IR 05000333/1986004

Insp Rept 50-333/86-04 on 860311-0509.Licensee Identified Violation Re Failure to Perform Surveillance Testing within Specified Time.Nrc Notice of Violation Not Issued Because Violation Identified & Corrected Per 10CFR2,App C,Va

ML20206J344
Person / Time
Site:	FitzPatrick
Issue date:	06/23/1986
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206J339	List: IR 05000333/1986004 ML20206J335
References
50-333-86-04, 50-333-86-4, IEIN-86-003, IEIN-86-3, NUDOCS 8606270106
Download: ML20206J344 (14)

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U.S. NUCLEAR' REGULATORY COMMISSION

REGION I

Report N Docket N License N DPR-59 Category C Licensee: Power Authority of the State of New York P.O. Box 41 Lycoming, New York 13093 Facility: J.A. FitzPatrick Nuclear Power Plant Location: Scriba, New York Dates: March 11 - May 9, 1986 Inspectors: A. J. Luptak, Senior Resident Inspector J. R. Stair, Reactor Engineer, DRP Section 2C Approved by:__ , if vyt 6 Lidfille, Chppf, ,Reactor ' Date jects Section DRP Inspection Summary: Inspection on March 11 - May 9, 1986 (Report N /86-04)

Areas Inspected: Routine and reactive inspection during day and backshift hours by one resident inspector and one region based inspector (227 hours0.00263 days <br />0.0631 hours <br />3.753307e-4 weeks <br />8.63735e-5 months <br />) of licensee action on previous inspection findings, licensee event report review, operational safety verification, surveillance observations, maintenance obser-vations, followup on a plant trip, and review of periodic and special report Results: One violation was identified during this inspection period by the licensee. A Notice of Violation was not issued based upon NRC review confir-ming that the violation met the requirements of 10 CFR Part 2 Appendix C, for self-identification and correction. The violation was the failure to perform surveillance testing required by Technical Specifications within the specified time interval (details in paragraph 9).

DCS No PDR ADOCK 05000333 G PDR

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J Events which will require additional followup by regional inspectors are con-taminated tools found outside of the restricted area (paragraph 7) and problems

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with the Environmental Qualification of four valve operators (paragraph 12).

An example of poor maintenance practice and the failure to consider possible consequences of actions were noted following the plant trip (paragraph 11).

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DETAILS Persons Contacted

• R. Baker, Acting Maintenance Superintendent

• R. Converse, Resident Manager W. Fernandez, Superintendent of Power J. Flaherty, Acting Instrument and Control Superintendent

• D. Lindsey, Operations Superintendent

• R. Matthews, Instrument and Control General Supervisor

• E. Mulcahey, Radiological & Environmental Services Superintendent R. Patch, Quality Assurance Superintendent

• D. Simpson, Training Superintendent

• T. Teifke, Security & Safety Superir endent V. Walz, Acting Technical Services Superintendent The inspector also interviewed other licensee per:9nnel during this inspection, including shift supervisors, administratite, operations, health physics, security, instrument and control, maintenance and contractor personne * Denotes those present at the exit intervie . Summary of Plant Activities The plant inspection period began with the plant operating at full powe On March 13, 1986, the plant was shut down to begin a scheduled two week maintenance outage to replace control rod drive mechanisms. A plant startup was conducted on March 28, 1986, and the generator was synchron-ized with the grid on March 31, 1986. A reactor trip occurred on April 4, 198 The plant returned to power operations on April 6, 1986 but was limited to about 55% power because only one reactor feed pump was operable. The plant returned to full power operation on April 8, 1986 and continued at full power throughout the remainder of tne inspection perio . Licensee Action on Previous Inspection Findings (0 pen) UNRESOLVED ITEM (333/84-04-05): In November 1983 United Engineers and Constructors (UE&C) were retained to investigate allegations regard-ing pipe support deficiencies. Based upon UE&C's findings while verifying as-built conditions, the licensee developed a program to inspect all safety related pipe supports against the as-built drawings to identify, evaluate, and correct any deficiencies. Phase I of the program inspected a random sample of 100 supports. With a dedicated work force the majority of the work was completed during the 1985 refueling outage. Based on the deficiencies found in Phase I, the licensee initiated a Phase II inspection for the remaining 1650 supports, in July 1985. Due to funding priorities no evaluations were being conducted by Stone and Webster

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i Engineering Corporation (SWEC) and the program was placed on hold in November 1985 when craft manpower was no longer available. Approximately 50 items were outstanding waiting SWEC evaluation; however, the licensee believed these items did not involve questions which would effect support or system operabilit In February 1986, program funding became available and SWEC reinstituted evaluation of the outstanding item In April,1986, it was determined that pipe support PFSK-2542 on the "B" Core Spray Minimum Flow line was inoperable as a result of discrepancies originally identified on November 7, 1985 when the support was found not welded to the pipe. Based on initial analysis performed by SWEC, the licensee declared the "B" Core Spray System inoperable, entered a seven day Limiting Condition for Operation, and

! repaired the support. After further analysis conducted by SWEC the licensee subsequently determined that the "B" Core Spray System was operable despite the inoperable support condition The lengthy delay in recognizing the inoperable support was due to the failure of the Pipe Support Field Engineer (PSFE) (a contract engineer),

to make an initial operability determination when the deficiency was note Generally, the PSFE would make the determination of support operability;

however in this case he referred this item to SWEC for evaluation. On  !

l November 15, 1985, the PSFE left the site after obtaining a permanent position with another utilit In addition, the Pipe Support Program Manager was not informed by the PSFE of the problem with this support, and no formal review of the support packages was conducted when the PSFE departe Both of these program deficiencies contributed to the delay in the deter-mination of operability. The inspector will continue to follow the licensee's pipe support inspection program and will review the licensee's corrective action to insure similar problems are prevented in the futur . Emergency Notification System Reports The inspector reviewed the following events which were reported to the NRC via the Emergency Notification System as required by 10 CFR 50.72. The review included a determination that the reporting requirements were met, that appropriate corrective actions have been taken, and that the event had been evaluated for possible generic implication The following reports were reviewed:

Event Date Subject March 12, 1986 The High Pressure Coolant Injection System was declared inoperable when a valve failed to operate during surveillance testing. This event was also reported in LER 86-0 . t

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March 15, 1986 Reactor trip occurred in cold shutdown with all rods fully inserted while conducting post work testing. This event was also reported in LER 86-0 March 25, 1986 Reactor trip occurred in cold shutdown with all rods fully inserted due to low vessel leve This event was also reported in LER 86-0 March 25, 1986 The potential failure of four Recirculation loop valves to meet Environmental Qualification require-ments. This event was also reported in LER 86-07 and is discussed in paragraph 1 April 4, 1986 The Reactor Core Isolation Cooling System automati-cally isolated due to spurious area high temperature signal. This event was also reported in LER 86-0 April 4, 1986 Reactor trip during routine Main Turbine Stop Valve testing. This event was also reported in LER 86-10 and is discussed in paragraph 1 . Licensee Event Report (LER) Review The inspector reviewed LERs to verify that the details of tFe events were clearly reported. The inspector determined that reporting requirements had been met, the report was adequate to assess the event, the cause appeared accurate and was supported by details, corrective actions appeared appropriate to correct the cause, the form was complete, and generic applicability to other plants was not in questio LERs 86-01*, 86-02*, 86-03*, 86-04, 86-05, 86-06, 86-07, 86-08, 86-09*

and 86-10* were reviewe *LERs selected for onsite followu LER 86-01 reported the failure to perform monthly surveillance testing within the required frequency on the Average Power Range Monitor flow bias scram circuits. This event was afscussed in paragraph 6 of Inspection N /86-0 LER 86-02 reported the failure to perform a quarterly surveillance test within the required frequency on the Diesel Fire Pump. This event was discussed in paragraph 6 of Inspection No. 50-333/86-0 LER 86-03 reported the failure of the motor operated High Pressure Coolant Injection (HPCI) outside containment steam supply bypass valve (23MOV60)

during surveillance testing. The insulation of the motor windings for 23MOV60 was found to be breaking down, causing a high resistance across

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the commutator. The motor was replaced, tested, and declared operabl Initial investigation indicated manual backseating of the valve to stop a packing leak may have caused the motor failure. However, after an

! Environmental Qualification inspection, performed during the maintenance

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outage, the valve again did not move when the motor was operate Inspection revealed that corrosion caused the manual clutch to stick, such that the motor would not engage the valve. It is believed that the corrosion was caused by steam from the packing leak. After replacing

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corroded parts, cleaning the valve's drive shaft, and retesting satisfac-torily, 23 MOV60 was returned to servic LER 86-04 reported a reactor trip caused by performance of post work testing on the Backup Scram Relays while the plant was in cold shutdown with all rods fully inserte LER 86-05 reported two inadvertant isolations of the Reactor Core Isolation Cooling System (RCIC). The isolations occurred when technicians moved a common wire bundle while troubleshooting a previous spurious high temperature indication on the RCIC Steam Leak Detection System. After i

checking the tightness of the leads associated wi.th these circuits, it was found that movement of the bundle no longer affected the trip units of the RCIC Steam Leak Detection Syste LER 86-06 reported a reactor trip due to low reactor vessel level which occurred while the plant was in cold shutdown with all rods fully inserted. A control room operator was in the process of lowering vessel level when a leak occurred in the feedwater system. While the operator was isolating the feedwater leak from the control room, vessel level reached the low level scram setpoint. The operator immediately secured the lineup for lowering vessel level and level returned to norma LER 86-07 reported the failure of four valve operators to meet Environmental Qualification requirements. Details of this are discussed in paragraph 12.

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LER 86-08 reported the setpoint drift of redundant pressure switche These switches are used in the Reactor Protection System to bypass a Main i'

Steam Line Isolation Valve Closure Trip Signal when the Reactor Mode Switch is not in the Run Mode and reactor pressure is less than 1005 psi LER 86-09 reput ed a late reactor coolant chemistry surveillance during startup. Details of this are discussed in paragraph 9.

i Ler 86-10 reported a reactor trip from 88% power while performing routine turbine valve testing. Details of this event are discussed in paragraph 11.

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6. Operational Safety Verification Control Room Observations Daily, the inspector verified selected plant parameters and equipment availability to ensure compliance with limiting conditions for operation of the plant Technical Specifications. Selected lit annunciators were discussed with control room operators to verify that the reasons for them were understood and corrective action, if required, was being taken. The inspector observed shift turnovers

, bi-weekly to ensure proper control room and shift manning. The t

inspector directly observed the operations listed below to ensure adherence to approved procedures:

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Plant shutdown on March 13, 198 Plant startup on March 28, 198 Routine power operation Issuance of RWP's and Work Requests / Event /

Deficiency form During this inspection period the inspector reviewed the licensee's actions on control room annunciators which were in a continuous alarming condition. The inspector noted several of these have been in this condition over an extended period of time, and the cause of the annunciators was of little or no safety significance. In ad-dition there were other operable annunciators not in a condition which

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would be indicative of problems with the equipment associated with the continuously alarming annunciators. Recently the licensee management has placed more emphasis on reducing the number of annun-ciators in the alarm conditio Several have been cleared and modifications requested to elminate others. The inspector will continue to monitor the licensee progress in eliminating continuously lit control room annunciator No violations were identifie Shift Logs and Operating Records Selected shift logs and operating records were reviewed to obtain information on plant problems and operations, detect changes and trends in performance, detect possible conflicts with Technical Specifications or regulatory requirements, determine that records are l being maintained and reviewed as required, and assess the effective- ]

ness of the communications provided by the log .

No violations were icentifie !

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6 Plant Tours During the inspection period, the inspector made observations and conducted tours of the plan During the plant tours, the inspector conducted a visual inspection of selected piping between containment and the isolation valves for leakage or leakage paths. This included verification that manual valves were shut, capped and locked when required and that motor operated valves were not mechanically blocked. The inspect ,r also checked fire protection, housekeeping /

cleanliness, radiation protection, and physical security conditions to ensure compliance with plant procedures and regulatory require-ment No violations were identifie Tagout Verification The inspector verified that the following safety-related protective tagout records (PTR's) were proper by observing the positions of breakers, switches and/or valves:

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PTR 860306 on High Pressure Coolant Injection Syste PTR 860382 on "A" and "C" Emergency Diesel Generator System PTR 860549 on "B" Core Spray Syste PTR 860640 on "B" Main Steam Leak Collection Syste No violations were identifie Emergency System Operability The inspector verified operability of the following systems by ensuring that each accessible valve in the primary flow path was in the correct position, by confirming that power supplies and breakers were properly aligned for components that must activate upon an initiation signal, and by visual inspection of the major components for leakage and other conditions which might prevent fulfillment of their functional requirements:

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High Pressure Coolant Injection Syste "A" Core Spray Syste .,

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Emergency Diesel Generator Fuel Oil and Air Start System During the two week maintenance outage, the inspector also visually inspected components which are normally inaccessible, verified the positions of normally inaccessible valves for various

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systems prior to startup and verified proper valve alignment for the shutdown condition, j No violations were identified.

< Contaminated Tools Found Outside of Restricted Area l On March 11, 1986 the licensee found contamination levels slightly above their release limit of 100 counts per minute above background on a tool l which was being taken offsite. This prompted a survey of two individuals

lockers which are also outside of the restricted area. Four additional

items were found with contamination levels ranging from 200 to 2000 counts j per minute t.y direct frisk. The licensee issued a memorandum to all i

personnel establishing a locker policy. All tools were removed from personal lockers and returned to the restricted area. A radiation survey

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will be conducted of each employees personal locker. The licensees corrective actions will be reviewed during a future inspection.

' Surveillance Observations The inspector observed portions of the surveillance procedures listed below to verify that the test instrumentation was properly calibrated,  ;

approved procedures were used, the work was performed by qualified '

l personnel, limiting conditions for operation were met, and the system was j correctly restored following the testing:

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F-ST-4E, High Pressure Coolant Injection (HPCI) Subsystem Logic l System Functional Test, Revision 20, dated June 19, 1985, performed i March 13, 1986.

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F-ST-4B, HPCI Flow Rate / Pump Operability / Valve Operability Tests,

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Revision 22, dated December 27, 1985, performed March 28, 198 j --

F-ST-20K, Control Rod Exercise / Venting, Revision 3, dated August 17,

{ 1984, performed March 18, 198 RAP 7.3.10, Control Rod Scram Time Evaluation, Revision 13, dated

{ February 21, 1986, performed March 31, 1986.

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F-ST-9B, Emergency Diesel Generator Full Load Test and Emergency i

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Service Water Pump Operability Test, Revision 21, dated November 13, 1985 performed May 8, 198 j

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The inspector also witnessed all aspects of the following surveillance j test to verify that the surveillance procedure conformed to technical l specification requirements and had been properly approved, limiting conditions for operation for removing equipment from service were met,

. testing was performed by qualified personnel, test results met i

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technical specification requirements, the surveillance test documentation was reviewed, and equipment was properly restored to service following the tes F-ST-3A, Core Spray Flow Rate / Valve Operability Test, Revision 21, dated February 20, 1986, performed April 17, 1986.

No violations were identifie . Followup on Missed Surveillance Test On March 27, 1986 a reactor startup was begun at 11:45 p Technical Specification 4.6.C.1.c requires a reactor coolant sample be analyzed for gross gamma activity prior to startup and at four hour intervals during a startu The sample required prior to startup was taken at 11:30 pm on March 27, 1986. However, during the reactor startup, the chemistry technician encountered difficulties in establishing sample flow. In addition, he was unsure about the exact sample requirement. Approximately 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> af ter the start-up began, still being unable to establish sufficient sample flow, the technician reviewed Process Surveillance l Frocedure #1 (PSP-1), Reactor Water Sampling and Analysis, to determine when the sample must be taken. Inadequate wording for the sample requirement during a startup led the technician to believe a sample was not required for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after startup. Technicians continued to check and readjust sample flow until 6:00 am on March 28, 1986, when it was found that flow had stablized and a sample was drawn. A review of the evening activities by a senior chemistry technician upon reporting to work at 6:30 am on March 28, 1986 revealed that the sample had been obtained 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 15 minutes late. The chemistry supervisor was immediately notified and steps were taken to ensure timely samples were taken for the remainder of the startu The cause of the late sample was technician error. A poorly worded procedure contributed to this error. The licensee's corrective actions include issuing a memorandum to all Radiological and Ervironmental Services Department personnel to emphasize compliance with sampling schedules and guidance to ensure sampling requirements are met, revising PSP-1 and other procedures which contain Technical Specification requirements to clarify the sample frequency, and a change of Operating Procedure 65, "Startup and Shutdown Procedure," to require notification of PES by operations that a reactor startup is being commenced and to begin four hour samplin l A review of gross gamma activity analysis performed prior to the startup and during the startup indicated there was no safety significance as a result of the late sample. The inspector also reviewed chemistry records from the past 10 reactor startups verifying sampling requirements were l me The failure to analyze reactor coolant for gross gamma activity l at 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> intervals during a startup is a violation of TS 4.6.C. As provided for by 10 CFR Part 2 Appendix C, V.A., a Notice of Violation is not being issued for this event in that: it was properly identified by the '

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licensee; it was reported; it was of minor safety significance; corrective actions to prevent recurrence have and are being taken; and, this was not a violation that could reasonably be expected to have been prevented by the licensee's corrective actions for a previous violation since the missed surveillance tests described in LERs 86-01 and 86-02 mentioned in paragraph 5 were only recently identified as a violation in Insoection Report 50-333/86-01 dated April 9, 198 . Maintenance Observations The inspector observed portions of various safety-related maintenance activities to determine that redundant components were operable, that these activities did not violate the limiting conditions for operation, that required administrative approvals and tagouts were obtained prior to initiating the work, that approved procedures were used or the activity was within the " skills of the trade," that appropriate radiological controls were properly implemented, that ignition / fire prevention controls were properly implemented, and that equipment was properly tested prior to returning it to service, During this inspection period, the following activities were observed:

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WR 03/41009, disassemble, inspect, and rebuild Control Rod Drive S/N 785 WR 03/41010, disassemble, inspect, and rebuild Control Rod Drive S/N 829 WR 02/238016, replacement of Automatic Depressurization System HFA relay WR 02-3/32724, Analog Transmitter Trip System termination replacemen WR 07/41773, repair "D" Source Range Monito WR 10/42756, repair and calibrate "B" Low Pressure Coolant Injection keep full pressure indicato PMWR 29/03031, preventive maintenance on the limitorque operator for the Main Steam Leak Collection Master Isolation Valv No violations were identifie . Followup on Plant Trip At 9:25 pm on April 4, 1986, the reactor tripped from 88% power while conducting a routine surveillance test F-ST-1E, " Main Turbine Stop Valve

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Limit Switch Instrument Functional Test." During the performance of F-ST-1E, two stop valves are simultaneously shut to less than 90% open to ensure a half trip signal can be generated. A full trip signal is generated when three stop valves are less than 90% open. The trip occurred when a #4 Turbine Stop Valve (TSV-4) erroneously indicated less than 90% open while testing TSV-1 and TSV- Although the Sequence of Events printout following the trip indicated an erroneous TSV-4 position caused the trip, the licensee's troubleshooting efforts could not reproduce the problem. The limit switch and the associated relays were replaced as a precautionary measure. A plant startup was commenced and the reactor taken critical at 11:45 pm on April 5, 1986. To ensure satisfactory operation, the licensee attempted to

, perform F-ST-1E at 22% power'. The relays for TSV-4 were found de-energized, indicating TSV-4 was less than 90% open. A calibration check of TSV-4 limit switch showed that the stroke of TSV-4 had decreased by cm from measurements taken in the cold condition. This shortened stroke prevented the limit switch from resetting when the valve was fully opened in a hot condition. The limit switch was reset and TSV-4 stroked several times to ensure proper operation. The plant startup then continue The inspector reviewed the process computer alarm printout, the post trip log, various chart recorders, and the completed data sheet for procedure No 00S0 23, " Post Trip Evaluation." Based on this review, the inspector determined that the operator actions in response to the event were proper and in accordance with approved procedures, the plant responded as designed, and the required notifications, including an Emergency Notification System call were mad The inspector questioned the licensee as to whether the consequences of the valve stroke change had been considered. A concern was the possibility that the limit switch would be out of Technical Specifications tolerance if the valve stroke returned to 19.1 cm during plant operation The licensee marked the valve and began verifying that its position had not changed on a once per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> basi A review of limit switch calibration data revealed that the valve stroke had historically been approximately 18 c While shutdown on August 11, 1985, after the limit switch was replaced due to broken internal parts, the stroke was found to be 19.2 cm. Prior to performing F-ST-1E on August 30, 1985, an operator noted that the relays for TSV-4 were de-energize The limit switch was recalibrated on August 31, 1985 in the hot condition with a valve stroke of 18.1 cm. On March 24, 1986, during routine l calibration of the limit switch in the cold condition, the valve stroke was found to be 19.1 c Following the trip on April 4, 1985, the stroke was found to be 19.1 cm in the cold condition; during the startup when the relays were found to be de-energized, the valve stroke was 18.0 cm in the hot conditio _ _ _

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However, this information concerning recent limit switch problems and the consistent change in valve stroke from cold to hot conditions was not recognized until several days following the trip and subsequent restar Although the licensee conducted extensive troubleshooting initially following the trip, the failure to review recent history of the suspect equipment is considered a poor maintenance practice.

Subsequent analysis of the trip was conducted by a site engineer and a corporate engineer as part of the post trip review process. Several possible causes for the iimit switch problem were given and will be investigated during the next available outage. The inspector will review the results of this investigation during a future inspection (333/86-04-01).

1 Failure to Meet Valve Operator Environmental Qualification Requirements During a scheduled plant outage the licensee inspected limitorque valve operators as a result of NRC I&E Information Notice 86-0 In addition to the wiring inspection, the licensee inspected other features of the operators to ensure they meet appropriate Environmental Qualification (EQ) requirements. On March 23, 1986, they discovered that the recirculation systems discharge and discharge bypass valves (total of four) contained torque switches and limit switches whose insulation did not meet primary containment environmental requirements. Further review by the licensee revealed discrepancies in the EQ report which indicated that an incomplete basis was given for establishing the qualification of the operators in question. Test reports referred to in the EQ documentation did not provide adequate basis for qualification of the actuators to DOR guidelines in a containment Loss of Coolant Accident environment. Upon discovery, the licensee replaced all four operators with operators fully qualified to NUREG 0588 requirements. Additional corrective actions by the licensee involved investigation of the documentation for the remaining operators inside Primary Containment and the Steam Tunnel, including an additional walkdown to verify nameplate data, and a review of outside containment operators. No additional discrepancies were found. This item is unresolved pending inspection of the Environmental Qualification program. (333/86-04-02)

13. Review of Periodic and Special Reports Upon receipt, the inspector reviewed periodic and special reports. The review included the following: inclusion of information required by the NRC; test results and/or supporting information consistent with design predictions and performance specifications; planned corrective action for resolution of pr,blems, and reportability and validity of report infor-mation. The following periodic reports were reviewed:

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February 1986 Operating Status Report, dated March 10, 198 March 1986 Operating Status Report, dated April 10, 198 April 1986 Operating Status Report, dat.ed May 8, 198 . 'Jnresolved Items l

Unresolved items are matters about which more information is required in '

order to ascertain whether they are acceptable items, violations or deviations. The unresolved item identified during this inspection is discussed in paragraph 12, 1 Exit Interview At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspection scope and findings. On May 13, 1986, the inspector met with licensee represen-tatives (denoted in paragraph 1) and summarized the scope and findings of the inspection as they are described in this repor Based on the NRC Region I review of this report and discussions held with licensee representatives during the exit meeting, it was determined that this repart does not contain information subject to 10 CFR 2.790 restrictiens.

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