JAFP-89-0284, Responds to NRC Re Violations Noted in Insp Repts 50-333/88-17 & 50-333/88-23.Corrective Actions:Combination of Unit Cooler Disassembly,Cleaning & Flusing Performed to Restore Design Flow Rates & Improve Heat Transfer
| ML20245D240 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/12/1989 |
| From: | Fernandez W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| JAFP-89-0284, JAFP-89-284, NUDOCS 8904280179 | |
| Download: ML20245D240 (15) | |
Text
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James A.FitzPatrick Nuclear Power Plant P.O. Box 41 bycomiag, New York 13093 315 342-3840 i
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April 12, 1989 JAFP-89-0284 U.S. Nuclear Regulatory Commission Mail Station F1-137 Washington, D.C.
20555 Attention:
Director, Office of Enforcement
SUBJECT:
RESPONSE TO NOTICE OF VIOLATION - INSPECTIONS 88-17 AND 88-23: NYPA RESPONSE (DOCKET 50-333)
Reference:
a)
USNRC Letter dated March 13, 1989
Enclosures:
1)
Response to Violations I.A, I.B, and I.C -
Inoperable Room Coolers (10 pages) 2)
Response to Violations II.A and II.B - High Service Water Temperatures (3 pages)
Gentlemen:
In accordance with 10CFR2.201, this letter provides the Authority's response (Enclosures 1 and 2) to the Notice of Violation transmitted by reference (a).
This refers to inspec-i tions conducted by your office during the periods of August 8 -
October 5, 1988 and October 6 - November 25, 1988 at the James A.
FitzPatrick Nuclear Power Plant.
Three violations set forth in reference (a) involve the inoper-ability of ECCS equipment area unit coolers for an undetermined period of time prior to October, 1988 because of reduced or totally impeded service water flow to the area unit coolers due to silting.
This degraded condition of the unit coolers was discovered, analyzed, and reported by the Authority to the NRC as a result of plant equipment inspections conducted in accordance with the JAFNPP ASME,Section XI Inservice Test Program.
Two violations involve plant operations when the safety-related service water (lake water) inlet temperature exceeded 77*F without a written safety evaluation.
During the Summer of 1988 many U.S. nuclear plants experienced high cooling water tempera-tures.
Some facilities were forced to restrict operations as a result of explicit Technical Specification requirements.
The Technical Specifications for FitzPatrick have no operating limits or bases information on this subject.
The Authority recognired that a written safety evaluation was necessary to support con-tinued operation and initiated the required work effort to 8904280179 e9o412 g/
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U.S.' Nuclear Regulatory Commission April 12, 1989 Attention:
Director, Office of Enforcement JAFP 89-0284
SUBJECT:
RESPONSE TO NOTICE OF VIOLATION Page INSPECTIONS 88-17 AND 88-23:
NYPA RESPONSE (DOCKET 50-333) prepare a written evaluation.
This issue was discussed on several occasions with the NRC Resident Inspector during the subj ect time frame and no objections were raised regarding interim plant operation pending completion of the formal, written 10CFR50.59 evaluation.
As a result, the Authority, at the time, considered its actions to be sufficient.
The proposed civil penalty has been transmitted under separate correspondence.
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Very truly yours, 3
ILLIAM FERN N.EZ WF:VMW:1s ENCLOSURES CC:
R. Liseno, JAF J. Brons, WPO R. Beedle, WPO J. Gray, WPO S.
Zulla, WPO NRC Resident Inspector, JAF NRCI File NRC Region I, W. Russell i
NRC Document Control Desk RMS, WPO TS File DCC i
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ENCLOSURE (1) TO JAFP 89-0284 Response to Notice of Violations I.A, I.3, and I.C (Inoperable Room Coolers)
NOTICE OF VIOLATION (I.A)
Technical Specification Limiting Condition for Operation (LCO) 3.11.B requires that crescent area ventilation and cooling
- equipment be operable on a continuous basis whenever certain Emergency Core Cooling System (s) (ECCS) are required to be operable in accordance with Technical Specification LCO 3.5.A, 3.5.B, and.3.5.C.
Further, if more than one unit cooler serving ECCS components in the same compartment are made or found to be inoperable, all ECCS components in that compartment shall be considered to be inoperable, and appropriate action shall be taken in accordance with Technical Specifications 3.5.A, 3.5.C, or 3.5.D to place the reactor in the cold shutdown conoition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, for an indeterminate period of time prior to October 1988, more than one crescent area unit cooler serving the ECCS components were inoperable in each of the two compart-ments because of inadequate heat transfer capability: however, the affected ECCS components were not declared inoperable and action was not taken to shut down the reactor within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
NYPA RESPONSE TO NOTICE OF VIOLATION I.A 1.
The Authority agrees with this violation (I A).
' 2.
Reasons for the Violation a.
The fundamental cause of this violation was inadequate surveillance testing to meet Technical Specification surveillance requirement 4.11.B.
The surveillance i
testing performed prior to October, 1988 to meet l
Technical Specification 4.11.B did not detect degraded thermal performance resulting from the fouling of the service water cide of the area unit coolers.
Refer to Notice of Violation I.B which addresses inadequate surveillance testing.
The surveillance testing per-formed prior to October, 1988 addressed operability of individual unit cooler subcomponents such as motors, fans, temperatur: controllers, and temperature control I
valves.
This testing did not assess air or water temperature changes and flow rates to determine actual unit cooler thermal performance.
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t ENCLOSURE (1)
Page NYPA RESPONSE TO NOTICE OF VIOLATION I.A (Cont'd.)
As a result, actions to be taken in accordance with Technical Specification LCO 3.5.A, 3.5.B, and 3.5.C to declare effected ECCS components inoperable were not taken because the Authority did not conclude, at the time, that the performance of the unit coolers had degraded to the point where operability of ECCS equip-ment could be affected.
b.
The Crescent Area ventilation and cooling equipment became inoperable due to system design deficiencies which contributed to component fouling in conjunction with suspended solids in the service (lake water) which provides cooling to the unit. coolers.
The area unit l
coolers became ineffective in their ability to remove area heat, as designed, due to a restriction in coolant flow (fouling) resulting from silting.
The origin of the silt is the cooling water system which is supplied from Lake Ontario.
Deposition of the silt in the unit coolers and connected service water piping resulted'in a flow restriction and loss of thermal efficiency.
The cause of the silting is a low flow condition inherent in the design of the unit coolers.
By design, full flow through the unit coolers in demanded by the 1
temperature control devices only during postulated emergency conditions when the design heat load is generated from operating ECCS equipment in the Crescent Areas.
l c.
Crescent Area Unit Cooler (66UC-221) was determined to I
have its lower cooling coil isolated due to a temporary system modification performed during 1981 which had not been restored to its proper configuration.
This 1
resulted in an approximate 50% loss in thermal capacity j
for this individual unit ecoler, i
d.
Crescent Area Unit Cooler (66UC-22D) was determined to have the cooling water supply lines improperly connect-ed.
The unit cooler was originally designed to approx-imate a counterblow heat exchanger, however, the supply and return piping had been reversed during the original installation of the equipment (original plant construc-tion).
This piping error resulted in reduced thermal performance for this individual unit cooler.
3.
Corrective Actions Taken and Results a.
A combination of unit cooler disassembly, cleaning, and flushing was performed to restore design flow rates and improve heat transfer.
Upstream service water strain-I crs were disassembled and cleaned.
Accessible tubes on the air side of the unit coolers were brushed and i
ENCLOSURE (1)
Page NYPA RESPONSE TO NOTICE OF VIOLATION I.A (Cont'd.)
vacuumed, followed by the installation of new air filters.
These actions resulted in restoration of the ten unit cooler thermal efficiencies to between 75% and 100% of required design basis values.
Prior to re-turning to normal operations following the Fall, 1988 refueling outage, the ability of the coolers to remove design basis heat load was restored for service (lake water) temperatures less than 66 F.
Operations Surveillance Test ST-19A (Crescent Area Unit Cooler Performance Test) was revised on November 19, 1988 to measure individual unit cooler thermal effi-ciency.
The test method utilizes guidance from INPO Technical Support Good Practice EA88-07 (TS.5-1) i
" Measure Performance and Determine Operability of Uninitrumented Safety-Related Room Coolers" (from GP 523, 9/22/88).
The test measures air and water inlet and outlet temperatures and air flow velocity.
The air flow velocity is converted to volume flow and then to air mass flow.
A heat balance is used to determine water flow rate and heat removal capacity of the cooler.
This testing is being performed biweekly instead of once every three months as required by Technical Specification 4.11.B.
This testing has resulted in the thermal efficiency measurements stated in the previous paragraph and is being used to deter-mine Crescent Area unit cooler operability.
b.
The following corrective actions have been taken to.
resolve the design deficiencies associated with the Crescent Area unit coolers:
1.
A more detailed analysis of Crescent Area normal and emergency heat loads has been performed which l
re-establishes the design basis for required heat I
removal capability.
This analysis was performed by the original nuclear steam system supplier (GE) and original architect-engineer (SWEC) and reduces the required heat removal capacity of the Crescent j
Area unit coolers.
This analysis shows acceptable environmental conditions for individual unit cooler efficiencies of >75% of the original design.
Plant operations with service water temperatures up to 82 F have been evaluated as part of this analysis.
2.
Modifications to the cooling water piping to reduce the accumulation of suspended solids have been initiated.
A conceptual design package has been prepared and detailed engineering is commencing.
The proposed modification is intended to reduce the silting problem.
Larger mesh l\\.
ENCLOSURE (1)
Page -
NYPA RESPONSE TO NOTICE OF VIOLATION I.A (Cont'd.)
service water strainers will also be installed.
Other facets of'this modification include. improved performance testing instrumentation for greater accuracy and to reduce radiation exposure (ALARA) to test personnel.
These modifications are scheduled to be completed by June, 1990.
c.
The ruissing section of flanged piping for unit cooler 66UC-22J, which was removed in 1981, was restored to its required design configuration and returned to service on November 4,1988.
This action has restored the loss of thermal capacity of this unit as confirmed by current surveillance testing in accordance with Technical Specification 4.11.b.
d.
The inlet and outlet cooling water piping for unit cooler'66UC-22D has been properly reconnected per original design requirements.
Unit cooler 66UC-22D was returned to service on January 4, 1989 and its. thermal capacity confirmed by current surveillance testing in accordance with Technical Specification 4.11.b.
4.
Further Corrective Actions to Avoid Further Violations I
a.
Further violations in the area of surveillance testing of Crescent Area ventilation and cooling equipment will be avoided due to the permanent corrective actions completed or in-progress as stated in Section 3 above.
The improved surveillance testing and completion of the proposed modifications will prevent further violations.
The Authority has reviewed other service water-cooled safety-related heat exchangers to determine the neces-
[
sity and feasibility of performing improved thermal
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performance testing.
This evaluation was completed on l
April 3, 1989 and the recommendations of this eval-l uation are under review.
This evaluation, which i
included a partial assessment of the thermal perfor-mance of the heat exchangers, did confirm their current operability based on either direct or observed perform-ance.
Performance testing of these other heat exchangers will be scheduled and implemented on a periodic basis, as appropriate, after review of this evaluation.
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ENCLOSURE (1)
Page NYPA RESPONSE TO NOTICE OF VIOLATION I.A (Cont'd.)
b.
Administrative controls regarding temporary modifica-tions to plant systems and components have been sub-stantially upgraded since 1981 when the temporary change to unit cooler 66UC-22J was made.
Presently, the implementation and restoration of such a change would be administered as a temporary modification or controlled by an approved plant procedure.
These procedural controls and extensive training, which has been completed, will prevent events of.this type.
5.
Date of Full Compliance The Authority achieved full compliance on November 19, 1988 prior to plant start-up after the 1988 fall refueling.
- outage, l
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ENCLOSURE (1)
Page NOTICE OF VIOLATION (I.B)
Technical Specification Surveillance Requirement 4.11.B requires that the Crescent Area unit coolers be checked once every three months to verify their ability to perform their intended func-1 tion.
Contrary to the above, the tests of the Crescent Area unit coolers performed prior to October 1988 were inadequate to verify that the unit coolers would perform their intended safety func-tion.
The tests were inadequate in that they only ensured that the fans were operating and the filters were not clogged, but did not verify that the coolers had adequate cooling water flow to ensure that the capability existed for removing their design heat load from the Crescent Areas during certain design basis acci-dents.
i NYPA RESPONSE TO NOTICE OF VIOLATION I.B 1.
The Authority agrees with this violation.
l 2.
Reasons for the Violation The surveillance testing performed prior to October, 1988 to confirm Crescent Area unit cooler operability in accordance with Technical Specification 4.11.B was the same testing performed during initial plant testing (1974) and was continued during the operational phase.
There was inade-quate review of this surveillance testing method to ensure that thermal performance degradation due to a variety of factors would not occur over the life of the plant.
3.
Corrective Action Taken and Results Achieved Operations Surveillance Test ST-19A (Crescent Area Unit Cooler Performance Test) was revised on November 19, 1988 to require measurement of individual unit cooler thermal efficiency.
The test method utilizes guidance from INPO Technical Support Good Practice EA88-07 (TS.5-1) " Measure Performance and Determine Operability of Uninstrumented Safety-Related Room Coolers" (from GP 523, 9/22/88).
The test measures air and water inlet and outlet temperatures and air flow velocity.
The air flow velocity is converted to volume flow and then to air mass flow.
A heat balance is used to determine water flow rate and heat removal capacity of the cooler.
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ENCLOSURE (1)
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I NYPA RESPONSE TO NOTICE OF VIOLATION I.B (Cont'd.)
At present, this testing is being performed biweekly instead i
of once every three months as required by Technical Specifi-cation 4.11.B.
This more frequent test interval will be continued and trended to establish the appropriate surveil-
' lance'and testing frequency to preclude further fouling of the unit. coolers.
This increased test frequency will be maintained until the trended data indicates that the fre-quency may be relaxed to the existing Technical Specifica-tion requirements.
4.
Further Corrective Actions to Avoid Future Violations An independent review of all Technical Specification sur-veillance requirements has been performed and has identified other cases where the Technical Specifications have an operability surveillance testing requirement, but no specif-ics on what testing must be performed to demonstrate oper-ability.
An initial review by plant senior management of these items indicates that present surveillance testing appears to be adequate.
Each of the cases identified are in the process of being further evaluated to ensure that current surveil-lance testing to meet Technical Specification operability requirements is adequate.
This review will be completed L)
April 30, 1989 and the recommendations of this review implemented as determined to be appropriate by the Plant Operations Review Committee (PORC).
5.
Date When Full Compliance Achieved Full compliance was achieved on November 19, 1988 upon approval and implementation of Surveillance Test Procedure ST-19A, Revision 1.
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ENCLOSURE (1)
Page NOTICE OF VIOLATION (I.C) 10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, in July 1987, a report of.a ventilation study of unit cooler rooms performed by Flakt, Inc. a licensee contractor, indicated that service water flow to the reactor building crescent area unit coolers may have been obstructed, and the licensee's Mechanical Design and Analyses Group confirmed this finding in January 1988: however, as of October 1988, action had not been taken to correct this problem.
NYPA RESPONSE TO NOTICE OF VIOLATION I.C 1.
The Authority agrees with this violation.
2.
Reason for the Violation a.
The reason for the violation is that corporate and plant review did not adequatelv assess the significance of the data and summary stated in the Flakt, Inc.
report.
The Flakt report had some information which would tend to establish that unit cooler operability was in question.
These Authority reviews did not prompt thermal performance testing to quantify a pocaible loss of unit cooler efficiency and its effect on Crescent Area ventilation and cooling.
- Instead, routine flushing and strainer cleaning was conducted and proper operation per design was assumed to result from these evolutions.
It is noted, however, that a proper review aid assessment of information obtained from the ASME,Section XI Inservice Pump and Valve Test Program resulted in the October, 1988 identification of the unit cooler silting problems.
3.
Corrective Actions Taken and Results Achieved a.
The incident has been reviewed with Authority personnel involved in the review of plant technical reports, and the potential effects of non-conforming conditions on system and component operability.
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ENCLOSURE (1) l Page NYPA RESPONSE TO NOTICE OF VIOLATION I.C (Cont'd.)
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I a.
A dedicated systems engineering group is being estab-lished in the Site's Technical Services Department.
This eventual group of eleven engineers will assume a company-wide role for coordinating actions relative to approximately 25 of the most significant safety and non-safety plant systems.
Reports or evaluations involving system performance issues will be~ reviewed by the cognizant systems engineer (as well as other cognizant plant personnel) and recommendations for actions made to appropriate.
levels of management.
This group will also strengthen interdepartmental coordination by providing a focal point where personnel can report on concerns associated with system operability and/or equipment performance.
Staffing is expected to be completed in June, 1989 with training to follow.
Administrative procedures de-scribing the responsibilities and establishing the various communication channels to be utilized by the system engineering group are presently being developed.
4.
Further Corrective Actions to Avoid Further Violations a.
In January, 1988 the corporate engineering organization was icitiated such that engineering personnel are assigned exclusively to engineering for the Authority's nuclear plants.
This corporate engineering organiza-tion reports directly to Executive Vice-President for Nuclear Generation.
Accompanying the corporate engineering re-organization l
is development of company-wide modification control I
procedures (Modification Control Manual) and design L
control procedures (Design Control Manual).
This procedural framework includes requirements for pre-paring and reviewing technical reports generated within or outside the company and provides a7propriate guid-l ance for performing these reviews, These procedures i
are partially impleaiented at the two nuclear plants and in the corporate office.
Full implementation is expected to be completed by June, 1989.
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i ENCLOSURE (1)'
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NYPA RESPONSE TO NOTICE OF VIOLATION I.C (Cont'd.)
b.
Root cause and failure analysis has been performed to date on a case-by-case basis, primarily at the request of'the Resident Manager or PORC.
The lack of a formal Root Cause Analysis Program was identified recently in NRC Inspection Report 88-24.
The Authority has commit-ted to developing a formal program'and is presently studying programs in place at other facilities to determine what might work-best at JAFNPP.
The'sched-uled completion date is July, 1989.
5.
,Date When Full Compliance Will Be Achieved The Authority considers its present program for identifying and correcting non-conformances and conditions adverse to quality as meeting 10CFR50, Appendix B, Criterion XVI.
Therefore, the Authority considers itself in compliance with this regulation.
As stated in paragraph 4.b, program enhancements are actively being pursued.
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ENCLOSURE (2) TO JAFP 89-0284 Response to Notice ~of Violations II.A and II.B (High Service Water Temperatures)
NOTICE OF VIOLATION (II.A) 10CFR50.59(a) allows the holder of a license to make changes in the facility as described in the safety analysis repo:t (SAR) without prior Commission approval unless it involves a change in the Technical Specifications or an unreuiewed safety question.
10CFR50.59(b) requires, in part, that records of these changes be maintained, and these records shall include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Section 6.5.1 of the FitzPatrick Final Safety Analysis Report (FSAR) lists the assumptions used to calculate the suppression pool temperature and minimum containment pressure following the design basis LOCA, and states that the maximum assumed inlet temperature for safety related service water systems is 77'F.
Contrary to the above, between August 3-17, 1988, a change was made to the facility as described in the FSAR in that the reactor was operated when the safety related water inlet temperature was above 77 F (as high as 79.5 F), and prior to or during that time, a written safety evaluation did not exist to verify that the condition did not involve an unreviewed safety question.
NYPA RESPONSE TO NOTICE OF VIOLATION II.A 1.
The Authority agrees with this violation (II.A).
2.
Reasons for this Violation a.
The Authority realized the necessity for performing a written safety evaluation per 10CFR50.59, and initiated efforts at the time of the lake temperature increase to do so.
Based on information received from the nuclear steam system supplier (GE), the original architect-engineer (SWEC) and Authority knowledge of the original plant design basis, the technical concerns appeared easily resolvable and no safety issues were identified.
These conclusions were not, however, formally documented or reviewed at the time.
This issue was presented and discussed with the NRC Resident Inspector who did not present any objections to continued plant operations.
Due to the need to maintain power produc-tion during record summer heat extremes, an understanding of the technical issues, and the tacit concurrence of the Resident Inspector, plant operation continued coincident with the preparation of the written safety evaluation.
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ENCLOSURE (2)
Page NYPA RESPONSE TO NOTICE OF VIOLATION II.A (Cont'd.)
l 3.
Corrective Actions Taken/Results Achieved i
i Lake Ontario temperatures decreased to less than 77"F on August 19, 1988 at which point a safety evaluation per 10CFR50.59 was not required.
The Authority continued with its. preparation of the required safety evaluation to support plant operations at lake temperatures up to 82 F.
This.
evaluation has been completed and is presently being re-viewed.
This evaluation establishes the technical and safety basis for plant operations in future summer seasons for lake temperatures up to 82 F.
The JAFNPP Final Safety Analysis Report (FSAR) will be updated to reflect this l
change in maximum lake temperature..
4.
Corrective Action to Avoid Further Violations a.
It has been re-emphasized to managers, operating personnel, and technical personnel of the need for a written: safety evaluation when deviations exist or develop which conflict or are outside the scope of the FSAR or known plant design bases.
b.
An improved company-wide procedure for determining the need for and preparation of safety evaluations required per 10CFR50.59 has been implemented.
Plant and corpo-rate engineers and Plant Operating Review Committee (PORC) members have completed training on this procedure.
c.
The Authority is developing a methodology for providing an expeditious review of FSAR and other design issues which potentially affect system operability or the design bases to provide justification for continued alant operation while a formal 10CFR50.59 evaluation is j
being developed.
This methodology will be completed by l
June 30, 1989.
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5.
Date When Full Compliance Was Achieved The Authority was in full compliance with the regulation on August 19, 1988 at the time when lake temperature decreased to 77*F.
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l ENCLOSURE (2)
Paga NOTICE OF VIOLATION (II.B) 10CFR50.72(b)(ii)(B) requires, in part, that the licensee shall notify the NRC Operations Center within one-hour of any event or condition during operation that results in a condition that is outside the design basis of the plant.
Contrary to the above, between August 3-17, 1988, the reactor operated in a condition outside the design basis of the plant (as set forth.in Violation II.A above),.and during that time, the NRC Operations Center was not notified of this condition.
NYPA RESPONSE TO NOTICE OF VIOLATION II.B 1.
The Authority agrees with the violation.
2.
Reason for the Violation Plant personnel were aware that the increase in lake temper-ature exceeded the maximum service water temperature-discussed in the FSAR, but concluded, based on available information, that the condition was acceptable pending completion of a written safety evaluation per 10CFR50.59 and tacit concurrence of the NRC (Resident Inspector).
3.
Corrective Actions and Results Achieved Plant requirements for deportability of events in accordance with 10CFR50.72 have been re-emphasized with all plant management and operating personnel.
Plant management will continue to monitor this issue closely to ensure full compliance with the regulation and the corresponding plant procedures.
No further failures to report events have been identified since the subject violation.
4.
Corrective Actions to Avoid Future Violation The Authority is developing a formal methodology for providing an expeditious review of FSAR and other design issues which potentially affect system operability or the design basen to provide justification for continued cperation while a formal 10CFR50.59 evaluation is being developed.
This methodology will be completed by June 30, 1989.
5.
Date Whe- 'ull Compliance Was Achieved The Authority considers itself in full compliance and will continue to report future occurrences per this regulation.
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