ML20126H221
| ML20126H221 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/29/1992 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML20126H223 | List: |
| References | |
| NUDOCS 9301050105 | |
| Download: ML20126H221 (21) | |
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- Td December 29, 1992
. hir. Ralph E. Ileedle lixecutive Vice President Nuclear Genceation New York Power Authority 123 hiain St.
White Plains, New York 10601
Dear h1r. Ileedle:
Subject:
RESTAl(T OF Tile IT12 PATRICK NUCLEAlt POWER PLANT The James A. FitzPatrick Nuclear Power Plant was shut down by the New York Power Authority (NYPA) on November 27,1991, to resolve a design deficiency in the core spray system containment isolation logic. However, once the design deficiency was resolved, NYPA decided on December 6,1991, not to restart the plant before the January 11,1992, refu-ling outage due to fire protection related issues. Subsequently, you agreed not to restart the plant following the refueling outage until you were satisfied with restart readiness and until the NRC agreed with your conclusion. Ily letter dated December 17,1992 (Enclosure 2), you stated that the FitzPatrick plant was ready for restart.
Significant inspection and assessment efforts have been undertaken by the NRC since the November 1991 shutdown to evaluate NYPA's progress in resolving technical concerns, and correcting the underlying root causes of the identified performance deficiencies. These efforts included: the establishment and imp!cmentation of an NRC FitzPatrick Assessment Panel; the conduct of numerous individual region and resident based inspections; NRC team inspections to evaluate the adequacy of the fire protection and emergency service water systems at the plant; an NRC meeting with you on October 5,1992, to review the results of
- NYPA's readiness for restart self assessment; and an NRC Restart Assessment Team Inspection during the period of Getober 5 through 14, 1992, to independently evaluate the plant's readiness for restart.
l Ilased on the above, the NRC staff has concluded that sufficient progress has been made to l support safe plant operation, Our detailed assessment to support that conclusion is contained
!= in Enclosure 1 to this letter.
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L in addition, there were three technical issues that developed late in the outage that required resolu 3.on prior to plant restart. These issues involved: (1) the adequacy of the relay room CO2 fire suppression system and its impact on control room habitability; (2) the adequacy of separation between cables of redundant safety divisions; and (3) questions regarding the adequacy of safety-related welds and radiographs. The NRC has reviewed your corrective actions for these deficiencies and concluded that they are satisfactorily resolved for restart.
-Our basis for that conclusion is contained in Enclosure 3.
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I Mr. Itniph E. iteedle 2 We note that NYPA has developed a detailed reactor stanup plan to describe the process and self aswssment efforts necessary to ensure a safe restart of the FitzPatrick plant. In preparation for restart, the NItC lias also developed an augmented inspection plan. The NitC will provide augmented inspection coverage to monitor unit startup and return to power operation.
In summary, based on the actions you have taken and our review of those actions, the NItC aprecs with your assessment that the FitzPatrick plant is ready for restart, if you have any questions regarding our assessment, please contact Curtis Cowgill of my staff at 215-337-5233. We appreciate your cooperation.
Sincerely, r
- tr:' gigg:.d By
. . T. !JMn Thomas T. Martin llegional Administrator linclosures;
- 1. FitzPatrick Itestatt iteadiness
- 2. NYPA letter dated December 17, 1992, iteadiness to Restart
- 3. Itesolution of itemaining Technical issues ec w/ encl:
J. lirons, President G. Goldstein, Assistant General Counsel J. Gray, Jr., Director, Nuclear 1.icensing - IlWit Supervisor, Town of Scriba C Donaldson, Ilsquire, Assistant Attorney General, New York Department of Law Director, linergy & Water Division, Department of Public Service, State of New York K. Abraham, PAO (2) All Inspection lleports Public Document lloom (PDit)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC itesident Inspector State of New York, St.O Designee OFFICIAL RECORD COPK
Mr. Ralph E. Ikedle 3 bec w/ encl:
Region 1 Docket Room (with concurrences)
T. Martin, RA W. Kane, DRA K. Smith, RC M. llanerjee, Acting SLO K. Abraham, PAO W. Hehl, DRP J. Wiggins, DRP C. Cowgill, DRP P. Eselgroth, DRP R. Urban, DRP W. Cook, SRI - FitzPatrick G. Tracy, SRI - IP-3 J. Taylor, OEDO J. Snierck, OEDO V. McCree, OEDO T. Murley, NRR F. Miraglia, NRR W. Russell, NRR J. Partlow, NRR t S. Varga,'NRR J. Calvo, NRR C. Vogan, NRR R. _Capra, NRR
' W.11odges, DRS L. Bettenhausen, DRS J. Durr, DRS OFFICIAL RECORD COPY
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linclowrg_.1 ED7,1% TRICK.RESTAID' RHADINESS 1.0 IIACKGROUND The James A. FitzPatrick Nuclear Power Plant (N.Y.) is a boiling water reactor owned and operated by the New York Power Authority (NYPA). A decline in plant performance was first ooted in the NRC staff's Systematic Assessment of Licensec Performance (sal.P) Report for the period October 1,1989, through January 31, 1991. Performance declines were noted in the functional areas of Plant Operations, Radiological Controls, and Safety Assessment /
Quality Verification. Most notably, the level of performance in the latter two functional ;
areas was rated Category 3. limergency Preparedness and Security were rated Category 1, and the remaining functional areas were rated Category 2.
In light of declining performance at the facility, NRC senior management concluded in June 1991 that an NRC diagnostic evaluation was warranted to provide an independent assessment of licensee performance. This evaluation was conducted in September and October 1991.
The Diagnostic livaluation Team (Dl!T) found deficiencies in the following areas: the licensed operator requalification program, support facilities, plant material condition, the procedure change process, the use of operating experience for plant improvements, Quality Assurance (QA) effectiveness, the fire protection program, the preventive maintenance program, the root cause analysis program for equipment failures, engineering evaluations, the configuration control program, corporate support and oversight, site management osersight and control, and the corrective action program.
The DliT determined that there were six root causes for the apparent poor performance at the plant. These were:
- Failure of corporate management to plan adequately and effectively for the operational support of Fit / Patrick.
- Inadequate management oversight and direction.
- Incf fective resource allocation and utilization.
- Inciteetive use of industry experience.
- Insufficient standards for performance.
- Ineffective com.nunications and teamwork between the plant and corporate headquarters.
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The plant was shut down on November 27,1991, to resolve a design deficiency in the core spray system containmem isolation logic. On December 6,1991, NYPA decided not to restart the plant before the scheduled January 11, 1992, refueling outage as initially planned.
The licensee concluded that restart of the plant would not be prudent without a thorough assessment of fire protection and 10 CFR Part 50, Appendix R deficiencies identined by the NRC and the licensec's staff. This action was hastened by an unexpectedly high failure rate '
experienced during penetration seal inspections. The plant has remained in an extended outage since November 27,1991. The outege was signincantly extended to resolve many design and engineering dc0ciencies, most notably in the fire protection and 10 CFR Part 50, Appendix R programs. The licensec committed, as stated in our letter dated October 15, 1992, not to restart the plant until the NRC was a.Med with the plant's readiness for restart.
in July 1991, the licensee began implementing sigrificant organizational and management changes. Furthermore, in December si, the ti. .;nsoc implemented a comprehensive, long-term Results improvement Fret.. .n design'ed to improve overall performance at the plant and corporate office. Coccurrent'y, the NRC utablished a FitzPatrick Assessment Panel to assess ,
the adequacy of the Results 1,oprovement Program and coordinate agency resources for monitoring and asses' sg licensee performance in January 1992, the NRC placed FitzPatrick l
on the NRC's list cf ' ' p ing close monitoring because of regulatory concerns about ;
declining m 'm e in the NR. SALP Relut for the period of February 1,1991, through April 18,1992,a further decline in performance was noted in the functional areas of Operations, Maintenance /
Surveillance, and lingineering/ Technical Support. The level of performance in these functional areas as well as Safety Assessment / Quality Verincation was rated Category 3, warranting increased management attention to ensure a continued acceptable level of performance. The Security and limergency Preparedness functional areas were rated Category I and the Radiological Controls functional area was rated Category 2.-
lleyond the weaknesses identified by the sal.P and DET, denciencies in several programs were found by the licensee and by the NRC staff in subsequent reviews. NRC inspections conducted at Fit 7 Patrick between December 2,1991, and May 1,1992, which included a DliT followup inspection, a Fire Protection Team inspection, and a Safety System Functional Inspection of the emergency service water system, identified the following violations:
- Inadequate control of a design modi 0 cation for the analog transmitter trip unit system.-
- The failure to identify and correct certain conditions adverse to quality that allowed several systems to degrade over time,
- Inadequate implementation of the fire protection program.
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- The failure to meet certain 10 CFit Part 50, Appendix l( requirements.
- The submittal of incomplete and inaccurate information to the NRC.
The NRC held enforcement conferences on March 18 and June 24,1992, to discuss these violations, their causes and corrective actions. As a result, the NRC took escalated enforcement action against the licensee on September 15, 1992. The NRC cited five Severity ixvel 111 violations with a cumulative Civil Penalty of $500,000. The lleensec's response dated October 15, 1992, agreed with the problerns underlying the violations, described the causes and provided corrective actions. The NRC found NYPA's response to the cited violations acceptable.
The staff evaluation of FitzPatrick restart readiness was conducted in accordance with NRC Inspection Manual Chapter 0350, " Staff Guidelines For Restart Approval."
2.0 ROOT CAUSI: IDl;NTIFICATION in 1991, NYPA senior management selected a team of plant and corporate personnel to identify the major issues involved in the decline in performance at Fit 7 Patrick. NYPA identined a total of six root and contributing causes. Following the DIIT, NYPAI rrformed a second review and finalized their root and contributing causes, which incorporated the DET root causes. NYPA determined that the three principal root causes of the performance decline were:
- Site and corporate management failed to provide adequate oversight, direction and support to the Fit / Patrick station.
- Management failed to effectively utili7e and alk>cate resources.
- Management failed to establish a policy that promoted and enforced standards for performance.
NYPA determined that there were also five contributing causes:
- Communications and teamwork at the site, and between the site and corporate staffs, were ineffective. '
- Industry operating experience was not used effectively nor were appropriate corrective actions taken to help solve long-standing problems.
- Management was not effective in providing leadership and monitoring performance through self-assessments.
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- Attention was not properly focuwd to establish accountability and responsibility, and to ensure attention to detail.
- Planning was not effective, resulting in Imrly scheduled maintenance and uncoordinated engineering projects, llased on the above findings, NYPA developed a comprehensive, long term Results improvement Program in December 1991. The program was designed to improve overall 1 performance at the plant and corporate office by correcting the eight root and contributing causes.
3.0 FITZPATitiCK ASSESSMENT PANEL, FORMATION A significant NRC cffort was required to follow licensee actions to correct deficiencies found by the DliT and to implement the Results improvement Program. The NRC created the FitzPatrick Assessment Panel (FAP) to assist Region I and NRR in the coordination of NRC resources for the overall performance monitoring and assessment of the licensee. The responsibilities of the PAP include:
- Monitor and assess performance of the licensec.
- Coordinate the inspectica program for the facility.
- Recommend and coordinate enforcement activities.
- Assess the adequacy of the Results improvement Program and monitor its implementation.
Review the licensee's response to the Dl?r and assess the adequacy of the associated corrective actions.
- Identify, evaluate, and track restart issues.
- Provide a plant restart recommendation and basis following the 1992 refueling outage.
4.0 NRC ASSFSSMENT OF NYPA ROOT CAUSES & COltRECTIVE ACTIONS Corrective actions to address the eight root and contributing causes are addressed in the Results improvement Program. .The NRC has conducted a th_orough review of the Results improvement Program. During this review, the NRC identified a series of questions and
- comments concerning the development, implementation, and assessment of the Results improvement Program. The NRC met with the licensee to discuss these concerns on March 30,1992. The licensee responded to the NRC's concerns in a letter dated April 29,1992, 4
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i in a letter to NYPA dated August 7,1992, the NI(C concluded that the 1(esults impmvement Program was a comprehensive plan that addressed the root causes for the previous decline in plant performance, and pmvided corrective actions and a reasonable process for assessing the effectivenew of those corrective actions.
The licensee established two groups to provide oversight of the 1(esults improvement Program. The Plant tradership ream, which consists of the 1(esident Manager and the three General Managers, is responsible for oversight of the Results improvement Program and for reviewing action items to ensure completeness before closcout. The Nuclear lxadership Team, which consists of the lhecutive Vice President, the corporate Vice Presidents and the Resident Managers for 1 itiPatrick and Indiun Point 3, is responsible for performing periodic ellectiveness assessments of the Resuhs improvement Pmgram.
In a public management meeting held on site on September 3,1992, NYPA presented findings hom their first semi-annual self-assessment of the Results improvement Program to the NRC. 'Ihe purpose of this self-assessthent was to determine whether actions taken to date had adequately resolved program issues, to assess the timeliness of actions in progress, and to evaluate action plans for elfectiveness in resolving issues. The licensee's Results improvement Program assessment team found that the Results improvement Program was a well canceived program and a useful management tool for identifying and resolving issues that would improve the overall performance at FittPatrick. The FAP concluded that the self-assessment took a critical look at the licensee's program and made appropriate reconunendations f or improvement.
(>verall, the licensee has made significant changes to promote both short and long terrn improvements in performance. Corporate management has provided substantial resources and oversipht. The Resident Manaper is new and there have been several other management and organizational changes to support the effort. NRC observations indicate that substantial ~
improvement has been made in overall performance at the site, The NRC will continue to monitor the implementation of this improvement program via the NRC inspection program and through periodic meetings with the licensee. The FAP will continue to be the focus for NRC oversight of the FitzPatrick facility.
5.0 NRC ASSF.SSS11'.NT OF Rl;STAltT ISSUFS AND STAl(TUP COORI)lNATION 5,1 IN'l RODUCTION As previously stated, the FAP was charged with identifying and evaluating issues alfecting testart. The ! Al' reviewed findings from the Dl!T, I ire Protection Team inspection, and limetrency Service Water Safety System Functional luspection. Various technical issues and industry opeiating esperience were also reviewed in the process. Ibch issue was discussed with the licensee and the corrective actions resolved and documented. The FAP developed a 5
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4 comprehensive restart readiness evaluation process to ensure that required restart issues were thoroughly reviewed and assessed by the NRC before plant restart.
In addition to the above effort, the NRC performed a Restart Assessment Team inspection (RATI) from October $ - 14, 1992. The principal objective of this inspection was to perform an in depth evaluation of the degree of readiness of NYPA management controls, programs, plant equipment and personnel to support safe restart n' , operation of FitzPatrick. The RATI inspection report was issued on November 12, 1992.
The following sections address the areas that were assessed by the NRC to establish a basis ,
for restart of the FitrPatrick plant. The areas assessed are consistent with NRC Inspection Manual Chapter 0350, 5.2 PilYSICAL STATE OF ltEADINFSS OF Tile PLANT MEf1EIALIDEDfflON Major work tasks completed during the extended shutdown included: motor operated valve maintenance and testing; bottom head drain valve replacement; jet pump beam replacement; analog transmitter trip systern (ATTS) relay replacement, shroud head bolt replacement; in-service inspection (ISI) of recirculation piping and reactor vessel head welds; and many Orc protection modlGeations. This work was typically well controlled and performed.
The overall material condition of the plant and equipment has significantly improved. NYPA has addressed the previous problems of poor housekeeping and material condition of the plant by improving controls on combustibles and oil leaks, and by developing a long term plant preservation program. The reduction in contaminated areas and combustible material in the plant, and improved plant and equipment preservation and cleanliness is notable, h1AINHiNANf1LUACKLOG
- Over 5,000 work requests were completed during the extended shutdown. The RATI conducted an independent review of a large portion of work requests designated for deferral until after startup to verify consistency with system / component availability as required by the operating license and technical specifications. The team determined that the criteria used by the licensee as required by their " Outage Closcout - Readiness For Startup Checklist," was -
conservative, demonstrated a strong safety perspective, were appropriately implemented, and provided an acceptable basis that the items in the backlog would have no impact on safe startup and operation of the plant. Furthermore, a review of the contents of the backlog >
clearly indicated a heightened sensitivity by plant personnel to identify and initiate corrective action for discrepancies of even minor significance.
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The NRC reviewed control room deliciencies to assure that those that affect the conduct of plant operation were scheduled to be addressed before plant start-up. Overall, the program for resolving existing control room defici.:ncies was comprehensive and well managed, and ,
the schedule for resolution of deficiencies was acceptable. Furthermore, the processes for evaluating, prioritizing, and tracking future control room denciencies are adequate to support safe operation of the plant.
MODIFICKDONS The program for making permanent modifications is well defined with comprehensive implementing procedures. Modification packages are well organized and of high quality.
Safety evaluations are adequate. Responsible engineers are generally knowledgeable of assigned modifications and responsibilities. .The licensee has made substantial progress in ,
reducing the backlog of temporary modifications. Those not closed out prior to startup will have no impact on safe startup and operation of the plant. The plant modification training administered to licensed and non-licensed operators is adequate.
SJSTliM AI.lGNM[ilfl'S The licensee has nnished or has appropriately scheduled the necessary plant system alignments needed for plant restart. The NRC independently walked down selected systems to verify the adequacy of the valve lineup checklist and system drawing, evaluate valve labeling, evaluate the control of locked valves, verify the operability of instrumentation and ,
support systems, and assess the overall material condition of the system and general L cleanliness of the area. The overall results of the safety system walkdowns were satisfactory.
The valve and eledric power lineups were proper. The checklist control of vent and drain capped connections and locked valves wa:. kquate. The required instrumentation and support systems alignments were appropriately established. Cleanliness and the condition of equipment and components were generally adequate. System drawings were adequate.
Although improvements have been made in plant labeling, some weaknesses were noted. No other concerns were noted.
TECHNICAL, ANILI.lARDRARli CONCERNS Many technical and hardware concerns were identified in the past by the DET, the resident inspector staff, NRC team inspections, and the licensee. The FAP elosely monitored each of these concerns lixamples of these technical and hardware concerns included denciencies in the low pressure coolant injection (LPCI) inverter environmental qualification, ATTS design control and testing, nre protection and AppendiCR programs, primary containment isolation ,
- system logic, electrical cable separation, and radiography. With the exception of the relay room CO 2fire suppression system, electrica' cable separation and radiography concerns, each item was inspected by NRC inspectors and formally closed in inspection reports. The FAP .
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tracked each issue to ensure that their resolution was satisfactory for plant restart._ Prior to NRC concurrence in the licensee's plans for restart, the NRC will complete required inspections and confirm satisfactory resolution or appropriate compensation for all remaining-open restart issues.
i CONCI USION The licensee has completed extensive physical work during the extended shutdown, which included substantial corrective maiatenance, modifications, and reduction of maintenance backlog, control room deficiencies, and temporary modifications. Based on substantial NRC:
inspection of these activities, the NRC staff concludes that tin physical _ condition of the FitzPatrick plant is adequate to support safe restart and operation. ,
5.3 PLANT AND CORPORATE STAFF READINESS DJ'ERATING STAFF In April 1991, the NRC found the licensed operator requalification program unsatisfactory.
The program failure was attributed to inadequate time validation of the written exams.
Although there were some individual knowledge and ability deficiencies noted, no programmatic knowledge or ability weaknesses were observed. NYPA provided a sound basis for continued operation and identified long term and short term corrective actions. In May 1991, the NRC issued Confirmatory Action Letter I-91-010 regarding these corrective actions, in June 1991, twelve operators were administered a special written requalification exam and all pased. This verified tha: NYPA had adequately addressed the time validation deficiencies. However, one crew and two individual failures of the simulator portion of the reexamination identified certain EOT uaining deficiencies. A subsequent review in December 1991, determined that emergency operating procedures (EOP) training had improved and that corrective actions committed to by NYPA had been satisfactorily completed. But the review also identified deficiencies involving licensed operator meintenance of qualification and reactivation of licenses. These problems and others identified by the DET showed insufficient management oversight.of the requalification program. NYPA initiated extensive corrective actions to resolve these issues.
In May 1992, the NRC conducted a requalification program evaluation and examination at FitzPatrick. The licensed operator requalification results met the Examin.:r Standard criteria for a satisfactory requaUfication program. All three reactor operators and all ten senior reactor opemtors examined passed all portions of the examination. All four crews that wem evaluated performed satisfactorily on the simulator _ portion of the examination. The -
corrective actions remaining from the Confirmatory Action Letter were reviewed and determined to be completed. By letter date(' June 12, 1992, the Regional Administrator, Region 1, notified the licensee that the requalification program met NRC's regulatory
, reqitirements and was considered satisfactory. Furthermore, this letter also documented closecut of Confirmatory Action Letter 1-91-010.
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NYFA authorized 48 new parmanent positions (some of which are not yet fdled) to inrease support of plant operations. Some of these positions included an additional reactor operator for each shift. Also, the shift technical advisor will be reinstated as a separate position.
Recent inspection by the NRC staff determined that the conduct of licensed control room operators and auxiliary operators has been good. Specifically, operator control board awareness, procedure adherence, communications, shift turnovers, and professionalism have been strong. The NRC has seen good communication between the operations staff and other on site organizations. Plant evolutions witnessed by the NRC ws ? siducted in a safe, controlled manner. The training provided to plant operators wa . gw . A newly developed position of engineer-on-shift has augmented the operating crews ind provided enhanced technical expertise. Staffmg and overtime control have been appropriate. Also, cperations management oversight of the Operations Department has been acceptable.
MMNIENL\NCE STAFF ,
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The NRC has determined that staffing, organization, and programmatic changes have effectively addressed previously identified weaknesses (poor material condition and equipment failure root cause analysis) in the maintenance / surveillance are:.. Communication between management and craft personnel has appeared good. The maintenance staff has been made aware of management expectations. The organization has been fully staffed and overtime controls have been appropriate. Additional procedure writers were employed to improve the quality of I&C procedures. The scope and quality of the preventive maintenance program is being upgraded. Finally, maintenance staff training and maintenance staff knowledge of plant activities have been good.
- ENGINEEllED/TECllNICAL SUPPORT STAFF The engineering organization has been effectively supporting plant operation and previously identified deficiencies in this area (poor communication and coordination within the organization) were improved. NYPA's engineering reorganization established a
- ?,le design authority in the corporate engineering department, a new site engineering group (34 people),
l and realigned the technical services department. NYPA has also authorized about 70 new..
engineering positions (the majority of which are aircady filled). The revised administrative policy adequately delineates responsibility for engineering and technical support so that previously identified problems with lack of organizational authority, conflicting program requirements, and functional overlap were addressed. Furthermore, the licensee has initiated
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several actions designed to improve communication and interaction among the site and corporate organizations.
Due to more clearly defined responsibilities and duties, and due to the formation of the site engineering staff, corporate engineering involvement has improved. The staff has observed evidence of effective communication between the site and headquarters engineering organizations. The cognizant engineers have demonstrated good knowledge of their 9
modifications and the overall modification process. The engineering organization's performance has improved and is adequate to support safe plant operation.
CQlmOR ATE /SEli STAFF INTliRFACF The licensee has initiated several actions designed to improve communication and interaction among the site and corporate organizations. These actions include monthly meetings between the corporate and site engineering organizations and technical services. The licensee has also initiated the use of teleconferencing between the corporate office and the site, and has maintained a charter aircraft on call to ease site accessibility from the White Plains Office.
The staff has noted evidence of effective communication between the site and corporate organizations, including resolution of an emergency diesel generator ground issue, preparation of engineering and modification packages, and implementation of the Results Improvement Program. Furthermore, the Nuclear Leadership Team has served as an effective mechanism of ensuring that corporate management oversight of implementation of the Results Improvement Program has been effective,*and cooperation between site and corporate management has been adequate to support safe plant operation.
CONCI USION The NRC staff concludes that there is reasonable assurance that the plant and corporate staffs are ready for restart of FitzPatrick. The current levels of organization performance and interface are adequate to support safe plant operation.
SA LICENSEE MANAGEMENT AND OVERSIGIIT NYPA management has demonstrated a serious commitment to improvement and has provided the management attention and resources necessary to implement its Results Improvement Program effectively. NYPA has made major organizational and personnel- -
changes. In July 1991, the position of Superintendent of Power, which reported directly to -
the FitzPatrick Resident Manager, was replaced with three new General Manager positions.
These new General Manager positions, Operations, Maintenance, and Support Services, have provided improved management oversight of plant activities. The management personnel changes included a new Resident Manager, General Manager-Operations, General Manager-Support Services, Technical Services Manager, Radiological Environmental Services Manager, and Training Manager. These personnel changes were implemented using individuals from_ outside the NYPA organization, thus providing site and corporate management with a broader industry perspecuve in operating and managing the FitzPatrick plant. Observations to date indicate that these individuals are effective in improving overall site performance.
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In order to ensure proper management oversight of the Results improvement Program,- NYPA implemented a Plant Leadership Team and a Nuclear Leadership Team. The Plant- .
Leadership Team, which consists of the Resident Manager and the three General Miinagers, has been responsible for oversight of the Results Improvement Program and for reviewing action items to ensure completcaess before close out. The Nuclear Leadership Team, which consists of the Executive Vice President, the corporate Vice Presidents and the Resident Managers for FitzPatrick and Indian Point 3, has been responsible for ensuring proper corporate support and oversight and for performing periodic effectiveness assessments of the Results improvement Program.
The NRC has seen signi6 cant performance improvement in management oversight, direction and support. Resources have been provided for extensive plant modifications, and increased staf6ng has been provided in operations, engineering and licensing, There has been clear-improvement in site and corporate management's involvement in plant activities and ~
operational concerns and in the communications of management expectations and standards of performance to the plant and corporate staff.
Improvements in planning and scheduling of activities have been evident. Improvement in the fostering of accountability, responsibility, and attention to detail have been observed.
NYPA management has encouraged improved horizontal and vertical communications and teamwork at the site and between the site and the corporate office. NYPA management has established a work environment that has been conducive to problem identification and has established improved programs to identify, prioritize and resolve significant issues. Programs for root cause analysis and the evaluation and utilization of operating experience have been upgraded.
Through development of the RIP, the RIP self-assessment program, and the Startup Readiness Evaluation (SURE), NYPA management has demonstrated its ability to conduct effective self-assessments and to factor the results of those assessments into improved program and personnel performance. In general, the' quality assurance program at the site has been effective. Although some weaknesses in QA were identified during the RATI, NYPA has
- developed corrective actions to address identified weaknesses. Satisfactory performance of-the on site Plant Operations Review Committee (PORC) and the off site Safety Review '
Committee (SRC) has been demonstrated.
The licensee developed a start-up plan to describe the process and management review necessary to en;ure a safe organized return to service of the plant. The plan describes the:
physical and administrative requirements for startup. The plan also describes approaches for -
the conduct of self-assessments of the start-up process. As part of the plan, the Plant Leadership Team will make recommendations to the Resi_ dent Manager for the continuation of plant start-up when milestones are completed. The plan also requires a senior manager to be assigned to each shift to provide continuous management presence and to supplement the shift .
supervisor during the startup. 'The staff found that the plan was comprehensive and had i1
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The staff concludes that there is reasonable assurance that NYPA management is ready for FitzPatrick restart.
5.5 FIRE PROTECTION ISSUES Fire protection issues have been a major concern at FitzPatrick. Licensee audits and several NRC inspections, including the October 1991 DET inspection found significant deficiencies.
When the unit was shut down on November 27,1991, NYPA notined the NRC that they would not restart the plant without thoroughly reviewing Fire Protection and Appendix R concerns raised by the NRC and their own staff. Based on findings from the NRC Fire Protection Team inspection in March 1992, NYPA stopped all work until signincant improvements were made in the control of combustibles and ignition sources. NYPA also completed an extensive Appendix R reanafysis and evaluated the operability of all fire barriers.
An analysis performed by NYPA found the following three root causes of the organizational and programmatic problems associated with fire protection at FitzPatrick:
- Lack of commitment to fire protecdon by NYPA management.
- Inadequate interface between corporate headquarters and the plant staff.
- Inadequate fire protection staff qualifications, in order to address these root causes, NYPA is com.olidating all fire protection elements into a single Fire Protection Program, which should be completed by April 1993. In addition, the licensee has made significant improvements to its fire protection and prevention (FP/P) procedures, staffing, training and fire brigade equipment. Administrative controls for combustibles and ignition sources have been notably improved. Fire protection training procedures have been upgraded, and fire brigade ard fire watch staff have been trained in the use of improved procedures. With the exception of the relay room CO 2fire suppression system, nre protection and personnel fire brigade equipment has been upgraded and are being adequately maintained. Fire Oghting pre-plans have been improved and further enhancements are planned. Additional fire prevention staff have been added. NRC inspectors have confirmed that the Fire Protection Program and its implementation by FitzPatrick staff members would be capable of adequate fire protection.
The licensee's Appendix R reanalysis identified the need for several plant modifications and changes to procedures for providing safe shutdown in the event of fire. NYPA committed to complete these actions before startup, except for six exemption requests submitted to the NRC for approval. The NRC approved three permanent (one new and two revised) and three 17
l temporary exemptions from the specific technical requirements of 10 CFR Part 50, Appendix R. Compensatory measures for the temporary exemptions have been verified acceptable by the NRC. NRC inspectors have reviewed the design packages, plant installations, and preoperational test results for those modifications that NYPA committed to complete before startup. All modifications were satisfactorily designed, appropriately documented and properly tested. Procedures used to provide safe shutdown in the event of a fire have been revised to incorporate changes identified by the licensce's Appendix R reanalysis. The adequacy of the technical content of procedures and completion of training for licensed operators, required due to procedure changes, has been verified. The licensce's Appendix R reanalysis has been docketed for NRC review. An initial review veriGed that this reanalysis addressed all of the safe shutdown concerns identified by the licensee, the DET and the NRC fire protection team inspection.
The staff believes that NYPA management is committed to the fire program. Organizational and personnel changes are planned to strengthen this management. Plans and programs have been established to ensure management ov6rsight is maintained after restart. With the exception of an outstanding issue involving the adequacy of the relay room CO2 Gre suppression system, NYPA has satisfactorily evaluated and resolved identified fire protection concerns. Pending resolution of this outstanding issue, the staff concludes that there is reasonable assurance that FitzPatrick is ready for restart. Prior to restart, an addendum to this basis will be issued to reDect satisfactory resolution of this issue.
5.6 LICENSING ACTIONS Several licensing actions required NRC review and approval during the extended outage to support FitzPatrick restart. These licensing actions included six license amendments, six exemptions to 10 CFR Part 50, Appendix R, and two In Service Inspection (ISI) safety evaluations. The following is a summary of the significant licensing actions filed by NYPA and reviewed and approved by the NRC to ensure that FitzPatrick and its prospective operation would not conflict with any applicable regulatory requirements:
- On September 10, 1992, the NRC staff issued six exemptions from specific technical requirements of 10 CFR Part 50, Appendix R. The exemptions were divided into three categories; revised, new, and temporary. The two revised exemptions were necessary to provide additional information or add additional fire areas to existing exemptions. The new exemption was needed based on an Appendix R reanalysis for the FitzPatrick plant. The three temporary exemptions were necessary to provide the additional time required to complete modifications designed to bring the plant into full compliance with Appendix R. For the temporary exemptions, the NRC staff found the compensatory measures that would be implemented by NYPA provided a level of safety equivalent to that required by the regulations.
- On January 23,1992, the licensee identified the failure of an analog transmitter / trip unit system (ATTS) relay. The ATfS functions to process input signals from 13 L_ _
Rosemount transmitters and resistance temperature detectors, and outputs to thd reactor protection system (RPS), primary containment isolation system (PCIS), and emergency core cooling system (ECCS) actuation logics. The failure was the result of -
the relay being installed in an energized state beyond its quali0ed service life. NRC followup of this relay problem identined that NYPA had failed to response time test the RPS according to the Technical Speci0 cations (TS) since the ATTS modification was installed in 1985. Following an extensive engineering analysis of this issue, the licensee submitted an amendment request that clarified and enhanced the response time testing requiremeats. On September 9,1992, the NRC staff issued Amendment No.
183 approving the new response time testing specifications.
- The recirculation system piping is susceptible to intergranular stress corrosion cracking (IGSCC). In response to Generic ! etter (GL) 88-01, the licensee acknowledged the susceptibility of this piping to IGSCC, but stated that no plans have been made to replace it. Instead, inspections are conducted as required by GL 88-01,- and weld' overlays are applied when necessary. Hydrogen water chemistry and zinc injection have been implemented as a deterrent to IGSCC During the 1992 refueling outage, no IGSCC indications were discovered. The NRC staff reviewed the IGSCC inspection methodology and results and found that they met the guidelines of GL 88-
- 01. By letter da:cd August 17,1992, the NRC concluded that the FitzPatrick plant can be safely returned to operation for at least one additional fuel cycle _with assurance that the integrity of the reactor coolant pressure boundary will be maintained. The licensee will continue to do IGSCC inspections each refueling outage according to GL 88-01. ,
- On November 20,1992, .the licensee applied for an amendment to TS 3.0.D and requested that it be processed on an exigent basis. The amendment revised TS 3.0.D to be consistent with the Standard Technical Specifications and NRC Generic Letter -
(GL) 87-09. TS 3.0.D previously stated that entry into an operational condition .
(mode) shall not be made unless the conditions of the Limiting Condition for Operation (LCO) are met without reliance on the provisions of the action requirements. In GL 87-09, the NRC presented its position that~ this speci0 cation unduly restricts facility operation when conformance to the action requirements provides an acceptable level of safety for continued operation. For an LCO that has action requirements permitting continued operation for an unlimited period of time,-
entry into an operational mode should be permitted in accordance with the action requirements. The application was processed on an exigent basis because the amendment was required to permit startup of the plant with compensatory fire watches in place. On December 17, 1992, the NRC issued Amendment No.184 approving the revisions regarding mode changes in TS 3.0.D.
- In November 1992, during a hydrostatic test on the reactor water cleanup (RWCU) system, the licensee detected a through-wall defect on the 1/2" equalizing line to. valve bonnet weld for RWCU suction isolation valve 12RWC-46. A preliminary root cause 14
4 analysis of the defect determined that the most likely cause of the failure was thermal fatigue due to differential expansion between the stainless steel equalizing line and the carbon steel valve txxly. The licensee designed a pipe assembly to encapsulate the through-wall defect. This design restores structural integrity of the pipe containing the defect and ensures that the repair is capable of meeting all primary and secondary stresses. However, this encapsulation repair method does not remove the pipe defect as required by Section XI of the ASME Code. Removal of the pipe defect would require draining the affected RWCU line. This line ties into the residual heat removal shutdown cooling suction line, which ties into the "B" reactor recirculation system suction line. These lines cannot be normally isolated from the reactor pressure vessel pressure boundary. Therefore, in order to do a repair in accordance with the ASME Code, a plug must be installed to isolate the recirculation suction line and hence the RWCU line. This requires disassembly of the reactor vessel, removal of the reactor _
internals, and offload of over 1/3 of the fuel from the reactor core. The licensee determined that performing a repair in accordance with the ASME Code would result in hardship or unusual difficulties without a compensating increase in the level of safety. Therefore, by letter dated December 14, 1992, the licensee submitted a request for relief from the ASME Code,1980 Edition through Winter 1981 Addenda,Section XI, IWA-5250(a)(2) and IWA-4130(a)(2) for one operating cycle. This relief request was reviewed by the NRC and a safety evaluation supporting relief from the ASME Code for one operating cycle was issued on December 23,1992.
The NRC has reviewed the status of licensing issues at FitzPatrick. The NRC concludes that the licensee has satisfactorily resolved and received staff review and approval of all outstanding licensing issties necessary for restart. 'Fttrthermorec the plant and its prospective ~
operation will not conflict with any applicable regelatory requirements.
5.7 TEAM INSPECTIONS -
NRC team inspections during the last year included a Diagnostic Evaluation Team (DET), an Emergency Service Water Safety System Functional Inspection (ESW SSFI), Fire Protection Team inspection (FPTI), and a Restart Assessment Team inspection (RATI). The findings from the DET, ESW SSFI, and the FPTl are discussed throughout this paper and were instrumental in pinpointing underlying problems at FitzPatrick. The results from the RATI played a major role in determining the readiness of FitzPatrick for restart, in addition to the team inspections, significant NRC management attention and oversight have been given to the site including several management meetings and the formation of the FAP.
The FAP has met frequently to assess the licensee's implementation of the Results improvement Program and overall performance. The FAP has observed tangible improvement in operations, maintenance, engineering, and safety assessment / quality verification.
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The RATI found that a signi0 cant effort had been made to improve performance in operations, maintenance / surveillance, engineering / technical support and safety assessment / quality verification. In particular, strengths were noted in the conduct of plant operators, permanent plant modi 6 cations, maintenance planning, and the evaluations of plant deficiencies. The team also identified three issues that required resolution before start;up.
NYPA did not provide adequate control over the duration'of temporary modification installations and associated control of plant drawings according to their administrative procedure. The team did note that this weakness was identified in NYPA's Start-Up ,
Readiness Evaluation and an operations department self-assessment. The second issue concerned discrepancies identined between the Final Safety Analysis Report electrical cable separation criteria and installed cables in the plant. The third issue dealt with a failure to provide an adequate margin in the high pressure coolant injec' ion system condensate to suppression pool swap-over set-point to allow for instrument drift. With the exception of the electrical cable separation issue, NYPA has satisfactorily resolved each concern. Prior to restart, an addendum to this basis will be issued to reflect satisfactory resolution of the electrical cable separation issue.
The NRC inspection team concluded that, within the scope of its review, following the completion of the start-up issues identified by the licensee and the team, management controls, programs, plant equipment, and personnel are adequate to. support safe restart and operation of the plant.
Augmented NRC inspection coverage during startup will be conducted to verify that startup preparations have been properly executed, surveillance tests have been completed,
' maintenance activities are' controlled, and that' management ^and operators conduct a * * ^-
controlled, safe, and orderly startup. The augmented coverage plan identifies NRC inspection activities associated with the startup and return to power. - Some around-the-clock coverage is planned during plant startup, with further backshift coverage scheduled during significant evolutions.
5.8 RESTART COORDINATION In a letter to the NRC dated July 31,1992, NYPA committed to perform a detailed Start-Up Readiness Evaluation before restart. The NRC recommended that NYPA complete their SURE before the NRC performed its Restart Assessment Team inspection. The licensee conducted this SURE in August and September 1992. In a letter dated September 28,1992, the licensee noti 0cd the NRC that the SURE had been completed successfully and that the facility was ready for the NRC Restart Assest.nent Team Inspection. 2 At the public entrance meeting for the Restart Assessment Team inspection on October 5,1992, NYPA presented the results of their SURE. The FAP concluded that the SURE results demonstrated thorough evaluations of specine technical areas.
In the licensce's readiness to restart letter dated December 17, 1992, NYPA informed the NRC that the FitzPatrick p! ant would be ready for restart once the three ~identi0ed restart-16
~
j issues are resolved. NYPA plans to submit separate correspondence addressing their.
resolution of relay room COf fire suppression system, cable separation and weld radiograph issues before restart.
During plant startup, the licensee plans to have their Plant Leadership Team review activities at various platcas during power ascension. They will then make recommendations to the Resident Manager regarding readiness to continue to the next plateau. ' A ' member of the Nuclear Leadership Team will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day during plant startup and a senior :
manager will be assigned to each shift until reactor power reaches 30%.
In accordance with NRC Inspection Manual Chapter 0350, " Staff Guidelines For Restart Approval," several federal, state, and local government officials were notified of the impending restart of the FitzPatrick plant. The Federal Emergency Management-Agency -
(FEMA) was notined of the impending restart of FitzPatrick as documented in.a -
memorandum from F. Congel, Director of the_ Division of Radiation Safety and Safeguards (NRR) to D. Kwiatkowski, Assistant Assobiate Director of the Office of Technological Hazards (FEMA) dated November 6,1992. FEMA was not aware of any off site emergency preparedness issues that could potentially affect restart of the plant. The New York State ,
Energy Office was notified of impending restart of FitzPatrick by the. Region I State Liaison -
Officer via-telephone on December 21,1992, and Oswego County government and local public officials were notified in a meeting on December 23,1992. Individuals from these -
various agencies identified no issues that would preclude restart of the plant.
5.9 CONCLUSION
The NRC staff has conducted a thorough assessment of the physical condition of the plant, tlie licensee's plant and corporate staffs,"the licensee's corporate and plant management oversight, and the licensing status of the plant. The staff has found all of these areas to be adequate to support safe restart and operation. The staff also found that the licensee's Results Improvement Program is a comprehensive plan that addressed the root causes and corrective =
actions for the previous decline in plant performance, and provided a reasonable process for .
assessing the effectiveness of those corrective actions. Furthermore, the staff found that the-licensee's start-up plan provides the process and management' oversight necessary to ensure a .
safe organized return to power operation.
Pending resolution of three outstanding issu'es involving radiography, cable separation, and the relay room CO2fire suppression system, the NRC staff has concluded that the New: York; Power Authority is ready to support safe restart and power operation of the James A.
Fit 7 Patrick Nuclear Power Plant. Prior to restart, an addendum to;this basis will be issued to reflect satisfactory resolution of these issues..The NRC will provide augmented inspection -
coverage during the start-up process. Also, the NRC will continue to closely monitor licensee performance and the implementation of the Results improvement Program, l
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