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Ack Receipt of in Response to & NOV Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-333/96-05
	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)
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l- October 22, 1996 i

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Mr. Michael J. Colomb '

Plant Manager

l New York Power Authority

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James A. FitzPatrick Nuclear Power Plant !

Post Office Box 41

Lycoming, NY 13093

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Dear Mr. Colomb: 1

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Subject: NRC Inspection Report No. 50-333/96-05 and Notice of Violation

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l This letter refers to your September 25,1996 correspondence, in response to our !

I August 21,1996 letter. I

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.

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Your cooperation with us is appreciated.

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l Sincerely,

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Original Signed by:

Curtis J. Cowgill, Chief l

Projects Branch 2 I

Division of Reactor Projects

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Docket No. 50-333

cc:

l C. Rappleyea, Chairman and Chief Executive Officer

R. Schoenberger, President and Chief Operating Officer ;

l W. J. Cahill, Jr., Chief Nuclear Officer '

l 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 i

R. Deasy, Vice President - Appraisal and Compliance Services

R. Patch, Director - Quality Assurance

! G. Goldstein, Assistant General Counsel

C. Faison, Director, Nuclear Licensing

T. Morra, Executive Chair, Four County Nuclear Safety Committee I

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9610290091 961022

PDR ADOCK 05000333

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0FFICIAL RECORD COPY IE:01

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j Harry P. Salmon, Jr. 2

cc w/ copy of Licensee's Response Letter: l

Supervisor, Town of Scriba

C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law

l P. Eddy, Director, Electric Division, Department of Public Service, State

l of New York

j G. T. Goering, Consultant, New York Power Authority

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J. E. Gagliardo, Consultant, New York Power Authority

l F. William Valentino, President, New York State Energy Research

! and Development Authority

J. Spath, Program Director, New York State Energy Research

and Development Authority

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Harry P. Salmon, Jr. 3

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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 .

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" = l

Copy with attachment / enclosure "N" = No copy

OFFICE Rl/DRP p, Rl/DRP () gg

NAME, RFernandes &p RBarkley (( ,

DATEyf 10/Sk96 'l

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10/y)/96 'l

i OFFICIAL RECORD COPY

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Jirn . AtiPatrick

Nucittr Pow:r PI:nt

l P O Box 41

. Ly:cmng New York 13093

315 342 3840

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> NewYo.rkPower Michael J. Colomb

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& Authonty

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eiemi a cege,

September 25, 1996 i

JAFP-96-0377 I

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U.S. Nuclear Regulatory Commission j

ATTN: Document Control Desk J

Mail Station P1-137

Washington, D.C. 20555

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SUBJECT:- James A. FitzPatrick Nuclear Power Plant !

Docket No. 50-333 ,

Reply to Notice of Violation l

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. I

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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.

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Attachment 11 provides a summary of the commitments contained in this submittal. l

If you have any question, please contact Mr. Arthur Zaremba at (315) 349-6365. !

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Very truly yours,

\.O b k - '

MICHAEL J. COLOMB

STATE OF NEW YORK

COUNTY OF OSWEGO )

Subscribed and sworn to before me

this A 5 day of (blac 1996

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NOTAlpf' PUBi.lG'

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Regional Administrator :

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U.S. Nuclear Regu!atory Commission

475 Allendale Road

King of Prussia, PA 19406

Office of the Resident inspector

i U.S. Nuclear Regulatory Commission

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P.O. Box 136

i Lycoming, NY 13093

Ms. K. Cotton, Acting Project Manager

Project Directorate 1-1

Division of Reactor Projects-l/Il

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U.S. Nuclear Regulatory Commission

3 Mail Stop 14 B2

Washington, DC 20555

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Attachments:

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l 1. Reply to Notice of Violation

Summary of Commitments t

i 11.

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Attachmint l l

.' 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any

seven day period, all excluding shift turnover time. In addition, any deviation from the ,

above guidelines shall be authorized by the Site Executive Officer or the General Manager - l

Operations or higher levels of management,in accordance with established procedures and l

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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6 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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e 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.

e Department managers conducted training sessions with department supervisors to

review and reinforce Technical Specification and Administrative Procedure policies

governing the use of, and the restrictions placed on, overtime applications,

e Tailgate meetings were conducted with department personnel to review and

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.

e Administrative Procedure AP-11.03," Control of Overtime", was revised to provide

clarification regarding restrictions to overtime usage, specifically, stating overtime

hourly limits as any seven (7) day,168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months 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

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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.) I

course. The course is designed to promote various potential supervisory position !

candidates. The inclusion of this case study into the program will provide future l

supervisors an understanding of the plant's administrative policies and rules

governing the use of overtime at JAF. Scheduled completion is 1/31/97. !

e A Quality Assurance Department audit is being conducted to review overtime

practices used during a recent short duration plant outage which involved overtime 1

usage. Audit results will pcovide a measure of assurance that overtime policies are !

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being correctly implemented. The audit is scheduled for completion by 10/15/96.

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Attachm;nt I

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

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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

18.7-1972 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. l

This is a Severity LevelIV Violation (Supplement 1).

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION

The Authority agrees with this violation.

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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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i Attachmont I

a Reply to Notice of Violation 96-05 .

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I ylOLATION B (cont.)

REASONS FOR THE VIOLATION (cont.)

! The cause for the incorrect equipment line up of the Control Room Ventilation System was

3 an inadequate procedure. The FSAR states that "if the normal operating chiller fails and

! the room ambient temperature reaches 98 degrees F, the spare air handling unit supply fan

i will start. This will start its associated chilled water pump and the chiller unit. Thus, the i'

complete spare air handling unit will start." Operating Procedure OP-55A, " Control and

i Relay Room Refrigeration Water Chiller" addressed the startup and shutdown of chiller i

l units, but did not address the standby condition as mentioned in the FSAR. For the ,

' shutdown sequence of the chiller unit, the procedure directed the operator to place the :

I Control Room chiller switch in the off position and to place the chilled water pump switch l

] in pull-to-lock position. The reserve chiller unit standby condition had never been

addressed in the operating procedure and had never been questioned. i

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CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN

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j e 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

i Outage are in accordance with the operating procedure valve lineups. Audit results ,

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i identified a normally open RHR pump seal cavity drain valve 10RHR-23C to have

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been left closed during a PTR restoration. The drain valve was restored to its ,

! normal open position. The audit found no other components out of the correct

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e The Controllers responsible for entering the incorrect release position for valves

l 46ESW-5D and 10RHR-23C on the PTR clearance forms have been counseled. ,

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e A review of the safety significance of (1) valve 46ESW-50 being in the full open

! position vice the correct position of throttled 4 turns: (2) Control Room refrigeration

{ water chilled pump 98 control switch being in pull-to-lock position versus standby

! position; and (3) valve 10RHR-23C being closed vice open was completed. The

l results of this review concluded that the mispositioning of these components had ]

l negligible system performance impact.

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e Administrative Procedure AP-12.01," Equipment and Personnel Protective Tagging"

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i has been revised to add the requirement that all PTR release positions be j

i independently verified by another qualified individual prior to protective tagging

restoration.

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} e Operating Procedure OP 55A was revised to reflect FSAR requirements that the

I redundant Control Room Ventilation train not in service be in a standby line up.

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4 Attachment I

i. Reply to Notice of Violation 96-05

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VIOLATION B (cont.)

CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont.)

e An FSAR versus Operating Procedure review was completed to verify that when

the " standby" operating condition for redundant equipment is described in the

plant's Final Safety Analysis Report, plant procedures reflect this requirement. The

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remaining operating procedures contained correct standby requirements.

e 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

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performance issues, including those related to this event, with all Shift Managers.

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

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

, attitude has been observed. The FSAR versus Operating Procedure reviews have provided

assurance that similar procedure deficiencies do not exist.

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CORRECTIVE ACTIONS TO BE TAKEN .

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e A summary of recent equipment status control issues will be developed and j

presented to plant personnel to reinforce expectations in this area. This action will '

1 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'y stem.

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o Reply to Notice of Violation 96-05

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

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supervisory position candidates. The inclusion of

this case study into the program will provide

future supervisors an understanding of the

i 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

i during a recent short duration plant outage

involving overtime usage. Audit results will

provide a rneasure of assurance that overtime 1

j policies are being correctly implemented.

J AFP-96-0377-03 A summary of recent equipment status control 10/26/96

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issues will be developed and presented to plant

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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ML20129F304

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