ML20042G827

Responds to NRC 900410 Ltr Re Violations Noted in Insp Rept 50-333/90-11.Corrective Actions:Mod Error Corrected,New Transmitters Installed & Mod Procedures to Be Revised to Assign Responsibility for Calibr Points Value Calculation

ML20042G827
Person / Time
Site:	FitzPatrick
Issue date:	05/09/1990
From:	Fitzpatrick J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JAFP-90-0396, JAFP-90-396, NUDOCS 9005160143
Download: ML20042G827 (8)

Text

., ;i James A Fit Patrick Nuclear Power Plant

.1- P.O. Box 41-

. . Lycoming, New York 13093

. 315 M2-3840

1. b hiewWrkPbwer

& Authori *""**"d**

Resident Manager May 9, 1990' JAFP 90-0396 United States Nuclear Regulatory Commission Mail Station P1-137.

Washington,.D.C. 20555 Attention: Document-Control Desk

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT  !

DOCKET NO. 50-333 l INSPECTION NO. 90-11  ;

Gentlemen: -.

'In accordance with the provis;nns of 10CFR2.201, the-Authority 1 submits this response to the' Notice of Violation transmitted by- ,

your-letter dated April- 10, 1990. This refers to the inspection conducted by Mr. Richard A. Plasse of your office during the l period January 30 through February 7, 1990 at the James A.

FitzPatrick Nuclear Power-Plant.- l NOTICE OF VIOLATION As a result of the inspection conducted on January.31 through l February 7, 1990, the following violation was identified: -y A. Facility Operating License No. DRP-59, Section 2.C.(1) authorizes NYPA to operate FitzPatrick at a thermal reactor power not to exceed 2436 megawatts (100 percent power of  ;

rated power).

4 Contrary to the above, NYPA operated FitzPatrick at a thermal power in excess of 2436 megawatts between October 3 1988 and November 1989. Based on calculated errors, NYPA operated the reactor at a power. level up to 101.4. percent of rated power. This occurred-due.to' errors in the calculation of feedwater flow transmitter calibration settings regarding

~

static pressurization effectc and feedwater flow nozzle ,

characteristics.  !

This violation has been categorized as Severity Level IV (Supplement 1).

I 9 -

9005160143 900509 Of /dI  ;

PDR ADOCK 05000333 ,

Q PDC- t i 1

r

'Unitod Statos Nuclocr_ Regulatory. Commission 1990

~

M2v: 9,

-, SU5 JECT:' NRC INSPECTION 50-333/90-11 JAPP 90-0396 i

~Page  ;

~

The Power Authority agrees with this finding but has established l that the actual steady state power level did not exceed.101%.

l The fundamental causes of this. violation were:

Previously unidentified vendor design ^ errors and an error; introduced as'a resultHof a plant modification., At no time  !

did the-Authority knowingly exceed its-authorized. thermal

+

power-limit of 2436 MW.'

Vendor Errors-The original feedwater venturi flow to differential-pressure 1 correlation was based on an incorrectLflow nozzle thermal expansion coefficient and an incorrect input'for the denefty- .

of feedwater at operating conditions. . In 1984, the flon venturis ' were: replaced. This.resulted in correction ofiche expansion coefficient but-the density _ error.was not' identified.

The Authority was not aware of these correlation errors prior-to. January.1990 since the plant normally oaerates ,

below turbine nameplate (1.0% 2.3%) and:no1 turbine performance acceptance test had been performed'onsthe unit to identify any discrepancy. ,

Modification Error i

The second error was introduced:during a" feed flow differen-tial pressure transmitter replacement:in October-1988.. The-replacement transmitter vendor.had quantified the span and '

zero shif t effects due to

operating line' pressure and- l i provided a compensation ~ method in thelvendor technical manual. .This compensation was not' included in the calibration of the replacement transmitters. The reason

that the compensation was not included in the calibration l procedure was an inadequate review of the vendor manual and '

i a weakness"in the administrative controls for minor l modifications.

I L

L l

l:

k

t y

United Statas' Nuclear:Ragulatory.zCommission- 'M y 9, 1990  !

SUBJECT:

NRC-INSPECTION 50-333/90 JAFP 90-0396 j Page=  :

l During 1988, modifications 1were controlled by plant proce-

dure,:WACP 10.1.6,." Control of Modifications,-Component-

. Changes and: Safety and Environmental Impact Evaluation", as 3 either. a' maj or ' modification or as a. minor modification. The ,

details of review, tracking, and document update, etc. -i

. differed between the two types.. Major modifications.re-

• quire alformal document tracking ~ form which-documents the: 4 need for procedure changes (i.e._ instrument procedures).and

tracks this.for'complet1on. 'The procedure states that  ;

department. superintendents are responsible for updating-their own procedures with the modification's responsible -

Lengineer.to provide assistance.- Theiminor modifications did-.

.not require a document-tracking form:nor-is it as explicit on procedural assistance byfthe responsible lengineern During the 1988 refuel outage, the-feedwater transmitter ~

replacement was : controlled as a minor modification - since it.

was basically a- change inivendor equipment with no : change 'in- '

function. Conversely,,a separate modification for' reactor ,

water level instrumentation, which' involved:a different: -

.model Rosemount transmitter, was - performed as a major modification. The instrument' calculations and instrument procedures associated with this major modification were -

thoroughly reviewed by-the responsible. engineering-organization.and I&C' personnel. The minor modification:

procedurcs/ calculations were -incompletely reviewed: by.

different I&C-personnel and:the modification responsible engineer did an inadequate review;of the technical manuals.

for the replacementJflow transmitters. The conceat of "an- l exact replacement" component resulted in a71ess, t:aorough'  !

l-review of the technical" manual; 4

L . -

l A review of-several major modifications-involving instrument- I L calculationsLandicalibration'procedsre.changesidid not

. identify any similar oversights.

1 1

,i l ..

l

[

United States 1Nuc1 cr Rhgulatory-Commission- .May 9, 1990-

SUBJECT:

NRC-INSPECTION 50-333/90-11 JAFP:90-03961 i Page1 .

1 The immediate corrective actions for-this. violation were:

F. . Vendor-Errors a

The-modification error was identified and corrected

' prior to discovery.offthe vendor flow nozzle errors.

. j" After the' modification-error was-corrected, the investigation continued: during power operation. New transmitters:were ordered to assure that the .

transmitter calibration was correct. At about the same time, a discrepancy was identified concerning thefflow '

nozzle calibration curve. Since the Authority could- . --

not duplicate the' vendor ~ calibration: curve, the Authority requested the calibration inputs.from the flow. nozzle vendor in order: to resolve .this discrep-

-ancy. Previous to this, the-Authority had; requested ,

all inouts to the calibration curve in' order to vali- ,

date them. Since this wasinot forthcoming,.the_most. . .!

conservative inputs were used for~the new transmitters' calibration, ,

On January 29, 1990 the new transmitters were installed which led to an. overpower indication. Core thermal power was immediately reduced. The indicated-overpower ^

was determined to be 0.55% based on the transmitter change-out. +

On January 30, 1990, the nozzle vendor supplied 1the nozzle-calibration inputs. With this new information,-

the Authority determined'that approximately half of the indicated overpower was-attributed to-overconservatism in the: calibration, input parameters.-

i On March 8-10,1990, a Na 241 tracer. test was: performed

^

s i_

l to confirm the feedwater flow measurement indication.- <

The results were thatsthe feedwater flow indication wast high by approximately~ 0.7%~. The Authority is.

evaluating how this'information can-be used to ensure that the feedwater: flow measurement is.as. correct as-possible.

c i

w I'

e i

• )  :'

' UnitGd .Statos Nuclocr Regulatory Commission MIy 9,e1990 l ,

SUBJECT:

- NRC-INSPECTION 50-333/90-11' .JAFP 90-0396 l Page l

2. Modification Error A review of^other Rosemount transmitters. revealed the

balance.of the transmitters were installed during the L 1985 ATTS upgrade. No static pressuref adjustment was L included originally, but the Authority modified:

L calibration 1 procedures to include span: pressure shift compensation after-receipt of NRC<IE Notice 85-100 and-L

' Revision C of Rosemount-Technical Manual. These'

. calibration procedure revisions did not include zero1 pressure-shift compensation because of the smal1~

magnitude of the.effect and-'the inability to_ predict-the direction of the change. The small>zero span effect has been included in instrument:setpoints:

associated with the ' reactor water level modifications-in~1988..

The transmitter static ~ pressure compensation error was identified and corrected during1startup after a brief outage in November, 1989. .This had; resulted inLa:

nonconservative error of approximately 0.9%: core l- thermal power.,

i Additional corrective actions includei  !

l- 1 l a. .Modificationiprocedures will'be-revised to clearly assign responsibility for generating calculated values for calibration points, spans, and setpoints. 1

b. Modification controls will be~ reviewed to ensure that the~ modification responsible engineer or system engineer is_ closely involved.with -!

post-modification testing and procedural updates. -j

c. A training program for management, instrument and control, and technical-_ support personnel will be q instituted in order to increase the staff's i awareness of the feedwater instrument loop' design  !

and.its effects on'the~ plant thermal power-calculation, j 1

Full compliance was achieved on January 29, 1990 when the static '

pressure-compensated transmitters were. installed and calibrated i using corrected feedwater flow nozzle-correlation values.

i l,

l l

1 i

i

1 ,

• Unitcd Stctos Nuciocr R:gulctdry 'Commissicn - May 9, 1990 i

SUBJECT:

NRC INSPECTION 50-333/90-11 JAFP 90-0396 Page NOTICE OF VIOLATION As a result of the inspection conducted on January 31 through l February 7, 1990, the following violation was identified: l B. 10CFR50, Alpendix B, Criterion XVI, requires in part that measures siall be established to assure that once identified  !

prompt corrective action is taken for conditions that are- ,

adverse to quality. i

' Contrary to the above, NYPA failed, following identification  :

by GE,-to take prompt corrective action on various feed-water transmitter calibration errors, known to have existed  :

at similar boiling water reactors. Failure to take action led to the operation of the plant-above the licensed core thermal power for-an extended period time. This informa- 't tion, provided by GE in October and November 1988, did not i get adequately reviewed until November 1989.

This violation has been categorized as Severity Level IV (Supplement 1).  !

RESPONSE TO NOTICE OF VIOLATION  !

The Power Authority agrees with this finding. [

The fundamental cause of this violation was >

Improper prioritization of the associated General Electric  !

Service Information Letter (SIL) was the fundamental cause of the violation. ,

Two elements led to the incorrect prioritization of this- l SIL. One element was a weakness in.P.he Operating Experience Program. Also contributing was a failure on the part of the i GE Service Information Letter (SIL) 1:o characterize the importance of the potential problem.

Operating Experience Program Weakness In early 1989 several weaknesses in the FitzPatrick Operat- ,

inz Experience Prozram were identified and actions were ,

to'<en to correct them. One of these weaknesses was inconsistent prioritization of documents for review and j action. No hierarchy for operating exoerience document type  :

had been formally established. In addition, no formal ,

screening guide existed.

L ,

i L a

UnitCd Stctos Nuclocr R gulatory Commissien May 9, 1990

SUBJECT:

NRC INSPECTION 50-333/90-11 JAFP 90-0396 Page Improper Characterization of the SILs Importance A contributing cause of the violation was an inadequate characterization of the importance of'the SIL by the originating organization. With the hundreds of operating experience documents requiring review and the limited number of knowledgeable reviewers, the ariority assigned to their reviews was sometimes based on the source's implication-of importance.

The associated SIL (RICSIL and SIL 452S1) indicated these potential calibration errors were "not considered to be a safety Concern". Consequently manpower was directed'to operating experience issues of more obvious importance.

The corrective actions for this violation were:

Weaknesses in the operating experience review program were corrected in July 1989.

The governing procedure (PSO-28) was revised to establish priority levels and to include a screening guide for significance. This additional guidance will assure that reviewers focus their attention on issues which'are more likely to have a significant effect on plant operations and safety. INPO Good Practice 82-003, "Significant Event Evaluation and Information Network Program Description", was used to prepare significance screening criteria.

The use of system engineers / experts to review a significant percentage of operating experience documents has resulted in more prompt and thorough reviews.

In March 1990 a review was erformed to ensure that all

" Priority 1 (high priority)p' operating experience documents were given an initial review for significance and applica-bility.

l

, o c; . . . .. ,

i

[ '

s

' ^

- 'g ' l'

.

• Unitcd Statcs. Nuc1cor R':gulatery Commissicn May 9, 1990

SUBJECT:

NRC INSPECTION- 50-333/90-11 JAFP 90-0396-j Page' An questions may be directed to Robert Liseno of my staff at (3 5.349-6011 .

t Very truly yours,

/

^

FE DEZ ,

WF:JRLils

' DISTRIBUTION Records Management - WPO

. Director of BWR Licensing NRC Resident Inspector-

=NRCI 90-11 File-Document-Control Center NRC Region I Office Attn William F. Kane - Director, Division of Reactor Projects CERTIFIED MAIL - RETURN RECEIPT REQUESTED

'1 h '_.