ML19225C496
| ML19225C496 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/23/1979 |
| From: | Leonard J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19225C491 | List: |
| References | |
| JAFP-79-257, NUDOCS 7907310107 | |
| Download: ML19225C496 (3) | |
Text
ep.
POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITzPATRICK N UCLE A" POWER PLANT q?:
JOHN D. LEONARD, JR.
P.o. box 41 Resident Manager May 23, 1979 Lycommg, New York 13093 JAFP-79-257 3is.3E3340 Mr. Boyce H. Grier, Director United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Docket No. 50-333 IE Inspection No. 79-02
Dear Mr. Grier:
With reference to the inspection conducted by Mr. R. Conte of your office on March 13 through 16. 1979 at the James A. FitzPatrick Nuclear Power Plant and in accordance with the provisions of Section 2.201 of Part 11 of Title 10 of the Code of Federal Regulations, we arc submitting our response to Appendix A_ Notice jf Violation transmitted by ywr letter dated May 4, 1979 as receiv d by the undersigned on May 10, 1979
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AfPENDIX A NOTICE OF VIOLATION A.
Technical Specifications (TS) 6.8(A) states in part: " Written procedures and administrative policies shall be... implemented
" and TS 6.8(C) states in part:
" Temporary changes to nuclear safety related procedures mi.y be made provided...The change is documented, reviewed by the PORC (Plant Operations Review Committee) and approved by the Resident Manager wi thin 14 days of implementation."
Administrative Procedure (AP)-1.4, Control of Plant Procedures, Revision 2, February 16, 1978, paragraph 7.4.1 requi res that temporary changes be documented on a " Procedure Ini tiation/ Revision Request Form" for proper review and approval.
Also, Operation's Department Standing Order No. 3, Valve (Electrical) Lineup Check-Off Lists Review, Revision 0, July 7,1978, paragraphs 7.1 and 7.2 require that the reasons for valve posi tions that are dif ferent from normal operating conditions be documented on a form (Form 8.1) which is to be a cover sheet for the completed valve line-up.
Contrary to the above as of March 16, 1979, temporary changes to various valve line-ups were not documented en Procedure initiation /
Revision Request Forms and, therefore, r.ot properly reviewed and approved; also, the reasons for various valve positio t}ata'/je 7907310\\o f
Mr.' Boyce H. Grier, Director Mas; 23, 1979 United States Nuclear Regulatory Commission JaFP-79-257
Reference:
Docket No. 50-333
" age lE Inspection No. 79-02 di f ferent f rom normal operating condi tions were not docu iented on the required valve line op cover sheets.
These conditions were observed for valve line ups completed to support plant startup following the 1978 Refueling Outage and were noted in the following specific valve line ups:
OP-1, Main Steam System; OP-2A, Feedwater System; OP-13, Residual Heat Removal System; OP-14, Core Spray Sys tem; OP-15, High Pressure Coolant injection System; OP-20, Standby Gas Treatment System; and OP-27, Reci rcula tion Sys tem.
RESPONSE TO ITEM A:
The findings of the Inspector as set forth above are correct. It should be noted however, ti.a t in no case were the valve line-up sheets misleading or different from the actral physical configura-tion of t's valves in the plant.
The error made was that the prescribet aper work had not been properly filled out.
The operating staff at all times, because of the changes made on the valve line-up sheet, knew the a-tual cc. figuration of the plant sys tems noted. As a specific example, a temporary change should have been issued to delete two vaives which had been removed because of a physical modification in the plant.
The va!/es had been lined out on the valve line-up sheet by the operator making the system line up and this had been brought to the attention of the Shift Supervisor.
Since the line-up sheet is an appendage to the syscem operating procedure, the ten.porary change control system should have been implemented to make this change to the sheet.
In other cases v.ere valve posi tions on the valve line-up sheet were noted as different from the specified line-up condition, this was because the system was in a startup condition and not in a normal operation at power condition.
Thoses cases whic' the valves were noted as being in a different than normal operation position should have bec, called out on die cover sheet as prescribed in our Operations Department Standing Order No. 5, which had been recently wri tten to cover this contingency.
We will p' ace this infraction reply ir our reading file for the operators to emphasize the importance of utilizing the correct administrative control measures to further ensure that valve line-ups are properly made.
In addition to the.ilve line-up sheets which are required prior to start up of this plant, the Operations Department conducts surveillance tests prior to startup on required reactor safety systems.
Th s further assures their proper operability.
423 j[(k it is rui terated that in these cases noted by the Inspector, the value line up sheets did properly represent the actual plant configu ation. This plant ccnfiguration was known to the operating staff and the violation was one of failure to implement the administrative controls established in the plant rather than
<s Mr. Boyce H. Grier, Director May 23, 1979 United States Nuclear Regulatory Commission JAFP-79-257
Reference:
Docket No. 50-333 Page IE Inspection No. 79-02 failure to properly prepare the physical plant fc operation.
Ve will also insure the use of these controls is emphasized during future training.
B.
Technical Specifications 4.7.A.1 states in part:
...whenever there is... testing which adds heat to the suppression pool, the pool temperature shall be continually monitored and also observed and logged every 5 minutes until heat addition is terminated..."
Contra.y to the cbove, on three ins;ances between September 23, 1977 and December 8, 1978, suppression pool temperature was not ntinually monitored, and was not observed and logged every 5 minutes during testing which added heat to the suppression pool in accordance with Surveillance Test, ST 22B, Automatic Depressuriza-tion System (ADS) Manual Relief Valve Operation (current revision in effect at the time of testing).
RESPONSE TO ITEM B The FitzPatrick Plant Staff acknowledges that the suppression pooi temperatures have not been logged every 5 minutes during the testing of automatic pressurization valves as described in Operations Surveillance Test F-ST-22B in the past.
This over-sight has been corrected by revising the referenced Surveillance Test.
Very,ttuly yours, 7('7H(:.
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' JGIN D. LEONARD, JR.
f CC:
G. T. Berry, PASNY, NY0 RESIDENT MANAGER G. A. Wilverding, PASNY, NY0 P. W. Lyon, PASNY, NY0 J. D. Leonard, Jr., PASNY, JAF R. J. Pasternak, PASNY, JAF M. C. Cosgrove, PASNY, JAF E. C. Abbott, PASNY, JAF D. E. Tall, PASNY, JAF Document Control Center d
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