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EA-99-325 - FitzPatrick (New York Power Authority)March 20, 2000 EA 99-325 Mr. Michael J. Colomb
Dear Mr. Colomb: On February 19, 2000, the NRC completed an inspection at the James A. FitzPatrick Nuclear Power Plant. The results of this inspection were discussed on March 2, 2000, with Mr. D. Lindsey and other members of your staff. The enclosed report presents the results of that inspection. This inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of a selected examination of procedures and representative records, observations of activities, and interviews with personnel. This report provides the final significance determination for the high pressure coolant injection (HPCI) system issue previously described in NRC Inspection Report 05000333/1999009. At your request, a regulatory conference was conducted with members of your staff on February 7, 2000, to discuss your views on the significance determination and proposed apparent violation. A copy of the handout you provided at this meeting is attached. During the regulatory conference you addressed two main issues for NRC consideration. First, that the characterization of the HPCI overspeed event as having White (low to moderate safety significance) was not appropriate, because you believed that had a valid HPCI initiation signal existed, HPCI would have injected without an overspeed trip. Secondly, you believed that the apparent violation, as written in NRC IR 05000333/1999009, was not appropriate because the testing cited in the apparent violation was not required for determining HPCI operability. The significance determination of the HPCI event was reevaluated and the NRC concluded that the issue had been appropriately characterized as White. The NRC concluded that the assumptions and uncertainties contained in your evaluation of the event did not provide adequate justification for a reduced safety significance. The details of this evaluation are provided in this report. In the Mid-Cycle Performance Review dated January 3, 2000, we previously noted our plan to address this White finding and the associated corrective actions as part of a supplemental inspection under Inspection Procedure 95001, which we have planned for April 4, 2000. Finalizing the White significance determination has not altered that plan. The NRC agreed with your position that the apparent violation was incorrect. Based on new information reviewed, we have concluded that the apparent violation proposed in NRC IR 05000333/1999009 regarding inadequate test control of the HPCI system did not in fact exist. However, we have concluded that NYPA failed to identify and correct problems with the HPCI governor control system. Specifically, NYPA failed to properly set the HPCI system hydraulic oil operating pressure. The improper oil operating pressure resulted in abnormalities in HPCI governor control system performance and could have resulted in an overspeed trip during a system injection. In addition, HPCI system performance monitoring was ineffective as evidenced by the failure of NYPA to identify the problems with hydraulic oil pressure, spring tension and general degradation of the system. These failures to identify and correct conditions adverse to quality associated with the HPCI system are cited in the attached Notice of Violation and the circumstances surrounding it are described in detail in this report. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. The inspectors identified one violation of NRC requirements related to timely corrective actions for a residual heat removal service water system strainer. This finding was evaluated using the applicable SDP and was determined to be Green (very low safety significance). This violation is being treated as a non-cited violation (NCV), consistent with the interim Enforcement Policy for pilot plants. This NCV is described in the inspection report and has been entered into your corrective action program. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room. Should you have any questions regarding this report, please contact Mr. Glenn Meyer at 610-337-5211.
Docket No. 05000333 Enclosure: cc w/encls:
During NRC inspections conducted from October 18, 1999 to February 19, 2000, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below: 10CFR50, Appendix B, Criteria XVI, "Corrective Action," requires that measures shall be established to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
These problems resulted in abnormalities in HPCI governor control system performance that resulted in an overspeed trip during the startup of the system on October 14, 1999, and could have resulted in an overspeed trip when the system was called upon to perform its intended function. As a result, the HPCI system was inoperable, contrary to Technical Specification 3.5.C, for a period greater than seven (7) days. Pursuant to the provisions of 10 CFR 2.201, the New York Power Authority
is hereby required to submit a written statement or explanation to the
U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,
D.C. 20555 with a copy to the Regional Administrator, Region I, and a
copy to the NRC Resident Inspector at the facility that is the subject
of this Notice, within 30 days of the date of the letter transmitting
this Notice of Violation (Notice). This reply should be clearly marked
as a "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing
the violation or significance determination, (2) the corrective steps
that have been taken and the results achieved, (3) the corrective steps
that will be taken to avoid further violations, and (4) the date when
full compliance will be achieved. Your response may reference or include
previous docketed correspondence, if the correspondence adequately addresses
the required response. If an adequate reply is not received within the
time specified If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. Because your response will be placed in the NRC Public Document Room
(PDR), to the extent possible, it should not include any personal privacy,
proprietary, or safeguards information so that it can be placed in the
PDR without redaction. If personal privacy or proprietary information
is necessary to provide an acceptable response, then please provide a
bracketed copy of your response that identifies the information that should
be protected and a redacted copy of your In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days. Dated this 20th day of March, 2000 |
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