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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M1851999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates JPN-99-035, Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 11999-10-15015 October 1999 Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 1 JPN-99-034, Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping1999-10-13013 October 1999 Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping JPN-99-033, Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon1999-10-0808 October 1999 Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon JPN-99-030, Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days1999-09-29029 September 1999 Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days JPN-99-032, Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request1999-09-29029 September 1999 Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request ML20212F8341999-09-22022 September 1999 Forwards Insp Rept 50-333/99-07 on 990718-0828.No Violations Noted JAFP-99-0262, Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl1999-09-16016 September 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl ML20212A8341999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20212A6951999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics 05000333/LER-1998-015, Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete1999-09-0808 September 1999 Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete ML20211N4301999-09-0808 September 1999 Discusses Proposed Meeting to Discuss Kaowool Fire Barriers. Staff Requesting That Affected Licensees Take Issue on Voluntary Initative & Propose Approach for Resolving Issues JAFP-99-0258, Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld1999-09-0808 September 1999 Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld JPN-99-028, Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity1999-08-30030 August 1999 Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity JAFP-99-0247, Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-08-26026 August 1999 Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0245, Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 19991999-08-19019 August 1999 Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 1999 ML20210U2621999-08-12012 August 1999 Forwards Insp Rept 50-333/99-06 on 990601-0717.No Violations Noted JPN-99-025, Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams1999-08-0505 August 1999 Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams JPN-99-026, Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds1999-08-0505 August 1999 Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds ML20216D9421999-07-28028 July 1999 Forwards Safety Evaluation Granting Requests for Relief from Requirements of ASME Code,Section XI for Second 10-year ISI Interval for James a FitzPatrick NPP JAFP-99-0229, Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1)1999-07-22022 July 1999 Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1) JAFP-99-0228, Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal1999-07-21021 July 1999 Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal ML20210A7001999-07-16016 July 1999 Forwards Request for Addl Info to Supplement Response Provided for GL 97-05, Steam Generator Tube Insp Techniques JAFP-99-0208, Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl1999-07-14014 July 1999 Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl ML20209D5511999-07-0606 July 1999 Informs That as Result of NRC Review of Licensee Response to GL 92-01,rev 1,suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2 ML20210C9031999-06-30030 June 1999 Summarizes Impact of Changes & Errors in Methodology Used by GE to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.Summary of Changes & Errors Provided in Attached Table JPN-99-021, Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend1999-06-22022 June 1999 Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend JPN-99-020, Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept1999-06-21021 June 1999 Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept ML20196G2981999-06-18018 June 1999 Forwards Insp Rept 50-333/99-04 on 990412 to 0529.Violations Being Treated as non-cited Violations ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First JPN-99-019, Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant1999-06-15015 June 1999 Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant ML20196L1451999-06-0707 June 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Ss Bajwa Will Be Section Chief for Ja Fitzpatrick & Indian Point NPPs JPN-99-018, Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1)1999-06-0101 June 1999 Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1) ML20207D9191999-05-27027 May 1999 Informs That on 990521 NRC Staff Held Planning Meeting to Identify Insp Activities at Facility Over Next Six Months JAFP-99-0171, Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr1999-05-20020 May 1999 Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr JPN-99-016, Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl1999-05-19019 May 1999 Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl ML20207A6751999-05-17017 May 1999 Forwards RAI Re 960626 Submittal & Suppl Related to IPEEEs for Plant.Licensee Committed to Revise Plant Fire IPEEE to Reflect Issues Associated with EPRI Fire PRA Implementation Guide within 120 Days of Issues Resolution JAFP-99-0168, Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls1999-05-13013 May 1999 Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls ML20206N0721999-05-11011 May 1999 Forwards Insp Rept 50-333/99-03 on 990301-0411.Four Violations of NRC Requirements Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy JAFP-99-0160, Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 41999-04-30030 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 4 ML20206C8551999-04-27027 April 1999 Informs That Util 990406 Submittal, Licensing Rept for Reracking of Ja FitzPatrick Spent Fuel Pool,Rev 7, Will Be Marked as Proprietary & Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP JPN-99-012, Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached1999-04-16016 April 1999 Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached ML20205P4641999-04-15015 April 1999 Forwards for Review & Comment Draft Info Notice That Describes Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station Unit 2,Arkansas Nuclear One Unit 2 & Ja Fitzpatrick NPP ML20205P1991999-04-0909 April 1999 Discusses 990224 PPR & Forwards Plant Issues Matrix & Insp Plan.Advises of Planned Insp Effort Resulting from Plant PPR Review JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick JAFP-99-0127, Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld1999-04-0808 April 1999 Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld JAFP-99-0124, Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) ML20205M8941999-04-0707 April 1999 Forwards Rev 21 to App C of JAFNPP Emergency Plan & Rev 1 to EAP-32, Recovery Support Group Manager JAFP-99-0125, Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARJPN-99-035, Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 11999-10-15015 October 1999 Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 1 JPN-99-034, Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping1999-10-13013 October 1999 Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping JPN-99-033, Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon1999-10-0808 October 1999 Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon JPN-99-030, Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days1999-09-29029 September 1999 Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days JPN-99-032, Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request1999-09-29029 September 1999 Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request JAFP-99-0262, Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl1999-09-16016 September 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl JAFP-99-0258, Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld1999-09-0808 September 1999 Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld 05000333/LER-1998-015, Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete1999-09-0808 September 1999 Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete JPN-99-028, Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity1999-08-30030 August 1999 Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity JAFP-99-0247, Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-08-26026 August 1999 Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0245, Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 19991999-08-19019 August 1999 Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 1999 JPN-99-025, Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams1999-08-0505 August 1999 Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams JPN-99-026, Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds1999-08-0505 August 1999 Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds JAFP-99-0229, Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1)1999-07-22022 July 1999 Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1) JAFP-99-0228, Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal1999-07-21021 July 1999 Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal JAFP-99-0208, Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl1999-07-14014 July 1999 Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl ML20210C9031999-06-30030 June 1999 Summarizes Impact of Changes & Errors in Methodology Used by GE to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.Summary of Changes & Errors Provided in Attached Table JPN-99-021, Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend1999-06-22022 June 1999 Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend JPN-99-020, Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept1999-06-21021 June 1999 Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept JPN-99-019, Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant1999-06-15015 June 1999 Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant JPN-99-018, Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1)1999-06-0101 June 1999 Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1) JAFP-99-0171, Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr1999-05-20020 May 1999 Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr JPN-99-016, Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl1999-05-19019 May 1999 Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl JAFP-99-0168, Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls1999-05-13013 May 1999 Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls JAFP-99-0160, Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 41999-04-30030 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 4 ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP JPN-99-012, Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached1999-04-16016 April 1999 Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick JAFP-99-0127, Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld1999-04-0808 April 1999 Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld JAFP-99-0124, Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) JAFP-99-0125, Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) ML20205M8941999-04-0707 April 1999 Forwards Rev 21 to App C of JAFNPP Emergency Plan & Rev 1 to EAP-32, Recovery Support Group Manager JPN-99-011, Forwards Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will Delegate Responsibilities to Another Staff Member,In Writing1999-04-0505 April 1999 Forwards Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will Delegate Responsibilities to Another Staff Member,In Writing ML20205G4111999-03-31031 March 1999 Forwards Rev 7 to JAFNPP EP App J & Rev 6,pages 7 & 8 to EAP-5.3 05000333/LER-1999-001, Forwards LER 99-001-01 Re Incorrect EDG line-up During Fire Placing Plant in Outside Design Basis.Suppl Contains Results of Completed Root Cause Evaluations & Subsequent Corrective Actions Taken.Rept Contains No Commitments1999-03-31031 March 1999 Forwards LER 99-001-01 Re Incorrect EDG line-up During Fire Placing Plant in Outside Design Basis.Suppl Contains Results of Completed Root Cause Evaluations & Subsequent Corrective Actions Taken.Rept Contains No Commitments JPN-99-008, Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl1999-03-31031 March 1999 Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl JPN-99-010, Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP1999-03-31031 March 1999 Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP JAFP-99-0114, Requests That License OP-11037,for Bs Brooks,Be re-issued Without Restriction for Corrective Lenses.Nrc Form 369,encl. Without Encl1999-03-29029 March 1999 Requests That License OP-11037,for Bs Brooks,Be re-issued Without Restriction for Corrective Lenses.Nrc Form 369,encl. Without Encl JAFP-99-0112, Informs of Util Determination That Listed Individuals No Longer Need to Maintain Operating License for Ja FitzPatrick Nuclear Plant.Termination of Listed Licenses,Requested1999-03-29029 March 1999 Informs of Util Determination That Listed Individuals No Longer Need to Maintain Operating License for Ja FitzPatrick Nuclear Plant.Termination of Listed Licenses,Requested JAFP-99-0097, Forwards JAFNPP Referenced Simulation Facility Four Year Performance Testing Rept, Containing Description of Performance Testing Completed During Past Four Years & Description of Testing Scheduled During Next Four Years1999-03-17017 March 1999 Forwards JAFNPP Referenced Simulation Facility Four Year Performance Testing Rept, Containing Description of Performance Testing Completed During Past Four Years & Description of Testing Scheduled During Next Four Years ML20204B6241999-03-17017 March 1999 Forwards Plant Referenced Simulation Facility Four Year Performance Testing Rept, Per 10CFR55.45(b)ii 05000333/LER-1999-003, Forwards LER 99-003-00,per 10CFR50.73(a)(2)(i)(B).One New Commitment Is Contained in Rept1999-03-16016 March 1999 Forwards LER 99-003-00,per 10CFR50.73(a)(2)(i)(B).One New Commitment Is Contained in Rept ML20204C7371999-03-15015 March 1999 Forwards Revised EP Coversheets for Sections to Vol 1 & Rev 26,Vol 3 to EPIP SAP-10, Meteorological Monitoring Sys Surveillance JAFP-99-0085, Submits in-vessel Visual Insp Summary Rept for RFO 13 for Ja FitzPatrick Nuclear Power Plant.All Relevant Indications Recorded During Insp Were Satisfactorily Dispositioned IAW Util Internal C/A Tracking Sys & Were Found Acceptable1999-03-0808 March 1999 Submits in-vessel Visual Insp Summary Rept for RFO 13 for Ja FitzPatrick Nuclear Power Plant.All Relevant Indications Recorded During Insp Were Satisfactorily Dispositioned IAW Util Internal C/A Tracking Sys & Were Found Acceptable ML20207J3201999-03-0505 March 1999 Forwards Form NRC-369,requesting That Restriction for Corrective Lenses Be Placed on Current License SOP-10089-3, for Ks Allen.Encl Withheld Per 10CFR2.790(a)(6).Without Encl JAFP-99-0073, Submits Annual Rept on SRV Challenges & Failures,Per Plant TS 6.9.A.2.b.No Challenges to SRVs from Automatic Control Circuits or from RCS Pressure Transients,Occurred.Ltr Contains No New Commitments1999-02-26026 February 1999 Submits Annual Rept on SRV Challenges & Failures,Per Plant TS 6.9.A.2.b.No Challenges to SRVs from Automatic Control Circuits or from RCS Pressure Transients,Occurred.Ltr Contains No New Commitments JAFP-99-0071, Forwards Semi-Annual Radioactive Effluent Release Rept for Period of 980701-1231. Format Used for Effluent Data Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-02-25025 February 1999 Forwards Semi-Annual Radioactive Effluent Release Rept for Period of 980701-1231. Format Used for Effluent Data Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0068, Forwards Form NRC-5 Equivalent Records of All Individuals Monitored at JAFNPP from 980101-1231 on Electronic Media, Per 10CFR20.2206(b) & App a of NRC Reg Guide 8.7, Instruction for Recording & Reporting..1999-02-22022 February 1999 Forwards Form NRC-5 Equivalent Records of All Individuals Monitored at JAFNPP from 980101-1231 on Electronic Media, Per 10CFR20.2206(b) & App a of NRC Reg Guide 8.7, Instruction for Recording & Reporting.. JAFP-99-0019, Informs of Licensee Intent to Upgrade ERDS at Ja FitzPatrick in Preparation for Year 2000 (Y2K) Readiness,Per GL 98-01. Encl Contains Brief Summary of Proposed Changes to ERDS1999-01-25025 January 1999 Informs of Licensee Intent to Upgrade ERDS at Ja FitzPatrick in Preparation for Year 2000 (Y2K) Readiness,Per GL 98-01. Encl Contains Brief Summary of Proposed Changes to ERDS JAFP-99-0012, Documents Util Position Re Methodology for LPRM Calibr During Reactor Operation Using Traversing In-core Probe Sys1999-01-18018 January 1999 Documents Util Position Re Methodology for LPRM Calibr During Reactor Operation Using Traversing In-core Probe Sys 1999-09-08
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Text
- J mes A. FitzP; trick Nuctnr Pow:r Pl:nt 268 Lake Road P.O. Box 41 Lycoming, New York 13093 315 342-3840 4 NewYo.rkPower ,cno ,, 3. c o,, , ,
4# Authonty sne exec.e omcer 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 Inteorated InSDection R_e_g. cst 50-333/97-08
Reference:
- 1. JAFP-98-0074, Reply to Notice of Violation, NRC Integrated Inspection Report 50-333/97-08, dated February 25,1998
Dear Sir:
In accordance with the provisions of 10 CFR 2.201, Notice of Violation, the New York 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 A. FitzPatrick Nuclear Power Plant.
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 0%1ification (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 i warranted to improve work control activities. The Authori'y has identified our need to j improve in this area and a formal root cause analysis is Lader final management review.
We believe the corrective actions resulting from this anaWsis will be effective in further improving our performance.
Attachment I, Revision to Reply to Notice of Violation, provides the description of the l violations, reasons for the violations, corrective actions that have been taken and the j results achieved, corrective actiong,}o be taken to avoid further violations, and the dates of full compliance. ,yst There are no commitments contained in this submittal. I l
9804270257 980420 PDR G
ADOCK 05000333 PDR jd #;
. Unitid Statrs Nucircr Rigul: tory Ccmmisal::n Attn: Document Control Desk
Subject:
Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 Pa'ge If you have any questions, please contact Mr. Arthur Zaremba, at (315) 349-6365.
Very truly yours,
~
QO s& .
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 24 day of)}% 1998 YAnv h h, /?JA W N(t'ary Pyb)lc U cc: Regional Administrator U.S. Nuclear Regulatory Commission NANCY B. CZEROW 475 Allendate Road W Putec, State of NewYctu Quellflod in Gewego Ctjunty #486H11 King of Prussia, PA 19406 Commission Expires /- A Tj Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 136 l Lycoming, NY 13093 James A. FitzPatrick NPP Project Manager Project Directorate 1-1 Division of Reactor Projects - l/ll U.S. Nuclear Regulatory Commission i Mail Stop 14 B2 Washington, DC 20555 Attachments:
Revision to Reply to Notice of Violation I
. Attachmsnt 1 Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 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. Abnormal Operating Procedure (AOP)
-23, Direct Current (DC) Power System Ground Isolation specified the sequence that breakers shall be opened to isolate system grounds.
Contrary to the above, on October 23,1997, procedures were not followed while performing AOP-23, DC Power System Ground Isolation, in that the sequence that breakers shallbe opened to isolate system grounds was not followed. Specifically, 71DCB2 Breaker Na 6, was openedprior to opening the breakers for 23MOV-57 and 23MOV-58, 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}
ADMISSION OR DENIAL OF THE VIOLATION.
The Authority agrees with the violation.
REASONS FOR VIOLATION The cause for this violation was personnel error. The performance factor leading to this l error was ineffective worker practices. The Nuclear Control Operator (NCO) assigned the duties associated with the performance of AOP-22 did not adequately utilize the practice of self-checking during the work evolutions associated with the procedure. This resulted in l
procedural steps being performed out of sequence.
Contributing human performance factors which influenced 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 pround. Additionally, the NCO became focused on getting the correct brea'ter (71DCB2 #6) due to the recognized plant impact of opening the wrong breaker. These distractions contributed to the oversight by the NCO for nat opening power supply breakers for 23MOV-57 and 23MOV-58.
- Lack of physical, orderly procedure place-keeping contributed to performing the AOP-23 procedure step out-of-sequence.
Page 1 of 11
. AttrchmInt 1 Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 CORRECTIVE ACTIONS THAT HAVE SEEN TAKEN
- A root cause evaluation was performed on the events associated with this violation to identify specific cause, evaluate the extent of conditions that contributed to the occurrence of the violation relative to recent similar plant occurrences, and develop lessons learned. Tt.e 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 l ensure proper procedure use.
- The NCO responsible for the error has been counseled.
l
- Abnormal Operating Procedures AOP-22, DC Power System A Ground Isolation, and
- l. AOP-23, DC Power System B Ground Isolation, have been revised to improve the human factors associsted with performing this procedure.
l l
- 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 j cause of this violation; 2) raised operator awareness to potential task distractions or interruption which may result in errors, and 3) increased emphasis to operators on proper procedure place-keeping.
l CORRECTIVE ACTIONS TO BE TAKEN None l l
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 71DCB2 #6 and restoration of HPCI suction paths to normallineup.
Page 2 of 11
Attichmznt 1 Revision to Reply to Notice of Violation NRC Integrated inspection Report 50-333/97-08 VIOLATION B 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 />; or isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one 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 Specification 3.7.D.2 requirements were not taken. After a maintenance error caused an invalid engineered safeguards feature actuation signal to occur in the same logic circuitry, operators recognizcd 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.
This is a Severity LevelIV violation (Supplement I).
ADMISSION OR DENIAL OF THE VIOLATION i
The Authority agrees with the violation.
L REASON FOR VIOLATION l The cause for this violation was personnel error. When listing the required Technical 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 staternent.
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.
- 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 scheduled HPCI work, would envelope the DC ground troubleshooting activity.
Page 3 of 11 l
I . .
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. Att::chmsnt 1 l Revision to Reply to Notice of Violation l NRC Integrated inspection Report 50-333/97-08 REASONS FOR VIOLATION (cont'd.)
- Procedure deficiency. Survei!!ance Test Procedure ST-2M, ECCS Trip System Bus l 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 HPCI 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 i 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 L 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.
- HPCI elementary drawing number 1.61-142 was revised to accurately reflect that relay j 23A-K35 is associated with PCIS isolation logic.
!
- Persons designated as Qualified Technical Reviewers (QTRs) and/or Qualified Safety l Reviewers (OSRs) within the Technical Services, Operations, Maintenance, and l Instrument and Controls Departrnents, whose responsibilities include conducting l 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:
- The Work Control Center supervisor has discussed management expectations for recognizing and understanding the potential plant impact and consequences of all work beitig released by Work Week Managers.
Page 4 of 11
AttschmInt 1 Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 CdRRECTIVE ACTIONS THAT HAVE BEEN TAKEN (cont'd.)
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 meeting.
- 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 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 Ooerations 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 Packaae Plannina, was revised to provide l 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.
l t
l 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 evolutions; and that emergent work must be methodically assessed for compliance with Technical Specifications.
CORRECTIVE ACTIONS TO BE TAKEN
- The formalized responsibilities and functions of the Operations planner for work package completion will be incorporated into Administrative Procedure AP-10.03.
(Scheduled Completion Date - June 30,1998)
Page 5 of 11
. Att:chmant 1 Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 DATE WHEN FULL COMPLIANCE WAS ACHIEVED 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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j Page 6 of 11
1
. Attrchm::nt 1 1 Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 VIOLATION C 10 CFR 50.49(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 environmmtal qualification be maintained in 1 an auditable form to permit verification that each item of electrical equipment important to k 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 electrical equipment important to safety was improperly removed from the environmental qualification program.
Specifically, high pressure coolant injection system pressure switches located in junction l box JB-R2250E were removed from the environmental qualification program based on a l 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 The Authority agrees with the violation. However, details provided in the text of the violation summary require correction and/or additional clarification.
The closing neragraph 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 operating 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 I maintain electrical integrity following a HPCilRHR steam line break was not recognized.
Details of this cause are provided in the following Reason For Violation summary.
Page 7 of 11
. Attachmint 1 Revision to Reply to Notice of Violation l NRC Integrated inspection Report 50-333/97-08 i REASOliS 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 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 operation following a small break Loss of Coolant Accident (LOCA) would cause an ;
inadvertent HPCI system isolation.
A 1993 JAF calculation (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 i harsh environment in the Reactor Building (RB) crescent area where the switches are located and therefore, the subject pressure switches were removed from the EQCL 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 EQCL in 1993 were added back to the List. It should be noted that the non-conservative assumption did not impact the original l conclusions made with regard to the removal of the subject pressure switches from the EQ Program.
( The consideration (EQ hasis) lacking in both the 1993 and 1996 reviews was the requirement that the switches must maintain electrical integrity following a HPCl/RHR l 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 l 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 3' 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 f actors:
l
- Worker Practices - Incorrect interoretation of drawino 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) i following a reactor building HELB was not recognized. As a result, this "Not- l Fail" safety function" was not identified in evaluation.
1 Page 8 of 11
Att:chmint 1 Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 REASON'S FOR VIOLATION (cont'd.)
- 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 (EQ). 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 appl #le drawings to the extent that the error in the 1988 report was caught.
- Worker Practices - Less than adeauate 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 identify the safety function to maintain electrical integrity for the subject switches.
CORRECTIVE ACTIONS THAT HAVE SEEN 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 and identification of lessons learned. The evaluation was prepared by and reviewed with Engineering Department personnel responsible for implementation of the EQ program.
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- Work Activity Control Procedure WACP-10.1.11, Environmental Qualification Proaram For Harsh Environment Plant Electrical Eauioment. Attachment 1,
" Environmental Qualification (EO) Component List", was revised to include HPCI pressure switches 23PS-86A, B, C and D.
- Engineering and Design Procedure EDP 20, Procedure For Estab@hina if Plant Electrical Eauipment 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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AttrchmInt 1 i Revision to Reply to Notice of Violation
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l NRC Integrated Inspection Report 50-333/97-08 j CDRREC'TIVE ACTIONS THAT HAVE BEEN TAKEN (cont'd.) f i
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- This violation and its root cause evaluation have been included as required reading on Engineering Department personnel Task Qualification Sheets for performance of 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 conditiori review was performed to identify similar control circuit configurations that may involve components not being included in the EQ Program. 1 The results of this review identified eight (8) additional components within the High Pressure Coolant injection System (System 23) and Reactor Core Isolation Cooling '
Systern (System 13), level switch 23LS-100, pressure switches 13PS-127, 23PS-85, 97A, 97B, and 84B, flow switch 13FS-57, and valve position switch 23PNS- )
LS4. The six HPCI components were removed from the EQ Program based on j similar 1993 incorrect EDP-20 evaluations as those discussed in the Reasons for i 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 l 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 l documentation addressing Loss Of Coolant Accident (LOCA) safety function only.
l The following actions were completed in support of reinstatement of the 8 l components into the EQ Program and corrections to the safety function of two existing EQ components:
l The DER process has been used to identify the discrepancies, complete l 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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Attichmznt 1 Revision to Reply to Notice of Violation NRC Integrated Inspection Report 50-333/97-08 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 procedure; and (2) provide additional clarification to emphasize that a review of the plant drawings must be performed to ensure that 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 is identified.
(Scheduled Completion Date - April 30,1998)
- The 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)
- 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 position switch 23PNS-LS4 to determine the need to perform a plant modification to either: 1) install a qualified electricalinterface 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.
(Scheduled Completion Date - December 01,1998)
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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