ML20129F304
| ML20129F304 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/22/1996 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 9610290091 | |
| Download: ML20129F304 (3) | |
See also: IR 05000333/1996005
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October 22, 1996
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Mr. Michael J. Colomb
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Plant Manager
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New York Power Authority
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James A. FitzPatrick Nuclear Power Plant
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Post Office Box 41
Lycoming, NY 13093
Dear Mr. Colomb:
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Subject:
NRC Inspection Report No. 50-333/96-05 and Notice of Violation
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This letter refers to your September 25,1996 correspondence, in response to our
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August 21,1996 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely,
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Original Signed by:
Curtis J. Cowgill, Chief
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Projects Branch 2
Division of Reactor Projects
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Docket No. 50-333
cc:
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C. Rappleyea, Chairman and Chief Executive Officer
R. Schoenberger, President and Chief Operating Officer
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W. J. Cahill, Jr., Chief Nuclear Officer
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H. P. Salmon, Jr., Vice President of Nuclear Operations
W. Josiger, Vice President - Engineering and Project Management
J. Kelly, Vice President - Regulatory Affairs and Special Projects
T. Dougherty, Vice President - Nuclear Engineering
R. Deasy, Vice President - Appraisal and Compliance Services
R. Patch, Director - Quality Assurance
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G. Goldstein, Assistant General Counsel
C. Faison, Director, Nuclear Licensing
T. Morra, Executive Chair, Four County Nuclear Safety Committee
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9610290091 961022
ADOCK 05000333
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0FFICIAL RECORD COPY
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Harry P. Salmon, Jr.
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cc w/ copy of Licensee's Response Letter:
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Supervisor, Town of Scriba
C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
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P. Eddy, Director, Electric Division, Department of Public Service, State
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of New York
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G. T. Goering, Consultant, New York Power Authority
J. E. Gagliardo, Consultant, New York Power Authority
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F. William Valentino, President, New York State Energy Research
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and Development Authority
J. Spath, Program Director, New York State Energy Research
and Development Authority
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Harry P. Salmon, Jr.
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Distribution w/ copy of Licensee's Response Letter:
D. Screnci, PAO
W. Dean, OEDO (WMD)
S. Bajwa, NRR
K. Cotton, NRR
D. Hood, NRR
M. Campion, RI
R. Correia, NRR
R. Frahm, Jr., NRR
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Nuclear Safety Information Center (NSIC)
PUBLIC
NRC Resident inspector
Region i Docket Room (with concurrences)
Inspection Program Branch, NRR (IPAS)
R. Barkley, DRP
R. Junod, DRP
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DOCUMENT NAME: G:\\ BRANCH 2\\RL9605.FTZ
To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure
"E" =
Copy with attachment / enclosure
"N" = No copy
OFFICE
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NAME,
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RBarkley
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DATEyf 10/Sk96
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10/y)/96
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OFFICIAL RECORD COPY
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Jirn
. AtiPatrick
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Nucittr Pow:r PI:nt
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P O Box 41
Ly:cmng New York 13093
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315 342 3840
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Michael J. Colomb
& Authonty
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September 25, 1996
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U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
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Mail Station P1-137
Washington, D.C. 20555
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SUBJECT:-
James A. FitzPatrick Nuclear Power Plant
Docket No. 50-333
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Reply to Notice of Violation
NRC Insoection Reoort 50 333/96-05
Gentlemen:
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in accordance with the provisions of 10 CFR 2.201, Notice of Violction the Authority
submits a response to the notice transmitted by your letter dated August 21,1996. Your
letter refers to the results of the integrated inspection conducted from June 2,1996 to
July 27,1996 at the James A. FitzPatrick Nuclear Power Plant.
Attachment I provides the description of the violations, reason for the violations, the
corrective actions that have been taken and the results achieved, corrective actions to be
taken to avoid further violations, and the date of full compliance.
Attachment 11 provides a summary of the commitments contained in this submittal.
If you have any question, please contact Mr. Arthur Zaremba at (315) 349-6365.
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Very truly yours,
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MICHAEL J. COLOMB
STATE OF NEW YORK
COUNTY OF OSWEGO
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Subscribed and sworn to before me
this A 5
day of (blac 1996
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NOTAlpf' PUBi.lG'
cc:
next page
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cc:
Regional Administrator
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U.S. Nuclear Regu!atory Commission
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475 Allendale Road
King of Prussia, PA 19406
Office of the Resident inspector
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U.S. Nuclear Regulatory Commission
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P.O. Box 136
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Lycoming, NY 13093
Ms. K. Cotton, Acting Project Manager
Project Directorate 1-1
Division of Reactor Projects-l/Il
U.S. Nuclear Regulatory Commission
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Mail Stop 14 B2
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Washington, DC 20555
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Attachments:
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1.
Reply to Notice of Violation
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11.
Summary of Commitments
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Attachmint l
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Reply to Notice of Violation 96-05
VIOLATION A
Technical Specification 6.2.2.6 requires that administrative procedures shall be developed
and implemented to limit the working hours of unit staff who perform safety-related
functions; e.g., senior reactor operators, health physicists, auxiliary operators, and
maintenance personnel who are working on safety-related systems. Requirements,in part,
include that an individual should not be permitted to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any
seven day period, all excluding shift turnover time. In addition, any deviation from the
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above guidelines shall be authorized by the Site Executive Officer or the General Manager -
Operations or higher levels of management,in accordance with established procedures and
with documentation of the basis for granting the deviation.
Contrary to the above, in February and March 1996, the requirements to limit the working
hours of unit staff who perform safety-related functions were not met in that a radiological
protection worker and a maintenance planner exceeded the 72-hour work limitation during
a seven day period without appropriate authorization for the deviation from overtimo
guidelines.
This is a Severity Level IV Violation (Supplement 1).
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ADMISSION OR DENIAL OF THE ALLEGED VIOLATION
The Authority agrees with this violation.
REASONS FOR THE VIOLATION
The cause for the violation was a misinterpretation of the overtime requirements provided
in JAF's Administrative Procedure.
Administrative Procedure AP-11.03," Control of Overtime", which provides the policy and
standards with respect to restrictions of hours worked, was written consistent with
Technical Specification requirements. However, the procedure guidance on restrictions to
overtime usage allowed plant staff the opportunity for misinterpretation of the " seventy-
two (72) hours in any seven (7) day period", overtime work limit. The error involved
establishing overtime limits based on a seven (7) day period rather than viewing total
overtime hours worked over any one-hundred sixty-eight (168) hour period. This resulted
in an incorrect application of the overtime policy.by plant personnel and the subsequent
violation of Technical Specification requirements.
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Attachm:nt i
Reply to Notice of Violation 96-05
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VIOLATION A (cont.)
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
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Following discovery of the misapplication of the overtime policy, the Plant Manager
conducted a special meeting with Department Managers to brief them on the
conditions identified and instructed Managers on the correct applications for
establishing overtime limits consistent with Technical Specifications requirements.
Department managers conducted training sessions with department supervisors to
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review and reinforce Technical Specification and Administrative Procedure policies
governing the use of, and the restrictions placed on, overtime applications,
Tailgate meetings were conducted with department personnel to review and
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reinforce JAF's policies and rules governing the use and restrictions placed on
overtime. The meetings communicated management's expectations that the
requirements of Administrative Procedure AP-11.03 are to be conservatively
managed by supervision and the worker. The meeting reviewed the procedural
steps to be followed in the event special work evolutions require individuals to
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deviate from the prescribed overtime limits.
Administrative Procedure AP-11.03," Control of Overtime", was revised to provide
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clarification regarding restrictions to overtime usage, specifically, stating overtime
hourly limits as any seven (7) day,168 hour0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> period.
RESULTS ACHIEVED
The above actions increased awareness, sensitivity and understanding of the overtime
policies by personnel at the James A. FitzPatrick Nuclear Power Plant.
CORRECTIVE ACTIONS TO BE TAKEN
A case study of the details associated with this violation will be included in the
Training Department's Technical Supervisor Selection and Development (T.S.S.D.)
course. The course is designed to promote various potential supervisory position
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candidates. The inclusion of this case study into the program will provide future
supervisors an understanding of the plant's administrative policies and rules
governing the use of overtime at JAF. Scheduled completion is 1/31/97.
A Quality Assurance Department audit is being conducted to review overtime
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practices used during a recent short duration plant outage which involved overtime
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usage. Audit results will pcovide a measure of assurance that overtime policies are
being correctly implemented. The audit is scheduled for completion by 10/15/96.
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Attachm;nt I
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Reply to Notice of Violation 96-05
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VIOLATION A (cont.)
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance was achieved on July 16,1996 following the Plant Manager's meeting
with the Department Managers to instruct Managers on the correct application for
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establishing overtime limits consistent with Technical Specification requirements.
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VIOLATION B
Technical specification 6.8.(A)1 requires that written procedures and administrative
policies shall be established, implemented and maintained that meet or exceed the
requirements and recommendations of Sections 5 of American National Standards Institute
(ANSI) 18.7-1972 " Facility Administrative Policies and Procedures." Section 5 of ANSI
18.7-1972Property "ANSI code" (as page type) with input value "ANSI</br></br>18.7-1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. requires, in part, that instructions shall be established for returning equipment
to its normal operating status. Administrative Procedure 12.01, " Equipment and Personnel
Protective Tagging", provides instructions to maintain equipment status control.
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Contrary to the above, on July 9,1996, the NRC identified that requirements for
maintaining equipment status control were not met in that the "D" emergency diesel
generator jacket water cooler outlet valve was found to be full open vice the required
throttled four (4) turns closed, and on July 11,1996, the Control Room refrigeration water
chilled water pump 9B was in pull to lock vice a normal standby condition. Therefore the
equipment was not returned to normal operating status following maintenance previously
performed on this equipment.
This is a Severity LevelIV Violation (Supplement 1).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION
The Authority agrees with this violation.
REASONS FOR THE VIOLATION
The cause for the violation involving the out of position Emergency Diesel Generator jacket
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water cooler outlet valve 46ESW-5D was personnel error. The operator assigned the
position of Controller, who was responsible for specifying the equipment restoration
sequence following the system outage, did not ensure the released valve position matched
the position specified in the system valve lineup.
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Attachmont I
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Reply to Notice of Violation 96-05
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ylOLATION B (cont.)
REASONS FOR THE VIOLATION (cont.)
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The cause for the incorrect equipment line up of the Control Room Ventilation System was
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an inadequate procedure. The FSAR states that "if the normal operating chiller fails and
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the room ambient temperature reaches 98 degrees F, the spare air handling unit supply fan
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will start. This will start its associated chilled water pump and the chiller unit. Thus, the
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complete spare air handling unit will start." Operating Procedure OP-55A, " Control and
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Relay Room Refrigeration Water Chiller" addressed the startup and shutdown of chiller
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units, but did not address the standby condition as mentioned in the FSAR. For the
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shutdown sequence of the chiller unit, the procedure directed the operator to place the
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Control Room chiller switch in the off position and to place the chilled water pump switch
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in pull-to-lock position. The reserve chiller unit standby condition had never been
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addressed in the operating procedure and had never been questioned.
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CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
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An audit of Protective Tagging Record (PTR) release positions was performed to
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obtain assurance that the specified release positions for PTRs since the last Refuelf
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Outage are in accordance with the operating procedure valve lineups. Audit results
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identified a normally open RHR pump seal cavity drain valve 10RHR-23C to have
been left closed during a PTR restoration. The drain valve was restored to its
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normal open position. The audit found no other components out of the correct
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position.
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The Controllers responsible for entering the incorrect release position for valves
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46ESW-5D and 10RHR-23C on the PTR clearance forms have been counseled.
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A review of the safety significance of (1) valve 46ESW-50 being in the full open
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position vice the correct position of throttled 4 turns: (2) Control Room refrigeration
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water chilled pump 98 control switch being in pull-to-lock position versus standby
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position; and (3) valve 10RHR-23C being closed vice open was completed. The
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results of this review concluded that the mispositioning of these components had
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negligible system performance impact.
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Administrative Procedure AP-12.01," Equipment and Personnel Protective Tagging"
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has been revised to add the requirement that all PTR release positions be
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independently verified by another qualified individual prior to protective tagging
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restoration.
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Operating Procedure OP 55A was revised to reflect FSAR requirements that the
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redundant Control Room Ventilation train not in service be in a standby line up.
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Attachment I
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Reply to Notice of Violation 96-05
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VIOLATION B (cont.)
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont.)
An FSAR versus Operating Procedure review was completed to verify that when
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the " standby" operating condition for redundant equipment is described in the
plant's Final Safety Analysis Report, plant procedures reflect this requirement. The
remaining operating procedures contained correct standby requirements.
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The events associated with this violation were placed into an Operations
Department briefing package for review with all department personnel. The
Operations Department Manager reinforced expectations regarding recent human
performance issues, including those related to this event, with all Shift Managers.
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The need for attention-to-detail, a questioning attitude, and prompt follow-up of
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concerns brought to the attention of Operations Department personnel was
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reinforced by Shift Managers with Operations Department shift personnel.
Additionally, these events have been submitted for inclusion into the biennial
operator PTR training module.
RESULTS ACHIEVED
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A generalimprovement in operator awareness and the maintaining of a questioning
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attitude has been observed. The FSAR versus Operating Procedure reviews have provided
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assurance that similar procedure deficiencies do not exist.
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CORRECTIVE ACTIONS TO BE TAKEN
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A summary of recent equipment status control issues will be developed and
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presented to plant personnel to reinforce expectations in this area. This action will
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be completed prior to the plant's Fall 1996 refuel outage.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance was achieved on August 3,1996 following the proper positioning of
valves 46ESW-5D and 10RHR 23C, the procedure change to OP-55A, and the corrected
equipment line up for the Control Room Ventilation S' stem.
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Attachm:nt ll
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Reply to Notice of Violation 96-05
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Summary of Commitments
Number
Commitment
Due Date
J AFP-9 6-0377-01
A case study of the details associated with this
01/31/97
violation will be included in the Training
Department's Technical Supervisor Selection and
Development (T.S.S.D) course. The course is
designed to promote various potential
supervisory position candidates. The inclusion of
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this case study into the program will provide
future supervisors an understanding of the
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plant's administrative policies and rules
governing the use of overtime at JAF.
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JAFP-96-0377-02
A Quality Assurance Department audit is being
10/15/96
conducted to review overtime practices used
during a recent short duration plant outage
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involving overtime usage. Audit results will
provide a rneasure of assurance that overtime
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policies are being correctly implemented.
J AFP-96-0377-03
A summary of recent equipment status control
10/26/96
issues will be developed and presented to plant
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personnel to reinforce expectations in this area.
This action will be completed prior to the plant's
Fall 1996 refuel outage.
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