ML19290D962

Responds to NRC 791109 Ltr Re Violations Noted in Insp Rept 50-333/79-16.Corrective Actions:Special Procedures in Training Program Will Be Reviewed Twice Per Yr & Procedures for Control of Jumpers Will Be Revised

ML19290D962
Person / Time
Site:	FitzPatrick
Issue date:	12/01/1979
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
ML19290D959	List: ML19290D962
References
JAFP-79-668, NUDOCS 8002290568
Download: ML19290D962 (5)

Text

. .

POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FsT2 PATRICK NUCLEAR FCWER ?LANT JOHN D. LEONARD, JR.

Resident Manager S

December 1, 1979 P.O. BOX 41 Lycommg, New York 13093 3153E3840 JAFP 79-668 Boyce H. Grier, Director United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA. 19406

SUBJECT:

DOCKET N0. 50-333 NRC I&E INSPECTION NO. 79-16

Dear Mr. Grier:

With reference to the inspection conducted by Mr. C. Ccwgill of your office on September 18-21, 1979, at the James A. FitzPatrick Nuclear Power Plant, and in accordance with the provisions of Section 2.201 of Part II of Title 10 of the Code of Federal Regulations, we are submitting our response to Appendix A, Notice of_ Violation, transmitted by your letter dated November 9,1979, as received by the undersigned on November 12, 1979.

APPENDIX A NOTICE E VIOLATION Based on the results of an NRC inspection conducted September 18-21, 10 ',

it appears that certain of your activities were not conducted in full compliance with conditions of your NRC Facility License No. DPR-59, as indicated below. Items A, B and C are categorized as deficiencies A. 10 CFR 55, Appendix A, Section 3d, states the regulatory requirement for the licensed operator and senior operator review of emergency precedures on a regularly scheduled basis. This requirement is imple-mer ted by facility Indoctrination and Training Procedure (ITP) 5, Licensed Operator Requalification, Revision 3, dated August 28, 1978.

Saction 5.5.5, Individual Study of this procedure states in part:

" Reading assignments shall periodically be made for licensed personnel.. 4. Special Procedures (Emergency Procedures) including simulation whenever possible (Semi Annually)"

Contrary to the above, for the period June,1978 to January 1979, no such reading assignments were made.

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Boyce H. Grier, Director December 1, 1979 Uni'ted States Nuclear Regulatory Commission JAFP 79-668

SUBJECT:

NRC I&E INSPECTION NO. 79-16 Page RESPONSE TO DEFICIENCY A The FitzPatrick Plant staff acknowledges that the individual study assignments for Special Procedures were not made for licensed operator and senior operator personnel from June,1978 to January,1979. The personnel in question had just completed their initial licensing training in June and had ieceived their licenses in July 1979. Individual study assignments which include the Special Procedures have been made as prescribed for licensed operators and senior operators in the calendar year 1979. In addition, it should be noted that a significant portion of the Special Procedures were practiced by licensed operators and senior operators during simulator requalification training sessions during 1979.

An internal audit of the Special Procedure review program is being conducted to assure complete compliance in 1979.

Further, FitzPatrick Plant training practices will be revised such that Special Procedures will be reviewed by licensed operators and senior operators twice each retraining year through a combination of the following:

a) Walk-through training sessions in the plant and control room, identifying and discussing automatic actions which are expected to occur and identification of the controls and indications which are required to be operated or observed, b) When simulation permits, practice with Special Procedures during simulator requalification training :;essions, and c) Informal sessions as well as fonnal classroom discussions including timely discussion of revisions which change the scope or intent of the Special Procedures, d) Individual study assignments.

These activities will be scheduled such that a complete review of Special Procedures will be performed during each half of the requalification year and a program for documentation and audit of the review of these procedures will be implemented to insure compliance.

It is expected full compliance will be achieved by January, 1980.

B. Technical Specification 6.8.A states in part, " Written procedures and adninistrative policies shall be established, implemented and maintained Work Activity Control Procedure 10.1.3, Placement of Jumpers, Blocks or Lifted Leads, Revision 1, dated June 13, 1979, Section 6.3.1, states in part: " Jumpers shall be numbered and maintained in the control room.

Jumpers missing from the inventory shall be accounted for by an entry in the Jumper Log...Section 7.2. When the jumper is placed entries shall be made... in the control room log that the jumper has been installed with a brief description of the circumstances and effects. Section 7.3.2. After restoration ... entries shall also be made in the control room log."

Boyce H. Grier, Director December 1, 1979 Uni'ted States Nuclear Regulatory Commission JAFP 79-668

SUBJECT:

NRC I&E INSPECTION NO. 79-16 Page Contrary to the above, on September 19, 1979, the following jumper and lifted lead log entries did not comply with one or more of the above re-quirements: log numbers78-204, 78-205,79-180, 79-181,79-182, 79-183, and 79-184.

RESPONSE TO DEFICIENCY B The FitzPatrick Plant staff acknowledges that all the prescribed log entries associated with jumper log pages79-181 through 79-184 were not completed.

However, it should be noted that each of these instances were the result of the application of electrical jumpers for very short time periods for testing within a single shift and controlled by the test procedure, thus there was no possibility that important information relating to the condition of plant systems was not properly passed on from one Gift to another.

As noted in the inspection report, inventory and investigation was commenced imediately when the deficiency was identified. This investigation yielded the following results:

a) Part of the inspector's review of the jumper and lifted lead control system was based on a jumper inventory log book which has not been used since Work Activity Control Procedure 10.1.3 was revised on 13 June 1979. Since this log book had not been used for some time, any inventory of jumpers based on that log would be in error. The inventory conducted by the plant staff was conducted by comparing the jumpers in use as determined from the jumper log against those jumpers contained in the cabinet.

b) The inventory noted in a) above revealed that with one exception, jumpers were either in the cabinet or the location was as specified on the jumper log pages.

c) The inventory noted in a) above did not reveal the location of the jumper listed on jumper log page 182. A thorough review of records and inspection of terminal boards, junction boxes, relays and similiar locations where an electrical jumper might be utilized, was conducted and the location of the jumper not discoverd. It is believed that the missing jumper was found damaged or became contaminated and was discarded without being used.

d) With respect to jumper log page 79-180, a complete review of the log and contrei room logs did not confirm the existence of any deficiency.

e) With respect to jumper log pages 204 and 205, th9e jumpers are actually temporary instrument tubing which is 'a use until a plant modification can be completely implemented. As such, these instrument tubing jumpers were not identified with the usual " wire markers" that are attached to each of the electrical jumpers for identification purposes.

The FitzPatrick Plant staff has recognized for some time that the procedures utilized in the control of jumpers tends to be cumbersome and as such can

Boyce H. Grier, Director December 1, 1979 United States Nuclear Regulatory Commission JAFP 79-668

SUBJECT:

NRC I&E INSPECTION f40. 79-16 Page provide the opportunity for deficiencies of the type noted by the inspector.

In view of this, the FitzPatrick Plant has, since the completion of the subject inspection, conducted a survey of other licensees in an effort to determine other practicable and acceptable methods of controlling jumpers.

As a result of this survey, we currently have under consideration, several possible changes which we believe will significantly reduce the possibility of recurring non-compliances in this area.

Notwithstanding these actions, this item of non-compliance has been discussed wi.h the personnel utilizing jumpers and responsible for the proper adminis-trative control of the jumpers and we believe we are now in full compliance.

C. Technical Specification 6.8.A states, in part, " Written procedures and administrative policies shall be established, implemented, and maintained Administrative Procedure 4.2, Control of Measuring and Test Equipment, paragraph 6.3 states, in part, "Each test instrument or tool shall have some form of a log ... showing when and where (ex. component, WR number, etc.) the instrument or tool was used ..."

Contrary to the above, as of September 21, 1979, the particular torque wrenches used in the performance of four separate Work Requests (WR) were not identified on the appropriate WR, or by a log entry, thereby preventing traceability to the maintenance activities for which the wrenches were used.

RESPONSE TO DEFICIENCY C.

The FitzPatrick Plant staff acknowledges the deficiency in documentation such that verification showing the use of a calibrated torque wrench for certain work could not be established. To correct this deficiency and to preclude recurrence, the applicable FitzPatrick procedures will be revised to require the calibration of a torque wrench just prior to, and following, use of the tool for tasks which require the use of calibrated equipment. In order to accomplish this corrective action, the FitzPatrick Plant is currently constructing a storage and calibration facility for equipment of this type.

In addition, personnel using mechanical measuring and test equipment such as torque wrenches have been made aware of this item of non-compliance and the requirements to properly document the equipment used, has been discussed.

Purchase and construction of the equipment associated with the storage and calibration facility is currently in progress.

We therefore expect to be in full compliance by January 31, 1980.

Very truly yours, w A_ v' /

JDL:VC:brp b X E C{.'~D d2 & w '

JOHN D. LEONARD, ,JR.

.~ _ RESIDENT MANAGER f

DISTRIBUTION LIST:

George T. Berry, President and Chief Operating Officer P. W. Lyon, Manager-Nuclear Operations A. Klausmann, Director, Quality Assurance M. C. Cosgrove, Quality Assurance Site Engineer J. F. Davis, Chairman, Safety Review Committee V. J. Cassan, Assistant General Counsel G. A. Wilverding, Licensing Supervisor D. E. Tall, Training Coordinator R. J. Converse, Operations Superinter. dent R. Baker, Maintenance Superintendent O