IR 05000333/1992023
| ML20127N803 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/20/1993 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127N801 | List: |
| References | |
| 50-333-92-23, NUDOCS 9302010081 | |
| Download: ML20127N803 (25) | |
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U.S. NUCLEAR REGULATORY COhlh11SSION Region 1 Report No.: 92-23 Docket No.: 50-333 License No.: DPR-59 Licensee: New York Power Authority
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in:way, New York 13093 Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, New York Dates: November 15, 1992 through December 24, 1992 Inspectors: W. Cook, Senior Resident inspector J. Tappert, Resident inspector R. Bhatia, Reactor Engineer L. Scholl, Reactor Engineer Approved by: h .// 'V / 4!f8 Peter \f EselgrothAhlef 'Date Reactor Projects Section 1B, DRP INSPECTION SUhth1ARY: Routine NRC resident inspection of plant operations, radiological controls, maintenance, surveillance, engineering and technical support, and quality assuranec/ safety verification, itESUlXS: See Executive Summary 9302010001 930120 PDR ADOCK 05000333 I O PDR
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l TAllLE OF SUMMARY OF FACII.lTY ACTIVITIES ' NYPA Activities During this inspection period the unit remained in cold shutdown and progress was being made toward restart. The major work activities coming to closure involved the fire protection and Appendix R modification.t and related procedure revisions, post-modification testing, and operator training. With identified exceptions, NYPA documented their readiness to restart FitzPatrick by letter dated December 17, 199 , NRC Activitics The inspection activities during this report period included inspection during normal, backshift and weekend hours by the resident staff. There were 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> of backshift (evening shift) and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of deep backshift (weckend, holiday and midnight shift)
inspections during this perio Region based inspectors were onsite nearly every week of the inspection period to review NYPA's closure of the multiple fire protection and Appendix R issues, inspector obsen'ations and findings were documented in inspection report 92-1 A region based specialist inspector reviewed the effluent monitoring program the week of December 7,1992 (inspection report 92-26).
A region based specialist inspector reviewed the Security Plan implementation the week of'
December 7,1992 (inspection report 92-25).
A region based specialist inspector conducted a review of the radiography program between December 2 and 4,1992 (inspection report 92-21).
A team of region based :,pecialists and resident inspectors observed the December 2,1992 backshift emergency preparedness exercise (inspection report 92-22).
During the week of November 30,1992, a specialist inspector reviewed the electrical cable -
separation issue at the site (inspection report 92-24).
-On December 23,1992, NRC reprewntatives met with local elected officials to discuss the ,
status of FitzPatrick and recent NRC inspection and assessment activities at the facility.
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3 ' PLANT OPERATIONS (71707,71710,93702) Routine Plant Operations Review i
During the inspection period the inspectors observed control room activities including !
operator shift turnovers, shift crew briefings, panel manipulations and alarm response, and routine safety system and auxiliary system operations conducted in accordance with approved operating procedures and administrative guidelines. The inspectors made independent verincation of safety system operability by review of operator logs, system markups, control-panel walkdowns and component status verifications in the field. Discussions were held with operators and technicians in the field to assess their familiarity with current system status and personnel response to events during the inspection period. In addition, during plant tours,-
inspectors reviewed routine radiological control practices. The activities inspected were acceptabl .1.1 Operational Safety VerifntiPJ1 The inspector conducted partial control room and in-plant walkdowns of the following systems:
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Reactor core isolation cooling
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A and 11 standby liquid control
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A and Il emergency service water
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liigh pressure coolant injection No discrepancies or concerns were identified by the inspectors during their review of the above system ' Previously Identified items 2.2.1 (Closed) Unresolved item (50-333/92-82-Olh Temporary Modification Control Weakness This unresolved item from the Restart Assessment Team Inspection (RATI) identified -
weaknesses in the administrative controls over the temporary modification (TM) proces Specifically, the TM backlog was found to be excessive, the duration of some temporary
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modifications exceeded two years, and controls over the drawing update process were poo .
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NYPA developed an action plan to assess and prioritize temporary modi 6 cations for closm The established action plan goal of clearing all TMs greater than two years old was targeted for the end of 1992. The inspector determined this goal will not be met. However, NYPA has reduced the number of TMs by about 50% since the RATI and audited TMs that will be in place for reactor startup to ensure all required safety analysis have been conducte inspector review of several TMs found the required reviews and safety analysis were conducted in accordance with the procedural guidanc The inspector also determined that Work Activity Control Procedure 10.1.3, Control of Jumpers, Lifted Leads, and Temporary Modifications, had been revised to strengthen oversight of the drawing revision process. The configuration manager is now tasked wit performing a weekly review to ensure the Revision in Process Index is updated to reflect recent temporary modifications. Inspector review of the Revision in Process index and master operating procedure drawings found this process to be effective in maintaining accurate drawing NYPA has adequately addressed the concerns of this unresolved item. The site staff continues to make progress in clearing TMs and in reaching their long term action plan goals. This unresolved item is close .0 RADIOLOGICAL CONTROIS (IP 71707)
The inspector observed routine radiological work practices during observation of various maintenance activities and in routine tours of the plant, in general radiological workers
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seemed to be well-trained and were observed to be using appropriate radiological work ,
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practices (i.e., bagged tools and other items, as required, maintained work areas clean, removed protective clothing properly, dosimetry worn properly, and all radiological postings obeyed). The health physics technicians were observed to give good pre-job briefings and maintained close surveillance over the work activities in their assigned areas. The radiological work areas, in general, were well-maintained (i.e., clean with appropriate radiological postings). The inspector concluded that the workers and health physics technicians were working well together to ensure safe and appropriate radiological work practice .l .0 MAINTENANCE (IP 62703)
The inspector observed and reviewed selected portions or preventive and corrective-maintenance to verify compliance with codes, standards and Technical Specifications, proper 4 use of administrative and maintenance procedures, proper QA/QC involvement, and appropriate equipment alignment and rctest. The following activities were observed:
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4 f 5 Reactor Water Clranup Valve 12RWC-46 Weld Repair Backcround On November 25, work was commenced per Work Request (WR) #12/106441 to repair a bonnet weld leak on valve 12 RWC-46, reactor water cleanup (RWCU) system supply inboard isolation valve. 12RWC-46 is a manually operated, six inch, double-dise, carbon steel gate valve manufactured by Anchor Darling Valve Company. This valve was installed ,
per modification F1-84-053 in 1985 with a one-half inch stainless steel equalizing line and associated isolation valve to provide a bonnet cavity vent. This vent climinates the potential- a for hydraulic locking between the disc During the performance of a hydrostatic test on another RWCU valve earlier in the outage, leakage was observed in the vicinity of the bonnet weld to the equalizing line. Rust stains were also observed on the bonnet of the valve. Based upon this information, NYPA prepared a work package to establish proper isolation of the bonnet weld and to make an ASME Code allowable repair. The inspector notes that the weld repair package was drafted with an assumption that the observed leakage was from the weld (suspected to have failed)
and that adequate mechanical isolation could be achieved using the equalizing line isolation valve and the upstream disc of the valve.12RWC 46 is unisolable from the primary except by the instaliation of a recirculation piping mechanical plu After weld grind-out and liquid dye penetrant testing, and during the weld build-up preparation, the leak was exacerbated (one-eighth inch diameter stream) requiring prompt plugging and a subsequent re-evaluation of the repair process. The now evident hole in the one-half inch stainless steel equalizing line (near the toe of the weld) was temporarily plugged using a piece of weld rod and excess weld material.. The leakage was reduced to approximately one gallon per hour at that time. While evaluating repair options, the leakage was further reduced by cycling the equalizing line isolation valve and 12RWC-46. However, the leakage could not be completely stoppe NYPA Reoair Options The inspector learned that three repair options were being evaluated by NYPA. The first option to perform a like-in-kind replacement of the equalizing line was not achievable because of the inability to establish complete isolation with the existing valve configuratio The second option involved a non-ASME Code encapsulation of all or part of the equalizing line. The third option was an ASME Code repair / replacement by installing a mechanical plug in the recirculation pipe penetration to provide appropriate isolation for the work. The second option was selected by NYPA and verbally concurred in by the NRC per telephone conference call on December 11,1992. A written ASME Code relief request was submitted to the NRC staff by NYPA on December 14. By letter dated, December 23,1992, the NRC staff granted the ASME Code relief, l
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6 Inspector Review In addition to reviewing the plant modification (MI-92-383) package and relief request documentation, the inspectors witnessed the mock-up training and results achieved. The encapsulation methodology was appropriately developed and renned by the weld engineer and his staff. A signincant amount of training was conducted and both non-destructive and destructive testing of the encapsulation devices proved excellent results could be consistently -
achieved. Furthermore, appropriate contingency plans were incorporated into the work instructions and practiced via the mock-up unit The repair work commenced on December 12, with initial fit up of the encapsulation-devices. A minor surface indication was identified in the bonnet weld area, but was easily buffed out. The longitudinal welds were completed on December 13, and radiography satisfactorily completed on December 14. Final weld-up was performed and the encapsulation devices satisfactorily hydrostatically tested on December 1 Inspector Review of NYPA Critique Following the unsuccessful repair attempt on November 25, NYPA conducted a critique per Administrative Procedure (AP)-03.03, Deviation and Event Analysis, Attachment 1. The critique identified a number of performance errors. They were:
-- Inadequate job preparation: The mechanic responsible for removing the 12RWC-46 stem packing, to verify the adequacy of isolation, did not remove all the packin ,
The packing configuration was properly described in the work package, but the mechanic did not review this information prior to starting the job. A carbon bushing-and braided ring remained in the valve, this masked the fact that the weld repair area had not been properly isolate The inspector notes that this step was critical to the valve repair, in that, a weld-repair of this type cannot be adequately performed with water present. Numerous .
cautions and work instruction steps were incorporated into the package to ensure proper work isolatio Inadequate work instructions: NYPA concluded that the packing removal guidance was inadequate and not specific in that the instructions did not state to remove all the packing or what results to expect. Secondly, the weld excavation and preparation step is assumed in the work instructions (an apparent oversight).
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Workers proceeded when unexpected situations were encountered: Water was encountered during the liquid dye penetrant (PT) examination by the Quality Control (QC) inspector. This PT examination was required by the work instructions prior to rewelding the excavated area. Also, the welder noted water twice in preparation for the weld build up. NYPA concluded that the workers should have stopped when water was encountered and that they should have sought further guidanc Ineffective non-destructive examinations (NDE): Prior to welding, no indications were allowed in the valve bonnet or pipe. Evidently the indication (crack leaking water) in the pipe was not identified. In addition, the PT report was not filled out-until requested for the event critiqu The inspector notes that NYPA's critique states the QC inspector had an acceptable weld prep area via penetrant testing, but that over a period of about 15 minutes the -
area became damp. The QC inspector informed the mechanic of his " satisfactory" PT results and of the observed dampnes Inadequate turnover: The mechanical supervisor in charge of thejob on November 25 had it turned over to him the previous day by the original job superviso However, his review and understanding of the work package was marginal and he relied heavily on the mechanic performing the wor In addition to the immediate corrective actions taken to control the leak, the critique stated that a team of NYPA engineering and maintenance personnel would be assembled to identify the failure mechanism and appropriate repair, Also, a human performance root cause analysis has been initiated to ideatify recommended actions to prevent recurrenc Insocctor Conclusions As stated above, NYPA's non-ASME Code encapsulation repair relief request was reviewed and approved by the NRC staff. However, a number of performance problems have been identified and corrective actions to prevent recurrence are pending the completion of a human performance root cause evaluation by NYPA Based upon the inspector's discussion with various NYPA representatives and review of the written event critique, it appears that NYPA has appropriately reviewed the chronology of events and has been suf6ciently self-critica NYPA's corrective actions have not been Gnalized or assessed by the inspector. This issue is unresolved pending issuance of NYPA's corrective action plan and NRC inspector revie UNRESOLVED 92-23-01
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8 Off Gas Syltem Integrity Testing The inspector observed portions of this work and concluded that it was conducted in a competent professional manner. During conduct of the test leaks were detected, repaired, and retested. The actual leak test consisted of pressurizing the system with service air and adding helium. Any leaking helium was detected with a mass spectrometer. One weakness was noted with the test procedure, in that, while it specified an allowable helium leakage rate, it did not specify the amount of helium to be added to the system. Therefore, depending on how much helium was added a given leak could be characterized as either acceptable or unacceptable. In actual practice, approximately 400 standard cuble feet of helium was added to the system which provided ample detection capability, but this practice was not procedurally controlled. This observation was relayed to the licensee and will be incorporated in future testing procedure .3 RHR 10 hiOV-39A Torus Isolation Valve Testing On November 16, 1992, NYPA tested 10 h10V-39A (torus spray outboard isolation valve)
ability to shut under full flow conditions in accordance with Generic Letter 8910. The full now of 15,000 ppm was only reduced to 7000 gpm after an attempt to close the valve. This was the only valve of the twenty-four tested during this outage that did not pass the full now test. The licensee disassembled the valve for inspection and repair and found excessive clearances between the disc guides. NYPA's analysis of the operator found it to be marginally acceptable. While a modi 0 cation to install a larger operator was being prepared, the dise guides were tightened and the valve retested. 10 h10V-39A grossly failed the post-work local leak rate test (LLRT) on December 4, but it passed the full flow test on December 5,1992, in response to the LLRT failure, NYPA reinspected the valve with no deficiencies noted and installed a larger operator. The post modification LLRT passed on December 18, and the full flow test was successfully completed on December 23. NYPA pursued repairs until a satisfactory result was obtained. NYPA is reviewing several other valves and is preparing modi 0 cation proposals to increase the size of these operators as wel The inspectot found NYPA's approach to resolving 10 hiOV-39A testing problems consistent with GL 89-10, SURVEILLANCE (61726)
The inspector observed and reviewed portions of ongoing and completed surveillance tests to assess performance in accordan with approved procedures and Limiting Conditions for Operation, removal and restoration of equipment, and de0ciency review and resolution. The following tests were reviewed:
The inspector observed surveillance test, ISP-72, SRh1 Instrument Trip Function Test. No denciencies were note _ _ _ _ _ _ _ _ _ . _ _ . . _ _. _ . . __ _ _ . _ _.__. _ _ ___ .. _ _ _ _ . . .
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l (Closed) Unreplved item (50-333/92-20-Olh Relay Room CO Full Discharge Test lhekground On November 11, the NYPA staff attempted to perform Special Test Procedure (STP)-76AE, CO, System Discharge Test - Relay Room. This test was performed to determine the design capability of the low pressure carbon dioxide (CARDOX) system in the relay room. The ,
relay room CARDOX system was designed to provide a minimum of 50% carbon dioxide I concentration for 20 minutes to extinguish a deep seated Gre. During an earlier NRC inspection (50-333/92 80) NYPA was unable to produce sufficient engineering documentation to support the design basis for any of the plant's CARDOX nre suppression systems, one of ;
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which was the relay room CARDOX system. Consequently, engineering calculations were generated (relay room calculation, [[::JAF-CALC-FPS|JAF-CALC-FPS]] 00697) to substantiate the design basis of these as-built systems. The inspector also determined that a records review by NYPA identined that pre-operational testing of all CARDOX systems except the relay room were performed satisfactorily in 1974. Records indicated that the relay room CARDOX system was not performed in 1974 due to the potential adverse affects of discharging carbon dioxide ;
into a room containing sensitive electronics (i.e., plant process computer, actuation and-protective system relays, off-site power protective relays). As a result, NYPA developed a testing scheme to demonstrate and verify that the relay room as-built CARDOX Dre suppression system could perform its intended design functio IciLResuhs >
NYPA generated two tests to accomplish this task. The first test (STP-76AD, Door Fan - ,
Pressure Test - Relay Room) was performed to determine the expected leakage from the room. This test was successfully completed on August 31,1992. The second test (STP-76AE) was attempted on November 11, but aborted due to carbon dioxide (CO,) in-leakage to the control room. Minutes into the discharge test, control room personnel became aware of elevated CO, concentrations and in accordance with the test procedure aborted the test and -
commenced purging the relay room of CO,. Per contingencies developed in the test ,
procedure, unnecessary control room personnel were evacuated and licensed operators- .
donned self-contained breathing apparatus and remained at the controls to monitor plant parameters and direct test recovery efforts; Acceptable oxygen breathing concentrations' >
were restored in less than an hour and the control room was returned to normal acces Immediately following restoration from the CO, discharge test, NYPA conducted a critique
. to identify and gather as much information as possible on the aborted test. This information would later be used to formulate both operational and design improvements that could be .
implemented. In addition, an investigation was commenced to identify the source of the CO,
in-leakage to the control room. The critique and design engineering investigation were completed the week of December 7. The final CO, corrective action pla;n was dockete? $c
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week of December 2 .
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NYPA Review The control room CO,in leakage was attributed to cross-flow contamination. The pathway was from the relay room heating and ventilation (ilVAC) exhaust duct work, through the exhaust-to-supply temperature modulating valves and ducting, into the relay room supply duct work which has a common intake with the control room supply duct work within a i missile-shield housing on the control building roof. A motor operated damper (70 MOD-10211) in the relay room HVAC exhaust duct was jumpered open for the full discharge test to ensure an over-pressure protection vent path. NYPA engineers assumed that the path of least resistance for the vented air and CO, was through 70 MOD 102B and out the exhaust duct work. As demonstrated, this was not the path of least resistance and the escaping air and CO, were entrained in the control room supply flow as the control room ventilation was aligned for full purge flow during the relay room CO, tes Data collected from the discharge test indicated that the 50% concentration of CO, was only achieved at the one foot from the floor level in the relay room. The middle level CO2 probe (nine feet from floor) results were borderline and the highest level probe (12.5 feet from floor) did not achieve 50% concentration. NYPA attributed the lower than acceptable concentrations to the inadequacy of the relay room vent path through the exhaust duct wor Rather than exhausting at a high point in the room, the exhaust duct work is located at ,
approximately the five to seven foot level in the room. As the room began to fill with CO, from the bottom and displace air (CO, is heavier than air) air was essentially trapped in the
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higher levels of the relay room. As discussed in the following section, NYPA design engineering has evaluated this ventilation configuration and has proposed a modification to remedy this problem. Specifically, a relay room high point vent would be installed which is independent of the ventilation duct wor NRC Review
The NRC staff reviewed the action plan items and concluded that combined with the Technical Specifications required actions, the action plan provided an acceptable approach for system operation during reactor restart and operation. In addition, the inspectors reviewed the revised procedures and the completed actions, and found them to have been acceptably impicmente NYPA management has committed that the above corrective and compensatory actions for the relay room CO, fire suppression system will remain in effect until a system modification can be designed, installed, and tested satisfactorily, including reperformance of the discharge
- test. Tentative NYPA plans include presentation of a system modification to the Plant
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Operations Review Committee in January 1993, and installation and testing during a suitable,
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subsequent reactor outage. The NRC concluded that this approach was acceptabl ;
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11 Insnector Followup
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Following completion of NYPA's critique and design engineering evaluation, the inspector conducte
discharge tes As discussed by the NYPA site staff at the December 3 meeting, the approach taken to jumper the damper contradicts general saveillance testing practice. The practice is to test the as-built configuration to verify the adequacy of the design and system operability. This aspect of the test was not adequately reviewed or addressed during ,
NYPA's procedure review process. The inspector learned that the PORC review discussed this approach,- but based upon incorrect information (the responsible test enginers thought that the damper had to bejumpered open the duration of the test to ensure satisfactory test results) the PORC approved the use of thejumpe The inspector questioned NYPA regarding the potential generic implications of the relay room CO, discharge test failure with respect to the seven other plant CARDOX systems. NYPA had not reviewed this question, to date, but planned to address this as part of their design basis reconstitution program. Preliminarily, as stated above, pre-operational tests results for the other seven CARDOX systems were satisfactor However, NYPA will review the associated ventilation systems for these rooms to sec if similar CARDOX system vulnerabilities exist.
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NYPA Corrective Action Plans in accordance with the Technical Specifications, backup fire suppression equipment and a continuous fire watch were established and maintained. (The relay room CO, system is designed to be manually initiated based on installed heat detection in the relay room and alarms in the control room.) NYPA implemented an action plan, dated December 16, 1992, that provided additional corrective and compensatory actions to enable reactor startup and operation. The action plan included the following compensatory items:
- The fire fighting pre-plan for the relay room was revised to provide a caution not to initiate the CO, system without first obtaining the Shift Supervisor's permission. The plan was also enhanced to reflect other available manual suppression systems in the are Operating Procedure, OP-55, " Control Room Ventilation and Cooling," was revised to provide direction to operators for the isolation of the control room ventilation syste Operating Procedure OP-56, " Relay Room Ventilation and Cooling," was revised to better describe system configuration during actuation of the CO, fire suppression syne .l
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The Alarm Response Procedure was changed to ensure that prior to manual initiation of the CO, system, control room operators are directed to carry out the actions per a new Abnormal Operating Procedure, AOP-63. AOP-63 requires that the control room ventilation system be placed in isolation, non-essential personnel be evacuated from the control room, all personnel in the relay room be evacuated (including the -
fire watch), and control room personnel don self-contained breathing apparatus and continue its use until habitability is verifie A Special Condition Tag requiring Shift Supervisor permission prior to CO, initiation has been posted at the remote statio .
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Posted instructions (operator aid) have been placed on the fire protection panel (in the control room) to instruct operators to don self-contained breathing apparatus prior to CO2 initiatio Corrective maintenance on the control room to relay room door restored it to original design basis leak tightnes A relay room ventilation control logic verification was complete ,
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-- Licensed operators were trained on all of the above procedure changes prior to startup or prior to assuming watchstanding responsibilitics, and all fire brigade members were ,
retrained on the revised Gre Oghting pre-pla Conclusion
As stated above, the NRC staff found NYPA's Action Plan, which included compensating actions and procedure enhancements acceptable for unit restart and power operation. The ,
proposed modincation to the relay room ventilation system and subsequent CO, full discharge verification testing appears appropriate. The performance concerns discussed above will be ;
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monitored by the inspectors in future inspectio - No additional or immediate safety concerns remain. Unresolved item 92-20-01 isclose .2 [ Closed) DEO.MT.024: EDG TESIlHQ During the Diagnostic Evaluation Team inspection, the team noted some apparent design denciencies involving the emergency diesel generator (EDG) air start system. The EDG system, as described in the FSAR, has a number of redundant design features. The as-built design has two air banks for each EDG that feed into a common supply header. The air header, in turn, supplies two sets of air start motors._ Because of the design limitations (i.e.,
no isolation valves for the pairs or individual air start motors), all four air start motors (two per set) were being tested simultaneously. This design concern was forwarded to NYPA by NRC letter dated January 16,.1992. NYPA's response to this letter was dated February 18, 1992. Inspector review of this response and procedure ST-98, EDO Full lead Test and ESW Pump Operability Test, revealed that provisions to test each air bank every other month '
has been added to ensure the operability of each air bank. The inspector reviewed several completed tests of the air start motors and overall system function. Based on several successful tests, the inspector concluded that this revised system surveillance test was appropriate to verify system operabilit ,
Other EDG as-built design concerns raised by the DET were that there was no pressure indication on the standby air bank, no air filters or dryers, and no fuel Glter differential'
pressure gauges, inspector walkdown verified that modification Mi-88-244, installed ,
differential pressure gauges and added duplex filters on each EDG to enhance system performance. The inspectors concluded that pressure indicators on the standby air tank was not a concern due to other available pressure indicators. Based upo'n these observations, this item is close .
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14 ENGINEERING AND TECIINICAL SUPPOltT (93702) Previously Identified items 6.1.1 (Closed) DEO.ENG.046: LPCI Batterv Inverter This Diagnostic Evaluation Team Observation (DEO) identified that the operability of the 1.PCI battery inverter, following a loss-of-coolant accident (LOCA), was not evaluated for radiation effects. At the time of the DET, inverter power was relied upon for LPCI system operation for 30 days. However, the licensec estimated that both (A and B) inverters would fail within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during a postulated post 1.OCA radiation environmen The licensee, with modification No. F1-91-305, added key-operated switches in control room panel 09-08 for each safety division. These switches provide plant operators the capability to transfer the LPCI inverter to an alternate power source. The alternate power is from the emergency motor control center (MCC) of the same safety division (MCC 153 and 163 located in the reactor building). This new design allows the operators to select the alternative power supply any time, up to and including 180 days after a design basis even The inspector review of design installation, test results and equipment qualification calculations revealed no concerns. The inspector concluded that the above design modification adequately addresses the above stated LPCI system operability concerns. This item is close .1.2 (Closed) Unresolved Iten' (92-15-Olh DC Coordination This item pertained to DC coordina: ion concerns, where five safety related feeder circuits were supplied from non-category I (ne'i-safety related) panels. Three safety related circuits were supplied from DC distribution panei 71DC-A3 and two ciTuits from DC distribution panel 71DC B3. Further review of the safety related circuits revealed that DC panel 71DC-A3, breaker 7, supplied the A standby gas treatment control system while the feeder breaker 6 of panel 71DC-B3 supplied the B train of the same systern. During the previous inspection, the licensee was not abic to demonstrate that with a fault on feeder circuits, one safety train would remain _ operable. This was due to lack of coordination between the feeder breakers and supply breakers. Since these panels were nonicategory I and inadequate coordination existed between DC breakers, a single credible failure with a seismic event could result in a common mode failure of safety related DC panels, which may result in the plant being outside the design basis (si ngle failure criterion).
The licensee completed a 125 Vdc protective coordination study (JAF RPT-ELEC-00527).-
This study focused on determining the corrective actions required to resolve the coordination concerns. Based on inspector review of this study, two feeder circuits associated with breakers 5 and 8 on DC panel 71DC-A3 required corrective action. To resolve the safety L concerns, the licensee initiated a minor design change, M192-249, to add fuses in series l
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with breakers 5 and 8 in panel 71DC-A3. The licensee also upgraded both panels (71DC-A3 and B3) to category I status, as they were originally procured category 1. Panel 71DC-B3 circuit breakers appear to have sufDelent cable lengths to allow selective coordination with upstream breakers. The licensee long-term goal is to achieve the complete coordination by replacing component Based on the inspector's review of the completed design work, this item is closed. NYPA subsequently completed this modification (M192-249) prior to unit startu .1.3 (Closed) Unresolved item (50-333/91-18-01): Missing Pine Suonort Calculation This unresolved item was closed in inspection report 92-17, section 6.1.6. However, the specialist inspector noted at the time of the inspection that some of NYPA's actions "1.s not yet completed and that these and others may warrant verifications. The specific actions
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pending completion were the installation of the relay room electro hydraulic control (EHC)
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cabinet fasteners. The inspector witnessed portions of the control room cabinet stitch '
welding (welding was done on cabinets 25-9,09-21,09-38,09-19, and 09-18) when it was performed in July 1991. During the week of December 14, the inspector was accompanied by the plant structural engineer and conducted a visual inspection of a sampling of various control room and relay room cabinets to verify the as-built cabinet seismic anchorage configurations (cabinet base to embedded channel welds). No discrepancies were noted. The inspector also determined that the work request for installation of the EHC cabinet fasteners was assigned a low priority and likely would not be performed prior to unit restart. The basis for the low priority was two-fold: the system is not safety-related and a seismic calculation /cyaluation has been performed which concluded the cabinet could withstand a design basis seismic event without the fasteners it' stalled. The installation of these fasteners after unit restart was determined to be appropriate, and was not considered a startup restraint by the inspector or NRC staff. The inspector notes that subsequent to the end of the inspection period, NYPA installed all 15 fasteners and torqued them to 60 inch pounds. This work was completed on December 22 per Work Request 09816 .1.4 (Closed) Violation (50-333/92-82-02): Scaffolding Control During a plant inspection on October 6,1992, the Restart Assessment Team identified scaffolding which was not installed in accordance with station procedure PSO-51, " Erection of Scaffolds Near Safety-Related Equipment." PSO-51 requires tie-offs for scaffolding greater than seven feet in height, unless located greater than one foot from safety-related equipment. - The inspectors identified scaffolding installed less than one foot from safety-related battery charger A and associated cable trays, without having tic-offs installed.- The failure to follow the requirements of PSO-51 is a violation of plant Technical Specification 6.8 which requires that procedures and written policies shall be established, implemented and maintained to control activities affecting safety. Without the required space and tie-offs, the scaffolding could potentially impact and damage safety-related equipment during a seismic even _ _ - - - - _~ _ _ _ . _ _ _
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As a result of the inspection finding, the NYPA took the following corrective actions as documented by letter, dated December 17, 1992:
-- All scaffolding in plant areas containing safety-related equipment was inspected and ,
identified deficiencies were corrected ,
-- Site-wide training was conducted on PSO-51 to improve plant personnel's knowledge of the requirements of this procedure
-- Procedure PSO-51 was reviewed and revised to clarify which piant areas contain -
safety-related equipment and to clarify the scaffolding installation requirements -
On December 11, 1992, several scaffolding installations were inspected and found to be-installed in accordance with procedure PSO-51. They were not in contact with safety-related ;
equipment and lateral supports wcre installed to prevent side motion in the event of a seismic
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event. The Scaffold Installation Checklists were also reviewed and found to properly document the licensee's scaffolding inspection. Based on the licensee corrective actions and the inspection of a sample of scaffolding installations, this violation is close .1.5 (Closed) Unresolved Item (50-333/92-82-03h Setpoint Control Program During a review of the licensee setpoints control program, the Restart Assessment Team identified a deficiency with Surveillance Test ISP-75, " Condensate Storage Tank _ Low Water Level (HPCI)." The procedure was deficient in that it allowed an "as left" level transmitter setting of 59.5 inches from the bottorr. of the Condensate Storage Tank (CST). This value corresponded exactly to the Technical Specification (TS) minimum level and therefore did not allow for instrument uncertainty or drift. The licensee acknowledged the deficiency and took corrective actions which included performing a detailed setpoint calculation, revising the procedure to change th9 setpoint and performance of the surveillance test using the allowable limit t
The licensee then performed a review of all station surveillance tests to determine if the -
setpoint limits contained some margin to the TS values. Five additional Instrumentation and Controls (l&C) surveillance tests and eight operations department surveillance tests were identified not to have margins built into the allowable setpoint criteria. Setpoint calculations -
were performed for eight of the tests, which were instrumentation related, and'the procedures-have been revised to reflect the new setpoints. The revised surveillance tests are being
-- performed prior to declaring the associated systems operable. The remaining five tests are being revised to include tolerances which are based on historical test data. These setpoints l
will be used on an interim basis until calculations are performed.
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The I&C department identined thirteen other surveillance tests which had a tolerance specified in the surveillance test, but did not have a supporting engineering calculation to ensure the tolerance was adequate. The licensee then reviewed actual test data for the last four performances of these tests (where available) and found that the existing test tolerances resulted in the TS limits being met for all but one test performance. The instrument was recalibrated and did not exhibit any significant drift when checked during a subsequent test ~
performance. Based on this review, the licensee concluded that the existinc setpoints werc adequate on an interim basis until a detailed calculation is comp'ete Based on the above actions, and a review of several of the calculations and procedure revisions, the inspector concluded that NYPA's actions adequately addressed the unresolved item. This item is close .0 SAFETY ASSESSMENT /QUALnT VERIFICATION (71707,93702) Review of Licensee Event Reports (LERs) and Special Reports The following LERs were reviewed and found satisfactory:
-- LER 91-16 01. Turbine Building Ventilation Exhaust Monitoring dated October 27, 199 LER 91-33-01, Voluntary Report Concerning Potential Torus Pressure Instrument Errors dated November 5,199 LER 92-27-01, Check Valve 14 AOV-13A, Seat Leakage Exceeding Technical Specification Limits dated November 13, 199 LER 92 036, Inadequate RCIC Vacuum Breaker Line Protection Against HELB dated July 24,199 LER 92-35, ESF Actuation and Loss of Effluent Monitoring Due to Transformer Failure, dated September 22,199 LER 92-48, Inadequate Seismic Installation of Safety-Related Transformers, dated December 7,199 LER 92-35 documents the failure of safety-related load center L-15 transformer T-13 and its associated plant impact. LER 92-48 focuses on the subsequent determination by NYPA that T-13 and its redundant safety-related transformer T-14 were not seismically installed.- .
Inspector followup (also reference inspection report 92-15) identified that initial control room operator response to the transformer failure was appropriate and that FitzPatrick staff followup correction actions were similarly thorough and timely. With respect to the scismic anchorage concern, NYPA engineers recognized the anchorage deficiency while conducting a
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field walkdown for the proposed modification (replacement of the failed T 13 transformer).
Close examination by NYFA determined that neither the original transformer coils or enclosure base channels were anchored. Examination of the redundant T-14 transformer showed the same configuration. Records and drawing reviews by NYPA, GE and the responsible architect / engineer were unable to identify any specine anchorage requirement NYPA concluded this condition to have existed since' construction, and the root cause to have been inadequate /non existent installation instruction The inspector verined that appropriate seismic anchorage instructions were established and implemented by NYPA. Work was completed on both the T-13 and T-14 transformers by November 10, 1992. NYPA verified that the two similar safety-related 4160V to 600V transformers (T 15 and T-16) were scismically anchored as required. The inspector-concluded that NYPA had taken proper and timely actions to address these transformer seismic anchorage deficiencie ,
+ hiceting with local Officials .
On December 23,1992, representatives of the NRC met with local area elected officials to discuss the status of the FitzPatrick facility and related NRC inspection and assessment activities. The meeting was held at the hiayor of the City of Oswego office in City Hall at 10:00 a.m. A list of the discussion topics is provided as Attachment I to this inspection repor ; h1 ANAGEN 1ENT A1EETINGS At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspectica scope and findings. In addition, at the end of the period, the inspectors met with licensee representatives and summarized the scope and findings of the inspection as they are described in this repor ,
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, U.S. NRC RI FITZPATRICK PROGRESS REPORT
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BACKGROUND -
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- 1991 OBSERVE PERFORMANCE DECLIN * SENIOR MANAGEMENT MEETING - FULL DISCUSSION PLANT
- DET EVALUATION SEPT /OCT
- NOVEMBER 1991 FORCED PLANT SHUTDOWN
- FORMATION OF ASSESSMENT PANEL
- JANUARY 1992 NRC WATCIILIST PLANT
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22 OUTAGE ACTIVITIES
- MAJOR OUTAGE WORK
- NRC INSPECTION ACTIVITIES'
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TEAM INSPECTIONS
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RESIDENT STAFF INSPECTIONS
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23 RESTART PR"sPARATION
- NYPA COMMITMENT
- NYPA SELF-ASSESSMENTS / EVALUATIONS
- NRC REVIEWS
- REGIONAL ADMINISTRATOk'S RESTART AUTHORIZATION
- CURRENT STATUS I
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