Resident 153 Routine Resident ! 6/21/86 - 8/8/86 Inspection ' 86-11 Specialist 46 Routine Quality
- 7/14/86 - 7/18/86 Assurance Program l 86-12 Specialist 36 Radiological 7/21/86 - 7/25/86 Environmental
' Monitoring Program 86-13 Resident 123 Routine Resident 8/9/86 - 9/29/86 Inspection l
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86-14 Specialist 57 Environmental 8/25/86 - 8/28/86 Qualification cf Limitorque Valve , Wiring ' 86-15 Specialist 130 Requalification 9/16/86 - 9/18/86 Training Program 86-16 Specialist 38 Maintenance 9/22/86 - 9/26/86 Surveillance Testing
& ISI Programs 86-17 Specialist 126 Routine Radiation l 9/29/86 - 10/3/86 Protection Program 86-18 Resident 171 Routine Resident 9/30/86 - 11/24/86 Inspection 86-19 Specialist 56 Special Nuclear 10/21/86 - 10/23/86 Material Control Program 86-20 Specialist 27 Routine t 10/21/86 - 10/23/86 Nonradiological Chemistry Program I
86-21 Specialist 56 Routine Effluent 11/17/86 - 11/21/86 Monitoring Program 86-22 Specialist 32 Routine Security 11/24/86 - 11/26/86 l l l
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TABLE 2 INSPECTION HOURS SUMMARY JAMES A. FITZPATRICK NUCLEAR POWER PLANT TIME HOURS % OF TIME Plant Operations........................... 773 4 Radiological Controls...................... 392 2 Maintenance................................ 159 . Surveillance............................... 194 1 Emergency Preparedness..................... 110 ) l Security and Safeguards.................... 140 Outage Management and Engineering Suppor .9 Licensing Activities........................ * * Training and Qualification.................. ** ** Effectiveness Assurance of Quality........................ ** ** I Total 1920 100% i
* Hours expended in facility license activities and operator license I activities not included with direct inspection effort statistic **: lours expended in the areas of training and quality assurance are included in other functional areas, therefore, no direct inspection hours are given for ,
these area l l
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TABLE 3 LISTING OF LERs BY FUNCTIONAL AREA - CAUSE CODES AREA A B C D E X TOTAL Operations 1 3 0 0 1 1 6 Radiological / Controls 0 0 0 0 0 0 0 Maintenance 0 2 0 2 1 0 5 Surveillance 3 0 0 1, 0 1 5 Emergency Prep 0 0 0 0 0 0 0 Sec/Safeauards 0 0 0 0 0 0 0 Outage Management 0 1 0 0 1 0 2 Training 0 0 0 0 0 0 0 Licensing 0 0 0 0 0 0 0 Assurance of Quality 1 0 0 0 0 1 2 TOTALS 5 6 0 3 3 3 20 Cause Codes: A - Personnel Error B - Design, Manufacturing, Construction or Installation Error C - External Cause 0 - Defective Procedures E - Component Failure J X - Other l l l _ _ _ - - _ _ _ _ _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ - _ _ - _ _ _ - _ _ _ _ - _ _ _
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i TABLE 4 LER SYNOPSIS LER Number Event Date Cause Code De sc ription 85-27* 11/22/85 E Inoperable Main Steam Isolation Valves found during testin /13/85 E High Pressure Coolant i Injection System Isolation I due to faulty trip uni /3/86 A Failure to perform APRM surveillance at required frequenc /3/86 A Failure to perform Diesel Fire Pump Surveillance at required frequenc l 86-03 3/12/86 X Inoperable containment I isolation valve on High Pressure Coolant Injection syste ' 86-04 3/15/86 D Reactor Trip while shutdown performing post work testin /4/86 6 Reactor Core Isolation Cooling isolation due to loose lea /25/86 A Reactor Trip while shutdown due to low vessel leve /23/86 A Failure to meet Environmental Qualification requirements l for 4 valve operators '. l inside containmen /27/86 X Setpoint drift of ASCO pressure switche _--_-_- _ _ _ ___ - _
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86-09 3/28/86 A Late chemistry surveillance during startu /4/86 B Reactor trip while conducting turbine stop I valve testin /15/86 B Failure of recirculation loop discharge bypass valve to operat i 86-12 5/25/86 B High Pressure Coolant fj Injunction inoperable due l ' to breaker tripping when wette /3/86 B Reactor trip due to protective relay test block failure.
l 86-14 9/3/86 D High Pressure Coolant Injection valve failure due to procedural inadequacie /4/86 D Reactor Core Isolation Cooling isolation due to inadequate venting of transmitte /9/86 X Use of incorrect Minimum rritical Power Ratio calculation, 86-17 9/30/86 E 7 Reactor Trips while shutdown due to neutron 1 instrument spike l 86-18 10/15/86 B Potential common mode failure of circuit breaker * Event occurred during previous assessment period i l i
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TABLE 5 ENFORCEMENT SUMMARY 12/1/85 - 11/30/86 JAMES A. FITZPATRICK NUCLEAR POWER PLANT Number and Severity Level Level of Violations Severity Level I O Severity Level II 0 Severity Level III O Severity Level IV 4 Severity Level V 2 Deviation 0 TOTAL ~6 Violation vs. Functional Area SEVERITY LEVEL FUNCTIONAL AREA 1 2 3 4 5 DE TOTAL Operations 2 2 Radiological Controls 1 1 Maintenance 1 1 Surveillance 1 1 Emergency Pre O Sec/ Safeguards O Refueling and Outage Management 0 Training 0 Licensing 0 Assurance of Quality 1 1 .__ __ __ _ TOTALS 2 4 6 ( _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - _ _ _ - -
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TABLE 5 (CONTINUED) ENFORCEMENT SUMMARY Inspection Violation Functional , Report Requirement Level Area Violation 85-31 10CFR50.72 5 Operations Failure to report 12/1/85-1/17/86 High Pressure Coolant Injection System Isolations and Inoperabilit Tech Spec 4 Surveillance Failure to perform 1/18/86-3/10/86 4. surveillance
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within required frequenc CFR50 4 Assurance of Failure to properly 7/14/86-7/18/86 APP. B(XIII) Quality care for items in storag Tech Spec 5 Rad Cei.;rol Failure to 7/21/86-7/25/86 properly implement procedure for calibration of Alpha Beta counte Tech Spec 5 Maintenance / Failure to 8/9/86-9/29/86 6.8(A) Rad Control properly implement procedures for installing a pressure transmitter and survey new fuel shipment CFR50.72 5 Operations Failure to make 8/9/86-9/29/86 ENS report for reactor core isolation cooling system isolation.
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TABLE 6 REACTOR-TRIPS AND UNPLANNED PLANT SHUT 00WNS- l The-reactor trips occurring during this assessment period fall into three cate-gories. These categories included personnel error, procedural deficiency, and equipment malfunction. This section assesses the root cause of each trip.with-in each category from the NRC's perspectiv . Power Functional Date Level Description Cause Area /15/86 SD Reactor trip due to personnel Error: Assurance post-work testing An inadequate review of a of on RPS. (LER 86-04) procedure change resulted Quality' . in energizing one " of-the backup scram solenoids causing the scra . 3/25/86 SD Reactor trip due to Personnel Error: Operations -1 reactor vessel' low Inadequate control of level. (LER-86-06) activities in the control room caused the trip when the operator's attention was diverted to stop a feedwater leak while purposely lowering vessel leve /28/86 Start-up l 1 /4/86 88% Reactor trip during Procedural Deficiencies: Maintenance- I turbine stop valve Loose bolts on turbine stop testing due to valve, which were apparently faulty valve not torqued, allowed a stroke position indication change causing faulty position j (LER 86-10) indicatio /6/86 Start-up /15/86 Shutdown required Equipment Failure: Engineering by Technical Spect- Inadequate design change Support fications due to review resulted in valve inoperable inoperability due to thermal Recirculation loop growt discharge bypass i valve (LER 86-11) 4 5/18/86 Start-up
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$ /3/86 100% Reactor Trip due to Equipment Failure - Maintenance
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(LER 86-13) protective relay test !
circuit caused a turbine tri ' 7/4/86 Start-up i /30/86 50 Reactor Trip due to Equipment Failure - Maintenance neutron monitoring Random: A wet connector instrument failure caused the LPRM to fail (LER 86-17) upscal J l 7-12. 10/1/86 SD Seven reactor trips Equipment Failure: Maintenance l 10/3/86 due to neutron During under-vessel work, l 10/4/86 monitoring maintenance personnel ' instrument spiking bumped "G" IRM connector (LER 86-17) which was later found to have a broken connecto /9/86 Start-up i l l l
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o UNITED STATES
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yfg g NUCLEAR flEGULATORY COMMISSION nEG10N l
* l % 4 631 FARK AVENUE %, ,8 KINO OF PHuSSIA, PENNSYLVANIA 19406 ..... . EflCLOSURE 4 l 13 MAR E Docket No. 50-333 Power Authority of the 5+, ate of New York James A. FitzPatrick Nuclear Power Plant ATIN: Mr. J. C. Brons Senior Vice President-Nuclear Generation 123 Main Street White Plains, New York 13093 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP); Report No.
. l 50-333/85-98 The NRC Region ! SALP Board conducted a review on February 13, 1987 and evaluated the performance of activities associated with James A. Fit: Patrick Nuclear Power Plan The results of this assessment are documented in the enclosed SALP Board report. A meeting will be scheduled to discuss this assessment. This meeting is intended to provide a forum for candid discussions relating to this performanc At the meeting, you should be prepared to discuss our assessment and your plans to improve performance. Any comments you may have regarding our report may be discussed at the meeting. Additionally, you may provide written comments within 30 days after the meetin We appreciate your cooperatio
Sincerely, ' O b, hh 4 omas E. Murley v Regional Administrator Enclosure SALP Board Report No. 50-333/85-98 l t-7%xjf - ,... m
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Power Authority of 2 , !
;o the State of New York 13 hAtsR 196t i i
l cc w/ encl: 's ) L. W. Sinclair, President j J. P. Bayne, First Executive Vice President and Chief Operations Officer ! A. Klausmann, Vice President - Quality Assurance and Reliability { R. L. Patch, Quality Assurance Superintendent George M. Wilverding, Chairman, Safety Review Committee 3 Gerald C. Goldstein, Assistant General Counsel 1 HRC Licensing Project Manager i Dept. of Public Service, State of New York i Public Document Room (POR) local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) HRC Resident inspector State of New York , Chairman Zech l Commissioner Roberts Commissioner Asselstine Commissioner Bernthal l Commissioner Carr S. Ebneter, DRS , T. Martin, DRSS J. Taylor, IE i T. Murley, R1 ! J. Allan, RJ 0. Holody, R1 l K. Abranam, PAC (2 copies) Board Members l
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a 3l ) i ENCLOSURE 5 I SALP BOARD REPORT ERRATA SHEET l
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19 3 audit appraisal i Basis: These changes were made in order to avoid any misconstrued meaning Note: No change was made on page 27 regarding the reason for the plant i i shutdown because information from you staff, as well as LER No. 86-11 l support the statement that the plant shut down because of Technical Specification wording problems. We are aware, however, that a packing -l leak was also identified and needed to be repaire I
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