IR 05000333/1993006
| ML20045F143 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/30/1993 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Harry Salmon POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 9307070030 | |
| Download: ML20045F143 (3) | |
Text
June 14, 1993
SUBJECT:
James A. FitzPatrick Nuclear Power Plant
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Docket No. 50-333 Reply and Answer to Notice of Violation NRC Inspection Report 50-333/93-06
Dear Sir:
This letter provides the Authority's reply to the Notice of Violation in accordance with the provisions of 10 CFR 2.201. The reasons for the violations, the corrective
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actions that have been taken and the results achieved, the corrective actions to be taken to avoid further violations and the date when full compliance will be' achieved l
for the violations is included in Attachment 1.
If you have any questions, please contact Mr. Mike Colomb.
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Very truly yours, A
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' Harry P.' Salmon, Jr. "
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STATE OF NEW YORK
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COUNTY OF OSWEGO Subscribed and sworn to before me thisl 4'" day of Lt R95 TAMMY L DANN 4985563 Notary Pubhe. State of New York Quahfied in Oswego Coun omtnission ires 8/191 ts W s
Notary P0blic cc: see next page Cu gqi
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Regional Administrator U.S. Nuclear Regulatory Commission
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475 Allendale Road King of Prussia, PA 19406 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 i
Lycoming, NY 13093 Mr. Brain C. McCabe Project Directorate I-11 Division of Reactor Projects-1/II U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555
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Response to Notice of Violation e
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Attachment 1 Violation
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Technical Specification 6.8.A states, in part, that written procedures shall be implemented that meet or exceed the requirements of Section 5 " Facility
Administrative Policies and Procedures" of ANSI 18.7 - 1972.
ANSI 18.7 - 1972, Section 5.1.2 states, in part, that procecures snail be
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followed.
Modification M1-91-004, " Chemical Decontamination - Addition of Permanent Piping and Valve", Installation Procedure No.1, Section 10.0, " Post-installation / Pre-operational Testing", specifies in paragraph 10.1 that all socket i
type welded fittings that were installed on the 1" diameter branch lines on the
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recirculation system piping risers will be verified leak-tight during reactor
vessel operational pressure testing per surveillance test procedure ST-39H.
i Contrary to the above, on September 30,1992, ST-39H was performed, but l
the manual isolation valves in the ten recirculation riser decontamination connections were not opened to allow pressurization and leak testing of the i
piping and welds downstream of the manual isolation valves.
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This is a Severity Level IV Violation.
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l Admission or Denial of the Alleged Violation i
The Authority agrees with this violation.
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The Reason for the Violation i
Personnel error is the primary cause that modification package M1-91-
004, " Chemical Decontamination - Addition of Permanent Piping and Valves", was not clear as to the intended testing requirements. The intent of the responsible engineer was not to leak test the' connections I
downstream of the manual isolation valves. This was not clearly communicated in the modification package or the installation procedure.
The installation procedure specified that "all socket type 1 of 3
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welded fittings" that were installed on the 1" diameter branch lines at the recirculation system piping would be verified leak-tight. The i
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procedure should have stated " perform an in-service leak test of the assembly at full system operating pressure with normal valve lineup during ST-390, i.e., new valves closed". This was the responsible l
engineers intent, based on plant procedure and the testing performed.
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Corrective Steps to be Taken to Avoid Further Violation A root cause analysis has been performed on Modification M1-91-004 to
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identify the cause and corrective action of this violation. The corrective action for this violation includes the following:
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To have the root cause analysis reviewed by the Engineers involved in the modification process.
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To review the need for attention to detail with engineers in f
defining modification test requirements.
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The modification package has been revised to clarify the testing
requirements.
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The Date When Full Comoliance Will be Achiev(d Full compliance will be achieved by August 1,1993.
Violation i
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10CFR50.9 requires, in part, that information provided to the Commission by
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a licensee be complete and accurate in all material respects.
Contrary to the above, NYPA provided inaccurate information to the NRC by i
letter dated March 12, 1993, transmitting Licensee Event Report 93-006,
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Inoperability of Fire Pumps. The sequence of events, when the electric driven and diesel driven fire pumps were declared inoperab!e, were in error and in
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conflict with the February 26,1993 Emergency Notification System i
chronology and a facsimile transmission made by NYPA, on March 1,1993, concerning this event.
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Admissier Denial of the Alleged Violatiqn The Authority agrees with the violation.
The Reasons for the Violation
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Personnel error is the primary cause for the inaccurate information contained in LER-93-006. An error was made by not incorporating the correct
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chronological data from the operations logs to the LER. The data omitted was the entry made for declaring the pump inoperable.
The Corrective Steos Taken to Avoid Further Violations A new procedure, AP-03.04, Information Reporting Requirements was implemented on May 15, 1993. This procedure contains a technical review
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(assigned by the Department Manager (s) responsible for providing the
description of the event) to ensure technical accuracy. The technical review
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checklist includes verifying the appropriate times of the occurrences during the event. A revised LER was issued on May 5,1993, to correct the inaccurate information contained in LER-93-006.
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Ihe Date When Full Comoliance Will be Achieved j
Full compliance was achieved on May 15, 1993.
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