ML20207S813
| ML20207S813 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 03/13/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207S799 | List: |
| References | |
| 50-333-85-98, NUDOCS 8703200292 | |
| Download: ML20207S813 (51) | |
See also: IR 05000333/1985098
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ENCLOSURE
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
SALP REPORT 50-333/85-98-
NEW YORK POWER AUTHORITY
JAMES A. FITZPATRICK NUCLEAR POWER PLANT
ASSESSMENT PERIOD: DECEMBER 1, 1985 - NOVEMBER 30,~1986
BOARD MEETING DATE, FEBRUARY 13, 1987
8703200292 870313
gDR
ADOCK 05000333
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TABLE OF CONTENTS
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Page
.I.
INTRODUCTION
1
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A.
Purpose and Overview
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B.
SALP Board Members
1
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C.
Background
2
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II. CRITERIA . . . . . . . . . . . . . . . . . . . . . .
4
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III . SUMMARY OF RESU LTS . . . . . . . . . . . . . . . . . . . . . .
6
A.
Overall Facility Evaluation . . . . .
6
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B.
Facility Performance
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IV.
PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . .
8
A.
Plant Operations
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B.
Radiological Controls . . . . . . . . . . . . . . . . . .
11
C.
Maintenance . .
15
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D.
Surveillance
18
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E.
. . . . . . . . . . . . . . . . .
20
F.
Security and Safeguards . . . . . . . . . . . . . . . . .
22
G.
Outage Management and Engineering Support .
25
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H.
Licensing Activities
27
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I.
Training and Qualification Effectiveness
30
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J.
Assurance of Quality
33
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V.
SUPPORTING DATA AND SUMMARIES
36
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A.
Investigation and Allegation Review . . . . . . . . . . .
36
B.
Escalated Enforcement Action
36
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C.
Management Conferences
36
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D.
Licensee Event Reports
36
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E.
Licensing Actions . . . . . . . . . . . . . . . . . . . .
37
TABLES
' Table 1 Inspection Report Activities
39
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Table 2 Inspection Hours Summary
41
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Table 3 Tabular Listing of LERs by Functional Area
42
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Table.4 LER Synopsis
43
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Table 5 Enforcement Summary .
45
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Table 6 Reactor Trips and Plar.t Shutdowns . . . . . . . . . . . . .
47
Figure 1 Number of Days Shutdown . . . . . . .
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I.
INTRODUCTION
A.
Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an inte-
grated NRC staff effort to collect the available observations and
data on a periodic basis and to evaluate licensee performance based
upon this information.
SALP is supplemental to normal regulatory
processes used to ensure compliance to NRC rules and regulations.
SALP is intended to be sufficiently diagnostic to provide a rational
basis for allocating NRC resources and to provide meaningful guidance
to the licensee's management to promote quality and safety of plant
operation.
A NRC SALP Board, composed of the staff members listed below, met on
February 13, 1987 to review the collection of performance observa-
tions and data to assess the licensee performance in accordance with
the guidance in NRC Manual Chapter 0516, " Systematic Assessment of
Licensee Performance." A summary of the guidance and evaluation cri-
teria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at James A. FitzPatrick Nuclear Power Plant for the peri-
od December 1, 1985 to November 30, 1986.
B.
SALP Board Members
Chairman:
W. F. Kane, Director, Division of Reactor Projects (DRP)
Members:
D. R.. Muller, Director, BWR Project Directorate No. 2, NRR
T. T. Martin, Director, Division of Radiation Safety and Safeguards
(DRSS) (part-time)
W. V. Johnston, Deputy Director, Division of Reactor Safety (DRS),
(part-time)
R. M. Gallo, Chief, Projects Branch 2, DRP
J. C. Linville, Chief, Projects Section 2C, DRP
A. J. Luptak, Senior Resident Inspector, FitzPatrick, DRP
H. Abelson, Licensing Project Manager, BWR Project Directorate No.2,
Other Attendees:
P. W. Eselgroth, Chief, Test Program Section, DRS (part-time)
R. R. Keimig, Chief, Safeguards Section, DRSS (part-time)
G. W. Meyer, Project Engineer, RPS 2C, DRP
N. S. Perry, Reactor Engineer, RPS 2C, DRP
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C.
Background
-1.
Licensee Activities
The facility operated at or near full power from December 1,
1985 until March 13, 1986 when the plant was shut down for a
scheduled maintenance outage which lasted until March 28, 1986.
During this outage, the licensee replaced 16 control rod drive
mechanisms, conducted preventive and corrective maintenance ac-
tivities, and completed several modifications. The plant re-
turned to power operation on March 31, 1986.
From this maintenance outage until the next scheduled mainte-
nance outage, normal power operatior, was interrupted by three
unscheduled outages lasting between one and three days. On
April 4, -1986 the reactor tripped from 88% power during main
turbine stop valve testing caused by an improper valve position
indication. On May 15, 1986, the plant was shut down as re-
quired by Technical Specifications due to an inoperable Recircu-
lation Loop Discharge Bypass Valve. On July 3,1986, the
reactor tripped from full power when a failure occurred in the
protective relaying circuit for the outgoing electrical trans-
mission lines.
The facility was shut down from September 27, 1986 until October
9,1986 for another scheduled maintenance outage which involved
the replacement of ten control rod drive mechanisms, turbine
blade inspection, preventive and corrective maintenance, and
modification insta11'ation.
Following the completion of the
maintenance outage, the plant again operated at near full power
until November 1, 1986 when a plant coast down began for the
refueling outage scheduled for Jr.nuary 1987. The plant was
continuing to coast down at the end of the assessment period.
Table 6 provides a description, including our classification of
the cause of all reactor trips and unscheduled plant shutdowns
during this assessment period.
2.
Inspection Activities
One NRC resident inspector was assigned to the James A.
FitzPatrick Nuclear Power Plant for this assessment period. The
total NRC inspection effort for the period was 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br /> with a
distribution in the appraisal functional areas as shown in Table
2.
During the assessment period, an NRC team evaluated the annual
emergency preparedness exercise conducted on September 26, 1985.
Tabulations of Inspection and Enforcement Activities are pre-
sented in Tables 1 and 5, respectively.
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This report also discusses " Training and Qualification Effec-
tiveness" and " Assurance of Quality" as separate functional ar-
eas. Although these topics are used in the.other functional
areas as evaluation criteria, they are being addressed separate-
ly to provide'an overall assessment of their effectiveness.
For
example, quality assurance effectiveness is assessed on a day-
to-day basis by resident inspectors and as an integral aspect'of
each specialist inspection. Although quality of work is the
responsibility of every employee, one of the management tools to
measure this effectiveness is reliance on inspections and au-
dits. 0ther n.afor factors that influence quality, such as in -
volvement of first line supervision, safety committees, and
worker attitudes, are discussed in each area, as appropriate.
Fire Protection was not evaluated as a separate functional area
since extensive new information on performance, such as when an
Appendix R team inspection has occurred, was not generated dur-
ing this assessment period.
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~II.
CRITERIA.
Licensee performance is assessed in selected functional areas, depending
on whether the facility,is in the construction, preoperational, or operat-
ing phase.
Each. functional area normally represents areas significant to
nuclear safety and the environment, and are normal programmatic areas.
Special areas may be added to highlight significant observations.
The following evaluation criteria were used, where appropriate, to assess
each functional area.
1.
Management involvement and control in assuring quality.
2.
Approach to resolution of_ technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Reporting and analysis of reportable events.
6.
' Staffing (including management)
7.
Training and qualification effectiveness.
Based upon the SALP Board assessment each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1
Reduced NRC attention may be appropriate.
Licensee management attention
and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that a high level of
performance with respect to operational safety is being achieved.
Category 2
NRC attention should be maintained at normal levels.
Licensee management
attention and involvement are evident and are concerned with nuclear safe-
ty; licensee resources are adequate and reasonably effective so that sat-
isfactory performance with respect to operational safety is being
achieved.
Category 3
Both NRC and licensee attention should be increased.
Licensee management
attention or involvement is acceptable and considers nuclear safety, but
weaknesses are evident; licensee resources appear to be strained or not
effectively used so that minimally satisfactory performance with respect
to operational safety is being achieved.
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- The SALP Board 'also assesses functional areas to compare the licensee's.
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performance during the last part of the assessment period to that during the
entire period (normally one year) in order to determine the recent trend for
functional areas as appropriate.
The SALP trend categories are as follows:
Improving:
Licensee performance has generally improved over the last
part of the SALP assessment period.
Declining:
Licensee performance has generally declined over the last
part of the SALP assessment period.
A trend is assigned only when, in the opinion of the SALP board, the trend is
significant enough to be considered indicative of a likely change in the
performance category in the near future.
For example, a classification of
" Category 2, Improving" indicates the clear potential for " Category 1"
performance in the next SALP period.
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III. SUMMARY OF RESULTS
A.
Overall Facility Evaluation
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Management attention has resulted in noticeable improvement through-
out the facility and in particular the areas of plant operations and
assurance of quality. Although the functional area ratings have
remained the same, this does not reflect the general, overall improve-
ment observed in site activities. The number of operational events
has significantly decreased during this assessment period with two
reactor trips from power. Neither was caused by operator error.
Plant management, and in particular the Resident Manager and Quality
Assurance Superintendent, have demonstrated a philosophy oriented
toward nuclear safety and have been influential in. improving the
overall plant performance. The New York Power Authority (NYPA) has
been effective in fostering an improved attitude towards safety,
accountability, and pride in workmanship.
Plant personnel now dis-
play a greater degree of attention to detail in day-to-day
activities. With the exceptions discussed in the licensing area,
Plant management is cooperative and responsive to NRC concerns and
initiatives.
Although an overall improving trend was evident, several areas previ-
ously noted as deficient warrant additional management attention.
These include, procedural adherence, follow-up of commitments, and
instilling a questioning attitude within the organization.
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B.
Facility Performance
CATEGORY
CATEGORY
LAST
THIS
RECENT
FUNCTIONAL AREA
PERIOD *
PERIOD **
TREND
1.
Plant Operations
2
2
Improving
2.
Radiological Controls
2
2
3.
Maintenance
2
2
4.
Surveillance
2
2
5.
Fire Protection
1
N/A
6.
1
1
7.
Security & Safeguards
1
1
8.
Outage Management and
2
2
Engineering SLpport
9.
Licensing Activities
2
2
Declining
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10.
Training and Qualification 2
2
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Effectiveness
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11. Assurance of Quality
2
2
Improving
- July 1, 1984 to November 30, 1985 (17 months)
- December 1, 1985 to November 30, 1986 (12 months)
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IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
(775 Hours, 40.3%)
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1.
Analysis
During the previcus assessment period, this functional area was
rated as Category 2 with an overall decline in performance. A
number of personnel errors and inconsistent review of opera-
tional events and root cause analysis were noted as
deficiencies.
During this assessment period, the plant operators were deter-
mined to be knowledgeable and conducted themselves in a profes-
sfonal manner. They exhibit a positive attitude toward
operating the plant in a safe manner.
During operational events
.and routine evolution, the operators demonstrated their ability
to respond quickly and efficiently. Also, their ability to con-
duct three normal reactor shutdowns and five reactor startups in
a controlled manner without causing a reactor trip is commend-
able. Several isolated cases occurred where operators did not
fully investigate or were not aware of.off-normal conditions.
These included annunciators, control room ventilation fan
operability, tripping of overloads on a motor operated valve,
and systems affected by a level switch failure. Although these
conditions were of minor safety significance, continued emphasis
should be placed on understanding and identifying off-normal
conditions.
One noteworthy improvement during this assessment period was the
absence of a significant number of personnel errors.
Two plant
trips occurred from power and neither was directly attributed to
personnel error. One of nine trips which took place while the
plant was shut down was attributed to operator error; however,
this occurred while the operator was taking necessary actions to
isolate a leak in the feedwater system while in the process of
lowering reactor vessel level.
In addition, no plant transient
or equipment inoperability occurred as a result of personnel
error.
As a result of the unusually large number of trips which oc-
curred during the previous assessment period, a Scram Review Team
conducted a comprehensive evaluation of the trips and the cir-
cumstances surrounding them. As a result of that review, about
66 recommendations were given to improve overall plant
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performance and reduce the number of trips. These recommenda-
tions, their resolution, and their implementation are tracked by
the licensee using a formal system. Although no single signifi-
cant root cause existed for the reactor trips, each recommenda-
tion improved the way plant management conducts operations.
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the.short term, the management continues to work to instill a
positive attitude and pride in workmanship among its employees,
which has resulted in a reduction of personnel errors and the
ability to correct deficiencies quickly and correctly.
Further
assessment of the long term recommendations is required.
Administrative controls, procedures and procedural adherence are
generally strong, but minor exceptions have been noted that re-
quire plant management attention.
Exceptions include not comply-
ing with the procedure for securing the high pressure coolant
injection turbine during surveillance testing, using data sheets
to perform testing instead of the procedure, and skipping steps
of a procedure during testing. These examples are not of major
significance' and are considered isolated events. Plant manage-
ment is aware of this concern and is stressing improvement in
this area.
Plant management continues to stress professionalism and to
improve the cor. trol room environment, as noted by the removal of
the Secondary Alarm Station from the control room, installation
of curtains to limit traffic in the control room, and continued
improvements in establishing an effective work control center.
In addition, plant management has placed emphasis on reducing
the number of continuously lighted annunciators. Although plant
management has made progress in this area, continued attention
is warranted. The Operations Superintendent conducts weekly
meetings with each shift to review events and stress the need
for improvements. Additional improvements noted were the in-
creased use of formal critiques to review events and a more com-
prehensive post-trip review procedure.
Senior plant management
takes an active role in the plant operations area as indicated
by daily control room reviews, which include log reviews, panel
walkdowns and discussions with operators.
Plant management
stresses safety and emphasizes a methodical approach to plant
evolutions.
There is consistent evidence of a commitment to
plant betterment and timely, effective corrective actions.
Corrective actions for a violation for a failure to comply with
10 CFR 50.72 reporting requirements did not prevent a second
violation. The second instance occurred nine months after the
first occurrence. Plant management failed to take adequate
measures to prevent recurrence.
In addition, the licensee had
not implemented all of the corrective actions committed to fol-
lowing the first occurrence, even though they had exceeded the
commitment date by several months. At the time of the second
instance, a formal tracking program was in the process of being
implemented.
The tracking program follows items on which action
is scheduled and highlights those which are commitments.
Although improvements were noted in the review of operational
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events and root cause analysis, some deficiencies have been not-
ed as discussed in Section C, Maintenance. A marked improvement
has been noted in the FitzPatrick Licensee Event Report (LER)
submittals.
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The LERs presented a clear understanding of the event, its
cause, and corrective action taken or committed to be taken.
Further improvement can still be made by consistently discussing
the safety implication of the event and identifying the manufac-
turer and model of failed components.
Housekeeping at the facility has improved.
Senior plant manage-
ment makes weekly tours of the facility to review cleanliness
conditions and continues to emphasize plant cleanliness. Al-
though cleanliness has generally been good, occasional lapses
have occurred in material storage, such as ladders left stand-
ing,' gas bottles improperly stored, and small items adrift.
In summary, plant operations is a strength as indicated by the
high unit availability and significant improvements. Plant
Management attention has resulted in a significant reduction in
operator related events.
2.
Conclusion
Rating: 2
Trend:
Improving
3.
Board Recommenaations
None
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B.
-Radiological Controls
(392 Hours, 20.4%)
1.
Analysis
During the previous SALP period this area was rated as Category
2.
Weaknesses included delayed responses?to NRC findings and
lack of management attention relative to conforming to radiation
protection procedures. This functional area will be discussed
in terms of radiological protection,- radioactive waste transpor-
tation, and effluent monitoring and control.
There were six
inspections conducted by radiation specialistsoin this area, two
in radiological protection, one in radioactive waste transporta-
tion, and three in effluent monitoring and control. The resi-
dent inspector also monitored tne implementation of the
radiation protection program.
RADIOLOGICAL PROTECTION
The licensee showed consistent performance relative to the pre-
vious assessment period, with no major weakness identified and
no major program improvements. Several minor instances of per-
sonnel-failing to follow procedures occurred during this assess-
ment period as in the previous assessment period.
The Radiological Protection Program is staffed with qualified
personnel.
However, it should be noted that the Health Physics
General Supervisor left FitzPartick in the last month of the
assessment period and that the station Radiation Protection
Manager has been temporarily acting in this position. When a
new General Supervisor is selected, increased management atten-
tion will be needed to assure a smooth transition.
The ALARA program is strong and effective with good management
support and represents a program strength. ALARA reviews for
planned work, completed work, and continuous evaluation of work
in progress are good. During the course of several inspections
in this rating period, the ALARA program was examined and found
to be of consistently high quality.
The licensee's ALARA person-rem goal for the site was 600 per-
son-rem for 1986, a non-refueling year, based on a calculated
exposure estimate of 575 person-rem. With the accumulated ex-
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posure at the end of the assessment period,'the exposure for
1986 was not expected to exceed 400 person-rem. While this ex-
posure reflects well on the ALARA program, it shows the goal set
for the 1986 calendar year was not aggressive.
The program for external and internal exposure control reflects
an adequate commitment to safety.
In this SALP assessment peri-
od, as in the previous assessment period, no overexposures oc-
curred and no individuals received an uptake that required
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-assessment or any further actions.
Radiation Work Permits were
effectively used to control work within the Restricted Area. As
-in past years, NYPA is implementing an adequate whole body
counting program.
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However, there are areas where improvement is necessary in the
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Linternal'and external exposure control program. Minor problems
1nclude failure'to follow procedures and insufficient middle
management attention to detail to provide oversight in the area
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'of-external exposure control.
Instances of failure to follow
' procedures included failure to maintain survey instrument.cali-
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bration records and failure to perform alpha surveys on arriving
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new fuel shipments. . Additional middle management attention to
.the-supervision and assessment of day-to-day radiological con-
trols activities is needed to improve self-identification and
correction of. program weaknesses.
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The re'spiratory protection program is of state-of-the-art
q'uali ty.
The licensee has placed a high priority on this pro-
gram as evidenced by effective respirator selection, issue, use,
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and maintenance practices.
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Radiological survey instrument controls were weak. Specifical-
.ly, the storage, maintenance, and calibration facilities for
portable survey instruments needed improvement.
Furthermore,
survey equipment availability during the October 1986 outage was
limited, which indicated poor control of equipment inventory.
Personnel frisking practices were inferior to industry stan-
dards, in that high background count rates potentially precluded
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effective detection of personnel contamination. Compounding
this problem were poor frisking; techniques by station personnel.
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Regarding both the survey instrument control and frisking prob-
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1 ems, middle management within the radiological controls group
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appeared unaware of these problems until informed by the NRC,
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despite the seemingly obvious nature of the problems.
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unclear whether the lack of awareness was due to the failure to
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personally inspect field activities, poor communications with
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personnel in the field, or low standards of work.
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Corporate management is frequently involved in the activities
providing guidance and consultation to FitzPatrick Station man-
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agement.
For example, Corporate and Standard Audits were per-
formed of the Rad ution Protection Program. However, most
Standard Audits, while timely, were superficial and of limited
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scope due to a lack of audit personnel qualified or trained in
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health physics and chemistry. This weakness was identified by
corporate management late in the SALP assessment period. Corpo-
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rate management indicated that their audit personnel, qualified
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in HP and Chemistry, would be made available to augment the
Standard Audit program.
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RADI0 ACTIVE WASTE TRANSPORTATION
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An inspection of radioactive waste transportation-found this
area to be generally good. While a concern was identified
regarding the circumvention of the receipt inspection system for
transport packages, the corrective actions were timely and
thorough.
In addition, when concerns were identified regarding
the adequacy and effectiveness of the audit program for trans-
port packages, QA/QC involvement in this area was promptly in-
creased.
EFFLUENT MONITORING AND CONTROL'
During the previous assessment period the Radiological Effluent
Technical Specifications (RETS) were implemented.
Inspections
during this period found no significant problems in RETS imple-
mentation, and the licensee was effective in correcting the
minor problems which occurred. An inspection of the environ-
mental monitoring program found a problem with implementation of
a calibration procedure. However, this problem appeared to be
an isolated instance due to a lack of attention to detail rather
than a programmatic breakdown. With this exception, the envi-
ronmental monitoring program was effectively implemented with
respect to Technical Specification requirements for sampling
frequencies, types of measurements, analytical sensitivity, and
reporting schedules.
'An inspection of the nonradiological chemistry program found it
to be generally effective. Minor deficiencies were identified
in several of the chemical analysis procedures, but the licensee
response was prompt and thorough. With a few exceptions, all of
the analyses of chemical standards agreed with the analyses of
the split samples. The reasons for the few disagreements were
determined and resolved.
An inspection of effluent and process radiation monitor calibra-
tion and surveillance testing, and in place filter testing found
these areas to be acceptable.
Summary
The established programs for radiological protection, radioac-
tive waste transportation, environmental monitoring, and
nonradiological chemistry are sound and effective. The day-to-
day implementation of these programs must be managed and super-
vised to achieve the results of which the programs are capable
and to prevent the minor problems experienced during this peri-
od. A more probing and effective quality assurance review of
these programs would aid in assuring proper implementation.
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2.
Conclusion
Rating: Category 2
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3.
Board Recommendations
None
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C.
Maintenance
(159 Hours, 8.3%)
1.
Analysis
During the previous assessment period, this functional area was
rated as Category 2.
Although FitzPatrick management continued
to implement several improvement programs, progress was slow and
had loosely defined completion schedules. Also, several per-
sonnel errors resulted in reactor trips or plant shutdowns.
During this period, this area was frequently reviewed by the
resident inspector.
In addition, specialist inspections re-
viewed the maintenance of the recirculation pump trip system and
the equipment qualification of Limitorque valve operators.
No
.sp'rogrammatic inspection of maintenance was conducted during the
' current assessment period.
During this assessment period, plant management became more ac-
tively involved in implementing the improvement programs, and
progress was generally good. A program to control vendor tech-
nical manuals was begun by developing a computerized index and
reviewing the manuals maintained by each department. However,
there have been delays in implementing the program in the Main-
tenance Department.
Implementation of the Planned Maintenance
Program continued with some minor delays. The development of
the Master Equipment List progressed with component classifica-
tions.
Improvements were made in tool control, and a vibration
analysis test program began.
Improvements were noted in the maintenance area during this pe-
riod. Most noteworthy was the absence of a significant number
of personnel errors. Maintenance personnel were well qualified
and conscientious, and exhibited a proper safety perspective
concerning their potential impact on plant operations. The ad-
ministrative control of preventive and corrective maintenance
work was good. Based on this, it appeared that maintenance
training programs were effective. Also, personnel turnover rate
was low.
Supervisory involvement was evident and effective in
the timely resolution of equipment problems.
During this assessment period, nine reactor trips occurred while
the plant was shutdown with all rods fully inserted.
Six of
these trips were caused by spiking of the "G" IRM during under
vessel work. A broken connector was later found on the IRM, and
it was determined that minimal contact by maintenance personnel
caused the spike.
Based on the nature of under-vessel work and
an abnormal condition of one channel of RPS deenergized for
other modifications, these trips are of minimal concern. The
three remaining trips while shut down were unrelated and are
discussed in Table 6.
. - -
. _ .
-
. .
-_
.
_ _ _ _ - ,
.
-_
_ _ _ - _ _ _ _ _ _ _ _ - _ - _ _
.
.
16
Regarding the Recirculation Pump Trip System, preventive mainte-
nance was properly controlled and documented, and corrective
maintenance was timely and adequate.
In addition, the engineers
and supervisors were technically competent and knowledgeable of
past system problems. Management involvement was evident in the
effort to modify a failed breaker and to pursue modifications
for the same breakers in other applications.
A concern was identified regarding examples of personnel not
following maintenance procedures. These involved not applying
thread sealant during assembly of a pressure transmitter conduit
connection as required by the technical manual, missing a step
during assembly of a control rod drive mechanism, and incorrect
torque setting for pressure transmitter mounting bolts. The
last two examples were identified by Quality Control personnel
observing these activities. These are considered to be individ-
ual errors and are not indicative of a widespread disregard for
,
procedures. Although these examples are of minor safety signif-
icance, plant management attention to prevent more significant
problems is warranted.
The licensee has taken a more aggressive approach to correct
several recurring equipment problems, including the Low Pressure
Coolant Injection Independent Power Supplies, the Containment
Atmosphere Analyzer, and the transmitters in the Analog Trans-
mitter Trip System.
However, plant management failed to estab-
lish the root cause of other problems such as the Main Steam
Isolation Valve limit switch failures, recirculation loop bypass
valve packing leakage, and the Turbine Stop Valve Limit Switch
failure.
Specifically, failure to establish the root cause of a limit
switch failure on a Turbine Stop Valve subsequently contributed
to a ceactor trip during surveillance testing. The limit switch
had ralfunctioned numerous times in the six months prior to the
trip but was not properly evaluated and repaired.
Following the
determination that the limit switch was involved in the reactor
trip, plant management conducted extensive testing to determine
the exact cause of the failure. However, maintenance managers
neglected to review the past failures of the limit switch, which
indicated that a change in the valve stroke was occurring.
In
addition, during the reactor startup following the trip, when
maintenance managers identified that the valve stroke had
changed, no detailed review of the cause of the stroke change
was considered until several days after the startup. Subsequent
inspection found that loose bolts had allowed the valve stroke
to change. Apparently, the bolts became loose due to a failure
to apply proper torque.
The environmental qualification (EQ) program for Limitorque
valve operators was generally effective. Management involvement
_ - _ _ _ _ _ _ - _ _ _ __
.
.
17
.
'was evident'by the number of management personnel who actively
participated in the EQ program, the high degree of organization
of EQ documents, and the prompt performance of EQ related activ-
ities. Further evidence of commendable performance included the
thorough resp'onse to NRC Information Notice 86-03, including a
100% inspection of.Limitorque valve operators requiring EQ and.
the licensee's decision to upgrade the Limitorque valve control
wiring, even though qualification data was available for the
existing control wires. However, some implementation problems
were identified within the general EQ program, which will be
evaluated during the pending inspection of the plant EQ program.
Overall, the plant maintenance program has improved from the
previous assessment period. The absence of significant per-
sonnel errors and the proficiency in properly completing work is
noteworthy. Continued emphasis should be placed on. timely com-
pletion of improvement programs, procedure compliance, and root
cause analysis to prevent recurring problems.
2.
Conclusion
Rating: 2
3.
Board Recommendations
None
.
.
.
..
-
18
D.
Surveillance
(194 Hours, 10.1%)
1.
Analysis
During the previous assessment period, this functional area was-
rated as Category 2, primarily due to repeated problems in es-
tablishing an effective Inservice Testing (IST) Program.
During the current assessment period, the surveillance, calibra-
tion, and IST programs were reviewed. The resident inspector
also examined surveillance testing during the routine inspection
program.
The licensee improved the IST Program by including all required
valves, rewriting procedures to include acceptable values, and
assuring that the operators do a thorough review of data follow-
ing the tests. However, the previous SALP Report noted problems
regarding the review of test data by operations and plant per-
formance personnel. During this period, operations department
reviews of the data were adequate and timely, but-the subsequent
review of the data by plant performance personnel was, at times,
excessively slow (up to several weeks). This review is relied
upon to determine trends and notify Operations to increase test
frequency when components exhibit undesirable trends.
Surveillance tests are performed by the responsible department,
with the majority of testing completed by the following depart-
ments: Instrument and Control, Operations, Maintenance, and
Radiological and Environmental Services.
Each depar_tment
maintains its own system for scheduling, tracking and performing
surveillances. The completed surveillance tests were well docu-
mented utilizing detailed procedures, data forms, and acceptance
criteria. Overall, personnel performing the tests were know1-
edgeable, responsible, and well trained.
Procedure use and ad-
herence was good in general with exceptions noted in Section A,
Operations. No plant trips or shutdowns were the direct result
of testing errors.
However, three surveillance tests were either performed late or
missed as follows:
A monthly test of the APRM flow bias network was missed for
--
eight months when it was not placed on the schedule follow-
ing a shutdown period.
A quarterly test of the diesel fire pump was performed 18
--
days beyond the grace period due to a lack of management
oversight of the maintenance department surveillance
program.
--
A chemistry sample during startup was about one hour late
due to personnel error.
.
-
_ . -
.
_. - . _ _ _
_
_
_,
- -
...
19
NYPA took prompt actions to strengthen its administrative re-
quirements associated with the surveillance test program to pre-
vent recurrence. No surveillance tests were missed in the last
six months of,the period.
Although no surveillance tests were missed during the previous
assessment period, there had been numerous missed surveillance
tests in the period preceding it.
It appears that the recurring
problem of missed surveillance tests is symptomatic of the unco-
ordinated approach that the surveillance program has taken. The
lack of an overall responsibility for surveillance testing be-
yond the individual departments and the minimal coordination
-
between departments appear to hamper the long term resolution of
surveillance testing problems.
The NRC identified that not all safety-related instruments were
being periodically calibrated, nor was there an adequat_e sur-
"
veillance test to verify that they are functioning within the
required ranges. The licensee immediately calibrated those
instruments identified and was further evaluating the remaining
.
safety related instruments for periodic calibration. Also, the
delayed implementation of calibration program improvements rec-
ommended by a 1983 QA audit reflected poorly on management's
interest in implementation high quality program.
Improvements were made in the storage and control of measuring
and test equipment, including a computerized system for tracking
the location, status, and restrictions regarding all measuring
and test equipment.
In summary, the surveillance test program is adequate. One
strength noted was in the area of conduct of the surveillance
tests, as aidenced by the lack of personnel errors during test-
ing.
However, increased management attention is warranted in
the area of program administration and coordination.
2.
Conclusion
Rating:
2
i
3.
Board Recommendations
,
None
- -
- -
.
,_.
- . . .
.
. --
-
- - - -
'.
.
20
.
E.
(110 Hours, 5.7%)
1.
Analysis
During the pr'evious assessment period this functional area was
rated as Category 1.
This assessment was based upon a good dem-
onstration of emergency response capability during two annual
exercises, responsiveness to weaknesses identified in these ex-
ercises and a clear management commitment to the emergency pre-
paredness program.
The current assessment period included observation of one
partial-scale exercise conducted'in June 1986. The exercise
demonstrated a high degree of proficiency which appears to re-
sult from a strong training program.
Emergency response person-
nel are quite knowledgeable and dedicated. Only one minor
deficiency was identified during the exercise. This exercise
showed improvement from the previous year's exercise, which had
only minor discrepancies.
The licensee staff is active in maintaining and improving the
emergency response program.
Program weaknesses are promptly
identified and corrected.
NYPA and others have taken the init-
iative to jointly study the local effects of Lake Ontario on
atmospheric dispersion. The information gained will help quan-
tify the local lake effect and improve capabilities overall in
protective action decision making for the central New York lake
region. The licensee recently incorporated the use of a " Lag-
rangian Puff" model for dose assessment.
The emergency preparedness training and qualification program
. continues to make a positive contribution to plant safety, com-
mensurate with procedures and staffing which have been consis-
tently good.
The licensee has developed and maintains a good rapport with the
local government (Oswego County) and the State (New York) regard-
ing emergency preparedness. They met on a regular basis (quar-
terly) to discuss, plan and address issues related to emergency
response. Also, in a joint initiative with Niagara Mohawk Power
,
Corp., NYPA plans to install a siren verification system.
In summary, continued commitment to a high quality emergency
preparedness program was demonstrated by excellent performance
during the exercise, thorough preparation in procedures and
training, and improvements in program and facilities.
2.
Conclusion
Rating: Category 1
...
.
.. -
- . -
~
.
c.
21
3.
Board Recommendations
None
y
-.
22
F.
Security and Safeguards
(140 Hours, 7.3%)
1.
Analysis
During this a'ssessment period, only one physical security in-
spection was conducted because the licensee's performance during
the two previous assessment periods was rated as Category 1.
Routine resident inspections of the security program were per-
formed throughout the assessment period. One material control
and accounting inspection was conducted.
The licensee continued to review the effect!veness of the secu-
rity program and the adequacy of related facilities during the
period. As a result, the licensee plans to move the security
administrative offices into new office facilities and has al-
ready moved the secondary alarm station (SAS) into new facili-
ties that provide more space and efficiency of operation.
Additionally, as a result of recommendations resulting from sur-
veys of the security program performed by outside contractors, a
new computerized security system and new card readers were in-
stalled, along with the new search equipment that was installed
at the end of the last assessment period. The licensee's com-
mitment to a high quality security program is evident by the
continued support, in terms of capital resources for program
upgrades, and the continued excellent interface among security
and other corporate and site functions.
The supervisory staff is well experienced and continued to dem-
onstrate their knowledge of and ability to meet NRC security
performance objectives.
The security training program is now managed by one full-time
training instructor with assistance from several part-time in-
structors who have expertise in specific areas. While this is a
reduction of one full-time instructor from the previous assess-
ment period, the assistance of the part-time instructors has
compensated for the reduction and no adverse impact on the
training program has thus far been apparent. The licensee has
excellent training facilities that, in addition to modern class-
rooms and physical fitness facilities, include an indoor firing
range. Contingency plan drills are conducted regularly as a
. supplement to the training program.
Critiques of the drills are
conducted and documented, with feedback into the training pro-
gram. This has proven to be a very effective training aid. The
effectiveness of the training program is apparent by the lack of
performance related events during the assessment period, and
this performance, as well as the appearance and morale of the
security force, reflect favorably on both the training program
and security management.
__
. .
.
- . ,
-.
-
-
-
.
. ~
- .
-
.
-. ..
4
1
- .
.
~
v
a
.
23.
'
.
Staffing of the security force appears.to be adequate with occa
,
. sional overtime being used to meet unforeseen operational needs.
This use of overtime has had no adverse effects on:the perfor-
mance of the force.
In preparation for an upcoming outage that
has the potential for taxing the existing' force, security man-
,
agement developed and implemented a training program to qualify
,
additional watch persons to supplement the force. This advance
planning.is characteristic of the licensee's security management
and 'is .further evidence of their desire to implement an effec-
tive and high quality program.-
I
Security management.is actively involved in the Region I Nuclear
"
. Security Organization and other organizations involved in nucle-
i
ar power plant security. The licensee maintains an. excellent
relationship with law enforcement agencies and periodically-in -
vites key members of these agencies to the site for orientation
in response procedures, plant layout and other matters involved
with the protection of a nuclear power plant, and to discuss
recent developments and innovations, in general. This is1 fur-
i
ther evidence of the licensee's. interest in providing an effec-
tive security program.
'
i
There were no security events that required reporting under 10
CFR 73;71 during the assessment period._ This is attributed to
the effective training program that resulted in excellent per-
formance from the members of the security force and to the pro-
'
gram implemented by the licensee to maintain its security
L
systems'and equipment in good working order, which includes mon-
L
itoring of and planning to replace aging' equipment and replace-
ment of equipment before it became a source of problems.
,
During the assessment period, the licensee submitted'two changes
i.
to the NRC approved Security Plan in accordance with the provi-
!
sions of 10 CFR 50.54(p). These plan ~ changes were reviewed and
i
considered acceptable.
The changes were clearly described and
'
the plan pages were marked'to facilitate review. The changes
- -
were made to accommodate modifications to existing site facili-
ties and, as with plans for similar modifications since that
,
l'
time, the licensee discussed its plans beforehand with regional
-
personnel to ensure a clear understanding of NRC security pro-
gram objectives. This demonstrated the licensee's' interest in
maintaining a high quality program.
1.
F
A material control and accounting inspection identified that two
j
neutron fission detectors had not been physically accounted for
!
during a 1985 inventory of special nuclear material (SNM). The
inventory was promptly reconciled. However, the failure to
t
physically account for all SNM during an inventory and a misin-
terpretation of an NRC requirement regarding the conduct of
l
physical inventories of SNM, also raised during that inspection,
i
1
4
-
,
4,
c%.,
-- y
% ,.
e,_e._%_.-wm
m,
.-.o__~,.,
-_m__m,
,_m,.,.mm_..
,.,,.,..,___-,_._.m.
-
o
.
24
demonstrate the need for increased management attention to the
accounting of SNM.
In summary, the continued good performance of the security
force, coupled with the associated attention to facilities and
equipment, training, staffing, and involvement with other secu -
rity organizations, demonstrated the security area to be a
strength within the FitzPatrick organization.
2.
Conclusion
Rating: Category 1
3.
Board Recommendations
None
9
1
b
I
.. _ _ _. _ ,
.
,_--____ _.
.
. . .
. -
-_ - _ . . . _ _ , - _ . . _ _ .
.
.
25
G.
Outage Management and Engineering Support
(152 Hours, 7.9%)
1.
Analysis
During the previous assessment period, this functional area was
rated as Category 2.
Performance had declined due to inadequate
planning, poor control of activities, and personnel errors.
During this period, no refueling outage took place, but two
short scheduled maintenance outages, totaling 24 days, cccurred.
During these outages major work included replacement of control
rod drive mechanisms, installation of several modifications, and
preventive and corrective maintenance. The resident inspector
reviewed these activities, and a specialist inspector reviewed
radiological controls during one of the outages.
In January, 1986, the licensee established a new Planning and
Contract Services Department to plan, schedule, and manage out-
age and contractor activities. In addition to a full time plann-
ing department, this action provided more direct plant manage-
ment control of outage activities by replacing the contractor
supervisors with licensee supervisors and eliminating the con-
tractors.
During both maintenance outages the licensee exhibited good con-
trol of outage activities. Daily meetings brought problems to
the appropriate level of attention and led to timely resolut-
ions. The newly organized Work Control Center also contributed
by better controlling work activities. Detailed critiques of
both outages examined methods of improving future outage activit-
ies. Despite an ambitious schedule and unforeseen required main-
tenance, the licensee was able to complete the outages with only
a day delay for each outage. Based on the above, both the
Planning and Contract Services Department and the Work Control
Center improved the control of the outages that were conducted.
The plant Technical Services Department supplied engineering
support for the review and design of modifications, resolved
plant engineering problems, administered the environmental qual-
ification program onsite, and reviewed all safety-related pur-
chase orders.
Significant modifications included installation
of a new plant computer system including SPDS, Appendix R modi-
fications, installation of a second level of undervoltage pro-
tection, and installation of new drywell sump level t'rans-
mitters. The engineers were knowledgeable and competent, and
were actively involved throughout the installation and testing
of the modifications. However, due to the significance of their
functions, the department's potential to impact other plant
departments and the fluctuating work loads between modifications
and plant ent'neering problems, the Technical Services Depart-
ment will require continuing plant management review to assure
__ . _ _
_ . _ _
. _ _ _ _ _
~ . _ _ _ , _
_ _--
_ - - -
-
--
r
'
f
26
.
proper oversight'of the department's activities.
It appeared
that this oversight was inadequate.on occasion based on the
.following examples:
'
~ The ongo'ing program to inspect all safety-related pipe sup-
--
ports was placed on hold in November 1985 following funding
shortages which prevented the Architect Engineer (AE) from
'
performing further evaluations. The licensee believed at
the time that-the fifty items waiting evaluation by the AE
did not affect support or system operability.
In April
1986 after.the funding became available, the AE determined
a support in the Core Spray system identified on November
7, 1985 as having a discrepancy was inoperable. Subsequent
evaluation concluded the inoperable support did not affect
the system operability. The delay in recognizing the inop-
erable support was caused by the Pipe Support Field Engi-
neer's (PSFE), a contract engineer, failure to make the
operability determination upon discovering the discrepan-
cies_as expected. On November 15, 1985, when the PSFE left
the site permanently, the Pipe Support Program Manager was
not informed of the problem by the PSFE, and no formal re-
view of the support packages was conducted when.the PSFE
departed.
An installation deficiency caused by inadequate design
--
change review on a valve motor operator resulted in a Re-
circulation Loop Discharge Bypass Valve being inoperable
due to mechanical interference following piping thermal
expansion. .During installation of the new operator, the
orientation of the operator had been changed due o dif-
ferent clearance requirements. This event resulted in a
plant shutdown required'by Technical Specifications.
In summary, outage management was well organized and effective
in planning and managing the two short outages. The dedicated
outage planning staff has been instrumental in upgrading the
planning for the upcoming refueling outage. With the exception
noted, the engineering support group performed well in assuring
the technical adequacy of modifications, but upper plant and
corporate management review of their activities should be in-
creased.
2.
Conclusion
Rating: 2
3.
Board Recommendations
None
<
m
i
~
- .
,
27
H.
Licensing Activities
1.
Analysis
During the previous assessment period, this functional area was
rated as Category 2.
Performance had improved as evidenced by
the reduction in the backlog of licensing actions.
A reorganization of the headquarters staff took effect at the
beginning of this rating period.
In the new configuration, the
licensing staffs for both FitzPatrick and Indian Point 3 report
to the same Vice-President. Notwithstanding the differences in
the respective reactor designs, this change has resulted in an
improved exchange of information between the two-licensing
staffs and should result in more uniform interactions with NRR.
Interaction between headquarters management and NRR was at a
comparatively reduced level during this rating period due to
elimination of a large backlog of licensing actions during the
previous rating period and the absence of any major outages.
Nevertheless, management interest and involvement in licensing
activities was evident. A case in point was the attendance of
licensee senior level management at a counterparts working meet-
ing between BWR Project Directorate #2 staff and licensing man-
agers of utilities assigned to that directorate, held in April
'
1986.
Increased management attention to the quality of Sholly
i
evaluations and licensing correspondence has also been evident
during this rating period and is responsive to a recommendation
made in the previous SALP evaluation.
,-
Licensee management, however, has not directed sufficient atten-
tion towards correcting and revising the Technical Specifica-
tions (TS) to ensure that the current, as-built configuration of
the plant is reflected, that errors are eliminated, and that
wording clearly reflects the intent of the TS. A case in point
is Table 3.7-1 regarding containment isolation valves.
Inaccu-
racies have existed in this table for years, and the table does
l
not reflect the current configuration of the plant, yet the
licensee has not, to date, proposed revisions. The TS pertain-
ing to recirculation bypass valves illustrates a case where
l
wording is not consistent with intent. Although this TS was
subsequently deleted, no effort was made to revise the wording
'
i
during a 6-month period from the time this TS led to a plant
i
shutdown to the time the deletion was requested.
l
Licensee efforts towards the resolution of safety issues is evi-
l
dent by its active participation and close contact with various
!
industry groups involved in the identification and resolution of
safety issues. These groups include the BWR Owners Group, the
Institute for Nuclear Power Operations, the Seismic Qualifica-
tion Utility Group, the Nuclear Utilities Fire Protection Group,
f
D
s
28
.
the Nuclear Utility Group on Station Blackout, IDCOR, the Nucle-
ar Utility Management and Resource Committee, the Atomic Indus-
.
trial Forum, and the American Nuclear Society.
With a few ex'ceptions, safety evaluations submitted by the
licensee in support of proposed TS changes or to resolve techni-
cal issues have been clear and substantive. One exception was
the documentation (a contractor report) submitted to support a
TS revision to lower the MSIV isolation water level setpoint.
Better screening of contractor outputs, for clarity as well as
technical content, will reduce the NRR resources required for
review, with attendant reduction in cost-'tc the licensee.
Licensee responsiveness to NRC initiatives was noted in the pre-
vious two SALP evaluations as an attribute for which improved
performance was sought.
No improvement in the licensee's over-
all spirit of cooperation, however, was evident during this
rating period.
Encompassed here is the licensee's responsive-
ness to requests for information, both verbal and written, de-
lays in submittal or resubmittal of documentation (often of a
routine or simple nature), and the general reluctance to provide
definitive schedules. All of these factors represent impedi-
ments to conducting day-to-day business.
Examples include poor
responsiveness to requests for additional information concerning
the following reviews: SpDS (isolation devices), Salem ATWS
Item 1.2, an Appendix R exemption related to safe shutdown, and
the ISI program review.
In addition, delays were experienced in
the resubmittal of amendment requests concerning NUREG-0737 TS
(a problem area identified in the previous SALP evaluation) and
transfer of reserve power (returned to the licensee because of
an inadequate Sho11y analysis).
Delays in the submittal of TS
needed to support plant modifications, in accordance with 10 CFR 50.59, have also been evident.
Cases in point are the TS re-
lated to second level undervoltage protection modifications, the
analog transmitter trip system installation, and containment
isolation valve additions.
In view of i.he previous elimination of a large backlog of li-
censing actions, and the increase in size of the licensing
staff, improvement was possible during this rating period but
was not achieved.
In summary, the licensee needs to improve
communications as well as its spirit of cooperation with the
HRC in the area of licensing activities.
2.
Conq1usion
Rating: 2
Trend:
Declining
,
,s
o
)
29
3.
Board Recommendations
None
l
!
!
.
I
!
l
t
F
3
-
y
- p
r
30
'
.e
.
,
'
I'.
~ Training and Qualification Effectiveness (NA)
1.
Analysis
The.various a'spects of this functional area have been considered
-
.
.and discussed as an integral part of other functional areas and
the respective inspection hours have'been included in each one.
- Consequently, this discussion is a synopsis of the assessment's-
related to training conducted-in other areas. Training effec -
tiveness has been. measured primarily by the observed performance
of licensee personnel and,,to a lesser degree, as a review of
program adequacy. The discussion below addresses three princi-
ple areas:
licensed operator training, nonlicensed staff
training, and the status of INP0 training accreditation.
In the previous assessment period, this-functional area was rat-
ed as Category 2.
FitzPatrick management displayed a strong
commitment to training, shown by several programs for the im-
provement of the technical knowledge of both licensed and non-
licensed personnel. A declining trend had been noted in lic-
ensed operator examination results. This was attributed to in-
adequate screening of the candidates.
During this assessment period, one set of replacement operator
. licensing examinations was administered, and a requalification
training program inspection was also conducted by NRC. Region I.
A total of six candidates were given written and oral examina-
tions for initial licenses in July 1986. The two (2) Senior
Reactor Operators (SRO) candidates-and the Instructor Certifi-
cation candidate passed the examination. Of the three (3).Reac-
tor Operators (RO) candidates, one passed, one failed the oral
examination,'and one failed both the. oral and written
,
examinations.
During this assessment period, several deficiencies were noted
in the administration of the licensed operator training program.
'
'As noted above, two of the three Reactor Operator license candi-
dates failed the examinaticn given this period. Over the past;
two years, four of six Reactor Operator candidates have failed
the examination. This poor performance has been attributed to
inadequate screening of NR' examination candidates and not poor
J
-training practices. This conclusion is based on the performance
of the-Reactor Operator and Senior Reactor Operators who have
passed the examinations and the fact that both the Senior Reac-
tor Operators and Reactor Operators are trained together in one
classroom.
An inspection of the FitzPatrick requalification training pro-
gram identified significant weaknesses. The utility training
,
x
<
-
6
e
31
.
~
staff ' submitted 20% of.both the _SRO and R0 written requalifi-
-
cation ~ examinations given, including the answer keys,.to.the NRC
for parallel grading.
A' comparison of results revealed signifi--
. cant differences between the licensee and the NRC grading, with
the NRC grade's being lower in allicases. A review of the grad-
ing techniques revealed that many questions were not graded
strictly'to the answer key, and grading between the examinations
g.
wa. ' ansistent.
Oth
weaknesses identified during the requalification training
program inspection included poor: lectures, poor attendance,
~
missed required reading assignments, missed oral examinations,
and overall weak program supervision. Some of these problems
can be attributed to the temporary reassignment of the requaliff-
cation program administrator,.who attended advanced technical
training for eight months.
In his absence,.the as;igned program
administrator did not adequately. implement the requalification
program and the licensee management failed to properly. oversee
the program. However, many of these weaknesses' existed before
4 the reassignment and are attributed'to overall poor management-
oversight of the program.
Although weaknesses were noted in the administration of the
requalification program, these weaknesses did not appear to
have a' direct-impact.on the day-to-day operations of the plant,
as evidenced by the 'small number of personnel errors and opera-
tional events. A positive. initiative,.which was-begun during
this assessment period by the Operations Department, was an
on-shift operator training program. This program, implemented
to improve operator knowledge, includes auxiliary operator
walkthroughs, scenario walkthroughs with the entire shift,
written examinations, and incident discussions.
The training programs for nonlicensed personnel continue'to be
strong and effective as evidenced by the absence of personnel
errors and improvement in performance. The stcte' accredited
training program has been implemented and well received. Con-
tinued. improvements are being made in the area of nonlicensed
. operator training program as evidenced by the implementation
of a formal remediation program.
In addition, FitzPatrick main-
'tained strong and effective training programs for maintenance,
radiation protection, and security personnel.
FitzPatrick received training program accreditation from INP0 in
the areas of Reactor Operators, Senior Reactor Operators and
auxiliary operators. The self-evaluation reports for the remain-
ing seven programs have been submitted and the Accreditation
Team visit to review these programs is scheduled for February
1987. The simulator and new training facility are scheduled for
completion in mid-1988.
. .
oc
. . :
32
'
In summary, the training programs for nonlicensed operators,
maintenance workers, radiation protection technicians, and
security personnel were strong and effective.
Problems occurred
in the screening of initial operator license candidates and the
- administration of the requalification training of ifcensed oper-
ators, but FitzPatrick management belatedly found the problems
(concurrently with NRC inspections)-and corrective action is.
being taken regarding the requalification program.
In spite of
the problems there is no evidence that they adversely affected
plant operations.
2.
Conclusions
Rating:
2
<
3.
Board Recommendations
None
i -
4
4
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33
J.
Assurance of Quality
1.
Analysis
Assurance of Quality is a summary assessment of management over-
sight and effectiveness in implementation of the quality assur-
ance program and administrative controls affecting quality.
Activities affecting the assurance of quality as they apply spe-
cifically to a functional area are addressed under each of the
separate functional areas.
Further, this functional area is not
merely an assessment of the Quality Assurance Department alone,
but is an overall evaluation of management's initiatives, pro-
grams, and policies which affect or assure quality.
During the previous assessment period, this functional area was
rated as a Category 2.
The Quality Assurance (QA) Department
was actively involved in startup testing, maintenance and modi-
fication activities. Weaknesses noted were in the scope of au-
dits and involvement in surveillance testing.
During this assessment period, the weaknesses noted above have
been corrected. With the exception of Radiation Protection Pro-
grams, audits were found generally to be of sufficient depth.
The QA departmeat also utilizes surveillances to review activi-
ties in progress.
The QA department expanded their involvement
in the surveillance test area.
A review of the quality assurance program found the QA depart-
ment to be adequately staffed. The QA personnel receive train-
ing in the department and at the Training Center. The QA depart-
ment is part of the corporate organization, but frequent meet-
ings of the QA Superintendent, the Resident Manager and the
Superintendent of Power are held to discuss QA/QC concerns.
.
Thus QA issues are brought to the attention of appropriate. plant
'
management in a timely fashion.
A maintenance program for items in storage was lacking and re-
sulted in a pump being improperly maintained. The lack of such
a program was brought to the licensee's attention in 1983, 1984
and during the course of inspection 86-11.
The licensee has
initiated corrective action in the form of a material equipment
list which is scheduled for completion in January 1987 and for
full implementation by late 1988. The list is intended to
identify all the maintenance requirements for each item. Cor-
rective actions in this area have been slow.
The licensee has recognized a need for improvement in the per-
formance of receipt inspections by QC inspectors and is develop-
ing an upgraded receipt inspection instruction.
The instruction
will delineate receipt inspection requirements, and provide
.
,
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34
.
-
.
guidance to inspectors. Without the instruction, inspectors
must rely on their experience, which can result in inconsistent
inspection results.
The Quality A'ssurance Department plays an active role in assur-
ing quality at the plant. There are excellent lines of communi-
catior, between the QA department, plant management and each
department. The QA department has also contributed significantly
by their involvement in the Scram Reduction Program, Technical
Specification Matrix, Master Equipment List, procedural reviews,
and surveillance of plant activities. The QA Superintendent
emphasizes _ quality on the front-end and not after-the-fact.
He
accomplishes this by making sure that in process inspections
and evaluations receive high priority and paperwork audits are
placed in proper perspective.
In addition, the QA department
conducted a review of vendor QA programs and facilities when
problems arose with Containment Atmosphere Analyzes and
Rosemount transmitters.
Corporate and station management are actively involved in plant
activities. Senior plant management exhibits an excellent
attitude toward plant safety and have focused their efforts on
reducing personnel errors and instilling a pride of workmanship.
These efforts appeared to be effective, based upon the small
number of personnel errors and high plant availability.
First
line supervision is actively involved in monitoring work activ-
ities to assure a quality product. NYPA's work force is stable,
experienced, knowledgeable, and dedicated, and represents a
strength. NYPA has demonstrated a quality attitude by imple-
menting the Scram Reduction Program, newly organized work con-
trol center, and revised work activity control procedures. They
also maintain an effective program of establishing and tracking
management goals and objectives. The goals provide an extensive
_.
data base of information for monitoring NYPA's performance and,
in many cases, are compared to a management goal.
Improvements have been noted in the Plant Operations Review Com-
mittee (PORC).
The PORC has generally displayed a more inquisi-
tive nature in reviewing events. One exception was the review
following a reactor trip discussed in Section C, Maintenance.
The PORC utilizes a formal system to track resolution of issues
or questions and corrective actions.
One overall weakness noted was the sinw or ineffective resolu-
tion to previously_ identified problems which included: mainten-
ance of stored items, calibration program weaknesses identified
in a 1983 audit, and failures to make required Emergency Notifi-
cation System reports discussed in Section A, Operations.
In summary, the Quality Assurance Department plays an active
role in assuring quality at FitzPatrick. The plant management
..
-.
35
generally displays an aggressive attitude for improvement of
quality at the facility, as evidenced by establishing and imple-
menting improvement programs noted above. However, some pro-
grams are still slow in developing and lapses have occurred in
implementing some corrective actions, performing root cause
analysis, implementation of the requalification training pro-
gram, and procedural adherepce. These issues require continued-
management attention.
2.
Conclusions
Rating: 2
Trend:
Improving
3.
Board Recommendations
None
.
_
_-
____-_
. _ _ _ _
_ _ _ _ _ .
.
.
36.
V.
SUPPORTING DATA AND SUMMARIES
A.
Investigation and Allegation
'
None
B.
Escalated Enforcement Actions
None
C.
Management Conferences
Two management meetings were held during the assessment period. One
was held April 25, 1986, to discuss the last SALP report. The second
was held August 5, 1986, this was to discuss NYPA's progress on the
Scram Reduction. Program as recommended in the last SALP.
D.
Licensee Event Reports
Twenty LERs were submitted during this assessment period. The LERs
are listed in Table 3.
The following is a tabular listing of the
results of the causal analysis of the LERs.
A.
Personnel
Error..................
5
B.
Design / Man./Construc./ Install....
6
C.
External
Cause....................
O
D.
Defective Procedures.............
3
E.
Component Failure................
3
X.
0ther............................
3
Total 20
Causal Analysis
The following sets of common mode events were identified:
Inadvertent RPS Actuations
Five LERs (86-04, 86-06, 86-10, 86-13, and 86-17) reported reactor
trips. The analysis of these events is delineated in Table 6.
Inadvertent ESF Actuations
l
Three LERs (85-28, 86-05, and 86-15) reported isolations of either
the High Pressure Coolant Injection System or Reactor Core Isolation
Cooling Injection System. These were due to different causes includ-
ing component failure, design deficiencies and inadequate procedures.
l
l
!
l
1
.
4.
37
Inoperable ESF Systems
Three LERs (86-03, 86-12, and 86-14) report the High Pressure Coolant
Injection System inoperable. The causes varied but all were due to
inoperable motor o'perated valves.
In one case, the failure was due
to corrosion. caused by a steam leak, another due to procedural inade-
quacies, and the third, design deficiencies.
Surveillance Testing
Three LERs (86-01, 86-02, and 86-09) reported missed or late surveil-
lance tests. Two were caused by inadequate program administration
and the third due to personnel error.
E.
Licensing Activities
1.
NRC/ Licensee Meetings / Site Visits
Site Visits: March 18, May 16, June 26-27, October 22, 1986
Meetings: February 10, 1986: Discussed licensing action status
March 18, 1986: Discussed Sholly preparation
April 10, 1986: Licensing counterparts meeting
(BWD#2)
April 25, 1986: SALP management meeting
May 16, 1986: Discussed licensing action status
July 31, 1986: Discussed Technical Specifications
related to control room habitability
September 11, 1986: Discussed licensing action status
2.
Commission Briefings
None
3.
Schedular Extensions Granted
None
4.
Relief Granted
April 18, 1986; Certain inservice inspection requirements
5.
Exemptions Granted
April 30, 1986; certain requirements of Appendix R
September 15, 1986; certain requirements of Appendix R
6.
License Amendments Issued
Amendment No. 98, issued May 6, 1986; revises TS regarding sin-
gle loop operation
_ - -
- . .
,
38
Amendment No. 99, issued June 20, 1986; revises TS to clarify
responsibility of Plant Operating Review Committee
Amendment No. 100, issued June 20, 1986; revises TS regarding
composition of Safety Review Committee
Amendment No. 101, issued October 24, 1986; revises TS regarding
enriched bundles stored in spent fuel pool.
Amendment No. 102, issued October 31, 1986; revises TS to impose
more restrictive leakage limit and increased surveillance re-
quirements (NUREG-0313)
7.
Emergency / Exigent Technical Specifications
None
8.
Orders Isse'ed
None
9.
NRR/ Licensee Management Conferences
None
s
-
-
.
4-
39
,
TABLE 1
INSPECTION REPORT ACTIVITIES
Report / Dates
Inspec' tor
Hours
Area Inspected
85-31
Resident
76
Routine Resident
12/1/85 - 1/17/86
Inspection
86-01
Resident
109
Routine Resident
1/18/86 - 3/10/86
Inspection
86-02
Specialist
26
Routine Security
1/13/86 - 1/16/86
'
86-03
Specialist
47
Routine Transportation
1/28/86 - 1/31/86
86-04
Resident
227
Routine Resident
3/11/86 - 5/9/86
Inspection
86-05
Resident
128
Routine Resident
5/10/86 - 6/20/86
Inspection
86-06
Specialist
74
Routine Dosimetry
5/19/86 - 5/23/86
Program
86-07
Specialist
110
6/17/86 - 6/19/86
and Observation of
Emergency Exercise
86-08
Specialist
72
Surveillance Program
6/2/86 - 6/6/86
86-09
Specialist
N/A
Operator Examination
7/28/86 - 7/31/86
Report
86-10
Resident
153
Routine Resident
6/21/86 - 8/8/86
Inspection
86-11
Specialist
46
Routine Quality
,
7/14/86 - 7/18/86
Assurance Program
86-12
Specialist
36
Radiological
7/21/86 - 7/25/86
Environmental
Monitoring Program
,
'
86-13
Resident
123
Routine Resident
8/9/86 - 9/29/86
Inspection
E-
. . , -
e
[
40
86-14-
Specialist
57
Environmental
8/25/86 - 8/28/86
Qualification of
Limitorque Valve
Wiring
,
86-15-
Specialist
130
Requalification
9/16/86 - 9/18/86
Training Program
86-16
Specialist
38
Maintenance
!
9/22/86 - 9/26/86
Surveillance Testing.
& ISI Programs
86-17
Specialist
126
Routine Radiation
9/29/86 - 10/3/86
Protection' Program
86-18
Resident
171
Routine Resident
9/30/86 - 11/24/86
Inspection
!
86-19
Specialist
56
Special Nuclear
10/21/86 - 10/23/86
Material Control Program
l
86-20
Specialist
27
Routine
l
10/21/86 - 10/23/86
Norradiological
i
Chemistry Program
86-21
Specialist
56
Routine Effluent
i
11/17/86 - 11/21/86
Monitoring Program
86-22
Specialisc
32
Routine Security
l
11/24/86 - 11/26/86
i
l
!
!
.
_
o
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.
-
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n,
41
.
,
3,
'
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,
[
TABLE 2
'
,
INSPECTION HOURS SUMMARY
- JAMES A. FITZPATRICK NUCLEAR POWER PLANT
TIME
HOURS
% OF TIME
A.
Plant Operations...........................
773
40.3
i
>
,
_
'. B.
Radiological
Controls......................
392
20.4
C.
Maintenance................................
159
8.2
,
D.
Surveillance...............................
194
10.1
l
E.
Emergency Preparedne s s. . . . . . . . . . . . . . . . . . . . .
110
5.7
+
i
F.
Sec,uri ty and Safegua rds. . . . . . . . . . . . . . . . . . . .
140
7.3
G.
Outage Managemert and Engineering Support..
152
7.9
H.
Licen sing Activi ti es . . . . . . . . . . . . . . . . . . . . . . . .
I.
Training and Qualification..................
Effectiveness
/
J.
, A s s u ra n c e . o f Q ua l i tyl . . . . . . . . . . . . . . . . . . . . . . .
t,
,
0 '. 9
Total
1920
100%
I
f.,,
(
)
,y
d
'liours expended in facility license activities and operator license
activities not included with direct inspection effort statistics.
- Hours expended in the areas of training and quality assurance are included in
other functional areas, therefore, no direct inspection hours are given for
p
,these areas.
-
!
1
,
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.5
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. . .
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42
'
.
TABLE 3
LISTING OF LERs BY FUNCTIONAL AREA
'
CAUSE CODES
AREA
A
!
C
D
{
X
TOTAL
Operations
1
3
0
0
1
1
6
Radiological / Controls
0
0
0
0
0
0
0
Maintenance
0
2
0
2
1
0
5
Surveillance
3
0
0
1
0
1
5
Emergency Prep
0
0
0
0
0
0
0
Sec/ Safeguards
0
0
0
0
0
0
0
Outage Management
0
1
0
0
1
0
2
Training
0
0
0
0
0
0
0
Licensing
0
0
0
0
0
0
0
Assurance of Quality
1
0
0
0
0
1
2
TOTALS
5
6
0
3
3
3
20
Cause Codes: A - Personnel Error
B - Design, Manufacturing, Construction or
Installation Error
-
C - External Cause
D - Defective Procedures
E - Component Failure
X - Other
.
~
.
43
TABLE 4
LER SYN 0PSIS
LER Number
Event Date
Cause Code
Description
85-27*
11/22/85
E
Isolation Valves found
during testing.
85-28
12/13/85
E
High Pressure Coolant
Injection System Isolation
due to faulty trip unit.
86-01
3/3/86
A
Failure to perform APR.:
surveillance at required
frequency.
86-02
3/3/86
A
Failure to perform
Diesel Fire Pump
Surveillance at required
frequency.
86-03
3/12/86
X
Inoperable containment
isolation valve on High
Pressure Coolant Injection
system.
86-04
3/15/86
D
Reactor Trip while
shutdown performing post
work testing.
86-05
4/4/86
B
Reactor Core Isolation
Cooling isolation due to
loose lead.
86-06
3/25/86.
A
Reactor Trip while
shutdown due to low vessel
level.
86-07
3/23/86
A
Failure to meet
Environmental
Qualification requirements
for 4 valve operators
inside containment.
86-08
3/27/86
X
Setpoint drift of ASCO
pressure switches.
. _ _ .
a.
.
44
86-09
3/28/86
A
Late chemistry
surveillance during
startup.
86-10
4/4/86
B
Reactor trip while
conducting turbine stop
valve testing.
86-11
5/15/86
B
Failure of
recirculation 'oop
discharge byp.tzs valve to
operate.
86-12
5/25/86
B
High Pressure Coolant
Injunction inoperable due
to breaker tripping when
wetted.
86-13
7/3/86
B
Reactor trip due to
protective relay test
block failure.
86-14
9/3/86
D
High Pressure Coolant
Injection valve failure
due to procedural
,
inadequacies.
86-15
9/4/86
D
Reactor Core Isolation
Cooling isolation due to
inadequate venting of
transmitter.
86-16
9/9/86
X
Use of incorrect
Minimum Critical Power
.
Ratio calculation.
86-17
9/30/86
E
7 Reactor Trips while
shutdown due to neutron
instrument spikes.
86-18
10/15/86
B
Potential common mode
failure of circuit
breakers.
Event occurred during previous assessment period
,
,
I
i
-
a
45
TABLE 5
ENFORCEMENT SUMMARY 12/1/85 - 11/30/86
JAMES A. FITZPATRICK NUCLEAR POWER PLANT
A.
Number and Severity Level
Level of Violations
0
0
0
4
2
Deviation
0
TOTAL
~6
B.
Violation vs. Functional Area
SEVERITY LEVEL
FUNCTIONAL AREA
1
2
3
4
5
DEV.
TOTAL
Operations
2
2
Radiological Controls
1
1
Maintenance
1
1
Surveillance
1
1
Emergency Prep.
O
Sec/ Safeguards
0
Refueling and Outage
Management
0
Training
0
Licensing
0
Assurance of Quality
1
1
_
_
_
_
_
_
TOTALS
2
4
6
, ,, .
.
46
TABLE 5 (CONTINUED)
ENFORCEMENT SUMMARY
.
Inspection
Violation
Functional-
Report
Requirement
Level
Area
Violation
85-31
5
Operations
Failure to report
12/1/85-1/17/86
High Pressure
Conlant Injection
System Isolations
and Inoperability.
86-01
Tech Spec
4
Surveillance
Failure to perform
'1/18/86-3/10/86
4.0.8.
surveillances
within required
frequency.
86-11
4
Assurance of
Failure to properly
7/14/86-7/18/86 APP. B(XIII)
Quality
care for items in
storage.
86-12
Tech Spec
5
Rad Control
-Failure to
7/21/86-7/25/86
7.2
properly implement
procedure for
calibration of Alpha
Beta counter.
86-13
Tech Spec
5
Maintenance /
Failure to
8/9/86-9/29/86
6.8(A)
Rad. Control
properly implement
procedures for
installing a pressure
transmitter and survey
new fuel shipments.
86-13
5
Operations
Failure to make
8/9/86-9/29/86
ENS report for reactor
core isolation cooling
system isolation.
.,.a.
47
TABLE 6
REACTOR TRIPS AND UNPLANNED PLANT SHUTDOWNS
The reactor trips occurring 'during this assessment period fall into three cate-
gories.
These categories included personnel error, procedural deficiency, and
equipment malfunction. This section assesses the root cause of each trip with-
in each category from the NRC's perspective.
Power
Functional
Date
Level Description
Cause
Area
1.
3/15/86
SD Reactor trip due to Personnel Error:
Assurance
post-work testing
An inadequate review of a
of
on RPS. (LER 86-04) procedure change resulted
Quality
in energizing one
of the backup scram
solenoids causing the scram.
2.
3/25/86
SD Reactor trip due to Personnel Error:
Operations
reactor vessel low
Inadequate control of
level . (LER-86-06)
activities in the control
room caused the trip when
the operator's attention was
diverted to stop a feedwater
leak while purposely lowering
vessel level.
3/28/86
Start-up
3.
4/4/86
88% Reactor trip during Procedural Deficiencies:
Maintenance
turbine stop valve
Loose bolts on turbine stop
testing due to
valve, which were apparently
faulty valve
not torqued, allowed a stroke
position indication change causing faulty position
(LER 86-10)
indication.
4/6/86
Start-up
!
l
4.
5/15/86
Shutdown required
Equipment Failure:
Engineering
by Technical Spect- Inadequate design change
Support
fications due to
review resulted in valve
inoperability due to thermal
Recirculation loop
growth.
discharge bypass
valve (LER 86-11)
5/18/86
Start-up
l
I
. - . . .
.
'48
5.
7/3/86
100% Reactor Trip.due to Equipment Failure -
Maintenance
Random: A failure in
(LER 86-13)
protective relay test
circuit caused a turbine trip.
7/4/86
Start-up
6.
9/30/86
~ SD Reactor Trip due to Equipment Failure -
Maintenance
neutron monitoring
Random: A wet connector
instrument failure
caused the LPRM to fail
(LER 86-17)
upscale.
7-12.
10/1/86
SD- Seven reactor trips Equipment Failure:
Maintenance
10/3/86
due to neutron
During under-vessel work,
10/4/86
monitoring
maintenance personnel
instrument spiking
bumped "G" IRM connector
(LER 86-17)
which was later found to'
l
have a broken connector.
10/9/86
Start-up
L
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