IR 05000333/1989002

Insp Rept 50-333/89-02 on 890122-0304.Violations Noted. Major Areas Inspected:Mgt Changes,Operations,Qa,Operational Safety Verifications,Surveillance & Maint Observations, Engineering & Technical Support & Radiation Protection

ML20247A065
Person / Time
Site:	FitzPatrick
Issue date:	03/19/1989
From:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247A015	List: IR 05000333/1989002 ML20247A010 ML20247A037
References
50-333-89-02, 50-333-89-2, NUDOCS 8903290038
Download: ML20247A065 (18)

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e U.S. NUCLEAR REGULATORY COMMISSION Region I i Report N Docket N l License N DPR59

i ' Licensee: New York Power Authority P.O. Box 41 Lycoming, New York. 13093 Facility: James 'A. FitzPatrick, Nuclear Power Plant Location: Scriba, New York , 3 Dates: January 22, 1989 through March'4, 1989 Inspectors: W. Schmidt, Senior Resident Inspector R. Plasse r , Resident Inspector Approved by: - [ # e ,4 W tt b 9 T

   .R. Johnson, hi f/JReactor Date  .

Projects Sect 2Cf/DRP 'l

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INSPECTION SU ARY, o This inspection report discusses routine and reactive inspections.during day and backshift hours of plant activities including; management changes, operations, quality assurance, operational safety verifications,. surveillance and maintenance observations, engineering and technicalesupport,land radiation- J protection. Also reviewed were licensee event report submittals. This report' l period encompassed a total of 236 hours of direct _ inspection effort. Of that: total, 43 were backshift hours while 14.5 were deep backshift hours which_were conducted on'1/28/89, 2/12/89, and 2/26/8 INSPECTION RESULTS Previously open items are addressed in sections 3, 4, 6, 7, 8, 9 and 10.- .An unresolved item dealing with the licensee's discovery of the.high pressure coolant injection (HPCI) exhaust line filled half way with water is discussed in.section 7.b. A violation is' discussed in section 9.a dealing with the licensee's method of. controlling drawings required by the control room 1 operators. An unresolved item is identified in .'section 11 dealing with the licensee's program for performing radiological ~ surveys when running the HPCI- , turbine' . 8903290038 890322 r l' PDR ADOC 1'

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The inspector will track the following issues in a subsequent inspection report: 1) the quality of information used by the licensee to close open items (see section 1.b); 2) licensee's. review of steam tunnel cooling fan I circuitry (see section 2.c); 3) the review conducted and procedure changes for I testing of the secondary containment with the track bay door seals deflated

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(see section 6.a); 4) licensee actions taken to determine why the torus exhaust  ,

bypass valve failed to shut during an isolation test (see section 6.c); 5) licensee's program to conduct biennial procedure reviews (see section 6.d); 6) licensee's actions taken to resolve the opening time deficiency with the HPCI l turbine stop valve (see section 6.e): 7) LLRT connection fatigue failures (see

section 7.a); 8) improvements to the system used to monitor the emergency siren ,

I system (see section 8); and 9) licensee's report documenting the SRV analysis -'

(see section 10).

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DETAILS Plant Management Change and Discussions Regarding Open Safety Issues (30703) On January 26, William Fernandez was appointed Resident Manager,' replacing Radford Converse who left the New York Power Authority (NYPA). Robert Liseno, formerly Planning Superintendent, has been appointed Superintendent of Power, a position previously held by M Fernandez. The licensee has not determined Mr. Liseno's replacement for the Planning Superintendent positio On February 9, Regional Management met with the newly appointed Resident Manager and Superintendent of Power. Discussions addressed status of.NRC open safety issues. The licensee committed to continu to work with the resident inspectors to resolve these-outstanding issues. In addition, the licensee will periodically meet with the residents to update the status, to ensure timely closure of these ' ;l item l The inspectors met with Mr. Fernandez and Mr. Liseno on March 3 to l

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discuss the open items. Recently the licensee provided two packages

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to the inspector, for closing out open item >, that did not support- ; closure of the issues. Documentation to fully support resolution by- 1 the licensee has not been found. Although other packages have been observed to be proper, the licensee has committed to reviewing the information used to close items more carefully. The quality of the information used by the licensee to close open items will'be followed j in subsequent report ; 1 Operations (71707,93702) During this reporting period the unit operated at'100% of rated power, except for a January 27 reduction to 60 % to allow' investigation of a i possible condenser tube leak in the ' A' water bo ~ j i On March 2, the high pressure coolant injection (HPCI) system was i declared inoperable due to surveillance testing results on the ; turbine steam trip valve. This event is further discussed in section 6.e below. The licensee entered a Technical Specification (TS) - Limiting Condition for Operation (LCO) which' allows the plant to continue to operate for seven days as long as the low pressure coolant injection (LPCI), core spray (CS), reactor core isolation cooling (RCIC) and automatic depressurization (ADS) systems are operable. The HPCI remained inoperable through the end of the

 . inspection period. This event was reported via-EN . On February 28, the licensee discovered that the power supply terminal box on the "A" residual heat removal _(RHR) system pump was

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   ' loose and was only being held on the pump with one bolt. The Itcensee examined the other low pressure emergency core cooling system (ECCS) pumps and found that four of the six had loose terminal boxes. The licensee conservatively declared all low pressure ECCS systems inoperable and entered a TS LCO which required the plant to be placed in cold shutdown within 24 hours. Upon inspection it was determined that lock washers were not installed on the bolts for these junction boxes. The licensee installed lock washers, tightened the bolts and exited the LCO prior to commencing a shutdown. This event was reported via EN On Fcbruary 16, a Primary Containment Isolation System Group I half isolation signal occurred due to main steam tunnel high temperatur The cause of the high temperature was a loss of ventilation in the steam tunnel. Two fans are available to. cool the steam tunnel, normally one operating and one in standby. One fan was isolated and released for preventive maintenance (PM) on the breaker and fan-motor. This was the first time this PM was performed. Due to the system logic, when the fan breaker was removed from its cubicle, the operating fan tripped. No annunciator informed the operator that the fan tripped because annunciator power was lost when the breaker was removed. The inspector reviewed the licensee's critique of this occurrence. The licensee is currently reviewing the design of the fan ci rcuit ry. The resident inspector will follow this ite . Quality Assurance (35502, 92702)
. The. inspector discussed the licensee's plans for self assessment with the Site QA Superintendent. These plans are currently being assembled and are expected to be presented to the inspector in the near future. The licensee was planning an internal Safety System Functional Inspection (SSFI) to be completed on the high pressure

' coolantinjection(HPCI). system,intheSpring. Subsequent to this discussion the licensee was informed of NRC plans to conduct an SSFI in April, 1989. Because of this the licensee has not decided when they will conduct their HPCI SSF (Closed) VIOLATION 88-10-01: A TS required audit was not performed on the Radiological Environmental Monitoring Program, within the required 12 month period. The inspector verified that the missed , audit was completed on November 15, 1988. The inspector reviewed the ! Quality Assurance Instruction, QAI-18.3, which is utilized to ensure ! audits required by TS are performed. In addition, the inspector reviewed the audits scheduled for completion in 1989. No  ; p discrepancies were found. This item is closed, l l

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   . . (Closed) UNRESOLVED ITEM 88-17-03: .' Licensee to review missing limitorque operator components for 10CFR21 deportability. During pre-installation checks of a new valve, the licensee noted  4 peculiarities in the baseline signature while performing actuator  '

testing. The licensee disassemb u d and inspected the operator and identified a missing thrust bearing.- The limitorque operator was supplied by the Anchor / Darling Valve Company. Limitorque's Part 21 review committee noted that the Anchor Darling test report for.the-valve indicated a difference in the opening and closing curren Limitorque has recommended that any difference in opening and closing current be considered reason for further investigation. Limitorque censidered this an isolated case and that the problem should have

 'been. identified by Anchor Darling during the valve testin Limitorque and the licensee determined this occurrence to be not reportable under 10CFR21. No deficiencies were noted and this item is close . Security (71707, 92702) (Closed) UNRESOLVED ITEM 88-19-01: Safeguards Informatio The l  inspector reviewed the licensee's corrective actions taken in

' response to the concerns addressed in the subject inspection repor The inspector finds the licensee's action adequate. This item is-close . Operational Safety Verification (71707)

, Control Room Observations and Plant Inspection -Tours During the inspection period, the inspector made tours of control room and accessible plant areas to monitor station activities and to make an independent assessment of equipment status,' radiological .{

conditions, safety and adherence to regulatory requirement ]

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 - The inspector periodically monitored shift turnovers and found them informative to the on-coming watchstanders. Changes in status and on going maintenance of safety related equipment were discussed when appropriat General plant housekeeping was satisfactory during this perio Emergency System Operability The inspector verified operability of the following ' systems b ensuring that each accessible valve in the primary flow path.was.in  1 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' ; which might prevent fulfillment of their functional requirements: .

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      - High Pressure Coolant Injection
     -- Emergency Service Water-
      - Core Spra No discrepancies were identifie . Surveillance Observations (61726, 92702, 93702)

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 personnel, limiting conditions for operations were met, and the-system was correctly restored following the testin a .' -(Closed) UNRESOLVED ITEM (88-29-09): The inspector brought to the licensee's attention a design inadequacy found at another reactor site relating to the reactor. building track bay door inflatable seals l which are supplied with non safety related instrument air. On January 23, the inspector observed the performance 'of Temporary Surveillance Test TST-03, Secondary Containment Functional Test with . Reactor Track Bay Door Seals Deflated. The purpose of this test was: to verify the ability of the Standby Gas Treatment System (SBGTS) to maintain a vacuum of at least .25 inches of water in the secondary containment with the reactor building track bay door inflatable seals deflated. The test used one train of the SBGTS taking a suction on

,      'the secondary containment. The track bay door seals were deflated one at a time in a controlled manner. After both' seals were deflated the outer track bay door was opened. Then the outer doors to the reactor building personnel airlocks were opene In this-

' condition .28 inches of water vacuum was maintained in the secondary containment, which was satisfactor Af ter completion of this portion of the test the Shift Supervisor (SS) terminated the test as directed by the Operations Superintendent, with concurrence from the Technical Services Superintendent. A temporary procedure change was not used. .All the remaining steps were asterisked and a note placed in the remarks sections stating that the test had been secure Their justification I for termination was that the test, to that point, had demonstrated ' sufficient margin to maintain secondary containment capability with  ; the seals deflated. The intent of the. procedure, when approved fo ; performance, was to perform additional testing with al1~the inner-doors opened and the outer doors close The' inspectors were concerned with the determinations made to secure the test prior to completion. This concern was discussed with the i Resident Manager who agreed that administratively the individuals i

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O should have performed the complete procedure, or performed a temporary change to the procedure to delete the testing that was not conducted. The licensee, however, is satisfied that the most

  : conservative conditions were tested., This is because the inner track-bay doors have approximately a 1/4Linch greater gap 1than:the outer l

track bay door, when the seals are defiste The inspector had no other concerns. The. operators involved in the test understood the procedure's intent, the pr,etest brief was informative, and the test was' conducted in a cont'olled r manner. -This item is close The licensee has requested Stone and Webster Engineering' Corporation-to evaluate the test data and previous data taken during: performance ) of the secondary containment leak rate test (ST-390).and. calculate _l the margin to the,TS limit. The licensee has also committed to 1 , . update the existing secondary containment, leak rate test to be I performed with the seals deflate Stone and Webster's evaluation and the procedure. change will be reviewed in a subsequent repor , b.< On February 21, the inspector observed the performance of ST-4N, HPCI Flow Rate and Inservice Test (IST). Previously, IST. baseline data was taken at a HPCI turbine speed of 2600. RPM. The-intent of this performance was to take the 2600 RPM data and also to take additional data at 3600 RPM to establish a new baseline with the turbine operating closer to normal operating speed. ;The'HPCI pump was started and the speed established at 3600 RPM and 2600 RPM b l' utilizing three operators, one to use the hand held tachtmeter and the other to call in the speed data to the control room operator, who )

,   then adjusted the speed by throttling the test valve to the condenser l storage tank. Once the 3600 RPM speed was established, a five minute stabilization period commenced prior to data recording. .

A number of problems occurred dur.ing test performance. Initial high vibration readings on the booster and main HPCI pump:were_due to an erratic hand held. instrument which.was replaced. The operator at the r HPCI turbine also noted a steam leak coming out of the inboard side of the turbine shaft. Maintenance was called to observe and a work request was issued to correct the steam leak. The control room operator seemed somewhat confused during the. data. recording. The inspector determined that part of the confusion was due to the operator's unfamiliarity with the intent of.the temporary change to establish a new baseline, and the' lack of clarity-in the temporary-change itself. Based on the time delays caused by the problems experienced during the test, the torus level and temperature continued to increase. The torus was pumped down and.the RHR system a was placed in the torus cooling mode. The Shift Supervisor (SS) i directed the ope _rator to secure the turbine prior to finishing the j collection of data based on the problems that' occurred during the j test performance, l q o i

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I i The inspector discussed these problems with the SS after the test was secured. The inspector was concerned that the operator in the control room was somewhat unfamiliar with the procedure.. The SS felt j the operator understood the procedure and that the problems were due .J to the temporary procedure change. The SS committed to reviewing the l procedure with the operator and making any necessary procedure 1 changes to clarify it prior to reperformance of tes Later that day the inspector monitored the test reperformance.' Torus parameters were reestablished as desired and a procedure change was 't initiated to clarify the procedur The operator thoroughly understood the procedu.re and the procedure was completed satisfactorily.

L J The inspector discussed the method of establishing a new base;line , vibration levels with Technical Servicas. It was determined that the l hand held vibration instrument used by the operators was not giving the required data and that the test was to be reperformed using other instrumentation. There was no need to do the testing right away i since the vibration results at 2600 RPM were within the required j acceptance criteria, for the previous baselin On February 23, the licensee performed ST-348, Reactor Building j Exhaust Monitor Instrument / Isolation Logic System Functional and j Simulated Automatic Actuation Test. The test was unsatisfactory due to the failure of the torus exhaust bypass valve (27-M0V-117) to fully shut when it received an isolation signa The valve appeared > to stop closing due to high torque. . The,SS declared the valve inoperable. The other operable valve in'the line 27-MOV-123 was verified shut as required by TS and a s'pecial condition-' tag was placed on 27-MOV-123 to prevent valve operatio A. work request was q initiated to troubleshoot the inoperable valve. At the close of the 1 inspection period the licensee had not completed the troubleshootin The inspectors will followup the licensee's corrective actions when I comple te While reviewing the TS for Fire Protection surveillance, the  ; inspector noted that the diesel and electric fire pumps are required ' to be run to demonstrate operability weekly. When reviewing the  ; applicable surveillance tests ST-76B and ST-76C, the procedures ' incorrectly stated that the test. frequency is " monthly per technical specification and weekly per the National Fire Protection Association Codes". The inspector independently verified that the procedures I have been performed within the TS required frequenc i

The inspector was concerned that this discrepancy had not been noted

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by the operators performing the surveillance on a weekly basi I Administrative Procedure AP-1.4 requires that all procedures have a  : biennial review. The procedures undergo a human factors, i

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administrative, technical, radiological, and-quality control revie A specific step in. the review checklist is to verify that the technical specification reference and test fre y ency are correc The last revisions to ST-76B and ST-76C-were ciated April 1981 and May 1983 respectively. This discrepancy should have been identified and corrected during the biennial reviews. The inspector will review the procedures for conducting and actual results of previous biennial reviews in a subsequent repor On March 2, the reperformance of ST-4N HPCI Full Flow Rate and Inservice Test was conducted. The test was conducted to collect more vibration data on pump bearings. The Technical Services department was involved. in installing several~ vibration monitoring devices including a new computer vibration analyzer. The conduct of the test-was observed to be proper and the data' collection was well coordinated.. After the test results were reviewed it was determined' that the turbine trip valve (H0V-1) did not open within the required

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time as specified by IST data. Because of this the machine was declared inoperable. Resolution of the this valve timing issue will be reviewed in a subsequent inspection repor I Maintenance Observation (62703, 92702)

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On February 1, a steam leak developed in the Reactor Water Cleanup l System (RWCU) at a local leak rate testing (LLRT) connection to the

) main supply line. The immediate corrective actions taken by the operators to isolate the leak were satisfactory. The inspector is' l concerned with the root cause of the failure of the LLRT connectio This is the third similar failure of this kind of connection in recent tim Previously two LLRT connections in the Residual Heat Removal l System shutdown cooling lines failed. The cause of the failure was determined to be fatigue. The licensee has not determined the cause of the RWCU LLRT failure at this time. The licensee is evaluating similar LLRT connections which may be susceptible to fatigue failure and is in the process of developing a preventive maintenance program to monitor them. The resident inspector will continue to follow this

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item, On January 29, operators initiated _a work request identifying water ) running down the vicinity of-the High Pressure Coolant Injection '

  (HPCI) exhaust bowl. Due to the lagging installed, the source of the :

water could not be determined. During troubleshooting on February 8, l it was determined that the leakage originated at the HPCI exhaust 'i bowl thermocouple. At that time the{ licensee set up a standpipe to .; determine the height of water and found the HPCI turbine exhaust line ' exiting the exhaust' bowl approximately half full of water. The 4 exhaust line was drained and an operational test on HPCI was '

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    -10-performed satisfactorily. A work request was initiated to calibrate level switch, 23-LS-98, which is designed to drain the exhaust line when the HPCI turbine is not running. With the turbine not running, water in the exhaust line comes from the condensation of the steam left in the line when the machine is secured and of normal steam leakage. The licensee recalibrates the level switch and is presently continuing to monitor the HPCI exhaust standpipe level daily to backup the level switch. The resident inspector found the licensee's corrective action and compensatory measures adequate. The inspector, however, was concerned with the water in the exhaust line and the possible additional stresses that could have been applied to the exhaust piping had HPCI been operated in the as found condition. The licensee's on site engineering personnel determined that they do not have the expertise to address this concern. Corporate engineering is preparing this analysis. This item is unresolved and will be covered l  in a subsequent inspection report. (89-02-01) (Closed) VIOLATION 87-15-01: This item identified a weakness in the performance of motor operated valve maintenance procedures, in that a limit switch cover to 14-MOV-5B was improperly secured. In response to this violation the licensee committed to include this finding into the required reading file for electricians and incorporate the violation into the Motor Operated Valve Maintenance training lesson plan The inspector verified these commitments were complete This item is close . Emergency Preparedness (71707)

On January 31, Niagara Moh.awk made an ENS call due to a major loss of emergency assessment capability. The event was the N s of 11 sirens for  ! l approximately 1.5 hours on January 15, caused by an amobile accident damaging a power pole. This event was not determined to exist until the . County Sheriff's Department reviewed the monitoring system printout on  ! January 31. The continuous monitoring system of emergency sirens is a recent modification to improve assessment capability. Prior to this modification, status of the sirens could only be determined by periodic testing. Although they are required to support emergency planning for the Niagara Mohawk plants and the FitzPatrick plant, Niagara Mohawk has the responsibility to maintain the siren Presently the two utilities have an agreement to ensure that Niagara Mohawk informs the New York Power Authority (NYPA) of any changes to emergency assessment capability. NYPA has the responsibility to ensure that all 50.72 reporting requirements are met for FitzPatrick even if Niagara Mohawk is making their own repor Although the licensee was not informed by Niagara Mohawk or the Sheriff's department of the siren problem, failure to make the required 50.72 notification is an apparent violation. As allowed by NRC enforcement policy, 10 CFR Part 2, Appendix C, section V.G.1 no Notice of Violation is _ - - - _ _ _ - _ - _ _ -

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being issued since this was identified by the licensee, would be a severity level V violation and corrective actions have be3n taken. An i open item number is assigned to this licensee identified siolation solely { for tracking purposes. (89-02-02) j NYPA, Niagara Mohawk, and the County have met discussing these problems with the new monitoring system and have incorporated some procedure changes to prevent reoccurrence of this event. The County Emergency Management Director has committed to review the monitoring system alarm l printout on a daily basis. The County will inform the control rooms for l Niagara Mohawk and FitzPatrick of any changes of emergency assessment capabilitie In addition, a long range plan is to transfer the monitoring system from the Sheriff's Department to the Fire Control Dispatcher's Station in the Oswego Fire Department Headquarters. This allows the system to be monitored continuously. The dispatchers will undergo appropriate training on recognizing alarms and procedures for notificatio This transfer is in the planning stage with a goal of completion prior to the May 1989 emergency exercise at Nine Mile. The resident inspectors will continue to follow these improvement . Engineering ad Technical Support (37700, 92702) 1 (CLOSED) UNRESOLVED ITEMS 85-13-02 and 87-12-02: Over the past . several months the licensee's drawing control program has been l reviewed. Specific areas of interest were: the method of providing the control room with the needed drawings to operate the plant after a modification has been completed; the method of updating drawings in operating procedures when a modification has been completed (87-12-02); and the backlog of drawings requiring update (85-13-02).

The licensee maintains several types of controlled drawings in the l control room. These include plant layout and system drawings (FM), electrical system drawings (FE), electrical elementary drawings (ESK), GE circuit drawings and others. On site there are seven sets of these controlled drawings which require updatin . The licensee is currently unable to provide updated controlled drawings to the control room prior to a modification being turned over to the operations department. In order to provide the operators with the information necessary to operate the plant after a modification, Work Activity Control Procedure (WACP) 10.1.9 states that the drawings affected by th modification are stamped with a " REVISION IN PROCESS" stamp and the applicable modification number written below the stam This prompts the operators to go to notebooks in the control room which have the as built drawing for each modification. The drawings in the notebooks should also list any Engineering Change Notices that changed the as built information on the drawing so that the operator can identify the full extent of the modification. The six other drawing sets located on site are - _ _ _ - - _ _ - _ _ _ _ _ _ - _

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l stamped.in the same manner. To review the changes that were made by a given modification a person would have to go to the j notebook'in the control room (CR) or actually review the ' modification-fil The inspector reviewed the licensee's series 1 FEs, which include the ' safety and non safety related electrical system one line drawings, and the FMs for safety and non safety related

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fluid systems. The number of drawings reviewed was approximately one hundred. Of.these, fifty four contained

      " revision in process" stamps and some listed several modifications. Cases were'found where CR'and technical services
      . drawings were not marked with the same modification number Instances of misfiled and mismarked drawings were note Sixteen modifications' referenced on these drawing were not found to have as built modification noteboaks in the control roo The notebooks reviewed were found to contain information that is ,

not useful and could wast e operators ' time. such as actual piping - i arrangements and hanger sketches. The inspector noted the following two instances where this method of drawing control could have lead an operator to receiving' wrong information on safety related systems.

, On December 27, 1988 the inspector was walking down 120 VAC l emergency distribution panels and noted thirteen circuit breakers in.two panels (71ACA5 and 71ACBS), for heat I tracing to post accident sampling system piping that were j in the off positio The inspector reviewed the prestartup { electrical switch position. lineup and determined that the i breakers were required to be and had been in the "on" l position prior to the November 1988 reactor startup. The operating procedure OP46 switch lineup and oneline diagram also showed that the breakers should be in the "on" , positio The inspector could not find the appropriate FE i drawing (IAW) in the CR and operators could not readily tell why the breakers were off. The inspector questioned the Resident Manager at this point who said that he believed that a modification had been' completed during the outage to disconnect these breakers and leave them as

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l spare The technical services. copy of IAW showed that l modification 87-45 was an outstanding revisien. The l notebook for.this modification was in the.CR.and showed that these breakers were in fact spares. The inspector ! found that the CR copy of FE 1AW was in the place of FE IW

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and in fact was stamped with modifications pertaining to FE IW. _It was determined that these breakers were opened as part of a review of loads as discussed in section. ; below.

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   -13- On March 1, the inspector'noted that modification 87-016, which replaced the inboard RCIC steam supply isolation valve (13MOV15) was listed on the technical services but not the CR copy of FM 22A. .This modification was listed as being ap'plicable to the RHR system on FM 200 in the C The notebook for this modification contained an as built revision of FM 22A showing that the original 13MOV15 ha been electrically disconnected, left in place, renamed-13MOV15A and locked open, while the new valve (13M0V15) was -

installed just downstream. .This drawing had no ECN posted against i The SS was. asked about this as was the Operations Superintendent- It was determined'that-an ECN

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had been issued and was in the notebook which allowed for the removal and replacement of the old 13MOV15 with a new valve. . The operating procedure for RCIC OP-19, properly.- reflected the as built condition . The licensee maintains system flow diagrams and electrical one line diagrams in their operating procedures. The flow diagrams-provide the operators with the numbers'and normal position of valves that might be require to be operated and normal flow direction indications. The electrical, diagrams provide the same information as-the FEs. In order to update these drawings-the operations department reviews the modification packages that are sent to and approved by PORC to identify what OP changes are required. Work Activity Control Procedure 10.1.6 requires that I a Plant Modification Control Form be used to identify what l Operating Procedures are required to be changed for a modification and that this information should be provided to the l Operations Superintendent. Operations Department Standing Order l- requires that operating procedures be updated to reflect  : changes, The inspector has noted.several instances where this - control has not been adequat ' i As described in section a.1 above, the OP 46' drawing and ! valve and switch lineup were not correct after the completion of modification 87-4 Modi'ication 81-36 was completed on the RHR. system, whic d removed unused keep fill valves. In this instance the actual configuration was not noted on the OP-13 drawin As documented in inspection report 88-23, section 3.a.4, j the licensee failed to have OP-25 reflect the modification j made to install the alternate rod insertion syste ; 3. The backlog of modifications requiring updated drawings remains i high at approximately forty (40).

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i 4. Technical Specification 6.8. requires that written procedures and administrative policies shall be established, implemented and maintained to control modifications to: safety related components and systems. The instances discussed in sections ; a.1, a.2, b.1, b.2 and b.3 above are an apparent violation of TS- ! (89-02-03) .i

, ' The current open items 85-13-02 and 87-12-02, dealing with the j control of drawings will be closed and the issues raised by them- ' will be tracked'along with the closure of the above noted violation.

5. The licensee has taken, or plans to-take, action to correct the deficiencies noted above, A data base has been established which gives a printout of J modifications that are posted against all drawings. A J notebook with this list has been put in the CR and at other " places where controlled drawings are kept. This eliminates' the need for stamping individual drawings with the REVISION IN PROCESS stamp and the personnel errors involved in j writing on each drawing at every location the modification information.

l A long term project has been undertaken by the operations and technical services departments to upgrade the FM drawings to include the information needed by operators, such as the numbers and normal positions of valves and the directions of flow. As this effort is completed for a given system the OP drawing can be removed and the FM will stand alone as the contro11.ed drawing Since the OP electrical one line drawings are not different in content from the FE drawings the licensee is contemplating removing the FEs and letting the OP one line drawings stand alon The licensee is in the process of writing a Modification Control Manual. A procedure in this manual will document the method of updating the OP drawing The operations staff is also planning on assigning each modification to a

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senior licensed operator to be tracked through completio d .' A senior reactor operator has completed a walkdown of all electrical distribution panels in the plant and developed a list of all loads on these panels. In many cases the operator had to remove the panel cover to verify that a breaker was a spar If a question arose he researched the

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electrical drawings to ensure that the information in this i list was accurat l I The operations and technical services department have , worked together to identify the critical drawings that the operators need in the control room to support the operation of the plan The technical services department plans to review the outstanding modifications .and ensure that the notebooks for these are in the control room and contain the information that is useful to the operators. Also, any notebooks for which drawing updates have been completed will be remove The technical services department is pursuing other changes , I on site that might speed up the drawing update proces They include the use of the same type computer aided design i program as used in the corporate drawing group to provide I l ' operations department with as built drawings after a j modification has been completed. These would be the controlled drawing until the final drawing is completed and received from the corporate office.

l (Closed) INSPECTOR FOLLOWUP ITEM 84-04-05: This item addressed a concern with the licensee's action in respnnse to NRC Bulletin 79-14, dealing with pipe supports. During a subsequent field inspection by a contractor in November 1983, dimensional discrepancies between the as found condition and the as built drawings on thirteen of eighteen supports were identified. As a result of these findings the licensee committed to develop a program to inspect pipe supports against the 1 as built drawings in order to identify, evaluate, and correct any discrepancie The long term pipe support inspection program was established and subsequently reviewed by the NRC in 1985. The pipe support program was reviewed during Inspection Report 87-25. No technical problems were identified with the program. One concern raised was the delay in completion of the program. The pipe support program is scheduled to be completed during the next refueling outage, which starts in March 199 The progress of this program will be monitored by the routine inspection process. This item is close (CLOSED) UNRESOLVED ITEM 86-13-02 and VIOLATION 87-14-11: On February 8, the NRC issued Enforcement Action 88-239, dealing with environmental qualification issue The two open items listed above were combined into one Notice of Violation. These items are considered closed and the Notice of Violation issued with EA 88-239 will be tracked with a new open item number. (89-02-04)

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10. Followup of Written Reports of Nonroutine Events ('92700) The inspector reviewed the following nonroutine reports to' determine j whether the licensee has taken proper corrective actions and whether the response was adequate and met regulatory requirement The inspector-reviewed.the following item: '

      (CLOSED) UNRESOLVED ITEM 88-29-06: On March 2, the licensee submitted
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i supplemental reports for Licensee Event Reports (LER) 88-04 and 88-1 i l These two supplemental reports were committed .to in .the original

      .submittals to document the reasons for failure of eight safety relief valves to lif t within the _TS required +/ 1 % of the nominal setpoint,'

during as found bench testing. The overi_ ding factor for these failures appears to be steam cutting of the pilot valve discs, bonding of the pilot valve disc and seat,-or excessive pilot valve leakag The LERs documant that the licensee has completed an. evaluation of SRV setpoint drift that shows that the bounding conditions for an overpressure event can include a +/- 3% setpoint drift, operatton with 2 SRVs inoperable and setting of all 11 SRVs to a. single nn:ninal' value. Thes conditions are not permitted by the current TS. The licensee is planning _

     'on submitting a TS change to incorporate these new conditions. This item        '

is close . Radiological'l Protection (71707) Prior to entering the east crescent area to observe the performance of-ST-4N, discussed in section 6.b above, the inspector asked the. radiation protection office if there were any changed conditions in the.HPCI pump l room since his last tour the previous day, and was informed that there were no. changes. When the HPCI pump was started a large.stenm leak wks observed at the low pressure turbine gland, with other minor steam leakage -{ at the high pressure gland and the turbine governor ' valve packing. These  ! leaks had been observed by opert. tors during the previous run of the HPCI j pump on February 21. The inspector took several dose.' rate readings with the licensee supplied minirad. At a distance of 1 foot from the turbine ~ exhaust piping a dose rate of 50 mr/bc was observed. At-the high pressure end of the turbine an ALARA AREA sign was poste These signs are posted in an area where the dose rates are low as compared to other areas within a given space. At this sign dose rates of between 25 and 30 mr/hr were observed, while the dose rates by the HPCI booster pump were 10 to 15 mr/hr. The dose rate after the machine was secured in the area was 5

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After the test had been completed the inspector asked to see a_ radiation f survey for the HPCI pump area with the pump operating. This survey'could not be produced. The inspector asked.to see the results of the air sample

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conducted during the pump run. No air sample was taken. The inspector j i

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was told that an air sample had been.taken the day prior to 'the pump run and that no isotopes of concern were detected. The. radiation protection superintendent said that the iodine concentrations in the reactor coolant-were so low that the observed steam leakage did not.posess any internal

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dose hazard. The. external beta radiation hazard could,not be evaluated by the self monitoring personnel.in the area since.they'were using minirad which do not have the capability ~to detect beta radiatio Radiation Protection Manual Chapter 15, Radiological. Surveys, section * 15.3.2, states that the frequency of radiological surveys ~is based on the potential changes in the radiological conditions of an' are Section 1 of the same chapter requires that self' monitors obtain adequate information on anticipated radiological conditions.in the area to b entered. There is.no reason to believe that the persons entering the HPCI room on that day received information that was'different than that received by the inspector. This item is unresolved pending review, i subsequent report, of radiological practices:during equipment operatio '

           'i (89-02-05)

12. Assurance o_f Quality (40500, 71707) s This section is included to provide assessment of the licensee's oversight and effectiveness in ensuring that activities are conducted in a manner i which assures qualit ] l The licensee efforts to meet with the resident inspector to track open items'is viewed as positive and should continue. The followup-and tract.ing of these items, and review of the final resolution appear"to warrant closer attentio The Operations staff continues to operate the unit in a conservative

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manner, in accordance with Technical Specifications and operating 1 procedure . Preparation for performance of procedures with new temporary l changes could be better in light of the difficulties observed while 'j conducting JiPCI surveillance testing, i Securing of the secondary containment functional test without'using a temporary procedure change is a weakness that.should be addresse i The control of drawings used by the operators appears to be a weakness.

l The licensee has identified most of the programmatic weaknesses and appears

 'to have solutions for them. The timeliness of implementing these solutions is something that.needs continued site and corporate suppor The transfer of information to the licensee from'the Nine Mile' Point sit .;

is poor. The licensee needs to upgrade these informational ties since1the '

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. . electrical power distribution and emergency preparedness capabilities of FitzPatrick are shared with those'of Niagara Mohaw The licensee's efforts to determine the cause of SRV failure to lift within the. required setpoint bands are noteworth The licensee must ensure'that the operations and radiologicalfprotection departments understand that when a radiological condition changes,Ja-survey needs to be-conducted to evaluate condition . Exit Interview (30703)-

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At periodic intervals during the course of this inspection, meetings were1 held with senior facility management to discuss inspection scope.and findings. ;In addition, at the. end of the period, the inspector met with licensee representatives and summarized the scope and; findings of the inspection as they are described in this report.- Based on the NRC Region I review.of this. report and discussions held with' NYPA~ representatives during the' exit meeting, it was determined that this-report does .not contain information subject to-10 CFR 2.790 restrictions.- l

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