ML20236K621
| ML20236K621 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/01/1998 |
| From: | David Lew NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| 50-333-98-01, 50-333-98-1, NUDOCS 9807100010 | |
| Download: ML20236K621 (3) | |
See also: IR 05000333/1998001
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July 1, 1998
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Mr. Michael J. Colomb
Site Executive Officer
New York Power Authority .
James A. FitzPatrick Nuclea.- Power Plant
Post Office Box 41
Lycoming, NY 13093
Dear Mr. Colomb:
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Subject:
NRC Inspection Report No. 50-333/98-01 and Notice of Violation
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This letter refers to your June 17,1998 correspondence, in response to our
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May 18,1998 letter.
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Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
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Original Signed by:
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David C. Lew, Chief
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Projects Branch 2A
Division of Reactor Projects
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Docket No. 50-333
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9907100010 980701
ADOCK 05000333
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0FFICIAL RECORD COPY
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Michael J. Colomb
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cc:
C. Rappleyea, Chairman and Chief Executive Officer
E. Zeltmann, President and Chief Operating Officer
R. Hiney, Executive Vice President for Project Operations
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J. Knubel, Chief Nuclear Officer and Senior Vice President
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H. P. Salmon, Jr., Vice President of Nuclear Operations
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W. Josiger, Vice President - Engineering and Project Management
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J. Kelly, Director - Regulatory Affairs and Special Projects
T. Dougherty, Vice President - Nuclear Engineering
R. Deasy, Vice President - Appraisal and Compliance Services
R. Patch, Director - Quality Assurance
G. C. Goldstein, Assistant General Counsel '
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C. D. Faison, Director, Nuclear Licensing
' K. Peters, Licensing Manager
T. Morra, Executive Chair, Four County Nuclear Safety Committee
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cc w/ copy of Licensee's Response Letter:
Supervisor, Town of Scriba
C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
P. Eddy, Director, Electric Division, Department of Public Service, State
of New York
- G. T. Goering, Consultant, New York Power Authority
J. E. Gagliardo, Consultant, New York Power Authority
E. S. Beckjord, Consultant, New York Power Authority
F. William Valentino, President, New York State Energy Research
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and Development Authority
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J. Spath, Program Director, New York State Energy Research
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and Development Authority
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Michael J. Colomb
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Distribution w/ copy of Licensee's Response Letter:
B. McCabe, RI EDO Coordinator
S. Bajwa, NRR
J. Williams, NRR
- M. Campion, Rt
R. Correia, NRR
F. Talbot, NRR
Nuclear Safety Information Center (NSIC)
PUBLIC
NRC Resident Inspector
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Region i Docket Room (with concurrences)
Inspection Program Branch, NRR (IPAS)
D.Lew,DRP
J.Rogge,DRP
P. Kaufman, DRP
R. Junod, DRP
DOCDESK
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DOCUMENT NAME: A:\\RL9801.FTZ
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To r:ceive a copy of this document, Indicate in the box:
"C" = Copy without attachment / enclosure
"E" =
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Copy with ettachment/ enclosure
"N" = No copy
OFFICE
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Rl/DRP
NAME
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DATE
07// /98
07/l/98
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OFFICIAL RECORD COPY
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JImaa A. FitzPatrick
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Nuct ar Pgw;r PIInt
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PO Ocx 41
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Lyccmirig New York 13093
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315 342-3840
4 NewYorkPower
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June 17,1998
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U.S Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Station PI-137
Washington, D.C. 20555
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SUBJECT:
James A. FitzPatrick Nuclear Power Plant
Docket No. 50-333
Reply to Notice of Violation
NRC Inteersted Inspection Report 50-333/98-01
Dear Sir:
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h accordance with the provisions of 10 CFR 2.201, Notice of Violation, the New York
Power Authority submits a response to the notice transmitted by your letter dated May
<18,1998. Your letter refers to the results of the integrated inspection conducted from
February 22,1998 through April 19,1998 at the James A. FitzPatrick Nuclear Power
Plant.
Attachment 1, Reply to Notice of Violation, provides the description of the violations,
reasons for the violations, the corrective actions that have been taken and results
achieved, corrective actions to be taken to avoid further violations, and the dates
of full compliance.
There are no commitments contained in this submittal.
If you have any questions, please contact Mr. Arthur Zaremba, Licensing Manager, at
(315)349-6365.
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y yours,
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li hael J. Colomb
Site Executive Officer
STATE OF NEW YORK
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COUNTY OF OSWEGO
Subscribed and sworn to before me
This
%i of $ 4 1998.
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Notary l ublic
MJC:GJB:las
TAMm cAmmesm
Attachments as stated
Notary Pubhe, State of New York
cuant.ed in oswago county
cc:
Next page
Commission E mpires 8/19/[
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United States Nuclear Regulatory Commission
Atta: Document Control Desk
Subject: Reply to Notice of Violation
NRC Integrated Inspection Report 50-333/98-01
cc:
Regional Administrator
U.S. Nuclear Regulatory Commission
475 Allendale Road
King of Prussia, PA 19406
Office of the Resident Inspector
U.S. Nuclear Regulatory Commission
P.O. Box 136
Lycoming, NY 13093
Joseph Williams, Project Manager
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Project Directorate 1-1
Division of Reactor Projects -1/11
U.S. Nuclear Regulatory Commission
Mail Stop.14 B2
Washington, DC 20555
Attachments:
Reply to Notice of Violation
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Att:chment I
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Reply to Notice of Violation
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NRC Integrated Inspection Report 50-333/98-01
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VIOLATION A
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10 CFR 50. Appendix B, Criterion XI, " Test Control", requires, in part, that a test
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program be established to assure that all testing required to demonstrate that structures,
systems, and components willperform satisfactorily in service is identified andperformed
in accordance with procedures which incorporate the requirements and acceptance limits
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contained in applicable procedures.
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Contrary to the above, on February 13,1998, the test programfor the reactor building
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system did not assure that all testing required to demonstrate that the system would
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perform satisfactorily in service was performed. Specifically, surveillance test
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procedure, ST-39D, Reactor Building Leak Rate Test, Revision 14, did not verify that
individual reactor building isoli tion valves were sufficiently leak tight to maintain
secondary containment integrity in the event ofa single activefailure.
@MISSI_ON OR DENIAL OF THE VIOLATION
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The Authority agrees-with the violation.
REASONS FOR VIOLATION
The cause for the failure of the Reactor Building System test program to demonstrate
single isolation valve integrity was a less than adequate test procedure. The primary
reason for the procedure weakness was that the process used during the initial plant
start-up test development failed to consider all important design features of the ' system.
A contributor to the duration of this problem was that the ongoing process used to review
the adequacy of surveillance tests was focused primarily on Technical Specification
requirements.
The Standby Gas Treatment (SGT) System is designed, in conjunction with the
Secondary Containment, to be single failure proof. The system logic is designed such
that following a single active component failure, building isolation can occur.
Review of historical data associated with surveillance test procedure ST-39D, indicates
that during the development of the initial test, and during subsequent test adequacy
reviews, single failure consideration was given to system logic and building access
penetrations. However, there was inadequate consideration ofleak tightness for
individual secondary containment isolation valves following a single failure of adjacent
valves.
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Reply to Notice of Violation
NRC Integrated Inspection Report 50-333/98-01
~ CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
Following identification of the surveillance test procedure deficiency, the Reactor
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Building isolation valves were tested individually. An operability determination was
also completed in conjunction with the tests. This demonstrated that, while individual
isolation valve leakage was not determined, the existing systems would sustain a
single failure and still perform their safety functions.
Surveillance test procedure ST-39D has been revised to establish test methods that
demonstrate the capability of each SGT System train to maintain Reactor Building
differential pressure at design requirements.
A review of other surveillance tests that verify building isolation has been completed
to confirm that leak rates are being measured properly. The results of this review '
identified one potential concern associate with testing the single failure design of the
Control Room Ventilation System. This condition has been reported on a Deviation
Event Report, and this issue will be tracked to resolution in the plant's formal
corrective action program.
RESULTS ACHIEVED
The results of the actions taken have provided assurance that Secondary Containment
testing methods are adequate to identify potential isolation valve problems.
CORRECTIVE ACTIONS TO BE TAKEN
Administrative procedure AP-02.k)4," Control of Procedures"is being evaluated with
regard to requirements for completion of surveillance test procedure adequacy
reviews. The scope of this review process will be expanded and/or refined as
appropriate.
(Scheduled Completion Date - 12/31/98)
Technical Services Department will evaluate system engineering programs to ensure
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that important design features of safety-related equipment are periodically verified, as
described in 10 CFR 50, Appendix B, Criterion XI.
(Scheduled Completion Date - 12/31/98)
DATE WHEN FULL COMPLIANCE WAS ACHIEVED
Full compliance was achieved on February 13,1998, following revision of surveillance
test procedure ST-39D to include the performance ofin lividual leak rate testing of the
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Att:chmnt I
Reply to Notice of Violation
NRC Integrated Inspection Report 50-333/98-01
VIOLATION B
Technical Specification 6.1 requires, in part, that proceduresfor personnel radiation
protection shall be prepared and adhered tofor allplant operations. Administrative
Procedure (AP)-07.00, Radiation Protection Program, Section 6.1.5, states that radiation
workers shall comply with radiation protection instruction"s.
Contrary to the above, three examples were identified in which radiation workers did not
comply with radiation protection instructions.
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On' Afarch 31,1998, two radiation workers exited the radiological controlled
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area (RCA)from the motor generator set room through a door that had a
radiologicalposting which stated the door was an unauthorized exit.
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On December 9,1997, a radiation worker did not have a thermoluminescent
dosimeter before entering the RCA as required by AP-07.05, Exposure
Monitoring and Controls, Rev. O.
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3.
On September 25,1997, a radiation worker did not log onto a radiation work
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permit before entering the RCA in the vicinity ofthe condensate storage tanks as
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required by AP-07.01, Rev. 4, Radiation Work Permit Program.
ADMISSION OR DENIAL OF THE VIOLATION
The Authority agrees with the violation.
REASONS FOR VIOLATION
The cause for this violation was personnel error.
In the first example, two radiation workers exited the Radiological Controlled Area
(RCA) from a door designated as emergency use only. The workers did not read the
radiological postings on the door they had entered which was posted "RCA Boundary"
and " Emergency Use Only".
In the second example, a radiation worker entered the RCA without a thermoluminesceat
dosimeter (TLD). The worker scanned the bar code on his TLD and put the TLD on the
table while completing the RWP log in process. Upon completion, a self-check was not
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performed and he failed to pick up his TLD and entered the RCA wearing only the
electronic dosimeter (ED).
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Reply to Notice of Violation
NRC Integrated Inspection Report 50-333/98-01
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In the third example, a radiation worker entered an RCA without logging onto the
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required Radiation Work Permit (RWP). The worker did not read posted instructions
which required an RWP for entry.
The common radiation worker performance factor identified in each of the three
examples was inattention to detail. In the first and third example, workers failed to stop
and assess the radiological condition or circumstance being encountered. In the second
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example, the worker did not self-check prior to entering the RCA.
Also, the radiation workers involved in the three examples encountered circumstances
unfamiliar to them. In the first example, one worker had entered the MO Set Room via
the access in question one time in the past several years, while the second worker had
never entered the work area from this location. In the second example, the process of
electronically logging onto an RWP and entering the RCA had changed since the worker
was last employed at FitzPatrick. In the third example, the worker entered an RCA
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outside the power block that he had not entered in a long time. These workers did not
vigorously pursue task-specific details prior to performing unfan:iliar activities.
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CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
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Formal disciplinary action was taken with each radiation worker involved.
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The Radiological and Environmental Services (RES) Department and the Design
Engineering Department have performed a root cause analysis on the most recent
example to correct personnel errors associated with RCA boundary control.
Following the Event in Examnie #1
The two workers who improperly' exited the RCA were directed to re-enter the MG
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Set Room and to exit at the main RCA control point.
A contamination survey was performed where the workers exited to ensure no spread
of contamination occurred. No contamination was found.
The workers were placed on Radiological Hold temporarily restricting their access to
the RCA.
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Reply to Notice of Violation
NRC Integrated Inspection Report 50-333/98-01
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont.)
Following the Event in Example #2
The worker who entered into the RCA without a TLD was placed on Radiological
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Hold restricting his access to the RCA.
A critique was conducted with the RES Department, the individual involved, his
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immediate supervisor, and the acting Director of Design Engineering.
The contracted worker involved was terminated and escorted from the plant. The
individual is currently employed at FitzPatrick but remains restricted from the RCA.
Radiological requirements for RCA entry were reviewed with plant staff during
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departmental tailgate meetings following this event.
Following the Event in Example #3
The worker who entered the CST area without logging onto an RWP was placed on
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Radiological Hold temporarily restricting his access to the RCA.
The worker was counseled on his actions and on management expectations.
The worker's department conducted a stand down meeting to review the factors
associated with the event and reinforce awareness of radiological postings.
The secondary RCA boundary which was temporarily removed to facilitate work was
replaced.
This event and the human performance issues of performing self-check / verification
were discussed with plant staff during weekly departmental tailgate meetings.
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RESULTS ACHIEVED
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Following each event, immediate corrective actions were taken to ensure compliance by
radiation workers involved. Tailgate meetings reinforced management expectations.
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Reply to Notice of Violation
NRC Integrated Inspection Report 50-333/98-01
CORRECTIVE ACTIONS TO BE TAKEN
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An evaluation will be conducted of RCA access / egress points to determine if
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additional error-like situations exist. Potential or past problem areas identified will be
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simplified to reduce the likelihood of additional individual performance errors.
(Scheduled Completion Date - 08/15/98)
Plant departments will conduct tailgate meetings to re-emphasize the importance of
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following radiological instructions. This violation will be discussed in detail.
(Scheduled Completion Date-07/15/98)
DATE WHEN FULL COMPLIANCE WAS ACHIEVED
Full compliance was achieved immediately following the discovery and the
implementation of radiological controls associated with each of the events.
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