JAFP-94-0117, Forwards Updated Status of Commitments Made in 920804 Revised Response to Violations & Deviations Resulting from SSFI 50-333/92-81 of Esws.Nuclear Generation Procedure NGP-26 & Nuclear Licensing Guideline NLG-13 Will Be Revised
| ML20063M200 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/24/1994 |
| From: | Harry Salmon POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JAFP-94-0117, JAFP-94-117, NUDOCS 9403110199 | |
| Download: ML20063M200 (7) | |
Text
. _ - _ _. _ _ _ _ _.
James A.FitzPatrick Nuclear P:wer Plant P.O. Box 41 Lycoming New York 13093
, 315 342-3840 9
- > NewYorkPower 4
4# Authority
""'L"da*n'e"; "' "
s February 24, 1994 JAFP-94-0117 U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. 20555 ATTN: Document Control Desk
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Inspection 92-81 Notice of Violation and Notice of Deviation Status of Commitments
Reference:
- 1. NRC letter, M. W. Hodges to H. P. Salmon, dated June 11,1992, regarding NRC Inspection Report 50-333/92-81.
- 2. NYPA letter, H. P. Salmon to the NRC dated August 4,1992 (JAFP 0578), regarding a revised response to Notice of Violation and Notice of Deviation - NRC Inspection 50-333/92-81.
- 2. NYPA letter, H. P. Salmon to the NRC dated July 13,1992 (JAFP 0527), regarding the reply to Notice of Violation and Notice of Deviation NRC inspection 50-333/92-81.
- 4. NRC letter, J. P. Durr to H. P. Salmon, dated September 9,1992, regarding NRC Inspection Report 50-333/92-81.
Dear Sir:
This letter updates the status of the Authority's commitments made in Reference 2 in response to the Notice of Violation and Notice of Deviation resulting from the NRC Safety System Functional Inspection of the FitzPatrick Emergency Service Water System (Reference 1).
Attachments 1 and ll summarize the status of the ten commitments made in response to the Notice of Deviation and the Notice of Violation respectively. Five of these commitments have been completed and five have been rescheduled. Attachment 111 outlines the commitments made in this letter, if you have any questions, please contact Mr. J. A. Gray, Jr.
Very truly yours,
'/&
Harry P. Salmon, Jr.
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i Attachments 9403110199 940224 r
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' U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector l
U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. Brian C. McCabe Project Directorate 1-1 Division of Reactor Projects - 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 t
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Att:chmtnt I to JAFP-94-0117 Updated Status of Commitments from Response to Notice of Deviation This attachment provides the updated status of commitments made by the Authority in
' response to the NRC Safety System Functional Inspection of the Emergency Service Water System Notice of Deviation (Reference 1, Attachment IV).
Commitment "FSAR Section 9.7-1 will be revised to include both the design specifications and the operability requirements of crescent area unit coolors. [ Duo date - 1993 FSAR Update]"
Status The FSAR was updated to include this information in the July 1993 update. The design specified flow rate of 24 gpm is listed on Table 9.7-1 and the operability requirements were added to pago 9.7-2.
i in Reference 4, the NRC expressed a concern with the potential effects on the temperature profilo of the crescent area of changing the required 24 gpm flow rate to an overall heat removal capability for each train of crescent area coolers. The resolution of the NRC concem is being documented by the Authority and is scheduled for completion on April
'l 30,1994. The FSAR will be updated as necessary.
Cornmitment "The Authority has established a Nuclear Generation Business Plan Objective to review its internal procedures used to maintain and update the FSAR.... [Due date - 9/30/92]"
Status A review of Nuclear Generation Procedure NGP-26, " Final Safety Analysis Report Amendmont Preparation and Control" and Nuclear Licensing Guideline NLG-13, " Final Safety Analysis Report (FSAR) Update Process" has been performed. As a result of this review, these proceduros were revised and are currently in the final stages of review and approval. This task has been rescheduled for March 31,1994.
Commitment
"... Included in this review will be an assessment of the FSAR level of detail based on recomrnendations in Reg Guide 1.70. [Due date - 9/30/921" Status The Authority has completed a comparison of the level of detailin the FitzPatrick FSAR to the format and content detailed in Regulatory Guide 1.70. After evaluating the potential benefits and development costs, the Authority staff recommended that management not upgrado the FitzPatrick FSAR because there is no tangible benefit to be gained. The upgrado proposed by the assessment would only duplicato information already in the Design Basis Documents (DBDs) and would require the Authority to maintain the same information in DBDs and the FSAR.
Page 1 of 2
Attichm:nt I to JAFP-94-0117
_ Updated Status of Commitments from Response to Notice of Deviation The Nuclear Generation Business Plan Objective and Results improvement Program item
- established for this task will be closed upon management review and approval of this recommendation.
Commitment "The Authority has established a Nuclear Generation Business Plan Objective to enhance-the process for review and revision of the FSAR to reflect current plant configuration and Design Basis Documents. [Due date - 12/30/92]"
Status Significant progress towards completion of this task has been made. However, additional
-actions are planned to further enhance the process for review and revision of the FSAR.
The FSAR update process now includes an additional review cycle. Each subchapter of the FSAR is assigned to a supervisory and senior / lead engineer, who are knowledgeable in the subchapter topic. The senior /laad engineers review their subchapter and all FSAR updates affecting their subchapter. All revisions to the subchapter are then evaluated by -
the assigned supervisor for completeness and technical accuracy.
'In addition, the preparer of a Design Basis Document (DBD) is required to review all i
applicable sections of the FSAR and provide Licensing with any necessary FSAR change requests.
The Nuclear Generation Business Plan Objective and Results improvement Program item.
established for this task has been rescheduled for July 31,1995.
Commitment "The Authority will formally document the FSAR deviation in accordance with Nuclear.
Generation Procedure NGP-38."
Status This action has been completed. A revision to Nuclear Safety Evaluation JAF-SE-90-067 was approved by the Plant Operating Review Committee (PORC) on September 11,1992 to formally document the deviation.
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Att2 chm:nt il to JAFP 94-0117 Updated Status of Commitments from Response to Notice of Deviation
~
l This attachment provides the updated status of commitments made by the Authority in j
' response to the NRC Safety System Functional inspection of the Emergency Service Water System Notice of Violation (Reference 1, Attachment II).
Commitment "MCM-6A will be revised to ensure the appropriate personnel (System Engineers and/or Nuclear Generation Department) are assigned to the review. (Due date - 10/31/92)"
Status This action has been completed. MCM-6A revision 2, dated December 15,1992, incorporated guidance to ensure that the appropriate personnel are assigned to the review.
Commitment "MCM-6A will be revised to provide additional guidance to ensure interfacing safety related systems are identified and evaluated during component classifications. IDue date -
10/31/92]"
Status This action has been completed. MCM-6A revision 2, dated December 15,1992, incorporated additional guidance to ensure interfacing safety related systems are identified and evaluated during component. classifications.
Commitment
" Training on the revised procedure will be provided. IDue date - 12/31/92]"
Status This action has been completed. Training on the revision to MCM-6A was provided on schedule.
Further incidents of incorrect classification of pressure boundary components have occurred since the completion of these items. The Authority has evaluated the need for further revisions to the procedure. Revisions will be completed by April 15,1994.
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Attschmsnt 11 to JAFP-94-0117 Updated Status of Commitments from Response to Notice of Deviation Commitment
" Full compliance will be achieved when the service water / emergency service water pressure boundary supplying the control room and relay room chiller condensers and the chiller room air handling units are reclassified as OA Category 1. Included in the upgrade is a revision to the Master Equipment List in accordance with procedure MCM-6A. An engineering evaluation verifying the acceptability of the installed components to meet QA Category I requirements is being performed in accordance with Engineering Design Procedure EDP-31... The Authority will complete the upgrade prior to startup from the 1992 refuel outage."
Status This action has been completed. The service water / emergency service water pressure boundary supplying the control room and relay room chiller condensers and the chiller room air handling units have been reclassified as OA Category 1. The Master Equipment List revision and the engineering evaluation verifying the acceptability of the installed components to meet GA Category I requirements were completed as part of the upgrade.
Commitment
"... a heating and air conditioning (HVAC) DBD is scheduled to be developed starting in September 1992."
Status An HVAC Design Basis Document (DBD) is currently under development for FitzPatrick.
The DBD is scheduled to be completed in October 1994.
i Page 2 of 2
Attachment lil to JAFP-94-0117 Commitments Commitment Number Commitment Due Date JAFP-94-0117-01 Further incidents of incorrect April 15,1994 classification of pressure boundary components have occurred since the completion of these items. The Authority has evaluated the need for further revisions to the procedure. Revisions will be completed by April 15,1994.
JAFP-94-0117-02 Revise Nuclear Generation March 31,1994 Procedure NGP-26, " Final Safety Analysis Report Amendment Preparation and Control" and Nuclear Licensing Guideline NLG-13,
" Final Safety Analysis Report (FSAR) Update Process" J AFP-94-0117-03 Document resolution of NRC April 30,1994 concern with the potential effects on the temperature profile of the crescent area of changing the required 24 gpm flow rate to an overall heat removal capability for each train of crescent area coolers.
JAFP-94-0117-04 The Authority will develop a October 1994 Heating, Ventilation, and Air Conditioning.(HVAC) Design Basis Document (DBD).
JAFP-94-0117-05 The Authority will develop July 31,1995 j
further enhancements to the process for review and revision of the FSAR to reflect current plant configuration and Design Basis Documents.
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