ML20137G873

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-333/97-07 & Expresses Appreciation for Clarifying & Expanding on Corrective & Preventive Actions Documented in Previous Ltr

ML20137G873
Person / Time
Site:	FitzPatrick
Issue date:	03/26/1997
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 9704010563
Download: ML20137G873 (4)

See also: IR 05000333/1997007

Text

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March 26, 1997 -

Mr. Michael J. Colomb

Plant Manager

New York Power Authority

James A. FitzPatrick Nuclear Power Plant

Post Office Box 41

Lycoming, NY 13093

Dear Mr. Colomb: '

Subject: NRC Inspection Report No. 50-333/96-07 and Notice of Violation  ;

This letter refers to your February 21,1997 correspondence, in response to our  ;

December 13,1996 letter and followup conversations as documented in our letter dated  :

February 24,1997. l

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Thank you for clarifying and expanding on the corrective and preventive actions

documented in your previous 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,

Original Signed by: ,

Curtis J. Cowgill, Chief

Projects Branch 2

Division of Reactor Projects ,

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Docket No. 50-333

cc: .

C. Rappleyea, Chairman and Chief Executive Officer '

R. Schoenberger, President and Chief Operating Officer ,

J. Knubel, Chief Nuclear Officer and Senior Vice President i

H. P. Salmon, Jr., Vice President of Nuclear Operations l

W. Josiger, Vice President - Engineering and Project Management

J. Kelly, Director - Regulatory Affairs and Special Projects j

, T. Dougherty, Vice President - Nuclear Engineering i1

I R. Deasy, Vice President - Appraisal and Compliance Services l l

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l R. Patch, Director - Quality Assurance  ; l

G. Goldstein, Assistant General Counsel '

C. Faison, Director, Nuclear Licensing j

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K. Peters, Licensing Manager >

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T. Morra, Executive Chair, Four County Nuclear Safety Committee gigpIRlIllplB!Ill '

9704010363 970326

PDR ADOCK 03000333

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0FFICIAL RECORD COPY IE:01 ,

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Michael J. Colomb 2 '

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Supervisor, Town of Scriba

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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 i

of New York ,

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

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

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E. S. Beckjord, Consultant, New Yo ! Power Authority  :

, F. William Valentino, President, Now York State Energy Research

and Development Authority j

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

! and Development Authority l

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Distribution w/ copy of Licensee's Response Letter

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D. Screnci, PAO

W. Dean, OEDO (WMD)

S. Ba}wa, NRR

, K. Cotton, NRR

, D. Hood, NRR

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M. Campion, RI ,

R. Correia, NRR

D. R. Taylor, NRR

L. Cunningham, NRR

D. Barss, NRR

Nuclear Safety information Center (NSIC)

PUBLIC

NRC Resident inspector

Region i Docket Room (with concurrences)

-Inspection Program Branch, NRR (IPAS)

C. Cowgill, DRP

R. Barkley, DRP

R. Junod, DRP

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DOCUMENT NAME: A:\RL9607.FTZ l

'Sas previous concurrences

To receive e copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No copy  ;

OFFICE * Rl/DRP * Rl/DRP 'Rl/DRP

NAME GHunegs/RSB for RBarkley/RSB CCowgill/CJC I

DATE 3/26/97 3/26/97 3/26/97

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OFFICIAL RECORD COPY

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Michael J. Colomb 3

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Distribution w/ccpy of Licensee's Response Letter:

D. Screnci, PAO

} W. Dean, OEDO (WMD)

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S. Bajwa, NRR

K. Cotton, NRR '

D. Hood, NRR

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M. Campion, R1

R. Correia, NRR

l D. R. Taylor, NRR

L. Cunningham, NRR

D. Barss, NRR

Nuclear Safety information Center (NSIC) ,

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NRC Resident inspector

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Region i Docket Room (with concurrences) i

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inspection Program Branch, NRR (IPAS)

, R. Barkley, DRP *

R. Junod, DRP

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DOCUMENT NAME: G:\ BRANCH 2\RL9606.FTZ l

To rxeive 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 n , ,l _ Rl/DRP [)/[/ PadRFf/p '

NAME GHunegs/R$ ji/ ,

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RBarkley /J'ffj_ CCowgill ~

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DATE 3 #/97 /AgqL. 3hk97 /'F 3/7/97

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OFFICIAL RECORD COPY I

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• Jam;s A. FitzPatrick

Nucl3tr Pow;r Ptint

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uc:mir; '.e* v <k 13093

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February 21, 1997

JAFP-97-0061

U.S. Nuclear Regulatory Commission l

ATTN: Document Control Desk '

Mail Station P1-137 i

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Washington, D.C. 20555

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SUBJECT: James A. FitzPatrick Nuclear Power Plant

Docket No. 50 333 .

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Revision to Reply to Notice of Violation

NRC Inspection Report 50-333/96-07

Reference: JAFP-97-0018, from M. J. Colomb to USNRC, Reply to Notice of i

Violation, NRC Insoection Reoort 50-333/96-07.  :

. Gentlemen:

This letter is being submitted to revise corrective actions for Violation A and Violation C

previously submitted in reply to Notice of Violation as referenced above.

In accordance with the provisions of 10 CFR 2.201. Notice of Violation. the Authority

submits a response to the notice transmitted by yotit letter dated December 13,1996.

Your letter refers to the results of the integrated inspection conducted from September 29,

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1996 through November 16,1996 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.

In addition to the corrective actions described in the attachment, in an effort to continue

improvement in all aspects of operation at the James A. FitzPatrick Nuclear Power Plant, a

team of line personnel was formed to evaluate human performance related events at the

site. Corrective actions developed by the team will be implemented to ensure continued

performance improvement. To address the lack of rigor and weaknesses in engineering

activities, an improvement plan is being developed. Both of these efforts are part of the

FitzPatrick Business Plan.

There are no commitments contained in this submittal.

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

Very truly yours,

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STATE OF NEW YORK

k COUNTY OF OSWEGO

MICHA L J. COLOMB Subscribed and sworn to before me

this c2/ day of Feb ,1997

- $b>ok.0LbAls>

MJC:GB:las ROTAff PUBLfC NANCY B.CZEROW

cc: next ;1 age Notary Public, State of New York

ouellflod in Oswego County #4484611 ;

Commlealon Expires /- & G j

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cc: R:gion:1 Administrator

', U.S. Nucirtr Rigulatory Ccmmission ,

475 Allendale Road l

King of Prussia, PA 19406 l

Office of the Resident inspector

U.S. Nuclear Regulatory Commission

P.O. Box 136

Lycoming, NY 13093

Ms. K. Cotton, Acting Project Manager

Project Directorate 11

Division of Reactor Projects l/II

U.S. Nuclear Regulatory Commission

Mail Stop 14 B2

Washington, DC 20555

Attachments:

1. Reply to Notice of Violation

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! Attachm:nt 1

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Renly to Notice of Violation 9647

Violation A

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Technical Specification 6.8.(A) requires that written procedures and administrative policies

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shall be estabWshed, implemented and maintained that meet or exceed the requirements

i and recommendations of Section 5 of American National Standards Institute (ANSI) 18. 7-

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1972 'FaciNty Administrative Policies and Procedures. " Section 5.1.2 of ANSI 18.7-1972

i states in part, that procedures shallbe followed, and the requirements for use of

I procedures shallbe prescribedin writing. MP-004.03, CRO Removaland Replacement,

l describes removal and rei;!scemsnt of control rod drives (Crus). The procedure requires

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that all CROs to be removed are accurately located and readily identified (marked) prior to

removal. l

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Contrary to the above, on November 11,1996, during the work preparation phase, CRDs

l to be removed were not accurately located prior to removal which resultedin the incorrect l

removalof three CROs.  :

i This is a Severity LevelIV Violation (Supplement 1).

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l Admission pr Dorial of the Alleged Violatiq0 1

Tiie Authority agrees with this violation. ,

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l Reasons for the Violation

} The cause for this violation war personnel error. The performance factors leading to these

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errors were: ,

j e inadequate training and qualification. The contract supervisor assigned the duties

associated with Control Rod Drive (CRD) replacement at FitzPatrick during the

i plant's Refuel Outage 12 did not have the proper training or experience to

j accurately locate and identify the correct CRDs prior to removal.

! e ineffective worker practices. The contract supervisors overseeing the CRD

! removal / replacement activities did not effectively utiize self-checking or second

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verification techniques to ensure the CRDs were correctly labeled. Additionally, i

i numerous opportunities arose during the CRD work evolution where work should

i have been stopped by both the contractor and the Power Authority because of  ;

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! abnormal or unexpected conditions.

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j e Pcc: wmdsory oversight and methods. The Authority did not provide an  ;

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e appropriate level of management or supervisory oversight of the job.

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Attachment i

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j Realv to.Notica of violation 96-07

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l e Poor written procedures and documents. The written procedure provided by the

! Authority to the contractor was inadequate and did not contain steps for

2 verification of crucial work evolutions (i.e., selection of the correct CRD).

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Additionally, the core map was not part of the work procedure. The core map

could have contained additional reference points such as nuclear instruments.

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! Corse.i;; Ac*tma That Have Been Tam

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l e The Authority revoked the contract supervisor's task qualification certification.

l e The Authority assigned Senior Nuclear Managers to oversee the remainder of the

1 CRD mechanism changeout once work was stopped.

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l e immediately following this event, a memorandum titled "NYPA Responsibilities For

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Contractors" was issued by the Plant Manager to all departments re-emphasizing

? obligations when using contract personnel at FitzPatrick. The accountability and

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responsibility for the quality of work performed by contract personnel belongs to

i the Authority. Expectations including work oversight, quality, questioning attitude,

l and open communication was stressed.

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l e A case study was completed to review and identify opportunities during the CRD

1 replacement evolution where personnel directly involved could have, but failed to

! take a questioning attitude and stop work. The case study was enhanced with

l management expectations at each opportunity. The case study was then presented

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to the appropriate plant staff.

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I Results Achieved

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l The Authority believes the corrective actions taken were effective in preventing

! recurrence. A heightened awareness of the issues relating to the causes for this violation

has been achieved. The Authority will continue to reinforce the importance of maintaining

! a questioning attitude, performing self verification and applying the appropriate level of

management oversight.

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I Corrective Actions To Be Tom

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j e Maintenance Procedure MP-OO4.03, "CRD Removal and Replacement" will be

revised to incorporate a map with reference points and verification steps to ensure

that the correct CRD unit is initially identified and assure the correct CRD unit is

l identified during ensuing steps when opportunities for selecting the wrong drive

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! exists. (Scheduled Completion Date - 06/30/97) j

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I e Guidelines will be proceduralized to give management expectations regarding

oversight of contract personnel assigned duties at FitzPatrick. The procedure will

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also include obligations and responsibilities as outlined in "NYPA Responsibilities For

4 Contractors". (Scheduled Completion Date - 06/30/97)

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Data Er. Ftd t'r"-we WlE Be Achieved

Full compliance was achieved on 11/15/96 following issuance of the Plant Manager's

memorandum affirming the Authority's responsibility for the quality of all work performed j

at FitzPatrick.

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Attachm:nt I

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Renly to Notice qf Violation 96 07

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Violation R

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10 CFR Part 50, Appendix B, Criterion 111, " Design Control," requires that the design basis

shall be correctly translated into specifications, drawings, procedures, and instructions:

that the adequacy of the design be verified; and that design changes be subject to design

i control measures.

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j Contrary to the above, on and before October 25,1996, the design basis was not

, correctly translated into procedures, the adequacy of design was not verified, and design

changes were not subjected to design control measures, as evidenced by the following

examples:

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(1) Unverified engineering judgement regarding design calculations JAF-CALC-ELEC-

00426 and JAF-CALC ELEC OO427 erroneously equated spare battery capacity

j with voltage at safety-related components.

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l (2) Electricalload added to safety related station battery calculations JAF-CALC-ELEC-

01417 and JAF-CALC-ELEC-01418 was not consistent with the load specified in

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Modification F1-89-158.

(3) Unverified engineering judgement concerning calculation JAF-CALC-HPCI-OO840

was used to conclude that air injection would not affect high pressure coolant

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injection pump operability.

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i (4) An incorrect assumption was made in calculation JAF-CALC-DHR-03445 that a

non-safety related component could be assumed as a limiting single failure.

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(5) An unverified assumption was made in calculation JAF-CAL-DHR-02380 that a

l plate heat exchanger could be modeled as a shell and tube heat exchanger.

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j This is a Severity Level IV violation (Supplement 1).

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Admission or Denial of the Allegned Violation

The Authority agrees with the violation. However, after review of pertinent data for cited i

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example 2, the Authority determined that battery calculations JAF-CALC-ELEC-01417 and

JAF-CALC-ELEC-01418 are consistent with the final calculations for modification F1-89-

158 and that no deviation exists.

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I Attachm:nt I s

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! Recly to Notice of Violation 98-07

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l Reasona for the Violation

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The cause for the violation was personnel error. The performance factors contributing to i

! this were:

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e inadequate training. For example 1, personnel assigned responsibilities for

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preparation and review of the battery calculations (JAF-CALC-ELEC-00426 and

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JAF-CALC-ELEC-OO427) did not exhibit rigor in verifying the assumption that

equated spare battery capacity with voltage. For example 4, personnel assigned

' responsibilities for preparation and review of the flooding analysis (calculation JAF-

j CALC-OHR-03445) demonstrated inadequate understanding of the application of

single failure criteria.

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e Weak supervisor / managerial methods. For examples 3 and 5, the expectations for

, documenting engineering judgement and unverified assumptions had not been

adequately communicated to the individuals responsible for preparing the

calculations.

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i Corrective Actions That Have Been Taken

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e An operability assessment was performed to review the adequacy of the unverified

judgement against station batteries A and B. The assessment confirmed that A and

B station batteries were operable. New calculations were prepared which properly

documented the basis for the station battery modified performance test. As a

conservative measure to assure adequate capacity exists for the long term,

Modification M1-96-078, Revision 1, was implemented which added two cells to

each station battery.

o Calculation JAF-CALC-HPCI-00840 was revised to state that NUREG-0897,

Revision 1, " Containment Emergency Sump Performance" was used as a basis for

vortex limit determination. The revised calculation also ine.luded the discussion with

the pump vendor which confirmed the use of the NUREG-0897 vortex limit is

appropriate.

• A review of calculation JAF-CALC-DHR-03445 was performed to confirm that no

safety-related components were affected as a direct consequence of the postulated

piping failure,

o Calculation JAF-RPT-DHR-02535, Revision 0, was developed and approved on

10/24/98. This calculation validated the use of the GOTHIC code used for the

specific Decay Heat Removal System application. The use of the GOTHIC

simulation of a shell and tube heat exchanger in place of a plate heat exchanger as

eva6uated in calculation JAF CALC-DHR-02380 was found to be acceptable,

o This violation, its causes, lessons leamed, and management expectations were

discussed with Design Engineering personnel at a depsrtmental tailgate meeting.

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Attxhment l

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Renly to Notice of Violation 96-07

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Results Achieved

i The Authority believes the above corrective actions were successfulin resolution of the

! conditions identified in the violation and will be effective in preventing recurrences.

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Corrective Actions To Be Taken

i e Design Engineerine Action Plan JDED-APL-96-018 was developed to track

! additional improvements with the DC systems' design calculations and surveillance

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tests. (Scheduled Completion Date - 06/30/97)

I e Engineering Procedure DCM-2, " Preparation and Control of Manual Calculations and

4 Analysis" will be reviewed, and revised if necessary, to assure appropriate design

i controls and processes related to rigor, verification and engineering judgement are

i included. T raining will be conducted with Design Engineering to reinforce and

ensure management expectations regarding documentation of engineering

) judgement are clesrly understood. (Scheduled Completion Date - 04/30/97)

{ e Training on the requirements of DCM-14, " Preparation and Control of Computer

Generated Calculations" will he performed to increase staff sensitivity to the

process for utilizing and centrolling computer generated calculations and analysis.

l (Scheduled Completion Date - 03/31/97)

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o This violation will be entered into the Engineering Support Personnel (ESP) Training

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Program to provide Technical Support staff with lessons learned from this event.

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(Scheduled Completion Date 03/01/97)

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e Calculation JAF-CALC-OHR-03445 will be revised to correct the application of

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j single failure criteria. (Scheduled Completion Date 03/01/97)

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l Date When Fd Comaliance Will Be Achieved

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! The Authority has been in compliance with 10 CFR 50, Appendix B, Criterion ill since the

identification, review and verification of the above conditions found no inadequacies in

plant design. This conclusion is based on: for example 1, when the new calculation was

prepared which properly documented the basis for the A and B station battery modified

performance test; for example 3, the revision to the calculation and confirmation by the

pump manufacturer that the vortex information in calculation JAF-CALC HPCI-00840 is

acceptable; for example 4, the review of calculation JAF-CALC DHR-03445 confirmed that

no safety-related components are affected by the postulated piping failure; and for

example 5, calculation JAF-CALC-OHR-02380 being performed and validating that the

GOTHIC code used was acceptable.

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, Attochment I l

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Reniv_tn_ Notice of Violation 96-07.

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Violatien.G

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10 CFR Part 50, Appendix B, Criterion XI, " Test Control,' requires written test procedures

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which incorporate acceptance limits contained in applicable design documents.

Contrary to the above, on and before October 25,1996, surveillance procedures did not

incorporate the acceptance limits containedin applicable design documents, as exemplified

by the following:

(1) Instructions in Work Request 94-02935-00, dated April 21,1994, did not contain

sufficient guidance to ensure that voit meters of appropriate accuracy and precision

were used to measure voltage between the reactor protection system electrical

protection assemblies and their respective power panels.

(2) Acceptance criteria in survcillance procedure ST 2X, 'RHR Service Water Flow

Rate, ' did not incorporate acceptance limits contained in applicable design

documents by not accounting for instrument error associated with measuring

required flow to the residual heat removal system heat exchangers.

(3) Acceptance criteria in station battery service test procedures MST-071.24, Revision

2 and MST-071.26, Revision 0, ' Modified Station Battery Performance / Service

Test,' did not reflect the minimum battery terminal voltages for acceptable

operation of safety-related equipment specifiedin design calculations JAF-CALC-

ELEC-00426, Revision 1, dated October 16,1992 and JAF-CALC-ELEC-00427,

Revision 0, dated June 4,1992, respectively.

This is a Severity LevelIV violation (Supplement 1).

Admi--% or Denial of the Allened Violation

The Authority agrees with the violation.

Page 6 of 17

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Attachment I

! Realv to Notice of Violation 96-07

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Reasons for the Violation

The cause for this violation was personnel error. The performance factors leading to the

4 three cited examples of design document acceptance limits not incorporated into written

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test procedures were:

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! e inadequate training. The individual responsible for preparing the work instructions

! for Work Request 94-02935-00 did not have an adequate knowledge of the test

i equipment requirements to assure the correct volt meters were identified in the

i work package and that their accuracy was properly considered. The individuals

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responsible for preparing the calculations used to establish the acceptance criteria

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used in station battery service test procedures MST-071.24 and MST-071.26 did

not assure that the results of their calculations were accurately translated to the

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test procedure. Contributing to this was the lack of written guidance for translation

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of the calculation to the test procedure and a lack of a questioning attitude by the

j preparer of the test procedure in establishing the basis for the acceptance criteria.

l e ineffective worker practices. The individuals assigned responsibility for the

preparation and inclusion of acceptance criteria into surveillance test procedure

< "RHR Service Water Flow Rate" did not maintain a questioning attitude. The

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procedure reflected an acceptance limit value contained in the Technical

! Specifications (T.S.). He assumed the T.S. value accounted for instrument error. ,

! The basis for this assumption had not been documented. Contributing to this error  !

was the ineffective corrective actions taken in 1994 when this condition was first )

identified. I

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Corrective Actions That Have Been Taken

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e An operability review was completed for the Reactor Protection System (RPS)

electrical protection assembly (EPA) calibration period. The review determined that

. RPS was operable. In addition, new voltage measurements between the RPS

electrical protection assemblies and their respective power panels have been

l' completed.

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e Calculations were prepared and surveillance test procedures ST-2R, "RHR Service l

l Water Pump and MOV Operability Test" and ST-2X, "RHR Service Water Flow

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Rate" were revised to accurately account for instrument error during test

j measurement evolutions. Additionally, a review was compl9ted of other similar

T.S. surveillance procedures which utilize installed instrumentation to measure test

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data. The review determined that these surveillance test procedures did not require

j change.

e New calculations were prepared to determine the acceptance criteria for the station

- battery service tests. Test procedures MST-071.24 and MST-071.26 were revised

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to include the acceptance criteria.

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Att: chm:nt 1

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Renly to Notice of Violation 96 07

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e An evaluation of other Technical Speedications was performed to confirm that an l

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adequate basis existed for the Technical Specification requirements.

e This violation, its causes, lessons learned, and expectations were discussed with

Design Engineering personnel at a departmental tailgate meeting.

Results Achieved

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l The above listed corrective actic7s were successful in resolving the deficiencies identified

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in the violation. The Authority believes the corrective actions taken will provide increased

awareness of the issues and the causes identified in this violation.

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i Corrective Actions To Be Taken

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i e This violation will be entered into the Engineering Support Personnel (ESP) Training i

j Program to provide Technical Support staff lessons learned from this event. )

!' (Scheduled Completion Date - 03/01/97)

! e Test standards are being developed to assist engineers in selecting proper test

methods. These standards will contain guidance on the proper consideration of

' measurement instrument accuracy. (Scheduled Completion Date - 08/01/97)

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e The Authority is currently engaged in an improved Technical Specifications Project.

The project will ensure that instrument accuracy is considered when specifying the

requirements of the Technical Specifications.

(Scheduled Completion Date - 12/31/97)

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! e The calculation for the RPS/ EPA calibration period will be revised using new

measured voltages. (Scheduled Completion Date - 03/01/97)

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Date When fun Compliance WIN Be Achieved

Full compliance was achieved on 01/16/97 following: (1) the operability assessment and j

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! completion of new RPS/ EPA voltage measurements: (2) the revision to surveillance

l procedure ST-2X; and (3) the revisions to the modified Battery Performance / Service Tests.

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Attachment l l

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} Renly to Notice of Violation 96-07 l

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Violation D

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> 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action,' requires conditions

i adverse to quality such as failures, malfunctions, deficiencies, deviations, defective ,

i material and equipment, and non-conformance be promptly identified and corrected. l

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i Contrary to the above, on and before October 25,1996, conditions adverse to quality

were not promptly identified and corrected, in that; j

b (1) Approximately 54 deviations and deficiencies associated with the Final Safety l

l Analysis Report, calculations, and procedures pertaining to the residualheat i

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remc* al system, identified in the design basis documentation verification program l

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1 (0B0-10) in 1994 were not evaluated for corrective action.

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) (2) Appropriate corrective action related to the calibration frequency was not taken to

correct recurring APRM flow bias flow transmitter calibration failures.

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, This is a Severity LevelIV violation (Supplement I).

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l Admission or Denial of the Alleged Violation

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l The Authority agrees with this violation.  !

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Reasons for the Violation j

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The cause for this violation was personnel error. The performance factor leading to these l

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errors was

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* Poor supervisory methods. Following compilation of the 54 Residual Heat Removal

i (RHR) System DBD identified deviationsideficiencies, adequate controls and '

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oversight were not in place to assure that the deviations were reviewed and

i resolved in a timely manner.

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) * Programs and/or processes did not require prompt resolution to questions involving

i transmitter performance history and instrument calibration failures that had been

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identified during instrument calibration in 1994.

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Attachment i

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Realv to Notice of Violation 96-07

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! Corrective Actions That Have seen T.ekgD

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e The Authority has completed evaluations and system operability reviews of the 54

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identified conditions found during the RHR System DBD review. No operability

concerns were identified. The evaluation determined that 24 issues had been

corrected and subsequently closed. Tne remaining issues have been prioritized and

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• entered into management's corrective action tracking system for resolution.

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! e Responsible design engineers have been assigned to DBDs, as owners, to ensure

accountability for proper maintenance and validity of DBDs.

e I&C engineering has reviewed the performance history of the Flow Bias Transmitter.

l The instrument calibration frequency for the transmitter has been rsduced to 12

j month intervals.

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e This violation, its causes, lessons learned, and management expectations were

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discussed with Design Engineering personnel at a departmental tailgate meeting.

l Baaldfs Achieved  !

i The completed corrective actions were effective in resolving the conditions identified in the

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violation. The Authority believes the corrective actions being taken will be an

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enhancement to the corrective action program.

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Corrective Actions To se Taken

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e A Nuclear Engineering Administrative Procedure NEAP-38, " Design Basis Document

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Validation Procedure" has been developed and is in the review and approval l

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process. This NEAP defines responsibilities and interfaces for the conduct of DBD

validations. These responsibilities include closure of open items. J

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(Scheduled Completion Date - 04/04/97)

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l * The flow bias transmitter parameters will be reviewed to determine the cause(s) for

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i and corrective action (s) to be taken to resolve instrument drift.

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e Administrative Procedure AP-19.01, " Surveillance Testing Program" will be

reviewed to determine the adequacy of the guidance contained in Corrective Action

section of the program. (Scheduled Completion Date - 03/17/97)

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e This violation will be entered into the Engineering Support Personnel (ESP) Training

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Program to provide Technical Support staff with lessons learned from this event.

l (Scheduled Completion Date - 03/01/97)

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Attachment i

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Reniv to Notice of Violation 96-07

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Date When Full Comaliance Will Be Achieved

- Full compliance was achieved 10/18/96 following completion of the operability

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determination for the open DBD items and following calibration frequency change to the

flow bias transmitters to a 12 month cycle to assure instrument reliability.

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Att: chm:nt I

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! Renly to Notice of Violation 96-07

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- Violation E

10 CFR 50.59, ' Changes, tests, and experiments,' permits licensees to make changes to

the facility, as describedin the Sefety Analysis Report, without prior Commission

approval, provided that the proposed changes do not involve a cleange in the technical

specifications or involve an unreviewed safety question. Records of these changes must

include a written safety evaluation which provides the bases for the determination that the

change does not involve an unreviewed safety question. ,

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Section 4.10.3 of the FitzPatrick Final Safety Analysis Report (FSAR) describes the

utilization of the equipment ares temperature monitanng system to detect reactor coolant

pressure boundary leakage outside of the primary containment. Area temperature sensors

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are calibrated with the station in operation with normal ventilation pattems and ambient

' temperature levels to detect a coven gaHon per minute leak. The residual heat removal  !

(RHR) system equipment area temperature detector is shown in FSAR Table 4.10-1,

" Summary ofIsolation/ Alarm of System Monitored and the Leak Detection Methods Used. ' l

Contrary to the above, on or about August 12,1996, a temporary high efficiency

particulate air (HEPA) filter and blower, which could have altered the accuracy of the area

temperature monitoring system, were installedin the 'A ' RHR heat exchanger room, and '

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no safety evaluation was performed and documented to provide the bases for the

determination that the change did not involve an unreviewed safety question. i

This is a Severity LevelIV violation (Supplement I). l

Admission or Denial of the Alleged Violation  ;

The Authority agrees with the violation.

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Reasons for the Violation

The cause for this violation was personnel error. The performance factor leading to this

error was:

e inadequate implementation of a change process. The individual assigned the task

of reviewing the temporary HEPA filteriblower installation for inclusion into the

Temporary Modification process, failed to consider all parameters impacted by the

temporary HEPA exhaust installation in the "A" Residual Heat Removal (RHR)

System Heat Exchanger Room, specifically, the potential effect on the design of the

Steam Leak Detection System (SLDS). This error lead to the decision of not

catagorizing the HEPA installatie as a Temporary Modification. Subsequently, the i

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10 CFR 50.59 safety evaluatic,, review process was not invoked.

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Attachm:nt i

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i Raniv to Notice of Violation 96 07

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Corrective Actions That Have Been Taken

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1 e The Technical Services Department Manager reviewed this event with the

responsible engineer and the engineer's supervisor. Discussed were factors leading

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to the determination that a Temporary Modification was not required, and potential

program weaknesses which may have lead to this conclusion.

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e A Procedure Change Request was initiated to revise Administrative Procedure i

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AP-05.02, " Control of Temporary Modifications", Section 2.0, APPLICABILITY, to

1 include changes which could add or remove heat, or affect the air exchange rate to ,

i plant areas with a potential effect on area equipment design requirements.  !

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e An abstract of this violation was included in the weekly Department Tailgate i

meetings to provided personnel a summary of the event and to increase their ,

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sensitivity on the use of portable ventilation and its potential effects on plant

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dengn.

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e RES Department Procedure RP-RESP-02.15, " Portable Ventilation Systems" has

been revised to include a prerequisite that all portable ventilation systems installed

in SLDS areas will require initiation of a Temporary Modification and a precaution i

statement that removing air from areas monitored by SLDS may render the SLDS

inoperable.

Results Achieved

Actions taken have increased awareness, sensitivity and understanding of the potential

affects that temporary ventilation may have on plant design.

Corrective Actions To Be Taken

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None

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Date Wt.;;; Fud Cc.T "- .cs Wid Be Achieved

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Full compliance was achieved immediately following removal of the temporary HEPA l

filter / blower from the "A" RHR System Heat Exchanger Room.

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j Attachment 1

Recly to Notice of Violation 96-07 1

i Violation F

l' Technical Specification 6.11 requires, in part, that each entry into a posted locked high

radiation area shew be under the control of a radiation work permit (RWP) and that a

i radiation monitoring device which continuously integrates the radiation dose rate in the

( area and alarma when a preset integrated dose is received be utilize. RWP 96-0411 issued

for work in the dryweH requires that each worker wear an alarm dosimeter.

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1 Contrary to the above, on October 30,1996, a contractor entered and workedin the

} dryweH under RWP 96-0411, a posted locked high radiation area, for three hours with his

} alarming dosimeter turned off. i

This is a Severity LevelIV violation (Supplement IV).

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l Admission er Denial of the ANeged Violation ]

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The Authority agrees with the violation.

Reasons for the Violation l

The cause for the violation was personnel error. The performance factor leading to this

error was ineffective worker practices. The contracted maintenance worker did not follow

procedures, did not utilize protective equipment properly, and did not utilize self-checking

to verify that the equipment was operating correctly. j

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Corrective Actions That Have Been Taken

e immediately following the event, a critique was conducted by the Radiological and

Environmental Services (RES) Department with the responsible individual and

Maintenance Department supervisors to review the circumstances surrounding this

event. The individual's employment was subsequently terminated. l

e Lessons learned from this event were included in all department tailgate meetings. I

Personnel were provided a summary of the circumstances surrounding this event l'

including the necessity to spend sufficient time to assure compliance with

procedures, maintaining a questioning attitude, take the time needed to perform

Radiation Worker practices properly, and reaffirming that self verification practices l

also include frequent checks of personal dosimetry.

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I, Attachment I

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Renly to Notice of Yiplation 96-07

• Additional changes to the Radiation Protection program included: (1) an

enhancement to the Radiological Controlled Area (RCA) access control computer

program which eliminated the need to turn alarming dosimeters off at satellite

control points when individuals change from one Radiation Work Permit to another;

(2) during the recently completed Refuel Outage, Radiation Protection technicians

verified that each individuals dosimetry was on prior to entry into the Drywell; and

(3) RCA entry briefing rooms were limited to one crew at a time to reduce noise

and confusion, and provide a better atmosphere for technician / radiation worker

interface. j

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Results Achieved

The Authority believes the corrective actions taken were effective in preventing

recurrence. A review of Radiation Worker events following FitzPatrick's recently completed ,

Refuel Outage provided assurance that the causes for this event were satisfactorily  :

addressed and resolved. l

Corrective Actions To Be Taken

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None.

Data When Ftd Coree u:e Will Be Achieved

Full compliance was achieved on October 30,1996 when the maintenance worker exited

the Drywell.

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i Attachment I

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j Ren!v to Nodce of Violadon 96-07

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i Violadon G

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Title 10, Code of FederalRegulations, Part 71.12 (10 CFR 71.12) states, in part, that

h shippers of Mcensed materials are generally licensed for shipment utilizing packages for

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which the Commrssion has issued a certificate of compWance, provided that the licensee

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have in place a quaHty assurance program meeting the requirements containedin sections

71.101 through 71.137. 10 CFR 71.133 requires, in part, that the licensee establish

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means to asswa that conditions adverse to quaHty, such as deviations, are promptly

i identified and corrected.

Contrary to the above, on October 22,1996, the Mcensee shipped licensed radioactive

materialin an NRC-approved package (Certificate of CompWance No. USA /9094/A) without

i promptly implementing corrective actions for a prior violation of an applicable shipping

procedure (involving the inck of current certification of technicians relative to the

l applicable computer code used to classrfy the shipment) as previously identified by the

- licensee's deviation event report (DER 96-1188).

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This is a severity levelIV violation (Supplement V).

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j Adnd==% or Denial of the Allened Violation

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l The Authority agrees with the violation.

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! Reasons for the Violation

The cause for this violation was poor managerial methods. The RES Department

' management failed to be rigorous in its implementation of corrective actions to an

! identified problem. RES procedure RW-SHP-104, " Radioactive Waste Data Base Control

Program" had been revised and was in the approval cycle. RES Department management

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did not ensure the changes were approved before the waste shipment was made.

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Corrective Actions That Have Been Taken

e RES management has been counseled by the General Manager of Support Services

' on the importance of thoroughness of corrective actions, and stringent procedure

compliance.

l e RES Department procedure RW SHP-104, was revised and approved for use on

' 10/24/96. l

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Results Achieved

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! The Power Authority believes the correction actions taken have been and will continue to

be effective in preventing recurrence.

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- Realy_to. Notice ofYlolation 96-07

f Corrective Acdons To Be Taken

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Date When Fid Commilance WW Be Achieved

] Full compliance was achieved on 10/25/96 following revision to procedure RW SHP-104.

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