IR 05000333/1986013

Insp Rept 50-333/86-13 on 860809-0929.Violations Noted: Failure to Implement Procedures & Make Emergency Notification Sys Call within Required Time Frame

ML20213F670
Person / Time
Site:	FitzPatrick
Issue date:	11/07/1986
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213F659	List: IR 05000333/1986013 ML20213F658 ML20213F664
References
50-333-86-13, NUDOCS 8611140381
Download: ML20213F670 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

DCS No Report N Docket N License N DPR-59 Category C Licensee: Power Authority of the State of New York P.O. Box 41 Lycoming, New York 13093 Facility Name: J. A. FitzPatrick Nuclear Power Plant Inspection At: Scriba, New York Inspection Conducted: August 9 - September 29, 1986 Inspectors: A.J. Luptak, Senior Reside Inspector Approved by: W /d

~nville, Chief,' Reactor

//h/M J Odtf ects Section 2C, DRP Inspection Summary:

Inspection on August 9 - September 29, 1986 (Report N /86-13)

Areas Inspected: Routine and reactive inspection during day and backshift hours by one resident inspector (123 hours0.00142 days <br />0.0342 hours <br />2.03373e-4 weeks <br />4.68015e-5 months <br />) of licensee event report review, opera-tional safety verification, followup on operational events, surveillance observations, maintenance observations, general employee training, Rosemount transmitter failures, and review of periodic and special report Results: Two violations were identified during this inspection period; failure to implement procedures (paragraph 9b) and the failure to make a Emergency Notification System call within the required time frame (paragraph 5). The failure to make the required notification is a reoccurrence of a violation cited in Inspection Report 85-31, dated February 27, 1986. This demonstrates a lack of timely attention to implement adequate measures to correct this viola-tion. The issue concerning the environmental qualification of transmitters discussed in paragraph 9b will be reviewed during a future region based inspectio PDR ADOCK 05000333 O PDR

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DETAILS Persons Contacted During this inspection period, the inspector interviewed or held discuss-ions with operators, technicians, and maintenance, contractor, engineer-ing, administrative and supervisory personne . Summary of Plant Activities The plant operated at near full power from the beginning of this inspec-tion period until September 27, 1986, when the plant was shut down to begin a scheduled, ten day maintenance outag . Licensee Action on Previous Inspection Findings (Closed) Inspector Followup Item (85-28-03): The inspector reviewed the results of the licensee's investigation into the failure of the dashpot bolts on a Main Steam Isolation Valve (MSIV). The valve manufacturer, Rockwell International, conducted a metallurgical examination of the bolts as a result of these failures and concluded that the failure mechanism was cyclic tensile overloading. The actuator manufacturer recommends a five year maintenance cycle for these actuators and concludes that the bolts should be replaced at that time. Based on the manufacturer's recommenda-tions, the licensee has replaced the dashpot bolts on all of the MSIV actuators and has added this to their preventive maintenance program. The inspector had no further questions and considers this item close . Licensee Event Report (LER) Review The inspector reviewed LERs to verify that the details of the events were clearly reported. The inspector determined that reporting requirements had been met, the report was adequate to assess the event, the cause appeared accurate and was supported by details, corrective actions appeared appropriate to correct the cause, the form was complete, and generic applicability to other plants was not in questio During this inspection period, the following LERs were reviewed:

LER 85-27-1 was a supplemental report to identify the failure mechanism associated with the Main Steam Isolation Valve failures. This issue is discussed in paragraph 3 abov LER 86-16 reported the use of an incorrect Minimum Critical Power Ratio Calculation. The licensee's review of the data during the period in which the incorrect calculation was in place indicated that the thermal limits were not exceeded based on the correct calculatio .

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3 Emeroency Notification System Reports The inspector reviewed the following events which were reported to the NRC via the Emergency Notification System as required by 10 CFR 50.72. The review included a determination that the reporting requirements were met, that appropriate corrective actions had been taken, and that the event had been evaluated for possible generic implication The following reports were reviewed:

Event Date Subject September 3, 1986 A call was made to report entering a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Limiting Condition for Operation when both the Reactor Core Isolation Cooling and High Pressure Coolant Injection System became inoperabl September 4, 1986 Automatic isolation of the Reactor Core Isolation Cooling Syste Following a Reactor Core Isolation Cooling (RCIC) isolation on September 4, 1986 at 9:00 p.m., the licensee initially determined that this event was not required to be reported. After further review on September 5, 1986, the licensee determined the event was reportable and made the Emer-gency Notification System (ENS) call at 8:33 CFR 50.72(b)(2)(ii) requires that the licensee notify the NRC Opera-tions Center via the ENS, as soon as practical and in all cases within four hours of any event that results in automatic actuation of any Engineered Safety Feature. The RCIC isolation is part of the Primary Containment Isolation System which is an Engineered Safety Featur The failure to make the notificaion within the required time is a violation of 10 CFR 50.72. (333/86-13-01)

In NRC Inspection Report 50-333/85-31, dated February 27, 1986, the licensee was cited for the failure to make required ENS notification The licensee response to that violation included a commitment to revise their notification procedure by July 1986. At the time of this most recent occurrence, this procedure was still in the initial draft for The failure to implement timely corrective action to prevent reoccurrence of this violation indicates a lack of management attention, to the followup of commitment . Operational Safety Verification Control Room Observations Daily, the inspector verified selected plant parameters and equipment availability to ensure compliance with limiting conditions for opera-tion of the plant Technical Specifications. Selected lit annunciators

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were discussed with control room operators to verify that the reasons for them were understood and corrective action, if required, was being taken. The inspector observed shift turnovers biweekly to ensure proper control room and shift manning. The inspector directly observed the operations listed below to ensure adherence to approved procedures:

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Plant shutdown on September 28, 198 Routine power operation Issuance of RWP's and Work Requests / Event / Deficiency form No violations were identifie Shift Logs and Operating Records Selected shift logs and operating records were reviewed to obtain information on plant problems and operations, detect changes and trends in performance, detect possible conflicts with Technical Specifications or regulatory requirements, determine that records are being maintained and reviewed as required, and assess the effective-ness of the communications provided by the log No violations were identified, Plant Tours During the inspection period, the inspector made observations and conducted tours of the plant. During the plant tours, the inspector conducted a visual inspection of selected piping between containment and the isolation valves for leakage or leakage paths. This included verification that manual valves were shut, capped and locked when required and that motor operated valves were not mechanically blocked. The inspector also checked fire protection, housekeeping /

cleanliness, radiation protection, and physical security conditions to ensure compliance with plant procedures and regulatory require-ment No violations were identifie d. Tagout Verification The inspector verified that the following safety-related protective tagout records (PTR's) were proper by observing the positions of breakers, switches and/or valves:

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PTR 861290 on High Pressure Coolant Injection Syste PTR 861313 on "B" Low Pressure Coolant Injection Independent Power Supply Syste . -_ - . , , .

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PTR 861323 on Diesel Fire Pump Syste No violations were identifie Emergency System Operability The inspector verified operability of the following systems by ensuring that each accessible valve in the primary flow path was in the correct position, by confirming that power supplies and breakers were properly aligned for components that must activate upon an initiation signal, and by visual inspection of the major components for leakage and other conditions which might prevent fulfillment of their functional requirements:

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Emergency Diesel Generator Fuel Oil and Air Start System Emergency Service Water Syste "B" Low Pressure Coolant Injection Syste No violations were idr_ntifie . Followup on Operational Events On September 3,1986, at 10:00 p.m., the licensee declared the Reactor Core Isolation Cooling (RCIC) System inoperable when a transmitter, which senses high steam flow, could not be calibrate The transmitter became suspect when it was noted to be oscillating during Daily Surveillance and Instrument check While performing High Pressure Coolant Injection (HPCI) surveillance testing, as required by Technical Specifications when RCIC is inoperable, the HPCI pump inboard suction valve from the torus (23MOV58) failed to operat The HPCI system was declared inoperable at 10:30 p.m., placing the plant in a Limiting Condition for Operation (LCO), requiring one of the systems to be restored or the reactor to be placed in a cold condi-tion and pressure to be reduced to less than 150 psig within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The RCIC transmitter was replaced, and the RCIC system was declared operable at 9:16 a.m. on September 4, 1986. While the HPCI system remained inoperable, the plant remained in a seven day LCO. At 9:00 the RCIC system automatically isolated due to a high steam flow signa Suspecting the recently installed transmitter, the licensee found air entrapped in the transmitter when it was revented. The RCIC system was declared operable at 3:00 a.m. on September 5, 1986 and the HPCI system was returned to service at 4:15 . _ . - .. - - . .

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The licensee concluded that, although the instrument appeared to be sufficiently vented after the transmitter replacement, a longer-than-usual length of piping for this instrument still contained air, which eventually worked its way into the sensor, causing the isolation. The licensee has instructed the Instrument and Control Supervisors to be aware of unusual piping configurations and will incorporate a caution statement, to ensure adequate venting, into a transmitter replacement procedure being develope In reviewing the cause of the failure of 23M0V58, the licensee concluded, after discussion with the operator's manufacturer, that excessive cycling of the valve caused the motor duty rating to be exceeded. This resulted in insulation breakdown, which led to the motor failure. During a semi-annual surveillance test conducted earlier on September 3, 1986, this valve was stroked (open or closed) eight times within approximately a 30-minute period. The valve stroke time is about one minut Review of this valve's maintenance history, in relation to the performance of the semiannual surveillance test, revealed that, although this motor has failed several times in the past, the failures did not occur immedi-ately following the test. This indicates that the excessive cycling does not necessarily result in immediate motor damage, but does cause insula-tion breakdown, which, in time, leads to motor failure. The licensee is conducting additional analyses to confirm the proper application of this motor, including its settings, and is reviewing other surveillance tests for similar problems. The inspector will review the LER on this issue during a subsequent inspectio . Surveillance Observations The inspector observed portions of the surveillance procedures listed below to verify that the test instrumentation was properly calibrated, approved procedures were used, the work was performed by qualified per-sonnel, limiting ccnditions for operation were met, and the system was correctly restored following the testin F-ST-24A, Reactor Core Isolation Cooling Pump and Valve Operability / Flow Rate Test, Rev. 20, dated May 1, 1986, performed August 25 and September 4, 198 F-ST-4E, High Pressure Coolant Injection Subsystem Logic System Functional Test, Revision 20, dated June 19, 1985, performed September 3, 198 F-ST-22C, Automatic Depressurization System Logic System Logic System Functional Test, Revision 16, dated March 19, 1986, performed September 4, 198 F-ST-11, Main Steam Isolation Valves Limit Switch Instrument Func-tional Test, Revision 7, dated March 26, 1986, performed September 15, 198 .

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The inspector also witnessed all aspects of the following surveillance test to verify that the surveillance procedure conformed to technical specification requirements and had been properly approved, limiting conditions for operation for removing equipment from service were met, testing was performed by qualified personnel, test results met technical specification requirements, the surveillance test documentation was reviewed, and equipment was properly restored to service following the tes F-ISP-225B, High Pressure Coolant Injection Steam Line Pressure Transmitter Calibration and Channel Functional Test, Revision 0, dated March 13, 1985, performed September 9, 198 No violations were identifie . Maintenance Observations The inspector observed portions of various safety-related maintenance activities to determine that redundant components were operable, that these activities did not violate the limiting conditions for opera-tion, that required administrative approvals and tagouts were obtained prior to initiating the work, that approved procedures were used or the activity was within the " skills of the trade," that appropriate radiological controls were properly implemented, that ignition / fire prevention controls were properly implemented, and that equipment was properly tested prior to returning it to service, During this inspection period, the following activities were observed:

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WR 00/38503, receipt and transfer of new fuel shipmen WR 23/45315, troubleshoot and repair the High Pressure Coolant Injection Torus Suction Valve 23MOV5 WR 23/43224, replace High Pressure Coolant Injection Low Steam Pressure Transmitter, 23 PT-68 WR 00/43229, irspect/ apply sealant to Analog Transmitter Trip System transmitter On September 9, 1986, during observation of the replacement of 23 PT-680 (WR 23/43224), the inspector noted that the technician failed to apply a sealant to the conduit connections of the transmitter being replaced, as required by the technical manua The technical manual, Rosemount Model 1153, Series B, Alphaline Pressure Trans-mitters for Nuclear Service, Revision C, dated May 1985, was the specified document for the transmitter replacement, since no proce-dure existe . _ -. __

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Work Activity Control Procedure,10.1.1, Procedure for the Control of Maintenance, Revision 10, requires that maintenance which can affect the performance of safety related equipment be performed in accor-dance with written procedures or documented instructions. The failure to apply the sealant is one example of a violation uf Technical Specification 6.8(A), which requires that written proce-dures and administrative policies be implemented which meet or exceed the requirements and recommendations of Appendix A of Regulatory Guide 1.33, November, 197 The technician explained that he did not apply any sealant because there was no sealant on the transmitter he removed. Based on this observation, the licensee inspected all of the Rosemount transmitters during a scheduled maintenance outage beginning September 27, 198 The licensee found none of the sixty-four environmentally qualified transmitters had sealant applied to the conduit connections and properly sealed the transmitters prior to reassembly. The technical manual requires that sealant be applied to the conduit connections to " avoid accumulation of moisture in the terminal side of the housing during accident conditions".

These transmitters were installed during the refueling outage ending in June 1985, as part of a modification which installed the Analog Transmitter Trip System. The instrument racks were assembled at a vendor site and shipped to licensee as a unit ready for installatio The licensee is investigating the environmental qualification impli-cations of the lack of sealant used in the transmitter assembl This item is unresolved and will be reviewed during the Environmental Qualification inspection. (333/86-13-02).

The inspector observed the licensee's receipt of new fuel shipments in accordance with Reactor Analyst Procedures (RAP) 7.1.1, Revision 4, Receiving and Handling of Unirradiated Fuel. RAP 7.1.1 requires that new fuel shipments be surveyed in accordance with Radiation Protection Technical and Analytical Procedure (RTP) 11. RTP-11, Revision 1 requires that beta / gamma and alpha contamination surveys be performed on the vehicle and shipping containers, and that these surveys be counted and evaluated prior to unloading the container In addition, the procedure requires that. beta / gamma and alpha surveys on each container be counted and evaluated prior to removing the fuel casks from their containe On September 3, 5, and 8, 1986, the technician performing the surveys did not count or evaluate the alpha surveys prior to allowing move-ment of the shipping containers and casks. This is another example of a violation of Technical Specification 6.8(A).

The two examples discussed above have been combined as a single violation of Technical Specification 6.8(A), which requires that

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procedures be implemented which meet or exceed the requirements and recommenJations of Appendix A of Regulatory Guide 1.33, November 1972 (333/86-13-03).

1 Rosemount Transmitter Failures During the refueling outage which ended June 1985, the licensee installed an Analog Transmitter Trip System. As part of this system, seventy-six Rosemount 11538 pressure and differential pressure transmitters were installed. These transmitters supply various pressure, flow and level signals to the Reactor Protection and Emergency Core Cooling System Since their installation, the licensee has had eight failures of these transmitters. The inability to calibrate or to maintain an instrument in calibration is considered a failure. The licensee has discovered these failures by observing drifting of the instrument output signal. To date, the manufacturer's destructive analysis of six of the failures determined five were due to a loss of oil. The oil is used to transmit the pressure from the isolating diaphram to the sensing diaphram. As this oil leaks, the transmitter begins to drif The licensee has begun a weekly monitoring program of the instrument output voltage, in addition to the routine once per shift monitoring of meter output conducted by the Operations Department to detect failure In addition, extensive discussions have been held with the manufacturer, and the licensee has sent a three-member team consisting of Quality Assurance, Technical Services, and Instrument and Control Supervisors to review the manufacturer's site and processes. Although no cause has been found, the licensee's review determined that the manufacturer's quality control, testing, and processes to be excellen Based on the number of transmitter failures, the licensee has begun to

, review this matter for potential 10 CFR 21 reporting requirements, in

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accordance with NGP 10, Reporting of Defects and Noncompliance, Revision 2. The inspector will review the licensee's corrective actions and 10 CFR 21 determination (333/86-13-04).

11. General Employee Training On August 13, 1986, the inspector attended a general employee training session and verified that the training was conducted as required by Indoctrination and Training Procedure No. 3, " General Employee Training,"

Revision 8. The inspector verified that training was provided on: the plant organization and administration; station security and access; industrial safety; fire protection; quality assurance; radiation protec-tion, including the contents of Regulatory Guide 8.13; and the emergency plan and implementing procedures. The inspector noted that approved lesson plans were used to conduct the training and determined that the technical content of the lectures was adequate. The inspector also noted that written examinations were administered during the training and that a grade of 80% was required to complete the trainin ,

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12. Review of Periodic and Special Reports Upon receipt, the inspector reviewed periodic and special reports. The review included the following: inclusion of information required by the NRC; test results and/or supporting information consistent with design predictions and performance specifications; planned corrective action for resolution of problems, and reportability and validity of report infor-mation. The following periodic reports were reviewed:

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July 1986 Operating Status Report, dated August 8, 198 August 1986 Operating Status Report, dated September 5, 198 . Exit Interview At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspection scope and findings. On September 29, 1986, the inspector met with licensee repre-sentatives and summarized the scope and findings of the inspection as they are described in this repor Based on the NRC Region I review of this report and discussions held with licensee represe'ntatives during the exit meeting, it was determined that this report does not contain information subject to 10 CFR 2.790 restric-tions.

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