JPN-93-074, Provides Updates to Commitments Made in Responses to NRC Diagnostic Evaluation Team Rept,Salp Rept,Nov & NRC Insp Repts 50-333/91-22,50-333/91-26,50-333/92-80 & 50-333/92-81

Provides Updates to Commitments Made in Responses to NRC Diagnostic Evaluation Team Rept,Salp Rept,Nov & NRC Insp Repts 50-333/91-22,50-333/91-26,50-333/92-80 & 50-333/92-81

ML20058P171
Person / Time
Site:	FitzPatrick
Issue date:	10/14/1993
From:	Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JPN-93-074, JPN-93-74, NUDOCS 9310220135
Download: ML20058P171 (11)

Text

123 Main street -

White Plains. New York 10601 ,

914 681 6846 4 NewYorkPower n..,s e. ... .

& Authori " - ~ " - ~

Nomear Generanon October 14,1993 JPN-93-074 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, DC 20555

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 CommitmenLUpdate

References:

1. NYPA letter, J. C. Brons to J. M. Taylor dated January 3,1992 (JPN 001 A), regarding " Diagnostic Evaluation Team Report."

2. NYPA letter, R. E. Beedle to the NRC dated February 18,1992 (JPN-92-008), regarding NYPA's Response to an NRC Request for Additional Information on certain Diagnostic Team Findings at the FitzPatrick Nuclear Power Plant.

3. NYPA letter, H. P. Salmon to the NRC dated July 20,1992 (JAFP 0551), providing a response to the Systematic Assessment of Ucensee Performance Report 91-99.

4. NYPA letter, R. E. Beedle to the NRC Director of the Office of '

Enforcement dated October 15,1992 (JPN-92-063), regarding NYPA's Reply and Answer to Notice of Violation - NRC Inspection Reports 91-22, 91-26, 92-80, and 92-81.

Dear Sir:

During the process of implementing improvements at the FitzPatrick plant, the Authority detemlined that modNations to the original improvement plans provided to the NRC in the letters referenced above were required. These changes are being provided to ensure that the NRC has the most current and complete information related to the status of these improvements.

Attachments I through IV to this letter provide updates to commitments made in responses to the NRC's Diagnostic Evaluation Team report (and subsequent request for additional information), Systematic Assessment of Ucensee Performance (SALP) report for the period of February 1,1991 through April 18,1992, and Notice of Violation - NRC Inspection Reports 91-22,91-26, 92-80, and 92 81 (References 1 through 4 respectively).

Attachment li also summarizes the resolution of concems related to the lake water intake structure deicing heaters.

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931032O535 931014 5 '

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4 If you have any questions, please contact Mr. J. A. Gray, Jr.

Very truly yours,  ;

Ralph E. Beedle  !

Attachments: As stated -

cc: Regional Administrator  ;

U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector  :

U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming. NY 13093 1

Mr. Brian C. McCabe '

Project Directorate 1-1 Division of Reactor Projects - 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14-B1 Washington, DC 20555 ,

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4 Nsw York Pow r. Authority ' '

. James A. FitzPatrick Nuclarr Powd Plant' ,

Attachment I to JPN-93-074 DIAGNOSTIC EVALUATION TEAM REPORT. .

l This Attachment provides updates to commitments made by the Authority in response to - l the NRC's Diagnostic Evaluation Team report (NYPA letter, J. C.- Brons to J. M. Taylor  ;

dated January 3,1992, (JPN-92-001 A)). j Eage_3 .

Statement: The Resident Manager's position, as well as the positions of General - '

Manager - Support Services ... were filled with personnel hired from outside the Authority.

j Update: The position of General Manager - Operations was also filled with an individual 1 hired from outside the Authority.

Eagel Statement: A job rotation program . . is also planned.

Update:- The job rotation objectives of instilling new management perspective has been - l accomplished by numerous management changes at NYPA nuclear facilities and at -!

headquarters. Continued changes in management structure will maintain freshness in ' j management's point of view. 1 1

3 Statement: [The site engineering] organization will be enlarged to 34 persons in 1992. t Update: The site engineering group is now staffed with 36 permanent employees and 16 contractors. j Eage_5 i I

7 Statement: A work process consisting of an " Engineering Prioritization Flowchart" ... will be used in the initial program. . A new site engineering tracking system and a process to .l estimate engineering and installation resources and its application to scheduling work -l activities is also being developed.  ;

Update: The work process is still under review. Scheduling of work is in progress. (

Statement: Permanent staffing within the NED section will be increased in 1992 for the - i following engineering disciplines: fire protection (4 positions) ..

Update: Three permanent positions were added to support fire protection activities. . In i

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addition, an Engineering Division reorganization is planned which may result in' relocation I

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James A. FitzPatrick Nuclear Power Plant

. i of various engineering functions and staffing between the White Plains Office and the two nuclear plant sites.

Eage_6 Statement: An additional group will be established to control the day-to-day planning and scheduling within the Nuclear Engineering Division.

Update: This planning function has been combined with the Planning and Scheduling group within the Nuclear Operations Division.

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. N:w York Power Authority j James A. FitzPatrick Nuclear Power Plant  !

. l Attachment 11 to JPN-93-074 DIAGNOSTIC EVALUATION TEAM REPORT Request for AdditionalInformation This Attachment provides updates to commitments made by the Authority in response to the NRC's Request for Additional Information associated with Diagnostic Evaluation Team report (NYPA letter, R. E. Beedle to the NRC dated February 18,1992, (JPN-92-008)).

Attachment I - Page_1 NRC Ouestion (A.) is concemed with the design basis (including single failure) of the lake water intake structure deicing heaters. A related FitzPatrick Licensee Event Report (LER 91-032-00 (Reference 1)) discusses the design basis of the deicing heaters with respect to safe shutdown of the plant under 10 CFR 50 Appendix R fire conditions. This Appendix R concern is discussed below.

An evaluation was undertaken to determine if the deicing heaters are needed to prevent ice blockage of the intake structure while the plant is implementing safe shutdown procedures.

The Authority contracted with Fleet Technology to perform the evaluation. The results of the Fleet Technology Report (Reference 2) were the basis for LER 91-032-01 (Reference 3) which concluded that the heaters are not necessary to achieve and maintain safe shutdown.

LER 93-004-00 (Reference 4) relates an incident in which ice blockage did occur during normal operation with the deicing heaters operational. As discussed in this LER, water level in the bays dropped due to ice blockage of the intake structure. Upon tripping the plant and securing two of the three circulating water pumps, the water level rapidly increased to normal levels.

The intake deicing heater issue was reviewed by the NRC in a recent inspection. The Authority anticipates that this issue will be closed in the near future.

REFERENCES:

i j 1) LER 91-032-00, " Intake Heaters Potentially Inoperable Due To Control Room Fire", NYPA letter, R. J. Converse to the NRC dated January 27,1992 (JAFP-92-0094).

2) Fleet Technology Umited Report # 3971, " Cooling Water intake at the J. A.

FitzPatrick Nuclear Power Plant: A Study on the Potential for Blockage by Frazil, Grease Ice and Slush", dated January,1993.

3) LER 91-032-01, " Intake Heaters Potentially Inoperable Due To Control Room Fire" NYPA letter, H. P. Salmon, Jr. to the NRC dated May 1,1993 (JAFP-93-0261).

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. N:w York Pow:r Authority Jcmns A. FitzPatrick Nucl:ar Pow:r PI:nt

4) LER 93-004-00, " Low intake Level Scram", NYPA letter, H. P. Salmon, Jr. to the NRC dated March 26,1993 (JAFP-93-0165).

EagfL6 Statement: The Authority is presently refining its process to review and improve the benefit / cost studies. A committee comprised of representatives from Operations, Maintenance, Planning, Technical Services, and Health Physics meets on a regular basis to review the cost / benefit documentation and is developing a weighted criteria scale to improve the assigning of priorities.

Update: The Authority has finalized the process of evaluating modifications in terms of their benefit / cost ratio, which has been modified to account for project impact on safety and regulatory compliance. This process documentation has been completed and the administrative controls are being formalized and are being included in the plant-wide work control process procedure.

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N:w York Powsr Authority James A. FitzPatrick Nuclear Power Plant Attachment ill to JPN-93-074 SALP REPORT This Attachment plovides updates to commitments made by the Authority in response to the NRC's SALP Report (NYPA letter, H. P. Salmon to the NRC dated July 20,1992, (JAFP-92-0551)).  !

Operations Eage_2 Statement: A license class . is expected to provide an additional six SROs and six ROs to operations.. The next license class will start January,1993. .

Update: The class provided five SROs and five ROs. The subsequent class started in February,1993.

Eage_3 Statement: Additional guidance and training on expected standards of shift tumovers, log keeping. and shift communication has been provided to the operating crews.

Update: The procedure for shift turnovers have been revised to strengthen this process.

This revision requires that a member of the incoming shift perform a full walkdown and verification of those items on the shift tumover checklist. In addition, an operator aid has been developed and is in use to assist operators in the identification of new annunciators on a once/ shift basis.

EngineeringdechnicaLSupport EageJ2 Statement: (none)

Update: A new Technical Services manager has been hired from outside the Authority.

This new manager brings external industry experience into the organization.

Eage_L4 Statement: A description of the project team concept for modifications has been issued and reviewed and is in the process of being formatted into a Nuclear Engineering Administrative Procedure.

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. N:w York Power Authority James A. FitzPatrick Nuclear Power Plant Update: Nuclear Engineering Administrative Procedure, NEAP-24, Project Teams and Project implementation" has been issued.

Statement: A planning group has been established with Nuclear Engineering consisting of a NYPA Planning Manager and four planners .

Update: This planning function has been combined with the Planning and Scheduling group within Nuclear Operations.

Safely _AssessmentlQualitylenfication Eagel6 Statement: An integrated assessment program had been developed and is being implemented by the White Plains Operations and Maintenance Department.

Update: The integrated assessment program has been reassigned to the Nuclear Administrative Programs group, reporting to the Executive Vice President, Nuclear Generation.

Eage_1Z Statement: Five new licensing engineer positions have been approved. The total licensing staff . now includes eight permanent . . engineers and four contractors. Four permanent vacancies will be filled in the near term with contractors. This will bring the total number of licensing engineers to sixteen.

The licensing staff now includes ... one engineer who is SRO certified at FitzPatrick.

Three of the eight permanent Authority engineers now have systems training equivalent to that required for an operators license.

Update: Three new licensing engineer positions have been approved. The total licensing staff currently consists of ten permanent engineers, one of whom is stationed at the Fitzpatrick plant. (One of these ten positions is currently vacant.) There are two contractors temporarily supplementing the staff.

The licensing staff now includes two engineers who were SRO certified at FitzPatrick and one former FitzPatrick SRO. Four of the nine permanent Authority engineers now have systems training equivalent to that required for a Senior Reactor Operators license. As stated in the SALP response, the Director, Nuclear Licensing - BWR also received an SRO certification for FitzPatrick.

Eagel8 Statement: The Authority is adding a verification function to the licensing section, which 6

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. James A. FitzPctrick Nuclser Powar Plant will be performed by one licensing engineer on a full time basis.

Update: Independent verification of selected commitments to the NRC will be performed by NYPA Quality Assurance as requested by Licensing.

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Statement: In the past, a weekly directors meeting was held in the White Plains Office.

This meeting will be reinstated, but on a more formal basis to make it more productive.

Update: The Directors' meeting is now held every morning. All Nuclear Generation Directors and Vice Presidents are on the agenda to present emergent issues and discuss important work activities. Minutes are electronically distributed to interested parties.

Statement: Ucensing also attends the monthly Project Meeting held at the FitzPatrick l

Plant and the White Plains Office Moming Meeting.

Update: In addition, the onsite Licensing Engineer attends the daily FitzPatrick morning meeting.

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. Nsw York Pow:r Authority James A. FitzPatrick Nuclear Power Plant Attachment IV to JPN-93-074 NRC INSPECTION REPORTS 91-22, 91-26, 92-80, and 92-81 '

This Attachment provides updates to commitments made by the Authority in response to the Notice of Violation (NYPA letter, R. E. Beedle to the NRC Director of the Office of Enforcement dated October 15,1992, (JPN-92-063)).

Attachment I Eage_1Z Statement: . the Authority will consolidate the existing fire protection elements into a single Fire Protection Program.... The consolidation will be completed by March 31, 1993.

Update: In JPN-93-036 (5/19/93), the Authority stated that the Fire Protection Program l will be consolidated by September 30,1993. This was completed on schedule.

Eage_20 Statement: The second phase will be a more comprehensive upgrade of the pre-fire plans and will conform to NRC's guidance document " Nuclear Plant Fire Protection -

Functional Responsibilities, Administrative Controls and Quality Assurance." Full compliance will be achieved on March 31,1993.

Update: In JPN-93-036 (5/19/93), the Authority stated that Phase 11 of the pre-plans will be completed by September 30,1993. This was completed on schedule.

Eage_23 Statement: A new position has been added (but not yet filled) to the Licensing Group for an engineer who will be responsible for verifying that commitments to the NRC are satisfied.

Update: Independent verification of selected commitments to the NRC will be performed by NYPA Quality Assurance as requested by Licensing.

Eage_29 Statement: Full compliance will be achieved when the installation of the new cable tunnel (fire suppression) systems are complete. Completion is scheduled for July 31,1993.

Update: In JPN-93-036 (5/19/93), the Authority stated that full compliance will be l

achieved by December 31,1993. The east cable tunnel suppression system is now 8

. N::w York Powsr Authority J mss A. FitzPatrick Nuclsar Powsr Picnt available. The west cable tunnel suppression system is in the process of being tested.

Eage_30 Statement: Full compliance will be achieved .. by completing modifications to correct all deficiencies current identified.

Update: Full compliance was achieved by completing modifications or implementing procedural changes to correct all deficiencies currently identified.

Eage_3B Statement: Five new licensing engineer positions have been approved and two have been filled.

Update: Two of the five new positions were subsequently eliminated.

Eage_3Z Statement: The Authority is adding a verification function to the licensing section ..

Update: Independent verification of selected commitments to the NRC will be performed by NYPA Quality Assurance as requested by Licensing.

Eage 38 Statement: A new Action Item Tracking System has been developed for use in the Nuclear Generation Department. Nuclear licensing will assume responsibility for this system and use it to assure timely resolution of licensing issues. In addition, licensing will use a computerized commitment tracking system for the recording and tracking of commitments to the NRC and outside organizations.

Update: A new Action item Tracking System was completed, but not implemented. An improved system will be developed and implemented. Responsibility for this has been transferred to the Director of Administrative Programs. A commitment database was developed by Configuration Management as part of the Design Basis Document project.

This database is being updated by Configuration Management and Licensing will assume responsibility for it by December 31,1993.

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