IR 05000333/1993008
| ML20044H280 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/04/1993 |
| From: | Drysdale P, Durr J, Prividy L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20044H275 | List: |
| References | |
| 50-333-93-08, 50-333-93-8, NUDOCS 9306080136 | |
| Download: ML20044H280 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
REPORT / DOCKET NO.
50-333/93-08 LICENSE NO.
LICENSEE:
New York Power. Authority Post Office Box 41 Lycoming, New York 13093 FACILITY NAME:
James A. FitzPatrick Nuclear Power Plant INSPECTION AT:
Scriba, New York INSPECTION DATES:
March 15-19 and March 29 - April 2,1993 h8N5 INSPECTORS:
P. Drysdale,/ r. Reactor Engineer, Region I Date S
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SlIYb93 L. J. Prividy, Acting Team Leader, EB, DRS Date
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EB, DRS i
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81 APPROVED BY:
77Jacque P. Durr, Chief, EB, DRS date'
Areas Inspected: An announced inspection was conducted to verify that design changes and plant modifications were being conducted in accordance with controlled procedures and NRC requirements. Other engineering activities were also reviewed to assess the effectiveness of the engineering organization.
9306080136 930604 PDR ADOCK 05000333 G
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l Results: The program for controlling design changes and plant modifications was found to be effective and adequately controlled by detailed administrative procedures. Communication among engineering personnel had imptr.ved in the past year. Also, the development of a modification prioritization process wr, a significant improvement. NYPA recognized that
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additional progress was needed to reduce engineering work backlog. No violations or
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deviations were identified.
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1.0 INSPECTION SCOPE l
A well implemented design change and modification program is essential in order to assure that changes to the plant do not degrade safety systems, structures and components. The
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objective of the inspection was to verify that changes to plant systems, which are described in the final safety analysis report, are implemented per controlled administrative procedures that satisfy regulatory requirements. This objective was accomplished by reviewing several major and minor modifications. Several related engineering organization activities were also reviewed.
2.0 INSPECTION FINDINGS 2.1 Design Changes and Modifications (37700)
Plant modifications are prepared, reviewed, approved and implemented in accordance with specific procedures provided in NYPA's modification control manual (MCM). For example, MCM-3, " Modification Package Preparation, Review and Approval," is the procedure used to define base documents which are then t:2nslated into detailed installation and testing documents comprising the plant modification. Other engineering procedures in NYPA's design control and engineering standards manuals also control design changes for plant modifications. The following modifications were reviewed:
2.1.1 Modification No. F1-89-066 - Replacement of Service Water Piping at the Reactor Building Closed Loop Cooling System (RBCLCWS) Heat Exchangers The service water system (SWS) at the outlet of the A, B and C RBCLCWS heat exchangers includes 12-inch piping connected to a common 20-inch discharge header which directs the SWS flow to the circulating water discharge tunnel. This SWS piping for each RBCLCWS heat exchanger conta(ns a 10-inch, air-operated flow control valve (46FCV-101) and a 12-inch manual butterfly valye before connection to the common header.
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This modification replaces the original 12 and 20-inch carbon steel piping with chrome-moly piping which is considered to be less susceptible to erosion / corrosion (E/C) problems. The original piping has experienced severe wall thinning and leaks due to E/C caused by cavitation from throttling at the flow control valves. Since the same piping arrangement is acceptable, existing pipe supports will be used. The existing valves will also be used. This modification has been implemented for only the C RBCLCWS heat exchanger as discussed below.
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NYPA had known about wall thinning in this piping since at least 1987, proposing to install this modification in the 1991 refueling outage. However, it was deferred at that time. In January - March 1992, NYPA again evaluated the condition of pipe wall thinning at the RBCLCWS heat exchangers. Ultrasonic thickness measurements of the pipe wall were
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obtained and calculations were performed. NYPA documented this evaluation in calculation JAF-CALC-SWS-00431, Revision 0, and Memorandum NED-CS-WP51-M172 (March 2, 1992) which the inspector reviewed. From their evaluation NYPA concluded that the
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severest wall thinning was occurring downstream of 46FCV-101C where further progression of E/C would reduce the pipe wall below the minimum required by the ASME code. NYPA recommended replacement of this piping during the 1992 outage and considered it acceptable to defer the replacement of the SWS piping for the A and B RBCLCWS heat exchangers until the 1993 refueling outage. The chrome-moly piping replacement for the C heat exchanger was implemented in mid-1992.
In late December 1992, a pinhole leak developed at the flange of the 12x10 reducer immediately downstream of 46FCV-101B. This location was not included in the mapping area used for the ultrasonic wall thickness measurements obtained earlier in 1992. Repairs
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were made using a new stainless steel fitting and then ultrasonic thickness measurements were taken at the area of interest downstream of the 46FCV-101 A, B and C. NYPA evaluated this data in Revision 1 to calculation JAF-CALC-SWS-00431 and memorandum
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NED-CS-92-WP51-HYC548 (December 31,1992). NYPA concluded that a minimum of 11-12 months of remaining service life existed for the A and B SWS piping which allowed sufficient time beyond September 1993 when the chrome-moly piping replacement was scheduled. The inspector found that NYPA demonstrated good engineering in their calculations and evaluation of this data and the earlier 1992 E/C data and information. The General Manager of Support Services noted that the NYPA decision to defer the chrome-moly SWS piping for the A and B RBCLCWS heat exchangers would be reviewed with the critique of 1992 modifications, which is an item being tracked by the FitzPatrick action commitment tracking system.
The inspectors reviewed modification documents, including the nuclear safety evaluation, conceptual design, installation procedures and engineering change notices (ECNs), associated with the installation of the SWS piping for the C RBCLCWS heat exchanger. These documents provided the necessary administrative controls for implementing the modification and satisfying regulatory requirements. The safety evaluation concluded that the modification involved no unreviewed safety question. Hydrostatic pressure testing was satisfactorily conducted after installation of the modification. The inspector observed the piping installation in the reactor building and noted that the modification installation procedure did not specifically require inspection and refurbishment, if necessary, of the existing valves.
Engineering personnel stated that craft personnel would be expected to observe and correct such items during installation. The inspector concluded that the modification documents
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issued provide the necessary guidance for changing the SWS piping.
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2.1.2 Mod!fication No. F1-90-202 - Reactor Water Cleanup (RWCU) Pump "A" Procurement and Installation This modification replaces the existing, non-functional "A" RWCU pump (Lawrence Pump)
with an Ingersoll-Rand pump which is similar to the "B" RWCU pump. The replacement pump will be a 50% system design flow pump. restoring the RWCU system to 100% design
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flow capacity. This modification was being implemented at the time of the inspection.
The inspectors reviewed design change and modification documents, including the nuclear safety evaluation, engineering installation requirements, modification test requirements, the technical procurement specification JAF-SPEC-RWCU-00069, Rev.1 and the installation procedure were reviewed. These documents were comprehensive and well prepared in accordance with various NYPA modification control manual and engineering design control procedures. For example, the procurement specification required and the safety evaluation noted that the low cobalt materials would be used for pump parts in contact with the pumped fluid. Installation procedures employed good ALARA techniques by requiring the use of temporary lead shielding around RWCU piping and remote cameras for surveillance of the work. Appropriate seismic design considerations also were included in this modification as noted in the safety evaluation. While the RWCU pump does not have to remain functional during or after a seismic event, it must be seismically supported so that it does not adversely i
impact the pump suction piping which is seismically designed. The procurement j
specification it. eluded these design requirements.
Two observations were noted concerning certain installation and design considerations for this modification. The existing pump bedplate is to be removed but the existing concrete pad-l and seismic anchor bolts are to be reused. While cautionary statements for protecting these anchor bolts were included in the installation procedure and on the pump foundation construction detail drawing, the inspector noted the potential for damaging the anchor bolts.
Certain operations, such as removing the existing pump or bedplate, were permitted earlier
in the procedure before the caution statements and could cause anchor bolt damage. The inspector noted that awareness of component anchor bolt damage was an issue at Indian Point 3 last year during the replacement of a component cooling water heat exchanger when one of the anchor bolts was damaged. The responsible engineer addressed the inspector's observation by verbally advising the craft personnel performing the work. The second observation concerned whether the FitzPatrick Power Uprate Project temperature and pressure parameters negatively impacted the available net positive suction head (NPSH) for
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the RWCU pumps. After some discussion of this item, the inspector found that NYPA Operations and Maintenance personnel had reviewed this modification for power uprate and concluded that the available NPSH would actually increase for the RWCU pumps. As installation problems or design information of this type occur, the inspector requested that the i
NYPA engineering organization share such items at the engineer level to improve the modification process.
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Overall, the design inputs and the engineering outputs provided the needed guidance for this modification.
2.1.3 Modification No. D1-90-208 - Replace Emergency Diesel Generator (EDG)
Service Water (SW) IIcat Exchangers (HXs)
This modification was initiated to evaluate the tube plugging limit in conjunction with an increase in the maximum intake water temperature from Lake Ontario. NYPA contracted
Stone & Webster Engineering Co. (SWEC) to conduct the thermal capacity analysis required for the EDG HXs. The analysis also determined the maximum number of plugged HX tubes allowed to meet design heat loads under various flow conditions.
SWEC determined that a SW flow reduction from =700 gpm to =600 gpm in the HXs could provide additional heat transfer capability and could increase the maximum number of plugged tubes allowed from approximately 10 to 20. Consequently, NYPA throttled the
EDG SW flow to =600 gpm. The worst case HX currently has 17 tubes plugged. NYPA stated that an increase above the maximum of 20 plugged tubes was possible with further analysis. The inspector reviewed this information and evaluation and verified that sufficient thermal margin was available in all four existing HXs.
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This design equivalent modification was further developed to include the procurement and installation of replacement HXs which will equal or exceed the thermal capability of the
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existing units. Improvements will also be provided in internal materials to stainless steel to inhibit corrosion and in flow characteristics to inhibit high velocity flow impingement and erosion. The replacement HXs have not yet been procured. The modification is currently scheduled for installation during the 1995 refueling outage.
2.1.4 Design Equivalent Modification Review
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Design equivalent modifications, otherwise known as "D-Mods," are a subset of minor modifications that do not involve a change to the design basis of a component or system. D-Mods are administratively controlled per procedure MCM-23. They usually involve component or material replacements and evaluations of equipment design capabilities.
NYPA obtained contractor (Bell Engineering) assistance approximately one year ago to work on D-Mods to assist in managing the engineering backlog. However, NYPA was not successful in reducing the total number of open D-Mods by the end of 1992. The inspector sampled several D-Mods performed for setpoint changes and motor-opere.ed valve spring pack replacements. D-Mods for parts for an electrical circuit 'criker ano an air-operated valve were also reviewed. The modifications met the criteria for design equivalency. The D-Mod packages reviewed were well engineered with appropriate reviews by contractor and
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NYPA engineers.
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2.2 Engineering Backlog i
NYPA tracks the completion of engineering work items in 5 categories: material concerns, plant improvement concerns, design concerns, regulatory compliance issues and temporary modifications. These performance indicators are listed in the NYPA Nuclear Generation Business Plan for which FitzPatrick had established goals of 930 open engineering work items for 1992 at year end and 750 for 1993. However, the engineering backlog was approximately 1150 as of February 28,1993, well above the aforementioned business plan goals. Despite the many work items completed during the shutdown in 1992, NYPA recognized that further progress was needed in this area.
2.3 Modification Prioritization Usually modifications are preceded by engineering work requests (EWRs) which are submitted by plant personnel to correct or improve an existing plant item. During 1992, NYPA established a process to systematically prioritize EWRs and modifications which had already been identified. A cost / benefit ratio is established by answering a set of standard
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questions. Elements in these questions include items such as personnel safety and regulatory impact. Each question has a certain weighting factor which impacts the calculated cost / benefit ratio. The process for each EWR leads to an engineering prioritization committee recommendation which is submitted for approval to the resident manager and the general manager of operations. NYPA was preparing a procedure to formalize this modification prioritization process. Also, by September 1993, NYPA expected to eliminate the current backlog of 100 EWRs not yet prioritized. The inspector concluded that NYPA had significantly improved their method for prioritizing EWRs.
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2.4 Communientions Monthly engineering meetings are being conducted to discuss important engineering issues as they develop at the supervisory level. The inspector observed the involvement of the technical services and site engineering personnel at the daily site planning meetings.
Approximately a year ago, NYPA instituted bi-weekly conference calls between site and corporate engineering personnel to improve communications. The inspector observed the conference call on April 1,1993 and noted the discussion of mechanical, electrical and '
j structural issues, including updated information concerning several calculations. The
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Director of Nuclear Licensing also participated in the call. The inspector observed this conference call to be constructive in building effective communications.
2.5 Engineering Support Personnel Training i
The inspector met with training department personnel and designated engineering department training coordinators to determine the status of engineering support personnel training identified in the FitzPatrick Results Improvement Program. The training department issued i
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8 Training Procedure 3.0, Revision 6, Engineering Support Personnel Training and Qualification Program, on December 7,1992. Qualification cards had been developed for technical services department personnel but not for site engineering department and corporate engineering personnel.
2.6 (Closed) NRC Unresolved Item 50-333/92-02-01 Residual IIcat Removal Service Water (RHRSW) and Emergency Service Water (ESW) Strainers This unresolved item was opened to track completion of several NYPA commitments made
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as a result of an inspection of Modification No. F1-88-204 which involved the replacement of RHRSW and ESW strainers. Problems noted with this modification included items such as the lack of including the strainer outlet check valves in the plant inservice testing (IST)
program. NYPA agreed to include these check valves in the IST program and committed to revise procedure DCM-13, " Conduct of Engineering," by June 30,1992, to strengthen IST program reviews. The inspector verified that DCM-13 had been changed. The last commitment was the conduct of specific training of corporate engineering personnel concerning the requirements of the IST program to be completed by December 31,1992.
The inspector verified that this training had been completed. This unresolved item is now closed.
3.0 CONCLUSION The inspector concluded that the design change and modification program was being controlled adequately with detailed administrative procedures. Based on the modification packages reviewed, the engineering products provided the necessary guidance to safely modify the plant.
The systematic modification prioritization process developed during 1992 was a significant improvement. Also, communications among engineering personnel has improved in the past year. NYPA recognized that additional progress was needed to reduce the engineering work backlog consistent with the goals of the NYPA Nuclear Generation Business Plan.
4.0 MANAGEMENT MEETING The inspector met with those listed in Attachment A, on April 2,1993, to discuss the preliminary inspection findings which are detailed in this repo _. -
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Attachment A Persons Contacted New York Power Authority
- B. Barrett, General Manager - Operations J. Colloca, Project Engineer, SED
J M. Colomb, General Manager - Support Services
- T. Dougherty, Director, Project Engineering l
- J. Erkan, Supervisor, Project Engineering
- J. Fitzgerald, Acting General Manager, Maintenance
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- J. Hoddy, BWR Licensing
- J. Kaucher, Manager, Technical Services
- P. Morris, Acting Manager, QA
- T. Moskalyk, Supervisor, Mechanical / Civil C. Patrickson, Project Engineer, SED
- D. Ruddy, Manager, SED
- H. Salmon, Jr., Resident Manager l
- T. Savory, Supervisor, Electrical /I&C J. Sherman, Project Engineer, Project Engineering
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- A. Zaremba, ORG Manager
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Nuclear Resulatory Commission (NRC)
- W. Cook, Senior Resident Inspector, FitzPatrick
- Denotes attendance at the exit meeting held at James A. FitzPatrick Nuclear Power i
Plant, April 2,1993.
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