ML19344E761
| ML19344E761 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/07/1980 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Pasternak R POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML19344E762 | List: |
| References | |
| NUDOCS 8009110257 | |
| Download: ML19344E761 (2) | |
See also: IR 05000333/1980005
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION I
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631 PARK AVENUE
KING OF PRu$$1 A PENNSYLVANI A 19406
306
7.1980
Docket No. 50-333
,
Power Authority of the State of. NeNYork
James A. F1tzPatrick Nuclear Power Plant
ATTN: Mr. R. J. Pasternak
Resident Manager
P. O. Box 41
Lycoming, New York 13093
Gentlemen:
Subject:
Inspection 50-333/80-05
This refers to your letter dated June 7,1980, in response to our letter dated
May 16, 1980.
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The following confirms a telephone conversation conducted on June 25, 1980
between Mr. N. Blumberg of this office and Mr. V. Childs and Mr. H. Keith of
your staff which further clarifies certain items in your response letter:
1.
The calibration procedure for RCIC Pump Minimum Flow Valve Control Switch,
13-FS-57 will remain in procedure F-1MP-13.3. However, procedure F-lMP-
13.3 is currently being revised to clarify that the calibration will be
accomplished only if required as a result of maintenance on the switch.
2.
The calibration for RCIC Flow Controller,13-FIC-91, currently in procedure
F-lMP-13.3, will be deleted from the procedure as calibration adjustments
cannot be made to this flow controller.
3.
The comitment date of June 30, 1981 to ensure that all Instrument Sur-
veillance Procedures will be revised to include a verification /signoff for
the recording of the test and measuring instruments used during performance
of the procedures and to review and revise, as necessary, previously un-
reviewed Instrument Maintenance Procedures,is a firm date from which no
slippage is expected.
Should our understanding of your commitments as described above be in error,
please contact us by telephone and in writing within 20 days of receipt of this
letter.
Thank you for informing us of the corrective and preventive actions documented
in your letter.
These actions will be examined during a subsequent inspection
of your licensed program.
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8009110257
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Power Authority of the State
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AU6
7 1980
of New York
Your cooperation with us is appreciated.
Sincerely,
[SLpC '/ ' ' ^^a*; /
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Boyce H. Grier
Director
cc:
George T. Berry, President and Chief Operating Officer
P.-W. Lyon, Senior Vice President-Nuclear Generation
A. Klausmann, Director, Quality Assurance
M. C. Cosgrove, Quality Assurance Supervisor
J. F. Davis, Chairman, Safety Review Committee
C. M. Pratt, Assistant General Counsel
G. M. Wilverding, Licensing Supervisor
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POWER AUTHORITY OF THE STATE OF NEW YORK
JAMES A. FITzPATRICK N UCLE AR power PLANT
S
RAYMOND J. PAsTERNAK
P.O. box 41
Resident Manager
Lycoming, New York 13C93
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315-342-3840
June 7, 1980
SERIAL:JAFP 80-482
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Boyce H. Grier, Director
United States Nuclear Regulatory Commission
Region I
631 Park Avenue
King of Prussia, PA.
19406
REFERENCE:
DOCKET N0. 50-333
I&E INSPECTION N0. 80-05
Dear Mr. Grier:
With reference to the inspection conducted by Mr. N. Blumberg
of your office on April 7 through 11, 1980 at the James A. FitzPatrick
Nuclear Power Plant , and subsequent discussions between Mr. Blumberg
and members of the FitzPatrick Plant staff on April l'7,1980, 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
May 16, 1Y80 as rece'ived by the undersigned on May 19, 1980.
APPENDIX A
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Based on the results of an NRC inspection conducted April 7 through April 11,
1980, it appears that certain of your activities were not conducted in full
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compliance with conditions of your NRC Facility License No. DPR-59 as indicated
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below.
Item A is an infraction and items B and C are deficiencies.
A.
Technical Specification 6.8(A) states in part, " Written Procedures and
administrative policies shall be established, implemented and maintained
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that meet or exceed the requirements and recommendations of Section 5
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" Facility Administrative Policies and Procedures" of ANSI N18.7-1972..."
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Boyce H. Grier, Director
June 7, 1980
United States Nuclear Regulatory Comission
REFERENCE:
DOCKET N0. 50-333
I&E INSPECTION NO. 80-05
Page -2-
ANSI N18.7-1972 paragraph 5.3.6 states in part, " Procedures shall
be provided for periodic calibration and testing of safety related
plant instrumentation..."
Contrary to the above, it appears that your program for establishment
and implementation of calibration procedures has not been adequately
implemented in that:
The procedure established for calibration of Peactor Core
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Isolation Cooling System instrumentation, idMP-13.3, "RCIC Flow
Indication", was not followed for calibratian of RCIC flow
indication instrumentation; and further th1
procedure is inadequate
in that during a review of 1977 and 1978 date the following was
observed:
(1) Applied input pressures to flow transmitter 13-FT-58 on the
data sheets do not correspond to that established by the
procedure.
In addition, the input pressures between data
sheets did not correspond.
(2) The procedure establishes a calibration for RCIC pump discharge
flow switch, 13-FS-57; however, no data was available to docu-
ment that this switch had ever been calibrated.
(3)
1977 and 1978 data sheets show a calibration for flow indicator,
13F1-91-1; however, there is no calibration procedure established
for this instrument.
The procedure established f or calibration of Jet Pump Flow, F-IMP-2-3.1,
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" Reactor Vessel Instumentation - Jet Pump Flow Loop", was not followed
for calibration of jet pump flow instrumertation and further this
procedure is inadequate in that during a review of 1977 and 1978 data
it was observed that applied input pressure and expected output current
for flow transmitter, 02-3-FT-64 and square rooter, 02-3-SQRT-74, were
different than that established by the procedure.
The Control Rod Drive accumulator pressure and level alarms are
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neither functically tested nor calibrated; nor, is there any procedure
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established for testing these alarms.
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No procedures have been established for the calibration of the contain-
ment leak rate monitor or for the cali* ration of Standby Liquid Con-
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trol System pressure indicator, 11-PI-53, which is used to verify the
testing of Standby Liquid Control System relief valve testing.
However,
in each instance, it was observed that these instruments are being
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calibrated.
B.
Technical Specification 6.8(A) states in part, " Written procedures and
administrative policies shall be established, implemented, and maintained..."
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Boyce H. Grier, Director
June 7, 1980
United States Nuclear Regulatory Commission
REFERENCE:
DOCKET NO. 50-333
I&E INSPECTION N0. 80-05
Page -3-
Procedure No. 4.1, " Procedure for Department Surveillance Tests",
paragraph 7.0 states in part:
"As a minimum each surveillance test
shall include... sign-off notification insuring department review and
evaluations of the test results".
Procedure No. 1.4, " Control of Plant Procedures", paragraph 7.3 states
in part, " Revisions to procedures shall receive the same review and
approval as the original... Revisions will also include a completed
approval cover sheet listing the effective pages and revisions".
Procedure No. 4.2, " Control of Measuring and Test Equipment", paragraph
6.4 states in part:
"Each test and measuring instrument...shall have
some form of a log. . . showing when and where. . .the instrument. . .was used
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and initials of the user".
Contrary to the above, it was coserved that:
Supervisory review of completed data for F-ISP-85, " Control Room
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Ventilation Temperature and Differential Pressure Instrument
Calibration", was inadequate in that two of five data points for
two control temperature instruments, TIC-105 and TIC-107, were out
of tolerance to the requirements of the procedure; but, test results
were signed off as acceptable during supervisory review.
In addition,
during performance of F-ST-6A, " Standby Liquid Control Pump Functional
Test (ISI)", the Standby Liquid Control Pump Flow was calculated as
50.88 gpm rather than 52.8 gpm as would be indicated by the data.
This error was not observed during supervisory review. The miscalcu-
lated data, although in error, was well above Technical Specification
requirements.
Instrument surveillance procedure cover sheets do not list the
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effective pages and latest revisions of sign-off and data sheets
which are associated with and integral to each procedure.
Test gage No. 2003 which was used for F-ISP-46, " Main Steam Line High
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Flow Instrument Functional Test / Calibration" performed on March 28,
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1980 was not entered in the Instrument and Control Department traceability
log for that instrument; and digital thermometer No. 01 which was used
for F-ISP-82-1, " Standby Liquid Control System Temperature Instrument
Calibration" performed on October 12,-1979 was not entered on the
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Instrument and Control Department traceability log for that instrument.
C.
Technical specification 6.8(A) states in part:
" Written procedures and
administrative policies shall be established, implemented and maintained..."
Procedure 1.4, " Control of Plant Procedures", Paragraph 7.2.4 states in
part:
" Procedures concerned with nuclear... safety shall be reviewed at
approximately two year intervals (not to exceed 21/2 years) by the depart-
cent superintendent or designee.
Review of procedures which have been
revised within the two year period may be deferred and the review accom-
plished approximately two years af ter the last revision..."
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Boyce H. Grier, Director
June 7, 1980
United States Nuclear Regulatory Commission
REFERENCE:
DOCKET NO. 50-333
I&E INSPECTION NO. 80-05
Page -4-
Contrary to the above, one hundred and thirty-one of one hundred
and sixty instrument and control maintenance procedures have not
been reviewed or revised within the last two and one half years.
RESPONSE TO ITEM A (INFRACTION)
The FitzPatrick Plant staff has conducted a review of the requirements of
Administrative Procedure 4.4 and Instrument Maintenance Procedure F-IMP-13.3.
As a result of this review and a review of the subject inspection, the staff
has, or will take the actions listed below to avoid further items of non-
compliance and achieve full compliance by the dates indicated.
1)
The staff concurs that improper test inputs were used in the calibration
of 13-FT-58.
An evaluation of the effect of these improper inputs
indicates that the resulting calioration yielded conservative RCIC
System flow rates with respect to the Technical Specifications.
To
assure that the requirements of AP 4.4 are adhered to, a training session
for certain med
' " the plant staff and technical personnel 4111 be
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conducted by /
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2)
A review of the circumstances associated with RCIC System flow switch
13-FS-57 indicates that no calibration is required by Technical Specifica-
tions or within the balance of plant instrument calibration program.
Flow
switch 13-FS-57 controls the RCIC pump minimum flow valve. This valve
is not required to open in crder for the RCIC system to perform its
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intended function.
In addition, the flow switch is functionally
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tested by the Operations Department when operations surveillance test
F-ST-24C, titled "RCIC Flow Rate Test (ISI)" is performed. Any mal-
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function of the minimum flow valve during the conduct of F-ST-24C due to
switch failure or malfunction would be noted and corrective action initiated
in accordance with established administrative controls.
No additional action
is required.
3)
With respect to the absence of a calibration procedure for 13-FI-91-1,
investigation has revealed that instrument maintenance procedure F-IMP-13.3
contains a typographical error. The typographical error lists instrument
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13-FIC-91-1.
When consideration is given to the existence of the typo-
graphical error, calibration procedures for 13-FI-91-1 do in fact exist.
As corrective action, F-IMP-13.3 will be revised and submitted to the Plant
Operations Review Committee for approval by June 30,.1980. This action
will bring the FitzPatrick Plant into full compliance in this area.
The plant staff has conducted a review of instrument maintenance procedure
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F-IMP-2-3.1 titled, " Reactor Vessel Instrumentation - Jet Pump Flow Loop" and
the associated 1977 and 1978 calibration data sheets. As a result of this
review, the plant staff concurs that the applied input pressure and expected
output current for the instruments referred to in the infraction above were
different than those established by the procedure.
It is the conclusion of
the plant staff that personnel performing the maintenance did not adhere to
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Boyce H. Grier, Director
June 7, 1980
United States Nuclear Regulatory Commission
REFERENCE:
DOCKET N0. 50-333
I&E INSPECTION N0. 80-05
Page -5-
the requirements of AP 1.4.
Accordingly, a training session for certain
members of the plant staff and technical personnel will be conducted by
June 30, 1980 to achieve full compliance in this area.
In addition, F-IMP-2-3.1
has been revised to reflect the correct input and output values. This
action was completed and reviewed by the Plant Operations Review Committee
at Meeting No.80-035 on May 29,1980.
The plant staff concurs that control rod drive accumulator pressure and level
alarms have not been formally functionally tested or calibrated in the past.
To correct this area of non-compliance, instrument maintenance procedure,
F-IMP-5.2 titled " Control Rod Drive System Hydraulic Control Unit" has been
revised and was reviewed by the Plant Operations Review Committee at Meeting
No.80-032 on May 22, 1980.
Functional test and calibration of the accumulator
pressure and level alarm switches will be completed by December 31, 1980.
This action will result in full compliance in this area.
The plant staff concurs that no procedures were established for the
calibration of the instrumentation which measures nitrogen makeup to the
primary containment for the purpose of detecting gross leakage of .the contain-
ment or for the calibration of instrument 11-PI-53 which is used during the
conduct of standby liquid control system relief valve testing. Accordingly,
the plant staff implemented instrument maintenance Procedure F-IMP-27.5 titled,
" Nitrogen Instrument Header Flow Ir.drument Calibration" and revised F-IMP-11.1
titled, " Standby Liquid Control Systam." These procedures were reviewed by
the Plant Operations Review Committee at Meeting No.80-032 on May 22,1980
and at Meeting No.80-022 on April 23, 1980, respectively.
As a result of this
action, the FitzPatrick Plant b411 eves it is in full compliance in this area.
RESPONSE TO ITEM B. - DEFICIENCY
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The FitzPatrick Plant staff has completed a review of the above deficiency
and Administrative Procedures 1.4, 4.1 and 4.2 and concurs with the findings
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of the inspector. As a result of these reviews, action has been taken or will
be taken as indicated below.
1)
The FitzPatrick plant will, by issue of a memorandum or Standing Order
and a training session directed to the staff personnel responsible for
the review of surveillance and similar data, reinforce the importance
of adhering to the requirements of the established administrative controls.
Informal discussions with the staff personnel responsible for data review
has been completed.
However, a more formal training session will be
completed by June 30, 1980.
This action will bring the FitzPatrick Plant
into full compliance in this area.
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2)
Instrument surveillance procedures will be revised to include the sign-off
and data sheet pages as a part of the procedure in such a manner as to
clearly indicate that a particular data sheet is the proper sheet for a
particular procedure issue (revision).
This action will be completed by
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June 30, 1981.
In the interim time period, the FitzPatrick Plant has
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Boyce H. Grier, Director
June 7, 1980
United States Nuclear Regulatory Commission
REFERENCE:
DOCKET NO. 50-333
I&E INSPECTION N0. 80-05
Page -6-
implemented an informal policy whereby prior to the conduct of
instrument surveillance, the data sheet is verified to accurately
reflect the content of the procedure to be performed. This informal
policy will be formalized in the form of a memorandum or Standing
Order in which data sheets will be marked to indicate the procedure
number and revision such that positive identification is provided.
This interim action will assure that each data sheet accurately
reflects the associated procedure that was used for conduct of the
test.
By combination of this interim action and the revision of the
instrument surveillance procedures, the FitzPatrick Plant will be
in full compliance in this area by June 30, 1980.
3)
Instrument surveillance procedures will also be revised to include
a verification / sign-off requirement for the recording of the test
and measuring instruments used during the performance of instrument
surveillance procedures.
Revision of the procedures will be completed
June 30, 1981.
In the interim time period, by issue of a memorandum
or Standing Order, and a training session which will be completed by
June 30, 1980,
the requirements of AP 4.2 will be reinforced for those
staff and technical personnel involved. The completion of this action
will bring the FitzPatrick Plant into full compliance in this area.
ITEM C. - DEFICIENCY
The FitzPatrick Plant staff has reviewed the deficiency above and as noted
in the response to Item B s ove, completed a review of Administrative
Procedure 1.4 and concurs with the inspector's findings.
In order to bring the FitzPatrick Plant into full compliance with respect
to the required two year review of instrument maintenance procedures, the
plant staff will review and revise as necessary, all instrument maintenance
procedures such that by June 30, 1981, each procedure has been reviewed
within the time interval specified in AP 1.4.
In he interim time period, for
any instrument maintenance procedure which has not been reviewed within the
time period specified by AP 1.4, each procedure will be reviewed prior to use
for acceptability and that review (and revision, if required) will be documented.
This action will assure compliance for any instrument maintenance procedure
which is used and will result in full compliance by June 30, 1981.
Very truly yours,
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ftE<
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AW
RJP:VC:brp
RAYMOND J. PASTERNAK
Attachment: Distribution List
RESIDENT MANAGER
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Boyce H.'Grier, Director
June 7, 1980
United States Nuclear Regulatory Commission
REFERENCE:
DOCKET NO. 50-333
I&E INSPECTION NO. 80-05
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DISTRIBUTION LIST:
George T. Berry, PASNY, NY0
G. M. Wilverding, PASNY, NY0
J. P. Bayne, PASNY, NY0
M. C. Cosgrove, PASNY, JAF
R. Baker, PASNY, JAF
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H. N. Keith, PASNY, JAF
NRCI 80-05 File
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D. E. Tall, PASNY, JAF
Document Control Center
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