ML19259C717

Responds to Request for Addl Info Re IE Bulletin 79-08 Concerning Safety Injection Sys Training Instructions, Critical Values,Inadvertent Transfer of Radioactive Liquids & Visual Checks of Sys Status

ML19259C717
Person / Time
Site:	FitzPatrick
Issue date:	08/08/1979
From:	Leonard J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Ippolito T Office of Nuclear Reactor Regulation
References
JAFP-79-408, NUDOCS 7908140626
Download: ML19259C717 (4)

Text

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POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. Fn2 PATRICK NUCLEAR POWER PLANT JOHN O. LEONARD, JR.

Resident Manager S

August 8, 1979 P.O. BOX 41 Lycoming, New York 123 3is-35-384o JAFP 79-408 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Thomas A. Ippolito, Chief Operating Reactors Branch No. 3 Division of Operatinc Reactors

SUBJECT:

Request for Additional Information NRC BULLETIN 79-08

Dear Sir:

The following pro" Hes the response of the James A.

FitzPatrick Nuclear Pow.c Plant itcff to the request for additional information for NRC Bullt.in 79-08.

The responses are enumerated in the same order as the questions or required actions set forth in the request for additional informa tion.

RESPONSE 1

1. The review specified in Item 1 of I&E Bulletin 79-08 has been completed. This was confirmed earlier durin, an inspection of the plant by the Inspection & Enforcement Division Inspectors from Region I.

RESPONSE 2

1. Since all penetrations not required for sr#ety injection isolate automatically, as set forth in the first paragraph to our original response to I&E Bulletin 79-08, item 2, there are no procedures which require isolation action. The plant Special Procedures do however, require that operators follow the automatic isolation closely ar" nould a valve not operate, operate that valve manually.

Since no procedures are required for manual isolation actions, no procedures were reviewed.

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Director of Nuclear Reactor Regulation August 8, 1979 U.S. Nuclear Regulatory Commission JAFP 79-408

SUBJECT:

NRC BULLETIN 79-08 Page RESPONSE 4

1. In view of the fact that there are seven (7) separate reacter vessel water level indicators in the control room for the reactor operators, which we have been informed by General Electric have been tested under accident conditions, it is our position that this multiplex of redundancy should be fully utilized by our operators in making judgments regarding reactor water level under normal and abnormal conditions. In addition, w6 are in connunication with General Electric regarding means by which tne reliability of these indications can be improved under accident conditions. We do not believe that possibly erronecas indications from other sources which might contradict corrobordted level indications should be utilized by the operators for action. There does exist drywell pressure indica-tions, containment sump level indications, suppression pool temerature indications, suppression pool level indications and indications on main steam isolation valves, safety relief valves, reactor water cleanup valves, high pressure coolant injection steam line valves, high pressure coolant injection valves, low pressure coolant injection valves, all of which may very well be monitored by the opera' tor to determine gross changes in reactor vessel inventory. We encourage corroboration of indication utilizing such means as noted in 2. below. Specifically, for small changes in the reactor coolant inventory, ie: less than five (5) gallons per minute, the containment sump indication systems are i .ilized to determine whether we are or whether we are not within the criteria of our Technical Specifications on minor leakage. However, none of these instrument systems can be used to adequately determine the vessel level and for this, the operator should rely on the seven redundant level systems.

2. With respect to sub-section 2 of this request for additional information, your attention is invited to our original response 5, sub-paragraph b, page 7.

RESPONSE 5

1. Training instructions which specify the curriculum for training programs will be revised to include the requirements for specific instruction to operators on the procedural guidance issued to them in our standard and special procedures as discussed in our original response. Our re-qualification program at present requires retrmining on these procedures. ,

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2. As part of the reviews conducted to satisfy the requirements of the subject bulletin, the FitzPatrick Plant Staff has reviewed the full range of instructions to the operators regarding operation of engineered safety features. In no case is it directed nor is it implied, that operators are to over-ride and prevent continued operation of these engineered safety features. The contrary is directed as is discussed in our original response. Should an unsafe plant condition arise because of continuea operation of an engineered safety feature, we would rely on the judgment of the operator to determine whether he should secure the system.

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Dit ' tor of Nuclear Reactor Regulation August 8,1979 U.S. Nuclear Regulatory Comission JAFP 79-408

SUBJECT:

NRC BULLETIN 79-08 Page 3. Instructions to operators are provided primarily by Operating Procedures, Special Procedures (Emergency Operating Procedures),

Standing Orders and Special Orders. All applicable procedures were reviewed pursuant to the criteria established in Item 5. B.

of the bulletin. Training instructions as noted in 1. above do not provide instructions to the operators but outline the curriculum for a specific training program.

4. Revision of the training programs noted in 1. ab6ve will be completed by September 30, 1979.

RESPONSE 6

1. The "certain critical valves" noted in our original response are those locked valves in safety-related systems which are accessi during plant operations. These valves are checked monthly for position and locking devices.

2. Positive administrative contrnis are implemented to assure that systems requireing retest ar in fact retested prior to the need for their operability. Retest is required on safety-related systems. The only exception allowed is if plant conditions require a delay in the retest. If plant conditions prevent immediate retest, a tag is placed on the system in the control com to insure the operator realize that a retest is required before declaring the system operable. In adoition, the Technical Specification limitation on systems which are inoperam and require testing of the redundant systems is followed during these periods.

3. Documented position checks on the valves in safety-related systems are (and have been) made during valve lineups prior to startups and af ter maintenance actions are completed that required tagging out of the valves in an abnormal condition. Valve lineup sheets have been reviewed by regional inspectors for accuracy and proper usage. The valve positions and valve operators, if applicable, are operationally checked by the surveillance test required by the Technical fpecifications to insure proper operability of these systems.

RESPONSE 7

1. We will modify our precedures to prevent inadvertent transfer of radioactive liquids through the reactor coolant sample line by September 1, 1979.

RESPONSE 8

1. We will comit to m 'ing a visual check of system status, to the extent practicable, prior w removing the redundant equipment from service and concommittantly rely on the prior operability verification within the current Technical Specification surveillance interv31. Prior to our committing to this however, it is our recommendation that this be discussed by the Office of Nuclear Reactor Regulation with Region I, L a ? '. '

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Director of Nuclear Reactor Regulation August 8, 1979 U.S. Nuclear Regulatory Commission JAFP 79-408

SUBJECT:

NRC BULLETIN 79-08 Page Division of Inspection and Enforcement since this represents considerable relaxation in the Regulatory position and it is our opinion that our Principal Reactor Inspector must cuncur with this.

2. Reactor operating personnel are required to relieve in the control room, review appropriate logs and status boards and discuss the status of systems, including safety-related systems. This procedure is set forth in Operations Department Standing Order No. 4, " Shift Relief and Log Keeping" which is available for review by the Comission's inspector at the site. Specifically, p3ge 3 of this Standing Order subsection A.3 states: "In addition to reading of the logs, the incoming operator shall be appraised of any testing, unusual operations, etc., that are in progress." and subsection A.6 states: "The verbal exchange of ir. formation between shifts must include the status of all safety related equipment and conditions, as set forth in Technical Specifications.,"

RESPONSE 9

1. It is our position that our c: 1ginal response and the request for supplementary information from your office has been out-dated by recent directives received from the Regulatory Commission. Specifically, a phone has been installed in the control room under the direction of the Regulatory Comission and guidance has been issued regarding the definition of " controlled or unexpected conditions of operation."

We are conforming to this guidance and do comit fully in every respect to fulfilling the desires of the Commission in this matter. We have presently directed this in our night orders to our reactor operating personnel and are preparing a Plant Standing Order promulgating the Regulatory Commission's definitive guidance recently received concerning this matter.

As a part of the review conducted to fulfill this request for additional information, the FitzPatrick Plant Staff has identified an error in the original response to Bulletin 79-08 (JAFP 79-207), dated April 25, 1979.

The original response to Bulletin 79-08 indicated on Page 5, Sub-paragraph 5, that 'Two (2) instruments initiate containment spray permissive at 0" of water level decreasing." This statement is in error in that the containment spray permissive is actually initiated at equal to or greater than 0" of water level increasing.

Very truly yours, t,s . _,

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JDL:brp JOHN D. LEONARD, JR.

DISTRIBUTION: RESIDENT MANAGER G. T. Berry, PASNY, NYO G. A. Wilverding, PASNY, NY0 P. W. Lyon, PASNY, NY0 R. Rajaram, PASNY, NY0 M. C. Cosgrove, PASNY, JAF .

R. J. Pasternak, PASNY, JAF UD8Udb Boyce H. Grier, Director, Region I Document Control Center