IR 05000333/1997001
| ML20141J801 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/20/1997 |
| 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 | |
| 50-333-97-01, 50-333-97-1, NUDOCS 9705280228 | |
| Download: ML20141J801 (3) | |
Text
May 20, 1997
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50 333 Reply to Notice of Violation NRC inspection Report 50 333/97-01
Dear Sir:
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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 March 24,1997. Your letter refers to the results of an inspection completed at the James A. FitzPatrick Nuclear Power Plant on February 22,1997.
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Attachment I provides the description of the violat;on, reasons for the violation, corrective steps that have been taken and results achieved, corrective steps that will be taken to avoid further violations, and the date when full compliance was achieved.
There are no commitments contained in this report.
Questions concerning this report may be addressed to Mr. Art Zaremba at (315) 349-6365.
Very Truly yours,
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MICHAEL J. COLOMB MJC:GJB:las Attachments as stated STATE OF NEW YORK
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COUNTY OF OSWEGO Subscribed and sworn to before me cc:
next page this J V day of A m i 1997.
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NDTARy/ PUBLIC NANCY B.CZEROW Notary Public. State of NewYork Quaufled in Oswego County #4884611 i
Commission Expires / W 'l1
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Regional Administrator t
U.S. Nuclear Regulatory Commission
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475 Allendale Road King of Prussia, PA 19406 j
i Office of the Resident inspector j
U.S. Nuclear Regulatory Commission
P.O. Box 136
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Lycoming, NY 13093 Ms. K. Cotton, Acting Project Manager
Project Directorate 11 Division of Reactor Projects-l/II i
U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 Attachment:
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Reply to Notice of Violation
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Att=hm:nt 1 l
Realv to Notice of Violation 9741
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VIOLATION f
10 CFR 50.59, " Changes, tests, and experiments," permits licensees to make changes to the facility, as described in the Safety Analysis Report, without prior
- Commission approval, provided that the proposed changes do not involve a change in the technical specifications or involve an unreviewed safety question. Records of l
these enanges must included a writtea safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety
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question.
The torus-to-drywell vacuum breaker isolation valves 27AOV-101 A and 27AOV-101B, end containment vent and purge isolation valves 27AOV 111 through 27AOV-118 are described in Sections 5.2.3.6 and 5.2.3.7 of the Fitz' Patrick Final Safety Analysis Report.
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Contrary to the above, since before January 31,1997, hose clamps or tie-wraps
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were installed to restrain the air operator disengaging levers of the vacuum breaker
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and containment purge isolation valves, and no safety evaluation was performed and documented to provide the bases for a determination that the change did not involve an unreviewed safety question.
This is a Severity Level IV violation (Supplement 1).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Authority agrees that the evaluation did not document the bases for no unreviewed
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safety question, however, the installation was in accordance with a procedure revision that was reviewed and approved by the Plant Operating Review Committee on i
December 11,1980.
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REASONS FOR THE VIOLATIO.N In response to a 1980 NRC Circular notifying licensees of potential failure of valve actuators due to disengagement of operator keys, NYPA revised Maintenance Procedure
MP 7.1, " Containment Vent and Purge Valve Maintenance", to include special instructions for the installation of tie wraps / hose clamps to prevent actuator failure. Included was concurrence from the equipment vendor for the installation. At the time of the procedure revision, the plant's safety review process comprised of submitting the procedure to the Plant Operating Review Committee (PORC) for their review and approval. Procedure MP-7.1 was approved by the PORC on December 11,1980. Work records indicate the tie
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wraps / hose clamps were subsequently installed on the valves.
The cause was the lack of adequate administrative guidance for performing 10 CFR 50.59 l
reviews in that the PORC and engineering reviews did not document the bases for determining that the tie wrap / hose clamps did not it'volve an unreviewed safety question.
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Page 1 of 2
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Attachment 1
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Raniv to Notice of Violation 97-01 CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN i
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System reviews concluded that the extent of the use of tie wraps / hose clamps on e
valve actuators was isolated to eight vacuum breaker and containment purge i
isolation valves and one Off Gas System valve.
The installadon of (ne hose clamps to the valve air actuators was incorporated into e
FitzPatrick's Temporary Modification Control Program. Implementation requirements included a technical assessment and the completion of a nuclear safety and environmental impact screen to document the bases for the activities not involving an unreviewed safety question as outlined in 10 CFR 50.59.
A plant modification has been developed to document permanent installation of j
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hose clamps on the subject valves.
Current procedures require safety and effectiveness reviews to be completed which e
document the bases and determine the need for a nuclear safety evaluation.
RESULTS ACHIEVED l
The Authority is confident that the procedure review, modification and temporary
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modification processes and programs, presently in place at FitzPatrick, are providing its
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staff an appropriate level of guidance necessary to support plant changes.
CORRECTIVI ACTIONS TO BE TAKEN An abstract of this violation will be included in the weekly Department Tailgate e
meetings. The abstract will: (1) provide personnel a summary of the event; review management expectations involving plant changes; and emphasize the importance of when implementation issues arise where uncertainty exists concerning activities which may or may not be considered a change / temporary change under the rules and guidance of 10 CFR 50.59, personnel shall assure that the activities receive appropriate nuclear safety screens.
(Scheduled Completion Date - May 09,1997)
DATE WHf3 FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on January 31,1997, following completion of the Nuclear Safety and Environmental !mpact Screen that documented the bases for the tie wrap / hose installations on the valve air actuator assemblies not affecting the design, operation, l
function, or method of performing the function of the valves as described in the Final l
Safety Analysis Report (FSAR).
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