IR 05000333/1996006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-333/96-06

ML20132E742
Person / Time
Site:	FitzPatrick
Issue date:	12/16/1996
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
NUDOCS 9612230384
Download: ML20132E742 (3)

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December 16, 1996 Mr. Michael Plant Manager New York Power Authority James A. FitzPatrick Nuclear Power Plant Post Office Box 41 Lycoming, NY 13093

Dear Mr. Colomb:

Subject: NRC Inspection Report No. 50-333/96-06 and Notice of Violation This letter refers to your November 27,1996 correspondence, in response to our  ;

October 23,1996 letter.  :

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Thank you for informing us of the corrective and preventive actions documented in your letter. .These actions will be examined during a future inspection of your licensed program. j Your cooperation with us is appreciated.  !

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Sincerely, i

Original Signed by: ,

Richard S. Barkley for l Curtis J. Cowgill, Chief Projects Branch 2 Division of Reactor Projects Docket No. 50-333 cc:

C. Rappleyea, Chairman and Chief Executive Officer R. Schoenberger, President and Chief Operating Officer W. J. Cahill, Jr., Chief Nuclear Officer H.- P. Salmon, Jr., Vice President of Nuclear Operations W. Josiger, Vice President - Engineering and Project Management  !

J. Kelly, Vice President - Regulatory Affairs and Special Projects T. Dougherty, Vice President - Nuclear Engineering R. Deasy, Vice President . Appraisal and Compliance Services R. Patch, Director - Quality' Assurance j G. Goldstein, Assistant General Counsel-

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j C. Faison, Director, Nuclear Licensing . j T. Morra, Executive Chair, Four County Nuclear Safety Committee 9612230384 961216

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PDR ADOCK 05000333 0 PM }

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OFFICIAL RECORD COPY IE:01 j

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Michael ,

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cc w/ copy of Licensee's Response Letter:

Supervisor, Town of Scriba C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law

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P. Eddy, Director, Electric Division, Department of Public Service, State of New York G. T. Goering, Consultant, New York Power Authority J. E. Gagliardo, Consultant, New York Power Authority F. William Valentino, President, New York State Energy Research

and Development Authority

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J. Spath, Program Director, New York State Energy Research and Development Authority i

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

D. Screnci, PAO )

W. Dean, OEDO (WMD)

S. Bajwa, NRR l

K. Cotton, NRR l D. Hood, NRR j M. Campion, RI l

R. Correia, NRR  ;

R. Frahm, Jr., NRR i

L. Cunningham, NRR D. Barss, NRR Nuclear Safety information Center (NSIC)

, PUBLIC NRC Resident inspector Region I Docket Room (with concurrences)

Inspection Program Branch, NRR (IPAS)

R. Barkley, DRP R. Junod, DRP J o

l DOCUMENT NAME: G:\ BRANCH 2\RL9606.FTZ To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / 99clgsure "N" = No copy ,

OFFICE Rl/DRP ff/// Rl/DRP ///j / Rl/DRP //ff NAME_ GHun,egs 7ffk RBarkley 'J(//p n CCowgill fyff-DATEg 12//f /96 ' 12////96 ' 7/ 12/14/96 OFFICIAL RECORD COPY <

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. JImea A. FitzPatrick Nucirr P'. Mr Pl;nt

, PO Box 41 LyCOrmng. New York 13093 315-342-3840 GWD 1# Authan,rdWer Michael ty neo m ame w November 27, 1996 JAFP-96-0474 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 50-333/96-06 Gentlemen:

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 October 23,1996. Your letter refers to the results of the integrated inspection completed at the James A.

FitzPatrick Nuclear Power Plant on September 28,1996.

Attachment I provides the description of the violations, reason for the violations, the corrective actions that have been taken and the results achieved, and the date of full compliance.

Attachment il provides the summary of commitments.

If you have any question, please contact Mr. Richard Plasse at (315) 349-6793.

Very truly yours,

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Att: chm:nt I to JAFP-96-0474

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RIply ts N:tica of Viol:ti:n 96-06

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VIOLATION t

A. Technical Specification 6.8.(A)1 requires that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the

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requirements and recommendations of Section 5 of American National Standards Institute (ANSI) 18.7-1972 " Facility Administrative Policies and Procedures."

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sedan 5.1.2 of ANSI 18.7-1972 states in part, that procedures shall be followed,

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and the requirements for use of procedures shall be prescribed in writing.

Contrary to the above, on September 16,1996, during work associated with WR '

96-02875-00, to perform calibration of 7159N-1UPRN05, two instances occurred where procedures were not followed and the failure to follow these procedures resulted in a reactor trip. The following examples were cited:

(1) Administrative Procedure (AP) 10.03, Work Package Planning, step 8.1.5 states

! where a.ccessible, perform a walkdown of the work site to obtain an understanding -

of the specific needs and location of the work environment. .However, failure to adequately walkdown the work associated with WR 96-02875-00, to perform l calibration of 71-59N-1UPRN05, was not performed with adequate detail to identify l the high risk involved with performing the maintenance with the plant at power.

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l l (2) instrument Maintenance Procedure IMP-G20, Generic Troubleshooting and Maintenance Procedure, states, that prior to disconnecting wires, ensure any adverse affects on plant equipment operation or operational status have been discussed with applicable Control Room Operator (s) and Shift Manager. However, during the calibration of 71-59N-1UPRN05, when the technician determined that the work had the potential to adversely affect the operation of the plant, he failed to notify control room operators or the shift manager.

This is a Severity Level IV Violation (Supplement 1).

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION t

The Authority agrees with this violation.

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i Att:chment I ts JAFP-96-0474

,' Riply to N tica cf Violiti n 96-06

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REASONS FOR.THE VIOLATION l

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, The cause for this violation was personnel error. The performance factors leading to these j- errors were:

j. e Inadequate work organization and planning.

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The individual in the Central Planning Department assigned responsibility for preparing the work package did not perform an adequate evaluation and walkdown l of the work activity pior to releasing the work to the field. This resulted in: (1) the l 4 failure of the work packsge to identify the proximity of sensitive energized d

equipment; and (2) the failure of the work package to identify work steps with high risks and potential impact on plant operation;

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e ineffective worker practices.

i The Instrument and Control (l&C) lead technician assigned responsibility for work

associated with calibration of the relay, upon commencing the work, was i confronted with an unexpected electrical termination configuration. He also i recognized and communicated to another technician that the work package did not

contain reference to the potential high risk associated with the work evolution.

i However, upon identifying these conditions: (1) the lead technician failed to stop

! work, question the adequacy of the work plan and report the deficient work i package condition to supervision; and (2) both technicians failed to properly protect adjacent energized equipment from accidental shorting and grounding prior to commencing the work activity. Had the adequacy of the work plan been-challenged, the work would have been either rescheduled during a plant outage to i reduce plant impact or the work package would have been revised to specify

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precautions to be taken when working in close proximity to energized equipment.

! -I i CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN  !

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o The procedures which govern the work control, work package planning and j

the rolling work schedule have been revised to: (1) strengthen the process 1 for identifying plant work with the potential to have an impact on plant operations; and (2) exclude risk significant work from the minor maintewnce process.

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i e Instrument Maintenance Procedure IMP-G20 was revised to add steps to require preventive measures be taken to protect against accidental shorting or grounding of lifted leads and jumpers when performing maintenance or testing activities.

e Training on the procedure changes was conducted with the plant staff.

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Attachm:nt I ta JAFP-96-0474

,[ RIply to Natiso cf Viol tiin 96-06 l i

, CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont) j i e The persons responsible for the development of the work package and the  ;

calibration of the relay have been counseled with respect to their performance,

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, management expectations regarding the need for pre-job walkdowns of work i

! packages, the need to maintain a questioning attitude, precautions to be taken ,

when working on or near energized circuits, and the importance of stopping work 1 and communicating with supervision when confronted with unexpected work l

, conditions.

i e Following this event, a training session was conducted for the Instrument and i Controls Department to review lessons learned from this incident.

i e Following this event, special " stand-down" meetings were held with plant staff to l

i discuss the circumstances associated with the event. Additionally, a training

package was prepared and presented to department personnel. The package i outlined the basic causes and operational significance of the event. The purpose of a this package was to reinforce management's expectations regarding the need to j

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identify and appropriately control risk. I i

!v RESULTS ACHIEVED 4

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The Power Authority believes the corrective actions taken were effective in preventing ;

recurrence. A heightened awareness of the issues associated with this violation has been achieved. The Authority will continue to reinforce the importance of pre-job preparation activities and emphasize the necessity to identify, communicate and appropriately control high risk evolutions.

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CORRECTIVE ACTIONS TO BE TAKEN  !

A training module is under development to improve worker awareness and enhance work practices when working on or near energized circuits. The module subject matter will include increasing worker awareness of potential risk (s) and plant impact of tasks being performed, protective measures for tools to avoid electrical shorting, protecting lifted leads /jurwers from shorting / grounding, and electrical protection of adjacent equipment.

The module will be required training for l&C, Electrical Maintenance and Operations Department personnel. Scheduled completion date for this training is March 31,1997.

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Attichm:nt I t2 JAFP-96-0474

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R: ply ts N:tica cf Viol:ti:n 96-06

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l DATE WHEN FULL COMPLIANCE WAS ACHIEVED

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Management expectations for a successful work control program have been and continue i to be reinforced. Full compliance was achieved on September 20,1996 following

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completion of departmental " stand-down" meetings.

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. Attichm:nt il ts JAFP 96-0474

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Summary of Commitments l'

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Number Commitment Due Date JAFP-96-0474-01 A training module is under development to 03/31/97 l improve worker awareness and enhance work

! practices when working on or near energized l circuits. The module subject matter will include: increasing worker awareness of L potential risk (s) and plant impact of tasks being j performed; protective measures for tools to l avoid electrical shorting; protecting lifted leads / jumpers from shorting / grounding; and electrical protection of adjacent equipment.

This module will be required training for I&C, Electrical Maintenance and Operations Department personnel.

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