ML20005F843

Responds to NRC 891201 Ltr Re Violations Noted in Insp Rept 50-333/89-10.Corrective Action:Audits Identified as Not Being Completed within Required Time Period Completed Prior to 891101

ML20005F843
Person / Time
Site:	FitzPatrick
Issue date:	01/05/1990
From:	Fernandez W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JAFP-90-0014, JAFP-90-14, NUDOCS 9001170311
Download: ML20005F843 (8)

Text

inemes A.PilePetdek

-* Nissient Power Plant

• • P;), Box 41

, Lycoming. New York 13093 ,

31$ 342 3640 i

William Femander 11 Resident Manager January 5, 1990 JAFP-90-0014 United States Nuclear Regulatory Commission  ;

Mail Station F1-137 l Washington, D.C. 20555 l i

Attention: Document Control Desk  :

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SUBJECT:

RESPONSE TO NOTICE OF VIOLATION - INSPECTION '

NO. 89-10 (DOCKET 50-332

Reference:

1) USNRC Letter Dated December 1, 1989, Subj ect : Inspection Report No. 50-333/89-10

Enclosures:

1) Response to Notice of Violation (4 pages)

2) Other Items Discussed in Inspection Report 89-10 (1 page) '

Gentlemen This letter provides the Authority's response (Enclosure 1)'to the Notice of Violation transmitted by Reference (1). This refers to the inspection conducted by Messrs.-W. Schmidt and R. Plasse of your office between September 7, 1989 and' October 7, 1989 at the James A. FitzPatrick Nuclear-Power Plant.

The Authority's comments on Open Item 89-10-01 are included in ,

Enclosure (2).

Very t uly yours,

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/ r LIAM FE NANDEZ i

WF:RTLila L Attachment ,

I cc R. Beedle, WPO S. Toth, WPO .

J. Brons, WPO J. Wiggins, NRC Region I  ;

R. Liseno, JAF Document Control. Center ]

WP0 Records Management NRC Resident Inspector, JAF y0 g 9001270311'900105  :

gDR ADOCK 05000333 A h p()4 i i

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ENCLOSURE I NOTICE OF VIOLATION A

" Technical Specification 6.5.2.8 requires that periodic audits of the.following activities be performed: conformance with the operating licenses site personnel. performance, training, and qualifications and the emergency plan and procedures, at 1 cast once per 12 months and the results of corrective actions to resolve deficiencies, at-least once per 6~ months."

" Contrary to the above, audits of the facility activities were not completed in the areas listed above in.the required time periods. Specifically, when identified by a utility group audit on September ;22, 1989, the audits of the above four areas were overdue by up to eight months."

NYPA RESPONSE TO NOTICE OF VIOLATION The Authority agrees with the violation.

1. Reasons for the Violation The reason that'the Technical Specification audits were not performed within the required time periods was failure of management tx> carry out the administrative requirements associated with the scheduling of audits. .In the past, suaervisory personnel were deeply involved in the audit scheduling. As their work load evolved, focus on the audit program was lost. This resulted in the audits not being properly scheduled and completed.

2) Corrective Action Taken and Results Achieved Those audits identified as not being completed within the required time period were completed prior to November 1, 1939,

3) Corrective Action Which Will Be Taken to-Avoid Further

, Violations Audit program procedure, specifically Safety Review Committee Procedure 9 and Quality Assurance Procedure-18.4,

, are being revised to more clearly define requirements for oversight of the Technical Specification required audits.

The changes include the development of a two-year Technical Specification audit schedule and requirements for periodic

-reports to the Safety Review Committee on audit completion-status. The procedures will be closely followed in' future audit scheduling activities.

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'4) The-Date When Full Compliance Will Be Achieved -l 1

a) All overdue audits identified as were completed prior  !

to November 1, 1989. q b) Procedure-Change Notice #1 to Safety Review Committee -

Procedure 9 was issued on October 31, 1989. .This- -!

change incorporated the corrective steps.which will-be l taken to avoid further violations-noted above. 1 l

c) The two-year-Technical Specification audit schedule was'  !

approved on December 28, 1989. .

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- . 1 d) . Quality.-Assurance Procedure 18.4 will be issued prior  !

to January 31,-1990, 1

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ENCLOSURE L NOTICE OF VIOLATION B Technical Specification 6.8.A and Regulatory Guide 1.33 require, in part, that written procedures be implemented for each surveillance testing activity specified by Technical .

Specifications. I Technical Specification Table 4.2-2, 1 tem 6, required ~that the function of the ECCS trip system bus-power monitors be checked monthly. A prerequisite step in-Surveillance Test 2M, which - i tests the function of these monitors, specifies that the residual heat removal system be:in the standby lineup when these relays ,

are tested, l Contrary to the above, on October 5, 1989, the residual heat j

removal system was not in the standby lineup when the ECCS trip '

system bus monitor relays were being tested and a temporary loss of shutdown cooling resulted.

NYPA RESPONSE TO NOTICE OF VIOLATION The Authority agrees with the violation.

1) Reasons for the Violation .

On October 5, 1989 while performing ST-2M, "ECCS Trip  !

Systems Bus Power Monitors Functional Test", the '

prerequisite for RHR system in standby operation per OP-13 was misinterpreted. The wording used in the procedure l resulted in the operator believing that the requisites had l been met. They read "RHR system in standby operation per '

OP-13". The word " operation" led tne operator to believe j

operating in the shutdown cooling mode, a mode of operation i described in OP-13, met the prerequisite called for in ,

ST-2M. j

2) Corrective Action Taken and Results Achieved-9 After the A RHR pump tripped, the operators scopaed the  !

surveillance and reviewed the~ logic drawings. They  !

determined the pump tri? was caused by for the pump suction valve position interloci. The surveillance'was completed satisfactory after shutdown cooling was secured and the RHR system was in a standby lineup. 1

3) Corrective Actions Taken to Avoid Further Violations a) Discussions with all operators have taken place during the weekly Operations Superintendent's shift meeting concerning the need to carefully-follow procedures.and maintain a questioning attitude.

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b) indic ST-2M-'will; prerequisite be " standby : revised to clearly' :means' operation ate that the; standbyDLPCI

lineup. This.will-be. completed:by February 1, 1990.-- .:

i c)- .0ther.similar surveillance tests will-be-reviewedL(an'd  ;

' corrected..if nec'essary)l:tolassure,this same -

phraseology does notiexist theresalso. This review,

will be completedLby Februaryjl, 1990. ,

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ENCLOSURE 2:

NRC OPEN ITEM NRCI-89-10-01 The following information was-requested by the NRC in Inspection Report- 50-333/89-10.

NRC Inspection Report-50-333/89-10 identified one unresolved: item concerning the operability of the A core spray subsystem when-the plant was in the cold condition and CRD mechanism replacement

! (potential to drain the vessel) was being performed on September.

19, 1989. During this time, one of two instrument trip systems for A core spray-pump _ actuation was functional. During this same time period, B core spray system was operable except that:its .)

emergency power source was not available, A RHR was in the shutdown cooling mode and available for manual ECCS actuation.

In addition, both A &-C emergency diesel. generators and.both CRD I pumps were available to support makeup.

The occurrence of having one of two trip channels for A- core -

spray inoperable was identified by one of the Authority's-Shift I Supervisors and subsequently reported to the NRC via 10CFR50.72  !

notification. FitzPatrick's PORC (Plant Operations Review l Committee) then reviewed the' occurrence;and concludedLthat the  !

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Technical Specifications had not been violated. Inspection L Report 50-333/89-10 asked the Authority to detail:the basis for -[

this determination and describe how the Authority complied with  ;

current Technical Specifications _on September 19, 1989.- l

'l Why Technical Specifications Were Not Violated

!. Two Technical Specifications related to the September 18-19 I condition:

l o Table 3.2-2 (" Instrumentation That Initiates or Controls- 1 I

the Core and Containment Cooling Systems" on Page 66) j a

o Specification 3.5.F (" Minimum. Emergency" Core and-Centainment Cooling System Availability on,Page 122) j Table 3.2-2 Item 2 of Table 3.2-2 is reactor vessel. low-low-low water-level which initiates core-spray, LPCI, and the emergency diesel j generators.  ;

4 On September 18, 1989, ATTS (Analog Transmitter Trip System) {

Panel 09-95 was deenergized to perform system modifications. i l This, in turn, rendered both A side (Division I) reactor vessel  ;

_w ater level instrument loops inoperable. The inoperability of the A side instrumentation placed the plant in an LC0' condition  !

l (per Table 3.2-2) since less than two instrument channels were  ;

L operable per trip system. The associated action state 6ent l (Note 1) states:  ;

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"Whenever any ECCS subsystem is required by Specification 3.5 to be operable, there shall be two operable tria systems. From and after the time.it is found that tLie first column cannot be met for one of the trip systems, that tri) system shall be placed in the tripped condition or t.2e reactor _shall-be placed in the cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Since the reactor was already in the cold condition, the associated action was satisfied and the Authority was in full-compliance with this LCO. Consequently, no report was required to satisfy either 10CFR50.72 or 10CFR50.73.-

Specification 3.5.F The second-specification associated with this condition is 3.5.F.

This specification permits "all-LPCI, core spray, and-containment-cooling subsystems" to be inoperable "provided that no work is being done which has the. potential for draining the reactor vessel." Other than the one channel of. instrumentation, LPCI and core spray sub-system were available: therefore, specification-3.5.F was met. To consider that both instrumentation channels are needed-to meet specification 3.5 F due to.the_need to meet j single-failure criteria, also implies that both core spray _and i both LPCI systems would be needed to ensure redundant valves,  ;!

pumps, etc.  !

The FitzPatrick Technical Specifications were written to assure safe' plant operation and primarily concern themselves with power-operation since the potential for and consequences of an accident ,

at power are of primary concern. Although not explicitly stated' in the specifications, many examples of this predication can be identified throughout the Specifications. Like many older.  !

nuclear power plants, this assumption is basic to.the. Technical- ,

Specifications such that, except for 3.5.F,, shutdown conditions I are not clearly addressed. Similar examples can_be found in the 1 specifications for other plants of similar vintage.

l During the installation of modifications.with the potential to 1 drain the vessel, special precautions are taken to minimize the possibility and consequences of a loss of' reactor coolant. These i precautions,-plus the inherently safer condition of the plant'and i the relatively slow coolant loss rate should a leak occur, assure "j that safety is not compromised. The Authority' contends that Technical Specifications were not violated and no. safety hazard existed.

The Authority, like the'NRC, recognizes that Technical 4 Specifications for older plants should clearly and: unambiguously ~i address the shutdown condition. However, any shutdown j specification must be based on a reasonable and justifiable b& sis with full consideration given to-the reduced: potential for and consequences of an accident.

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AUTHORITY ACTIONS TO CLOSE OPEN ITEM-As'noted in the' inspection' report, the Authority has been working 1 on a proposed Technical Specification change to remedy this .

omission.: The new specifications are based.on the NRC's'STS (Standard Technical 1 Specifications) for BWRs with alterations to.

accommodateiFitzPatrick's custom format. The proposed changes are currently being circulated with the Authority for review and approval.. A formal application to amend the Technical Specifications,will be submitted to the NRC by March 31, 1990.

Until the Technical Specifications can be amended,.the Authority-will require both channels of reactor vessel low-low-low water.

level instrumentation to be operable to satisfy Specification 3.5.F.

The Authority is also participating in a BWROG (BWR Owners'- l Group) ad hoc committee to address this and other issues 4 associated with Technical Specifications for shutdown The:

committee hopes to propose generic specifications that address ' >

issues other than'just reactor vessel level instrumentation, f

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