IR 05000220/1978018
| ML17053A298 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/09/1978 |
| From: | Blumberg N, Conte R, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053A297 | List: |
| References | |
| 50-220-78-18, NUDOCS 7812270449 | |
| Download: ML17053A298 (24) | |
Text
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R U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Docket No.
50-220 License No. DPR-63 Pr iority Category C
Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse, New York 13202 Facility Name:
Nine Mile Point Nuclear Station, Unit
Inspection at:
Scriba, New York Inspection conducted:
October 24-27, 1978 Inspectors:
R.
.
Co te, Rea or Inspector te signed N. J.
B mberg, R actor Inspector da signed da e signed Approved by:
H. B. Kiste, Chief, Nuclear Support Section No. 2, RO&NS Branch at signed Ins ection Summar:
Ins ection on October 24-27, 1978 Re'rt No. 50-220/78-18 R,dd t
dt tt dt Pt of administrative controls for facility procedures; format and technical content of facility procedures; procedure revisions resulting from Technical Specification Admendments; procedure revisions made in accordance with 10 CFR 50.59(a)
and (b)',
standing orders, special orders, and temporary procedures; reportable occurrences; and licensee action on previous inspection findings.'he inspection involved 31 inspector hours onsite by 2 NRC regional based inspectors.
Results:
No items of noncompliance were identified.
Region I Form 12 (Rev. April 77)
7 8 X2 Sv0 Vlf
DETAILS Persons'Contacted D. Balduzzi, Central File Supervisor B. Drews, Reactor Analyst
- T. Perkins, Plant Superintendent R.
Raymond, Fire Protection Coordinator J.
Shea, Station Shift Supervisor
- M. Sill iman, Results Superintendent
- C.. Stuart, Operations Supervisor B. Taylor, Inspection and Calibration Supervisor Several other members of the operations and administrative staff were also contacted.
. * denotes those present at the exit interview.
Licensee Action on Previous Ins ection Findin s (Open)
Noncompliance (220/76-24-01):
Failure to retain surveillance records of'reactor low water level calibration.
The licensee had reviewed existing procedural controls in the area of record retention and attempted to determine if any other instrument and control calibration records were missing.
As a result of this review, the licensee has made an entry in the appropriate area of the records file documenting (by reference to other records)
the completion of the subject calibration.
Further, the licensee has established a
computerized Documentation and Retrieval System which involves the indexing and filming of plant records.
Throughout the course of the inspection, various records were retrieved for inspector review.
It was noted that some records were incorporated into the new system and others were not.
The inspector found no instance of a missing record in either case.
The licensee representative indicated that the scheduled completion date for lOOA incorporation of'he backlog of records into the computerized system was somewhat ambiguous (end of 1977).
Approxi-mately one hundred thousand documents had been filmed and/or indexed and the backlog consists of approximately an additional one hundred thousand documents.
The licensee representative stated that a good date for 100% implementation is the end of 1980.
This date is based on anticipated upcoming outage work and charted completion progress with the existing personnel leve This remains unresolved pending further NRC:I review.
(Cl osed)
Unresol ved Item (220/77-06-01 ):
Facil ity procedures to be reviewed on a periodic basis.
Office of Inspection and Enforcement Inspection Report No. 50-220/78-09 stated that approximately 505 of the Special (Emergency/Abnormal)
Procedures had been revised and needed SORC review.
The inspector verified on a sampling basis that these procedures have been properly reviewed, approved, and issued; and that periodic reviews on older procedures have been accomplished and documented in accordance with the licensee's administrative controls.
(Closed)
Noncompliance (50-220/77-20-05):
Failure to calibrate instruments to cover operational limits.
Revision 1 dated April 2, 1978, to ICP-41, Liquid Poison System, incorporated appropriate test points to cover the Technical Specification limits for Standby Liquid Poison Tank Level Calibration.
ICP-210, Revision 0, January 5, 1978, Control Room Air Treatment System Delta Pressure Indicators, was issued to control the calibration of system filter/charcoal differential pressure (DIP) gages (Equip-ment Piece Nos.
210-09 and 210-10).
The licensee utilizes both gages (each with a range of 0-3" H~O D/P) in series to verify compliance with the TS limit of c 6" H20.
Therefore, it was inappropriate to include the calibration of these gages as an example of failure to calibrate instruments to cover operational limits.
This example is hereby retracted from this noncompliance item.
(Open) Unresolved Item (220/78-03-01):
Licensee to revise various surveillance procedures.
Office of Inspection and Enforcement Inspection Report No. 50-220/78-09.documented that the surveillance procedure for Core Spray System operability checks remained to be revised pending a physical modification to the system.
A previous inspection identified that the Core Spray Motor Cooler lacked instrumentation-to certify its operability and the applicable surveillance procedure did not have provisions for monitoring cooler performance.
The licensee representative stated that this area is being reviewed with respect to the. Inservice Inspection Program which will be implemented shortly.
This remains unresolved pending subsequent review by NRC: I of the results of the licensee action as stated abov (Closed)
Unresolved (220/78-17-01):
Licensee to revise calibration procedure to incorporate a conservative setpoint with respect to Technical Specification limits.
Revision 4, October 1978, to ISP-RE-04, High Drywell Pressure Instrument Channel Test/Calibration was issued to incorporate a new setpoint such that a nonservative tolerance applied to this setpoint would not exceed the appropriate TS limit.
Further details are discussed in. Paragraph 9.
3. 'dministrative'Controls'for Facilit Procedures Administrative controls were reviewed to determine the licensee's system for implementing requirements associated with the control of facility procedures as specified in Technical Specification, Section 6; Regulatory Guide 1.33, guality Assurance Program Requirements; and, ANSI N18.7, Administrative Controls for Nuclear Power Plants.
Areas of emphasis were in the established controls for format, content, review (including periodic review),
and approval of facility procedures.
The following documents were reviewed:
APN-1, Revision 2, June 19, 1978; Procedure For Administrative Controls; APN-3, Revision 0, October 25, 1977, Site Operations Review Committee Procedure; APN-5, Revision 1, January 16, 1978, Procedure For Control of Procedures, Instructions and Orders; APN-6, Revision 1, July 3, 1978, Preparation of Procedures, Instructions, and Orders; and, APN-20, Revision 1, April 3, 1978, Station Fire Protection Program.
4.
Technical Content of Facilit Procedures Facility procedures were reviewed on a sampling basis using FSAR System Descriptions, Piping and Instrument Diagrams and Technical Specifications, where necessary, to verify that procedures were sufficiently detailed to control the operation or evolution described within Technical Specification Requirements.
The procedures re-viewed with respect to this area are marked by asterisk (*) in the next paragraph (Paragraph 5, Review of Facility Procedures).
5.
Review of Facilit Procedures a.
Facility procedures were reviewed on a sampling basis to verify the following:
Procedures, plus any changes, were reviewed, approved, and retained in accordance with the requirements of the Technical Specifications and the licensee's administrative controls; The overall procedure format and content were in conformance with the requirements of the Technical Specifications and ANSI N18.7, "Administrative Controls for Nuclear Power Plants;"
Checklists, where applicable, were compatible with the stepwise instructions in the procedures; Appropriate Technical Specification limitations had been included in the procedures; and, Temporary changes were made in conformance with Technical Specification requirements and the licensee's administrative controls.
(This temporary change review included procedures in addition to those listed below.)
b.
The following procedures were reviewed:
Administrative Procedures (Verification of proper review and approval only APN-2, Revision 0, October 27, 1977, Composition and Responsibilities of Site Organization; APN-2A, Revision 0, October 12, 1977, Conduct of Operations and Composition and Responsibilities of Station or Unit Organization; APN-8, Revision 0, October 27, 1977, Test and Inspection Program; APN-8A, Revision 0, October 28, 1977, Procedure for Pre-Operational Test '0 er'atin
'Procedures OP-43, Revision 10, November 22, 1977, Startup and Shutdown Procedure; OP-44, Revision 2, June 28.
1977, Generator Stator Cooling Water System; OP-3, Revision.6, November 22, 1976, Reactor Cleanup System; OP-13, Revision 4, October 15, 1976, Emergency Cooling System; OP-6, Revision 3, September 22, 1975, Fuel Pool Filter and Cooling System; OP-16, Revision 3, December 17, 1975, Feedwater System Booster Pump to Reactor; OP-19, Revision 4, September 27, 1976, Circulating Water System; OP-21, Revision 1, January 6,
1976, Fire Protection System; OP-38C, Revision 3, December 16, 1975, Local Power Range Monitors - Average Power Range Monitors; OP-37, Revision 4, January 17, 1977, Rod Worth Minimizer.
Emer enc Procedures SOP-20, Revision 1, August 21, 1978, Loss of Condensor Vacuum; SOP-26, Revision 1, August 21, 1978, High Activity Reactor Coolant or Off Gas; SOP-4, Revision 3, August 21, 1978, Feedwater Malfunction (Increasing Feedwater Flow);
SOP-24, Revision 1, August 21, 1978, Loss of Shutdown Coolin Maintenance Procedures MP-11.4, Revision 1, August 2, 1978, Overhaul of Reactor Cleanup Relief Valves; MP-9.4, Revision 1, March 21, 1977, Repair of Emergency Condenser; MP-27.19, Revision 1, July 6, 1978, Maintenance of Fuel Pool Circulating Motors; MP-27.5, Revision 1, July 6, 1978, Maintenance of Condensate Pump Motors; MP-9.7, Revision 0, October 27, 1977, Repair of Emergency Condenser Return Valve 39-07; MP-44.4, Revision 0, June 28, 1976, Installation of Fire Stops; IMPNEU-4, Revision 0, September 5, 1978, Local Power Range Monitoring; IMP-15, Revision 1, February 3, 1977, Rod Worth Minimizer System Instrument Maintenance.
Alarm Procedures Panel K3-5, Clean-Up Pump 11 Trip - Overload Suction Pressure Low; Panel K3-20, Clean-Up System Steam Leak Temperature High; Panel K1-2, Emergency Condenser Vent 811, Radiation Monitor; Panel Kl-10, Emergency Condenser Makeup Water Tank 0'1 Level Hi-Low; Panel L1-21, Fuel Pool Low Level, Surge Tank Makeup Valve Open; Panel L1-29, Fuel Pool Annunciator (Various Alarms);
Panel H3-21, Feedwater Heaters 131-135 Level High High;
- --
Panel H3-15, Reactor Feedwater Pump 812, Trip Overload Suction;
- --
Panel H2-3, Circulating Water Pump Intake Level Low;
Panel Hl-24, Intake Icing;
- --
Fire Control Panel No. 1, Window F-8, Turbo-Generator Fire Detecting Zones Heat Activated Device (HAD) Circuit Open Control Power Out;
- --
Fire Control Panel No. 1, Window G-8; Diesel Fire PV-1 Engine Trouble;
- --
Panel Fl-14 APRM 11-14 (Flux, Inoperable, Downscale, Upscale, Rod Block, Upscale Reactor Trip);
- --
Panel F2-15, APRM Flow Unit No. 12; and,
- --
Panel F2-46, Rod Block.
During this review, the inspector observed several instances where the licensee has identified the need for procedure revisions yet there appears to be an excessive delay documenting.
reviewing, approving and issuing these revisions.
In the examples listed'elow, the revisions wer e warranted due to TS Amendments or as a result of periodic reviews.
OP-21, Revision 1, January 6, 1976, Fire Protection System does not recognize the applicable TS requirements in this area.
These requirements were issued February, 1978, as a part of Amendment No.
22 to the Facility License.
In addition, a periodic review of OP-21 conducted February, 1978, identified the need for changes to this procedure.
In particular, the valve number for a supply isolation valve for the High Pressure Cardox System was left blank.
The procedure has not been revised.
Also, during February, 1978, the periodic review of OP-38C, Revision 3, December 16, 1975, Local Power Range Monitor-average Power Range Monitors, identified that changes were needed, yet no revision has been issue TS Amendment No.
24 issued Hay 15, 1978, permits isolated recirculation'oop operation, however, no procedure has been issued governing operation with less than full
'reactor coolant flow.
A procedure is being developed to control this operation.
OP-13, Revision 4, October 15, 1976, Emergency Cooling System, does not reflect appropriate surve'illance require-ments for inoperable equipment.
Specifically, Amendment No.
18, issued July 1977, permitted one Emergency Condenser to be inoperable for the present cycle and, therefore, relaxed surveillance frequency requirements from daily to weekly on the operable condenser.
OP-13 reflects the daily requirements.
In all instances above, applicable surveillance procedures, logs, etc.
were updated or issued to reflect current TS require-ments.
The licensee representative stated that the procedures addressed above, would be revised/issued as appropriate to correct the noted discrepancies and that the established internal "tickler system" will be utilized to identify and track procedures needing revision due to periodic reviews or TS Amendments.
This is unresolved pending licensee action as stated above and subsequent NRC:RI review.
(220/78-18-01)
6.
Standin Orders, S ecial Orders, and Tem orar Procedures The inspector reviewed licensee Orders/Procedures which are cate-gorized as Standing Orders, Special Orders, or Temporary Procedures as defined in ANSI N18.7, "Administrative Controls for Nuclear Power Plants," to determine that:
The:content of the Order/Procedure was compatible with ANSI N18.7 definitions; and, Provisions exist for approval, periodic review, updating and cancellation of these Orders/Procedures.
The inspector identified that the Standing Orders and Station Shift Supervisor (SSS) Instructions were issued in this area.
The inspector reviewed the effective Standing Orders and SSS Instructions on a sampling basis.
No items of noncompliance were identifie.
Chan es to Procedures as Described in the Safet Anal sis Re ort Pursuant to 10 CFR 50.59 a
and b
The inspector reviewed licensee records to identify changes to procedures which are described in the Final Safety Analysis Report (FSAR) and to verify that these changes, if any, were reviewed and maintained by the licensee in accordance with 10 CFR 50.59(a)
and (b).
Records reviewed were associated with the procedures noted in the previous paragraph (Paragraph 5, Review of Facility Procedures)
and included the licensee's Procedure History File and Onsite Safety Committee Meeting Minutes File.
Of the procedures/changes to procedures sampled, the inspector did not identify any change to procedures as described in the FSAR. It was noted that the licensee has established administrative controls for such changes and these controls do not conflict with 10 CFR 50.59 requirements.
8.
Procedure Chan es Resultin From License Amendments Licensee Amendments (18 through 25), which included Technical Specification (TS) changes, were reviewed to verify that applicable procedures were revised as necessary to reflect these
'changes.
During this review, it was observed that several procedures did not reflect current TS requirements.
This is addressed in Paragraph 5.c.
No items of noncompliance were identified.
9.
Review of Re ortable Occurrences a 0 An in-office review of Licensee Event Reports submitted during 1977'nd 1978 indicated that several instruments had drifted on a repetitive basis in the nonconservative direction with respect to Technical Specification (TS). limits.
The instruments involved were as follows:
Reactor Low Low Low Water Level (RE-18A through D); Vacuum Relief Suppression Pool to Reactor Building (68-12 A and B); Main Steam High Flow Isolation (RE-22 A through H);,and High Drywell Pressure (RE-04 A through D).
An onsite review of the calibration procedures and associated data for the-above instruments (except for High Drywell Pressure Instruments)
was conducted for.the period January 1,
1977, to the present.
Recent LER's on High Drywell Pressure were reviewed during Office of Inspection and Enforcement Inspection No. 50-220/78-17.
As a result of this review, it was determined that the setpoints in the calibration procedures for High Drywell pressure and Main Steam High Flow Isolation were at the TS limits.
Therefore, any instrument drift, which is expected for the types of instruments, could be in the nonconservative direction with respect to the TS limit.
This indeed occurred as documented by the various LER's on these two instruments.
During the inspection, the licensee revised the associated calibration procedures to specify conservative setpoints such that a nonconservative tolerance applied to these setpoints would yield a value not to exceed the TS limits.
Revision 4, October, 1978, to ISP-RE-04, High Drywell Pressure Instrument Channel Test/Calibration and Revision 5, October, 1978, to ISP-RE-22, Main Steam High Flow Instrument Channel Test/Calibration were issued to incorporate these conservative setpoints.
The calibration to these new setpoints were conducted October 28-29, 1978.
The inspector considered this acceptable and this action closes Unresolved Item (220/78-17-01)
on High Drywell Pressure.
The calibration procedures for, Vacuum Relief Suppression Pool to Reactor Building and Reactor Low Low Low Water Level Instrumenta-tions have setpoints, including drift tolerances, that are conservative with respect to TS limits, but these values are close to the TS limits due to operational considerations.
These instruments were the subject of instrument drift LER's in relatively few instances within the past two years.
The licensee representative stated the present frequency schedule is adequate to insure early detection of instrument drift and that any further con'servatism in this setpoint would adversely effect the operational capabilities of the plant.
The inspector considered this acceptable.
This will be reviewed in subsequent inspection d.
The inspector also reviewed the circumstances associated with a prompt report (LER No. 78-35, dated October 28, 1978).
This report identified that the setpoint for all channels of Main Steam High Flow transmitters were less conservative than the TS limit due to a test pressure gage being out of calibration.
Subsequent review by the licensee revealed that this was erroneous.
The test gage was indeed out of calibration, but it was in a conservative direction.
Therefor e, the setpoints for the Main Steam High Flow Transmitters were conservative with respect to the TS limit.
The licensee has reviewed the usage file for the subject test gage and has concluded no other safety related instruments were affected.
Investigation continues on why the test gage was out of calibration.
This will be the subject of the 2 week followup report.
The inspector had no further questions.
10.
Unresolved Items Unresolved items are findings about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations, An unresolved item disclosed
'uring the inspection is discussed in Paragraph 5.c.
11.'xit'Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on October 27, 1978', to suamarize the purpose, scope, and findings of the inspection.
Subsequent discussions of inspection findings occurred in telephone conversations between Mr.
R. Conte, NRC:RI and Mr.
C. Stuart, on October 30, 1978 and between Mr N. Blumberg, NRC:RI and, Mr. T.
Perkins, on October 31, 1978.