JPN-93-057, Responds to NRC Re Weaknesses Noted in Initial SALP Rept 50-333/92-99 for Period of 920419-930417.Util Will Use Recommendations from INPO Assist Visit Team to Enhance ALARA Program Which Maintains Worker Radiation Exposure
| ML20046D402 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/16/1993 |
| From: | Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| JPN-93-057, JPN-93-57, NUDOCS 9308190170 | |
| Download: ML20046D402 (6) | |
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August 16,1993 JPN-93-057 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 s Besponstto_initiaLSALP Repon
Reference:
NRC letter, T. T. Martin to R. E. Beedle, dated July 7,1993, regarding " Initial Systematic Assessment of Licensee Pedormance (SALP) Report No. 50-333/92-99."
Dear Mr. Martin:
This letter provides the New York Power Authority's response to the initial Systematic Assessment of Ucensee Performance (SALP) for the James A. FitzPatrick Nuclear Power Plant for the period of April 19,1992 through April 17,1993.
The Authority agrees with the NRC's assessment of performance. The initiatives implemented through the FitzPatrick Results improvement Program (RIP) have been effective, as recognized in the report.
The Power Authority is committed to continued improvements in performance and is confident that the cited weaknesses are being addressed through capital improvements, engineering organizational improvements, the Nuclear Generation Business Plan, as well as the FitzPatrick RIP. The Authority's detailed comments on the initial SALP are contained in the attachment to this letter.
If you hava any ouestions, please contact me.
Very truly yours, q
Ralph E. Beedle Attachment cc:
see next page l
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U.S. Nuclear. Regulatory Co.mmission ATTN: Document Control Desk.r Mail Station P1-137< '
i Washingtoni DC 20555 Office of the Resident inspector U.S.' Nuclear Regulatory Commission P.O. Box 136 Lycoming,' NY 13093 i
Mr. Brian C. McCabe Project Directorate 1-1 Division of Reactor Projects - 1/11 U.S. Nuclear Fegulatory Commission Mail Stop 14-82 i
Washington, DC 20555 i
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New York Pow:r Authority James A. FitzPatrick Nuclear Power Plant s
Attachment to JPN-93-057 RESPONSE to INITIAL SALP REPORT Operations The Authority agrees with the assessment of performance in the operations area, and is encouraged by the strengths cited. As noted in the report, the weaknesses identified during the period were effectively corrected and FitzPatrick RIP initiatives are in progress to prevent similar occurrences. These include procedure upgrades, use of procedure-validation and the continued emphasis on attention to detail, self-verification, and a conservative "do it right the first time" operations philosophy.'
BadiologicaLCont1ols i
The Authority agrees with the assessment of the radiological controls area. The Authority appreciates the NRC's recognition of continued good performance in several areas.
As stated in the report, radiological incidents are now addressed in the plant wide Deviation / Event Reporting system. This system has been effective in improving the tracking and close out of associated corrective actions. The procedures that control implementation of the Radiation Work Permit program have been improved, and further procedure improvements are being made. The need for procedure adherence in accordance with JAF Administrative Procedure 02.06, " Procedure Use and Adherence /
continues to be stressed.
The program which maintains worker radiation exposure as low as reasonably achievable (ALARA) continues to improve. At the request of the Authority, the institute of Nuclear Power Operations (INPO) performed an assist visit to the FitzPatrick plant in the ALARA area. Recommendations from the assist team will be used to further enhance the program.
The Authority is confident that the stated changes and the radiological control portion of the Results improvement Program will further improve performance.
Maintenance /Sursveillance The Authority agrees with the assessment of Maintenance and Surveillance. Improved procedural instructions and increased emphasis on equipment failure root cause analyses with corresponding focused corrective actions, have resulted in higher work quality and a lower incidence of re-work. This emphasis continues. The preventive maintenance l
program is being significantly irnproved and several major component group evaluations have been completed.
As noted in the report, the combustible control and scaffolding programs have been strengthened.
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- New York Pow:r Authority James A. FitzPatrick Nuclear Power Plant Attachment to JPN-93-057 e
A plant wide stand-down was conducted to reemphasize the need for attention to detail,
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and to reenforce the management expectation that work needs to be done right the first time.
l Efforts to improve the surveillance program include procedure upgrades, an adequacy review of Logic System Functional Tests, and centralized scheduling.
These and other continuing initiatives, such as equipment failure, root cause, and shutdown risk evaluations, critiques, and enhancements in planning and scheduling will further improve our performance in maintenance and surveillance.
1 Emergency _Ereparedness The Authority agrees with the assessment of this area. Management is committed to continued strong support and superior performance.
Initiatives taken or in progress during this SALP period include use of the plant specific control room simulator for the June 30,1993 emergency plan drill, initiation of an upgrade of Emergency Action Levels consistent with NUMARC guidance, and implementation of an improved dose assessment model.
Security i
The Authority agrees with the assessment in the security area and is committed to maintain superior performance through effective corporate support, critical self-assessment, and timely effective corrective actions.
Engioratin9EechnicaLSuppott The Authority agrees with the NRC assessment of this area. We are encouraged by the ackrowledgement of improved performance and are taking actions to address the weaknesses cited.
The Technical Services group is initiating an engineering on-call " duty officer" schedule to provide enhanced multi-disciplinary, timely, high quality resolution of emergent issues.
Technical Services activities are prioritized, assigned to a responsible individual ano tracked. Personnel training and vacations are being scheduled a year in advance to allow better resource planning and utilization. An issues Tumover Log has been established to improve the quality of task tumovers and to ensure availability of accurate technical information.
Technical Services staffing is being increased. Three experienced engineers have accepted offers and fourteen positions are being filled.
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I New York Power Authority James A. FitzPatrick Nucl:ar Power Plant Attachment to JPN-93-057 l
Several improvement initiatives are in progress in the engineering area. Improved analytical tools that have been implemented include: computerized modeling of the electrical distribution system; and computerized models for motor start circuit analysis, coordination analysis, and load studies. Improvements in modification and design control procedures and standards are ongoing.
Development of Design Basis Documents (DBDs) continues. Design information was retrieved from the NSSS supplier and the original plant architect-engineering firms and is being consolidated at the Authority's corporate office.
Engineering work backlogs are being trended and appropriate action is taken if trends are not satisfactory.
Improvements were made in the tachnical evaluations of Appendix R safe shutdown issues to address the weaknesses noted in the report. The lessons Icamed from the fire door deficiency issue were used to sensitize our engineering staff to operability concems, and to provide better guidance in this area.
A training program for support personnel has been developed and is being implemented.
Training has been completed for selected personnel in root cause analysis, observation, and human performance improvement techniques.
Effective July 30,1993, the corporate Vice President - Nuclear Engineering position has been filled with a loanee from INPO for a term of approximately one year. The engineering organizational structure is currently being evaluated. Changes needed to ensure more effective engineering support of both of the Authority's nuclear plants are being developed and will be initiated by January 1994.
Strong management attention will be given to the engineering / technical support area to ensure performance improvements continue at an acceptable pace, and that commitment i
schecules are accurate and consistently met.
Salety_AssessmentLQuality Verification The Authority agrees with the NRC assessment of this area. Management continues to emphasize safe, conservative operations and the need to do all tasks right the first time.
Strong management oversight, the use of management observations and self-assessment programs will provide feedback and monitoring of performance. Continued training in the use of root cause analysis techniques, and timely and effective corrective actions will ensure continued improved performance.
A Nuclear Assessment group has been established and permanent positions filled at both plants. These positions report directly to the Vice President - Nuclear Operations.
l The effectiveness of the Plant Operations Review Committee (PORC) will be further i
enhanced by improvements to the procedure review process that will allow the PORC to better focus on safety.
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4 New York Power Authority James A. FitzPatrick Nuclear Power Plant s
Attachment to JPN-93-057 The process used to review Licensee Event Reports prior to submittal to the NRC has been improved to ensure submittal of accurate information.
Tha Authority will continue to implement performance based, in-depth quality assurance audia to identify and correct weaknesses.
l The Power Authority is committed to achieve superior performance in this area.
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