IR 05000333/1993026
| ML20059F574 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/22/1993 |
| From: | Eapen P, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059F567 | List: |
| References | |
| 50-333-93-26, NUDOCS 9401140071 | |
| Download: ML20059F574 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION 1
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DOCKET / REPORT NOS.: 50-333/93-26 LICENSE NO.:
DPR-59 LICENSEE:
New York Power Authority Post Office Box 41 Lycoming, New York 13093 FACILITY NAME:
James A. FitzPatrick Nuclear Power Plant i
INSPECTION AT:
Lycoming, New York INSPECTION DATES:
November 15-19, 1993 i
INSPECTORS:
Fred Bower, Reactor Engineer, Systems Section, EB, DRS Leanne Kay, Reactor Engineer, Electrical Section, EB, DRS i
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o Al Finkel, Sr. Readtdr Engineer Date '
Systems Section, EB, DRS APPROVED BY:
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Plackcci K. Eapen!C/tief bate
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Systems Section, EB, DRS 1140071 940104
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Areas Insoccted: Announced safety inspection of the fire protection program and its implementation in the areas of administrative controls, surveillances, combustible controls, testing, audits, brigade training, firewatch program and followup on previously identified NRC inspection report findings in the areas of fire protection and emergency' service water.
Results: No significant safety issues were identified with the fire protection equipment, system, or program. The fire detection surveillance, control of combustibles, fire brigade training and drills and fire audits are being conducted as described in the site fire protection plan. The fire protection system for the site is operational and a dedicated firewatch is performing a controlled compensatory firewatch inspection when needed as part of their site rounds program. The licensee had approximately twelve locations in their compensatory firewatch program at the time of this inspection. A licensee weakness in documenting the safety significance of the new fire doors between the turbine building and the new administration and support facility is detailed in Section 8.0. Fire protection open items are evaluated and classified as part of their work schedule planning program. The fire equipment backlog is listed in a site " Work Order" computer program that tracks the 076 system, which list all the fire equipment components. The fire items in the backlog did not affect the operability of the fire system.
The status of the items listed in the licensee's tracking report, " Fire Protection Post-Startup Item Status," are addressed in Sections 10.0 and 11.0 of this report that provide details on previously identified NRC inspection report findings. Several open items were reviewed.
As stated in Section 11.0, the packages provided by the licensee as complete did not contain sufficient information to close several of the issues. Additional licensee commitments were not completed by the committed date in several cases. Licensee management support is i
required to facilitate closure of open items in the fire protection area.
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DETAILS 1.0 FIRE PROTECTION PROGRAM (64704)'
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This inspection was performed to evaluate the adequacy of the licensee's fire protection program and the associated implementing procedures and to review the status of previously
identified NRC inspection findings documented in the " Fire Protection Post-Startup Item l
Status" report. The inspectors verified procedure implementation, technical adequacy of procedures and programs, inspection of plant fire facilities, fire brigade training status,
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firewatch personnel qualifications and program requirements, manpower assignments, combustible controls and review of the licensee's audit program. Surveillance and routine testing, administrative and other procedures related to the implementation of the fire program
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were reviewed by the inspectors to measure the effectiveness of the fire protection program, r
1.2 Plant Tour
i The inspectors toured accessible vital and nonvital areas of the site and visually inspected the fire protection water systems, fire pumps, fire water piping and distribution systems, post-l indicator valves, yard hydrants, contents of fire protection equipment storage cabinets and the condition of the fire brigade equipment. The tour also included the inspection of the various
types of fire detectors, alarm panels, positions of automatic and manual fixed suppression instruments, interior plant fire hose stations, fire barrier penetrations, fire doors, and l
discussions with firewatch personnel encountered during the tour. The inspectors noted that most fire protection equipment was operational; and, where there was an item of fire
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protection equipment not operating, it was identified with a deficiency tag, and it was listed in the non-conformance system and fire backlog program. _ Fire equipment tank gauges
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indicated correct levels as described in their procedures and battery powered lights tested l
during the tour were in working order. During the plant tour, the inspectors noted that l
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(except for the fire doors in the compensatory program) the fire doors were closing and latching automatically. Additional details concerning the new support and administration
facility fire doors are discussed in Section 8.0. Also during the tour, the inspectors noted that a leaking jockey pump had been tagged for maintenance to replace and repair the gasket water seal. The inspectors verified that the jockey pump was still capable of performing its required function.
2.0 DOCUi.'ENTS AND PROGRAMS REVIEWED i
I The program documents listed in Attachment 2 of this report were used by the inspectors in performing the inspection of the fire program at this site. In general, the licensee's fire program polices, procedures, drills and analyses reviewed by the inspectors were technically --
sound and effectively implemented. No violations or unresolved items were identified.
'The parenthetical notations following the paragraph title denotes the NRC inspection procedure that was used by the inspector in conducting this inspection.
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3.0 FIRE BRIGADE TRAINING AND DRILLS i
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Fire Department training procedures and attendance records for brigade members were
reviewed by the inspector. The records were complete and mainitained in an up-to-date
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status. The inspector verified that the fire brigade members listed on the November 1993,
" Fire Brigade Qualification Status Listing," have completed their required fire training i
courses including their hands-on training program at the fire school. Discussions with fire brigade members, during the site inspection, indicated that they are cognizant of their j
responsibilities and that the training they are provided is beneficial in maintaining their
awareness of current developments in fire protection and fire fighting techniques.
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Approximately 90 qualified members are listed on the Fire Brigade Qualification Status Listing. This is an adequate number of qualified fire brigade personnel to support the licensee's shift operation which requires 30 to 36 qualified personnel.
4.0 FIREWATCII PROGRAM
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The shift Drewatch personnel receive their shift assignments from the fire shift supervisor.
Permanently assigned personnel perform the firewatch task for this site. The fire shift supervisor is notified of the daily firewatch requirements listed in the control room log. The firewatch personnel, as part of their rounds, inspect their assigned firewatch areas and record the firewatch area locations on a firewatch log sheet. The fire shift supervisor verifies that the firewatch personnel performed their required shift assignments by randomly inspecting firewatch personnel on shift. In conjunction with this random inspection, the fire protection supervisor also audits the firewatch logs. The NRC inspectors verified that the 12 locations listed on the firewatch log sheets were verified by the firewatch personnel and documented on their rounds log sheets during a firewatch shift review on November 17,1993. The inspectors also reviewed the firewatch personnel training records to ensure that they have received their required firewatch training.
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5.0 COMBUSTIBLE CONTROL PROGRAM The inspectors reviewed the implementing procedures established by the New York Power Authority (NYPA) to support the control of combustibles at the FitzPatrick site. The scope of the inspectors' review included the handling of and limitation on the use of combustibles, flammables, and explosive hazards in safety-related areas. In addition, control of transient fire loads during maintenance and modification activities and the appropriate administrative requirements were reviewed to identify potential transient fire loads and the additional fire protection required. The inspectors compared the licensee's administration of the control of-combustibles with the fire protection program as described in the FSAR and other licensing documents.
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Administrative Procedure 14.02, Revision 2, " Combustibles and Flammable Material Control," provides guidance and specifies requirements for the use and storage of combustible materials. In addition, job responsibilities and specific instructions for implementing this procedure were presented. Other procedures reviewed associated with the control of combustibles are listed below.
e WACP-10.1.13, Rev.6, " Chemical Material Control Program" WACP-10.1.13, Rev.5, " Disposal of Waste Oil, Chemicals, and Material" o
WACP-10.1.33, Rev.2, " Hot Work Permits" FPP-2.4, Rev.7, " Fire Protection Inspections" e
STD-4.600, Rev.1, " Smoking Policy" AP-10.03, Rev.2, " Work Package Planning"
These procedures directed in-plant reviews of fire hazard loading prior to storage and periodic inspections for accumulation of combustibles. The inspectors verified that measures had been established to adequately track transient combustibles via the combustible control permit system and periodically verify material quantities by performance of weekly plant walkdowns. The inspectors performed a plant walkdown of selected plant areas including interim waste storage areas. The inspectors did not identify any nonconforming conditions.
Based on this review, the inspectors concluded that the licensee had devcicped and was implementing adequate procedures to ensure that the use and storage of materials remained within safe limits for combustion and flammability. No unacceptable conditions were identified by the inspectors.
6.0 FIRE EQUIPMENT TESTING The inspectors reviewed the following fire protection equipment surveillance test procedures, and test results to verify that the fire system equipment was in conformance with the requirements of the Technical Specification and that the fire system was in an acceptable operational status. A review of the last six months' test results and calculations indicated that the equipment met the test procedure acceptance requirements with no indication of system degradation.
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ST-76A, Fire Protection System Weekly Check AP-1.6, Fire Protection Program
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ST-76B, Electric Fire Pump Operational Check
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ST-76C, West Diesel Fire Pump 76P-1 Operational Check
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Fire Pump Performance Evaluation Methodology, Calculation No. JAF-CALC-FRS-01170 A review of the Semi-Annual Fire Hydrant Check Procedure (FPP-3.5) results indicate that all yard fire hydrants and associated hydrant hose houses met the requirements of the piocedur,
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The NRC inspectors review oflicensee trend data reports on the results of the above tests
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indicated that there was no system degradation at the time of this inspection.
7.0 AUDITS OF FIRE PROGRAM The inspectors reviewed the latest annual audit report (No.793) performed on the fire protection program plan and system equipment during the month of November 1992. The
1992 audit report did not identify any fire concerns.
The fire protection Triennial Audit (No.91-07) was conducted from June 3 through
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July 21,1991. The licensee's findings identified in this audit were determined by the NRC i
inspectors to be inconsistent with the National Fire Protection Association (NFPA) Code 13, 1972 in the occupancy classification definition of the Emergency Diesel Generator Room
(EDG). The audit identified the EDG rooms as an " Extra Hazard." Based on this
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classification, the installed sprinklers in these rooms are not designed to NFPA Code 13 requirements. The licensee fire protection engineer did an evaluation of the EDG sprinkler design (NED-JAP-93-452, November 17,1993) and established that the audit report was in error and the correct classification for the EDG rooms are considered " Ordinary Hazard."
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NFPA Code 13, 1972.
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8.0 TURBINE IlUILDING FIRE DOORS During a tour of the plant, the inspectors noted that the two fire doors between the turbine building and the newly constructed cdministration building had not been installed as planned because construction in the area was continuing. The inspectors requested information concerning what Technical Specification Limiting Condition for Operation and Action
Statements applied to these doors and what compensatory measures were in place. NYPA operations and site fire protection personnel stated that they did not believe that these doors were regulatory fire doors. However, hourly roving fire watches had been established as a
conservative measure because the doors were required by the New York state building codes.
Further discussions with corporate fire protection engineering personnel indicated that these were technical specification controlled fire doors. The inspectors verified that the doors
were included in the technical specification required surveillance procedure for fire barrier penetration seals, ST-76Y, " Fire Door Inspection and Operability Test," Revision 8, dated
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August 17, 1993. NYPA engineering personnel stated that the safety evaluation for the construction of the new administration building would be updated to better reflect all the
regulatory fire protection concerns. The fire watches established for these doors provided compensatory actions required by the technical specification.- The inspector had no further questions on this issue.
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9.0 LICENSEE EVENT REPORTS RELATED TO FIRE SYSTEM l
In 1992, the licensee issued nine Licensee Event Reports (LER's) which were identified with
missed fire watches, inadequate fire supervision training and inadequate fire watch training.
These problems were identified in LERs 92-001-00, 92-006-00, 92-010-00, 92-019-00, 92-025-00, 92-030-00, 92-042-00, 92-045-00 and 92-052-00. To correct the conditions that led i
to above LERs, the licensee replaced the fire supervisors, retrained the firewatch personnel
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and reduced the firewatch staff to a manageable level. The fire training instructor retrained
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the compensatory firewatch personnel to Procedure LP-13.9.2, January 21,1993. This
retraining and reduction in firewatch personnel were effective and no LER's were issued in
this area since the completion of the above actions. The NRC inspectors interviewed
randomly selected compensatory firewatch personnel on the items described in the 1992
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LER's. The personnel were aware of the problems associated with the firewatch program in 1992 and indicated that their re-training and supervisor control corrected the conditions that existed in 1992. Based on the re-training of the firewatch personnel, discussions with the fire supervisors and no LER's on this subject since the corrective action, the inspectors
considered that the licensee's actions were adequate to resolve the concerns of the above
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10.0 LICENSEE'S ACTIONS ON PREVIOUSLY IDENTIFIED NRC FINDINGS i
(92701)
i (Closed) Violation No. 50-333/93-18-01 reeardine the control of combustibles in storace i
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NRC Inspection Report No. 50-333/92-80 documented examples of the licensee's failure to implement adequately the license condition requirements for control of combustibles. During NRC inspection 50-333/93-06, this area was reviewed and the inspector determined that the combustible control procedures for this area still needed improvement. Another inspection conducted in September 1993 (Inspection Report No. 50-333/93-18) revealed that Work Activity Control Procedure (WACP) 10.1.10, " Control of Combustibles and Flammable Materials," Revision 7, which implements technical specification requirements, had not been fully implemented. Specifically, the procedure required the Fire Protection Supervisor to establish alert and action levels for various transient combustible storage areas in the plant.
Additionally, these alert and action levels were established by calculations using data from weekly Interim Waste Storage Logs to determine the quantity of combustible and flammable materials present. Failures by the licensee to establish the calculated Alert and Action levels -
and implement fully Procedure WACP 10.1.10, were documented as two examples of a i
violation of Technical Specification 6.8.A.
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During this inspection, the corrective actions were reviewed which were established by NYPA as presented in their reply letter to the Notice of Violation, JAFP-93-0582, dated November 3,1993. In response to the Notice, NYPA stated that the alert and action levels for storage of transient combustibles were established on September 9,1993, and that the appropriate guidance and direction for implementation of the alert and action levels had been provided to the fire inspectors via the night order log book. The reply letter also stated that -
a review by the licensee of the process for controlling combustibles in interim storage areas identified procedunJ improvements. These improvements included more timely identification and disposition of transient combustibles. Improvements were scheduled to be implemented by November 19, 1993.
The inspectors reviewed the licensee's alert and action levels established for seven various storage areas of the plant. Alert and action levels were established using the baseline storage levels and the overall effects on the Fire Hazard Analysis (FHA) and available fire protection features. The alert and action levels established for the interim waste storage area were determined to be 61,760,000 BTU and 77,200,000 BTU, respectively. These values correspond to eight 55 gallon and ten 55 gallon drums of oil, respectively.
The inspectors reviewed Administrative Procedure 14.02, Revision 0, " Combustibles and Flammable Material Control," which replaced WACP 10.1.10, Revision 7. This new procedure deleted the reference to alert and action levels discussed in the violation and referenced two WACPs revised to control fire hazard quantities. This administrative procedure also added a requirement that the Fire Protection System Engineer review and maintain the log of weekly Interim Waste Storage Area inventory sheets prepared by the Environmental Engineer.
The two WACPs, Number 10.1.13, Revision 6, and 10.1.14, Revision 5, had been revised to place specific responsibility on the waste generator for controlling combustible and flammable material quantities prior to placing any material in a designated storage area. In addition, all site personnel were directed to contact the Fire Protection Supervisor for any needed guidance or clarification.
The inspectors reviewed the night order information provided to fire inspectors and determined this action was sufficient for identifying the need to determine baseline and transient combustible and flammable material quantities. The inspectors performed an extensive walkdown of several storage areas including the Interim Waste Storage Area and did not identify any non-conforming conditions.
The inspectors also verified that all appropriate plant personnel including instrumentation and controls, buildings and grounds, and maintenance personnel had received training regarding the new procedure revisions and requirements. The licensee stated that th_e future general employee training will also address requirements regarding control of combustible.
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Based on the licensee's corrective actions, the inspectors determined that adequate measures '
q had been established to sufficiently limit the quantities of stored fire hazard materials and
responsibilities had been delineated to prevent exceeding the established requirements. This item is closed.
(Closed) Violation No. 50-333/92-80-04 regarding the 43 Open Items Resulting from the 1992 Annendix R Reanalysis
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NRC Inspection Report No. 50-333/92-80 documented 43 issues that a NYPA 1992 Appendix R reanalysis identified that needed to be resolved in order to achieve full compliance with the post-fire safe shutdown capability of Section III.G of Appendix R to 10 CFR 50.
The inspectors * review found that 42 of these issues had been reviewed and closed in NRC Inspection Report 50-333/92-14. The remaining issue was reviewed and closed by NRC Inspection Report 50-333/93-17. Based on the above, this report administratively closes the
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violation.
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(Closed) Unresolved Item 92-81-04 regarding power sup_ ply voltages t
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The emergency service water logic diagram ESK-10GA indicated that the output of the ac/dc power supply was 135 Vde, whereas the output of the de supply is shown as 125 Vdc.
During a walkdown of the relay panel, the licensee noted that the uninterruptible power
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i supply voltage was 165 Vdc.
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The design of the existing de power supply is such that when no load is on the system the
voltage will read high, and when the interposing relays load the de power system the voltage j
drops. The present 250 interposing relays connected to the de power source are in a de-l energized state. As a signal is detected, the contacts on the relays close energizing the relay
coil and indicating on the control room annunciator panel. The design has been sized so that at full load (250 energized relays coils) the de voltage will drop between 125 to 130 Vdc.
i The inspectors reviewed the licensee history for the last five years on these relays and there is no history of relay failures in their data records. On November 19, 1993, the licensee i
added notes to their drawing No.11825-ESK-10GA explaining the loading and Vdc readings.
Based on the function of the de power supply design, the loading requirements of the de-l energized relay coils, the lack of any relay failures in this design and the adding of additional i
information on the drawing, this item is closed.
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(Closed) Unresolved Item (URI 333/92-81-05)
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NRC Generic letter 89-13, Action VI, requested licensees to confirm that the service water l
system will perform its intended function in accordance with the licensing basis for the plant, including consideration for a single active failure. NRC Inspection Report 50-333/92-81'
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concluded that, in general, the single active failure analysis performed by NYPA's
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consultant, NUTECH, appeared to be acceptable although it was noted that this analysis did
not recognize that a single active failure interrupting the emergency service water flow to either train of crescent area unit coolers could compromise both trains of emergency core cooling system equipment. Specifically, it did not appear that the analysis considered that j
the wall separating the east and west crescents was not full height and; therefore, if only one train of coolers was available, the operable train would have to cool both crescent areas.
l This issue was left unresolved pending the licensee's re-review of the single active failure analysis and the implementation of actions required as a result of this analysis.
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The inspectors found that NYPA had a new analysis, " Emergency Service Water (ESW)
System Single Failure Analysis for James A. FitzPatrick Nuclear Power Plant," dated October 12, 1992, performed by a contractor. This analysis did consider the unavailability of one train of the crescent area unit coolers as a result of the loss of one ESW pump, and one train's injection motor-operated valve or an in-line check valve's failure to open. The analysis identifies that these conditions could be identified in the control room by a change in the total ESW flow indication. Additionally, the alarms and annunciators for HPCI and RCIC steam leak detection systems, which measure area temperatures near these pumps located in the crescents, would actuate at 104 F. It was noted that the anticipated temperature,110 F, during a postulated accident was used in the calculations for the design life of the environmentally qualified equipment. Operator procedural response for these high temperature alarms is to go to the local panel to investigate the situation and verify the service water system line-up. The inspectors noted that these instruments are safety-related and QA Category I. Non-safety grade instrumentation also provides control room indication of the east and west crescent area temperatures. The licensee considers the existing safety-related instrumentation adequate indication of crescent area temperature, but has an outstanding work request for engineering to evaluate whether the non-safety instrumentation should be upgraded to safety-related.
The inspectors noted that the contractor's report made additional recommendations based on their analysis. Technical Services Systems Engineering Memorandum, JSEM-92-081, dated November 11,1992, evaluated and dispositioned these. items by adding corrective actions to the licensees corrective action tracking system. The inspectors reviewed a sample of the recommended corrective actions, such as, adding valves and valve positions to the existing system line-up procedures, and found that these items had been completed. This item is l
closed.
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r (Closed) Unresolved Item (URI 333/92-81-07)
NRC Inspection Report Number 92-81 identified that three pairs of valves (70WAC-5A and 5B,46(70)SWS-9 and 10,46ESW-10A and 10B), were not in the Inservice test (IST)
program. This item was left unresolved pending NYPA's final evaluation as to whether these valves belonged in the IST program.
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The inspectors reviewed NYPA Performance Engineering Evaluation, JPEM-92-028,
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"Special - Component Evaluations for IST Program Applicability," dated September 26,1992, to determine what actions had be.en taken to address this issue. The
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evaluation stated that valves 70WAC-5A and 5B were added to the IST program as part of Revision 5, on May 14,1992. The inspectors confirmed this by reviewing Revision 7 of the i
IST program. The inspectors also verified that the cycling of these valves was included in
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Surveillance Test Procedure ST-8V, " Control and Relay Room Refrigeration Water Chiller I
System Quarterly Manual Valve Test (IST)," Revision 1, dated October 6,1993.
The NYPA engineering evaluation stated that valves 46(70)SWS-09 and 10, which were designated as the boundary valves between safety and nonsafety classification, are now used for flow balancing and not isolation and; therefore, these valves should not be included in the IST program. This agrees with the Inspection Report 92-81 finding that the licensee proposal to upgrade the service water piping to safety-related would be an acceptable method to eliminate the need to exercise the valves. The inspectors verified that the piping had been upgraded to safety-related and added to the Inservice Inspection (ISI) program by reviewing
the following documents: Modification Control Manual Procedure (MCM)-6A, " Component Classification and System Safety Function Control (JAF)," Revision 3, dated August 25,1993; Drawing Number ISI-FB-35E, " Flow Diagram - Control Room Area Service & Chilled Water - System 70," Revision 3; Drawing Number FB-35E, " Flow Diagram - Control Room Area Service & Chilled Water - System 70," Revision 22.
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For valves 46ESW-10A and 10B, the evaluation concluded that the valves are not required to be included in the IST program. The purpose of these valves is to isolate the control rod drive (CRD) coolers from the emergency service water system (ESW). These valves are in
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the reactor building (RB) and credit cannot be taken for operator action because the RB would be uninhabitable during a design basis accident (DBA). The concern is that the CRD-pumps are a non-safety load that is un-isolaole during a DBA; therefore, diverting flow from
safety-related equipment. In an evaluation performed for NYPA, Stone and Webster Calculation 02268-M-5017-3, Variation in Target Flows for Surveillance Test ST-8Q with Lake Level, ESW Pump Strainer Pressure Drop and Pump Head, Revision 1, dated August 14, 1992, concluded that this flow diversion would be negligible on the balance of the system. The inspectors found that the calculation results were based on a computer -
model of the system. The inspectors noted that these computer generated results did indicate no significant difference between system balance with and without the CRD cooler on line.
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Based on the above review, the inspectors considered the licensee's actions adequate and this unresolved item is closed.
The following items were provided to the inspectors as complete and ready for NRC review.
NRC review found that although progress had been made, these items were incomplete and the information submitted to the inspectors was inadequate to close the items.
(Undated) Unresolved Item (URI 333/93-18-02) and Inspection Follow-up Item (IFI 333/92-14-06 IItem 2.2.41) regardine Fire Fighting Pre-Plans These items were established to track the licensee's long term corrective action to resolve escalated enforcement item, EEI 333/92-80-15F, for NYPA's failure to implement an effective Fire Protection Program as required by Amendment No. 47 to the FitzPatrick Operating License Condition,2.C.(3), including the failure to develop and maintain adequate fire fighting plans. These items were previously reviewed in Inspection Reports 92-14 and 93-18. A NYPA letter, JPN-93-036, " Fire Protection Improvement Program Schedule Revision," dated May 19, 1993, provided a revised schedule date of September 1993 to complete the upgrade of the fire Oghting preplans to resolve these issues.
NYPA representatives identified that this issue was complete and provided a closure package to the inspectors that they considered ready for NRC review. During this inspection period, the inspectors found NYPA's work on this issue as not complete. An Engineering Standards Manual section, FPES-05, " Pre-Fire Plans," that has been developed to provide detailed guidance relative to the development and organization of pre-fire plans was in the final review and signature process. The upgraded fire fighting pre-plans were not complete in that the licensee had not incorporated plant walkdown comments and Plant Operating Review Committee (PORC) review remained. As such, the NYPA did not meet their committed date of September 1993. Therefore, these items remain open.
(Updated) Inspection Follow-un item (IFl 333/92-14-08 IItem 2.3.21) regarding Improved Fire Protection Program Training for Design Engineers NYPA letter, JPN-91-050, dated September 13, 1991, identified a schedule for completing long term action items for improving NYPA's fire protection program at the James A.
FitzPatrick Nuclear Power Plant (JAFNPP). Item VIII.F.1 from this letter identified NYPA's commitment to improve the training for design engineers dealing with fire protection issues by June 1992. NYPA letter, JPN-92-023, dated May 27,'1992, re-identified this commitment as item 2.3.2 and changed the ' schedular commitment to complete the training by December 1992. NYPA letter, JPN-93-036, dated May 19, 1993, updated the scheduled completion of this item to September 1993. This inspection followup item was opened as a result of Inspection Report 92-1..-.
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NYPA representatives identified that this issue was complete and they provided a closure package to the inspectors that was considered, by NYPA, ready for NRC review. During this inspection period, the inspectors found NYPA's work on this issue was not complete.
The training of design engineers at the James A. FitzPatrick Nuclear Power Plant site had been completed in September 1993. However, the Engineering Support Personnel Training Program had not been updated to identify what fire protection related training would be provided to newly hired engineering personnel and what, if any, refresher training would be provided. -The NYPA representatives stated that the Engineering Support Personnel Training Program Review Committee was scheduled to meet in December 1993 and the "new hire" and refresher training issues were scheduled for evaluation at that time. As such, NYPA did not meet their committed date of September 1993. Therefore, this issue remains open.
LIJpdated) Escalated Enforcement item (EEI 333/92-80-14): A) Item VI. A regardine Maintenance and Surveillancs of Emergency Lighting Units: B) Item C regarding Accessibility of 25 ASP-2 A)
Item VI.A renardine Maintenano and Surveillance of Emergency Lighting Units NRC Inspection 92-80 identified a violation for NYPA's failure to incorporate vendor
'i recommended monthly, quarterly, and annual maintenance and testing into the emergency lighting surveillance and test procedures to assure operability and availability of emergency lighting units. As documented in an NRC letter, dated July 10, 1992, and at an enforcement conference held on June 24,1992, NYPA's response to this violation stated that their
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corrective actions would include: 1) a review of the maintenance and surveillance requirements for emergency lighting units as specified in the manufacturers' technical bulletins, Electric Power Research Institute's (EPRI's) report, and a consultants report; and 2) revision of m'ntenance and surveillance procedures to implement results of the procedure review and doc. _nent specific elements associated with maintenance and surveillance, testing, lamp orientation, and illumination levels. NYPA's response to this violation in Item VI.A in letter JPN-92-063, dated October 15, 1992, stated that their corrective actions included revising the emergency lighting surveillance procedures to incorporate appropriate requirements that will ensure that the emergency light units are properly maintained and that the vendor maintenance recommendations were considered in determining maintenance requirements. NYPA letter JPN-93-036, dated May 19, 1993, summarized the outstanding emergency lighting unit commitments and provided July 1993 as a schedule date for their completion.
The inspectors also noted that NRC Inspection 93-06, conducted in March and April 1993, had previously reviewed this issue, but the item was not closed because all of the vendor recommendations had not been incorporated into NYPA's emergency lighting unit surveillance procedures and technical evaluations have not been prepared to justify variance.
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NYPA representatives identified that this issue was complete and they provided a closure package to the inspectors that was considered, by NYPA, ready for NRC review. During this inspection period, the inspectors found NYPA's work on this issue was not complete.
Review of engheering evaluation JAF-RPT-FPS-01168, " Evaluation of Vendor Reco.mmended Test Requirements for Appendix R Emergency Lighting Units," Revision 0, dated April 29, 1993, found that this evaluation recommended.not incorporating all of the vendor recommended surveillance and testing. It was also noted that the evaluation did not appear to have reviewed all of the EPRI recommendations as NYPA had indicated that they would in the June 24,1992, enforcement conference. From discussions with NYPA representatives, the inspectors found that a NYPA contractor, Engineering Planning and Management, Inc. (EPM), had recently completed a point-by-point review of the EPRI maintenance and testing recommendations and documented recommended procedure improvements in a letter from EPM to NYPA, dated October 6,1993. The NYPA representatives stated that they have not completed their review of this document to determine what recommendations they will implement. The inspectors concluded that NYPA efforts to update their emergency lighting unit maintenance and surveillance procedures was incomplete. Therefore, this portion of this item remains open.
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Item C regarding Accessibility of 25 ASP-2 Section VII, Item C of NYPA letter JPN-93-036, dated May 19, 1993, summarized NYPA's outstanding emergency lighting unit corrective action commitments and provided a schedule for their completion. It stated that for emergency lighting units they would "... assess the placement of Alternate Shutdown panel 25 ASP-2..." by July 1993.
NYPA representatives identified that the three issues listed in this letter were complete and they provided a closure package to the inspectors that was considered, by NYPA, ready for NRC review. The inspectors reviewed NYPA's assessment of the placement of Alternate Shutdown panel 25 ASP-2. NRC Inspection 92-80 identified that this panel was mounted on the wall halfway up an adjacent stairway, potentially placing an operator in a precarious position on the stairway in order to reach the upper right section of the safe shutdown panel.
NYPA memo, NED-AJB-93-097, dated April 20,1993, documented the licensee's review and evaluation of operator access to Alternate Shutdown panel 25 ASP-2. This evaluation concluded that the panel was adequately accessible based on the panel only being manned for-less than 30 minutes during alternate shutdown activities. It also stated that the panel was validated to be accessible during the development of the Alternate Shutdown Procedure, AOP-43, and the panel's Surveillance Procedure, ST-4 _ _ _ _ _ _ _ _ _ _ _ _ _ _
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During an inspection of panel 25 ASP-2, the inspectors noted that a short step ladder, labeled AOP-43, was chained to the sair railing adjacent to the panel. The inspectors als, found fuses and a fuse puller in the adjacent alternate shutdown equipment locker. This equipment was not in the Surveillance Test ST-99C, " Safe Shutdown Equipment Inventory and Panel Operability VeriGcation," Revision 12, dated June 18, 1993. The inspectors discussed the need for the step ladder and the discrepancies between the equipment available and the surveillance test. NYPA representatives stated that this equipment was left over from the previous alternate shutdown scheme that required replacing all the fuses in the panel prior to its use. It was stated that this equipment has become unnecessary due to a 1989 modification that installed parallel fuses in the alternate shutdown panel. The inspectors noted that the surveillance test was not revised to reflect the modiGed equipment inventory as a result of the lack of attention to detail. The surveillance procedure change had not been completed by the end of the onsite inspection period.
The inspectors found NYPA had made progress on this item but not all of the corrective actions for these issuts were complete. The inspectors veriGed the licensee's conclusion that the Alternate Shutdown panel 25 ASP-2 was accessible to support alternate shutdown of the plant, although it is not ideally located. As identified in the previous section, the inspectors concluded that the issue related to the vpdating of the emergency lighting unit maintenance and surveillance procedures was incomplete. Therefore, these issues will remain open pending NRC verification of the completion of the above actions and all the commitments in NYPA letter JPN-93-036. As such, the NYPA did not meet their committed date of July 1993.
(Updated) Deviatic.n (DEV 333/92-81-01) regarding Emergenc1 ervice Water Flow Rates S
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NRC Inspection Report Number 92-81 identified a NYPA deviation; the licensee's failure to adjust the emergenc3 service water flow rates to individual crescent area unit coolers to the minimum value that is specified by the Final Safety Analysis Report (FSAR). NYPA's response to the Notice of Deviation, transmitted in NYPA letter JAFP-92-0578, dated August 4,1992, included the following schedule of corrective steps to be taken to avoid further deviations. 1) the FSAR will be revised to include both design speciGcations and operability requirements of the crescent area unit coolers (Scheduled due date - 1993 FSAR update); 2) the internal procedures used to maintain and update the FSAR will be reviewed including an assessment of the FSAR level of detail (Scheduled due date - 9/30/92); and 3)
the process for review and revision of the FSAR will be enhanced to reflect current plant con 0guration and design basis documents (Scheduled duc date - 12/30/92); 3) NYPA will formally document the FSAR deviation in accordance with their internal procedures.
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The inspectors began to review NYPA's corrective actions and found that the FSAR had been revised as committed. The FSAR revision was not reviewed during this inspection because the two remaining scheduled corrective actions were not complete. Discussions with licensing personnel indicated that the schedule for completing the planned corrective actions had been delayed. The NYPA personnel informed the inspectors that the NRC was verbally notified of this delay in June 1993, and NYPA made a commitment at that time to submit a revised schedule via docketed correspondence. Therefore, this item remains open.
11.0 EXIT MEETING Licensee management was informed of the scope and purpose of the inspection at an entrance meeting conducted on November 15, 1993.
The findings of the inspection were discussed periodically with licensee representatives during the course of the inspection listed in Attachment 1 of this report. An exit was conducted on November 19, 1993, at which time the fm' dings of the inspection were presented.
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ATTACHMENT 1
Persons Contacted i
New York Power Authority Personnel
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- R. Barrett, General Manager-Operations
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- W. Bergins, Public Affairs
- F. Bioise, Fire Protection Engineering Manager
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- M. Colombs, General Manager-Support Systems l
- F. Edler, Technical Services Manager
- T. Hermann, Technical Programs Consultant i
- J. Hoddy, Licensing Engineer
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- G. Hofer, BWR Licensing Engineer
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- D. Lindsey, General Manager-Maintenance
- B. MacDonald, Fire Protection Supervisor j
- J. Pechacek, Fire Protection Engineer
- R. Post, Quality Assurance Engineer
- L. Retzer, Fire Protection
- D. Ruddy, Site Engineering Manager i
- H. Salmon, Resident Manager
- J. Scott, Quality Assurance Specialist
- S. Sutkowski, System Engineer i
- G. Tiner, Fire Training Engineer
- A. Zaremba, Operations Review Manager
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United States Nuclear Regulator Commission
- W. Cook, Senior Resident Inspector
- Denotes those personnel attending the exit meeting of November 19, 1993 The inspectors also held discussions with managers, supervisors and other licensee employees during the course of this inspection including operations, technical, quality assurance and administrative personnel.
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ATTACHMENT 2 i
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Documentation Reviewed i
Fire Protection Procedures
- ST-76A, Fire Protection System Weekly Check AP-1.6, Fire Protection Program i
- ST-76B, Electric Fire Pump Operational Check
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- ST-76C, West Diesel Fire Pump 76P-1 Operational Check
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- ST-76Y, Fire Door Inspection and Operability Test, Revision 8, dated August 17,1993 l
- ST-99C, Safe Shutdown Equipment Inventory and Panel Operability Verification,
Revision 12, dated June 18,1993
- Maintenance Surveillance Procedures (MST)-076.05, Exide F-100 Emergency Light Surveillance Test, Revision 09, dated July 30,1993
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- MST-076.06, Holophane Emergency Light Surveillance Test, R.evision 01, dated August 2,1993
- ST-8V, Control and Relay Room Refrigeration Water Chiller System Quarterly Manual
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Valve Test (IST), Revision 1, dated October 6,1993
- FPP 1.0, Fire Protection and Prevention Program
- FPP 1.1, Fire Brigade Duties
- FPP 1.8, Compensatory Firewatch
- FPP 2.4, Fire Protection Inspections i
- FPP 3.2, Monthly Fire Equipment Check l
- FPP 4.0, Fire Pre-Plans
- AP-10.03, Work Package Planning
- AP-14.02, Combustibles and Flammable Material Contro!
l Fire System Analysis Reports
- Fire Diesel Flow Data For Pump No. 76P-1, March 4,1993
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- Fire Diesel Pump No. 76P-2 Flow Curves, April 20,1993
- Fire Pump Performance Evaluation Methodology, Calculation No. JAF-CALC-FRS-01170 Fire Audit Reports l
- Annual Audit Report No. 793, November,1992
- Triennial Audit Report No. 91-07, June 3-July 21,1991 i
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Attachment 2
Miscellaneous Fire Program Documents
- Fire Brigade Training Attendance report (60 records reviewed)
- Fire Drill Attendance Reports (January 1,1993-November 1993
- Firewatch Qualified Personnel List, November 1993
- Compensatory Firewatch Training and Approved Personnel Listing, November 1993
- Emergency Service Water Logic Diagram No.11825-ESK-10GA
- Figu e OP-33-3, Fire Protection Water Piping System 76
- Drawing No. FB-48A, Flow Diagram Fire Protection Water Piping System 76
- Drawing No. FB-49A, Flow Diagram Fire Protection Water Piping System 76
- NYPA JAFP-93-0582, Notice of Violation Response
- WACP 10.1.10, Control of Combustibles and Flammable Materials
- WACP 10.1.13, Chemical Material Control Program
- WACP 10.1.14, Disposal of Waste Oil, Chemicals and Material
- WACP 10.1.33, Hot Work Permits
- STD-4.600, Smoking Policy
- Engineering Standards Manual section, FPES-05, " Pre-Fire Plans," (DRAFT)
- FitzPatrick Operating License Amendment No. 47 and License Condition 2.C.(3)
- NYPA letter JPN-92-023, " Fire Protection Improvement Program"
- NYPA letter, JPN-93-036, " Fire Protection Improvement Program Schedule Revision,"
dated May 19, 1993
- NRC guidance document, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance."
- NRC letter to NYPA, dated July 10, 1992, concerning June 24,1992, enforcement conference
- NYPA letter JPN-92-063, dated October 15, 1992
- NYPA letter JPN-93-036, dated May 19, 1993
- NYPA memo, NED-AJB-93-097, dated April 20,1993
- Engineering Evaluation JAF-RPT-FPS-01168, Evaluation of Vendor Recommended Test Requirements for Appendix R Emergency Lighting Units, Revision 0, dated April 29,1993
- EPM letter from Kevin Cloran (EPM) to Frank Bloise (NYPA), dated October 6,1993
- Nuclear Safety Evaluation JAF-SE-92-007, Support and Administration Facility, Revision 5, dated August 19, 1993
- NRC Branch Technical Position 9.5-1
- Final Safety Analysis Report (FSAR)
- NYPA letter JAFP-92-0578, dated August 4,1992
- NRC Inspection Report 50-333/92-81
- NRC Inspection Report 50-333/92-80
- " Emergency Service Water (ESW) System Single Failure Analysis for James A. FitzPatrick Nuclear Power Plant," dated October 12, 1992, performed by Ogden Environmental and Emergency Services Co.
- Technical Services Systems Engineering Memorandum, JSEM-92-081, dated November 11,1992
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Attachment 2
- NYPA Performance Engineering Evaluation, JPEM-92-028, Special - Component Evaluations for IST Program Applicability, dated September 26,1992
- Modification Control Manual Procedure (MCM)-6A, Component Classification and System l
Safety Function Control (J AF), Revision 3, dated August 25,1993
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- Drawing Number ISI-FB-35E, Flow Diagram - Control Room Area Service & Chilled.
Water - System 70, Revision 3
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- Drawing Number FB-35E, Flow Diagram - Control Room Area Service & Chilled Water -
System 70, Revision 22
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- Stone and Webster Calculation 02268-M-5017-3, Variation in Target Flows for Surveillance Test ST-8Q with Lake Level, ESW Pump Strainer Pressure Drop and Pump Head, Revision 1, dated August 14,1992
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