ML19341B033

Responds to NRC 801001 Ltr Re Violations Noted in IE Insp Rept 50-333/80-17.Corrective Actions:Fire Doors Closed, Density Tests of Sealing Matl Performed & Stop Work Order Issued on Electrical Penetration Sealing Work

ML19341B033
Person / Time
Site:	FitzPatrick
Issue date:	10/28/1980
From:	Pasternak R POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19341B029	List: ML19341B033
References
JAFP-80-832, NUDOCS 8101300074
Download: ML19341B033 (4)

Text

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POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FsT2 patrick N UCLE A R POWER PLANT RAYMOND J. PASTERNAK Resideat t%aege, S P.O. 80X 41 Lycommg New York 13o93 315-342 3840 October 28, 1980 SERI AL: 'CP-80-832 Boyce H. Grier, Director United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

REFERENCE:

DOCKET NO. 50-333 ISE INSPECTION NO. 80-17

Dear Mr. Grier:

With reference to the inspection conducted by Mr. P. Koltay of your office on September 8 through 11, 1980 at the James A. Fit: Patrick 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 October 1, 1980 as received by the undersigned on October 8, 1980.

APPENDIX A NOTICE OF VIOLATION

Based on the results of an NRC inspection conducted on September 8-t 11, 1980 it appears that several of your activities were not conducted l in full compliance ;*ith conditions of your License No. DPR-59 as indicated i below. These ituas are infractions.

l INFRACTION A l.

l Technical Specification 3.12.F, paragraph a, states: The fire

! barrier penetration seals shall be functional for each protected l area...". Technical Specification 3.12F, paragraph 6, states:

l "Within one hour that any of the fire barrier penetration seals for j any protected area is found or made nonfunctional a continuous fire t watch shall be established on one side of the fire barrier."

Contrary to the above, the fire door between the East and West

! Cable Tunnel and the fire door between the West ' Cable Tunnel and Electric Fire Pump Room were found open and unattended on September l 9, 1980 without adequat3 meas'ures either established or implemented j to ensure that a fire watch was in effect.

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Boyce H. Grier, Director October 28, 1980 United States Nuclear Regulatory Commission JAFP-80-832

REFERENCE:

DOCKET NO. 50-333 ISE INSPECTION NO. 80-17 Page RESPONSE TO INFRACTION A The doors in question, which had beer opened for passage of material and personnel for modifications, were immediately closed. A ceneral meeting was held with the personnel involved in the innlementation of nodifications, including supervisors, in which the reasons for security and fire doors were reemphasized and the requirements for fire watches and/or security guards discussed. Sunervisory tours have been increased, with emphasis on security and fire doors. Uor fire doors, temporary signs were printed and installed, denoting fire doors and the required positions of those doors. These temporary signs will be replaced with permanent signs when available.

To prevent recurrence, continued emphasis will be placed in these areas in training and increased supervisory tours will be conducted during periods of numerous modifications or maintenance activities involving large numbers of personnel. These actions bring the Fit: Patrick Flant into full compliance.

.:NFRACTION B Technical Specification 6.8 states: " Written procedures...shall be established, implemented and maintained fer the Fire Protection Program." Licensee's Maintenance Procedure No. 57.5, " Procedure -

for Opening and Saaling Electrical Conduit Sleeves" Revision 5, June 23, 1980, paragraph 8.1, states: "In progress inspection will be conducted in accordance with Tech-Sil Quality Oratrol Manual (NP 12-0-101)...".

Tech-Sil Quality Control Manual NP 12-0-101, Section 210, paragraph 1.4, states: " Record dam approval on Form TS-QA-5C for each penetration filled (where dams are to remain in place) all penetrations above 4 inches."

Contrary to the above, not.all penetrations requiring permanent damming were inspected, and the inspected penetrations were not identified on Form TS-QA-5C.

RESPONSE TO INFRACTIdN B During the time period just prior to Inspection 80-17, the number '

of penetrations being sealed was increased to the point where QA personnel assigned could not perform a 100% inspection. The required density tests of sealing material was performed to verify both material specification conformance and . proper operation of the sealing' equipment.

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Boyce H. Grier, Dire' tor October 28, 1980 i United States Nue?' Regulatory Commission JAFP 80-832 l

REFERENCE:

D0t :f NO. 50-333 ISE INf*?CTION NO. 80-17 Page l l

Correctiv ction was taken by stopping the work and performing a j

100'. i. cction of the penetrations sealed during the time period i

of concern and no deficiencies were identified. This work stop was continued until the corrective action noted in the response to Infraction C below was completed.

To prevent recurrence, additional qualified inspection personnel were assigned to the task and penetrations are receiving 100% in-process inspection. This corrective action will c,ntinue in the future when penetrations are being sealed.

The assignment of additional inspection personnel, to provide 100*.

in-process inspection will be continued for the duration of work l

under modification F1-80-07 and these actions resulted in the Fit: Patrick Plant being in full compliance when work was resumed on Septembei 13, 1980.

INFRACTION C .

Technical Specification 6.8 states

" Written procedures . . . shall be established, implemented and maintained for the Fire Protection Program."

Licensee's Procedure No. 10.1.1, Procedure for Control of Maintenance,

Revision 2, July 1979, Section 7.2, states

"The Work Tracking Form...shall be issued...to properly... track, control and document corrective maintenance for Category 1, Safety Related or QC inspection required work."

The Licensee's Work Request Event Deficiency (WRED) No. 6979 issued May 20, 1980 identifies the Electrical Cable Penetration Modifica-tion FI-80-07A as Category 1, Safety Related and QC inspection required.

Contrary to the above, the licensee has conpleted electrical penetration sealing work through the secondary containment at elevation 272' and between the cable spreading room and the battery room, without issuing appropriate Work Tracking Forms.

RESPONSE TO INFRACTION C An immediate verbal and written stop work order was issued. This order directed' that open penetrations be sealed, no further penetrations be opened, and that existing Work Tracking Forms be closed out. It further directed that work in this area not be resumed until full compliance could be assured.

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Boyce H. Grier, Director October 28, 1980 United States Nuclear Regulatory Commission JAFP-80-832

REFERENCE:

DOCKET NO. 50-333 ISE INSPECTION NO. 80-17 Page -4 Additional training was eanducted for personnel involved in this work, emphasi:ing both t a technical and administrative aspects of the work. In addition to the copies of procedures previously issued, personnel pi;#ot~ing the modifications were individually given reference copies of the applicable procedures. Individual supervisors assigned this work .. counselled in the responsibilities for and rethods of job control. Further, the nurber of penetrations on which w ~rk is authorized is being limited to provide assurance-that the work is controlled and to specify on each Work Tracking Form those penetrations on which work is permitted.

Following these actions, work was commenced again on September 13, 1980. Since recommencement of vork, satisfactory work control has been observed resulting in full compliance.

Very truly yours,

/

sf; f/ .s Raymond J. Pasternak Resident Manager n

RJP:JRH:la DISTRIBUTION LIST:

George T. Berry, PASNY, NYO G. M. Nilverding, PAShT, NYO J. P. Bayne, PASNT, hTO R. Ram, PASNY, nTO M. C. Cosgrove, PAShT, jar R. Baker, PAShT, JAF M. N. Brosee, PASNY, JAF NRCI 80-17 File D. E. Tall, PASNT, JAF Resident Inspection, JAF

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