IR 05000220/1981017

IE Insp Rept 50-220/81-17 on 810701-31.Noncompliance Noted: on 810729,emergency Cooling Insolation Logic key-lock Switches Found Placed in Bypass During Troubleshooting on Vent Radiation Monitor 122

ML17053C848
Person / Time
Site:	Nine Mile Point
Issue date:	08/14/1981
From:	Doerflein L, Sharon Hudson, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17053C849	List: IR 05000220/1981017
References
50-220-81-17, NUDOCS 8109240581
Download: ML17053C848 (22)

Text

Report No

17 Docket No.

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U.S.

NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I DCN:

50220-810729 50220-810709 License No.

Priority Category Niagara Mohawk Power Corporation 300 Erie Boulevard Nest Syracuse, New York 13202 Facility Name Nine Mile Point Nuclear Station, Unit

Inspection at:

Scriba, New York Inspection conducted:

July 1-31, 1981 Inspectors:

S

. Hudson, e

dent pector

. 7.

P /x C

d te signed L. T. Doerflein Resident Inspector date signed Approved by:

H. B. Keister, C se, Reactor rogects Section 1C date signed JC, g

dat signed Ins ection Summar:

Ins ection on Jul 1,

1981 to Jul 31, 1981 Ins ection Re ort No. 50-220/81-17 Areas Ins ected:

Routine, onsite, regular and backshift inspections by the resident nspectors

ours).

Areas inspected included:

licensee action on previous inspection findings, operational safety verification, physical security, plant tours, surveillance tests, maintenance activities, licensee action on I8E Bulletins, followup on plant trips and followup on licensee events.

Results:

Of-the nine areas inspected, no items of noncompliance were identified anne g t areas.

One item of 'noncompliance was identified in one area:

(Bypassing all automatic isolation protection on both Emergency Cooling Systems and failure to follow administrative procedures for the removal of equipment from service)

Region I Form 12 (Rev. April 77)

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DETAILS Persons Contacted R. Abbott, Supervisor, Operations K. Dahlberg, Site Maintenance Superintendent W. Drews, Superintendent of Technical Services J. Duell, Supervisor, Chemistry'

Radiation Protection E. Leach, Superintendent of Chemistry E Radiation Management T. Perkins, General Superintendent, Nuclear Generation T. Roman, Station Superintendent M. Silliman, Technical Superintendent B. Taylor, Supervisor, Instrument and Control The inspector also interviewed and talked with other licensee personnel during the course of the inspection including shift supervisors, administrative, operations, health physics, security, instrument and control, and contractor'ersonnel.

Licensee's Action On Previous Ins ection Findin s (Closed)

UNRESOLVED ITEM (80-19-02):

Determine the applicability of the Office of Nuclear Reactor Regulation's (NRR) interim position on containment vent and purge valves.

The inspector discussed the

.

applicability of NRR's interim position on containment vent and purge valves with the Licensing Project Manager assigned to this plant. It was determined that the primary concern was the operability of the large (20-24)inch) butterfly-type valves.

There is no requirement to limit the opening of 4 inch air operated globe valves.

The inspector also reviewed Operating Procedure Nl-OP-9, "Nitrogen Inerting and H2-02 Monitoring for the Primary Containment and Pressure Suppression System," Revision 5, dated January 30, 1981 and determined that administrative controls are established that prohibit bypassi,ng both

'ontainment isolation signals during power operations.

(Closed)

UNRESOLVED ITEM (81-13-02):

Review the licensee's position allowing the shift supervisor to leave the control room during a fire.

10CFR50, Appendix R prohibits the shift supervisor from being a member of the fire brigade.

However, it is the NRC's position that he may go to the scene of the fire to consult with the fire brigade as an aide in assessing its effect on plant operation.'he inspector reviewed Emergency Plan Implementing Procedure No. EPP-2,'Fire Fighting,"

Revision 5, dated April 29, 1981 and has determined that it meets the guidelines stated above.

(Closed)

INSPECTOR FOLLOW-UP ITEM (80-05-07):

Surveillance test procedure and its data sheets were inconsistent.

The inspector reviewed Operator Surveillance Test Nl-ST-W4, "Main Steam Line High Radiation Instrument Channel Test," Revision 4, dated October 2, 1980

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and verified that it has been revised to include in both the test procedure and its data sheets the prerequisite step of recording the radiation monitors set point prior to beginning the test.

(Closed)

UNRESOLVED ITEM (80-14-01):

Minimum Emergency Condenser Make-up Tank level should be 9 ft.

The inspector reviewed Operator Surveillance Test No. Nl-ST-DO, "Daily Checks," Revision 6, dated October 24, 1980 and determined that it correctly specifies the correct tank level.

He also verified that the Emergenoy Condenser Make-up Tank Level Indications (LI 60-09B + 10B) have been recalibrated and marked to show a minimum level of 9 ft.

3.

0 erational Safet Verification a.

Control Room Observations Routinely throughout the inspection period, the inspector indepen-dently verified plant parameters and equipment availability of engineered safeguard features against a plant specific checklist to ensure compliance with the limiting conditions for operation (LCO's).

I The plant specific checklist has been developed to assist the inspector in ensuring the following items are obser'ved during control room tours:

Switch and valve position required to satisfy the LCO's Alarms or absence of alarms Meter indications and recorder values Status lights and power available lights Front panel bypass switches Computer print-outs Comparisons of redundant readings Mode switch in the proper position Selected lit annunciators were discussed with control room operators to verify that the reasons for them were understood and corrective action, if required, was being taken.

Shift turnovers were observed to ensure proper control room and shift manning on both day and back shifts.-

Shift turnover checklists and log review by the oncoming and off-going shifts were also observed by the inspector.

The inspector also independently verified that selected jumpers and lifted leads had been correctly installed and removed.

On a

sampling basis, the inspector reviewed equipment tag-outs to verify that the limiting conditions for operation were met when safety-related equipment was removed from servic "

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On July 16, 1981, the inspector noted several of the average power range monitor gain adjustment factors (AGAF's) were slightly greater than one.

This indicates that the average power range monitors (APRN's) are indicating less than the actual percentage of core thermal power.

This is a nonconservative reading.

The reactor protection system uses these indications as the inputs into the APRM scram trip circuit.

The inspector identified his concern to the licensee, who took immediate action to adjust the APRN's indication to less than or equal to actual percentage of core thermal power.

During subsequent daily inspections, the resident inspector has confirmed that the APRM's are properly adjusted.

b.

Review of Lo s and 0 eratin Records The inspector reviewed the following logs and instructions for the period July 1 through July 31, 1981:

The Control Room Log Book Station Shift Supervisor's Log Book Station Shift Supervisor's Instructions Licensee Event Report Log Jumper and Lifted Leads Log Hook logs and instructions were reviewed to:

Obtain information on plant problems and operation; Detect changes and trends in performance; Detect possible conflicts with technical specifications or regulatory requirements; Determine that records are being reviewed as required; Assess the effectiveness of the communications provided by the logs and instructions; and Determine that the reporting requirements of technical specifications are met.

No items of noncompliance were identified.

4.

Observation of Ph sical Securit The inspector made observations and verified during regular and off-shift hours that selected aspects of the plant's physical security system were in accordance with regulatory requirements, physical security plan and approved procedures.

The'following observations relating to physical security were made:

The security force on both regular and off-shifts was properly manned and appeared capable of performing their assigned functions.

Protected area barriers were intact, - gates and doors closed and locked if not attende I

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Isolation zones were free of obstructions and objects that could aid an intruder in penetrating the protected area.

Persons and packages were checked prior to entry into the protected area.

Vehicles were properly authorized, searched, and escorted or controlled within the protected area.

Persons within the protected area displayed photo-identification badges, persons in vital areas were properly authorized, and persons requiring escort were properly escorted.

Compensatory measures were implemented during periods of'quipment failure.

No items of noncompliance were identified.

5.

Plant Tours a.

~Sco e

During the course of the report period, the inspector made multiple tours of plant areas to make a independent assessment of equipment conditions, radiological conditions, safety and adherence to regulatory requirements.

The following areas were among those inspected:

Turbine Building Auxiliary Control Room Vital Switchgear Rooms Yard Areas Radwaste Area Diesel Generator Rooms Screen House Reactor Building Refueling Area-Drywell b.

~Findfn e

The following determinations were made:

(1)

Monitoring instrumentation:

The inspector verified that selected instruments were functional and demonstrated parameters within Technical Specification limits, and that stack gas and building ventilation monitor recorders showed no abnormal releases.

(2)

Radiation protection controls:

The inspector verified that the licensee's Radiation Protection procedures were adhered to at the time of observation in the following areas:

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Access control including tagging, posting and maintenance of step-off pads.

(b)

Confirmation of licensee survey results by independent measurements.

(c)

Verification that requirements of Radiation llork Permits are appropriate and are being followed.

(3)

Plant housekeeping:

Observations relating to plant housekeeping identified no unsatisfactory conditions.

(4)

Fluid leaks:

No significant fluid leaks'were observed.

(5)

Fire protection:,

The inspector verified that selected fire extinguishers were accessible and inspected on schedule, that fire doors were unobstructed and that adequate controls over ignition sources and fire hazards were maintained.

6.

Surveillance Tests During the inspection period, the inspector witnessed the performance of various surveillance tests.

Observations were made to verify that:

Surveillance procedures conform to technical specification requirements and have been properly approved.

Test instrumentation is calibrated.

Limiting conditions for operations for removing equipment from service are met.

Testing is performed by qualified personnel.

Surveillance schedule is met Test results met technical specification requirements.

Appropriate corrective action is initiated, if necessary.

Equipment is properly restored to service following the test.

The following tests were included in this review:

"High Level Scram Discharge Volume Instrument Channel Calibration,"

Nl-ISP-RD-08, Revision 6, dated June 10, 1981.

."Stack Isotopic and Release Records,"

Nl-CRP-2, Revision 3, dated January 5, 1981.

The inspector witnessed the computation of the average daily release rat S

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"Reactor Protection System - Auto Trip System Instrument Trip Channel Test/Calibration,"

Nl-ISP-RPS-TP, Revision 8, dated June 17, 1981.

The inspector witnessed the instrument trip test on main steam line break instruments 801-26E, F, and H.

"Turbine Anticipating Trip-Bypass Reactor Scram Instrument Channel Test/Calibration," Nl-ISP-IC-02-13, Revision 4, dated September 1980.

"LPRM Detector V/I Plot," Nl-IMP-NEU 4.2, Revision 0, dated September 1980.

While observing the LPRM Detector V/I Plot, the inspector noted that the digital volt meter (DVM) being used was overdue for recalibr ation.

The inspector also verified that since the DVM's calibration had expired on June 9, 1981, it had been used during three other surveillance procedures.

(Source Range Monitor Instrument Channel Calibration, Nl-IMP-NEU 1.1, performed June 29, 1981; Reactor Recirculation Flow Comparotor Calibration, Nl-ISP-IC-26, performed July 5, 1981; and Intermediate Range Monitor Instrument Channel Calibration, Nl-ISP-NEU-2, performed July 6, 1981).

The licensee stated that the DVM would be sent to be calibrated and based on the results of the calibration, the licensee will determine whether or not the three surveillance procedures, in which the out of calibration DVM was used, were performed satisfactorily and the specified testing intervals were met.

This item is unresol,ved pending licensee action and subsequent NRC review.

(220/81-17-03)

7.

Plant Maintenance During the inspection period, the inspector observed various maintenance activities.

The inspector reviewed these activities to verify that:

Technical Specification requirements for removal of equipment from service are met.

Appropriate radiological controls were established and properly implemented.

Required equipment mark-ups were obtained';

Work is performed in accordance with approved procedures or the activity is within the "skills of the trade".

The following activities were included during this review:

Repair of the Emergency Condenser Drain Isolation Valves 839-12 and 39-1 P

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Troubleshooting

¹122 Emergency Condenser Vent Radiation Monitor On July 29, 1981, while witnessing the troubleshooting on ¹122 Emergency Condenser Vent Radiation Monitor, the inspector noticed that both Emergency Cooling isolation logic key-lock switches had been placed in "by-pass".

About 9:15 a.m., the inspector notified the shift supervisor, who immediately ordered that the key-lock switch for the ¹11 Emergency Cooling System be returned to "normal".

The inspector reviewed reactor protection system logic drawing

¹C-19859-C and determined that each key-lock switch (¹ll and 12)

by-passes all automatic isolation signals for its respective Emergency Cooling System (¹11 and 12).

The ¹12 key-lock switch was returned to "normal" at 9:45 a.m.

Through discussions with operating personnel, the inspector determined that both key-lock switches had been placed in "by-pass" about 8:50 a.m.

Technical Specifications Table 3.6.2c,

"Instrumentation that Initiates or Isolates Emergency Cooling," states that the minimum number of tripped or operable trip systems required for isolation of each Emergency Cooling Systems is one for the Emergency Cooling Vent Radiation Monitors and two for the Emergency Cooling System Steam Line High Flow.

Placing the key-lock switches in "by-pass" defeats all automatic isolation protection for these systems.

As a result, no trip systems were operable for either Emergency Cooling System.

The defeating of these automatic isolation functions designed to limit a release of radioactive material to the.--

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environment is considered to be an item of noncompliance. (

The inspector observed that the licensee made a prompt notification to the N.R.C. Operations Center as required by 10 CFR 50.72.

He has also documented this event as Licensee Event Report ¹81-36.

The inspector reviewed the Equipment Status Log and determined that no entry had been made regarding the removal of ¹122 Emergency Condenser Vent Monitor from service.

Through discussions with the personnel involved, the inspector determined that the shift supervisor had not reviewed the applicable technical specifications but relied on his memory.

The assistant shift supervisor was not aware that the monitor was being removed from service.

Administrative Procedure APN-2A, "Conduct of Operations and Composition and Responsibilities of Station or Unit Organization,"

Revision 5, dated February 20, 1981 requires that an Equipment Status Log be maintained.

Section 4.2 of APN-2A states:

"A log of all station equipment which may limit station output or which must be normally operable as defined in Technical Specifications or which may require cognizance of guality Control prior to placing in service shall be maintained in the Station Shift Supervisor's office whenever the equipment or system is not capable of performing its intended function in its required manner.

The Status Log shall include the following:... d) Applicable Tech.

Spec.

paragraph, and verification of review."

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The failure to meet the requirements of Administrative ProcedureAPH-2A lis considered to be part of the i.tern of noncompliance'.

(220/81-17-01')

Through discussions with the licensee, the inspector determined that a review of the event has been conducted with the Operations Department personnel involved.

Other planned actions to prevent a recurrence include:

l.

A written instruction to all shift supervisors and shift technical advisors reminding them of the significance of the event; 2.

A revision to the operating procedure to clarify the purpose and use of the switches; and 3.

A review of the event with all Operations Department personnel as part of the regular training program.

In February 1981, a similar event occurred when a main steam line radiation monitor was removed from service.

This reduced the minimum number of operable instrument channels to less than that required by technical specifications.

t 8.

Followu on Licensee Event On Jul

1981 at about 1 :00 a.m., reactor water conductivity and chloride ion concentration exceeded the Technical Specification Limits of 10 micromhos per centimeter (+mho/cm)-and 0.5 parts per million (ppm) respectively.

Conductivity peaked at 15.5 p mho/cm and the chloride ion concentration peaked at approximately 1.4 ppm.

The high conductivity and chloride ion concentration was due to placing no.

13 reactor feedwater pump in operation which injected a slug of high conductivity water into the reactor vessel.

The high conductivity water apparently remained after a hydrostatic test of a replaced feedwater heater during which a personnel error introduced service water into the feedwater system.

Reactor Mater Cleanup System flow was maximized and the conductivity was reduced to less than

p mho/cm at about 2:30 a.m.

on July 9, 1981.

The chloride ion concentration was reduced to less than 0.5 ppm at about 4:00 a.m.

on July 9, 1981.

A review of the event indicated a large difference between the control room conductivity recorder and the lab analysis (greatest difference was 7.454mho/cm).

The control room conductivity recorder did not indicate that the reactor water conduc-tivity had exceeded 10gmho/cm.

The licensee calibrated the conduc-tivity recorder and commenced performing daily comparisons between the control room conductivity recorder and the lab analysis of reactor water conductivity.

Since the conductivity recorder was calibrated it appears to be in agreement with the sample results.

The licensee reported the event as Licensee Event Report 081-3 P<<IHI( I hhs s'

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Followu of a Plant Tri On July 5, 1981 at 12:26 a.'m. the reactor tripped from approximately 20 percent power due to low water level in the reactor vessel.

The apparent cause of the low water level was a failure in the High Pressure Coolant Injection (HPCI) controller.

The'trip occur red in the course of a plant startup during which the main turbine was manually tripped to correct a turbine vibration problem.

The HPCI mode of the feedwater system is designed to regulate feedwater flow to the reactor vessel to maintain water level for either a main turbine trip or a low water level in the reactor vessel.

When the turbine was tripped the HPCI controller assumed control of the feedwater regulating valves.

However, due to an apparent time lag in the response of the HPCI controller, the feedwater regulating valves momentarily went shut causing the low water level.

After the scram the HPCI controller responded properly and maintained reactor water level.

The licensee replaced the HPCI controller and is continuing to investigate the problem with the original HPCI controller.

10.

Ins ection and Enforcement Bulletins Licensee action concerning the following Inspection and Enforcement Bulletins (IEB) was reviewed to verify that:

Written response was within the stated time period and contained the required information;

'ritten response includes adequate corrective action commitments; Licensee management forwarded copies of the written response to appropriate onsite management; Information discussed in the licensee written response was adequate; and Corrective action taken by the licensee was as; described in the written response.

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IEB 80-13, "Crackin in Core S ra S ar ers" The inspector reviewed the licensee's response dated Hay 13, 1981.

A visual examination of the core spray spargers was performed during the 1981 refueling outage.

A regional-based inspector conducted a

review of the video tapes to examine the crack indication area and verify acceptability visual clarity.

The results of this inspection are documented in Inspection Report 850-220/81-09.

Prior to start-up of the plant, the NRC reviewed the licensee's evaluation that the two observed cracks are minor and have no appreciable effects on the structural integrity or hydraulic performance of the system.

It was also determined that no repairs are required at this time.

The licensee has committed to inspect the core spray spargers during the 1983 refueling outage.

This Bulletin is close y'

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"En ineered Safet Feature (ESF)

Reset Control" Item 2 of this Bulletin requires the licensee to perform tests to demonstrate that all equipment remains in its emergency mode upon removal of the actuating signal and/or manual resetting of the various isolating or actuation signals.

The inspector reviewed the following surveillance tests to verify compliance with the above requirement:

"Secondary Containment Leak Rate and Reactor Building Emergency Ventilation System Operability Test," Nl-ST-C5, Revision 5, dated March 13, 1981, performed on June 27, 1981.

"Loss of Coolant and Emergency Diesel Generator Simulated Automatic Initiation Test," Nl-ST-R2, Revision 3, dated June 18, 1981, performed on June 30, 1981.

"High Radiation Emergency Cooling System Vent Monitors Instrument Channel Test," Nl-ST-R7, Revision 1, dated September 13, 1978, performed on July 1, 1981.

"Automatic Initiation of Off-Gas Isolation Valves,"

Nl-ST-C8, Revision 2, dated December 10, 1980, performed on June 19, 1981.

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equipment.tested remained in the proper position after removal and/or resetting of the appropriate signals.

The inspector noted the tripping and isolation of the mechanical vacuum pumps and the automatic depressurization system had not been tested.

The licensee stated test procedures would be prepared promptly and additional testing performed during the next plant outage to cold shutdown after the procedures had been written and approved.

This Bulletin remains open pending review of the additional testing.

11.

Exit Interview At periodic intervals during the course of the inspection, meetings were held with senior facility management to discuss the inspection scope and finding kq q f I h q

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