ML20045C485

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-333/93-06.C/As:engineers Involved in Mod Process Reviewed Root Cause Analysis & Mod Package Revised to Clarify Testing Requirements

ML20045C485
Person / Time
Site:	FitzPatrick
Issue date:	06/14/1993
From:	Harry Salmon POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JAFP-93-0338, JAFP-93-338, NUDOCS 9306230179
Download: ML20045C485 (5)

Text

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i James A. FitzPetrick -

o Nuclear Powor Plant '

="= P.O Box 41 Lycoming, New York 13093 315'342-3840

1. > ewWrkPbwer W thon.ty Harry P. Salmon, Jr.-

nesioent ueneger June 14,:1993 JAFP-93-0338 Director, Office of Enforcement U.S. Nuclear Regulatory Commission ATTN: Document Control Desk -

Washington, DC 20555 -

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Reply and Answer to Notice of Violation NRC Inspection Report 50-333/93-06

Dear Sir:

This letter provides the Authority's reply to the Notice of Violation in accordance.

with the provisions of 10 CFR 2.201. The reasons for the violations, the corrective actions that have been taken and the results achieved, the corrective actions to be taken to avoid further violations and the date when full compliance will be achieved for the violations is included in Attachment 1.

If you have any questions, please contact Mr. Mike Colomb.

Very truly yours, x // r

' Harry P.' Salmon, Jr. "

STATE OF NEW YORK COUNTY OF OSWEGO

' Subscribed and sworn to before me thislT" day of b l%5.

TAMMY L DANN 4985563..

Notary Public, State of New York -

Quahfted in OsweCo Coun 4 mmission #pires 8/191 sa w k) s

-Notary Public cc: see next page. 210D -J'. r 9306230179.930614-  ? / 1 l }-

.PDR

.G. :ADOCK 05000333 PDR. - 'Q g --

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  ',    - cc: Regional Administrator                 i U.S. Nuclear Regulatory Commission Region I -

475 Allendale Road King of Prussia, PA 19406 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 - Mr. Brain C. McCabe Project Directorate I-11 Division of Reactor Projects-I/II U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 t 3 l 1 l 2

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       .                                   Esponse to Notice of Violation                                              l Attachment I                                                   ;

Violation , A. Technical Specification 6.8. A states, in part, that written procedures shall be - implemented that meet or exceed the requirements of Section 5 " Facility i Administrative Policies and Procedures" of ANSI 18.7 - 1972. ANSI 18.7 - 1972, Section 5.1.2 states, in part, that procedures shall be followed.  ; . Modification M1-91-004, " Chemical Decontamination - Addition of Permanent  ! Piping and Valve", Installation Procedure No.1, Section 10.0, " Post-installation / Pre-operational Testing", specifies in paragraph 10.1 that all socket type welded fittings that were installed on the 1" diameter branch lines on the recirculation system piping risers will be verified leak-tight during reactor vessel operational pressure testing per surveillance test procedure ST-39H. . Contrary to the above, on September 30,1992, ST-39H was performed, but the manual isolation valves in the ten recirculation riser decontamination connections were not opened to allow pressurization and leak testing of the piping and welds downstream of the manual isolation valves. This is a Severity Level IV Violation. Admission or Denial of the Alleged Violation The Authority agrecs with this violation. The Reason for the Violation Personnel error is the primary cause that modification package M1 l 004, " Chemical Decontamination - Addition of Perinanent Piping and -l Valves", was not clear as to the intended testing requirements. The intent of the responsible engineer was not to leak test the connections -l downstream of the manual isolation valves. This was not clearly communicated in the modification package or the installation procedure. - The installation procedure specified that "all socket type -' l 1 of 3 R l

( + welded fittings" that were installed on the 1" diameter branch lines at the recirculation system piping would be verified leak-tight. The procedure should have stated " perform an in-service leak test of the assembly at full system operating pressure with normal valve lineup during ST-390, i.e., new valves closed". This was the responsible engineers intent, based on plant procedure and the testing performed. Corrective Steps to be Taken to Avoid Further Violation A root cause analysis has been performed on Modification M1-91-004 to identify the cause and corrective action of this violation. The corrective action for this violation includes the following:

1. To have the root cause analysis reviewed by the Engineers involved in the modification process.

2. To review the need for attention to detail with engineers in defining modification test requirements.

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3. The modification package has been revised to clarify the testing requirements.

The Date When Full Compliance Will be Achieved Full compliance will be achieved by August 1,1993. Violation B. 10CFR50.9 requires, in part, that information provided to the Commission by a licensee be complete and accurate in all material respects. Contrary to the above, NYPA provided inaccurate information to the NRC by letter dated March 12, 1993, transmitting Licensee Event Report 93-006, Inoperability of Fire Pumps. The sequence of events, when the electric driven and diesel driven fire pumps were declared inoperable, were in error and in conflict with the February 26,1993 Emergency Notification System chronology and a facsimile transmission made by NYPA, on March 1,1993, concerning this event, i 2 of 3

Admission or Denial of the Alleged Violation

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The Authority agrees with the violation. The Reasons for the Violation Personnel error is the primary cause for the inaccurate information contained in LER-93-006. An error was made by not incorporating the correct chronological data from the operations logs to the LER. The data omitted was the entry made for declaring the pump inoperable. The Corrective Steps Taken to Avoid Further Violations A new procedure, AP-03.04, Information Reporting Requirements was implemented on May 15, 1993. This procedure contains a technical review checklist for LERs. This checklist will be used by the technical reviewer (assigned by the Department Manager (s) responsible for providing the description of the event) to ensure technical accuracy. The technical review checklist includes verifying the appropriate times of the occurrences during the event. A revised LER was issued on May 5,1993, to correct the inaccurate information contained in LER-93-006. The Date When Full Compliance Will be Achieved Full compliance was achieved on May 15, 1993. i 6 3 of 3}}