IR 05000333/1990003

Insp Rept 50-333/90-03 on 900426-0526.Major Areas Inspected: Plant Activities Including:Plant Operations,Radiological Protection,Surveillance & Maint,Engineering & Technical Support & QA & Safety Verification

ML20055D055
Person / Time
Site:	FitzPatrick
Issue date:	06/27/1990
From:	Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20055D050	List: IR 05000333/1990003 ML20055D049
References
50-333-90-03, 50-333-90-3, NUDOCS 9007030154
Download: ML20055D055 (13)

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U.S. NUCLEAR REGULATORY COMMISSION Region I

. Report No.: 50-333/90-03 L

Docket No.: 50-333 License No.: DPR-59 Licensee: New York Power Authority Post Office Box 41 Lycoming, New York 13093 Facility: James A.' FitzPatrick. Nuclear Power Plant , Location: Scriba, New York Dates: April 26 through May 26, 1990 Inspectors: W. Schmidt, Senior Resident Inspector R. P as,e, r., Resident Inspector Approved.by: . ._ Ab L #7!fe Glenn W. Yeyer, Chfef / D(te-Reactor Pfojects Section No. 18 Inspection Summary: This inspection report discusses routine and. reactive inspections of plant activities- during day and backshif t hours including:. plant operations, radio-logical protection, surveillance and maintenance, engineering and technical-support, . and quality assurance and safety verification. This period included-deep backshift and weekend inspection conducted on May 5 and 19, 199 Results An Executive Summary and an Outline of Inspection follo .

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JAMES A. FITZPATRICK NUCLEAR POWER PLANT INSPECTION REPORT 90-03 EXECUTIVE SUMMARY Operations The inspector reviewed three instances of personnel errors by operators in the area of system statu While of minor safety significance the frequency of these types of errors appeared to be increasin These issues were character-ized as one licensee identified violatio Radiological Protection While the radiological controls used during the outage were observed to be generally good, there were instances observed of an apparent lack of sensi-tivity to radiological posting Surveillance and Maintenance Outage related surveillances and corrective maintenance appeared to be well handled. This included the primary containment local leak rate testing (LLRT),. inservice hydrostatic testing, snubber functional testing and inservice inspec-tion. NYPA identified a potential flaw in a reactor -vessel head wel To address this NYPA planned to send final engineering evaluations to the NRR staff for review and issuance of'a safety evaluation prior.to startup. A non-

- cited violation was identified when an operator did not follow a surveillance procedure and failed to tag open a valve between the system being hydrostati-cally tested and the test gag Security The inspector noted one case where 'a security guard did not fully check items as required that were being allowed into an are Engineering and Technical Support NYPA took action to resolve confusion in the acceptance criteria for the pri-mary con tainment integrated leak rate testing (ILRT). Following a conference call with NYPA on unresolved issues surrounding the onsite and offsite elec-trical power issues, the NRR staf f provided a letter to NYPA which dccumented these concerns. These concerns will be handled as an unresolved ite Safety Assessment / Quality Verification The inspector identified a case where NYPA did not perform a written safety evaluation prior to implementing a control room design review modificatio The reason for this instance appeared to be a lack of coordination between site personnel and corporate licensing personne ..
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P OUTLINE OF INSPECTION Operations (MC 71707, 93702) 1.a. Review of Operations Department Critique Operations Department personnel errors, Licensee Identified Violation 90-03-0 .b. (Closed) Unresolved Item 90-02-01: Corrective actions to prevent further spurious shutdown cooling isolation. LER 90-016 revie l.c. (Closed) ' Violation 90-!!1-01: Failure to maintain SRO in control roo . Radiological Protection (MC 7.707) 2.a, An observed lack of sensi'.ivity to radiological postin .b. Radiological housekeepin . Surveillance and Maintenance (MC 61726,62703,92702) 3.a, Local leak rate testing (LLRT).

3.b. ISI hydrostatic tests. Failure to follow surveillance test proced-- ure, Non-Cited Violation 90-03-0 .c. Snubber functional testing. Evaluation of failed snubbers, F- .d. Head indication resolutio . Security (MC 71707) 4.a Routine security revie . 4.b Vital area access control . Engineering'and Technical. Support (MC 37700, 90712, 92702, 71710) 5.a. Preparations for containment integrated leak rate test (ILRT), F-2.

5.b. Review of LERs 90-13-00 and 90-15-0 .c. Unresolved onsite and of fsite power supply issues, Unresolved Item .c 90-03-0 '

l Safety Assessment / Quality Verification (MC 30703) 6.a. NYPA -performed an inadequate written safety evaluation for portions of the control room design review modifications, Unresolved Item 90-03-0 . Commissioner Roger's Visit, Other Inspections and Enforcement Action . Exit Interview Attachment A - Acronyms

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DETAILS Operations l

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The unit remained in cold shutdown during the period while NYPA conducted their 1990 refueling outag j The inspector found that several Operations Department critiques of personnel errors adequately determined causes and recommended actions to prevent recurrenc However, there -was no specific commitment ; that the recommendations, provided by the appropriate SS, would be  ; implemented. The inspector reviewed the following critiques: An operator lif ted the wrong lead during surveillance testing, resulting in an inadvertent discharge of carbon dioxide into the south emergency switchgear room. NYPA did not determine a specific. cause other than inattention to detai Corrective .I actions recommended included conspicuous labeling of the correct  ! lead and manual isolation of the CO 2 tank, during surveillance i testing, to prevent inadvertent discharg . During operation of the ESW system to support EDG testing, three l tagged open drain valves resulted in inadvertent water spray in ' the ESW pump roo The critique identified two personnel errors: 1) the tag holder did not clear the tags and close the valves following' the system tagout: boundary change to support ongoing ESW maintenance and the EDG testing and, 2) inadequate tagout log review by the SS to ensure that the ESW system was lined-up- to support EDG testin The critique identified i

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methods which could have prevented these errors including: 1) a detailed review by operators of tagout boundaries following  ; changes to support ongoing work and, 2) performance -of a system i valve lineup rather than a review of the tagout lo ! In preparation for an RHR system ISI hydrostatic test, an oper-ator failed to perform an adequate independent verification of a valve position during tagging of a drain valve. The valve was required to be tagged shu When test pressure could not be increased, an operator found that the drain valve was open while tagged shut. The critique recommended that second checking of tagout be fully independen ,

While these instances were of little safety significance, it appeared that the frequency of personnel errors in the area of system status control was increasing. NYPA committed to take action to ensure that corrective actions are taken for each of these events. Further, NYPA planned to implement a critique program to centralize the procedure i I

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and implementation of. corrective action These actions appeared adequat NYPA did not receive a notice of. violation because they identified these issues and initiated adequate corrective action NRC enforcement policy,10 CFR Part 2, Appendix C, section V.G.I. , allows licensee identified violations to not be cited. Assignment of an open item number identifies this non-cited violation solely for-tracking purpose LI NCV 90-03-01 (Closed) Unresolved Item (90-02-01): NYPA performed adequate troubleshooting and took corrective actions to prevent further spur-ious shutdown cooling isolations. The inspector observed portions of the troubleshooting and found that it was well supervised and coordi-nated. The final troubleshooting indicated that chattering of one of the two pressure switches caused the isolation signals. NYPA specu-lated that air entrapped in the sensing 1.ine could have caused the chattering. NYPA removed the switch in question and sent it to the vendor for further testing. Further, NYPA revised the procedure that calibrates these instruments to ensure proper venting prior to return to service. NYPA documented this troubleshooting and the corrective actions in LER 90-16, (Closed) Violation (90-01-01): This item dealt with the failure of an SRO to maintain control room command responsibilities as defined in 00S0-1. NYPA agreed with the violation in their May 14, 1990 response. Corrective actions taken by plant management appeared appropriate to ensure. all SR0s understand their responsibilities when they are in command of the control room. The inspector observed no

   . similiar incidents subsequent to this violatio Accordingly, the inspector closed this ite . Radiological Protection The inspector noticed seve'ral instances of a lack of sensitivity to radiological postings. During a plant . walk-through, the -inspector noted that the area outside the drywell equipment hatch was posted as a high radiation area and observed a welding technician lounging on a work box in that area. The inspector contacted RP personnel who stated that the area was. not in fact a high radiation area and that the posting was inappropriate. The following day the inspector noted that NYPA had changed the posting to a highly contaminated area. On a subsequent walk-through, the inspector noted that a welding tech-nician was asleep on the floor in this same area. A NYPA welding supervisor awoke this person when he noticed the inspector's concer _ _ _ _ _ . . . . _
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During a subsequent walk-through, the inspector noticed a person-leaning on a section of RHR SW piping covered with lead blankets and ! posted with a sign that directed personnel to keep off the piping because of varying dose rates. The inspector brought this to the i attention of the RES superintendent, who was in the area, who direc- j ted the person to mov l These three instances did not result in any significant personnel exposure. However, the disregard of the personnel for the posted radiological warnings indicated a lack of sensitivity on the worker's i par The inspector concluded that NYPA 'did not properly convey ; their expectation for radiological work to contractors and NYPA personnel, { b The -inspcctor observed generally good radiological housekeeping throughout the plan . Surveillance and Maintenance l NYPA adequately completed the testing of containment penetrations, with the exception of two drywell access hatche The inspector monitored various local leak rate tests (LLRTs) and found the testing and coordination to be proper. The total . as-found leakage was 4027= standard cubic feet per, day (SCFD), with an as-lef t. leakage of 1519 SCFD. The LLRT TS leakage limit (0.6 of the maximum allowable acci-dent leakage rate (L,)) was 3216 SCFD. Application of as-found mini- q mum pathway LLRT ' leakage combined with the result of the integrated ; leak rate test (ILRT) will determine if the as-found condition of the '

 -containment met the La limit per 10 CFR 50, Appendix Adequate corrective actions were taken when, as a result of travers-ing incore probe (TIP) system modifications, NYPA determined that i the as-built configuration of the TIP system containment penetration flanges were not in accordance with. design. The design called for one flange face to be flat with the other machined to accept two con- ,

centric o-ring The design provided for a test connection on the flange face that allowed pressurization between the o-rings. NYPA added the o-ring leakage to the ball valve leakage to determine the total penetration leakage. NYPA determined that red gasket material ' was installed in addition to the o-rings and that both flange faces had the o-ring grooves. Although the joint was not made up as designed, the integrity of the joint did not appear to be a questio The- test connection was verified to be unobstructed resulting in adequate LLRT test of the join NYPA corrective actions included modifying the joint to the required configuratio ,

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     . While observing performance of the B CS system ISI hydrostatic test, the inspector noted a minor discrepancy in that the isolation valve between the system and the test gage was not ~ tagged open. AP 2.6, Procedure for System and Component -Leak Tests, required the tagging open of any valves between the pressure source and overpressure pro-tection device or test gage The auxiliary operator performing the ;

test incorrectly . indicated that the step requiring the isolation

, valve to be tagged open did not apply, The inspector verified tFit i the' valve was open by observing the- response of the pressure gage .o ,

the stroke of the test pump. The inspector then discussed this with-the. Operations Superintendent (05). The 05 agreed that the valve should have been tagged open and stated that he would discuss the reason for having the valve tagged open with the operators conducting this testin Further, he stated that this deficiency would be cor-rected prior to the next hydrostatic test by removal of the test gage isolation valv Subsequently, the inspector observed the hydrostatic test performed on the B RHR sub-system. NYPA had modified the test rig, deleting the isolation valve to the test gage. The inspector also verified that no isolation valve existed between the test pump and the test relief valv No other discrepancies in the performance of either test were note Failure to tag the isolation valve open was a violation of the sur-veillance test. However, NYPA did not receive a notice of violation because they took adequate corrective actions prior to the end of the inspection period. . NRC enforcement policy, 10 CFR Part 2, Appendix C, section V.A. allows non-citing of isolated Severity Level-V viola-tions that are corrected before the end of the inspection perio Assignment of an open item number identifies this non-cited violation , solely for tracking purposes. NON 90-03-02

, NYPA adequately conducted the TS required snubber functional testing progra During the outage a total of seven hydraulic and three mechanical- snubbers failed functional testin Because of the fail-ures NYPA completed functionally testing 80% of the hydraulic and 40% t of the mechanical snubbers as required by TS 4.6.I.4. This TS also required the testing of snubbers installed at locations where pre- !

5, vious installed snubbers had failed their testing. One such snubber, installed on the HPCI exhaust line, failed its functional tes NYPA determined through TS Interpretation #14 that failure of a snubber to pass this functional testing, did not constitute a need to increase i the sample by 10%. The inspector found the interpretation accept-able. A snubber rod was found fractured at the connection point to the piston when a snubber on an SRV tailpipe was removed for testin NYPA had not completed engineering evaluation of th.e failed HPCI snubber or the fracture snubber rod. The inspector planned to review these engineering evaluations on these snubbers in a subsequent report, F- f

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' 5 During the week of May 1, NYPA identified. indications in a weld at

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the upper portion of the reactor vessel hea NYPA examined this - weld as part of their ISI program using ultrasonic testing (UT) from - the external surface. Visual inspection -_of the internal _ surface

,  showed_an indication open to the surface for about one inch. Initial manual UT indicated that the internal indication might have been con-nected with sub-surface indications. NYPA performed radiography and extensive, automated UT of this are Based on these examinations NYPA ground- the surface af the internal _-indication and performed a dye penetrant and magnetic particle test to prove that this indica-tion did not connect to a sub-surface fla The NRR staff held a meeting on May 17 in NRC headquarters to discuss the _ indications. NYPA performed fracture mechanics analysis of two sub-surface-indications and provided this analysis during the week of May 21 to the NRC staf f. The NRC staff planned to issue a safety evaluation to address this issue prior to reactor startu . Security The inspector observed personnel and vehicle searches prior to entry to the protected area. The security personnel carried out these pro-cedures properl , The - inspector noted one instance of instrumentation being allowed into an area without being specifically inspected as required by a security guard. Review of this event showed that_the guard had dis-cussed the items to be brought into the area with radiation protec-
 ' tion personne The inspector observed the guard talking on ' the radio,-in the general area at the time of entry, but not ensuring that only the specified equipment = was being allowed into the are The inspector later determined that the guard was communicating the fact that the- access to the area was open to the security command cente This appeared to be an isolated case, for which NYPA security took adequate action to prevent recurrenc . Engineering and Technical Support The inspector reviewed TS Interpretation #15 written to support th planned ILRT and found it to be acceptable. TS 4.7. A.2.a.8 requires that the leakage rate acceptance criteria at peak pressure shall be less than 0.75 of the maximum allowable accident leakage rate (L,)

and not greater than the containment design leakage rate (Ld ). L d-was 0.5 weight percent of containment air per day at the test pres-FSAR section 14.6 evaluated the design basis LOCA and incor-

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sur I porated an L, of 1.5 weight percent / day. Based on the above NYPA'has interpreted TS 4.7.A.2.a.8 to mean that the measured containment leakage rate (L,,) during the ILRT shall be less than 0.75 L, and

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d less than 0.5 weight percent / da )

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L The confusion with this TS has been brought up numerous times since-initial containment testin NYPA submitted a TS amendment, dated January 16, 1990, to make the TS consistent with 10 CFR 50, Appendix ! J. This change requested the elimination of the. L , and establishes d a design basis leakage rate (L,) of 1.5 weight percent /24 hour Further, this would establish a test acceptance criterion of 0.75 L, 1 (1.125 weight percent / day) at the test pressure P,. The inspector had a concern with this amendment in that there was no documentation available to verify the acceptability of the maximum allowable accident leak rate of 1.5 weight percent / day (at accident conditions) with respect to the maximum allowable test leak rate (at test conditions). NYPA was reviewing this question. The inspec+.or j

'will review this in a subsequent inspection of the ILRT, F- l The inspector reviewed the following LERs and found the information f provided to-be adequat The infor ation in parentheses indicates the event date and the SALP functional area to which the report -

applie (April 8, 1990, Operations); Isolation of Shutdown l Cooling Due to Jumper Falling Off.'

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90-15-00 ( April 20,1990, Operations); Missed SRM Surveillance j During Replacement of LPRM ' On May 10, the NRC and NYPA staf fs held a conference call to discuss several outstanding issues dealing with onsite and offsite electrical :. power supplies. By letter dated May 18, 1990, the NRC staff provided ; these concerns to NYPA. The concerns dealt with the actual voltage ' seen at the 600V busses, the phase angle differences when transfer-ring busses, and- long-term corrective actions and coordination 'with ; load dispatche Closure of these issues will be tracked with an' Unresolved Ite .

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6. Safety Assessment / Quality Verification j NYPA did not have a written 10 CFR 50.59 safety evaluation prior to - implementing portions of a modification to improve the human factors 2 aspects of instrumentation in the control and relay rooms. In early i April 1990 NYPA contacted the senior resident inspector and the NRR project manager to discuss planned instrument range and scale changes to instruments listed in TS Table 3.2-6. These changes, per modifi- ! cation 87-61, entailed; rescaling of torus water level instruments to be consistent with E0P conditions, rescaling drywell and torus pres-sure instruments to read in psig vice psid, and removal of drywell pressure instrumentation to be compensated for by other installed g l !* l I

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s accident instruments. NYPA stated-that they aiu not feel a TS amend-ment was necessar The inspector and project manager stated that NYPA should comply with 10 CFR 50.59 and that as long as the safety evaluation for the modification adequately addressed the reasoning : behind this discussion, it would be acceptable. Based on these con- i

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versations NYPA generated a telephone conversation memo stating that the modifications were covered under 10 CFR 50.59. The inspector found this characterization acceptable, j On May 15, the inspector requested the safety evaluations for these i modifications (SE 89-131, dated January 24,1990 and SE 90-12, dated February _ 21,1990). The cover sheet for each evaluation stated that a TS change to table 3.2-6 was required; however, the next section stated that the TS amendment was not necessary prior to implementa-tion. SE 89-131 was clear what would require the TS amendment,-which

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I was changing of narrow and wide range torus water level scales to be ' consistent with indications used for E0Ps. SE 90-12 was unclear as i to what required a TS change. This SE dealt with changes in scale i and ranges for torus and drywell pressure and differential pressure and removal of two drywell pressure instruments. In neither case ! did the SE state why TS changes were not required. prior to implementatio ! The inspector reviewed Modification Control Manual Procedure 4, Safety Evaluations (MCM-4). Section 7d stated that an evaluation must be made by the corporate licensing director whether a TS amend-- ment was needed prior to implementatio The procedure further-required documentation of this evaluation and maintenance of the-documentation with the safety evaluations. The inspector contacted l the BWR licensing director and the onsite responsible engineer to . obtain this document. Both stated that the telephone conversation ! memo which stated that NYPA was going to perform the modification in 5 accordance with 50.59, was the appropriate documen . 1 -j The inspector did not find this acceptable since 10 CFR 50.59 requires review for the need of a TS change before implementation-of a modification. The inspector stated to the TSS that if NYPA had j adequate engineering basis to reach a decision that a TS change was not necessary, the decision and engineering basis should have been documented prior to implementing the modification. NYPA committed to document adequate safety evaluations prior to reaching a condition when the TS required these instruments to be operable. The inspector considered that this represented an unresolved item. 90-03-0 .

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, Commissioner Roger's Visit, Other Inspections and Enforcement Actions On May 22, Commissioner Kenneth Rogers visited the site. During this visit he . discussed various aspects of plant operations and mainten-ance with the NYPA staff and NRC resident inspector ' Inspection Report 90-80, Maintenance Team Inspection, April 30 through May 11, 1990, Inspection Report 90-17, Routine Radiation Protection, May 7 through May 11, 1990, On May 10, the NRC issued a Severity Level III Notice of Violation and a proposed 575,000 Civil Penalty to NYPA based an. unplanned per- t sonnel exposure to Na-24 on March ' Exit Interview At periodic' intervals during the course of this inspection, meetings were held with sen;or facility management to discuss inspection scope and find ;

ing In addition, at the end of the period, the inspectors met with licensee representatives and summarized the scope and finaings of -the inspection as they are described in this repor _ . . . _--- ---

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     -ATTACHMENT A
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Acronyms- i ALARA- - - - As Low as Reasonably Achievable:

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ASS- - Assistant Shift Superviso a-1 J CS- -

   . Core Spray' System
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CAM -1 Containment Air Monitor

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ECCS - Emergency Core Cooling. System j i EDG- - -

   . Emergency Diesel. Generator-   '

g E0P -- - Emergency Operating-Procedures EP- - Emergency Plan-

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BWR Owner's' Group Emergency Procedure Guideline a

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Emergency Service Water l

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HEL High Energy Line Break ,

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High Pressure Coolant Injection System I FFD -

   : Fitness for Duty
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Inter Granular. Stress Corrosion .ig I&C- - Instrumentation and Control y

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ISI - lii-Service Inspection IST - In-Service' Testing s

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Licensee Event Report LLRT - Local Leak Rate' Test . . MOV - Motor Operated Valve 1

   -Nuclear Regulatory Commission
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NRC NYPA - New York Power Authority

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Operations Department Standing Order

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OR~ - Occurrence Report ~! PdIV - Primary Containment Isolation Valve

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Preventive Maintenance PMT - Post Maintenance Testing PORC - Plant Op s ations Review Committee PT Protective Tagout Request QA-

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Quality Assurance QC

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Quality Control RBCCW - Reactor Building Closed Cooling Water RCIC' - Reactor Core Isolation Cooling System RHR - Residual Heat Ren. oval System RP - Radiation Protection RPS - Reactor Protection System \ s RWCU -

  . Reactor Water Cleanup System i RWP -
  ' Radiation Work Permit SALP -

Systematic Assessment of Licensee Performance

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, SPDS' - Safety Parameter Display System 1 .SRC - Safety Review Committee SRO - Senior' Reactor Operator },'

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SS Shift Supervi or ST- - Surveillance Test STA - Shift Technical Advisor SW - Service Water T5 - Technical Specification TSLCO - Technical Specification Limiting Condition for Operation Technical Specification Action Statement

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TSAS UE - Unusual Event i

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