ML13017A358

from Ed Knutson to Mel Gray: FW Fitzpatrick Hardened Vent

ML13017A358
Person / Time
Site:	FitzPatrick
Issue date:	04/18/2011
From:	Knutson E C Reactor Projects Branch 2
To:	Gray M K Reactor Projects Region 1 Branch 4
References
FOIA/PA-2013-0010, IR-95-006
Download: ML13017A358 (4)

Text

Gray, Mel From: Knutson, Ed Sent: Monday, April 18, 2011 11:38 AM To: Gray, Mel

Subject:

FW: FitzPatrick Hardened Vent Attachments:

Fitz Hardened Vent.pdf From: Knutson, Ed Sent: Thursday, March 17, 2011 1:47 PM To: Vaidya, Bhalchandra

Subject:

FitzPatrick Hardened Vent Attached is from a 1995 inspection report concerning completion of the TI that looked at hardened vents.

UNITED STATES NUCLEAR REGULATORY COMMISStON REGION I~~ 475 ALLEN DALE ROAD KING OF PRUSSIA, PENNSYLVANIA 1W4(1.1415

'April 18,. 1995 Mr. Harry P., Salmon, Jr.Resi'dent, Manager New YorkPower Authority James A. FitzPatrick Nuclear Power Plant Post Office Box 41 Lycoming, New York 13093

SUBJECT:

.

NOTIC'E OF VIOLATION (NRC REGION I INSPECTION NO. 50-333/95-06)

Dear,

Mr., Salmoný.This refe~rs to -the results of, the routi'ne resident safety inspection conducted byjMessrs.

W.. C.o.ok and R. Fernandes from February 12, 1995 to March 25, 1995 at, the- ýJame's ,A. FitzPatrick Nuclear Power Plant, Scriba, New York. A summary of the inspiec ,tion findings was presented to you and members of your staff at ,an exit .-meeting on April 1?, 1995.Thisinspectioon was directed toward areas important to public health' and safety.. eas examined during the inspection are described in the NRC Region I inspection report, whichi is enclosed with this letter. Within these areas, the inspectioneconsisted of observation of activities, interviews with personneluand document reviews.Performance by the plant staff during this inspection period was mixed.NYPA's deliberate and cautious approach to verifying the extent of fuel assembly debris and potential fuel pin damage demonstrated a safety consc'ious philosophy.

On the other hand, a number of personnel performance errors that involved radiation protection requirements and surveillance testing procedural noncompliances indicated carelessness by members of your staff for ,administrative controls.

Several examples of procedural noncompliance were citediand are discussed in detail in the enclosed report. We note that these, events occurred during 'your 1994-95' refuel outage and that NYPA has expe~rienced similar performance declines during previous planned outages.Your continued strong management attention is warranted.

You are required to respond to this letter and, should' follow the instructions specified in the enclosed Notice of Violation (Notice) when preparing your response.

In your response, you s*iould document the specific actions taken and any additi'onal actions you plan to prevent recurrence.

After reviewing ,Your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC e~nforcement-action is necessary to ensure compliance with NRC regulatory requiremen ts,.In'acco~rd'ance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will' beplaced in the NRC Public Document Room.Theresponhse directed by this, letter and the enclosed Notice are not subject"to the clearance procedures of the Office of Management and Budget 'as required by .the Paperwork Reduction Act of '1980, Pub. L. No. 96.511.

10 0 Two component hangers on the. A emepgency firl ter;7 train were6 not reflected' on plaant drawin"gs ,and pare .a different design. than those similarly:

depicted on '-the drawings.;

Thetiiensee iniftiated drawing chaniges tJo, reflect the supports and prdvided the inspector with calculations , to.,demonstrate the structural integrity of system supports,.::

The inspector reviewed the c aicUlationsiand hadno 6further questions.

• Two AODs, 701OD-114 and '70MOD-113, were disconnected and lock wired in the cl osed and, open position, respec tively. The inspector' subsequently l earned that the configuration Iwas the result of. a temporary modi~fication (No.ý93-152) pu-t into. place, to :addre~ss si~ngle fali~l~u reýconcerns previouslyy Identified, by, the licensee,.

The temporary modification placed the modulating .dampers' in failY-safei positions, to ,ensure that the control !room I.s provided a' maximum ýsupply of, fresh airf and to ensure positi~ve

ýcontrol room air pressure,,,:duri'ngg emebrgencqdfty conditions.

The inspector also learned a... minor modihficationi , wa jin, prgestocnetthis tlelmporar modification, into a perna'nent-syttem-moodif ic-a tion.The inpctor reviewe"'d, the mi nor modi f ,ictioakg n had no further' quedstions...

41 As. part of the system. wa1kdown "the e :to : te NYPA staff that ,two MODs, and' M0"-114, and flow element FE'-102 were omited frmis-bu~ilt drawing FB-3-5C, Re-v. 12, Equipment Room Heating, Vent and Air Conditioning.

However, the inspector noted that the tcomponents were identified on the control room flow diagram FB-45A and Identified in the FSAR. The inspector was concerned that despite a temporary modification and a minobr modification being processed for two safety-,related components,, this deficiency in the as-built drawin~g ws,,-not Identified by the, NYPA staff. The.:insipector identified his to NYPA. ' NYPAP's' evaluation

was inotf:compliete' at the end, o6f. theý period.The issue will remaini unresolved pendinig

!of NYPA 'eval uation and subsequent NRC rfeview. (RF WG643) /-The. inspector-s cdonclluded: -that the: control room :emergency.

ventilatiton!, system was ope-rable,.

and': with the.

bf the observations noted abovehad, no6 further qetos 4.3' TI 2515/121 Verification of Mark IHardenedtVent Modificaions As part of a comprehensive plan for closiniigL:

severe accident i issuesi, the NRC.staff undertook a program to determine if any actions should be taken, on a generi c basis, to reduce the vul nerabilI ty, of BWR' Mark I containments .to:severe accideht challenges.

At the conclusion of the Mark I Containment Performance Improvement Program, the. staff identified a number of plant.-Mod ifi cat ions Ithat would substantiially,,, enhance the pl ants' capabil ity t bboth prevent! and mitigate the conseque'nce I s of severe accidents.

R icommended

'improvements, included imprved hardened" etwe-0 vent capabilitj!.y:.

On Septembe0r" 1', 19809,, Ithe? NRC: i'ss~ue'dGeneric Ldetter (-GL) 89-1l6,, "Installatin o.a Hardened Wetwell Vent ," r,,equesting liten'see~s wi.th MNark- I ctinai~nments "to-, cons~ider instal ation of' hardened, wetwei i vent systemsunder the provisi,ons of 10* CFR 50.59. Using guidance provided in Temporaryiinnstction

('I)2515/,"Vrfcato of~ Mark& I Hardened 'ent. Modfctos.G

91) the.flRC'

~is in al the process of ,conduct ing inspections ,to verify iicensees" impl ementationof commitments made in response to, GL 89-16. , Byltes a7 ctbr2, 18,,and July 2u5, 1990, NYPA not fified:the

ýýNRC, staff ,that it' would defer it s decision on harden ed wetwel 1 vent i on until the Fitzpatrick Indiv'idual Plant, Examinati:n (IP'E) as completed.

The NRC reviewed the information provided 4n tihose letters and also, inspected the,-existing wetwell vent path at, FitzPatricL,..

As a result -o f these activiti~es, the, NRC identified weaknesses:

in procedures and operations trai;ning al'Sdo, determined that all Boil ing, Water Reactor Owners Group (,BWRO) Fy crifteri a were not met by the licensee's current design. However, because the design was expected to achieVe the desired reduction in coe damage frequency, the NRC approved NYPA's request toi defer its decision 'o Ifully implement the BWROGýhardened vent general destgn criteria until completion of their IE. This aproa adIntal safety- eval uati on, is documented in an NRC letter dat~d January. 24,1 1991.The January 19911 letter talo approved the dferai of improvemets in Ioperator tranin ad po'dus u Il IPE comlto .After the~ FitzPatr'ick,'

WEl` was completed, the NRC eed the ýchang t6o the and pr6o6edures

propoqsed' by the l-icnse Th subseqen NRC s~afetyhts

`6h NIf evaluation, of t"he Vent-related proced6res and propqosed wag trns mitted by NRC' ltte'r April 27, 1992.In a September.280, 1992 le tter, the NRCdetermined that the current ve' path fet the, intent of the BW'IaROG design criteria,,, based on additionalt infor.ati'oh provided, by, NYPA and results of the previous NRC inspection' of thee vent path.Thits letter forwvarded the NRC staff',s safety evaluation for the harde~ned vent.n, -addition, the NCfound that the plant ,Procedures and training Wver~e adeq~ua'te toprovide'-the"Information and g.Ujdanqce necessary for ope~rators to.effectively

'use. the 'FitzPatric~k, hardened.

wtwe~ll- vent.The, inspector reviewed the referenced reports: and determi-ned ithat all T appl icabl.e portiidons of TI -2501,1121 for, the hardened vent at rt zPa trihk have been effectively addrietsd.

The FitzPatrick wetwell 'vent, met, th:e intent of the NRC approved BWROG cy'Qpeati Procd....were avalbet direct, the ini t iat ion -nd, termnat ion of vent ing,, ':oppe~rator training on the was ýacceptable, and operators were found to beý " .knowledgeable of-the design and funct iion. .of, t heý system. TI 2515/121 is closed.4;4 Previously 1ýIdentofi:d Iýtems S dd..U.. ...rol v.I1tem.(92-14-01): -Rel a Room. CO System Testing As noted in inspection report, 0-3331/95-02', Section 4.C;2_.1,, NY0A, conducted, special' test procedure, STP-76AU, Relay Room Enclosure i-ntegrity T:estf,-, to! ..cq lect data "for an' engi neering anal ysiis perfOre' In li ieu ofa full discharge test of the relay room CO 2 fire suppression system. The engineering analys"'is was performed.

for WYPA: by Yankee Engineerinhg Seryvices via a February 1995~EngineePrilng ,Report to, NYPA and captured under a memorandum (JAF-RPT-FPS-02009o).

teda ted:March 2, "1995. Based, uponl satisfactory completion of th i s eng ng