IR 05000333/1993007
| ML20035D272 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/02/1993 |
| From: | Conte R, Williams H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035D267 | List: |
| References | |
| 50-333-93-07, 50-333-93-7, NUDOCS 9304130021 | |
| Download: ML20035D272 (8) | |
Text
.
_.
_
_
. -
_
_
_ _ _
.-
_-
._.
,,
,
.
$
U.S. NUCLEAR REGULATORY COMMISSIGN
REGION I
,
,
REPORT NO.
93-07 i
DOCKET NO.
50-333 LICENSE NO.
DPR-59 LICENSEE:
New York Power Authority James A. FitzPatrick Nuclear Power Plant
,
Post Office Box 41 i
Lycoming, New York 13093 FACILITY:
James A. FiaPatrick Nuclear Power Plant INSPECTION AT:
Lycoming, New York.
.
INSPECTION DATFS:
March 16-19,1993
ACCOMPANIED BY:
C. Sisco, Operations Engineer
)
,
0.M #&w vN#s
.
LEAD INSPECTOR:
[4. ' Williams, Sr. Operations Engineer Dat6 '
2h7
$
APPROVED BY:
' hard L Cont [/ Chief, BWR Section Date -
"
Ric Operations Branch, Division of Reactor Safety
,
INSPECTION SUMMA ~RY: insoection conducted March 16 - 19. 1993 Gnsaclian Report 5Q-333/93-07)
'
,
l AREAS INSPECTED: An announced safety inspection was conducted of the licensee's EOPs using Inspection Procedure 42001 which included an assessment of the technical l
adequacy of die EOPs; the EOP review, revision, and approval process; the QA involvement
in the EOP program; and the operator training in EOPs.
RESULTS: Based upon this inspection, the EOF's are technically accurate and are written and formatted in accordance with plant procedures. Procedural controls are in place to maintain the technical basis, format, and validation of the procedures. Minor changes to the
EOP flowcharts were found not to be incorporated into all controlled copies of the
"
flowcharts. The procedure to control changes to the EOP flowcharts and distribution of up-i
t 9304130021 930402 PDR ADOCK 05000333
'
G PDR
-
.
-
-
.
.
I
P
.
!
to-date EOP flowcharts as weak. Controls to ensure that plant equipment problems are
,
evaluated for EOP impacts were weak. QA audits of the EOP program were in-depth and comprehensive. The recent QA audit conducted by the licensee had identified many of the NRC findings. The licensee took prompt action to correct weaknesses and resolve proble.ms identified during this inspection.
The EOP's are usable by operating crews and operators understand how to implement the EOP's. I.esson plans for licensed operator training on EOP's were well written. EOP training programs for nonlicensed operators and other support personnel have been recently
.
enhanced.
,
.I I
>
!
t i
l
1 i
. -.
.
- DETAILS 1.0 INTRODUCTION AND OVERVIEW
<
This safety inspection reviewed for adequacy, on a sampling basis, the facility's emergency
,
operating procedures (EOPs) and operator training. The requirements for the inspection and
,
related guidance is found in NRC Inspection Manual Procedure (IP 42001). This IP was developed as a result of special inspections conducted to verify completion of a TMI-2 action
item (TAP) No.1.C.1, " Guidance for the Evaluation and Development of Procedures for i
Transients and Accidents," (NUREG-0737 and supplement 1).
2.0 TECHNICAL ADEQUACY OF EOPS
.
Scope The scope of the review was to determine that the EOPs are consistent with the NRC endorsed accident mitigation strategies. la addition, the inspection was to determine if the licensee has procedural controls in place to maintain the technical basis, format, verification and validation of the EOPs. The inspection focused on changes made to the EOP's since the last EOP inspection conducted in October 1990.
Findings j
I l
The inspector reviewed the licensee's current Plant Specific Technical Guidelines (PSTGs)
which was used to develop the EOPs. The PSTG is complete and technically accurate. The
'
,
inspector verified that changes to the EOPs were documented in the PSTG and incorporated
,
into the EOPs. On a sampling basis, the inspector determined that the EOPs contain accident mMgation strategies as described in the BWR Owner's Group Emergency Procedures Guidelines (EPG's), Revision 4.
>
The inspector reviewed procedure AP-2.2, " Procedure For Emergency Operating Procedures," Rev.7. The procedure provides adequate controls to maintain the technical basis, format and validation of the EOPs.
l
Conclusion
,
Based on this review, the EOP" are consistent with the BWR Owner's G oup EPG's, Revision 4 and the site specific PSTG. Also, the licensee has procedural controls in place to maintain the technical basis, format, and validation of the EOPs.
i
,
a i
i
-
- __.
-
-
_
l r
.
3.0 EOP REVIEW, REVISION AND APPROVAL PROCESS Scope The scope of the inspection was to determine whether changes to the licensee's EOPs are properly controlled and to verify that the licensee's administrative procedures adequately govern the review, revision, and approval process of the EOPs.
Findings Three relatively minor changes were made to the EOPs since they were issued in June 1990.
Dese changes were made between the period of August 1990 and October 1992.
Appropriate analyses were made before the changes were incorporated into the EOP flowcharts and PSTG. The changes were validated and verified as required by AP-2.2.
The temporary procedure change process described in AP-1.4, " Control of Plant Procedures," Rev.10, Section 7.3 was used to implement these changes. The inspector questioned the appropriateness of using the temporary change process for EOP changes.
The three changes to the EOPs were not incorporated into Controlled copies of EOP flowcharts except for the copics in the control room and the simulator. The inspector discussed with the licensee the need to maintain current copies of the EOP flowcharts at other locations such as the Technical Support Center and Emergency Operating Facility.
These issues were also identified in FitzPatrick Audit Report No. 807 (Recommendation No.
!
807-1). The inspector will review the licensce's actions on these issues in a future inspection
[ Inspector Follow Item (IFI) No. 333/93-07-01].
,
The plant modi 6 cation process was reviewed to ensure that impacts on EOP's were considered. Plant modi 6 cations made in 1990 and 1991 and described in reports to NRC staff were reviewed for EOP impacts. No impacts on EOP's were found in these modi 6 cations. The licensee has procedures in place to ensure that modifications are reviewed for EOP impacts.
Conclusion Minor changes to EOP's were not incorporated into all controlled copies of EOP's. The EOP procedure change process including distribution of revised EOP's was weak. The licensee had independently identiDed these weaknesses and has initiated actions to strengthen their program. No weaknesses were identined in the plant modification process as it relates to the EOP program.
l
.
.
.
4.0 EOP SUPPORT PROCEDURES Scope The scope of the inspection was to verify that selected EOP support procedures could be implemented by the plant staff. The inspection was conducted by walking-down the procedures.
Findings
,
The inspector walked-down the following EOP support procedures.
-
AOP-34, " Backup Control Rod Insertion," Rev.11
-
AOP-38, "EOP Isolatiordinterlock Overrides," Rev. 8 i
--
AOP-52, " Termination or Prevention of Reactor Vessel Injection When Directed by the Emergency Operating Procedures," Rev. 8
.
The inspector reviewed Attachment 3 of AOP-38. The inspector noted that the installation
points of electrical jumpers to override the main turbine bypass valves closure are equipped with large, round head screws and questioned the adequacy of this arrangement. The licensee demonstrated that installation of the necessary electrical jumpers could be installed.
However; the licensee has been evaluating the current method of alligator clips attached to pan head screws to install electrical jumpers to defeat isolations and interiocks due to past experience. The licensee's plans are contained in Work Request No. 106451 dated
.
October 30,1992, that requests a plant modification to install a more secure attachment method for installing electrical jumpers.
t The inspector determined that Attachment 4 of AOP-38 concerning the restoration to service
,
of the override of the Low Pressure Coolant Injection valves 10 MOV-27A(B) was inconsistent with AOP-52 sections C.18 and 19. AOP-52 requires that timers 10A-K45A(B)
be recalibrated before returning the system to service. The licensee took prompt corrective action and revised AOP-38 to be consistent with AOP-52.
l
The inspector noted that the above discrepancies are typically found during the validation and verification process of EOP support procedures. The licensee does not currently require that
!
EOP support procedures to receive the same validation and verification as the EOPs. A
,
recently completed QA audit had findings that also identified the difference between the EOPs and support procedures validation and verification process. The actions taken by the facility regarding QA audit report Recommendations 807-1(4) and (6) will be further
,
reviewed by NRC staff (IFI No. 333/93-07-02).
,
i a
t
.
a
The inspector noted that prestaged EOP equipment located in locked cabinets in various l
'
locations in the plant was routinely inventoried. In addition, plant labeling of components and those components named in the procedures that were reviewed were in agreement.
Conclusion The differences between the EOPs and support procedures validation and verification may have resulted in discrepancies in the support procedures. The inconsistency identified between AOP-38 and AOP-52 may have been identified by the facility if those procedures had received the same verification and validation as the EOPs. The licensee took prompt
>
corrective actions to revise AOP-38 to be consistent with AOP-52.
When the plant modifications are completed, it will be an enhancement to safety by
,
equipping the plant with electrical connections that provides a more secure connection.
5.0 QUALITY ASSURANCE INVOLVEMENT IN TIIE EOP PROGRAM L
Scope The scope of the inspection was to verify that the licensee conducts independent quality assurance (QA) audits of the EOP program.
Findings Two QA audits were reviewed and discussed with the licensee. The first audit was dated August 17,1990 and was well documented. The second audit was performed from February 22 to March 10,1993, and was dated March 17, 1993. The licensee used Appendix B of NUREG-1358, Supplement 1, dated October 1992, to develop an audit check list for the EOP program. Most findings identified during the NRC inspection had been noted in the licensee's second QA audit.
Conclusion The QA audits were in-depth and comprehensive and the QA auditors were knowledgeable of the EOP program and plant operations.
i 6.0 PLANT OPERATOR TRAINING c
Scope The scope of the inspection was to verify, based primarily on performance in the simulator, l
that the EOP's can be implemented by operating crews. EOP lesson plans were reviewed for adequacy.
i i
!
.
S
Findings The inspector reviewed lesson plans used to instruct the plant operating staff in the use of EOPs and determined that the lesson plans were well written and technically consistent with the EOPs.
The inspector observed three operating scenarios using the plant referenced simulator. A plant operating crew, in their training cycle, demonstrated their abilities to carry out the l
procedural requirements of the EOPs during plant upset conditions. Following the scenarios,
the inspector conducted in-depth discussions associated with the EOP's with the operating i
Crew.
l Based on interviews conducted and observed performance of the operating crew, the l
!
inspector determined the crew understands how to implement the EOPs.
i The inspector reviewed a recently completed Job Task Analysis that identifies those EOP related task (and other task) that may be completed by nonoperations or nonlicensed personnel. This analysis will be used by the licensee to enhance their training program, i
Conclusion l
The lesson plans used to instruct plant opemtors in the use of the EOPs are well written and are consistent with the EOPs. The EOPs are useable by the operating crew and the crew understands how to implement the EOPs. The licensee is enhancing their training program by identifying EOP related tasks and developing training on those tasks for nonoperations and j
l nonlicensed personnel.
7.0 OTIIER OBSERVATIONS The inspector determined that inconsistencies existed between the posted Operator Aids (in the control room and relay room) and the Operator Aids record sheets. Specifically, Operator Aids Nos. 197, 448, and 449 are composed of two different operator aids. The Operator Aids index identifies the aids to be only single postings. After the inspector discussed the problem with the licensee, they issued an Adverse Quality Condition Report No.93-024 that requires each Operator Aid record sheet description section exactly matches the posting. In addition, for multiple operator aids posted under one operator aid number, each is to be correctly identified in the record sheet. The corrective actions will be completed and documented in Surveillance Test ST-99D, " Operator Aids," that is scheduled to be completed the first week of April 1993.
l The inspector determined that all provisions of procedure ODSO-28, "EOP Entry and Use,"
were not adhered to when area radiation monitor 18RIA-051-18, " Contaminated Equipment Storage Room," failed in service. The procedure requires that the associated computer point be removed from scan of the Safety Parameter Display System (SPDS). When informed of
-.-
l l
.
,
l the problem by the inspector, the licensee took prompt corrective actions and removed the computer point from scan. This area radiation monitor is imponant because it serves as an entry condition into the EOPs. In addition, it is important to remove the input to the SPDS to ensure the operator is given a visual cue that the area radiation instrument reading is faulty. The area radiation monitor was subsequently returned to service following repair and the computer point retumed to scan by the SPDS.
The inspector noted that the licensee had properly identified two out of service individual
,
control rod scram switches. However, the impact on procedure AOP-34, section C.6.3 regarding individual rod scrams during emergency conditions was not fully evaluated by the licensee. It is noted that the procedure does contain additional methods to insert control rods
'
during emergency situations. The out of service individual rod scram switches may create a delay as the operating staff implements the procedure.
Based on the inspector's observations of the individuals rod scram switches and the out of service radiation monitor, the inspector concluded that controls to ensure plant equipment problems are evaluated for EOP impacts were weak.
8.0 EXIT MEETING An exit meeting was conducted at the site on March 19, 1993. The inspector discussed the findings of the inspection with those individuals identified below.
The following personnel were contacted during the inspection.
New York Power Authority l
,
- H. Salmon Resident Manager
- B. Barrett General Manager, Operations
- M. Colomb General Manager, Support Services j
- D. Burch Reactor Engineer Supervisor
- F. Catella Operations Training Supervisor P. Abbott Sr. Shift Supervisor
- J. Fitzgerald General Manager, Maintenance
- D. Simpson ORG/ Licensing Engineer A. Zaremba ORG/ Licensing Manager
- J. Kaucher Technical Services Manager G. Tasick QA Superintendent J. Prokop Quality Assurance
- R. Post Quality Assurance
- F. Aldrich Operations
.
l
-
.
t U.S. NUCLEAR REGULATORY COMMISSION
- H. Williams Sr. Operations Engineer
- C. Sisco Operations Engineer
- J. Tappert Resident Inspector
- Denotes those present at the exit meeting.
t
!
.
'
i k
I
!
I
[
l
'
r i
!
>
t l
l I
i
-.
._. _,.