JAFP-86-1051, Responds to NRC Re Violations Noted in Insp Rept 50-333/86-13 on 860809-0929.Corrective Actions:Survey Smears Taken During Receipt of New Fuel Shipments Counted & Evaluated for Alpha Contamination

Responds to NRC Re Violations Noted in Insp Rept 50-333/86-13 on 860809-0929.Corrective Actions:Survey Smears Taken During Receipt of New Fuel Shipments Counted & Evaluated for Alpha Contamination

ML20211Q208
Person / Time
Site:	FitzPatrick
Issue date:	12/10/1986
From:	Radford Converse POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
JAFP-86-1051, NUDOCS 8612190219
Download: ML20211Q208 (4)

Text

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James A. Fit; Patrick Nuclear Power Plant PO. Ebu 41 Lycomuig. New York 13093 315 342.3840 Radford J. Converse

1. > NewYorkPbwer 4# Authority December 10, 1986 JAFP 86-1051 United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Attention: Robert M. Gallo, Chief Projects Branch No. 2 Division of Reactor Projects Subj ect: JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET No. 50-333 INSPECTION NO. 86-13 Gentlemen:

In accordance with the provisions of 10 CFR 2.201, we are submitting our response to Appendix A Notice of Violation transmitted by your letter dated November 10, 1986, as received by the undersigned on November 17, 1986. This refers to the inspection conducted by Mr. A. Luptak of your office on August 9 thru September 29, 1986, at the James A. FitzPatrick Nuclear Power Plant.

NOTICE OF VIOLATION As a result of the inspection conducted between August 9 and September 29, 1986, the following violations were identified:

A. Technical Specification 6.8(A) requires that written procedures and administrative policies be implemented that meet or exceed the requirements and recommendations of Appendix A of Regulatory Guide 1.33, November 1972.

1. Radiation Protection Technical and Analytical Procedure (RTP) 11, New Fuel Radiological Survey Procedure, Revision 1, dated June 29, 1984, sections 4.3.1 and 4.3.2, requires counting and evaluation of smear surveys for alpha contamination prior to unloading new fuel shipping containers from the truck and prior to removal of the casks from the shipping containers.

Contrary to the above, on September 3, 5, and 8, 1986, smear surveys taken during the receipt of new fuel shipments were not counted or evaluated for alpha contamination prior to unloading the shipping containers or during the removal of the casks.

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m To: United States Nuclear Regulatory Commission Dec. 10, 1986 Attention: Robert M. Gallo, Chief JAFP 86-1051

Subject:

JAMES A~. FITZPATRICK NUCLEAR POWER PLANT Page DOCKET NO. 50-333 INSPECTION NO. 86-13

2. Work Activity Control Procedure 10.1.1, Procedure for Control of Maintenance, Revision 10, dated January 29, 1986, requires that maintenance which can affect the performance of safety related equipment be performed in accordance with written procedures or documented instructions.

Contrary to the above, on September 9, 1986, the conduit connections of the High Pressure Coolant Injection Low Steam Pressure Transmitter PT-68D were not sealed as required by the technical manual which was the specified document for the transmitter replacement.

This is a Severity Level V Violation.

B. 10 CFR 50.72 (b)(2)(ii) requires that the licensee notify the NRC Operations Center, via the Emergency Notification System, as soon as practical and in all cases within four hours of any event that results in automatic actuation of any Engineered Safety Feature.

Contrary to the above, the licensee did not notify the NRC Operations Center within four hours of an automatic isolation of the Reactor Core Isolation Cooling System which occurred at 9:00 p.m. on September 4, 1986. The notification was made at 8:33 a.m. on September 5, 1986.

This is a Severity Level V Violation.

RESPONSE TO NOTICE OF VIOLATION A. The Power Authority agrees with this finding.

The fundamental cause of this violation was an inattention to detail; in particular, the failure to question inconsistencies between procedures and general practice. In example A.1, radiological practices for the receipt of radioactive material other than new fuel, have allowed smear surveys for alpha contamination to be counted subsequent to beta / gamma surveys when no problems are expected. In example A.2, the technician reassembled the conduit connections in the as-found condition, i.e. not sealed.

The immediate corrective action for example A.1, the improper survey, was to count and evaluate the smears for alpha contamination. As expected, no contamination was found. The immediate corrective action for example A.2, the conduit connection, was to seal it in accordance with the technical manual.

To: United States Nuclear Regulatory Commission Dec. 10, 1986 Attention: Robert M. Gallo, Chief JAFP 86-1051

Subject:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT Page DOCKET NO. 50-333 INSPECTION NO. 86-13 Permanent corrective action was or will be as follows:

1. Senior plant management has emphasized, through a series of recently completed training classes, the importance of attention to procedural detail to the members of all operating departments.

2. For example A.1, procedure RTP-11 is being reviewed to correct inconsistencies with other radiological

-procedures. This will be completed by March 1, 1987.

3. For example A.2, all of the other similar transmitters were inspected during a Fall outage for proper sealant of conduit connections.

B. The Power Authority agrees with this finding.

The fundamental cause of this violation was the failure of shift personnel to classify the Reactor Core Isolation Cooling

-(RCIC) System isolation as an automatic actuation of an Engineered Safety Feature (ESF). 10 CFR 50.72 does not clearly define what constitutes an ESF actuation. At FitzPatrick, the overall RCIC system is not an Engineered Safety System which resulted in the initial misclassification.

The containment isolation segment of RCIC is such a system, however. Supervisory review of the occurrence, the following morning, identified the misinterpretation and ordered the ENS notification.

The immediate corrective action for this violation was to counsel the appropriate shift personnel on this interpretation of an ESF actuation.

The permanent corrective action was as follows:

A new administrative procedure has been implemented which more l clearly defines the requirements of 10 CFR 50.72 and ESF l

actuations, and provides for a clear step-by-step check-off.

In response to your concern with the timeliness of corrective action implementation, the response to the inspection 85-31 violation specified that procedural changes would be completed by July 1986. This response, submitted in March 1986, discussed how the existing site occurrence report system was l

intertwined within three plant procedures, including WACP 10.1.1, " Procedure for the Controls of Maintenance". The

, response also discussed that the July 1986 date was required due to a major revision in WACP 10.1.1 which was in progress.

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. w To: United States Nuclear Regulatory Commission Dec. 10, 1986 Attention: Robert M. Gallo, Chief JAFP 86-1051

Subject:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT Page DOCKET NO. 50-333 INSPECTION NO. 86-13 At the time of the response, the revision to WACP 10.1.1 was anticipated to be completed in June. However, due to the complexity of the changes, the revision to WACP 10.1.1 was not completed until November, thus delaying completion of the 85-31 violation commitment. During the summer, members of your staff were informed of the delays and status of revising WACP 10.1.1. Although specific mention of the subsequent delay in the July 1986 commitment date may not have been made, the site staff assumed that this was adequate notification of the delay. A new action commitment tracking system was initiated during the Fall which includes special annotations for NRC commitments. This should prevent reoccurrence of not clearly notifying the NRC of delays in subsequent commitments.

Very truly urs, AMW RADFORD J. CONVERSE RJC:WF:fah CC: RMS for Headquarters Distribution: WPO PORC Members NRC Resident Inspector NRCI 86-13 File Document Control Center CERTIFIED MAIL - RETURN RECEIPT REQUESTED l

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