ML20215D005

Forwards Draft NRR SALP Rept Input for Period Dec 1985 - Nov 1986.Proposed Overall Performance Rating in Functional Area of Licensing Activities Is Category 2

ML20215D005
Person / Time
Site:	FitzPatrick
Issue date:	12/12/1986
From:	Abelson H Office of Nuclear Reactor Regulation
To:	Bernero R Office of Nuclear Reactor Regulation
References
NUDOCS 8612160157
Download: ML20215D005 (10)

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• D cembsr 12, 1986 Docket No. 50-333 l NOTE FOR: Robert M, Bernero, Director

' Division of BWR Licensing THROUGH Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing FROM: Harvey I. Abelson, Project Manager CWR Project Directorate #2 Division of BWR Licensing

SUBJECT:

DRAFT NRR SALP INPUT FOR THE JAMES A. FITZPATRICK NUCLEAR POWER IllPUT FOR RATING PERIOD DECEMBER 1, 1985 THROUGH NOVEMBER 30, 1986 Enclosed is the NRR SALP report for the PASNY James A. FitzPatrick Nuclear Power Plant for the period December 1,1985 through November 30,

1986. The proposed overall performance rating in the functional area of Licensing Activities is Category 2. The report is scheduled to be sent to the Region early next week. x Cit?=I ?! nsd v.,

Harvey I. Abelson, Project Manager BWR Project Directorate #2 l Division of BWR Licensing

Enclosure:

Draft NRR SALP Report DISTRIBUTION t_ Docket File NRC PDR-Local POR PD#2 Memo 8612160157 DR 861212 ADDCK0500g3 SNorris a HAbelson i Glainas t DMuller Hb son /cd 12/W/86 12/ G /86 12//v/86

/.2 0FFICIAL RECORD COPY l

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Docket No. 50-333 FACILITY: James A. FitzPatrick Nuclear Power Plant LICENSEE: Power Authority of the State of New York (PASHY)

EVALUATION PE' OD: December 1, 1985 to November 30, 1986 PROJECT MANAGER: Harvey I. A.belson 1.0 'INTRODLCTION This report contains NRR's input to the SALP review for the James A.

FitzPatrick Nuclear Power Plant. The assessment of the licensee's performance was conducted according to NRR Office Letter No. 44, NRR Inputs to SALP Process, dated January 3,1984. Office Letter No. 44 incorporates NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance.

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SUMMARY

NRC Manual Chapter 0516 specifies that .each functional area evaluated will be assigned a performance category (Category 1, 2 or 3) based on a composite of a number of attributes. The performance of the PASNY in the functional area of Licensing Activities is rated Category 2.

3.0 CRITERIA t

The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.

4.0 METHODOLOGY This evaluation represents the integrated inputs of the Project Manager (PM) and those technical reviewers who expended significant amounts of effort and/or prepared a Safety Evaluation for the James A. FitzPatrick Nuclear Power Plant licensing actions during the current rating period. Using the guidelines of NRC Manual Chapter 0516, the PM and each reviewer applied specific evaluation criteria to the relevant licensee performance attributes, as delineated in Chapter 0516, and assig ed an overall rating' category (1, 2 or 3) to each attribute. The reviewers included this informatior as part of each Safety Evaluation transmitted to the PM. The PM, af ter reviewing the inputs of the technical reviewers, combined this information with his own assessment of licensee performance and arrived at a composite rating for the licensee. This rating also reflects the comments of the NRR Senior Eecutive assigned to the FitzPatrick SALP assessment. A written evaluation was circulated to NRR management for comments, which were considered in the final draft.

The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating period. These actions, consisting of amendment requests, exemption requests, code relief requests, responses to generic letters, THI and Salem ATWS itens, and other actions, are listed below:

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Kultiplant Actions B-72 NUREG-0737 Technical Specifications (Generic Letter 83-02)

B-78 PostMaintenanceTesting(Items 3.1.1 & 3.1.2)*

B-83 NUREG-0737 Technical Specifications (Generic Letter 83-36)

B-85 Post Trip Review (Item 1.2)

B-87 Post Maintenance Testing (Items 3.2.1 & 3.2.2)*

B-92 Reactor Trip System Functional Test (Item 4.5.1)*

D-20 Mark I Drywell Vacuum Breakers

• E-04 Single Loop Operation (Technical Specification Change)*

F-09 Safety Parameter Display System F-71 Detailed Control Room Design Review Plant Specific Actions NUREG-0313 Technical Specifications

• ISI Relief Requests * <

Exemption: AppendixR(FireDampers)* '

Exemption: Appendix R (Core Uncovery During Safe Shutdown)*

Feedwater 110zzle Cracking Analysis Review

• Technical Specification Change: PORC Function

• Technical Specification Change: SRC Alternate. Vice-Chairman

• Technical Specification Change: Enriched Bundles in Spent Fuel Poo1*

Review of Inservice Inspection Second 10 Year Program Review of Revision to Offsite Dose Calculation Manual

• Technical Specification Change: Control Room liabitability i Technical Specification Change: Management Reorganization Technical Specification Change: Dual Role SR0/STA > -

Technical Specification Change: NSIV Water Level Setpoint Technical Specification Change: Transfer of Reserve Power to Emergency Buses 5.0 ASSESSMENT OF PERFORMANCE ATTRIBUTES This evaluation of the licensee's performance was based on consideration of six of the seven attributes specified in NRC Manual Chapter 0516. These are:

- Management Involvement and Control in Assuring Quality

- Approach to Resolution of Technical Issues from a Safety Standpoint

- Responsiveness to NRC Initiatives i

- Reporting and Analysis of Reportable Events .

-Staffing (includingManagement)

- Training and Qualification Effectiveness For the remaining attribute, Enforcement llistory, there is no basis for a rating by NRR.

In addition, this evaluation includes an assessment of the licensee's housekeeping practices and the conduct of control room personnel.

• Indicates action completed

5.1 MANAGEMENT INVOLVEMENT AND CONTROL'IN ASSURING QUALITY 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 now report to the same Vice-President (Mr.

. Ralph Beedle). Notwithstanding the differences in respective reactor designs, this change should result in more uniform interactions with hRR and an ,

enhanced exchange of information and experiences between the two licensing staffs. .

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 w tages. Nevertheless, management interest and involvement in licensirg ,

activities was evident.- A case in point was the attendance-of Mr. Beedle and ,

the Indian Point Licensing Director at a counterparts working meeting between

.BWR Project Directorate #2 staff and licensing managers of utilities assigned to that directorate, held last April. Mr. Beedle,was the only Vice-President

-in attendance. Increased management attention to the quality of Sholly evaluations and correspondence, in general, has also been evident during this rating period and is responsive to a recommendation made in the previous SALP evaluation.

Increased management attention, however, should be directed toward ensuring i the timely scheduling of submittals, particularly those that are outage related or on a critical path, to avoid last minute activities that could result in delay in plant startup. Communications with NRR regarding the advanced planning and scheduling of licensing actions should be improved.

Perhaps better use could be made of the computerized tracking systems which both the licensee and NRR have available. Where planned modifications will require new Technical Specifications (TS) or changes to existing TS, NRC approval must be granted, as per 10 CFR 50.59, prior to operation with the .

' modification in place. Cases which illustrate these points include the TS associated with second level undervoltage protection modifications and new installations of containment isolation valves. Submittal of these TS appear ,

to be unnecessarily delayed.

Increased management attention should also be directed toward correcting and revising the TS to ensure that the current, as-built configuration of the plant is reflected. A case in point is Table 3.7-1 regarding containment isolation valves. Revisions to the TS should also be proposed in a timely i manner where errors are evident, or where the wording does not clearly reflect i

the intent of the TS. An example of the latter is the TS pertaining to j recirculation bypass valves.

! Based on the above considerations, the licensee is rated Category 2 for this .

. attribute.

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5.2 APPR0ACH TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT The licensee's efforts towards the resolution of safety issues is evident 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 of Nuclear Power Operations, the Seismic Qualification Utility Group, the Nuclear Utilities Fire Protection Group, the Nuclear Utility Group on Station Blackout, IDCOR, the Nuclear Utility Management and Resource Committee, the Atomic Industrial Forum, and the American Nuclear Society.

With a few exceptions, safety evaluations submitted by the licensee in support of proposed TS changes or to resolve technical issues have been clear and substantive. One of these exceptions was the documantation (a GE report) submitted to support a TS revision to lower the MSIV 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 to the licensee.

The rating for this attribute is Category 2.

5.3 RESPONSIVENESS TO NRC INITIATIVES ,

In the previous two SALP evaluations, this was noted as an attribute for which improved licensee performance was sought. In view of the previous elimination of a large backlog of licensing actions, and the increase in size of the licensing staff, we would have expected greater improvement than was evident during this rating period.

The overall spirit of cooperation exhibited by the licensee remains less than

, satisfactory. Where the licensee at times appears to view the Commission's

- role as an adversarial one, the common goals of the Commission and the licensee should be better recognized. Encompassed here is the licensee's

, responsiveness to requests for information, both verbal and written, the delays in the submittal or resubmittal of documentation (often of a routine or simple nature), and the general reluctance to provide definite schedules. All of these factors represent impediments to conducting our day-to-day business.

Some examples of poor responsiveness include providing data in response to a ,

request for informatiori concerning the SPDS review, resubmittal of an amendment request pertaining to transfer of reserve power because of an inadequate Sholly analysis, resubmittal of an amendment request related to NUREG-0737 (a problem area already identified in the previous SALP evaluation), and a response to a request for information regarding the ISI s program review. Additionally, there appear to be impediments to open and direct exchange of information between NRR and plant management. An improvement in the level of communications is needed in the future.

Based on the above considersations, the rating for this attribute is Category 3.

5.4 REPORTING AND ANALYSIS OF REPORTABLE EVENTS Operating Events During this rating period, the licensee submitted 20 non-security reportable events in accordance with 10 CFR 50.72 and 24 Licensee Event Reports (LER) in accordance with 10 CFR 50.73. None of the events were considered significant enough to be discussed at the NRR Operating Reactors Events Briefing. A study

-of the reported events shows no pattern of repetition, indicating that corrective actions are effective. Events were generally identified and analyzed properly and there were few subsequent revisions of_ the LERs. The licensee has been diligent in submitting LERs within the prescribed time  :

limit. '

Occupational Dose The FitzPatrick plant started commercial operation in July,1975. Since 1976, the plant average occupational dose per unit electrical power production has i been approximately 2.1 person-rem per/MWE-Yr. The average total yearly dose has~ been approximately 1081 person-rem. Both values are higher than at other .

operating BWR's. 'In addition, for the years 1983 to 1985, the average total; yearly ' dose at FitzPatrick has been 1037 person-rem, which is higher than the average dose of 921 person-rem for a BWR. However, from January 1986 to November 1986, the occupational dose at FitzPatrick was approximately 350 .

person-rem. This is clearly a significant reduction from their current '

average. However, it should be noted that no refueling' outage occurred during this period and, therefore, the dose represents only an average value for the ,

industry. 4 1 FitzPatrick's ALARA management program for the assessment period

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demonstrates significant progress in reducing occupational dose. However, due i to the plant's poor history in maintaining doses at a low level, a continued effort should be made by plant management towards further reduction of the occupational doses at the site.

Conclusion r

The above discussion regarding operational events indicates a well operated and well maintained plant. On the' basis of FitzPatrick's dose history since ,

the beginning of commercial operation, occupational doses are significantly higher'than at most other operating BWR's. However, progress has been noted for the current assessment period.

The composite rating for operating events and oce.upational dose management is , ,

Category 2. .

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y' 4 5.5 STAFFING During this rating period, two new members were added to the FitzPatrick licensing staff. The staff is now comprised of seven full-time members, all of whom are degreed engineers, and one of whom is a former reactor operator.

One of the two new additions will serve as a licensing assistant, responsible for various administrative tasks including the tracking of licensing actions.

With its present complement, it is expected that the staff will interact with NRR in an efficient and effective manner, particularly in the absence of any significant licensing action backlog. There have been no turnovers of personnel within the licensing staff.

The rating for this attribute is Category 1.

5.6 TRAINING AND QUALIFICATION EFFECTIVENESS During this rating period, two members of the licensing staff participated in a four week training course at the FitzPatrick site. The course, " Boiling Water Reactor Technology", addressed procedures and administrative controls as well as systems and components. This indicates that licensee management is willing to allocate significant resources to providing its licensing' staff with well-rounded and comprehensive training.

The rating for this attribute is Category 1.

5.7 HOUSEKEEPING AND CONTROL ROOM CONDUCT Observations made by the NRR project manager while visiting the site on several occasions during this rating period indicate that the licensee's housekeeping practices are adequate. The removal and relocation of the security panel from the central .part of the control room appeared to alleviate the previous congestion and improve the traffic pattern. Control room personnel appeared to conduct themselves in a professional manner.

The rating for this attribute is Category 2.

6.0 CONCLUSION

An overall performance rating of Category 2 has been assigned in the licensing area.

Section 042 of the Manual Chapter 0516 defines the meaning of rating the licensee's performance Category 2 as follows: "NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonable effective such that satisfactory performance with respect to operational safety or construction is being achieved."

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We believe that no less management effort on the part of the licensee should

'be exerted in licensing activities. Similarly, even though the Power Authority of the State of New York is rated Category 2, no less NRC attention in the licensing category would be appropriate.

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Information to be Added to Section 5 of SALP Report

" Supporting Data and Summary"

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: Licensingcounterpartsmeeting(BWDh2)

April 25, 1986: SALP management meeting May 16, 1986: Discussed licensing action status July 31, 1985: Discussed Technical Specifications related to control room habitability September 11, 1986: Discussed licensing action status

2. Comission 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 single loop operation i 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 requirements (NUREG-0313)

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7. Emergency / Exigent Technical Specifications None

8. Orders Issued None

9. NRR/ Licensee Management Conferences None ,

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