IR 05000333/1996002

Ack Receipt of 960531 & 0616 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-333/96-02 & 50-333/97-02

ML20149F191
Person / Time
Site:	FitzPatrick
Issue date:	07/15/1997
From:	Rogge J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
50-333-96-02, 50-333-96-2, 50-333-97-02, 50-333-97-2, NUDOCS 9707220080
Download: ML20149F191 (4)

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July 15, 1997

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4 Mr. Michael Site Executive Officer New York Power Authority '

James A. FitzPatrick Nuclear Power Plant i

Post Office Box 41 ,

Lycoming, NY 13093 1.

Dear Mr. Colomb:

Subject: NRC Inspection Report Nos. 50-333/96-02 & 97-02 and Notices of Violation This letter refers to your May 31,1996, and June 16,1997, correspondences, in response I to our May 3,1996, and May 8,1997, letters, respectively. 1 Thank you for informing us of the corrective and preventive actions documented in your letters. These actions will be examined during a future inspection'of your licensed '

program.

Your cooperation with us is appreciated.

Sincerely,

Original Signed by:

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John F. Rogge, Chief I Projects Branch 2 Division of Reactor Projects i

Docket No. 50-333 l l

cc:

C. Rapplayea, Chairman and Chief Executive Officer R.- Schoenberger, President and Chief Operating Officer ,

J. Knubel, Chief Nuclear Officer and Senior Vice President  !

H. P. Salmon, Jr., Vice President of Nuclear Operations W. Josiger, Vice President - Engineering and Project Management J. Kelly, Director - Regulatory Affairs and Special Projects

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T. Dougherty, Vice President - Nuclear Engineering )

R. Deasy, Vice President - Appraisal and Compliance Services

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l R. Patch, Director - Quality Assurance G. Goldstein, Assistant General Counsel C. Faison, Director, Nuclear Licensing K. Peters, Licensing Manager gjgllllc@ll*{l{l*l i**

T. Morra, Executive Chair, Four County Nuclear Safety Committee

9707220000 970715 PDR ADOCK 05000333 G PM ^

0FFICIAL RECORD COPY IE:01 L

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i ec w/ copy of Licensee's Response Letters:

Supervi.sor, Town of Scriba C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law P. Eddy, Director, Electric Division, Department of Public Service, State of New York

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- G. T. Goering, Consultant, New York Power Authority J. E. Gagliardo, Consultant, New York Power Authority  !

E. S. Beckjord, Consultant, New York Power Authority  !

l F. William Valentino, President, New York State Energy Research  !

and Development Authority  !

J. Spath, Program Director, New York State Energy Research I

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Michael Distribution w/ copy of Licensee's Response Letters:

W. Dean, OEDO (WMD)

A. Dromerick, NRR K. Cotton, NRR D. Hood, NRR M. Campion, RI R. Correia, NRR F. Talbot, NRR Nuclear Safety Information Center (NSIC)

PUBLIC NRC Resident inspector Region i Docket Room (with concurrences)

Inspection Program Branch, NRR (IPAS)

J. Rogge, DRP R. Barkley, DRP R. Junod, DRP DOCUMENT NAME: G:\ BRANCH 2\RL9702.FTZ

'Sta previous concurrences To rIceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No copy OFFICE * Rl/DRP * Rl/DRP 'Rl/DRP NAME GHunegs RBarkley JRogge DATE 07/ /97 07/ /97 07/ /97 OFFICIAL RECORD COPY

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l Michael Distribution w/ copy of Licensee's Response Letter:

W., Dean, OEDO (WMD)

A. Dromerick, NRR K. Cotton, NRR D. Hood, NRR ,

M. Campion, RI  !

R. Correia, NRR F. Talbot, NRR Nuclear Safety Information Center (NSIC)

PUBLIC NRC Resident inspector Region 1 Docket Room (with concurrences)

Inspection Program Branch, NRR (IPAS) i J. Rogge, DRP l R.' Barkley, DRP I R. Junod, DRP

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DOCUMENT NAME: G:\ BRANCH 2\RL9702.FTZ To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No copy j

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OFFICE Rl/DRP J/f' Rl/DRP g) g Rl/DRP NAM ff GHunegs TV RBarkley #/E JRogg @ l DATGl" '07ll5/97 07/f5/97 [7

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James A. FitzPatrick p

. Nucle:f Pow:r PI:nt \ gd.

P.O. Box 41 Lycoming, New York 13093 315-342 3840

1. > NewYorkPower uicnaei a. coioms

& Authority eient Manager May 31, 1996 JAFP-96-0226 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.C. 20555 SUBJECT: James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Reply to Notice of Violation NRC inspection Report 50-333/96-02 i Gentlemen:

In accordance with the provisions of 10 CFR 2.20'l, Notice of Violation. the Authority submits a response to the notice transmitted by your letter dated May 3,1996. Your letter refers to the results of the routine resident safety inspection conducted by Messrs.

G. Hunegs and R. Fernandes from February 18,1996 to April 6,1996 at the James A.

FitzPatrick Nuclear Power Plant.

Attachment I provides the description of the violation, reason for the violation, the corrective actions that have been taken and the resuhs achieved, corrective actions to be taken to avoid further violations, and the date of full compliance.

Attachment ll provides a summiry of the commitments contained in this submittal, if you have an', questions, please contact Mr. Arthur Zaremba at (315) 349-6365.

- 1 Very truly yours,

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MICHAEL J. COLOMB STATE OF NEW YORK COUNTY OF OSWEGO Subscribed and sworn to before me this 3 i * day of hw /1996 t

--960$04tT4SO760531 *

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PDR ADOCK 05000333 %j

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NOTA $i PUBLIC cc: next page TAMMY L CALKINS 4985563 Notary Pubhc. State of New York Quahfied in Oswego Count Commission Emswres 8/19@ y

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U. S. Nucisar Rsgulatory Commission 475 Allendale Road King of Prussia, PA 19406

Office of the Resident inspector U. S. Nuclear Regulatory Commission l P.O. Box 136 l Lycoming, NY 13093 l Ms. K. Cotton, Acting Project Manager Project Directorate 1-1 Division of Reactor Projects-l/II U. S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 l

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Attachments:

1. Reply to a Notice of Violation 11. Summary of Commitment 1

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Attichm:nt I to JAFP-96-0226

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R: ply to N tics cf VI:lIti n 96-02 Page 1 of 3 Violation Technical Specification 6.8.A.1 requires that written procedures and adininistrative policies #

shall be established, implemented, and maintained that meet or exceed the requirements and recommendations of Section 5 of American National Standards . Institute (ANSI) 18.7-1972, " Facility Administrative Policies and Procedures."

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Section 5 of ANSI 18.7-1972 requires, in part, that facility rules and instructions shall be established pertaining to maintenance that can affect the performance of safety related ,

equipment and that maintenance that can affect the performance of safety-related equipment shall b6 prgerly pre-planned and performed in accordance with written procedures which conform to applicable codes, standards, specifications and criteria.

Administrative Procedure (AP)-05.06, " System internal Cleanliness and Foreign Material Exclusion *," establishes requirements.for maintaining system and component cleanliness during modification, maintenance, operations, and refueling activities. These requirements include administrative controls and techniques established to define practices whh working to minimize the introduction of foreign materialinto systems.

Contrary to this, on February 26,1996, requirements for maintaining system and component cleanliness were not met in that foreign material was found in the pneumatic supply lines and pilot solenoid valves for the safety / relief trolves which revealed that previous system maintenance was not proper ly performed.

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This is a Seve ity Level IV Violation (Supplement 1). <

Admission _or_ Denial of the Alleaed Violation The Authority agrees with this violation.

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Eqpsons for the Violation l

The cause of this violation was inadequate methods used by Mechanical Maintenance personnel to remove debris following rnaintenance activities on small bore tubing.

Additionally, the Authority procedure for system internal cleanliness and foreign material exclusion (AP-05.06) did not contain specific requirements and criteria for flushing of i systems following maintenance activities with the potential to introduce foreign material into plant components and sysdems.

The source of the foreign materialintrusion was determined to be installation of new

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fittings on the Safety / Relief Valve pilot solenoid valve contiections, and replacement of l tubing on pilot solenoid valves, performed during the 1994-1995 refueling outage. The '

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i activity involved cutting of the Nitrogen supply tubing with either a hacksaw or aluminum oxide grinding wheel. Deburring tools were used on the tube ends during assembly of the i

new fittings. Attempts were made to remove foreign material generated using manual means (Tubing was wiped out with tack cloth and Q-tips), however, a flush was not l

l performed following these maintenance activities.

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[ . Rrply to N:tica cf Violation 96-02 Page 2 of 3 Corrective Actions That Have Been Taken b;,

• The Drywell nitrogen system was blown down and sampled at all Safety Relief Valve (SRV) locations and at other appropriate locations in the system to ensure, to the extent practical, that foreign materialin the systeni was reinoved, and to establish a cleanliness benchmark for the system.

• An independent analysis was performed on the foreign material recovered during the assessment of the nitrogen supply system. The data obtained was used as

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input into determining the source of materialintrusion. Analysis included microscopic examination to determlae physical characteristics, and laboratory anulysis to determine material composition.

• Maintenance personnel were briefed on proper FME controls and f!ushing/ blowdown of tub'.ng following evolutions that could generate foreign material.

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• A programmatic atsessment was perforrned on the foreign material exclusion (FME)

program. This assessment included:

- Review of FME practices during the 1994-1995 refuel outage SRV work.

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Administrative review of the program and procedures to ensure all commitments are met, and identify potential improvements to the program.

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Review of selected work packages from the February 1996 forced outage to determine if proper FME controls were established and adhered to.

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Review of the FME progrsm against others in the industry.

• The FME Program, as defined in AP-05.06, " System Internal Cleanlinees and Foreign Matorial Exclusic,n*," nas been revised to include additional guidance regarding flushing of systems following evolutions where debris has been introduced. This gu; dance includes specific requirements and acceptance criteria for flushing of systems. The Program revision also includes improved guidance on determining system cleanliness level requirements.

• Maintenance Department first line supervisors and Central Planning personnel were

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trained on the additional guidance contained in AP 05.06. Additional briefings on the new procedure revision were held with Maintenance and instrument and Control personnel as part of the weekly department meeting.

• Personnel responsible for introducing debris into the system through their activities have been counselled.

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AttachmInt I to .lAFP-96-0226 U )

R: ply ts N:tico cf Violation 96-02

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i Results Achieved i l

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The source of the foreign materialintrusion has been determined and internal cleanliness of the drywell nitrogen supply system has been reestablished. Severalimprovements have been incorporated into a new revision to AP-05.06, " System internal Cleanliness and .

Foreign Material Exclusion *." Maintenance persormel have been briefed on prope; FME controls and flushirg/ blowdown of tubing, and have been trained on the requirements !

contained in the new revision to AP-05.06. The briefing and training has increased worker .

awareness of the importance of implementing proper FME practices during maintenance i activities.

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Corrective Actions to be Taken e Additional training in improved FME procedures and methods will be performed for l all Mechanical Maintenance and appropriate Construction Services Craf t personnel prior to the start of the next refooling outage. (Planned Completion Date: October !

28,1996) i e An assessment of the effectiveness of the corrective actions will be performed by the Maintenance Department. (Planned Completion Date: August 1,1996)

e A review of work packages planned for the upcoming refueling outage will be performed to ensure that the improved AP-05.06 guidance is implemented.

(Planned Completion Date: October 28,1996)

Date When Full Comoliance Will be Achieved Full compliance was achieved upon implementation of the improved procedural guidance of AP-05.06 on May 28,1996.

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Att:chmrnt il ts JAFP-96-0226 kl

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Page 1 of 1 Number Commitment Due Date JAFP-96-0226-01 Additional training in improved FME procedures Oct 28,1996 and methods will be performed for all Mechanical Maintenance and appropriate Construction Services Craft personnel.

JAFP-96-0226-02 An assessment of the effectiveness of the Aug 1,1996 corrective actions will be performed by the '

Maintenance Department.

JAFP-96-0226-03 A review of work packages planned for the Oct 28,1996 upcoming refueling outage will be performed to ensure that the improved AP-05.06 guidance is implemented.

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• * James A. Fit 2P: trick Hucirr Pgwsr Flint

. P O Box 41 i Lycoming. New York 13093 315 342 3840 m0

- (# Authon,dbW ty uien ,,,3, c oio ,3 site executive otocer June 16,1997 JAFP-97-0218 U.S. Nuclear Rer,ulatory Commission Attn: Docum snt Control Desk Mail Station P1-137 Washington, D.C. 20555 SUBJECT: James A. FitzPatrick Nuclear Power Plent Docket No. 50 333 Reply to Notice of Violation NRC Inscection Rooort 50 333/97-02

Dear Sir:

In accordance with the provisions of 10 CFR 2.201, Notice of Violation. the Authority submits a response to the notice transmitted by your letter dated May 8,1997. Your letter refers to the results of an inspection completed at the James A. FitzPatrick Nuclear Power Plant on April 12,1997.

Attachment i provides the description of the violation, reason for the violation, the corrective actions that have been taken and the results achieved, corrective actions to be taken to understand the broader implications of the violation and avoid further violations, and the date of full compliance.

There are no commitments contained in this report.

If you have any question, please contact Mr. Arthur Zaremba at (315) 349-6365.

Very truly yours,

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MICHAEL J. COLOMB STATE OF NEW YOKX COUNTY OF OSWEGO Subscribed and sworn to before me this /6 day of iv C ,1997 fl WJ u M fA > ~

MJC: RAP:las NQTARpUBLIC J l

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! NANCY B. CZEROW Notary Public, State of NewYork

, Quellflod in Oswego County #4864611

Commission Empires / =22* N -

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cc: RIgionni Administrator

• U.S. Nucl:Cr Regulatory Commission

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475 Allendale Road

• King of Prussia, PA 19406 is

Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Ms. K. Cotton, Acting Project Menager Project Directorate I-1 Division of Reactor Projects-l/ll U.S. Nuclear Regulatory Commission Mail Stop 14 82 Washington, DC 20555 Attachments:

1. . Reply to Notice of Violation

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, Realv to Notice of Violation 97 02 Violation L-l

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10 CFR Part 50 Appendix B, Criterion XVI, ' Corrective Action', requires, in part that

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measures shah be established to assure that conditions adverse to quality, such as failures, '

deficiencies, and deviations, are promptly identified and corrected, with corrective action taken to preclude repetition of the condition.

Contrary to the above, the license; failed to take' prompt and adequate corrective action for a condition adverse to quality as exemplified by the following:

Actions taken following the May 19, IS93 shutdown cooling isolation due to a reactor high pressure trip, including the recommendations of Technical Services Systam Engineering Memorandum, JSEM-93-049, Root Cause Analysis of RHR Shutdown Cooling Isolations, dated November 11,1993, to installa high point vent, were not completed and did not prevent the reoccurrence of the automatic engineered safety feature actuation of shutdown cooling isolation on January 24,1997.

This is a Severity LevelIV violation (Supplement I).

Admission Or Denial Of The Alleaed Violatin The Authority agrees that past corrective actions taken did not prevent the shutdown cooling (SDC) isolation which occurred on January 24,1997; however, the Authority has completed several design and proceduralimprovements as a result of analysis of previous SDC isolation events. These improvements have been effective in reducing the occurrence of SDC isolation events. Prior to the May 19,1993 SDC isolation, seven isolation events occurred over a three year period. Since completion of the system improvements, no SDC isolation events (other than the recent event) have occurred.

Reasons For The Violation in 1993, the Authority completed an in-depth engineering review of the recurring problem (seven events in three years) with inadvertent SDC isolations. This review is documented in Technical Services System Engineering Memorandum JSEM-93-049, " Root Cause Analysis of RHR Shutdown Cooling isolations", dated November 11,1993. This review was unable to definitively identify a root cause for the isolation problem due to the numerous design and procedural issues identified during the root cause analysis. The most likely root cause of the intermittent isolation events was postulated to be air in the pressure instrument 02PS 128A sensing line. The cause was based on high speed chattering of the pressure switch, a symptom which is indicative of air in the instrument sensing line and the fact that the isolations did not occur during troubleshooting efforts

, after thorough fill and vent of the pressure instrument and sensing line. Although not  ;

l formally eliminated as a potential root cause, the Authority determined that the air voids in j the RHH suction piping were not the most likely root cause. This was based on the fact L that isolations had been experienced while shifting RHR pumps on an operating RHR loop.

l Based on the 1993 evaluation, immediate corrective action included ensuring the pressure

! sensing line was properly vented and backfilled. The long term corrective action

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Attachment 1 J

, Realv to Notice of Violation 97-02 l

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was rerouting the pressure switch 02PS-128A sensing line to eliminate the air trap. The j i

l 02PS 128A sensing line reroute was completed in March 1995.  !

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l The 1993 engineering review also provided the recommendation to install a high point j j vent. This action, however, was a. low priority, compared to the other recommendations

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l discussed above, based on the conclusions of the engineering report. Although this action l

! was documented and screened through the plant modification process, this modification )

! was never committed by NYPA as a corrective action to prevent SDC isolations in the !

previous Licensee Event Reports because the most likely root cause for the isolations was the air in the instrument sensing line. LER corrective action commitments were completed (procedure changes and removal of air trap in the instrument sensing line). During the !

1994 and 1996 refuel outages and unplanned plant shutdowns, shutdown cooling operation was successfully initiated numerous times with no inadvertent isolations. Based !

on these results, the high point vent modification continued to be a low priority.

Further review of the recent SDC isolation on January 24,1997 by engineering  :

recommended that the high point vent modification be installed. This modification will )

improve system venting capabilities. The operating procedure was revised to require a

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minimum time for venting the system.  ;

l Corrective Actions That Have Been Taken

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e Shutdown Cooling was placed in service after resetting the isolation logic and '

refilling and venting the system in accordance with plant procedures.

e The operating procedure OP-13D RHR Shutdown Cooling was revised to require a minimum fill and vent time of thirty minutes to ensure the best possible system fill and vent given the existing configuration.

e A pla' nt modification to install a high point vent to the system has been reprioritized and is planned to be completed prior to startup from the next refueling outage.

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Based on historical review, previous corrective actions have resulted in significant I l improvement in reducing SDC isolations, but they have not been fully effective in preventing all SDC isolations.

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Reolv to Notice of Violation 97-02

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i The Authority will complete an engineering evaluation of this event relative to previous events documented in JSEM-93-049 to evaluate other contributing causes. (Scheduled Completion Date: 12/16/971 The high point vent modification will be completed prior to startup from the next refueling outage. This modification willimprove the ability to fill and vent the RHR SDC suction piping. [ Scheduled Completion Date: 01/01/99]

The Authority will monitor the effectiveness of this modification in preventing RHR SDC isolations and will perform an engineering evaluation of RHR SDC system operation.

Additional corrective actions will be developed, if necessary, to assure proper RHR system {

response to shutdown cooling initiations, i

l This violation will be submitted to the Training Program Review Committee for

' development of lessons learned from this event into appropriate engineering and ,

management training. [ Scheduled Completion Date: 07/01/97]

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Date When Full Comoliance Will Be Achieved Full compliance will be achieved upon completion of the high point vent modification scheduled to be completed prior to startup from the next refueling outage.

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