ML20236D592
| ML20236D592 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick |
| Issue date: | 07/27/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML20236D594 | List: |
| References | |
| NUDOCS 8707300540 | |
| Download: ML20236D592 (4) | |
See also: IR 05000333/1985098
Text
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l27 JUL 1987
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'D'ocket No,'50-333
Power Authority of.the' State-of New York.
James A. FitzPatrick Nuclear Power Plent
ATTN: Mr. J.'C. Brons
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' Senior Vice Pr'esident - Nuclear Generation
=123 Main Street-
White Plains, New York 13093
Gentlemen:'.
'
Subject: ;SystematicAssessmentofLicenseePerformance(SALP){ReportNo.
50-333/85-98 - Amended' Report
'
'This refers: to the assessment we ' conducted of the activities at the. James A.
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FitzPatrick- Nuclear. Power Plant,. for the period December 1,1985 to' November-
30, 1986. This report.was discussed with you at a meeting on April. 15, 1987.
at.the Region I' office in King of Prussia, Pennsylvania. The list'of meeting'.
attendees is attached as Enclosure:1'. Your; written comments on our. report
have been reviewed and are enclosed as Enclosure 2.
We acknowledge.the
additional:information you have supplied; however, my staff.'has only made
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' minor editorial changes to the report as described in'the errata sheet,.
' Enclosure 5.
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Our overall. assessment of your. facility'operati.on^ concludes that your
' initiatives have improved performance:throughout the' facility. Although the
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functional area' ratings have remained..the same, this'does'not reflect.the
. general',-overall: improvement observed in site activities. ~ Plant management ~
ihas demonstrated a philosophy oriented toward nuclear' safety and has been
' influential.in improving the overall. plant performance. 'However, additional
management attention is'needed in the following areas:
procedural adherence,
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. follow-up. of commitments, and resolution of previously identified problem.
areas.
.
No reply to this letter is required.
Your' action in response to the NRC
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Systematic Assessment of Licensee' Performance -will be reviewed during future
'. inspections of your licensed facility.
We. appreciate your cooperation.
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~ Sincerely,.
Original Signed By
.
WILLIAM T. RUSSELI.
William T. Russell
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Regional Administrator
8707300540 870727 ,'~
ADOCK 05000333
a.
PDRc
. OFFICIAL RECORD COPY
SALP FITZ 85-98 - 0052.0.0
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27 JUL 1987
' Power Authority of-the' State
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of New York.
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' Enc 1osure:
1.
Attendees at FitzPatrick SALP Management Meeting
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2.
Response letter from New York Power Authority dated May 15, 1987
w/ attachments
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3.
SALP Board Report
)
4.
Letter from NRC to New York Power Authority dated March 13, 1987
5.
SALP Board Report Errata Sheet.
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cc w/ encl:
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J. Phillip Bayne, President and Chief Operating Officer
A. Klausmann, Vice President - Quality Assurance and Reliability
R. L. Patch, Quality Assurance Superintendent
George M. Wilverding, Chairman, Se
ay Review Committee
Gerald C. Goldstein, Assistant Gene,al Counsel
NRC Licensing Project Manager
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Radford J. Converse
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Dept. of Public Service, State of New York
Public Document Room (PDR)
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Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
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. State of New York
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
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Commissioner Carr
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bec w/ encl:
Region'I Docket Room (with concurrences)
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Management. Assistant, DRMA (w/o encl)'
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Section Chief, DRP
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. Robert J. Bores, DRSS
{
W. Johnston, DRS
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T. Martin, DRSS
J. Taylor, DEDO
W. Russell, RI
J. Allan, RI
]
D. Holody, RI.
K. Abraham, PA0 (2 copies)
Management Meeting Attendees
DRP Wishlist Coordinators (2)
- See previous concurrence page
hb
RI:DRP
RI:DRF
RI:DRP
RI:DRP
RI:DRA
RI:RA
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- John son /rhl
- Gallo
- Collins
- Kane
Allan
Russell
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7/ /87
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OFFICIAL RECORD COPY
SALP FITZ 85-98 - 0053.0.0
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27 JUL 1987
Power Authority of the State
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of New York
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cc w/ encl:
.J. Phillip Bayne, President and Chief Operating Officer
A. Klausmann, Vice President - Quality Assurance and Reliability
R. L. Patch, Quality Assurance Superintendent
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George M. Wilverding, Chairman, Safety Review Committee
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Gerald C. Goldstein, Assistant General Counsel
NRC Licensing Project Manager
Radford J. Converse
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Dept. of Public Service, State of New York
Public Document Room (PDR)
Local Public Document Roor.. (LPDR)
Nuclear Safety Information Center (NSIC)
.j-
NRC Resident Inspector
State of New York
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
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Commissioner Carr
bcc w/ enc 1:
Region I Docket Room (with concurrences)
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Management Assistant, DRMA (w/o encl)
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Section Chief, DRP
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Robert J. Bores, DRSS
,
W. Johnston, DRS
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T. Martin, DRSS
J. Taylor, DEDO
W. Russell, RI
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J. Allan, RI
D. Holody, RI
K. Abraham, PA0 (2 copies)
Management Meeting Attendees
DRP Wishlist Coordinators (2)
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RI:DRP
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R :DRP
I:DRP
RI:DRA
RI:RA
Johnson /rh1
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ollins
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Allan
Russell
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0FFICIAL RECORD COPY
SALP FITZ 85-98 - 0053.0.0
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ENCLOSURE 1
Attendees at FitzPatrick SALP Management Meeting
(April 15,1987)
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Nuclear Regulatory Commission
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J. M. Allan, Acting Regional Administrator
W.'F. Kane, Director, Division of Reactor Projects
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H. Abelson, Project-Managar - FitzPatrick
R. Capra, Acting Director, Project Directorate I-1
/R. M. Gello,: Chief, Projects Branch No. 2
J. Linville, Reactor Projects Section 2C
'G. Meyer, Project Engineer.
A. Luptak, Senior Resident Inspector, FitzPatrick
New York' Power Authority
J. Brons, Senior Vice President Nuclear Generation
.J. Bayne,'First Executive Vice President - Operations
R. Burns, Vice President Nuclear Operation
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S. Zulla, Vice President Nuclear Engineer
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.R. Beedle, Vice President Nuclear Support
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C. Spieler, Vice President Public Relations
.R. Converse, Resident Manager
W. Fernandez, Superintendent of Power
{
J Gray, Director Nuclear Licensing - BWR
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T. Dougherty,' Director Operation and Maintenance
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J. Kelly, Director Radiation Health and Chemistry
C. Patrick, Director Nuclear Policy and Information
D. Halama, Quality Assurance Manager
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R. Patch, Quality Assurance Superintendent
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ENCLOSURE 2
111 681.6200
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- > NewYorkPower
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tv Authority.
May 15, 1987
U.
S. Nuclear Regulatory Commission
Attn: > Document Control' Desk
D.C.
20555
Subject:
James A. FitzPatrick Nuclear Power Plant
Docket No. 50-333
Systematic Assessment of Licensee Performance (SALP)
,
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Reference:
SALP Board Report No. 50-333/85-98, transmitted
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by NRC letter T.
E. Murley to J.
C.
Brons, dated
March 13, 1987.
Dear- Sir:
On March 13, 1987, the Nuclear Regulatory Commission (NRC)
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issued the Systematic Assessment of Licensee Performance (SALP)'
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report for the James A. FitzPatrick Nuclear Power Plant.
A meeting
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to discuss the contents of this report was held in the NRC Region 1
offices on April 15, 1987.
This letter provides comments on three specific areas of the
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report where the presentation of additional information'is needed to
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provide a more accurate assessment.
Attachment 1 contains
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additional information concerning the areas of ALARA goal setting,
the instrument calibration program and nuclear licensing.
The Authority appreciates the opportunity. afforded by the SALP
process for improved understanding of issues related to the
FitzPatrick plant.
The report has been carefully reviewed and the
observations will be used as a basis for improvements in operation
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and support of the FitzPatrick plant.
Should you have any questions
-regarding this SALP response, please contact me or Mr.
J.
A.
Gray, J r.
of my staff.
Very truly yours,
ohn C.
Brons
Executive Vice President
{
,)NuclearGeneration
cc:
Office of the Resident Inspector
U.
S.
Nuclear Regulatory Commission
P.
O.
Box 136
Lycoming, New York
13093
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Nuclear Regulatory' Commission /
U.
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Region I
631 Park' Avenue
' King of Prussia, PA
19406
Mr.
H.
Abelson, Project Manager
Project Directorate I-1
Division of Reactor Projects-1/II.
U.S. Nuclear Regulatory Commission
7920 Norfolk Avenue
Bethesda, MD
20014
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ATTACHMENT 1
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.A.
ALARA Goal Setting:
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NRC SALP Statement (page 111:
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"The licensee's ALARA person-rem goal for the site was 600
person-rem.for 1986, a non-refueling year, based on a
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calculated exposure estimate of 575 person-rem.
With the
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accumulated exposure at the end of the assessment period,
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the exposure'for 1986 was not expected to exceed 400
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person-rem.
While this exposure reflects well on the
ALARA program, it shows the goal set for the 1986 calendar-
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year was not aggressive."
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NRC Inspection 86-17 Statement (pace 5):
"For 1985, a refueling year, the licensee had established
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an exposure-goal of 1,000 man-rem.
Actual exposure for
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that year was.1051 man-rem.
For 1986, a non-refueling
year, the established goal-is 600 man-rem.
This goal,
however, does not appear to be c,hallenging in view of the.
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following:
1.
The licensee estimated that they would only need 575
man-rem for the year.
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Exposure status as of September 14, 1986, was 248
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man-rem, with the potential for not exceeding 400
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man-rem for the year.
3.-
NUREG-0713, " Occupational Radiation Exposure at
Commercial Nuclear Power Reactors 1983 identifies the
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median exposure for all BWR's from 1973-1983, as
approximately 650 man-rem, which includes refue' ling
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outage.
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While the licensee appears to effectively control
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exposure, as evidenced by the current exposure total, it
does not appear that the 1986 goal serves as a useful
management tool for exposure control.
The inspector
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discussed goal setting with the licensee, who agreed that
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the 1986 goal was "not ambitious enough" and that efforta
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would be made to improve the setting of future ALARA
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goals."
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Authority Response:
The process of defining the final 1986 plant goal for
man-rem exposure included several steps and inputs which
unfortunately were not made clear to the inspectors during
Inspection 86-17.
The determination of the 1986 goal was
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made through-theffollowing process:
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lThe' projected cumulative exposure for 1986.was 571.8
man-rem based'on identified major-work achivities'for
1986. .This included two 14 day planned maintenance
outages and.14' days of unplanned outage time with
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exposure. rates of.approximately 5-1/2 man-rem per
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outage' day.
This estimate did not include projected
exposure'for several jobs that were to be scheduled-
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for 1986.
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2.
The prior'three years of FitzPatrick operations
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included the following exposure; data:
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Year
- Total Man-Rem
Outace Rem
Outace Days.
Rem / Day
'Proi'.
Actual
Proi.
Actual
Outace
Oper
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'83
993
1,090
632
748
92
8.13
1.25
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'84'
773
971
176-
645
62
10.40
1,38
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'85
1,197
1,051
887
764
106
7.21
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Therefore, the average outage day expcsure for. planned
and unplanned work.was about 8.5 rem and while operating
about:1.25 rem / day.
Thus, based on the 1986 proposed
schedule, the projected exposure rate based on
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historical data was 42 x 8.5 + 323 x 1.25 = 760.75 r?m.
3.
From INPO data, between 1982 and 1984, the median yearly
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BWR exposure was 1,030 man-rem per unit.
In addition,
from.other data (NRC), FitzPatrick's exposure history
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was:
{
Year
Averace BWR Exposure
Fit 2 Patrick
'79
733
85S.
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'80
1,136
2,040
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'81
980
1,425
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882
940
1,190
'83
1,056
1,090
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1,003
971
After assessment of these three data sets, the goal was set at
600: man-rem.
This goal was chosen to provide a continued downward
trend, challenge the work force and at the same time become a useful
management parameter.
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'During.the course of.1986, many-of the tasks planned for
" accomplishment;had to be delayed-because of manpower constraints-
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. caused by creation of the onsite construction group.
As1a result, the
1exposure-for the year was significant1y'less than projected, with a'
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final value of.-410 man-rem.'
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The SALP report in this instance is based on the information
-contained.in NRC Inspection Report 86-17 and the statement that the-
" licensee agreedLthat the goal was 'not ambitious enough'...".
There
is clearly. room for improvement in the area of ALARA work practices
and goal setting.
However, the data-in the inspection report did not
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reflect all-of the inputs which established'the1 basis for the 1986
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exposure goal. 'This.was due to incomplete information provided.to the
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' inspectors (ie.' input from only.one' department) which the< Authority
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did'not correct after publication of the inspection report.
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B.
Instrument Calibration Program
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NRC SALP Statement (pace 19):
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"The.NRC' identified that not.all safety-related instruments
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were being periodically calibrated, nor was there an
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adequate surveillance test to verify that they are
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functioning within the required ranges.
The licensee'
immediately calibrated those' instruments identified and was'
further evaluating thefremaining safety-related instruments
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for periodic calibration.- Also, the delayed. implementation
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'alibration program improvements recommended'by a 1983 QA
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audit reflected: poorly on management 's interest- in
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implementation high quality program'(sic)."
NRC Inspection Statement 86-08 (pace 6):
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"The:plantLQuality Assurance department has performed
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comprehensive: audits and surveillance
of the calibration
programfin the last two years and has identified many-
weaknesses in the program. 'Also.-an internal; appraisal of
plant M&TE program was conducted in-late 1983 (Report
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- 83-02) which recommended several improvements.
However,
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the plant management has not acted on these
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recommendations.
It appears that the licensee has been
somewhat slow in responding to and/or implementing their own
recommended improvements'and the QA findings.
The licensee
acknowledged the' inspector's comments, and indicated that
this area would receive additional management attention."
Authority Response:
At the time of the inspection exit, the exact status of the
QA, inspection 83-02 recommendations wasEunknown.
The
Authority did not make an official response to the NRC
Inspection 86-08 finding to correct the inspector's
observation, since' prior site policy was to formally respond
only to violations.
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QA[h' asis'ince: reviewed-the recommendations and we believe the.
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resultsn which follow,'do not: demonstrate a poor: interest by
management'in imp 1'ementing a1high quality ~ program:-
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'a)
.The'QAJinspection 83-02 was conducted in . late 1983 and
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the report.was issued December 5,
1983.With'six broad-
(recommendations (not'the. type of issuer;which are
- quicklyLresolved).
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'b)
Recommendation l'was-implemented on September.2, 1984
with a follow-up' improvement completed in 1986.
c); Recommendation 2 was completed on FebruaryL26,.1986.
d )l Recommendation 3 was' essentially implemented on-
. September'2, 1984.
However, 1.
couple of items remain
open.
Ee )
Recommendation 4 was formally addressed and implemented
on. September'2, 1984.
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Recommendation 5'is-an on-going effort of updating
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record.andEdocumentation files after formal: programs
were implemented.
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Recommendation 6 included the need for follow-up audits
- which were accomplished.in
- 1985 and 1987.
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In March-April ~ 1985, a. follow-up examination was
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conducted by the same-QA individual"to assess'the
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progress in implementing.the recommendations.
'In'a
letter dated lApri1L30, 1985..the following statement was.
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made:
"1 am pleased to report'that.the' Maintenance.
Instrument and-~ Control-and. Quality Assurance' Departments
have-done'an excellent' job implementing their' responses
to'these recommendations."-
C.
Nuclear Licensino
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NRC SALP Statement (Dace 27):
"The TS pertaining to. recirculation bypass valves illustrates.a
case.where wording is not consistent with intent.
Although this
TS-was subsequently deleted, no effort was made to revise the'
Lwording-during'a.6-month period from the time this TS led to a
plant shutdown to the time the deletion was requested."-
' Authority Response:
At the time in question, the FitzPatrick plant was shutdown as a
result of a valve packing leak and not the result of technical
specifications problems.
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ENCLOSURE 3
SALP BOARD REPORT
U.S. NUCLEAR' REGULATORY COMMISSION
REGION I
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
SALP REPORT 50-333/85-98
.
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NEW YORK POWER AUTHORITY
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. JAMES A.'FITZPATRICK NUCLEAR POWER PLANT
ASSESSMENT. PERIOD: DECEMBER 1, 1985 - NOVEMBER 30, 1986'
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BOARD MEETING DATE, FEBRUARY 13, 1987
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TABLE OF CONTENTS
Page
I.
INTRODUCTION.
1
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A.
Purpose and Overview
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B.
SALP Board Members
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C.
Background
2
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II. CRITERIA . . . . . . . . . . . . .
4
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III. SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . .
6
A.
Overall. Facility Evaluation .
6
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B.
Facility Performance
7
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IV.
PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . .
8
A.
Plant Operations _. . . .
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B.
Radiological Controls . . . . . . . . . . . . . . . . . .
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C.
Maintenance . . . . . . .
15
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D.
Surveillance
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E.
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F.
Security and Safeguards . . . . . . . . .
22
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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
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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 Plant Shutdowns .
47
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Figure 1 Number of Days Shutdown .
49
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~ INTRODUCTION
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' Purpose and Overview
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The Systematic Assessment of. Licensee Performance (SALP) is an inte-
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grated NRC staff effort to collect the available observations arid
data on'a periodic. basis and to evaluate licensee performance based-
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upon this information. .SALP is supplemental to. normal regulatory.
. processes used to ensure compliance to NRC rules and regulations.
SALP.isiintended.to'be sufficiently diagnostic to provide a rational
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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
i
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 a'ssessment 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
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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 20, 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)-
,
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R. R. Keimig, Chief, Safeguards Section, DRSS (part-time)
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G. W. Meyer', Project Engineer, RPS 2C, DRP
N. S. Perry, Reactor Engineer, RPS 20, DRP
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Background ~
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- 1.-
Licensee Activities
~
'
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The facility. operated at or near full power.from: December.1,..
~
1985.until' March 13, 1986 when'the plant'was shut downifor 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-
'
p
~ 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 1 outage, normal power operation 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:stopLvalve-testing. caused by an improper valve position-
4
indication'. On May 15, 1986, the-plant was shut down as re-
.
L
Lquired by Technical Specifications.due to an inoperable Recircu-
L
llationlloop DischargeLBypass Valve. .On~ July 3,'1986..the
F'
- re' actors tripped
- from full power when a. f ailure occurred in the
.
Lprotective. 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:which2 involved
<
- the replacement of- ten control rod drive mechanisms,L turbine
blade inspection, preventive and corrective'm'aintenance', and-
,*"
modification'insta11ation.
Following the completion of.the ,
'
maintenance outage, the plantLagain.. operated:at<near full'poweri
'
O
LuntiltNovember 1, 1986"when al plant coast down began for the'
.i
refueling. outage scheduled for January 1987. ;The; plant was:
<
continuing.t'o" coast?down;at.the end'of theLassessment 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
T
.
tota 1LNRC 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
,
4
-
distribution in the appraisal 1 functional areas'a's shown in Table
'
2.
s
7
During the' assessment period, an NRC team evaluated the annual
F
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" ana " 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- l1
ly to provWe 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. Other major 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 ', g s
,
ing this assessment period.
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_ _ _ _ _ _ _ _ . _ _ . __ _ _
- - - - -
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,
,
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'
II. CRITERIA
1
Licensee performance is assessed in selected functional areas, depending
.on whether the facility is in the construction, preoperational, br operat-
^
.ing phase.
Each functional area normally represents areas.significant to
nuclear safety and the environment, and are normal programmatic areas.
1
Special areas may be added to highlight significant observations.
!
'
The following evaluation criteria were used, where appropriate, t.r asse.y'
h(
?
each functional area.
-
4
(
1.
Management involvement and control in assuring quality.
1
'
2.
. Approach to resolution of technical issues from a safety standpoint.
/
3.
Responsiveness to NRC initiatives,
n
5~
4.
Enforcement history.
'? "
i. *y
.
5.
Reporting and analysis of reportable events.
,,
6.
Staffing (including management)
t
7.
Training and qualification effectiveness.
Based upon the SALP Board assessment each functional area evaluated is
9-
-
classified into one of three performance categories.
The definitions of
"
these performance categories are:
Category 1
6
T
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.
,
,
I
Category 3
J
Both NRC and licensee attention should be increased.
Licensee management
J
attention or involvement is acceptable and considers nuclear safety, but
weaknesses are evident; licensee resources appear to be strained or not
effectively used sc that minimally satisfactory performance with respect
to operational safety is being achieved,
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The SALP Board allp' assesses functional areas to compare the Ifdensee's
performance'durinQthelastpartoftheassessmentperiodtothatduringthe
entire;. period (normally one year) in order to determine the recent trend for
functlonal areas ar; appropriate. The SALP trend categories are as follows:
,rp
Improving:
Licensee performance Fats generally improved over the last
part of thW SALP assessment period.
,
i~ ' 1 6.
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.,
,
A
Declining:
Licensee psrfortdce has generally declined over the last
,j '/ g ' /
part of the SALP assessment,4erio1.
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,
A trend is assigne6'cnly when, in'tNe opinion of the SALP board, the trend is
d
significant enough*to be considered indic'ative of a likely change in the
performance category in the near futur .
For example, a classification of
" Category'2, Improving" indicates the clear potential for " Category 1"
performance in the next SALP period. a'
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_ _ _ _ _
_ - _ _ _ _ _ _ _ _ -
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6
.
III. SUMMARY OF RESULTS
A.
Overall Facility Evaluation
Management attention has resulted in noticeable improvement through-
out the facility and in particular the areas of pla it 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
i
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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_ _ _ _ . . _
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CATEGORY.
CATEGORY
-
-LAST
THIS
RECENT:
'
_.' FUNCTIONAL AREA
' PERIOD *
PERIOD **-
TREND
..
1.- :-Plant Operations-
2-
.
2
Improving-
,
2.
. Radiological Controls:
'2
2
' '
i <-
l3,
Maintenance'
2-
L2i
-S
4.
- Surveillance-
.2:
2,
5. Fire Protection
1
.N/A
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,-
6.
1
1-
1
'7.
Security & Safeguards
1-
1
,
8.
' Outage' Management and-
2
'2
'
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Engineering Support
Y
9.
Lice'nsing Activities
2
2-
Declining
10. ' Training and-Qualification
'2-
2
._
. Effectiveness
11.. Assurance'of Quality
2
2
Improving
- July 1, 1984 to November 30, 1985.(17 months),
- December 1,l1985 to November 30,1986~(12.. months)
-
,
-4-
5
-..
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. _ - _ _ _
_
__
C
8
.
!
IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
(773 Hours, 40.3%)
1.
Analysis
W
During the previous assessment period,. this functional area was
1
rated as Category 2 with an overall decline in performance. A
J
number of personnel errors and inconsistent review of opera-
l
tional events and root cause analysis were noted as
.j
deficiencies.
{
\\
During this assessment period, the plant operators were deter-
mined to be knowledgeable and conducted themselves in a profes-
i
sional manner. .They exhibit a positive attitude toward
i
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-
!
4
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
h
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,
j
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
j
conditions.
l
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,
L
this occurred while the operator was taking necessary actions to
j
isolate a leak in the feedwater system while in the process of
lowering reactor vessel level.
In addition, no plant transient
q
or equipment inoperability occurred as a result of personnel
j
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
I
66 recommendations were given to improve overall plant
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.
In
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the 'short term, the managementicontinues to work to instill a
-positive-attitude and pride inLworkmanship among its employees,' .
Which has resulted.in a' reduction'of personnel errors and the'
ability to' correct deficiencies'quickly and correctly,. Furtherf
Lassessment of- the:long term recommendations is required
'
'
AdministrativeLcontrols, procedurestand. 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 s> curing the.high pressure. coolant
injection. turbine during. surveillance testing, using dataLsheets
- 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 ~ofLthis concern and is stressing improvement in:
L
this area.
,
<
.1
Plantimanagement: continues to st-ess prof _essionalism and to
'
improve the control ~ room environment, asinoted by the removal-of
the Secondary.' Alarm Station from the control room, installation
of' curtains' to limit traffic in the control. room, and' continued
u
'
improvements in establishing-an'effe'ctive work control center.
.
In addition, plant' management has placed emphasis on reducing
d
thenumberofcontinuouslylighted' annunciators.fAlthoughplant
I
r
management _has made progress in this area, continued attention
y
is warranted.
The Operations Superintendent. conducts weekly
1
meetings with each shift to review events and stress the need
for improvements. Additional improveme'nts 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 aridition, 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
1
instance, a formal tracking program was in the process of being
1
+
implemented.
The tracking program follows items on which action
1
~
is scheduled and highlights those which are commitments.
1
Although improvements were noted in the review of operational
f
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,
. _ _ _ _ . < _ _ _ _
_. . _ _ _ _ _ . .
- _
_
. . _ >
__
_.________.._______.______________i_m__
_
'
_-_
_
_
-
-
_
.
10
.
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.
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-
4
ment makes weekly tours of the facility to review cleanliness
1
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
I
!
Rating:
2
Trend:
Improving
l
3.
Board Recommendations
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 and1
lack of management attention relative to' conforming to radiation
protection procedures.
This functional area will be-discussedl
'in terms of: radiological protection, radioactive waste transpor-
tation,'and effluent monitoring and. control. . There were six
inspections conducted.by radiation; specialists in this area, two
'
in radiological: protection, one in radioactive waste transporta-
e
tion, and three 1n effluent monitoring and-control'. The resi-
~
'
dent inspector also monitored the implementation'of the
radiation'. protection program.
. RADIOLOGICAL PROTECTION
q
_
'
'
The licensee showed consistent performance relative to the pre -
l
<c
vious assessment period, with noL major weakness identified and -
l
.
no major program' improvements.
Several minor instances of'per--
D
_
sonnel failing.to follow procedures occurred during.this assess-
ment period as in the previous' assessment period.
LThe 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
q
a
assessment period and that the station Radiation Protection'
l
Manager has been temporarily acting in this position. When a-
new General Supervisor is selected, increased managoment atten-
tion will be needed to assure a: smooth transition.
The ALARA program is strong and etfective 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
j
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
- j
exposure estimate of 575' person-rem. With.the accumulated ex'-
'
posure at the end of the assessment period, the exposure for
-j
-1986 was not expected to exceed 400 person-rem. While this ex-
.j
posure reflects well on the ALARA program, it shows the goal set-
.l
for the 1986 calendar year was not ambitious.
i
'
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 overexposure oc-
,
curred and no individuals received an uptake that required
!
!
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____________________1____.______o
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assessment or--any further actions.
Radiation Work Permits were-
J
effectively used to; control work within the Restricted Area. As
!
-
in past years, NYPA'is implementing ~an adequate whole. body
counting' program.
However, -there.are : areas where improvement is necessary.in the
internal and external exposure control program._ Minor problems
include failure _-to follow procedures and insufficient' middle
~
management' attention.to' detail to provide oversight-in the area
)
of external exposure control.
Instances of failure to follow
-1
procedures included failure to maintain survey. instrument cali '
-
bration records and failure to' perform alpha surveys on arriving
I
new fuel shipments. Additional middle management attention to.
q
the supervision and assessment of day-to-day radiological con-
trols activities is.needed.to improve self-identification'and-
correction of program weaknesses.
1
The respiratory protection program is of state-of-the-art
e
quality. The licensee has placed a high priority on this pro -
i
gram as evidenced by effective, respirator. selection, issue, use,
)
+
and maintenance practices.
1 Radiological survey instrument controls were weak. . Specifical-
.ly, the storage, maintenance, and calibration facilities for-
portable survey l instruments needed improvement.
Furthermore,
j
survey' equipment availability during tho October 1986 outage was
1
~
limite'd, which indicated poor control of equipment inventory.
I
Personnel frisking practices were inferior to industry stan-
dards, in that high background count rates potentially precluded
effective detection'of personnel contamination.
Compounding
this problem were. poor frisking techniques by station personnel.
.]
Regarding both.the survey instrument control and frisking prob-
lems, middle management within the radiological controls group
appeared unaware of these prob _lems until informed by the NRC,
despite the seemingly obvious nature of the problems.
It was
unclear whether the lack of awareness was due to the failure to
personally-inspect field activities, poor communications with
personnel in the field, or low standards of work.
Corporate management-is frequently involved in the activities
providing guidance and consultation to FitzPatrick Station man-
agement.
For example, Corporate and Standsrd Audits were'per-
formed of the Radiation Protection Program. .However., most-
Standard Audits, while timely, were superficial and of limited
scope due to a lack of audit personnel qualified or trained in
health physics and chemistry.
This weakness was identified by
i
corporate management late in the SALP assessment period.
Corpo-
rate management indicated that their audit personnel, qualified
m__u_ _
'
, , ,-
,
-
, _ _ - - - _ _
-
--
___
- - _ _
-- - _ _ - - - _ - _ - _ _ - - _ _ _ - - - - -
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,
I
in;.HP and Chemistry, would be~made available to augment the
j
.
Standa'rd Audit program.
'
- RADI0 ACTIVE WASTE TRANSPORTATION-
y
'
An' inspection of-radioactive waste transportation fo'und this
4
g.
areaLte:be'generallyfgood. .While;a concern'was. identified
regarding the' circumvention of.the-receipt inspectionjsystem for;
transport packages, the corrective. actions'were timely and ..
m
a
_
thorough. .In addition,.when concerns were identified regarding
A
the adequacy andEeffectiveness .of the1 audit program for trans - ~
.' port packages, QA/QC involvement in this area was promptly in--
creased.
U
' EFFLUENT MONITORING AND CONTROL-
L
During the previous assessment' period-the Radiological Effluent
4
Technical Sp'ecifications:(RETS);were implemented.
Inspections-
'!
during this period-found'no'significant problems.in:RETS.imple-
mentation, and thellicensee was effective in correcting ~.the
minor problems ~which1 occurred. 'An inspection'of the environ-
~
mental monitoring program found a' problem with-implementation of-
,o
-a calibration' procedure.
However, this problem appearedLto be :
an isolated instance due to a lack of. attention to c'atail rather
than a programmatic breakdown. With this exception,' the envi-
ronmenta1Lmonitoring program was effectively imphmented with
respect to Technical Specification. requirements for sampling
frequencies, types of measurements, analytical sensitivity, and
,
reporting schedules.
' '
'l
-
An inspection of the nonradiological chemistry program found.-it
.to be generally effective. . Minor deficiencies were identified
in several of the chemicalfanalysis' procedures, but.the licensee-
respon'se 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.
i
An inspection of effluent and process radiation monitor calibra-
!
tion and surveillance testing, and in place filter testing-found
'these areas to be acceptable.
Summa ry t:
'The; established programs for radiological protection, radicac--
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
i
'
and to prevent the minor problems experienced during this peri-
od. A more probing and effective quality assure 7ce review of
these programs would aid in assuring proper implementatic'n.
i
_ .___ _______ _
, - _ . _.
- -_ _
-
.
_
. _ _ .
. _ _ - _ _ _ _ - - _ _
_ _ _ _ _
.
. . . .
.1
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- ;. ;
-
14
. i.
e
i0
'i
2.
Conclusion.
i
!
Rating: Category 2
3.
Board Recommendations
4
J
None
j
,
1
!
!
I
___.__.__. _ . _ _ _
_
'
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. , .
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15
L,..
,
C.
Maintenance ~
(159 Houn ,.8.3%)
,
.
1.
Analysis
q
.
,I
JDuring the previous assessment. period, this functional' area'was.
~
rated as. Category 2.
Although FitzPatrick management continued
'
p
.to implement several improvement. programs,-progress was slow and
i
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
,.
..re siden t ; i n specto r. l In addition,' specialist inspections re-
viewed the-maintenance of the recirculation pump trip system and
the equipment qualification of -Limitorque valve operators. . No
,
-programmatic inspection of maintenance was conducted during the
current assessment. period.
During. thi.s assessment period,, plant: management became more ac-
tively involved in implementing the improvement' programs, and
progress was generally good.
'A' program ~to1 control. vendor tech--
nical' manuals was begun by developing:a computerized index and~
l reviewing the manuals maintained by each department. However,
.tN re have~been delays'in implementing'the program in the Main-
tenance Department. . Implementation of the Planned tiaintenance
Program continued with some minor' delays. .The development of
the Master Equipment List progressed'with component.classifica--
tions.
Improvements were made in1 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 in'volvement 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
l
an-abnormal' condition of one channel of RPS deenergized for
i
other modifications, these trips are of minimal concern.
The
!
three remaining trips while shut down were unrelated and are
discussed in Table 6.
l
)
s
i
= _
_____ - ._
_.
. _ _ _
_ _ _ .
u
_
_
y
'
16
.
F
Regarding the Recirculation Pump Trip System, preventive mainte-
nance was properly controlled and documented, and corrective
i
maintenance was timely and adequate.
In addition, the engineers
i
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 inodifications
for the same breakers in other applications.
A concern was identified regarding' examples of personnel not
i
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 twol 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-
1
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 reactor trip during surveillance testing.
The li nit switch
had malfunctioned 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
i
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-
i
changed, no detailed review of the cause of the stroke ch6nge
was considered until several days after the startup.
Subsequent
inspection found that loose bolts had allowed the valve stroke
to change.
Apparently, che 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
j
-___ _ ____-__
. .
.
.
-__
V,
_.
'
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,
'
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,
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,
-17
C
i
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.wasevidentbylthe' number.of.managementpersonnel'whoactivelyL
-
participated:in the. EQ pr ogram,' the.high degree ofcorganization.
,
LU
'
.of EQ~ documents, and the prompt performance of EQ~related activ-
.
'
ities.
Further.' evidence of commendable performance included the;
thorough response to NRC Information Notice 86-03,. including a:
.
1100%: inspections of Limitorque valve operators requiring EQ and
ca
'
the' licensee's' decision:to upgradeTthe Limitorque valve: control
+
wiring,'even:though qualification data'was.available'for the
i existingLeontrol wires. -However, someLimplementation problems
were Lidentified within the generall EQ program,.which will be
E
evaluated.during the.pendinglinspection of the' plant;EQ program.
'
'
'Overall, the plant ~ maintenance' program has improved from th'
.
e
previous assessment period; The' absence of significant'per-
sonnel errors' and: the proficiencylin-properly completing workL isa
S
n'ot'ewo rthy. < Continued, emphasis should be'placed on timely com-'
' pletionlof improvement / programs,c procedure compliance, .and ' root
-
cause analysis to preventLrecurring problems.
- 2.
Conclu~sion
RatingiL2:
3
3.
Board Recommendations
l
.)
None-
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.
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,
.
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'18
,7
I
(
! surveillance
(194 Hours, 10.1%)
D.
S
1;
Analysis
During the. previous assessment period, this functional l area was
rated as Category 2, primarily due-to repeated problems in es-
tablishing an1 effective Inservice 1 Testing.(IST) Program.
During'the current assessment' period, the' surveillance, calibra-
tion,.and IST programs were,'eviewed.
The resident-inspector-
r
.also examined surveillance testing during the routine. inspection
. prog ram..
The' licensee improved the IST Program by. including'all required
valves,' rewriting. procedures-to include acceptable values, and-
assuring that the1 operators do a thorough review of data follow-
ing the tests.
However, the. previous SALP. Report noted problems
L
regarding the; review of test data by operations and plant per-
'fo,rmance personnel. During:this' period, operations department
p
reviews of the' data were adequate and timely, but the subsequent
'
. review of the data by plant performance personnel was, atitimes,
excessively slow (up to several: weeks). This review!is relied'
.upon to determine trends and notify'0peratio'ns 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: Ir.strument and Control, Operations, Maintenance, and
Radiological and Environmental Servic'es.
Each department
'l
maintains, its own system for scheduling, tracking and performing
surveilla,nces. The completed surveillance tests were well'docu-
mented. utilizing. detailed procedures, data forms, and acceptance
c ri te ri a..
Overall, personnel performing the tests were knowl-
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:
1
--
A monthly test of the APRM flow bias network was missed for
I
eight months when it was not placed on the schedule follow-
i
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
l
.
1
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-
I
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 adequate sur-
veillance test to verify that they are ft'nctioning 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 improveraents
recommended by a 1983 QA appraisal reflected poorly on manage-
ment's interest in implementation of a Figh 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 evidenced 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
3.
Board Recommendations
None
l
l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
g"ul,
e
,-
i
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,
>
v
,
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4
20
>
4
.
E.
(110 Hours, 5.7%)
1.
, Analysis'
q
.During the previous assessment period this functional; area was
1
D
rated 'as. Category;1.' . This assessment was based upon 'a good _dem-
'
,
.
onstration of emergency response capability during twoiannual
exercises, responsiveness to weaknesses :ident:fied 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.hi'gh. degree of-proficiency which appears.to re-
~
sult from a strong training program.
Emergency l response person-
nel are quite knowledgeable and dedicated. Only one minor
cdeficiency was_. identified during the exercise.
This exercise-
showed improvement from the previous year's exercise, which.had
.only minor' discrepancies.
,
- The-licenseeLstaff is active in maintaining and improving thel
emergency. response program.' . Program weaknesses are.promptly _
.
. identified and corrected.
NYPA and others have taken the init-
-iativeito 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 eme'rgency
preparedness r,rogram 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
..
L
2
- 2- _ _ _
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21
.
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.
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-3.
-Board Recommendations
None
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'
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,
- _-- _ - _ -_- _
__
.--
_-
_ _ . - - _
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3
.
,
.
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' t
221
..
.
1
F.~
- Security and. Safeguards
. (140 Hours, 7.3%)
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,
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1.
Analysis
'
'
y
During this assessment period, only one physical security in-
spection was conducted because the. licensee's' performance during
.
thef 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 l inspection was conducted.-
'
The licensee continued to review the effectiveness of the:secu--
rity program and.the adequacy of.related facilities during the
u-
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 .statio'n (SAS) into new facili-
- ties.that provide more space-and efficiency..of operation,.
Additionally,.as a result of recommendations resulting from sur-
g
veys of the. security program performed by.outside contractors,ia
<
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 onejfull-time
training instructor with assistance'from several part-timetin-
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.
1
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.
.
,
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,
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23
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.
. Staffing;of'the security 3 force appears,to be... adequate with.occa-
'
1
'sional' overtime.being used;to' meet unforeseen operational needs.
. ,"
This use of overtime has had no: adverse effects on the:perfor--
mance ofltheLforce.
In~ preparation ~for.an upcoming. outage.that'
3
has the ^ potential for taxing the' existing force', security man :
agementl developed and implemented a training program'to qualify.
additional watch persons to supplement'the force. This advance-
-
planning is. characteristic ofLthe licensee's' security management
and'is'further evidence.of their desire'to implement-an effec-
-.
tive and high quality program,
u
Security management is actively' involved.in.the' Region I Nuc?aar
-
. Security' Organization and other organizations involved in nucle -
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,s'ite for orientation-
'
in. response procedures, plant layout.and other. matters involved
with the protection..of a nuclear. power plant, and..to. discuss-
'recentidevelopments 'and innovations,:in general .
This is>. fur-
ther.' evidence of the licensee's interest. in providing.cn effec '
!
tive~ security program.
There'were'no security events lthat require'd reporting'under 10-
'
CFR-73.71~during the assessment period.' .This .is attributed'te
.
the effective training program that resulted .in excellent'per-
I
'
formance from the members of the security force and to the pro-
gram implemented by the licensee to maintain.its security
systems and equipment in good working order, which includes mon-
itoring of and'plann Mg 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-
to the NRC approved Security Plan.in accordance with the provi-
sions of 10 CFR 50.54(p). These plan changes were' reviewed and
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 sivce that
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.
i
maintaining a high quality program.
A material control and accounting inspection identified that two
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
physically account for all SNM during an inventory and a misin--
terpretation of an NRC requirement regarding the conduct of
physical inventories of SNM, also raised during that inspection,
o
s
!
,_
l
'
'
,
L
.
'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.
q
2.
Conclusion
Rating:
Category 1
3.
Board Recommendations
None
l
l
<
!
!
1
1
!
l
.
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--
_
-
..
-
.
.
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,
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t
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,
,
-
G .' . Outage Management and Engineering Support
(152 Hours, 7.9%)
i
,
1.
- Analysis-
^
During the previous-assessment period, this functional area was-
,
rated as Category 2.
Performance had declined.due'to inadequate
.
z
P
planning,' poor control of activities, and personnel. errors.
,
During this period, no. refueling outage took place,1but'two'
.
i
-short scheduled maintenance outages, totaling 24 days, occurred.
'
During these o~utages major work included replacement of. control
rod drive mechanisms, installation of several modif.ications, and
preventive.and corrective maintenance. The resident. inspector
reviewed these activities, and a specialist. inspector reviewed.
- radio 7ogical' 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 lof 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
l
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 trans-
mitters.
The engineers were knowledgeable and competent, and
were actively involved throughout the installation and testing
i
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' engineering problems, the Technical Services Depart-
ment will require continuing plant management review to assure
1
i
-
_- _ __.
_
.
-_.
-
- -
-- -
_ .
-___
_
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proper. oversightof;the department's activities.
It appeared-
'
,
,
that this oversight was inadequate on occas. ion based.on the-
'
.foll_owing examples:
,
The ongoing program :to inspect:all. safety relhte'd pipeLsup-
---
'
Lports'was placed on hold in November 1985.fol. lowing. funding
-thortages which prevented the Architect Engineer (AE) from!
i
performing further evaluations. 'The licensee believed at.
the time that.the; fifty items waiting' evaluation by the AE-
'did not, affect'_ support o'r system operability.
InLApril
1986,after the funding becamejavailable, the:AE determined
.a support:in the' Core.. Spray system' identified on November
7,11985 as having a discrepancy was inoperable.
Subsequent
evaluation' concluded the inoperable support did not' affect.
y
the: system operability. . The delay in recognizing the inop -
erable support was caused by.the Pipe Support Field'Engi -
-
E
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 pe.rmanently, 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.'
l'
l
An installation-deficiency caused by' inadequate design
--
change review on a v'alve 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 to 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 vpgrading 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
i
_______________1_
___n_______
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7--
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- - - - - - - - -- - -- --- - - - -
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'27
em.
o
n
H.
Licensing ' Activi ties -
.
fl.
Analysis-
During:the previous assessment period,.this' functional area was-
.
the reduction.in:the' backlog of licensing actions.
rated as Category 2.
Performance had improved as evidenced by'
'
'1
A reorganization of the headquarters' staff.took effe'ct 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 Vi_ce-President.
Notwithstanding the diffe'rences'in
-thefrespective' reactor. designs,Lthis 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;duringLthe
previous ratin~'~ period and the absence of any;majorfoutages.
g
,
Nevertheless, management interest and involvement in licensing.
i
activities was evident. ,A case in point was the attendance.of'
licensee senior level management at & counterparts working meet *
ing between BWR. Project Directorate #2 staff and,11censin.g man-
- agers of utilities assigned .to. that directorate, held. in ' April
,
1986.
Increased management attention to the quality of Sholly-
evaluations and licensing correspondence'hastalso been evident.
.
during this rating. period.an'd is responsive-to a' recommendation
f
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
m
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
not reflect the current configuration of;the' plant, yet the-.
,
licensee has not, to date, proposed revisions. 'The TS pertain-
i
ing to recirculation bypass valves illustrates la case where-
.. wording is not consistent with intent. Although this TS was
subsequently deleted,-no effort was.made to revise the wording
a
_
'during a.6-month period from the time this TS' led to a plant
.
'
L
shutdown to the time the deletion was requested.
l
Licensee efforts towards the resolution of. safety issues is evi-
dent by its active participation and close contact with various
':
. industry groups involved in the identification and' resolution of
i
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,
,u
,
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..
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.
y
,,
l
With a few exceptions, safety evaluations sub_mitted.by'the.
..
'-
licensee in support of.' proposed:TS changes'or to. resolve techni-
c'a1. issues have been clear 1and substantive..'One. exception was.
the documentation (a contractor report)' submitted'to support a-
L.
LTS revisionito' lower the.MSIV. isolation water'1evel setpoint.
L
~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.
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'sLover-
- allf spirit 1of cooperation ~, however, was evident during this
>-
rating period. .. Enc'ompassed.here is the licensee's responsive-
ness to requests.for.information,fboth verbal:and written, de-
~
lays in submittal or. resubmittal of documentation (often of a
~
routineLor' simple nature), and the general reluctance to trovide
definitive' schedules.
All-of-these factors' represent impedi-
- .
.ments to conducting day-to-day business.
E.xamples 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=
4 -
i an inadequate Sholly 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
j
isolation valve additions.
J
-
-
.1
In view of, the previous elimination of a large backlog of li-
censing actions, and the. increase.in size of the. licensing
j
staff, improvement was possible during this rating period but
was not achieved.
In summary,-.the licensee oeeds to improve
communications as well as its spirit of cooperation with the
,
NRC in the area of licensing activities.
1
2.
Conclusion
Rating:
2
Trend:
Declining
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3.
Board Recommendations
None
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_ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _
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Training and Qualification Effectiveness (NA)
o.
,
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Analysis
Thefvarious aspects of. this functional 1 area ha' e: bee'n considered
~
v
and. discussed as an integral part.of. other functional areas and'
the. respective inspection. hours have been included in each one.
0
Consequently, this; discussion.is'a. synopsis of'the assessments 1
, s
related to training.. conducted in other areast . Training. effec -
'
tiveness:has been measured primarily by the observed performance ;
~
1
of-licensee; personnel and, to a lesser degree, as a. review of .
program adequacy. The- discussion below' addressesi three: princi-
,
P
_ple areasi', licensed operator training;unonlicensed staff-
. training,- and .the ' status ~ of INP0 training accreditation. .
,
p
In the previous 'assessmentiperiod, this functional area'was' rat--
ed as: Category 2.
FitzPatrick management' displayed'a strong
y
'
commitmentet'o training, shown Lby 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 l 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 198C.: The two (2) Senior
Reactor Operators (SRG) 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.
i
.
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 examination 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.NRC examination candidates and.not poor
n
train.ing 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 1n~one
classroom.
'
An inspection of the FitzPatrick requalification training pro-
gram identified significant weaknesses.
The utility training
x_-_-__-
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31
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2
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 resulty , revealed signifi-
cant differences.between the licensee and the(NRC grading, with
the NRC grades being lower,in all cases. A re' view uf. the grad-
ing techniques revealed that many questions were not graded-
strictly to the answer key, .and grading between the examinations.
was inconsistent
Other weaknesses identified during the requalification training
program inspection included poor lectures, poor attendance,
missed required reading assignments, missed ora 1 4 examinations,
and overall weak program supervision.
Some of , tfiese problems -
can be attributed to the temporary reassignment of the requalifi-
cation-program administrator,.who attended' advanced technical
training for eight months.
In his absence, the assigned program
administrator did.not adequately implement.the requal.ification
program and the -licensee management failed to properly oversee .
the program.
However, many of these weaknesses existed before
'the reassignment and are attributed to overal.1 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 iriative, which wa( begun during
this assessment period by the: Operations Departsnt, was an-
on-shift operator training program.. This progfam, implemented
-to improve operator knowledge, includes auxiliary operator
walkthroughs, scenario walkthroughs with the entire shift,
written examinations, and incident discussions.
\\
t
Thetrainingprogramsfornonlicensedpersonnelcontinuetobe
iY'
strong and effective as evidenced by the absence of penonnel
errors and improvement irc performance.
The state accred$ted
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 remedi, tion program.
In addition, FitzPatrick main-
tained strong and effective training programs for maintenance,
radiation protection and security personnel.
n
'
FitzPatrick received training program accreditation from INPO in
the areas of Reactor Operators, Senior Reactor Operators and
auxiliary operators. The self-evaluation reports for the remain-
ing seven programs have been s'bmitted and the Accreditation
j
u
Team. visit to review these programs is scheduled for February
1987.
The simulator and new training facility are scheduled for
completion in mid-1988.
,
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4
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(Inl summary,Lth'e training. programs for non11cen_ sed operators,
"
.
.
.
~
maintenance workers, radiation protection technicians,.and
l-
security. personne1~ were ' strong.and _ef fective. - Problems occurredtf'
<
i
in the breening of. initial operator license candidatesL and the.
"
-administration of the requalification training'o_f licensed oper-
A7 3'.
<
-
ators, but IitzPatrick management belatedly. found ~the: problems
,f.h.
'
.
,
. (concurrently with'NRC inspections) and corrective a'ction is
'
_
-
'.
- _ .
~.being taken regarding the requalification ' program.
In' spite of.1- k.V
" '
Lthe problems there is no' evidence that theyJ. adversely:affectedJ
'
'
plant _ operations.
..a
12.
-Conclusions'
<v
-.Ratingr 2:
?P
R.6
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..
7
3.
Board Recommendations'
a
W
E.
'
None.
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.
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' _ ] f. ss i ,?- 1 7 (, '
i - - ~ Pi 33 " , , t e , l g e J. Assurance N Quality , j t .tt ] ' v 1. Analysis { l i'h Assurance .of Quality is a summary assessment of management over- 1
\\ sight and effectiveness in implementation of the quality assur- fk.* ance prog am and administrative controls affecting quality. , , h 'Q - , ActivitiG affbi:ttng the assurance of quality as they4pply spe- cifically to a tunctional area are addressed under each of tho < ! separate functional areas.. Further, this functional hrea is not- merely.an. assessment of the Quality Assurance Department alone, but is an.overa17 evaluation of management's initiatives, pro- , .g m s, an! policies which affect or assure quality. ' < ' 4 ' I Durin;i the previous assessment period, this functi6nd ~ area was t ? rated as a Category 2. The Quality Assurance (QA) Department ' was actissly involved it startup testing, mainter4nce and modi- { , fication activities. Weaknessesnotedwereintpclsppeofau- l dits and involvement ia surveillance testing. 7'" ' During this assessment period, the weaknesses noted above have + been corrected, With the exception of Radia. tion Protection Pro- grams, audits were found generally to be of sufficient depth. .l The QA department also utilizes surveillance to review activi- 1 ties in progress. The QA di.partment expanded their involvement ' in the' surveillance tcst area. A A review of the quality ass)rence(progrNn found the QA depart- ' a ,p me t to be adequatefy staffed. hie QA personnel receive train- y,b,Tment)3partofthecorporateorganization,butfrequentmeet- in , the department and at the Training Center. The QA depart- V h . ings % the $ Superintendent, the Resident Manager and the , i 1 Superf atendedt of Power are held to discuss QA/QC concerns.
'l, \\ Thus QE i sues are brought to the attentf on of appropriate plant ! ' '
' f
- K
tianage, ens;in a timely fashion, j
'(\\ ' .,4 maintenance program for items in storace was lacking and fe- - 4 ' suited in a pump being improperly maine:dned. The lack of such . , a prcgram was brought to the licensce%' attention in 1983, 1984 . . Th j 'ard during the course of inspection M-11. The licensee has ' O initiated corrective action in the form of a material equipment 3 i list which is scheduled for completiod infE utry 1987 and for 'M kfullimplementationbylate1988. The lisi. h. intended to 5 identify all the maintenance requirements for each item. Cor- i , ,C( l .) %g grective actions in this area have been's ow. 7 - ? x , The licensee has recognized a need for improvMontyin the per- , a ' formance of receipt inspections by QC inspecte d ind .'y develop- , ing an upgraded recept inspectico instruction. The Instruction s, a will delineate receiAt inspectign9ec,uirements,andprovide s . c . 'N <A l S ) , E-- 4
_ . -. . .' . 3- r8 .t- 34 7, . guidance to. inspectors.' Without the. instruction,' inspectors must rely on their' experience, which can result in inconsistent- inspectionires'ults. , , The. Quality Assurance. Department plays an'ictive role in.assur- 14 -.ing' quality at.the' plant., : There are excellent : lines of Jcommuni- cation.between the' QA department, plant management and'each . ' department.:The QA department bas.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 Lin process inspections. , - and. evaluations receive high priority and paperwork audits are J - placed in-proper perspective. 'In a'ddition,-the QA' department- conducted a. review of vendor QA programs and facilities when ' prablems arose with Containment Atmosphere Analyzes and' Rosemount transmitters. Corporate and station management are actively involvedLin 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,'ne'wly 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, j } Improvements have.been noted in the Plant Operations Review Com- j mittee (PORC). The PORC has generally displayed a more inquisi- i tive nature.in reviewing events. One exception was the review I following a reactor trip discussed in Section C, Maintenance. L The PORC utilizes a formal system to track resolution of issues ! or questions.and corrective actions. 1. One overall weakness noted was the slow or: ineffective resolu- ! ' tion to previously identified problems which included: mainten- I 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 cole in assuring quality at FitzPatrick. The plant management
- .
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_ _ . ._ - _ __ h l- l L* 35
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. generally displays an aggressive attitude for improvement of quality at the facility, as et fdenced 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 action', performing root cause s analysis, implementation of the requalification training pro- gram, and procedural adherence. These issues require continued ' management attention. 2. Conclusions -Rating: 2 Trend: Improving 3. Board Recommendations. None I - - _ _ - _ _ .
. _ - -- , % < < , Q;g y ;, Wr . 36 [p '[ w 1 SUPPORTING-DATA AND SUMMARIES' , fA .' l Investigation and'A11egation None B. Escalated Enforcement" Actions LNone- is C. .Managemen't Conferences .Two management meetings were held during'theLassessment pericd. One was' held April' 25,.1986, to discuss the.last SALP report. The: second ' was held' August 5, 1986, thislwas 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 al tabular listing-of the - results.of the? causal analysis of the.LERs. A. Pe rsonnel Er ror. . . . . . . . . . . . . . . . . . 5 B. Design / Man./Construc./Insta11..... 6, C. External..Cause................... 0 . D. Defective Procedures.......... ....- 3 E. . Component Failure................. 3 X. 0ther............................ 3 . N' Total 25 , , 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. L Inadvertent'ESF Actuations 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- ' ng component failure, design deficiencies and inadequate procedures. i l { i __m____ .m._._______ --
, - I / ' + d' r -37 4 Inoperable'ESF Systems 1 "ThreefLERs1(86-03, 86-12, and 86-14) report the High Pressure Coolant ~ p . '
- Injection System >1noperable. .The causes' varied but all were due to
inoperable motor operated valves. In one.cese,.the. failure was due. . to. corrosion' caused by.a~ steam-leak,!another due to procedural inade- F
- quacies',~and~the third, design deficiencies.
, ' Surveillance-Testing- Y . ThreeL LERs. (86-01, 86-02, and 86-09) reported missed' or late surveil- ' lance tests. LTwo were caused by inadequate; program administration and:the third due to personnel error. E.
- Licensing' Activit'ies
- 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 7 March 18, 1986: Discussed-Sholly preparation ' April 10, 1986: LicensingLcounterparts meeting (BWD#2) April'25, 1986: SALP management meeting May 16,'1986: ' Discussed licensing action status Joly.31, 1986:. Discussed TechnicaljSpecifications related to control room habitability. September' 11, 1986: Discussed-licensing action' status -2. Commission Briefings- .. None' ~3.- -Schedular Extensions Granted I None 1 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. r Amendment No. 98, issued May 6, 1986; revises TS regarding sin- gle. loop operation ^ _-_:_ _- _- - i
._ . 38 . Amendment No. 99, issued June 20, 1986; revises TS to' clarify responsibility of Plant Operating Review Committee t Amendment No. 100, issued June 20, 1986; revises TS regarding composition o' 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- ) L quirements(NUREG-0313) ! 7. Emergency / Exigent Technical Specifications None 8. Orders Issued None 9. NRR/ Licensee Management Conferences None l . l ' i ! ! 1 - _ ,
- . _ - - - .- _ . - - _ _ - _ - - _ - - _ _ _ _ - - - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ e:+ ,< (JV' .j '- ! p t. - < , 39 1 4,< 1 . TABLE 1 , INSPECTION REPORT ACTIVITIES ' Report /0atesi . Inspector- Hours 'A'rea Inspected ' 185-311 Resident- 76 12/1/85 - 1/17/86 ' Routine Resident 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 .Res'ident 227 Routine Resident "3/11/86.- 5/9/86 Inspection . 86-05 Resident 128 Routine. Resident 'l 5/10/86;--6/20/86 Inspection - ' t 86-06 l Specialist 74 Routine' Dosimetry 5/19/86 - 5/23/86 ~ Program '86-07 Specialist' 110 Emergency. Preparedness 6/17/86 - 6/19/86' ~ and Observation of Emergency Exercisef 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. l "g . 7/21/86 --7/25/86 Environmental J Monitoring Program l 1 P 86-13 Resident 123 Routine Resident ! 8/9/86 - 9/29/86 Inspection , I 1 l I 3.j x i >
,. , - - _ _.- -_ . - . - . - . , - - - _ - - - - _ _ _ - _ - - _ _ - - - - _ _ - - - - _ - - - - - . ' 6 i n ., -( . ,: , m
- 40'
, , .. , - , .. . 86-14l . Specialist- 57 , Envi ronmental'-
- 8/25/86 - 8/28/86
Qualification of. . , Limitorque Valve- Wiring 86-15: LSpecialist- 130 .Requalification ' N 9/16/86' '9/18/86 Training' Program " . - ~86-16 . - Specialist 38 Maintenance-
- 9/22/86 - 9/26/86
Surve111ance' Testing- - & ISI Programs . q 86-17 ' . . Specialist y .9/29/86 - 10/3/86 ' 126 Routine Radiation . Protection. Program- ~ - o- .. 86-18 .. Resident 171 Routine. Resident 9/30/86 -:11/24/86 -Inspection 86-19: Specialist - 56. Special NuclearJ t 10/21/86'- 10/23/86 . Material Control - Program , . 86-20. ' Specialist 27- Routine ' _. 10/21/86 - 10/23/86 Nonradiological _ '-- ' Chemistry Program- . .86-21 . Specialist 56 . Routine Effluent .11/17/86'--11/21/86 Monitoring Program-
- 86-22
.. -Specialist 32 Routine Security- 111/24/86 - 11/26/86 ~ , . 1 i l. . - . -- - 1
__ __. , .. 41 ! .. i s i J TABLE 2 j INSPECTION HOURS SUMMARY JAMES A. FITZPATRICK NUCLEAR POWER PLANT I TIME HOURS % OF TIME i A. Plant Operations........................... 773 40.3 B. Radiological' Controls.................. ....'392 20.4 C. Maintenance..................... ....... .. 159 8.3 0. Surveillance............................... 194 10.1 E. Emergency Preparedness..................... 110 5.7 ] F. Security and Safeguards...... ............. .140 7.3 l G. Outage Management and Engineering Support.. 152 7.9 H. Li cen si ng Acti vi ti e s . . . . . . . . . . . . . . . . . . . . . . . .
I. Training and Qualification..................
Effectiveness J. Assurance of Quality............ '**
........... -Total 1920 100%
- Hours expended in facility license activities and operator license
activities.not included with direct inspection effort statistics. i
- Hours expended in the areas'of training and quality assurance are included in
other functional areas, therefore, no direct inspection hours are given f - these areas. l ! ' - 1 i 1 ____.1.__.___ _ . _ . _ _ _. _ _>
g_-- -. . . -
42 l 's l TABLE 3 ' LISTING OF LERs'BY FUNCTIONAL AREA' CAUSE CODES AREA A B C D E' X. TOTAL
- Operations
- 1
3 0 0 'l 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 l 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 i D - Defective Procedures' l E - Component Failure X -'Other ! i i l J . - _
, _ _ - _ . _ _ _ _ _ _ - _ _ _ _ _ _ - - -__ , 4 , ,. , , , % ? . .r 4 ' 'e- C 43L , ,y , 7 , :. TABLE =4U ' ' ' r ,' 'LER SYNOPSISE ' , c; q _. > A LER Number Event.Date Cause Code Description ,e , '85-27*- '11/22/85 E
- Inoperable Main
- Steam.
> ' Isolation Valves foundi ' duri n'g '.te sti ng . .85-28'
- 12/13/85
E ' H igh LPressureL Coolant'~ , Injection' System-IsolationL , 'due' to: faultyitrip:' unit , 86-01. 3/3/86 A. Failure to perform APRM surveillance;at required . frequency. 86-02 3/3/86 A Failure to perform ' Diesel-Fire Pump: .. Surveillance atl required; > $ frequency. '" < 86-03L 3/12/86 X: . Inoperable containment 1 isolation valveron High H Pressure Coolant. Injection system 86-04~ 3/15/86 .D ' Reactor. Trip while. ' shutdown performi ng: po s't work' testing. ~86-05 4/4/86 B Reactor Core Isolation Cooling isolation due:to; .j loose lead. 1. 86-06 3/25/86 A Reactor Trip'while..- ' ,n 1 ' shutdown due.to' low vessel l level ., . l 86-07 3/23/86 A Failure to meet- D' Environmental' Qualification requirements for 4 valve operator's j r inside containment, j ~ 86-08- '3/27/86 X Setpoint drift of ASCO pressure switches. 1 .! ! l L
-. _. . .. -_-. - _ _ , y I , { ,, 'j ' .- ] q 44 .l i. 1' : l l; a ' . l -86-09 3/28/86 A Late chemistry surveillance during ] startup. a
- l
l.- 86-10 4/4/86 8 Reactor trip while i ' conducting turbine stop valve testing. ! 86-11 5/15/86 8' Fail ure ' of recirculation loop ! discharge bypass valve to ! operate. i 86-12 .5/25/86 B High Pressure Coolant Injunction inoperable due 1 to breaker tripping when ' wetted.-
1 86-13 7/3/86 B Reactor trip due to l protective relay test j block failure. 86-14 9/3/86 D High Pressure Coolant
Injection valve failure f due to procedural inadequacies. 86-15 9/4/86 D Reactor Core Isolation Cooling isolation due to
inadequate' venting of I transmitter. 86-16 9/9/86 X Use of incorrect ' Minimum Critical Power Ratio calculation. ! 1 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 ! l ! ! _ -__ -
m .. - .3 i ,j; j .. ~45
, ! TABLE 5 ' ENFORCEMENT SUMMARY 12/1/85 - 11/30/86 l i JAMES A. FITZPATRICK NUCLEAR POWER PLANT , . s 'A. . Number and Severity Level . Level of Violations -j Severity Level II 0 ' Severity Level I' 0 Severity Level III O Severity Level IV 4 4 Severity Level V 2 l Deviation 0 I TOTAL ~ii j i ! B. ~ Violation vs. Functional Area SEVERITY LEVEL FUNCTIONAL AREA 1 2 3 4' 5 DEV. TOTAL I ! Operations 2 2
- l
Radiological. Controls 1 1 Maintenance 1 1 Surveillance 1 1 Emergency Prep. O. i l Sec/ Safeguards 0 Refueling and Outage Management 0
) Training 0 Licensing 0 , Assurance of Quality 1 1 _._ __ .__ __. __ _ TOTALS 2 4 6 I , 1
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_ _ , _ _ -- . _ . _ _ _ '% 46 r l ' ' TABLE 5 (CONTINUED) ENFORCEMENT SUMMARY .. Inspection Violation Functional Report Requirement Level Area . Violation __ 85-31 10CFR50.72 5 Operations Failure to report i 12/1/85-1/17/86 High Pressure
Coolant Injection System Isolations and.Inoperability.
86-01 Tech Spec 4 Surveillance Failure to perform 1/18/86-3/10/86 4.0.B. surveillance within required 1 frequency. ! 86-11 10CFR50 4' Assurance of Failure to properly I 7/14/86-7/18/86 APP. B(XIII). Quality care for items in storage. ! 86-12 Tech Spec 5 Rad Control Failure to j '7/21/86-7/25/86 7.2 properly impicment 1 procedure for ! calibration of Alpha- j Beta counter. 1 i 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 l transmitter and survey { new fuel shipments. ' l 86-13 10CFR50.72 5 Operations Failure to make 8/9/86-9/29/86 ENS report for reactor I core isolation cooling system isolation. l l ' - - _ _ _ _ - - _ _ _ _
- . - - _ - . _-_ _ _ _ _ _ _ _ _ _ _ _ - - _ __ .: 4/ a 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 vesse'l 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 I position indication change causing faulty position ] (LER 86-10) indication. j l 4/6/86 Start-up I 4. 5/15/86 Shutdown required Equipment Failure: Engineering by Technical Speci- Inadequate design change Support , fications due to review resulted in valve i inoperable inoperability due to thermal Recirculation loop growth. , discharge bypass J valve-(LER 86-11) ! 5/18/86 Start-up l , - ___ _ _ _ - - _:
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7 1 , E a ~ u l5. 7/3/86: '100% Reactor 1 Trip'due to . Equipment Failure - Maintenance ,
" 1Turbineitrip Random: A' failure in. , ' ' o . (LER'86-13)- . .rotective, relay; test. . p
' ' circuit' caused'a; turbine trip. ' . .. . 7/4/86- Start-up. ' 6. >9/30/86 -SD LReactor Tr.ip'due to: Equipment' Failure 1- Maintenance.- . neutron monitoring . Random: A; wet connector ' instrument failure ' (LER 86-17); ' caused the LPRM to fail upscale. ,
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10/1/86; SD .Seven reactor' trips ' Equipment Failure: . . Maintenance - 10/3/86. due to neutron During under-vessellwork, 10/4/86 monitoring . maintenance' personnel . -instrument spiking' .which was'later.found to bumped ~"G"'IRM connecto'r -(LER 86-17) < have a; broken connector. h i10/9/86- Start-up: ' , ) e ; J. s , 'l
P; -" ~^~ 7 4, . = d' if%l . , UNITED STATES = j ycg NUCLEAR REGULATORY COMMISSION .. J , 'E 5 REGION I I .*f 0 .8: ' 631 PARK AVENUE '- _4 ' _44 , ,d KING oF PHUSSIA, PENNSYLVANIA 19406 . .... . .
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ENCLOSURE'4 l
. d 13 MAR F ' .
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p. ' Docket'No. 50-333- ] ' 1 Power Authority of'thet State of New York l _ ' James A. FitzPatrick Nuclear. Power Plant { ATIN: Mr.' J.-C. Brons' Senior Vice President-Nucle'ar Generation J 1 123 Main Street . White Plains, New York 13093 ] i Gentlemen: i < ' -Subject: Systematic Assessment of Licensee Performance (SALP); Report No. 50-333/85-98 The'NRC Region.-l SALP Board conducted a. review on February 13, 1987 and } evaluated the performance of activities associated with James A. FitzPatrick j Nuclear Power Plant. The results of this assessment are documented in the . i enclosed SALP Board report. -A meeting will be scheduled to discuss,this assessment. This meeting is intended to provide'a-forum for candid' ' discussions relating to this performance. 5 . At the ' meeting, you should be prepared to discuss our assessment and your 4 plans'to improve performance. Any comments you may-have.regarding our report. may be discussed at the meeting. Additionally, you may provide written comments within 30 days after the meeting. We appreciate your. cooperation. Sinc.erely, h Mi 4 omas E. Murley v Regional Administrator Enclosure: 1. SALP Board Report No. 50-333/85-98 ! < I 'Y5f ( 4 ,, . 1 - -
, . ,; ; ;sy y- - - n . , ny - , . .;, - - , ac " JQ%' .. ,. ,. .. ., . ; ' kb W ' / Power'AuthorityJof' . > -
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l R 13 MA 19fd -. l .? g ' ithe; State of.New York- , v < h. peo
cc w/ encl: . .. . .. -h ' ' c +m '
- LizW. Sinclair, President
' ' ' "J.i P! Bayne, First Executive.Vice President and, Chief Operations Of ficer; $ ' ' (A. Klausmann,6Vice' President (- Quali.ty Assurance and' Reliability? ] ' ' R. LF Patch; Quality. Assurance Superintendent o , George;M.;Wilverding? Chairman', Safety Review Committee 1 Gerald C; Goldstein, Assistant General Counsel . "NRC Licensing Project. Manager- " ' - , -l-Dept; ofLPublicSe'rvice,LState of New York ' ' Public. Document Room (PDR)' '
- Local .Public Document . Room 1(LPDR)
' Nuclear. Safety Information Center (NSIC) L NRC Resident inspector L,' State of.New York Chairman'Zech I ' Commissioner Roberts Commissioner Asselstine. < . -Commissioner Bernthal ' Commissioner Carri S. Ebneter, DRS- 4 T. Marti n ~, DRSS 'J. Taylor nIE- s fT. Murley, RIL J.'Allan,LRI. r > D.lHolody,' RI K' Abraham! PA0 (2 copies)' . . , . . . Board Members: 1 l~ e z' i ! h. , s
1 .. Y l 1 C i
- _ _ - - - _ _ _ _ _ - _ ., .' o f cp ENCLOSURE 5 SALP BOARD REPORT ERRATA SHEET Page Paragraph Original Should. Read
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5- aggressive ambitious 19 3 audit appraisal Basis: These changes were made in order to avoid any misconstrued meanings. Note: No change was made on page 27 regarding the reason for the plant . shutdown because information from you staff, as well as LER No. 86-11 . support the statement that the plant shut down because of Technical l Specification wording problems. We are aware, however, that a packing leak was also identified and needed to be repaired. f l $, !
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