View source for JAFP-96-0474, Responds to NRC Re Violations Noted in Insp Rept 50-333/96-06.Corrective Action:Training on Procedure Changes Was Conducted with Plant Staff

{{Adams
| number = ML20135B936
| issue date = 11/27/1996
| title = Responds to NRC Re Violations Noted in Insp Rept 50-333/96-06.Corrective Action:Training on Procedure Changes Was Conducted with Plant Staff
| author name = Colomb M
| author affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
| addressee name = Fitzpatrick J
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000333
| license number = 
| contact person = 
| document report number = JAFP-96-0474, JAFP-96-474, NUDOCS 9612060107
| title reference date = 10-23-1996
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 7
}}

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J:.mes A. FitzP; trick
     -          Nuclear Pow:r Plint P.O. Box 41 Lycoming, New York 13093 315-342 3840 A NewYo.rkPower                                                                         uicn   ,,s. c oio m ,
l      & Authonty                                                                             Piant uanager l        November 27, 1996 JAFP-96-0474 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.C. 20555

==SUBJECT:==
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333                                                             '
Reply to Notice of Violation NRC Inspection Report 50-333/96-06                                             -
Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Notice of Violation the Authority submits a response to the notice transmitted by your {{letter dated|date=October 23, 1996|text=letter dated October 23,1996}}. Your letter refers to the results of the integrated inspection completed at the James A.
FitzPatrick Nuclear Power Plant on September 28,1996.
Attachment I provides the description of the violations, reason for the violations, the                            l corrective actions that have been taken and the results achieved, and the date of full                             l compliance.
1 Attachnient 11 provides the summary of commitments.                                                                '
If you have any question, please contact Mr. Richard Plasse at (315) 349-6793.                                     1 Very truly yours, MICHAEL J. COLOMB S EDI              y 1
STATE OF NEW YORK MJC:GB:las                                                 COUNTY OF OSWEGO Attachments                                                Subscribed and sworn to before me l                                                                  this ??     day of A'w,Lc 1996 l       cc:      next page (I W fL/&
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9612060107 961127                                                                f'. ''"
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cc:   Rrgion:1 Administr:: tor l                       U.S.' Nucinr Rigulatory Commission                                                                                         l 475 Allendale Road                                                                                                        i King of Prussia, PA 19406                                                                                                  i Office of the Resident inspector                                                                                           ,
U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 4
Ms. K. Cotton, Acting Project Manager                                                                                  -
Project Directorate 1-1 i
Division of Reactor Projects-l/ll                                                                                          !
U.S. Nuclear Regulatory Commission                                                                                       :'
Mail Stop 14 B2 Washington, DC 20555 Attachments:
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: l.                  Reply to Notice of Violation'                                                                                1 II.                 Summary of Commitments l
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Attichmint I ta JAFP-96-0474 Riply to N:tice of Violation 96-06 VIOLATION A.      Technical Specification 6.8.(A)1 requires that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5 of American National Standards Institute (ANSI) 18.7-1972 " Facility Administrative Policies and Procedures."
Section 5.1.2 of ANSI 18.7-1972 states in part, that procedures shall be followed, and the requirements for use of procedures shall be prescribed in writing.
1 Contrary to the above, on September 16,1996, during work associated with WR l
96-02875 00, to perform calibration of 71-59N-1UPRN05, two instances occurred           ~
where procedures were not followed and the failure to follow these procedures resulted in a reactor trip. The following examples were cited:
I (1) Administrative Procedure (AP) 10.03, Work Package Planning, step 8.1.5 states        l where accessible, perform a walkdown of the work site to obtain an understanding of the specific neects and location of the work environment. However, failure to         l adequately walkdown the work associated with WR 96-02875-00, to perform                  l calibration of 71-59N-1UPRN05, was not performed with adequate detail to identify the high risk involved with performing the maintenance with the plant at power.
(2) Instrument Maintenance Procedure IMP-G20, Generic Troubleshooting and Maintenance Procedure, states, that prior to disconnecting wire,a, ensure any           i adverse affects on plant equipment operation or operational status have been             !
discussed with applicable Control Room Operator (s) and Shift Manager. However,-
during the calibration of 71-59N-1UPRN05, when the technician determined that the work had the potential to adversely affect the operation of the plant, he failed to notify control room operators or the shift manager.
This is a Severity Level IV Violation (Supplement 1).
ADMISSION OR DENIAL _OF THE ALLEGED VIOLATION The Authority agrees with this violation.
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AttrchmInt I t3 JAFP-96-0470 Reply to Notice of Violation 96-06 REASONS FOR THE VIOLATION The cause for this violation was personnel error. The performance factors leading to these errors were:
* Inadequate work organization and planning.
The individual in the Central Planning Department assigned responsibility for preparing the work package did not perform an adequate evaluation and walkdown of the work activity prior to releasing the work to the field. This resulted in: (1) the failure of the work package to identify the proximity of sensitive energized equipment; and (2) the failure of the work package to identify work steps with high risks and potential impact on plant operation;
* Ineffective worker practices.
The Instrument and Control (l&C) lead technician assigned responsibility for work associated with calibration of the relay, upon commencing the work, was confronted with an unexpected electrical termination configuration. He also recognized and communicated to another technician that the work package did not contain reference to the potential high risk associated with the work evolution.
However, upon identifying these conditions: (1) the lead technician failed to stop work, question the adequacy of the work plan and report the deficient work package condition to supervision; and (2) both technicians failed to properly protect adjacent energized equipment from accidental shorting and grounding prior to commencing the work activity. Had the adequacy of the work plan been                     ,
challenged, the work would have been either rescheduled during a plant outage to         I reduce plant impact or the work package would have been revised to specify precautions to be taken when working in close proximity to energized equipment, i
I CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
* The procedures which govern the work control, work package planning and the rolling work schedule have been revised to: (1) strengthen the process for identifying plant work with the potential to have an impact on plant operations; and (2) exclude risk significant work from the minor maintenance process.
* Instrument Maintenance Procedure IMP-G20 was revised to add steps to require             I preventive measures be taken to protect against accidental shorting or grounding of      l lifted leads and jumpers when performing maintenance or testing activities.
* Training on the procedure changes was conducted with the plant staff.
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Attichm:nt i 13 JAFP-96-0470 R ply ts Notice of Violation 96-06 CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont)
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* The persons responsible for the development of the work package and the calibration of the relay have been counseled with respect to their performance, management expectations regarding the need for pre-job walkdowns of work packages, the need to maintain a questioning attitude, precautions to be taken when working on or near energized circuits, and the importance of stopping work and communicating with supervision when confronted with unexpected work conditions.
e       Following this event, a training session was conducted for the Instrument and Controls Department to review lessons learned from this incident.
e       Following this event, special " stand-down" meetings were held with plant staff to discuss the circumstances associated with the event. Additionally, a training package was prepared and presented to department personnel. The package outlined the basic causes and operational significance of the event. The purpose of
:                  this package was to reinforce management's expectations regarding the need to identify and appropriately control risk.
RESULTS ACHIEVED The Power Authority believes the corrective actions taken were effective in preventing recurrence. A heightened awareness of the issues associated with this violation has been achieved. The Authority will continue to reinforce the importance of pre-job preparation j         activities and emphasize the necessity to identify, communicate and appropriately control high risk evolutions.
CORRECTIVE ACTIONS TO BE TAKEN
;         A training module is under developrnent to improve worker awareness and enhance work i          practices when working on or near energized circuits. The module subject matter will include increasing worker awareness of potential risk (s) and plant impact of tasks being 1          performed, protective measures for tools to avoid electrical shorting, protecting lifted leads / jumpers from shorting / grounding, and electrical protection of adjacent equipment.
The module will be required training for l&C, Electrical Maintenance and Operations Department personnel. Scheduled completion date for this training is March 31,1997.
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Attschm:nt I t2 JAFP-96-0474 R: ply to N:tica cf Violatirn 96-06 DATE WHEN FULL COMPLIANCE WAS ACHIEVED Management expectations for a successful work control program have been and continue to be reinforced. Full compliance was achieved on September 20,1996 following completion of departmental " stand-down" meetings.
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Att chm:nt il t3 JAFP-96-0474 Summary of Commitments Number                          Commitment                     Due Date JAFP-96-0474-01 A training module is under development to          03/31/97 improve worker awareness and enhance work practices when working on or near energized circuits. The module subject matter will include: increasing worker awareness of potential risk (s) and plant impact of tasks being performed; protective measures for tools to avoid electrical shorting; protecting lifted leads / jumpers from shorting / grounding; and electrical protection of adjacent equipment.
This module will be required training for l&C, Electrical Maintenance and Operations Department personnel.
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