IR 05000333/1999007

Insp Rept 50-333/99-07 on 990718-0828.No Violations Noted. Major Areas Inspected:Plant Activities

ML20212F861
Person / Time
Site:	FitzPatrick
Issue date:	09/22/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212F841	List: IR 05000333/1999007 ML20212F834
References
50-333-99-07, NUDOCS 9909280400
Download: ML20212F861 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-333

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License No.: DPR-59

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Report No.: 99-07 Licensee: New York Power Authority Facility: James A. FitzPatrick Nuclear Power Plant  !

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Location: Post Office Box 41 Scriba, New York 13093 Dates: July 18 to August 28,1999 l

Inspectors: R. A. Rasmussen, Senior Resident inspector R. A. Skokowski, Resident inspector T. J. Kenny, Sr. Operations Engineer (August 2 - 6,1999)

T. A. Moslak, Radiation Specialist (August 23-27,1999)

Approved by: J. F. Rogge, Chief Projects Branch 2 1 Division of Reactor Projects l

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l 9909290400 990922 PDR ADOCK 05000333 G PDR

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SUMMARY OF FINDINGS James A. FitzPatrick Nuclear Power Plant NRC Inspection Report 50-333/99-07

The report covered 'a six week period of resident inspection, and the results of announced inspections by a regional radiation safety inspector and a regional engineering inspecto Inspection findings were assessed according to potential risk significance, and were assigned colors of GREEN, WHITE, YELLOW, or RED. GREEN findings are indicative of issues that,

while not necessarily desirable, represent little risk to safety. WHITE findings would indicate l issues with some increased risk to safety, and which may require additional NRC inspection YELLOW findings would be indicative of more serious issues with higher potential risk to safe performance and would require the NRC to take additional actions. RED findings represent an unacceptable loss of margin to safety and would result in the NRC taking significant actions that could include ordering the plant shut down. The findings, considered in total with other inspection findings and performance indicators, will be used to determine overall plant performanc Mitigating Systems I

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Green. The inspectors identified that instrument uncertainties were not adequately incorporated into the residual heat removal system minium flow valve setpoint analysi Subsequently, the licencee identified additional discrepancies, which, in total, caused the I setpoint to be inadequate to ensure pump protection during low flow conditions. This i issue was considered green in the significance determination process because the loss of RHR pump low flow protection was only credible during certain loss-of-coolant-accident conditions, which have a low probability of occurring. Nonetheless, the failure to adequately establish the RHR low flow switch setpoints was a violation of NRC requirements. The inspectors also noted that ineffective communications between the engineering and operations departments resulted in the shift manger using incorrect information as part of the bases for initially justifying system operability. (NCV 50-333/99-07-01) (Section 1R15)

Other Activities

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None. The inspectors reviewed performance indicator (PI) data submitted by NYPA in the area of safety system unavailability.- The inspectors reviewed data for emergency AC power systems, and the residual heat removal system. The data reviewed represented a sampling of records form July 1,1998 through June 30,1999. There were no findings identified and documented during this inspectio i l

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Report Details SUMMARY OF PLANT STATUS The inspection period began as the unit returned to full power following a shutdown to repair a cracked feedwater system drain line. The unit remained at full power for the remainder of the period. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier integrity 1R03 Emeroent Work Insoection Scope The inspectors reviewed the licensee's actions associated with leak repairs to feedwater system piping, repairs to the reactor core isolation system (RCIC) turbine steam )

admission valve, and the evaluation of noisy reactor protection system relay Observations and Findinas l

l There were no findings identified and documented during these inspections.

1R04 Eauioment Alianments Inspection Scope The inspectors performed partial system walkdowns of the reactor core isolation cooling (RCIC) system and the emergency diesel generator syste Observations and Findinas There were no findings identified and documented during these inspections.

1R05 Fire Protection Inspection Scope The inspectors toured the reactor building, the emergency diesel generator rooms, the emergency service water pump rooms, and fire pump room Observations and Findinas There were no findings identified and documented during these inspection r:

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1R09 Inservice Testina Insoection Scope The inspectors observed inservice testing of the reactor core isolation cooling pump, and l

core spray pumps.

1 Observations and Findinas

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There were no findings identified and documented during these inspection ;

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- 1R12 Maintenance Rule (MRI implementation l

l .1 'lmolementation Inspection Scope The inspectors assessed the licensee's implementation of the Maintenance Rule, Title 10 of the Code of Federal Regulations Part 50.65 (10 CFR 50.65), for deficiencies with the steam condensing mode of the residual heat removal system, failures of a reactor core isolation cooling containment isolation valve, and for a failure of a fire system pump. ) Observations and Findinas l

There were no findings identified and documented during these inspections.

i .2 Periodic Maintenance Rule Evaluation I

' Inspection Scope The inspector reviewed MR " Periodic Assessment for FitzPatrick NNP 10/95 - 10/97 (10CFR50.65(a)(3))", and completed licensee documents that recommended actions for improved program effectiveness. The inspector also reviewed licensee actions for the operation and maintenance of DC electrical distribution systems, AC electrical i

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distribution systems and diesel generator systems to verify: Balancing reliabil.ity and unavailability of MR systems, structures, and components (SSCs)in accordance with the MR; system goals and monitoring, feedback of self and industry operating experience and preventive maintenance activities for 10 CFR 50.65(a)(1) in accordance with the MR; and licensee evaluation of functional failures, maintenance preventable functional failures and repeat maintenance preventable functional failures for adjustments to systems acceptable under 10 CFR 50.65(a)(2) of the MR. The inspector also conducted interviews with licensee staff and management. The above activities were to verify if the scope of the MR was being conducted in a manner to ensure reliable, safe operation of l the plant and plant equipment.

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3 Observations and Findinas Periodic Evaluation There were no findings identified and documented during these inspection Balancina Reliability and Unavailability There were no findings identified and documented during these inspection CFR 50 65(a)(1) Activities l There were no findings identified and documented during these inspection {

10 CFR 50.65(a)(2) Activities There were no findings identified and documented during these inspection R13 Maintenance Work Prioritization Inspection Scope The inspectors reviewed maintenance work prioritization associated with NYPA's preparations for a forced shutdown. The forced shutdown, on July 18,1999, was required to repair a cracked feed system drain line. The inspectors also reviewed issues associated with work on the 115 KV system electrical transformer and for activities with an emergency diesel generator inoperabl Observations and Findinas There were no findings identified and documented during these inspection R15 Operability Evaluations

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.1 RHR Minimum Flow Setpoints Inspection Scope The inspectors assessed the licensee's operability determinations following the identification of residual heat removal (RHR) system minium flow value actuation setpoint discrepancie Observations and Findinas The inspectors identified that instrument uncertainties were not adequately incorporated into the residual heat removal system minium flow valve setpoint analysi ;

Subsequently, the licencee identified additional discrepancies, which, in total, caused the l

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setpoint to be inadequate to ensure pump protection during low flow conditions. This issue was considered green in the significance determination process because the loss of RHR pump low flow protection was only credible during certain loss-of-coolant-accident conditions, which have a low probability of occurring. Nonetheless, the failure to adequately establish the RHR low flow switch setpoints was a violation of NRC requirements. The inspectors also noted that ineffective communications between the engineering and operations departments resulted in the shift manger (SM) using incorrect information as part of the bases for initially justifying system operability.

The RHR low flow switches cause the minimum flow bypass valves to open, which protect the pumps from operating in iow flow conditions. The minimum flow bypass valves are normally open and close when flow is increased above the setpoint. The minimum flow valves must reopen if flow is subsequently reduced below the minimum setpoint.

In 1973, NYPA replaced the RHR low flow switches with switches having a wider range, however, this change was not reflected in the Final Safety Analysis Report (FSAR).

Following the identification of the error within the FSAR, NYPA completed an evaluation of the installed equipment. This evaluation was documented in an April 1999 safety evaluation (SE 99-08). The inspectors reviewed the safety evaluation and identified that instrument inaccuracies were not incorporated in the setpoint. Subsequently, NYPA identified additional discrepancies with the setpoint calculation, and they issued Deviation / Event Report (DER) 99-1297. The impact of these discrepancies was that the minimum flow valves could not ensure pump protection during low flow conditions. The failure to adequately establish the RHR low flow switch setpoints was a violation of 10 CFR Part 50 Appendix B, Criterion 111, " Design Control." This issue was considered green in the significance determination process because the loss of RHR pump low flow protection was only credible during certain loss-of-coolant-accident conditions, which have a low probability of occurring. Therefore, this violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix F of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as DER 99-01297. (NVC 50-333/99-07-01)

During their review of the DER, the inspectors questioned NYPA regarding the impact of the non-conservative minimum flow value setpoint on the operability of the RHR syste Discussions with the SM and other members of the operations department indicated that the RHR minimum flow valves were still capable of performing the intended function without operator actions. However, based on the inspectors' discussion with members of NYPA's engineering department, operator actions would be required to provide low flow protection. Therefore, the inspectors concluded that the communication between the engineering and operations departments was ineffective, which resulted in the SM using incorrect information as part of the bases for initially justifying system operabilit Subsequently, NYPA completed a formal evaluation justifying system operability. The inspectors reviewed this evaluation and found it to be technical sound and completed in accordance with industry guidance. Within the next week, NYPA changed the switch setpoint to ensure proper minimum flow valve operation .

.2- Other Operability Evaluations . Inspection Scoce I

The inspectors reviewed operability determinations associated with the following two other issues identified during the perio ,

) Reduced flow through the reactor water cleanup bottom drai j Identified errors in the high pressure coolant injection system minimum flow valve setpoint calculation I Observations and Findinas There were no findings identified and documented during these inspection R16 OoeratorWork-Arounds

Insoection Scope The inspectors reviewed an operator work-around involving operation with a containment isolation valve blocked open, and operation of the residual heat removal system steam condensing mode with a leaking level transmitter, and motor operated valves which were de-energized for isolation, Observations and Findinas There were no findings identified and documented during these inspection l 1R19 Post Maintenance Testina l Insoection Scope The inspectors reviewed post maintenance testing performed following maintenance to l the reactor core isolation cooling (RCIC) turbine steam admission valve, and following l maintenance activities on the 115 KV transformer Observations and Findinas There were no findings identified and documented during these inspection R22 Surveillance Testina Insoection Scope The inspectors reviewed surveillance testing of the A and C emergency diesel generator air start systems and fuel oil transfer systems, surveillance testing to demonstrate

operability of the B and D emergency diesel generators, and the residual heat removal system loop A monthly operability tes Observations and Findinas There were no findings identified and documented during these inspections.

1R23 Temporary Modifications  ! Inspection Scope l

The inspectors reviewed temporary modifications associated with a leak repair to a feed system piping crack, and an alteration to the emergency diesel generator fire door, Observations and Findinas There were no findings identified and documented during these inspections. RADIATION SAFETY Ocmerstone: Occupational Radiation Safety [OS]

OS3 Egdiation Monitorino instrumentation Inspection Scope Calibration and maintenance records were reviewed for various portable survey instruments, contamination monitors, area radiation monitors, airbome radioactivity monitors / samplers, and electronic dosimetry. Technicians were observed calibrating two area radiation monitors and an airborne radioactivity monitor. Technicians were observed performing response tests and pre-use checks of various survey instruments, portal monitors, and laboratory equipment. The operability of various instrumentation l was independently verifie Relevant DERs and the licensee's recent self-assessment (JRES-99-087) of the radiological monitoring program were reviewe Observations and Findinas There were no findings identified and documented during these inspection . .

7 OTHER ACTIVITIES [OA]

40A2 PIVerification

.1 Safety System Availability Insoection Scope The inspectors reviewed performance indicator (PI) data submitted by NYPA in the area of safety system unavailability. The inspectors reviewed data for emergency AC power systems, and the residual heat removal system. The data reviewed represented a sampling of records form July 1,1998 through June 30,199 Observations and Findinas Th'.sre were no findings identified and documented during this inspectio A4 Other (Closed) LER 50-333/99-03-01: Safety Relief Valve Setpoint Drift. This LER was submitted to change a commitment due date for data evaluation. No further issues were identified and this LER is close (Closed) URI 50-333/98-08-01: ECCS Availability During Reactor Draindown. This item was unresolved pending NRC review of NYPA's compliance with technical specifications (TS) during the reactor cavity draining evolution. NRC review concluded that NYPA was in compliance with TS. However, the conditions established did not meet the current standards as described in the improved standard technical specifications. NYPA has ;

submitted a proposed amendment for conversion to improved technical specifications, i which should resolve this concem for the long term. This item is close i 40A5 Meetinos j l

Exit Meetina Summarv The inspectors presented the inspection results to Mr. M. Colomb and other members of licensee management on September 8,1999. The licensee acknowledged the findings presented. No proprietary information was identifie .

ATTACHMENT 1 l PARTIAL LIST OF PERSONS CONTACTED Licensee M. Anderson Supervisor, Radiological Support / instrumentation G. Bregg Instrumentation & Control Manager G. Brownell Licensing Engineer P. Brozenich Operations Manager B. Burnham MR Coordinator P. Chaldn Public Affairs M. Colomb Site Executive Officer R. Converse General Manager Maintenance (Acting)

F. Edler Assistant Maintenance Manager ]

J. Fitzgerald Construction Services Manager T. Herrman Senior Mechanical Design Engineer J. Hibbert System Engineer K. Hobbs Health Physics - General Supervisor B. Horning Shift Manager D. Kleper General Manager - Maintenance L. Leiter System Engineer D. Lindsey Plant Manager R. Locy Training Manager J.Lona Component Engineer A. McKeen Radiological & Environmental Department Manager E. Mulcahey General Supervisor, Radiological Engineering W. O'Malley General Manager Operations D. Ruddy Director, Design Engineering J. Stead System Engineer G. Tasick Licensing Manager i D. Wallace Director, Design Engineenng j A. Zaremba General Manager Support Services

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Attachment 1 (cont'd) 2 ITEMS OPENED, CLOSED, AND DISCUSSED Opened None j Opened and Closed I

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NVC 50-333/99-07-01: Failure to Adequately Establish the RHR Low Flow Switch Setpoints Closed l LER 50-333/99-03-01: Safety Relief Valve Setpuint Drift URI 50-333/98-08-01: ECCS Availability During Reactor Draindown 4 I

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Attachment 1 (cont'd) 3 LIST OF ACRONYMS USED DER Deficiency and Event Report i ECCS Emergency Core Cooling System EDG Emergency Diesel Generator .

LER Licensee Event Report  !

MR Maintenanco Rule NCV Non-Cited Violation NNP Nuclear Power Plant NRC Nuclear Regulatory Commission NYPA New York Power Authority Pl Performance Indicator RCIC Reactor Core isolation Cooling RHR Residual Heat Removal RO Reactor Operator SE Ssfety Evaluation SM Shift Manager SSC Systems, Structures and Components !

UFSAR Updated Final Safety Analysis Report l URI Unresolved item

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