IR 05000333/1992099
| ML20149D598 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/02/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20149D572 | List: |
| References | |
| 50-333-92-99-01, 50-333-92-99-1, NUDOCS 9309210092 | |
| Download: ML20149D598 (30) | |
Text
September 17, 1992
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 RcSponse to initial SALP Report Reference:
NRC letter, T. T. Martin to R. E. Beedle, dated July 7,1993, regarding " initial Systematic Assessment of Licensee Performance (SALP) Report No. 50-333/92-99."
Dear Mr. Martin:
This letter provides the New York Power Authority's response to the initial Systematic Assessment of Licensee Performance (SALP) for the James A. FitzPatrick
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Nuclear Power Plant for the period of April 19,1992 through April 17,1993.
The Authority agrees with the NRC's assessment of performance. The initiatives
implemented through the FitzPatrick Results improvement Program (RIP) have been effective, as recognized in the report.
The Power Authority is committed to continued improvements in performance and is confident that the cited weaknesses are being addressed through capital improvements, y
engineering organizational improvements, the Nuclear Generation Business Plan, as well as the FitzPatrick RIP. The Authority's detailed comments on the initial SALP are contained in the attachment to this letter.
If you have any questions, please contact me.
Very truly yours,
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, DC 20555 Office of the Resident inspector
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U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 l
Mr. Brian C. McCabe Project Directorate 1-1 Division of Reactor Projects - l/II U.S. Nuclear Regulatory Commission
Mail Stop 14-B2 Washington, DC 20555
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F New York Power Authority
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James A. FitzPatrick Nuclear Power Plant
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Attachment to JPN-93-057
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Y RESPONSE to INITIAL SALP REPORT Operati_ons The Authority agrees with the assessment of perfomiance in the operations area, and is
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encouraged by the strengths cited. As noted in the report, the weaknesses identified
during the period were effectively corrected and FitzPatrick RIP initiatives are in progress
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to prevent similar occurrences. These include procedure upgrades, use of procedure
validation and the continued emphasis on attention to detail, self-verification, and a
conservative "do it right the first time" operations philosophy.
ELafiological _ Controls The Authority agrees with the assessment of the radiological controls area. The Authority appreciates the NRC's recognition of continued good performance in several areas.
As stated in the report, radiological incidents are now addressed in the plant wide DeviatiorVEvent Reporting system. This system has been effective in improving the tracking and close out of associated corrective actions. The procedures that control implementation of the Radiation Work Permit program have been improved, and further procedure improvements are being made. The need for procedure adherence in accordance with JAF Administrative Procedure 02.06, " Procedure Use and Adherence,"
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continues to be stressed.
The program which maintains worker radiation exposure as low as reasonably achievable (ALARA) continues to improve. At the request of the Authority, the Institute of Nuclear
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Power Operations (INPO) performed an assist visit to the FitzPatrick plant in the ALARA area. Recommendations from the assist tearn will be used to further enhance the i
program.
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l The Authority is confident that the stated changes and the radiological control portion of j
the Results improvement Program will further improve performance.
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Maintenancr/Surveillancs The Authority agrees with the assessment of Maintenance and Surveillance. improved
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procedural instmetions and increased emphasis on equipment failure root cause analyses with corresponding focused corrective actions, have resulted in higher work quality and a lower incidence of re-work. This emphasis continues. The preventive maintenance program is being significantly improved and several major component group evaluations l
have been completed.
As noted in the report, the combustible control and scaffolding programs have been strengthened.
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New York Power Authority
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James A. FitzPatrick Nuclear Power Plant
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Attachment to JPN-93-057 A plant wide stand-down was conducted to reemphasize the need for attention to detail; and to reenforce the management expectation that work needs to be done right the first time.
Efforts to improve the surveillance program include procedure upgrades, an adequacy review of Logic System Functional Tests, and centralized scheduling.
These and other continuing initiatives, such as equipment failure, root cause, and shutdown risk evaluations, critiques, and enhancements in planning and scheduling will further improve our perfonnance in maintenance and surveillance.
Emerge 11cy_P_teparndness The Authority agrees with the assessment of this area. Management is committed to continued strong support and superior performance.
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initiatives taken or in progress during this SALP period include use of the plant specific control room simulator for the June 30,1993 omergency plan drill, initiation of an upgrade of Emergency Action Levels consistent with NUMARC guidance, and implementation of an improved dose assessment model.
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Senprity The Authority agrees with the assessment in the security area and is committed to
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maintain superior performance through effective corporate support, critical self-assessment, and timely effective corrective actions.
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EngineenagEcchnicaLSupport The Authority agrees with the NRC assessment of this area. We are encouraged by the acknowledgement of improved performance and are taking actions to address the weaknesses cited.
The Technical Services group is initiating an engineering on-call " duty officer" schedule to
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provide enhanced multi-disciplinary, timely, high quality resolution of emergent issues.
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Technical Services activities are prioritized, assigned to a responsible individual and tracked. Personnel training and vacations are being scheduled a year in advance to allow
better resource planning and utilization. An issues Tumover Log has been established to improve the quality of task tumovers and to ensure availability of accurate technical intormation.
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Technical Services staffing is being increased. Three experienced engineers have accepted offers and fourteen positions are being filled.
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o New York Power Authority-
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James A. FitzPatrick Nuclear Power Plant
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Attachment to JPN-93-057
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Several improvement initiatives are in progress in the engineering area. Improved analytical tools that have been implemented include: computerized modeling of the electrical distribution system; and computerized models for motor start circuit analysis,
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coordination analysis, and load studies. Improvements in modification and design control procedures and standards are ongoing.
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Development of Design Basis Documents (DBDs) continues. Design information was retrieved from the NSSS supplier and the original plant architect-engineering firms and is being consolidated at the Authority's corporate office.
Engineering work backlogs are being trended and appropriate action is taken if trends are not satisfactory.
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Improvements were made in the technical evaluations of Appendix R safe shutdown issues to address the weaknesses noted in the report. The lessons leamed from the fire door deficiency issue were used to sensitize our engineering staff to operability concerns, and to provide better guidance in this area.
t A training program for support personnel has been developed and is being implemented.
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Training has been completed for selected personnel in root cause analysis, observation, and human performance improvement techniques.
i Effective July 30,1993, the corporate Vice President - Nuclear Engineering position has l
been filled with a loanee from INPO for a term of approximately one year. The
engineering organizational structure is currently being evaluated. Changes needed to l
ensure more effective engineering support of both of the Authority's nuclear plants are I
being developed and will be initiated by January 1994.
Strong management attention will be given to the engineering / technical support area to ensure performance improvements continue at an acceptable pace, and that commitment schedules are accurate and consistently met.
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Safe _ty_AssgssatentLQuality_V_crification The Authority agrees with the NRC assessment of this area. Management continues to f
emphasize safe, conservative operations and the need to do all tasks right the first time.
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Strong management oversight, the use of management observations and self-assessment
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programs will provide feedback and monitoring of performance. Continued training in the
use of root cause analysis techniques, and timely and effective corrective actions will
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ensure continued improved performance.
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i A Nuclear Assessment group has been established and permanent positions filled at both f
plants. These positions report directly to the Vice President - Nuclear Operations.
i The effectiveness of the Plant Operations Review Committee (PORC) will be further i
enhanced by improvements to the procedure review process that will allow the PORC to better focus on safety.
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h New York Power Aethority
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James A. FitzPatrick Nuclear Power Plant
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Attachment to JPN-93-057
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i The process used to review Licensee Event Reports prior to submittal to the NRC has been improved to ensure submittal of accurate information.
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The Authority will continue to implement performance based, in-depth quality assurance audits to identify and correct weaknesses.
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The Power Authority is committed to achieve superior performance in this area.
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