ML19322A201
| ML19322A201 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/20/1978 |
| 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 | |
| ML19322A199 | List: |
| References | |
| 781201, NUDOCS 7901040247 | |
| Download: ML19322A201 (4) | |
Text
/^'s POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FIT 2 PATRICK NUCLEAR POWER PLANT S
JOHN o. LEONARD, JR.
P.O. BOX 41 R:sedent Manager Lycoming, New York 13093 ais 342 384o December 1, 1978 JAFP-78-630 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. 78-19
Dear Mr. Grier:
Wi th reference to the inspection conducted by Mr. T. Stetka of your office on September 19-22, 1978, 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 are sub-mitting our reply to items A, B and C of Appendix A of the Notice of Violation transmitted by your letter dated November 8, 1978 and received by the Undersigned on November 13, 1978.
APPENDIX A NOTICE OF VIOLATION Based on the results of the NRC inspection conducted on September 19-22, 1978, 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 and B are Infractions.
Item C is a De-ficiency.
A.
Technical Specification 6.11 (A) 1 states in part:
"In lieu of the
' control device' or ' alarm signal' required by paragraph 20.203 (c)
(2) of 10 CFR 20, each High Radiation Area (i.e., > 100 mrem /hr) in which the intensity of radiation is 1000 mrem /hr o7 less shall be barricaded and conspicuously posted as a high radiation area..."
Co trary to the above, on September 19, 1978, the East and West Crescent Rooms which had general area radiation levels of 450 mrm/hr and 250 mrem /hr, respectively, were not barricaded and posted as High Radiation Areas.
holoVo777
Mr.'Bsyca H. Grior, Dircctor D:ctmber 1, 1978 United States Nuclear Regulatory Commission JAFP-78-630
Reference:
Docket No. 50-333 IE inspection No. 78-19 Page REPLY TO INFRACTION A
.A temporary High Radiation Area was created when a RHR system relief valve lif ted and blew contamination on to the floor in the Crescent area resulting in radiation levels of up to 250 mrem /hr at waist level due to this. contamination. In order to clean up the resultant contamination, a decontamination crew was working in the area at the time the inspector observed the open door. The door was open to facilitate movement of cleaning equipment in and out of the area.
The clean up ef fort was being performed under a radiation work permit (RWP) No. 5993(S).
The door.In question was posted on the 20th of September, 1978 (after the decon ef fort was completed) as a High Radiation Area even though dose rates were at that time 25 to 30 mrem /hr in the area.
This area will continue to be posted as a High Radiation area as a precaution because of potential increases in dose rate in the area.
Spring clos-ures were installed on the door to ensure that it is closed to provide a barricade.
The relief valve will be repaired te prevent this type of contamination in the future.
The radiation protection technicians were reinstructed that whenever they find an area where the whole body dose is greater than 100 mrem /hr, they properly barricade and post the area even though the area is only a temporary High Radiation area.
B.
Technical Specification 3 5.C.I.a states: "from and after the date that the HPCI System is made or found to be inoperable for any reason, continued reactor operation is permissible only during the succeeding 7 days unless such system is sooner made operable, provided that during such 7 days all active components of the Automatic Depressurization System, the Core Spray System, LPCI System, and Reactor Core Isolation Cooling System are operable."
Technical Specification 4.5.C.I.a states: "When it is determined that the HPCI subsystem is inoperable the RCIC, the LPCI subsystem, both core spray subsystems, and the ADS subsystem actuation logic shall be demonstrated to be operable immediately.
The RCIC system and ADS subsystem logic shall be demonstrated to be operable daily thereafter."
Contrary to the above, on August 6, 1978, when the High Pressure Coolant injection (HPCI) system became inoperable due to a failed suction valve, the system was not delcared inoperable and the required operability demonstrations of the other core cooling systems were not performed.
REPLY TO INFRACTION B A review of the HPCI system and Technical Specification Appendix A,
O.
M.- Bioyca H. Grier, Director December 1, 1978
, United States Nuclear Regulatory Commission JAFP-78-630
Reference:
Docket No. 50-333 IE Inspection No. 78-19 Page.
I'
. Paragraphs 3.5.C and 4.5.C by the plant staff does not confirm the inspector's judgement that the HPCI system was Inoperable for the approximate 36~ hour period in which its normally closed pressure suppress-
-lon pool suction valve was not capable of automatic operation.
Through-
~
out the indicated time period the normally open suction for the pump was 4
l --
available from the ' condensate storage tanks which contain a reserve of at least 100,000 gallons. Operations personnel had been instructed to manually shift the pump suction to the pressure suppression pool in the event operation of the system was required (as confirmed by our review of the Night Orders). - Since the capacity of the HPCI system is 4250 gpm at rated conditions, the 100,000 gallon reserve in condensate storage tanks would have allowed more than 24 minutes to accomplish such a task.
In_ addition, a review of the FSAR sections dealing with accident analysis
=and ECCS systems indicates that for a wide spectrum of-line breaks or other postulated events, the HPCI. system would not require shif t of its suction from condensate storage to the pressure suppression pool before i
operation of the system is automatically terminated by low steam line pressure at.150 psig.
In the case of small line breaks, the reactor l
pressure (and thus HPCI steam line pressure) decreases to less than 150 psig well before the system can pump 100,000 gallon to the reactor.
For larger breaks, the reactor pressure decrease is even more rapid and again results in isolation of the system on low steam line pressure.
In view of the fact that the HPCI system could inject its rated capacity into the-reactor vessel utilizing its normally open suction valve and for the~ associated reasons stated above, we feel that the HPCI system was not inoperable and respectfully ' request that this infraction be reviewed by your staff.
C.
Technical Specification 6.9-(A) 4.1 states in part:
"The types of events listed below shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone 1
and confirmed by telegraph, mallgram, or facsimile transmission to I
the' Director of the Regional Office, or his designate no later than the first working day following the event, with a written followup report within two weeks." One of the events listed in Technical Specification 6.9 (A) 4.1 is:
" Errors discovered in the transient l
~
or accident analyses or in the methods used for such analyses as described in the safety analysis report or in the bases for the i
technical specifications that have or could have permitted reactor i
operation in a manner-less conservative than assumed in the analyses."
Contrary to.the above, on August 19, 1978, a telephone call reporting an event concerning errors discovered in the safety analysis was i
not confirmed by'a telegraph, mailgram, or facsimile transmission.-
r REPLY TO DEFICIENCY C This; deficiency 'is~ solely the responsibility of the Resident Manager and is accepted.asJsuch.
The telephone call in question, made-on a Saturday
-morning to the principal Reactor Inspector at his home,- was to inform the i
.~,
r l
- Mr. Boyce H. Grier,- Director Cecember 1, 1978 f
United States Nuc' lear Regulatory Commission JAFP-78-630 1
Reference:
Docket No. 50-333 IE Inspection No. 78-19 Page inspector of a discussion occurring between the office of Nuclear Reactor Regulations in Washington and the General Manager of the Power Authority wherein the Power Authority stated that power would be main-tained at 80% of rated power until an analysis could be performed on the multiple actuation of several safety / relief valves.
At that time, no definitive analytical information existed to determine whether this multiple actuation was in fact a problem. When the analysis was com-pleted and the problem and its corrective action identified, a Licensee Event Report (LER-78-069) was sent to officially inform the Headquarters Region 1 Inspection and Enforcement Division of the situation.
Very truly yours,
. /'
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R R.
CC:
G. T. Berry RES'lDENT MANAGER P. W. Lyon j
R. Rajaram G. Wilverding E. Kelly J. F. Davis R. J. Pasternak H. C. Fish, Jr.
R. A. Burns S. Wells Document Control Center
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