IR 05000333/1987014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-333/87-14

ML20244D468
Person / Time
Site:	FitzPatrick
Issue date:	04/04/1989
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Fernandez W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
NUDOCS 8904210359
Download: ML20244D468 (2)

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Docket No. 50-333 Power Authority of'the State of New York James A. FitzPatrick Nuclear Power Plant ATTN: W. Fernandez Resident Manager P. O. Box.41 Lycoming, New York 13093 Gentlemen:

Subject: Inspection No. . 50-333/87-14 This refers to your letter dat.ed March 10, 1989, in response to cur letter dated February 8, 1989.

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Thank you.for informing us of the corrective and preventive actions documented in your letter. These actions will'be examined during a future inspection of your licensed program.-

Your cooperation with us is appreciated.

Sincerely, Original Signed By:

. Ack R. Str0 snider Jacque P. Durr, Chief Engineering Branch Division of Reactor Safety cc:

J. Phillip Bayne, President Mr. John C. Brons, Executive Vice President A. Klausmann, Senior Vice President - Appraisal and Compliance Services R. L. Patch, Quality Assurance Superintendent George M. Wilverding, Manager Nuclear Safety Evaluation Gerald C. Goldstein, Assistant General Counsel R. E. Beedle, Vice President Nuclear Support S. S. Zulla, Vice Presi' dent Nuclear tingineering R. Burns, Vice President Nuclear Operation Dept. of Public Service, State of New York i State of New York, Department of Law Licensing Project Manager, NRR Public Document Room (PDR) '

Local Public Document Room (LPDR) l Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New York 0FFICIAL RECORD COPY RL FITZ 87-14 - 0001.0.0 03/27/89 1 8904210359 890404  !

PDR ADOCK 05000333 T E '.Ol i \

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APR 0 41989

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Power Authority of the State of New York 2 bec:

Region I Docket Room (with concurrences)

MenegementAaai>Lont,DRMA(w/venci7 Section Chief, DRP Robert J. Bores, DRSS B. Clayton, EDO j

RI:DR RI:DRh Paolino Anderso 3/J'/89

/ 3/J/ /89 0FFICIAL RECORD COPY RL FITZ 87-14 - 0002.0.0 03/27/89 l

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James A. FitzPatrick

. Nuclear Power Plant

. . P O. B;x 41

, Lycoming. New York 13093 315 342-3840

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Resident Manager March 10, 1989 JAFP 89-0195 U.S. Nuclear Regulatory Commission Mail Station F1-137 Washington, D.C. 20555 Attention: Director, Office of Enforcement SUBJECT: NOTICE OF VIOLATION - INSPECTION NO. 86-04, 86-13, 87-14, 87-21: NYPA RESPONSE (DOCKET 50-333)

Reference: a) USNRC letter dated February 8, 1989 b) USNRC letter dated September 16, 1988, SALP Report No. 50-333/86-99 c) NYPA letter JAFP 87-0905 dated November 5, 1987 d) NYPA letter JAFP 88-042 dated August 19, 1988 Enclosures: 1) Response to Notice of Violation I 2) Response to Notice of Violation II

Dear Sir:

Ir: accordance with the provisions of 10 CFR 2.201, the Authority submits its response to the Notice of Violation transmitted by Reference (a). This refers to Inspections 86-04, 86-13, 87-14 and 87-21 conducted by various personnel of your office during the periods of March 11 - May 9, 1986, August 9 - September 29, 1986, April 27 - May 1, 1987, and September 1 - October 20, 1987 at the James A. FitzPatrick Nuclear Power Plant.

In addition to the Notice of Violation, the referenced letter identified an NRC concern regarding the use of contract engineering as well as the role of EQ personnel at FitzPatrick.

The Authority has used the plant's Architect Engineer, NSSS  ;

vendor, and several consulting engineering companies to assist in 4 the development of the plant parameters, master list, and EQ )

files to comply with IE Bulletin 79-01B and subsequently i 10CFR50.49. Due to the scope, time constraints, and evolving nature of the EQ issue, this was a necessary and appropriate course of action to achieve compliance. The Authority has addressed these concerns previously identified in reference (b)

regarding the review of EQ documentation prepared by outside contractors by improving the level of detail in the review of work performed by outside contractors. The Authority's response to this issue has been transmitted in references (c) and (d).

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. U.S. Nuclear Regulatory Commission March 10, 1989 l Attention: Document Control Desk JAFP 89-0195 SUBJECT: NOTICE OF VIOLATION - Page -2-INSPECTION NO. 86-04, 86-13, 87 ,14, 87-21: NYPA RESPONSE (DOCKET 50-333)

The EQ personnel at FitzPatrick within the Technical Services Department have maintained an active role in the activities of the EQ program. All of the procedures which control the EQ program were generated by these Authority personnel, as were installation . s?ecifications and maintenance procedures for EQ-equipment and 'nterfaces.

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JAF EQ personnel review all EQ files prepared by outside contractors, determine the maintenance intervals for component replacement and review the EQ maintenance l

' activities, and contr.ol the list of ecuipment in the EQ program.

In addition, JAF EQ personnel review the purchasing documentation for EQ equipment and replacement parts to ensure that all qualification attributes are addressed. They also review operating experience information, IE Notices, and vendor information which may affect EQ. Although the Authority will use contractors to perform specific identified tasks, to our knowledge we are similar to other single unit plants in the use of contractors. JAF EQ personnel at FitzPatrick have direct responsibility for maintaining the JAF EQ program on a day-to-day _

basis and are tasked with improving the quality of the program and ensure continuing compliance with 10CFR50.49.

Very truly yours, v

WILLIAM FERNAtDEZ II gpWmf 8,80STIAN #4S57051 Notary Public, State of Now York N 0$**8' C8V d WF/KDM/ct My Commtssion Expires June 30,1988" Subscribed and sworn to before me this !cNay of YHo ec A - 1989.

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CO b M Notary Public cc: R. Liseno J. Gray, WPO NRC Resident Inspector NRCI File NRC Region'.1 Office',.W. Russelli NRC Document Control Desk RMS, WPO DCC TS File

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, ENCLOSURE (1) TO JAFP-89-0195 Response to Notice of Violation J NOTICE OF VIOLATION l

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During four NRC inspections conducted between March 11, 1986 and October 30, 1987 of the licensee's program for environmental qualification (EQ) of electrical equipment important to safety, violations of NRC requirements identified by the licensee were l evaluated. In accordance with the (1) " Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety of Nuclear Power i Plants," the enclosure to Generic Letter 88-07, as well as (2)

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" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the particular violations are set forth below:

I. VIOLATION CLASSIFIED IN ACCORDANCE WITH GENERIC LETTER 88-07 10 CFR 50.49 (f) requires that each item of electric equip-ment important to safety shall be qualified by testing of identical or similar equipment under conditions identical or similar to those postulated for an accident, and that qualification based on similarity shall include a supporting analysis to show that the equipment to be qualified is acceptable.

Contrary to the above, from November 30, 1985 through March 31, 1986, the qualification of four Limitorque valve actua-tors in the Reactor Recirculation System was not established in that the torque switch and limit switch insulation material was Durez (red), not Fibrite (brown), which was not qualified by Limitorque for primary containment use.

This violation constitutes an EQ category C violation. /

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

As presented in LER 86-007 dated 3/23/86 and the enforcement conference conducted 11/29/88, the fundamental cause of this violation was a walkdown of the four Limitorque actuators which incorrectly identified the color of the torque and limit switches. A secondary cause was an inadequate review of the EQ file by the Authority.

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ENCLOSURE (1) TO JAFP-89-0195

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Corrective Steps That Have Been Taken A_nd Results Achieved Following determination on March 24, 1986 that the actuators were not qualified for in-containment use,. they were replaced with environmentally qualified. actuators on March l 31, 1986. All other EQ actuators in the containment were i immediately Com inspected.taken.plete walkdowns were performed and photographs were All other valve actuators in the EQ Program which are located in the containment were identified as having torque End limit switches qualified for I in-containment use. These actions were completed prior to i returning the plant to service. The qualification documen- '

tation for all EQ Limitorque actuators was also reviewed, including the traceability cf each s tuator. The trace- 4 ability of each actuator was verified to ensure that the i identified deficiency did not apply to any other actuators.

No other deficiencies were identified. Subsequently, the EQ files for Limitorque actuators were completely . revised.

The traceability of each actuator to the appropriate test report was established, and the qualification of each actuator was reverified.

Corrective Steps That Have Been Taken To Avoid Further Violations In order to improve the consistency and completeness of the Authority review, verification, and acceptance of EQ files generated by outside consultants, a new procedure titled Review of Plant Specific Qualification Reports-(EDP-28), was written and implemented on September 27, 1987. This

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procedure requires written documentation of the review, verification, and acceptance of these EQ files in accordance with a checklist which documents the details of the file review and verification. Completion of the checklist documents acceptance of the file by the Authority and concurrence with the conclusion that the equipment is qualified. The checklist includes verification that accept-ance criteria, similarity, installation interfaces, and all other pertinent qualification attributes are specified and adequately addressed.

All FitzPatrick EQ files including those prepared by outside

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contractors / vendors are being reviewed in accordance with EDP-28.

Compliance Status The Authority considered itself in compliance with 10CFR50.49 relative to this item on March 31, 1986, upon installation of the replacement actuators.

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!' ENCLOSURE (2) TO JAFP-89-0195 Response to Notice of Violation II NOTICE OF VIOLATION During four NRC inspections conducted between March 11, 1986 and October 30, 1987 of the licensee's program for environmental qualification (EQ) of electrical equipment important to safety, violations of NRC requirements identified by the licensee were evaluated. In accordance with the (1) " Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety of Nuclear Power Plants," the enclosure to Generic Letter 88-07, as well as (2)

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the particular violations are set forth below:

II. VIOLATION CLASSIFIED IN ACCORDANCE WITH 10 CFR PART 2, APPENDIX C 10 CFR 50.49(j), requires that a record of the qualification shall be maintained in an auditable form to permit verifica-tion that each item of electrical eqdli> ment important to safety is qualified and r. hat the equipment meets the spec-ified performance requirements under postulated environ-mental conditions.

Contrary to the above, frcm November 30, 1985 through January 28, 1987, documentation in a qualification file was inadequate to establish qualification of sixty-four Rosemount pressure transmitters installed in the analog transmitter trip system. The transmitter were installed without the use of required thread sealant at the instrument conduit connection, and there was no record in the qualifi-cation file to verify that the transmitters, as installed, would function properly in a post accident condition.

This is a Severity Level IV violation (Supplement I)

NIM RE3PONSE TO NOTICE OF VIOLATION The Power Authority agrees with this violation.

The fundamental cause of this violation was the lack of detail in the written procedure for the installation of Rosemount transmitters. The absence of step-by-step instructions led to the omission of thread sealant from the conduit entry ports on the transmitters.

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ENCLOSURE (2) TO JAFP-89-0195 (Continued)

These transmitters have two conduit entry ports, one of which is used to electrically connect the transmitter using a Rosemount 353C seal assembly. The other port is not used, and is blocked by a stainless steel pipe plug. The technical manual for this model transmitter specifies that the conduit threads on the ports must be sealed with a pipe-thread sealant.

Corrective Steps That Have Been Taken and Results Achieved During a maintenance outage commencing on September 27, 1986, the Authority inspected all 64 transmitters and applied thread sealant to the threads of all of the previously unsealed ports. In addition, to demonstrate operability of the transmitters and verify that a lack of thread sealant would not affect the qualification of the transmitters, the Authority investigated industry testing of Rosemount transmitters. Successful qualification testing had been performed by Wyle Laboratories on a Rosemount transmitter which had the cover o-rings removed and the covers hand-tightened and then loosened 1/4 turn. This test program subjected the transmitter to a steam environment at pressure up to 1.6 psig. The Authority determined that the tested configuration represented a more severe moisture leakage path than a lack of thread sealant. The test utilized a test pressure 2.2 times greater than required for the FitzPatrick transmitter applications. Based on these test results, it was concluded that the absence of thread sealant did not affect the transmitter qualification.

A formal evaluation of the installed configuration of the FitzPatrick transmitters (without thread sealant) was performed to substantiate the Authority's previous determination. This evaluation was based on a comparative study of leakage path potential between the installed configuration and the tested configuration, and was completed on January 5, 1987. The evaluation verified that the Authority's determination was correct, since the testing and analysis demonstrated that the transmitters would have performed their design function during all applicable postulated accident conditions.

Corrective Steps That Have Been Taken To Avoid Further Violations To ensure that future installation and maintenance acti-vities are performed in accordance with environmental qualification requirements, including conduit entry sealing, Instrument Maintenance Procedure IMP-77, Replacement of Rosemount Pressure Transmitter Model 1153, Series B, Code R, with Conduit Seal 353C* has been prepared and approved.

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I ENCLOSURE (2) TO JAFP-89-0195 l (Continued)

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This is one of 31 EQ maintenance procedures written to

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ensure that maintenance activities on EQ e performed in accordance with the manufacturers' quipment are requirements and the appropriate EQ requirements. ] ,

In addition, the Authority is ' performing a review of the -

modification arocess to determine whether additional actions are requirec to ensure that the review of vendor documentation is thorough and complete, and that all appropriate installation requirements are defined in the installation procedures. This review will be completed by h

September 30, 1989. i i Compliance Status I

The Authority considered itself in compliance with i 10CFR50.49 with respect to this item on October 9, 1986, !

when the inspection of the. transmitters and the application i of thread sealant was completed.

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