ML20012A020

Forwards Response to NRC SALP Initial Rept 50-333/88-99 for May 1988 - Sept 1989.Emergency Operating Procedures Being Upgraded to Rev 4 of Emergency Procedures Guidelines & Will Be in Place Upon Startup from Spring Refueling Outage

ML20012A020
Person / Time
Site:	FitzPatrick
Issue date:	02/28/1990
From:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JNP-90-019, JNP-90-19, NUDOCS 9003080137
Download: ML20012A020 (8)

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{ John C. Brons Executive Vice President

( Nuclear Generation February 28, 1990 JPN-90-019- 1

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a U. S. Nuclear Regulatory Commission Mail Station P1 137 - .

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' ATTN: Document Control Desk  ;

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Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Response to NRC Systematic Assessment of Licensee Performance (SALP) Initial Report 50-333/88-99

Reference:

1. . NRC letter, W. T. Russell to J. P. Bayne, regarding Systematic Assessment of Ucensee Performance (SALP) Initial Report No. 50-333/88-99, dated January 11,1990.

Dear Sir:

Reference 1 issued the Nuclear Regulatory Commission (NRC) Systematic Assessment 1 of Ucensee Performance report for the FitzPatrick plant. A meeting to discuss this assessment was held in the NRC Region I offices on January 29,1990.

The Authority agrees with the overall functional area ratings, and be'ieves that the.

Information exchanged during the SALP meeting was beneficial for both parties.

- Attachment I to this letter'provides comments on each of the functional areas evaluated in the SALP report. These comments reflect many'of the issues discussed during the=

meeting and are provided to ensure a more accurate assessment of the functional areas, y The Authority appreciates the opportunity afforded by the SALP process for improved L - understanding of the NRC issues as they relate to the FitzPatrick plant. The SALP report

!i has been reviewed carefully, and the observations are being used, as appropriate, to improve plant operation and support.

Should you or your staff have any questions regarding this matter, please contact l Ms. Sofia M. Toth of my staff.

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Very truly yours,

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o'hn C. Brons l ecutive Vice President Nuclear Generation cc: See Next Page i

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. cc: U. S. Nuclear Regulatory Commission 475 Allendale Road y-King of Prussia, PA 19406 L

' Office of the Resident inspector U.S. Nuclear Regulatory Commission 4 P.O. Box 136 Lycoming, NY13093 Mr. David E. LaBarge Project Directorate 11 ,

Div slon of Reactor Projects l/ll U. S. Nuclear Regulatory Commission Mall Stop 14 B2 Washington, DC 20555  !

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' ATTACHMENT I 5

RESPONSE TO NRC SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PERIOD MAY 1,1988 TO SEPTEMBER 30,1989 f

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New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLA'NT >

Docket No. 50-333 DPR-59

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w ),, I g , Attachment I New York Power Authority JAMES A. FIT 2 PATRICK NUCLEAR POWER Pl. ANT.

g RESPONSE TO NRC  ;

L SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE  :

b PERIOD MAY 1,1988 TO SEPTEMBER 30,1989 A. Operations 1 1

in this SALP evaluation period, the NRC rated the functional area of operations as Category 1.

The NRC evaluation noted the commendable operating record and the effective use of the plant specific simulator for improving operator capabilities and upgrading operating procedures.

The subject report states on page 5 that the quality assurance (OA) department was not involved in the development or maintenance of the EOPs (Emergency Operating Procedures).

This statement is in error. The OA department was intimately involved with the verification and -

validation activities of the EOP process. The NRC inspection team did not review the process or documentation by which the FitzPatrick plant took the generic owner's group emergency guidelino, generated the plant specific guideline and created the plant specific EOPs. The issue of OA involvement was not discussed in the EOP inspection; consequently, an earlier clarification was not provided. <

The Authority is continuing efforts to improve plant operations. The EOPs are being upgraded-to revision 4 of the Emergency Proceduro Guidelines and will be in place upon startup from the spring refueling outage. The control room human performance improvement program will also bo

completod during the upcoming refueling outage. In addition, all facets of professionalism continue to be stressed including new initiatives in the operations procedural program.

-B. Radiological Controls This functional area received a rating of Category 2 in the SALP report. The repon noted that the Radiation Control Program was generally well defined and programmatic improvements were noted. The report noted effect.tvo programs in ALARA (As Low As Reasonably Achievable),

contamination control and environmental and offluent monitoring. In addition, the report cited the aggressive dose reduction initiatives to reduce the collective exposure over the life of the facility.

-The report does contain certain statements that the Authority has comments on:

1) On page seven (7), the fourth paragraph states, "Correctivo actions for NYPA's k

T quality assurance (OA) findings in the area of contractor personnel oversight and control did not always resolve the finding." During the SALP meeting, the Authority l-questioned the basis of this statement to enable a bottor understanding of the issue. Clarification was not provided by the NRC.

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RESPONSE TO NRC SALP 4 Page 2 of 5

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" ' 2) The sixth paragraph on page seven (7) utilized the wording " continued lack of sensitivity" on the control of non routine radiologically significant tasks. The Authority disagrees with this wording. As discussed at the SALP meeting, this v choice of wording implies that an apathetic attitude existed. The NRC agrees that-this was not the case. Perhaps better wording would be, "... Indicated a continued insufficient control of...".

3) On page 8, the first paragraph implies that no department management overcight occurred for over 2 months. As delineated in the original inspection report, even though no documented reviews occurred as specified by plant procedures, supervisors were frequently on the refuel floor as evidenced by logs and radiation work permits.

4) Once again on page 9, paragraph 4, the words " lack of sensitivity" were used to describe a problem with evaluation of the- solidification of non-routine waste i streams. As discussed in the SALP meeting, the NRC did not mean what is L implied with this wording.

Overall, the Authority believes that significant improvements were made in specific areas but agrees that certain non-routine evolutions, such as refuel floor work, resulted in preventable

- problems. A high level of emphasis continues to be placed on improving the overall performance

.of radiological practices at the FitzPatrick plant. ALARA and contamination control goals remain ,

aggressive. Although the SALP period did not cover all of calendar 1989, the Authority notes that significant improvements were achieved in person-rom, contamination events and radwaste.

Changes are being implemented which will provide better control of contractors and more officient use of the permanent, highly experienced Authority personnel.

C. Maintenance and Surveillance in rating the functional area of maintenance and surveillance as Category 2, the report noted

l. the improved preventive maintenance and planning programs and the thorough and timely L reviews conducted for equipment failures.

The report stated that the surveillance program is adequate; however, numerous problems were identified in test acceptance criteria. In addition, although the incidence of missed surveillance tests was reduced, problems were identified with tracking inservice inspection L examinations.

' The Authority has instituted a comprehensive curveillance improvement program to address the problems which are being identified. We do not agree with the report's assessment that the overall effectiveness of the surveillance test program has degraded. A new and different perspective of the program is emerging from both the Authority and the NRC. As a result, E numerous issues involving.former and present interpretations of acceptance criteria, testing L methods, scheduling techniques, etc. have arisen. The Authority believes that as the issues are being identified and resolved, the overall program is improving, not degrading.

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.r RESPONSE TO NRC SALP jl Page 3 of 5 P,

L The planned maintenance task force activities continue to support the Authority's overall goal

. of achieving a complete, well formulated and comprehensive maintenance program.

1 D. Emergency Preparedness Emergency preparedness was given a SALP rating of Category 1. The report stated that the program remained a high quality program that received strong support from management.

The report erroneously stated that both the Emergency Planning Coordinator (EPC) and Assistant.EPC have held their respective positions for approximately 6 years. This is not entirely -

accurate. The two individuals have been involved with emergency planning for about 6 years but not in their present positions.

E. Security This functional area was once again rated as Category 1. The report stated that the Authority continued to maintain a very effective and performance oriented security program.

The Authority continues to place an appropriate emphasis on security program improvements.

The recent permanent relocation of the plant access to the secondary, access facility has greatly -

Improved the Authority's ability to process personnel in more orderly fashion. Upgrades to the-perimeter security system continue with the engineering of a new fixed camera system.

Installation will commence later in the year. .

F. Engineering and Technical Support This . functional area received a rating of Category 2. The report stated that although programmatic -improvements were underway, and some good engineering work occurred, deficient engineering work continued in some areas, and, as a result, there appeared to be no significant overall improv_ement in engineering support. The Authority does not agree with this summary, although we do agree with the overall rating category.

l The report discusses some of the organizational, procedural and programmatic E

improvements. No mention is made of the additional engineering personnel added to the site staff

- to establish a dedicated system engineering organization and to expand the performance monitoring staff.  ;

' To support the deficient engineering work characterization, the report uses recently identified deficiencies which actually occurred several years earlier. These deficiencies reflect weaknesses that existed at that time and are not representative of current Authority practices.

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RESPONSE TO NRC SALP Page 4 of 5 Examples include the SSFI (safety system functional inspection) findings on obsolete calculations, inadequate safety evaluations, and the crescent area cooler operability problems. No mention is

! made of the recent quality of safety evaluations, although the functional area write up for safety l assessment notes this improvement. In addition, no mention is made of the engineering support which implemented modifications with significant importance to operation such as security, zine injection,- hydrogen water chemistry, containment Isolation valve replacement, resolution of '

recirculation scoop tubes, and radiation waste treatment. Many of these modifications were cited in the other functional areas as reasons for improved performance. <

There were several areas of the report which were not clear and were discussed during the SALP meeting. First, on page 21, the last paragraph discussed an issue of the continued high backlog of drawings not being updated. As clarified during the SALP meeting, this issue actually I involved the method of updating those critical drawings required to support plant operations, not an overall problem of a high backlog of drawings requiring updating. As discussed, a program '

? was instituted to correct this issue. a Secondly, on page 22, the fourth paragraph discusses several issues relating to the ISI program. Once again, as discussed at the SALP meeting, the Authority does not understand the identified concerns. The concerns involve:

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1. " untimely and incomplete submittals" - During the 1988 refueling outago , the Authority detected IGSCC (intergranular stress corrosion cracking) indications late in the outage. This resulted in additional weld inspections, crack growth evaluations, and repairs. A total of 92 welds were inspected and nine weld overlays installed. To support a timely restart, the Authority submitted, both formally (JPN 88-055, dated October 21,1988) and informally, data and information to the NRC staff as soon as it was available. The technical submittals were followed up with face to-face meetings to facilitate the NRC staff review process. The 1988 outage report (JPN 88-061 & JPN 88-062, both dated November 10, 1988) was submitted approximately a week prict to plant startup.- The Authority recognizes the NRC staff's expedited review process; however, considering the circumstances, we believe that the information exchange between the Authority and the NRC was effective and appropriate.

2. " weak justifications" - The Authority is unaware of any inadequate submittals regarding recirculation system welds. Three recirculation system welds28-112,28-33, and 28-53 were evaluated by fracture mechanics and found to be acceptable (NRC Letter R. A. Capra to J. C.

Brons, dated November 18,1988). A similar evaluation of crack growth on two additional welds 28-48 and 28-116 for operation through a mid-cycle inspection was informally denied by the NRC staff. The fracture mechanics evaluations established weld acceptability in accordance NUREG 0313, Rev. 2 and Section XI of the ASME Code. Wolds 28 48 and 28-116 I- were repaired with overlays because Generic Letter 88-01 requires NRC staff approval on all crack growth evaluations. The Authority understands the NRC's differing professional opinion regarding weld repair and immediately implemented these repairs.

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~ .- Attachment i RESPONSE TO NRC SALP

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3. "basellne UT Inspection of nine weld overlays" By letter dated November 10,1988 (JPN-88-061) the Authority identified that sudace finishing and ultrasonic inspections of five of the o nine wold overlays might be deferred because they potentially impacted plant restart.

However, productivity improvements allowed eight of the weld overlays to be inspected during the outage and the ninth weld overlay was inspected due to startup delays. All weld overlays installed during the 1988 refueling outage were surface finished and ultrasonically tested in accordance with EPRI BWROG requirements (

Reference:

JPN-89-012, dated March 24,1989). ' The Authority does not understand the NRC's concern regarding schedule extensions on surface finishing and UT inspections. Generic Letter 88 01 and NUREG 0313 provide for short term installation of wold overlays, which are designed in accordance with Section 4.0 of NUREG 0313. UT inspections in accordance with Section 5.0 of NUREG 0313 establish the basis for weld overlays as long term repairs.

Without the benefit of further information regarding the concerns identified on page 22, the Authority can not agree with an assessment of a " negative trend in ISI program performance." Tho Authority will continue its policy of providing IGSCC data and information to the NRC staff as quickly as possible during plant outages.

In summary, the Authority believes that the engineering assessment for the FitzPatrick plant should accurately reflect the changos initiated. Clarification should be added that results are still-too early to assess.

G. Safety Assessment / Quality Verification The SALP report assigned a Category 2 rating to this functional area. The report noted the safety conscious approach to plant operations as demonstrated by the absence of reactor scrams and by infrequent plant transients. Also cited were the improvements in licensing submittals,

~ procedures and procedural complianco.

Some statements in this functional ares need to be changed to reflect the present status more accurately. On page 25, in the second paragraph, the Authority is "still developing" a plant wide corrective action system. The system has not been implemented. Completion is expected within the next six months. In the third paragraph, OA management "is" involved in designing the plant-

- wide corrective action system; not "was". On page 26, the second paragraph states that safety evaluations were generally comprehensive and well documented;- however,- the paragraph identifies some design changes which occurred without proper safety evaluations. The paragraph does not specify that those later identified safety evaluations occurred many years earlier and do not reflect present standards or Authority practico.

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