ML20247K297
| ML20247K297 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/08/1998 |
| 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 | |
| 50-333-97-08, 50-333-97-8, NUDOCS 9805220057 | |
| Download: ML20247K297 (4) | |
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! May 8, 1998 l l
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Mr. Michael J. Colomb l Site Executive Officer New York Power Authority l James A. FitzPatrick Nuclear Power Plant Post Office Box 41 Lycoming, NY 13093
Dear Mr. Colomb:
Subject:
NRC Integrated Inspection Report No. 50-333/97-08and Revision to Notice of Violation This letter refers to your April 20,1998 correspondence, in response to our January 20,1998 letter.
Thank you for infor. ting us of the results of an extent of condition review of your Environment Qualification (EO) Program which identified additional program changes and i and that full compliance date needed extension. l The results of the corrective and preventive actions documented in your revised response letter will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, Original Signed by:
David C. Lew, Chief Projects Branch 2A Division of Reactor Projects Docket No. 50-333 i
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9805220057 990505 '
0FFICIAL RECORD COPY IE:01 ,
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l l' Michael J. Colomb 2 l cc:
- l. C. Rappleyea, Chairman and Chief Executive Officer E. Zeltmann, President and Chief Operating Officer R. Hiney, Executive Vice President for Project Operations J. Knubel, Chief Nuclear Officer and Senior Vice President l H. P. Salmon, Jr., Vice President of Nuclear Operations W. Josiger, Vice President - Engineering and Project Management J. Kelly, Director - Regulatory Affairs and Special Projects T. Dougherty, Vice President - Nuclear Engineering i R. Deasy, Vice President - Appraisal and Compliance Services R. Patch, Director - Quality Assurance G. C. Goldstein, Assistant General Counsel C. D. Faison, Director, Nuclear Licensing L K. Peters, Licensing Manager T. Morra, Executive Chair, Four County Nuclear Safety Committee
! cc w/ copy of Licensee's Response Letter:
l Supervisor, Town of Scriba l 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- )
l E. S. Beckjord, Consultant, New York Power Authority '
F. William Valentino, President, New York State Energy Research and Development Authority J.' Spath, Program Director, New York State Energy Research and Development Authority i
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Michael J. Colomb 3 Distribution w/ copy of Licensee's Response Letter:
B. McCabe, RI EDO Coordinator S. Bajwa, NRR J. Williams, NRR M. Campion, RI R. Correia, NRR F. Talbot, NRR Nuclear Safety information Center (NSIC)
PUBLIC NRC Resident inspector l
Region i Docket Room (with concurrences) l inspection Program Branch, NRR (IPAS) l D. Lew, DRP P. Kaufman, DRP R. Junod, DRP DOCDESK 1
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l DOCUMENT NAME: A:\RL9708R.FTZ i *S:a previous concurrences l To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =
Copy with attachment / enclosure "N" = No copy l
l OFFICE
- Rl/DRF
- Rl/DRP 'Rl/DRP NAME GHunegs PKaufman DLew l DATE 05/ /98 05/ /98 05/ /98 )
OFFICIAL RECORD COPY i I l '
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Michael J. Colomb 3 Distribution w/ copy of Licensee's Response Letter:
B. McCabe, RI EDO Coordinator S. Bajwa, NRR J. Williams, NRR M. Campion, RI R. Correia, NRR F. Talbot, NRR Nuclear Safety Information Center (NSIC)
PUBLIC NRC Resident inspector Region i Docket Room (with concurrences) inspection Program Branch, NRR (IPAS)
J. Rogge, DRP A. Blamey, DRP R.Junod,DRP DOCDESK DOCUMENT NAME: A:\RL9708R.FTZ To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =
C:py with attachment / enclosure "N" = No copy l OFFICE Rl/DRP , s fl Rl/DRP Rl/DRP NAME GH6 PKaufm
{ DLe DATE 05/D /98 05/6 /98 05/ 7/98 OFFICIAL RECORD COPY
J rnis A. Fit 2 Patrick
. Nuct:ar PIwir PI:nt
.* , . 2G8 Lake Acad P O Box 41 Lycoming, New York 13093
. 315-342 3840
- > NewYorkPower tv Authority w cnaeia. coiorne sae exec *e =cer April 20,1998 JAFP-98-0137 United States Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Revision to Reply to Notice of Violation NRC Intearated Inspection Report 50-333/97-08
Reference:
- 1. JAFP-98-OO74, Reply to Notice of Violation, NRC Integrated Inspection Report 50-333/97-08, datad February 25,1998
Dear Sir:
In accordance with the provisions of 10 CFR 2.201, Notice of Violation, the New York j Power Authority submitted a response (Reference 1) to the notice transmitted by your !
letter dated January 20,1998. Your letter referred to the results of the integrated inspection conducted from October 27,1997 through December 21,1997 at the James l i
A. FitzPatrick Nuclear Power Plant.
l Contained in Reference 1 (Reply to Notice of Violation C) was a commitment to the NRC.to submit a revision to this response if the results of an extent of condition review of JAF's Environmental Qualification (EQ) Program identified additional program changes requiring an extension to the reported scheduled full compliance date of March 15,1998. This revised response contains: 1) EQ Program changes resulting from this review; 2) a current status of Corrective Actions That Have been Taken for Reply to Notice of Violations A, B, and C; and 3) a clarification to information in Corrective Actions that Have Been Taken as reported in Reply to Notice of Violation C.
Also discussed in your letter are indications that additional focus and attention are warranted to improve work control activities. The Authority has identified our need to improve in this area and a formal root cause analysis is under final management review.
We believe the corrective actions resulting from this analysis will be effective in further improving our performance.
Attachment I, Revision to Reply to Notice of Violation, provides the description of the
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violations, reasons for the violations, corrective actions that have been taken and the 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. l Q0W lhf
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- , United Stit:s Nucl;;r Regul: tory C mmissi n Attn: D: cum:nt Control D:sk
Subject:
Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50 333/97-08 i Page 2-i If you have any questions, please contact Mr. Arthur Zaremba, at (315) 349-6365.
Very truly yours, MICHAEL J. COLOMB Site Executive Officer MJC:GJB:las STATE OF NEW YORK COUNTY OF OSWEGO Attachments as stated Subscribed and sworn to before me This 2g) day of % 1998
'llw i, N(t"ary Pyb)lc A k& a cc: Regional Administrator U.S. Nuclear Regulatory Commission NANCY B.CZEROW 475 Allendale Road WN"*"
King of Prussia, PA 19406 ousenedin oewego county edesee11 m y f. .tp vs Office of the Resident inspector U.S. Nuclear Regulatory Commission 1
P.O. Box 136 Lycoming, NY 13093 James A. FitzPatrick NPP Project Manager Project Directorate 1-1 Division of Reactor Projects - 1/Il U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 l
Attachments:
Revision to Reply to Notice of Violation
r Att chm:nt 1 R: vision ta Reply ta N:tisa cf Virl: tion NRC Integrated Inspection Report 50 333I97-08
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yl9'.ATION l A Tect nical Specification 6.3.(A)1 requires that written procedures and administrative policies shallbe established, implemented and maintained that meet or exceed the requiremen ts and recommendations of Section 5 of American National Standards Institute (ANSI) 18.7 - 1972 " Facility Administrative Policies at, f Procedures." Section 5.1.2 of ANSI 18. 7 - 1972 states in part, that procedures shallbe followed, and the requirements '
for use of procedures shallbe prescribed in writing. Abnormal Operating Procedure (AOP)
-23, Direct Current (DC) Power System GroundIsolation specified the sequence that breakers shallbe opened to isolate system grounds.
Contrary to the above, on October 23,1997, procedures were not followed while perfctming AOP-23, DC Power System GroundIsolation, in that the sequence that breakers shallbe opened to isolate system grounds was not followed. Specificdly, 71DCB2 Bre?ker No. 6, was openedprior to opening the breakers for 23MOV-57 and \
23MOV 52, the high pressure coolant injection (HPCI) booster pump suction from the suppression pool downstream and upstream isolation valves, respectively, which caused the valves to open inadvertently.
This is a Severity LevelIV violation (Supplement l}
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ADMISSION OR DENIAL OF THE VIOLATION.
The Authority agrees with the vioistion.
REASONS FOR VIOLATnON The cause for this violation was personnel error. The performance factor leading to this error was ineffective worker practices. The Nuclear Control Operator (NCO) assigned the duties associated with the performance of AOP-23 did not adequately utilize the practice of self-checking during the work evolutions associated with the procedure. This resulted in procedural steps being performed out of sequence.
Contributing human performance factors which iifluenced the NCO's actions were:
Task interruptions and perceived pressure to complete task. Following the pre-job brief, delays were encountered prior to performance of the procedure step. This, combined with an increasing ground condition, caused concern on the part of the NCO to focus his attention on actions which would eliminate the ground. Additionally, the NCO became focused on getting the correct breaker (71DCB2 #6) due to the recognized plant impact of opening
' the wrong breaker. These distractions contributed to the oversight by the NCO for not opening power supply breakers for 23MOV 57 and 23MOV-58.
Lack of physical, orrierly procedure place-keeping contributed to performing the AOP-23 procedure step out-of-sequence.
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Attachmsnt 1 Rsvision to Riply to Notica of Violstion NRC Integrated Inspection Report 50-333/97-08 CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN A root cause evaluation was performed on the events associated with this violation to identify specific cause, evaluate the extent of conditions that ,:ontributed to the occurrence of the violation relative to recent similar plant occurrences, and develop lessons learned. The Operations Manager has reviewed the results of this evaluation with Operations shift personnel, The Operations Manager emphasized, during this review and in night order entries, the importance of good procedure place-keeping to ensure proper procedure use.
The NCO responsible for the error has been counseled.
- 1 Abnormal Operating Procedures AOP-22, DC Power System A Ground Isolation, and AOP-23, DC Power System B Ground Isolation, have been revised to improve the human factors associated with performing this procedure.
Administrative Procedure AP-12.03, Administration of Operations, has been revised to formally state management's expectations for procedure place-keeping and provide examples of acceptable techniques.
RESULTS ACHIEVED Actions taken have: 1) increased operator sensitivity to the issues associated with the cause of this violation: 2) raised operator awareness to potential task distractions or interruptions which may result in errors, and 3) increased emphasis to operators on proper procedere place-keeping.
CORRECTIVE ACTIONS TO BE TAKEN None l
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on October 23,1997, subsequent to Control Room recognition that missed steps to AOP-23 had occurred. Control Room actions included re-closure of breaker 71DCH2 #6 and restoration of HPCI suction paths to normallineup.
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Att: chm:nt 1 R:vi: ion to Reply to N:tico of VI:lttion NRC Integrated inspection Report 50 333/97-08 ;
VIOLATION B l
Technical specification 3.7.D.2 states, in part, that, with one or more of the containment isolation valves inoperable, maintain at least one isolation valve operable in each affected penetration that is open and restore the inoperable valvels) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; orisolate each affectedpenetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of atleast one
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deactivated automatic valve securedin the closedposition.
Contrary to the above, on October 24,1997, maintenance activities to repair a ground problem were conducted which rendered the primary containment isolation function of the \
outboard high pressure coolant injection steam isolation valve inoperable and Technical l
' Specification 3. 7.D.2 requirements were not taken. After a maintenance error caused an l
invalid engineered safeguards feature actuation signal to occurin the same logic circuitry, operators recognized the failure to complete TS requirements andisolated the valve approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> later. l This is a Severity LevelIV violation (Supplement I).
i ADMISSION GR DENIAL OF THE VIOLATION The Authority agrees with the violation.
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- i REASON FOR VIOLATION i The cause for this violation was personnel error. When listing the required Technical l
! Specification actions to be taken for testing on the "B" HPCI logic circuit in support of DC ground troubleshooting activities, operators failed to recognize that the "B" HPCI logic Primary Containment isolation System (PCIS) function of the outboard HPCI steam isolation valve was also being rendered inoperable. This resulted in failure to take the appropriate ;
actions required by Technical Specification 3.7.D.2. LCO action statement. '
l Contributing causal factors leading to this human performance error were:
Less than adequate development of the Work Planning Package. The work planning package assessment and development was not commensurate with the level of risk associated with the maintenance activities.
l Inadequate work practices. The pre-work technical reviews by Operations staff of the planned DC ground troubleshooting efforts failed to identify the Primary Containment isolation System (PCIS) function that was affected. Operators incorrectly concluded that the HPCI seven day shutdown LCO, declared on 10/22/97 in support of ongoing i scheduled HPCI work, would envelope the DC ground troubleshooting activity, f
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Att: chm:nt 1 j
R:visi:n to R: ply to N:tino cf Vi:lation NRC Integrated inspection Report 50 333/97-08
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t REASONS FOR VIOLATION (cont'd.)
Procedure deficiency. Surveillance Test Procedure ST-2M, ECCS Trip System Bus Power Monitors Functional Test, and Abnormal Operating Procedure AOP-23, DC_
Power System B Ground Isolation, used to de-energize the HPCI logic, did not contain guidance associated with entry into T.S. LCO 3.7.D.2.
Drawing deficiency. The electrical elementary drawing for the HPCl PCIS logic contained a misleading label (i.e.; the logic was described as " manual steam valve isolation" not PCIS isolation) which contributed to operators failing to recognize that HPCI PCIS isolation logic was being de-energized.
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN A root cause evaluation was completed to identify the cause for the violation, contributing conditions, and develop lessons learned. The results of this evaluation were reviewed with all licensed shift personnel. Included in the review was the need for operators to reassess special work evolutions for new LCOs as emergent work occurs and assure they understand the potential consequence of work being released.
Surveillance Test Procedure ST-2M, was revised to identify the Containment isolation function (s) being placed in the inoperable condition as a result of fuse removal in various trip logic circuitry.
Procedure revisions have been completed to Abnormal Operating Procedures AOP 22, DC Power System A Ground Isolation, and AOP-23. Changes included revising DC ground isolation circuit procedure Attachment 2 to include functions effected by the breaker, and inclusion of T.S. LCOs required to be taken prior to isolation of the breaker to properly bound the extent of the activity. 3 HPCI elementary drawing number 1.61-142 was revised to accurately reflect that relay 23A-K35 is associated with PCIS isolation logic.
Persons designated as Qualified Technical Reviewers (OTRs) and/or Qualified Safety Reviewers (OSRs) within the Technical Services, Operations, Maintenance, and instrument and Controls Departments, whose responsibilities include conducting procedure reviews, were counseled on the results of the root cause evaluation.
Included was reinforcement of management's expectations regarding QTR and OSR responsibilities for procedure technical accuracy and completeness.
Deviation Event Report (DER 97-1649)) was generated following completion of the root cause evaluation to review and identify additional potential weaknesses in the work package planning and development process that were not addressed by the root cause evaluation. Corrective actions resulting from this DER included:
l The Work Control Center supervisor has discussed management expectations for i recognizing and ur,derstanding the potential plant impact and consequences of all work being released by Work Week Managers.
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Att: chm:nt 1 R; vision t2 R: ply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont'd.) l The issues associated with the failure (s) within the work package planning and development process to perform a detailed review of the HPCI PCIS logic prior to the issuance of the work to the field were reviewed with the Work Package ;
Planners during the Central Planning Department Manager's weekly tailgate I meeting.
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- The licensed operator initial training and continued training programs have been '
! updated to include scenarios involving fuse isolation, circuit analysis and assessment of its impact with respect to T.S. compliance.
A review was completed of other Surveillance Test Procedures and Operating Procedures to identify conditions where fuse removal occurs, and to assure resulting l
T.S. impact is captured. The review resulted in the revision of Surveillance Test Procedure ST-8E, Emergency Service Water System (ESW) Logic System Functional Test and Simulated Automatic Actuation Test, to require ESW to be declared inoperable when removing control power fuses for the ESW Lockout Matrix.
Actions were completed to delineate and define the responsibilities and functions of the Operations planner for three phases of work package completion: 1) Work Package Operational Assessment; 2) Work Package Review; and 3) Post-Work Testing Preparation and Review. These responsibilities were formalized and issued in a memorandum by the Operations Manager to Operations Department Senior Reactor Operators.
Administrative Procedure AP-10.03, Work Packaoe Plannina, was revised to provide added guidance for work package planning and preparation. Specifically, the level of detail and instruction, and depth of review used in the work control package planning and preparation process is dependent on the impact of the work on high risk or potential high-risk evolutions.
RESULTS ACHIEVED The results of the actions taken have reinforced management's expectations for:
maintaining independence when involved in procedure and process technical reviews to ensure compliance with Technical Specifications and NYPA commitments during special i evolutions; and that emergent work must be methodically assessed for compliance with Technical Specifications.
l CORRECTIVE ACTIONS TO BE TAKEN The formalized responsibilities and functions of the Operations planner for work l package completion will be incorporated into Administrative Procedure AP-10.03.
l (Scheduled Completion Date - June 30,1998)
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- Att:chment 1 R: vision ta R: ply to N:tica cf Violation NRC Integrated inspection Report 50-333/97-08 I
DATE WHEN FULL COMPLIANCE WAS ACHIEVED '
I Full compliance was achieved on October 25,1997, following the reinsertion of fuses, re-energizing the HPCI PCIS trip logic, and exiting from the HPCI LCO.
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Att:chment 1 R: vision to Reply ta N: tiro of Violation NRC Integrated Inspection Report 50 333/97-08 VIOLATION C 10 CFR SO.49(f) requires each item of electrical equipment important to safety to be environmentally qualified by testing or by combination of testing and analysis.
10 CFR 50.49(j) requires that a record of the environmental qualification be maintained in an auditable form to permit verification that each item of electrical equipment important to safety is qualified for its application and meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function.
Contrary to the above, from March 3,1993, to November 4,1997 electricalequipment important to safety was improperly removed from the environmental qualification program.
Specifically, high pressure coolant injection system pressure switches located in junction box JB-R2250E were removed from the environmental qualification program based on a nonconservative assumption in the calculations prepared to document the basis for the removal of certain components from the environmental qualification program.
This is a Severity levelIV violation (Supplement I).
ADMISSION OR DENIAL OF THE VIOLATION l The Authority agrees with the violation. However, details provided in the text of the violation summary require correction and/or additional clarification.
The closing paragraph provides the location of the HPCI pressure switches. It should be noted that the subject switches are installed on instrument Rack 25-50, located in Reactor Building elevation 242', adjacent to junction box JB-R2250E.
This paragraph also states that ".. pressure switches...were removed from the environmental qualification program based on a non-conservative assumption in the calculation prepared to document the basis for the removal of certain components from the environmental qualification program." It should be noted that the non conservative assumption in Calculation JAF-CALC-HPCI-00820 related to an assumed post-accident operatin' g time for the HPCI components and did not impact the conclusion made with regards to the subject components being removed and remaining off the Environmental Qualification Component List (EOCL). The cause for the removal was that the component safety function to maintain electricalintegrity following a HPCllRHR steam line break was not recognized. l' Details of this cause are provided in the following Reason For Violation summary.
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Att2hment 1 R;vi:lon ta R: ply to Nstice of Violation NRC Integrated Inspection Report 50-333/97-08 REASONS FOR VIOLATION In 1988, the Authority completed an Environmental Qualification Component List validation effort. The process was proceduralized in a NYPA approved vendor procedure. The l validation effort confirmed that HPCI pressure switches 23PS-86A, B, C, and D were required to be EQ. This was based on the safety function of these switches to initiate HPCI steam line isolation on high turbine exhaust pressure. This is not an accident mitigating safety function, however, false actuation of these switches during HPCI 1
operation following a small break Loss of Coolant Accident (LOCA) would cause an inadvertent HPCI system isolation.
A 1993 JAF calculation ([[::JAF-CALC-HPCI|JAF-CALC-HPCI]] 00820) was performed to support the basis for removal of several HPCI components from the EOCL, including pressure switches 23PS-86A, B, C, and D. The calculation considered that a small break LOCA does not create a harsh environment in the Reactor Building (RB) crescent area where the switches are located and therefore, the subject pressure switches were removed from the EOCL in 1996, a Deviation Event Report was initiated due to an identified non-conservative assumption made in calculation JAF-CALC-HPCI-00820. The non-conservative assumption was evaluated and the calculation revised. As a result, several HPCI motor operated valves (MOVs) that were deleted from the EOCL in 1993 were added back to the List. It should be noted that the non-conservative assumption did not impact the original conclusions made with regard to the removal of the subject pressure switches from the EQ Program.
The consideration (EQ basis) lacking in both the 1993 and 1996 reviews was the requirement that the switches must maintain electricalintegrity following a HPCl/RHR steam line break in the RB because the switches share common circuitry with the HPCI steam line auto isolation logic. They are not separately fused, therefore, it is postulated that a common mode failure (short to ground) caused by a HPCl/RHR steam line break and a single failure will disable the steam line auto isolation logic and prevent isolation of the breaker. Had this "not-fail" safety function consideration been included in the EQ evaluations for the subject switches, they would have remained in the EQ Program in 1993.
The cause for the violation was personnel error. A root cause analysis of this event identified the following human performance causal factors:
Worker Practices - Incorrect interpretation of drawina information. During the EQ component evaluation effort in 1988, the consequence of the failure of the pressure switches to maintain electrical integrity (a "Not-Fail" safety function) following a reactor building HELB was not recognized. As a result, this "Not-Fail" safety function" was not identified in evaluation.
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Att=hm:nt 1 R: vision ts R: ply to N tice of Violation NRC Integrated inspection Report 50 333/97-08 REASONS FOR VIOLATION (cont'd.)
I Worker Practices - Document use oractice. The 1993 and 1996 EQ evaluations were performed using Engineering and Design Procedure EDP-20, Procedure For Establishing if Plant Electrical Equipment is Within The Scope Of 10 CFR 50.49 l
(EO). Section 3 of the instructions for the evaluation (EDP-20, Attachment 1 form) provides specific instructions to identify component safety functions and designates "not-fail" as the safety function of components whose failure will prevent the accomplishment of the safety function of other safety related components due to fusing and circuit configuration. The evaluations did not correctly identify the "not-fail" safety function to maintain electrical integrity for the subject pressure switches. The engineers utilized a 1988 EQ component list evaluation report as a basis for the EDP 20 evaluation and did not review the applicable drawings to the extent that the error in the 1988 report was caught.
Worker Practices - Less than adeouate review / verification orocess.
The review processes used following the 1988,1993, and 1996 EQ evaluations were inadequate in that they did not identify the failure of the evaluations to identi!/ the safety function to maintain electrical integrity for the subject switches.
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN A root cause evaluation was performed to identify the conditions that caused or contributed to the occurrence of this violation, the recommended corrective actions i
and identification of lessons learned. The evaluation was prepared by and reviewed with Engineering Department personnel responsible for implementation of the EQ l program.
l Work Activity Control Procedure WACP 10.1.11, Environmental Qualification Proaram For Harsh Environment Plant Electrical Eouloment. Attachment 1,
" Environmental Qualification (EQ) Component List", was revised to include HPCI l pressure switches 23PS-86A, B, C and D.
t Engineering and Design Procedure EDP-20, Procedure For Establishing if Plant Electrical Eouloment is Within the Scoce of 10 CFR 50.49 (EQ), Attachment 1,
" Evaluation Form For Identification of Plant Electrical Equipment Requiring Environmental Qualification", was completed for HPCI pressure switches 23PS-86A, B, C, and D.
Addendum No. 7 to EQ Reference No. 310, " Addition of Component ID's 23PS-86A/B/C/D which were inadvertently deleted from the EQ Component List by WACP-10.1.11, Revision 17-1" was generated to reinstate the subject switches in the EQ file for Static-O-Ring pressure switches.
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Att:chment 1 R; vision to Reply to N:tico cf VI:l: tion NRC Integrated inspection Report 50-333/97-08 CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont'd.)
( This violation and its root cause evaluation have been included as required reading on Engineering Department personnel Task Qualification Sheets for performance of l
i Engineering Department Procedure EDP-20. This will assure that all prospective engineers, and all engineers presently qualified to perform EDP-20, will review the conditions associated with this violation.
An extent of condition review was performed to identify similar control circuit configurations that may involve components not being included in the EQ Program.
The results of this review identified eight (8) additional components within the High Pressure Coolant injection System (System 23) and Reactor Core Isolation Cooling ,
System (System 13), level switch 23LS 100, pressure switches 13PS-127,23PS- l 85,97A,978, and 848, flow switch 13FS-57, and valve position switch 23PNS-LS4. The six HPCI components were removed from the EQ Program based on similar 1993 incorrect EDP-20 evaluations as those discussed in the Reasons for '
Violation. RCIC flow switch 13FS-57 was deleted from the EQ Program based on the EQ Component List validation effort in 1988. RCIC pressure switch 13PS-127 was apparently not considered in the EQ Component List validation effort in 1988 due to an original QA classification of category M. The review also identified two components (HPCI level switches 23LS-91 A and B), presently in the EQ Program, having "Not-Fail" safety functions during HELB conditions, but with supporting EQ documentation addressing Loss Of Coolant Accident (LOCA) safety function only.
The following actions were completed in support of reinstatement of the 8 components into the EQ Program and corrections to the safety function of two existing EQ components:
The DER process has been used to identify the discrepancies, complete operability determinations for each component, initiate cause analyses of the discrepancies, and track corrective actions associated with the deficiencies.
Procedure EDP-20, Attachment 1 forms were completed for the 10 components.
RESULTS ACHIEVED The Authority believes the corrective actions taken were effective in resolving the conditions identified in the violation.
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Attzhment 1 R vision to Reply to Notice of Violation NRC Integrated inspection Report 50-333/97-08 l
CORRECTIVE ACTIONS TO BE TAKEN To improve worker practices for selection of appropriate input for use with EDP 20 evaluations, a revision will be made to EDP 20 to: (1) list the root cause evaluation for this violation as a management expectation under the Requirements Section of the l
procedure; and (2) provide additional clarification to emphasize that a review of the l
plant drawings must be performed to ensure that safety function of components whose l
- failure will prevent the accomplishment of the safety function of other safety related components due to fusing and circuit configuration is identified.
(Scheduled Completion Date - April 30,1998) l ihe Engineering Support Personnel (ESP) Training Program Review Committee (TPRC) will review this violation for possible inclusion into the ESP Continuing Training Program.
(Scheduled Completion Date - June 30,1998) I The effected EQ documentation and procedure WACP-10.1.11, Attachment 1 will be revised to address environmental qualification of additional components identified in the extent of condition review.
(Scheduled Completion Date - June 30,1998)
Perform an engineering evaluation on the electricalinstallation configuration of HPCI
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position switch 23PNS-LS4 to determine the need to perform a plant modification to either: 1) install a qualified electrical interface device at 23PNS-LS4 to meet EQ '
installation requirements for NAMCO position switches; or 2) electrically isolate 23PNS-LS4 and the HPCI steam line automatic isolation circuitry.
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DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full Environmental Qualification Program compliance will be achieve following completion of plant modification to HPCI System position switch 23PNS-LS4. The modification will be completed prior to plant startup from the fall 1998 Refuel Outage.
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