IR 05000333/1997010
| ML20247B947 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/05/1998 |
| From: | David Lew NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| 50-333-97-10, NUDOCS 9805110160 | |
| Download: ML20247B947 (3) | |
Text
May 5, 1998
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Reply to Notice of Violation NRC Intearated Inspection Report 50-333/97-10
Dear Sir:
In accordance with the provisions of 10 CFR 2.201, Notice of Violation, the New York Power Authority stibmits a response to the notice transmitted by your letter dated March 12,1998. Your letter refers to the results of the integrated inspection conducted from December 22,1997 through February 22,1998 at the James A. FitzPatrick Nuclear Power Plant.
Attachment I, Reply to Notice of Violation, provides the description of the violation, reasons for the violation, corrective actions that have been taken and the results achieved, corrective actions to be taken to avoid further violations, and the dates of full compliance.
There are no commitments contained in this submittal.
if you have any questions, please contact Mr. Arthur Zaremba, Licensing Manager, at (315) 349-6365.
Very truly yours,
<~x
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I, MICHAEL COLOMB Site Executive Officer NANCY B.CZEROW Notary PubHc, State of NewYork MJC: RAP:las STATE OF NEW YORK 0"ll'I'd in 0*wego county e4esset t C mml**l n EXP res p.a 6 - W i
COUNTY OF OSWEGO Attachments as stated Subscribed and sworn to before me This /J_ day of % 1998 CC: Next page d?W/ I 0 0 A R A. A 1A 3 (j1)
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Regional Administrator i
U.S. Nuclear Regulatory Commission
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475 Allendale Road I.
King of Prussia, PA 19406 Office of the Resident inspector U.S. Nuclear Regulatory Commission
. P.O. Box 136 Lycoming, NY 13093 Joseph Williams, Project Manager Project Directorate 1-1 Division of Reactor Projects - 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14 82 Washington, DC 20555 Attachments:
l Reply to Notice of Violation
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Attichm:nt i
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Riply to N:tico cf Vislati:n NRC Integrated inspection Report 50 333/97-10 VIOLATION l
During an NRC inspection conducted from December 22,1997 to February 22,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:
Technical Specification (TS) Appendix B, Section 3.8, Standby Gas Treatment System (SBGTS) discusses the applicability of the SBGTS instrumentation and states the objective is "to assure that the SBGTS is actuated with the proper signal. " The limiting conditions for operation are stated in TS Table 3.10-1, Radiation Monitoring Systems That Initiate and/or Isolate Systems. Table 3.10-1 requires at least one channelof the Reactor Building area exhaust monitors to be operable with the applicable notes stating "Whenever the systems are required to be operable, there shallbe one operable or trippedinstrument channelper system.
- From and after the time it is found that this cannot be met, the indicated action shall be taken. " The indicated action is to isolate secondary containment and start the SBGTS.
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Contrary to the above, on January 28,1998, from approximately 10:00 a.m. until 4:00 p.m., the licensee failed to isolate secondary containment and start the SBGTS when the only operable channel of the Reactor Building radiation monitor system below the refueling floor was made inoperable by the plan: operators by taking the
"B" instrument to the down scale condition while the "A" train of the SBGTS was removed from service.
This is a Severity levelIV violation (Supplement I).
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ADMISSION OR DENIAL OF THE VIOLATION.
The Authority agrees with the violation.
REASONS FOR VIOLATION The cause for the violation was ineffective work practices. The "A" Standby Gas Treatment (SGT) was out of service for planned maintenance and the "A" Reactor Building l
below refuel floor ventilation exhaust radiation monitor (17RM-452A) was in service. The
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"B" Reactor Building below refuel floor ventilation exhaust radiation monitor (17RM-4528)
was removed from service for maintenance to troubleshoot and correct a spurious isolation
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signal. The Operations shift failed to recognize the effects of removing this radiation monitor from service on the operable "B" Standby Gas Treatment System. The Operators performed an inadequate review of the Technical Specifications (TS) when researching the l
LCO for 17RM-4528 removal from service.
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Att::hm:nt i R: ply to N:tico cf Violati:n
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NRC Integrated Inspection Report 50-333/97-10 Contributing human performance factors which influenced the Operator actions were:
Desire to complete the task due to the potential for the radiation monitor to cause
another spurious isolation which would result in another automatic Group ll isolation and SGT initiation. The decision was made to perform required maintenance on a priority basis. This contributed to the decision to remove 17RM-452B from service.
Written procedures and documents. The procedure which removed the radiation monitor
from service, OP-31, " Process Radiation Monitoring System", and the applicable TS referenced by the procedure, had no reference to the SGT system when removing a monitor from service. Specifically, Radiological Effluent Technical Specification (RETS)
Table 3.10-1 allows the removal of one Reactor Building ventilation radiation monitor with no reference to the impact on the SGT system.
As part of the Root Cause Analysis, a plant review was done to look for similar
occurrences. This review identified an event in January 1995 associated with the radiation monitor logic circuit. Although the event was not similar, the impact of the monitor on the SGT system was questioned at that time. The plant review, dccumented in a memorandum, recommended a corrective action for applicable departments to review procedures that remove Reactor Building radiation monitors from service, and provided a caution against removing a radiation monitor with the opposite
side of SGT out-of-service. This recommendation was not formally tracked or j
documented in the plant corrective action program.
l CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN Initial actions included isolation of Reactor Building and start of "B" SGT.
- Operations Department revised ODSO-34, "TS LCO and Maintenance Rule Unavailability
Tracking", to ensure that independent reviews of TS's are performed prior to removing equipment from service. The LCO tracking sheet was also revised to include consideration of the impact on existing LCOs when removing equipment from service.
The Operations Manager has briefed the Operators on the details of this event. The
lessons learned from the Root Cause Analysis were reviewed by Operations management with the operating crews. These lessons learned included the need to perform independent peer reviews for determining the impact on all effected systems prior to removing equipment from service and emphasized the use of all available resources (i.e. Work Planning staff and/or Licensing staff) prior to removing the equipment from service.
Plant management initiated a licensing and design basis review of the Refuel Floor and
Reactor Building ventilation radiation monitor systems to determine the need for a TS amer.dment and/or design change. Based on the results of this review to date, a need for a TS amendment has been determined to be appropriate.
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Atttchm:nt I I
Riply to Nctics cf Vitittirn o
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NRC Integrated Inspection Report 50-333/97 10
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Plant personnel were briefed on the details of this event and the lessons learned,
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stressing the importance of tracking recommendations when identified by utilizing the plant corrective action program.
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RESULTS ACHIEVED l
Actions taken have: 1) increased operator sensitivity to the issues associated with the cause of this violation; 2) increased emphasis to operators to perform independent reviews
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with removing equipment from service for maintenance; and 3) increased plant staff
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awareness of the need to formally track potential problems to ensure' appropriate corrective actions are completed.
CORHECTIVE ACTIONS TO BE TAKEN Actions will be taken to ensure that applicable Licensed Operator training material
i includes a caution on removing a Reactor Building radiation monitor from service with the opposite side of SGT removed from service. (Scheduled Completion Date: 7/1/98)
Review and revise all applicable plant procedures to caution against removing a Reactor
Building ventilation radiation monitor from service when the opposite SGT system is already removed from service. (Scheduled Completion Date: 6/1/98)
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- Submit a Technical Specification change to RETS Table 3.10-1 to address effects on
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Reactor Building isolations and Standby Gas Treatment actuation with the associated j
radiation monitor out of service. (Scheduled Completion Date: 6/30/98)
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Evaluate the need to perform a design change to the radiation monitor logic circuitry.
(Scheduled Completion Date: 6/30/98)
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~ DATE WHEN FULL COMPLIANCE WAS ACHIEVED l
Full compliance was achieved on January 28,1998 when the Shift Manager isolated the l
Reactor Building and inhiated the "B" SGT system.
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