IR 05000333/1990013
| ML20034A906 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/02/1990 |
| From: | Anderson C, Thomas Koshy, Julio Lara NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034A901 | List: |
| References | |
| 50-333-90-13, NUDOCS 9004250046 | |
| Download: ML20034A906 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-333/90-13 Docket No. ~50-333 License No. pDR-59 Licensee:
New York-Power Authority Facility Name:
FitzPatrick Nuclear Power Plant Inspection At:
Scriba, New York Inspection Conducted:
February 20 - March 2,1990
[R TKe b
.,7" 2 f-f0 Inspector:
N T. Koshy, Sr. Reactor Engineer, Plant Systems date Section, EB, DRS
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J. F.~ Lara, Reactor Engineer, Plant Systems date Section, EB, DRS Approvt j !y:
d&o-I C. J/ Anderson, Chief, Plant Systems Section, date Engineering Branch, DRS Inspection Summary:
Inspectio.i Report No. 50-333/90-13 Areas Inspected: Routine announced inspection of the licensee's fire' protection /
prevention program activities. The licensee's actions taken in response to NRC SSFI inspection (89-80) were also reviewed.
Results: Of the areas inspected, one violation was identified with respect to-inaccurate statements made in a technical specifications change submittal to-the NRC.
9004250046 900413 PDR ADOCK 00000333 O
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DETAILS
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1.0 Persons Contacted
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1.1 New York Power Authority (NYPA)
- Baker, B., Maintenance Superintendent
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Bostain, T., Electrical Maintenance Engineer Dowiot, R., Plant Engineer.
- Fernandez, W., Resident Manager Guaquil, L., Director, Project Engineering i
Heath, R. A.,-Fire Protection Supervisor
- Liseno, R., Superintendent of Power
- Locy, R., Operations Superintendent
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- Moody, K., Plant Engineer
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Moskalyk, T., Plant Engineer Supervisor
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Patch, R., Quality Assurance
- Ruddy, D., Plant Engineer Supervisor Scott, J., Quality Assessment Specialist
- Tasick, G., Quality Assurance Superintendent
Toth, S., Acting Directcr, Licensing Tyner, G., Fire Training Specialist Vandermark, D., Quality Assessment Supervisor
- Vargo, G., Radiological and Environmental Services Superintendent-
- Walz, V., Technical Services Superintendent 1.2 U.S. Nuclear Regulatory Commission (NRC)
- Plasse, R., Resident Inspector
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- Schmidt, W., Sr. Resident Inspector
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- Denotes those present at the exit meeting held on March 2, 1990 2.0 Fire Protection / Prevention Program (64704)
2.1 Follow-up of Previous Inspection Findings (Closed) Unresolved item (50-333/89-07-02) This item pertained-to the lack of fire barrier inspections within the required Technical Specification time requirements. The missed inspections were due to an inadequate surveillance test which was based on a new fire-protection reference manual completed by a contractor. This manual did not identify all the required fire barriers since it only included those required by 10 CFR Appendix R.
The. licensee established fire watches until the required fire barriers were inspected.
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The licensee has revised the fire protection reference manual to include all fire barriers.
This manual (dated October 1989) was reviewed by the fire protection staff to verify its completeness and accuracy.
The inspector reviewed the manual and verified by means of a walkdown of the diesel generator room that fire barriers, other than those required by Appendix R, were included
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in the revised manual.
Selective surveillance procedures which implement the barrier inspection activities, were reviewed to verify that they al'so included
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all required fire barriers.
Based on the licensee actions, this item is
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considered closed.
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2.2 Program Review
The inspector reviewed documents in the following areas of the fire orevention program to verify that the licensee had developed and implemented adequate procedures consistent with the Final Safety Analysis Report (FSAR), Fire Protection Hazard Analysis, and licensee commitments.
The documents reviewed, the scope of review, and the inspection findings for each area of the program are described in the following sections.
2.2.1 Program Administration and Controls for Ignition Sources and Combustible Materials The inspector reviewed the following administrative procedures to verify that-the fire protection program, as described in the FSAR and other licensing documents, is properly implemented.
'The following documents were reviewed:
FPP 1.0, " Fire Protection and Prevention Program"
AP 1.6, " Fire Protection Program"
WACP 10.1.10. " Control of Combustibles and Flammable Materials"
FitzPatrick Fire Hazard Analysis
The scope of the review was to ascertain that:
Personnel are designated for implementing the program at the site;
Qualifications are delineated for personnel designated to implement the.
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Special authorization is required.for the use of combustible, flammable or
explosive hazardous material in safety-related areas; Prohibition exists on the storage of combustible, flammable or explosive
hazardous material in safety-related areas; l
a Removal is required of all wastes, debris, rags, oil spills or other
l combustible materials resulting from work activities-at the end of the job
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t All wood used in safety-related areas is required to be treated with flame
retardant; Periodic inspections are specified for accumulation of combustibles;
Housekeeping is required to be properly maintained in areas containing
safety-related equipment and components;-
Requirements exist for special authorization (work permit) for activities
involving welding, cutting, gritiding, open flame or other ignition sources and that they are properly safeguarded in-areas containing safety-related equipment and components; Prohibition on smoking exists in safety-related areas, except where " smoking
permitted" areas had been specifically designated by plant management;.
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Fire brigade organization and qualifications of brigade members are I
delineated; Fire reporting instructions for general plant personnel are developed,
Periodic audits are required to be conducted on the entire fire protection
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program; and, Fire protection / prevention program is included in the licensee's QA program.
- The review of these documents did not identify any procedure weaknesses.
The inspector noted daily interactions between fire protection and the operations-staff due to a recent reorganization which placed the fire protection program responsibilities under the operations department. The above areas were~ reviewed with inspection observations described below.
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2.2.2 Equipment Inspection and Tests
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The inspector reviewed selected documents to determine if the licensee had developed adequate procedures which-established inspection and testing require-ments for the plant fire protection equipment. The inspector _also reviewed inspection / test records to verify compliance with Technical Specifications and with established procedures.
Documents reviewed are listed below.
I ST-76A, " Fire Protection System Weekly Checks"
ST-76B, " Electric Fire Pump Operational Check"
ST-76C, " Diesel Fire Pump 76P-1 Operational Check"
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ST-76D, "High Pressure Water and Cardox Fire Protection System Valve
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Posi tion ' Check" ST-76J11, " Heat Detector Functional ~ Test - RCIC Pump Area"
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ST-76J19, " Smoke and Heat Detector Functional Checks -
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ST-76J23, " Diesel Fire Pump 76-P-1 Performance Test"
ST-76J24, " Electric Fire Pump 76P-2 Performance Test"
ST-76J45, " Heat Detector Functional Test-Water Curtain Boundary Number 1"
ST-76V, " Fire Damper Operability Test"
During the review of test records,_the inspector noted that test abnormalities and deficiencies were adequately reviewed and resolved by retest, when necessary.
The inspector also reviewed the maintenance request list to determine the fire protection equipment that is. inoperable. The fire protection equipment that requires maintenance has only a minor impact on plant safety.
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No unacceptable conditions were identified.
2.3 Fire Brigade Training 2.3.1 Procedure Review The inspector reviewed the fire brigade training program to verify that this program includes:
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Requirements for announced and unannounced drills;
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Requirements for brigade training and retraining at prescribed frequencies; c.
Requirements for at least one drill per year to be. performed on a "back shift" for each brigade; and, d.
Requirements for maintenance of training records.
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The inspector reviewed training records for several fire brigade members to
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verify that the above requirements were being met.
The inspector also observed
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the fire drill conducted on February 23, 1990.
The fire brigade responded with
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proper equipment gear to the simulated fire area.
During _this review, no deficiencies were identified.
2.3.2 Records Review l
The inspector reviewed the training records of the fire brigade members for
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1989 to ascertain that they had attended the required quarterly training,
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participated in a quarterly drill, and received the annual hands-on fire extinguishment practice.
The inspector reviewed the following documents:
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ITP-13, " Fire & Rescue Training"
Fire Protection Training Modular Systems
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The above reports documented training requirements and lessons for fire brigade members.
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2.4 Quality Assurance Audits The licensee's Fire Protection Program requires that annual, biennial and
'i triennial audits of the fire protection program be conducted..The inspector reviewed the reports of the following audits conducted by the Quality Assessment Department to satisfy program requirements.
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1988 Triennial Fire Protection Audit
1989 Fire Protection Audit
Audit No. 683 dated 12/33/89'
Audit No. 684 dated 1/9/90
Audit No. 687 dated 1/8/90
The inspector noted that the documented audit findings and observations were thorough and addressed program requirements.
Selected responses to the audits were reviewed and found to be acceptable.
2.5 Fire Protection Facility Tour The inspector examined fire protection water systems, including fire pumps, fire water piping and distribution systems, hydrants and contents of hose houses. The inspector toured accessible vital and non-vital plant areas and examined fire detection ano alarm systems, automatic and manual fixed suppression systems, interior hose stations, fire barrier penetration seals, and fire doors. The inspector observed _ general plant housekeeping conditions and randomly checked tags oi' portable extinguishers for evidence of periodic inspections.
No deterioration of equipment was noted.- The inspection tags attached to extinguishers indicated that monthly inspections were performed.
The inspector also examined several valves to verify that positions were as specified in surveillance procedures for water systems.
No unacceptable cunditions were identified.
3.0 Follow-up of Previous SSFI Findings (Update) Violation (50-333/89-80-01) Susceptibility of Reactor Building Closed Cooling Water System (RBCCWS) to high energy line breaks.
This system provides cooling water to two non-safety related components; drywell coolers and recirculation pump motor coolers.
The piping to these loads was not protected against the effects of high energy line break. A potential break could provide a leakage path to the reactor building and the lake.
-In the light of this NRC finding, the licensee conducted an engineering review of the RBCCW installation.
The licensee concluded that the piping as installed could withstand a high energy line break.
During this review process, the licensee staff evaluated the system capability to withstand LOCA temperatures.
This resulted in identifying 3 piping supports which should be stiffened to
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withstand seismic forces under elevated temperatures. This modification is currently scheduled to be implemented during the 1990 refueling outage.
This
' item remains open pending NRC review of licensee corrective actions.
(Clo:;ed) Violation (50-333/89-80-02) This violation contains four examples of-inadequate procedures, a.
This example pertains to inappropriate calibration of the Diesel Generator Day Tank Level Switches.
Licensee procedure F-1MP-93.6 Revision 2 did not relate the switch actuation to a known level in the tank.
In response to this NRC finding, the licensee has revised the subject procedure to include:
(1) level instrument calibration to a standard, (2) a three point calibration for desired accuracy, (3) a requirement to record the as-left reading, and (4) a verification of level switch operability based on the correctly calibrated level instrument, b.
The second example pertains to inadequacy of procedure F-0P-22.
This procedure was determined to be inadequate in that the' instructions for connecting the backup air bank did not address the isolation of a defective bank of starting air.
In circumstances when the on-line air bank has been depleted, the on-line air bank isolation valve should be closed before the standby air bank isolation valve is opened to prevent losing air from the standby air bank to the depleted on-line air bank.
This situation was not addressed in the subject procedure since it only addressed the circumstance of normal transfer of the air reservoirs.
The licensee has revised the subject procedure to include actions to be taken to properly isolate the affected air reservoir prior to transfer, c.
A third example pertains to the inadequacy of Operations Department Standing Order-0D50-17, " Auxiliary Operator Plant Tour and Operator Logs,"
in which the specified minimum acceptablo voltage of 90 volts _for the Class IE 125 Vdc battery could render the equipment inoperable.
In re-sponse to the violation, the licensee stated that the use of 90 volts as the minimum acceptable voltage was due to an error caused by association with the minimum voltage input to the station 'UPS system, which is 90 volts.
The subject procedure has been revised to-incorporate acceptable voltage levels for the 125 Vdc battery, d.
The fourth example pertains to inadequacies in the diesel generator annunciator response procedures in that no specific-directions were given to the operator to respond to-engine and fuel oil' abnormalities.
The licensee revised the subject procedure to provide the operators specific guidance to determine the root problem associated with the annunciator alarm.
Based on the licensee's corrective actions, this violation is closed.
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(Closed) Violation (50-333/89-80-03) This violation pertained to the inadequate
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drawing control of electrical drawings resulting in several discrepancies between actual equipment installations and those specified by controlled drawings.
Discrepancies included errors in circuit breaker sizes and motor horsepower ratings.
The licensee review identified discrepancies and the licensee resolved them by revising appropriate drawings.or by installing correct equipment where required.
In addition, the licensee completed a walkdown of all ac and de
motor control centers to collect as-built data.
This data will be compared against one line drawings to verify the adeauacy of the installed equipment and resolve any discrepancies. The licensee indicated that the walkdown identified other drawing discrepancies. These discrepancies were subsequently resolved.
Based on the. licensee's corrective actions, this violation is closed.
(Closed) Violation (50-333/89-80-04) This violation pertained to the failure to establish procedures for periodic calibration and testing of safety related
alarm devices, sensors and protective circuits.
Licensee corrective actions with respect to the individual components are described below, a.
At the conclusion of the SSFI inspection, Class 1E 125.Vdc circuit breakers and battery charger voltage sensing relays had not been subjected to periodic testing and calibration as required.
In response to this finding, the licensee implemented a program for periodic-testing of de circuit breakers.
Battery Motor Control Center (BMCC) 3 circuit breakers were subjected to testing during the 1989 fall maintenance outage in accordance with procedure MP-200.16. " Maintenance and Subcomponent Replacement of GE 7700 Series DC MCCs (BMCC)." The inspectors reviewed the procedure and associated test
. results for the tested circuit breakers.
The results were reviewed with maintenance engineers to resolve inspector questions.
The inspectors did not identify any deficiencies in the licensee's program for routine testing of DC circuit breakers, b.
The licensee has implemented procedure IMP 71.23, " Station Battery Charger 71BC-1A(18) Undervoltage and Ground Alarms", to calibrate the battery charger voltage sensing relay every two years.
The inspectors reviewed the procedure, acceptance criteria and calibration records for the calibra-tion performed during-the 1989 maintenance outage. The inspectors did not identify any deficiencies in the calibration procedure or calibration performed.
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The surveillance testing of the backup air supplies for containment isolation valves in the reactor building closed loop cooling water system (RBCLCW) was inadequate to demonstrate operability.
Specifically, the testing did not address one aspect of the backup air supply's fundamental function of holding the valves shut for the duration of an accident.
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licensee implemented a modification to provide the RBCLCW valves with a reliable source of pneumatic supply to maintain a constant makeup to the accumulators. The modification consisted of installing a safety-related pneumatic supply line from the nitrogen supply system to the RBCLCW containment isolation valves.
The safety-related supply ensures that the valves will remain closed during an accident.
Based on the licensee's corrective actions, this violation is close *
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(Closed) Unresolved Item (50-333/89-80-08) Reactor Building MCC Enclosure Cooling Unit These MCC enclosures shield the MCCs from the adverse effect of a LOCA. A cooling system is installed to moderate the temperature inside enclosures during normal-and abnormal environment.
The SSFI inspection rever. led concerns on the adequacy of the cooling system for the enclosure.
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In order to address this concern, the licensee generated calculation JAF 89-019 which addressed the various heat loads during design bases events and reevaluated the cooling system adequacy.
The inspectors reviewed this calculation and concluded that the present cooling system is adequate.
No discrepancies were observed.
This item is closed.
(Closed) Unresolved Item (50-333/89-80-09) This item pertained to whether there was sufficient drainage in the EDG rooms to prevent spillover into the adjacent diesel generator rooms during maximum sprinkler flowrate during a (
postulated oil fire. The inspectors reviewed SWEC calculation No. 14620-8-9017-1 which concluded that six floor drains would be adequate to handle the water from the actuation of the sprinkler system.
The calculation'results indicated that the drainage system piping design was such that water would not back up into other areas. The inspectors confirmed that all drains are unplugged to allow water drainage.
NRC review of the calculation did not identify any discrepancies. This item is closed.
(Closed) Unresolved Item (50-333/89-80-11) This item pertained to' operating the 600 volt system at higher voltages and the potential effect on the short circuit analysis for the 600 volt system and the capability of the 600 volt equipment to operate satisfactorily.
The licensee evaluated the effect on equipment of operation at system voltages of 635 volts.
It was concluded that operating 600 volt equipment at a higher voltage (635 volts) could not be supported based on equipment ratings.
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the licensee revised the operating procedures and adjusted the 71T-4 transformer.
tap changer to maintain the 600 volt buses at 590-600 volts.
In addition, the licensee installed alarms to alert operators of unacceptably high voltages on the 155 kV and 345 kV systems.
The licensee completed calculation No.14620-E-9012-5 Rev-O, " Fault Current
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Calculation for 600 V Emergency Load Centers and.600 V Emergency MCCs." Results indicated that the 600 V load centers and MCC circuit breakers-are rated such that they will be able to withstand and clear postulated fault currents.
The calculation was based on a system voltage of 600 V which is within the system voltage administrative limits. This item is closed.
(Closed) Unresolved Item -(50-333/89-80-15) This item pertained to the lack of
a formal written procedure to perform sampling of diesel generator lube oil.
The licensee established procedure MP-52.17, "EDG Lube Oil Sampling" which describes acceptable methods of taking lube oil samples. This item is close F
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(Closed) Unresolved Item (50-333/89-80-17) This item pertained to the guidance provided to plant personnel for the storage of portable equipment.
Licensee requirements were delineated in a memorandum which allowed storage of portable equipment,within four (4) feet of safety related equipment.
This guidance also applied to equipment on wheels.
The inspection team questioned the basis of
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not requiring wheels to be chocked to limit movement during design bases seismic events. The licensee included'in procedure WACP 10.1.7, " Housekeeping and Cleanliness Control" requirements for the storage of equipment near safety related equipment.
Procedural requirements include requiring.that equipment with wheels have the wheels chocked to prevent. rolling.
This item is closed.
(UpdateLUnresolved Item (50-333/89-80-18) This item consists of five parts, a.
This part pertains to the setpoints for the fuel. oil day tank low-level alarms being below the start setpoints for both the lead and backup fuel oil transfer pumps. The licensee plans to implement a modification during the 1990 outage to provide the alarm when the first pump is out of service.
This part of the unresolved item is closed.
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This part pertains to the fuel oil day tank level switch positions being located in such a manner that there is insufficient fuel for diesel generator operation at full load for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> as specified in the Technical Specification Bases.
The licensee submitted an application for an amend-ment to the technical specifications (JPN-89-082) to clarify the design bases of the diesel fuel oil day tanks and storage tanks. This part of the unresolved item is closed, c.
This part pertains to the use of all the fuel filters in the operational mode. That is, operating in the "BOTH" filter mode does not allow backup lineup if any one of the filters'were to become clogged.
The-licensee is planning to address this problem in the forthcoming outage in 1990.
Additionally, the team noted conflicting information regarding the fuel filter capacity.
One excerpt from the vendor manual described the filter to be " designed to filter 100 gallons per hour with clean elements." A drawing of the filter unit from the same manual stated 5 gallons per minute.
Furthermore, this drawing did not specify single or double filter operation. The licensee contacted.the supplier of the equipment and confirmed that 100 gallons per hour is based on a 1 psi pressure drop.
The manufacturer, Purolator, rates the filters according to the'above criteria.
This requires the filters to be aligned in the "both" mode for the engine driven and de motor driven fuel supply systems. This alignment has been the practice at FitzPatrick.
The licensee's proposed modifica-tion F1-88-2444 for 1991 consists of a fuel filter assembly replacement with differential pressure indication, allowing filter swapping and change-out during diesel generator operation.
This part of the unressived item will remain open pending implementation and NRC review of the modificatio *
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This part pertains to the quality control of diesel generator fuel oil.
During the 1989 SSFI, the team identified an apparent error in the licensee's technical specification requirements for the diesel fuel as compared with t
ASTM D975 standard.
The current ASTM standard limit for water and sediment is 0.05% and 0.01% for ash whereas the-licensee's technical specification
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limit is 0.5% for water and sediment and 0.5% for ash. At the conclusion of the SSFI, the licensee agreed to evaluate the discrepancies to determine
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if a technical specification change was warranted.
On December 15, 1989 the licensee submitted.to the NRC proposed changes to the technical specifications regarding diesel fuel quality limits to incorporate the present ASTM standard limits. Within the enclosed Safety Evaluation, the licensee twice stated that applicable plant procedures had-been revised to incorporate the new limits. However, as of February 22, 1990, plant procedure PSP-7, " Diesel Fuel Oil Sampling anct Analysis" Rev. 4, had
not been revised to incorporate the new limits.
In response to the inspector's concerns, on February.23,-1990 the licensee revised procedure PSP-7 to incorporate the new limits as specified in their December 15, 1989 submittal. The inspector reviewed oil analysis records taken from the EDG and diesel fire pump oil tanks.
The inspector noted that the results for the "B" and "C" EDG tanks indicated that the ash parameter for the month of December exceeded the ASTM limit.
However, the parameter was less than the Technical Specification limit. The January 1990 records indicated that all parameters were within the ASTM limits.
Based on this finding, the inspector had no immediate. concerns as to the quality of the fuel oil.
Nevertheless, failure to revise the procedure, as specified in the licensee's proposed technical specifications change submittal, is a violation of NRC regulations which require that information provided to the Commission be complete and accurate in all' material aspects (50-333/90-13-01).
At the conclusion of the inspection,_the licensee stated that the inaccurate statements in the technical specifications change submittal were due to miscommunication between different NYPA groups as to which procedures were actually revised.
During the 1989 SSFI,.the licensee prepared-a Receipt Inspection Procedure-(QAI 7.0, Appendix 7.9) to take onsite samples of new fuel oil.
The licensee stated that this procedure was apparently confused with PSP-7, which was never revised, in preparing the licensee's submittal.
This part pertains to the lack of testing the diesel generator to verify e.
the fuel consumption rate. The licensee performed a consumption test
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during the 1989 maintenance outage.
However, the collected data did not provide the necessary information to accurately determine the consumption rate. Therefore, the licensee intends to perform a test during the 1990 outage.
This item will remain open pending completion of the test and-review of the result..
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4.0 Exit Interview At the conclusion of the inspection on March 2, 1990, the inspectors met with
.I the licensee representatives denoted in Section 1.0.
The inspectors summarized the scope and results of the inspection at that time.
At no time during this' inspection was written material given to the. licensee.
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