IR 05000220/1989033
| ML17056A682 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/08/1990 |
| From: | Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A680 | List: |
| References | |
| 50-220-89-33, 50-410-89-22, NUDOCS 9003160296 | |
| Download: ML17056A682 (36) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION Region I 50-220/89-33 Report Nos.:
50-410/89-22 50-220 Docket Nos.:
50-410 DPR-63 License Nos.:
NPF-69 Licensee:
Niagara Mohawk Power Corporation 301 Plainfield Road Syracuse, New York 13212 Facility:
Nine Mile Point, Units 1 and
Location:
Scriba, New York Dates:
Inspectors:
Approved by:
December 14,1989 through January 31, 1990 W. A. Cook, Senior Resident Inspector R.
R.
Temps, Resident Inspector R. A. Laura, Resident Inspector R. J. Paolino, ad Reactor Engineer enn W. Meyer, Chief Reactor Projects Sectio o.
1B-7Q Date Ins ection Summar This inspection report documents routine and reactive inspections during day and backshift hours of station activities including:
plant operations; radio-logical protection; surveillance and maintenance; emergency preparedness; security; engineering and technical support; and safety assessment/quality verification.
Results:
The inspe'ctors identified two violations at Unit 1.
V-type electrical cable splices were found to be unqualified per
CFR 50.49, and system configuration controls were found to be in violation of station procedures.
An Executive Summaiy follow Executive Summar Plant 0 erations (Modules 71707, 93702)
At Unit 1, inspection effort during this period focused on core reload activities.
Reload preparations were deter-mined to be thorough and deliberate, as was the actual fuel loading, with one significant exceptions The movement of fuel in a
quadrant with the source range monitor in bypass indicated poor control of system operability.
A viola-tion was identified with respect to control of this event.
Niagara Mohawk's self-assessment of this event also had some weaknesses.
Unit 2 was shutdown much of this inspection period to repair feedwater pumps.
Niagara Mohawk aggressively pursued resolution of this problem, and repair activities observ'ed were well executed.
Preliminary assessment of the January
Group 5,
7, and
containment isolations indicate a
continuing problem with plant impact assessments and personnel errors.
Radiolo ical Protection (Module 71707)
Routine review of this area identified no noteworthy findings.
Surveillance and Maintenance (Modules 61726, 62703)
Observations of hydro-static testing at Unit 1 indicates these tests are being adequately controlled; however, the inspectors endorse Niagara Mohawk development of a testing guid-ance instruction based upon their findings and discussion with test personnel.
Maintenance and surveillance testing observed at Unit
was generally well executed.
Emer enc Pre aredness (Module 71707)
Review in this area identified no note-worthy findings.
~Securit (Module 71707)
Routine review in this area identified no noteworthy findings.
En ineerin and Technical Su ort (Modules 71707, 90712, 92700)
Specialist inspector review of a previously.unresolved item (50-220/89-17-01)
concluded that there was a violation of 10 CFR 49 for non-qualified 3 wire V-'ype splice configurations.
Closeout of the NRC review of the Unit 1 restart issue invol-ving degraded fire barrier penetrations is complete with the closeout of viola-tion 50-220/88-15-01 AEB.
Review of Niagara Mohawk's response to violation 50-410/89-05-02, failure to perform a
CFR 50.59 evaluation, identified some additional inspector concerns about a non-conservative Technical Specification interpretation.
Safet Assessment/ ualit Verification (Modules 71707;30703)
Safety Review and Audit Board (SRAB review of station activities was deemed to be thorough and probing.
A review of the Fitness for Duty training provided to station employees was considered to be satisfactor DETAILS 1.
'Plant 0 erations Unit 1.
During this inspection period the unit remained in cold shutdown.
Reload-ing of fuel was commenced on January 3 and completed on January 18.
Upon completion of reload, preparations continued to support unit restart.
a
~
The inspector reviewed and discussed with the control room operators the applicable surveillance, operating and fuel handling procedures used to verify and maintain system operability and to control the reloading evolutions.
No procedural discrepancies were noted and operators appeared to be familiar with the reload prerequisites and controlling procedures.
In addition to the selected area reviews of Niagara Hohawk's prepara-tions for reload of Unit 1, as documented in the previous two resi-dent office inspection reports, the inspectors observed the Site Operations Review Committee (SORC)
review and deliberation of Unit
reload preparations.
The SORC review of unit, reload readiness was focused upon the, completion and acceptance of the N1-88.6 series temporary procedures (TPs).
These one time use TPs documented the necessary 'eload requirements and noted exceptions following the extended refueling outage at Unit 1.
The inspectors attended several SORC meetings between December 20'and
and made the following observations:
SORC members did not ini-tially have a clear objective or understanding of their responsibi 1-ities for review of the N1-88.6 series procedures; TPs presented for SORC review were not available in advance of the meeting for SORC member preparation; SORC meetings were well attended and, in spite of an initial lack of clear purpose and preparation, the member par-ticipation was good and discussion items were thoroughly examined.
These observations were discussed with the SORC chairman, who agreed with the findings and indicated that the planned SORC review of the N1-88.7 series, Restart Preparation TPs, would be better planned and more efficiently executed.
C.
Reload operations commenced on January 3,
1990.
The resident inspec-,
tors provided expanded coverage for the first few days, of reload activities.
Reload was completed on January 18.
The inspectors con-cluded that, for the most part, the reload was carried out in a
deliberate and conservative manner.
Personnel on the refueling bridge and in the control room performed their tasks competently, and there was good cooperation and communication between the groups involved in reloa However, one incident occurred during reload, on January 15, in which the toggle switch for the Source Range Monitor (SRN)
14 was found in the bypass condition when it should have been unbypassed following repairs to the SRM circuitry.
The sequence of events leading to this event were as follows:
J~anuar
2:30 a.m.
SRM 14 alarmed on short period trip and was placed in bypass.
(SRM indication remains available, but the SCRAM, rod block and annunciator alarm functions are disabled.)
2:50 a.m.
Fuel moves were halted and the Reactor Protection Sys-tem (RPS)
was. returned to coincident logic while troubleshooting and repairs were made to SRN 14.
5:30 a.m.
Repairs were completed to the SRM (relay replaced)
and post-maintenance test was completed satisfactorily.
Fuel moves commenced shortly ther'eafter.
7:00 a.m.
During shift change, the offgoing station shift super-visor (SSS)
briefed his relief on SRM problems, and stated that he was awaiting the work request.
7:45 a.m.
Work request
¹172523 arrived in the control room (CR).
The SSS accepted the SRN as operable, but neglected to tell the chief shift operator (CSO)
to take the SRN out of bypass.
3:00 'p.m.
The offgoing SSS briefed oncoming SSS that the SRM was operable.
The offgoing SSS assumed the SRM was taken out of bypass.
5:30 p.m.
10:46 p.01.
11:07 p.m.
Fuel loading commenced in the same quadrant as SRM 14.
The loading of 18 fuel assemblies in the same quadrant as SRM 14 was completed.
The oncoming shift which originally bypassed the SRM noted SRM 14 was bypassed and unbypassed it.
11:30 p.m.
A preliminary assessment by SSS and assistant opera-tions superintendent determined that there was no Technical Specification (TS) violation with SRN
bypassed.
Fuel reloading recommenced.
Neither the oper'ati ons superintendent, nor unit superintendent were informed of the proble ~Januar
9:00 a.m.
The'nit superintendent, upon reviewing this event and examining the TS, decided to suspend further fuel movement pending a
root cause investigation of the entire event.
During the inspector's initial review of the event, as well as the unit superintendent's, it appeared that TS 3.5.3 had been violated.
Fuel movement in the quadrant covered by SRM 14, while the detector was in the bypass condition, appeared to contradict TS 3.5.3.b which states that when core alterations are being performed the SRM in the effected quadrant and one SRM in an adjacent quadrant must be operable.
The inspectors determined that with the detector bypassed, the source range counts readout was still functional and able to be monitored by the operators during fuel movements as required by procedures.
Plac-ing the SRM in the bypassed condition defeated the rod block, scram, and annunciator alarm functions.
While the annunciation of alarm functions is important, the requirement for operators to continuously monitor source range instruments during fuel movement somewhat ameliorates bypassing of the alarm functions.
The rod withdrawal block function, while required by TS Table 3.6.2.g to be operable in the REFUEL mode, serves no practical safety function during core reload and is redundant to the mode switch and refuel bridge control rod withdrawal block functions.
Lastly, although the scram function was bypassed, the TSs do not address this function, but do require the intermediate range and average power range monitors'cram func-tions to be operable during refueling operations.
As a result, the safety significance of this event was low because SRM indication remained available'perators were required to mon-itor the SRM counts during fuel movement and would observe any increase in count rate.
This method of protection is consistent with statements in the TS bases for Section 3.5, 1 and 3.5.3 which equate detector operability with the ability to monitor SRM count rate.
Additionally, this is consistent with information contained in the Safety Evaluation Report for TS Amendment 27.
Regarding the SRM scram function, this was the first time that core reload has been performed with this protection available'his was due to the fact that reload was performed with the reactor protection system (RPS) in the non-coincident logic mode.
By plant design, this enables the scram function of the SRM circuitry such that any one of the four SRMs are capable of generating a full scram.
Niagara Mohawk
chose to conduct the reload in the non-coincident mode to be consis-tent with recommendations made by General Electric for off-center spiral reload of the core.
Although bypassing SRM
and loading fuel in its quadrant defeated the intent of the GE recommendations, the Unit
TS do not require, nor do they address, that the SRM scram function be operable in any mode of operation.
The inspectors con-cluded that TSs were not violated by loading fuel in the quadrant covered by SRM 14 while the SRN was bypassed.
Inspector review of the issues involved in this event raised the following concerns:
1.
The inspectors were concerned with the performance of operators in the control room.
First, the day shift SSS was remiss in that he failed to ensure that SRM
was taken out of bypass when the work request was -cleared.
Subsequently',
he misled his relief (SSS) to the effect that the SRM was operable.
Addition-ally, the fact that none of the chief shift operators (CSOs)
on watch questioned why the SRM was still in bypass caused us to question their control board awareness and maintenance of a
questioning attitude.
It is to the oncoming CSO's credit (at ll:07 p.m.) that he noticed that SRM 14 was still bypassed and brought this to the attention of his SSS.
The inspectors are concerned about the manner in which bypassing of SRM
was controlled.
Procedure AP-4.0, Administration of Oper'ations, revision 13, states that when a
change to a
system configuration is required that is not within the scope of an approved operating, surveillance, or special test procedure, it shall be controlled in accordance with the Equipment Markup Pro-cedure, AP-4.2.
Specifically, off normal positioned valves, breakers and control switches shall be tagged with yellow hold out tags if for equipment protection or other administrative reasons.
Contrary to these requirements, the inspectors deter-mined that:
(a)
On January 15, the bypass switch for SRM 14 was not tagged with a yellow hold out tag when placed in the bypass condi-tion due to a malfunction, (b)
On January 24, the inspector identified nine pump switches in the pull-to-lock position that were not tagged with yellow hold out tags or otherwise controlled per procedure.
This is a violation of the requirements of AP-4.0.
VIOLATION (50"220/89-33-01)
3.
The inspectors were concerned that in Niagara Mohawk's initial assessment of this event, they did not identify that bypassing of the SRM was not done per AP-4.0 and that Revision
to AP-4;0 was not being properly implemented at Unit 1.
Revision
had become effective on October 9,
1989, and had clarified the control of hold out tags as to their use on off normal controls.
In developing this concern the inspectors toured the Unit 1 and 2 control rooms and interviewed licensed operators to determine if they understood the requirements of AP-4.0.
At Unit 2, the inspectors identified that the requirements of AP-4.0 were being adhered to and that the operators had a
good understanding, of Revision 13 to AP-4.0 and the reasons behind its issuance.
This was in contrast to the inspectors'indings at Unit 1.
Opera-tors w'ere not familiar with the yellow hold out requirements imposed by Revision 13 to AP-4.0.
Niagara Mohawk appeared to have missed an important aspect of off normal equipment control when developing the root causes for this event.
This is an example of poor problem identification and self assessment.
However, unit management did take prompt action to attempt to better understand the root causes for this event after being apprised of the problem on the morning of January 16.
The inspectors were concerned with the lack of or ineffective training conducted by Niagara Mohawk on procedure revisions.
As discussed above, Unit
operators were not familiar with Revision 13 of AP-4.0.
A recent emergency preparedness inspec-tion ( Inspection 50-220/90-01 and 50-410/90-01)
also identified
.a similar training deficiency with the station communicators'nowledge of a recently revised Emergency Plan, emergency notif-ication procedure, S-EPP-20.
Similarly, a
recently revised radiation work permit program was implemented without thorough station employee training and familiarization.
Collectively.,
these events indicate poor preparation of station employees for procedure revisions and policy changes which directly impact safety related activities.
1.2 Unit 2 The unit was returned to power on December'5 following the repack of valve 2MSS*V1A and the repair of 2GTS*MOV2A actuator.
The unit remained at power until December
when all.three feedwater pumps developed unacceptable vibration and/or mechanical leakage problems.
The unit was shutdown and remained shutdown through the end of this inspection period to repair the feedwater pump On January 28, the unit experienced a Group 5, 7 and 10 contain-ment isolation initiation from the Division II leak detection system.
This occurred during the performance of a calibration of the spent fuel pool heat exchanger room high temperature trip unit.
The trip unit failed upscale during the calibration and was declared inoperable.
After conferring with the assistant station shift supervisor (ASSS)
and chief shift operator (CSO),
the I&C technician restored the isolation bypass switch to the normal position with the trip unit removed.
This action resulted in a
residual heat removal system isolation, reactor core isolation cooling system isolation and a
reactor water cleanup system isolation, Groups 5,
and 10, respectively.
The inspector identified two concerns.
The first concern is that the IKC technician aborted the procedure and attempted to restore the system to normal based on his knowledge rather than researching and verifying from electrical prints or gaining assistance from IEC supervision.
The second concern was that the ASSS and CSO also relied on the IKC technician's knowledge rather than independently verify the impact of his proposed course of action.
In addition, the SSS was not informed or involved in the decision of how to restore the system to normal.
The corrective actions taken by Niagara Mohawk were still being developed at the conclusion of the inspection period and wi 11 be reviewed upon issuance of the associated Licensee Event Report (LER).
The inspectors performed a tour in the drywell and found this area to be clean and in good material condition.
(Closed)
Unresolved Item (50-410/89-14-01):
Positive procedural controls of the feedwater runback inhibit switch were not incor-porated into the feedwater operating procedure.
The inspector reviewed Operating Procedure
(OP3)
and found that Niagara Mohawk issued a Temporary Change Notice (TCN) which added a pre-caution to only use the inhibit switch during surveillance test-ing of the system.
The TCN did not address the verification of the switch position in the system lineup section of the proced-ure.
This was brought to the attention of operations management who committed to issue another procedure change to incorporate the required switch position in the system lineup checklist.
This item is close }%
d.
(Closed)
Violation (50-410/89-05-01):
The reactor protection system minimum number of channels for main steam line radiation monitors were less than that required by TS.
Niagara Mohawk admitted to the violation as stated.
This violation was caused by personnel error.
LER 50-410/89-13 contained the corrective actions taken to preclude recurrence.
The inspector reviewed the LER and response to the violation and found the corrective actions to be satisfactory.
This violation is closed.
1.3
~Meetin s
On January 17, the Regional Administrator, William Russell, toured both Unit 1 and Unit 2 and met with senior Niagara Mohawk management to di scuss numerous technical issues and recent performance trends.
Mr. Russell was also briefed on the latest integrated restart schedule for Unit 1.
On January 25, a working level meeting was held on site with Niagara
~ Mohawk to discuss the status of NRC review and closeout of Unit
restart items.
The meeting was beneficial, particularly with respect to the NRC's ability to schedule future inspection activities rela-tive to Unit 1 restart.
2.
Radiolo ical Protection The inspectors monitored, station employee radiation protection practices in.conjunction with observation of surveillance and maintenance activities in the field.
No noteworthy concerns in this area were identified.
3.
Surveillance and Maintenance The inspectors observed portions of the surveillance testing and mainten-ance activities listed below to verify that the test instrumentation was properly calibrated, approved procedures were used, the work was performed by qualified personnel,
. limiting conditions for operations were met, appropriate system or component isolation was provided and the system was correctly restored following the testing or maintenance activity.
3.1 Unit
a.
Maintenance activities observed included:
Oil change out of the loop 12 core spray pumps.
Disassembly an'd repair of valve 106 on hydraulic control units (HCUs) 46-27 and 38-35 and a diaphragm replacement on the scram inlet valve for HCU 26-3 b.'urveillance testing observed included:
Nl-RPSP-9, procedure for source range monitor (SRM) dunking to check operability of SRM every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while SRM counts are less than 3 counts per minute.
Nl-FHP-25 8 27, the fuel handling procedures.
Control rod coupling checks.
Control rod scram time tests.
Grapple checks.
(The above listed surveillance tests were conducted in conjunc-tion with refueling activities.)
Other surveillance tests observed:
Nl-ISI-HYD-420, Hydrostatic test of portions of the reactor building closed loop cooling (RBCLC) system.
Nl-ISI-NYD-407, Hydrostatic pressure test of liquid poison system, observed on January 22 and January 23.
The inspec-tor noted a
few minor observations and testing practices which he questioned the test coordinator on.
Although no observations involved a
safety concern, the inspector determined that limited guidance was provided to the test-ing coordinator for the conduct of tests, such as this.
A heavy reliance was placed upon the skills and knowledge of the test coordinator to resolve unforeseen problems and testing anomalies.
Further discussion with station person-nel identified that a
testing guidance instruction.
was being prepared for implementation at the station.
The inspector had no additional concerns'.2 Unit 2 The inspector observed the following surveillance activities:
Low pressure core spray valve operability test per N2-0SP-CSL-QOOl.
Low pressure core spray pump and valve operability and sys-tem integrity test per N2-0SP-CSL-Q00 Diesel fuel oil chemistry surveillance per N2-CSP-SV.
Monthly functional test of suppression pool water tempera-
'ture indications per N2-ISP-CMS-M002.'hannel functional test of the reactor building below the refuel floor process radiation monitors per N2-RSP-RMS-M107.
During the performance of these tests, the inspector observed good procedural compliance and familiarity with the systems.
During low pressure core spray system integrity walkdowns, two minor concerns were identified.
The operator did not use a
flashlight to aid in the identification of leakage.
The inspec-tor observed the operator walking on small diameter low pressure core sppay piping to the relief valve upstream of the isolation valve.
This could potentially damage the piping/welds and con-tradicts good station work practice.
These concerns were dis-cussed with station management and the inspector will continue to monitor these areas.
b.
The inspector monitored various aspects of the feedwater pump repairs and observed that the corrective maintenance was well
. coordinated and controlled.
Significant supervisory and manage-ment oversight was evident and radiological control practices were observed to be good.
4.
Emer enc Pre aredness During the week of January 22, a specialist inspector from Region I con-ducted a
program implementation review on site.
The specialist inspec-
, tor'
findings are documented in Inspection Report 50-220/90-01 and 50-410/90-01.
The resident inspectors had no noteworthy findings during this inspection period in this arear'.
~Secuci t The inspectors observed routine site access controls including personnel and vehicle searches and adherence to vital area access requirements.
No noteworthy findings were observed.
Niagara Mohawk continued to effec-tively implement their security plan.
6.
En ineerin and Technical Su ort 6.1 Unit
a
~
(Cl osed)
Unresolved Item (50-220/89-17-01):
Qualification of the V-type stub splice configuration which differs from the test specimen qualified in Wyle Test Report No.
17722-1 and construc-tion specifications for in-line splices described in Procedure
No.
N1-EMP-44.2.
Documents (proprietary Wyle Test Report No.
17947-01)
presented to the NRC at the close of the June 16, 1989 inspection (No.
50-220/89-17)
indicated that the V-type splice configuration was qualifiable.
However, the two-wire, V-type splice configuration used as test specimens in the report did not represent the NMP-1 V-type spice configuration which uses three wires.
There was no test data or analysis to support qualification of the three wire V-type splice configuration used at NMP-1.
This item is
'
violation of
CFR 50.49(f)
and (g)
which requires that each item of electrical equipment important to safety be environmentally qualified and that qualification be completed at a time,no later than November 30, 1985.
VIOLATION (50-220/89-33-02)
Subsequent to NRC inspection 50-220/89-17, Niagara Mohawk per-formed an inspection of the suspect splices and determined that three equipment types were involved:
Rosemount transmitters; ASCO valves; and Fenwall temperature switches.
All splices to these instruments were determined to be located in enclosed con-dulets outside containment.
The worst case qualification environment for these splices was established as having a
peak temperature of 308 degrees F and a
peak pressure of 17.3 psig.
Additional testing performed by Hyle Test Laboratories (Test Report No.
17655-TPE-1.
1 dated September 8,
1989)
documents the testing of the subject splice assembly integrity in moisture saturation conditions.
All test specimens were in condulets and mounted in the horizontal position similar to the Unit 1 con-figuration.
The results of the test showed that no leakage was measured and the applied voltage was unaffected by submergence of the splice and condulet.
To enhance the splice configuration for splices in a high energy line break (HELB) environment, Niagara Mohawk is reworking these splices in accordance with the revision to specification Nl-EMP-GEN-003 which calls for inter-wire weaving of qualified sealing tape between and among the wires for additional sealing and iso-lation of the splice connection.
This unresolved item is closed based on the issuance of the violation and completion of the technical review.
Since this item was determined to be qualifiable, based on available documentation at the time of this NRC inspection and qualification was confirmed by subsequent tests, no technical response to this violation is required.
The violation response need only address the administrative aspects of the violatio b.
(Closed)
Unresol ved Item (50-220/89-17-02):
/vali f ication of D.G. O'rien penetration connectors.
Niagara Mohawk has submit-ted additional data (Wyle Test Report No. 17655-P-281, Water and Submergency Tests)
performed on D.G.
O'rien connector No.
106-16-5P/HF2, one of the test specimens (MRL-8) in the original Franklin Test Report.
This data demonstrated that the poly-urethane potting provided the primary seal for the test speci-mens.
Based on the test results, which were conducted with and without the Raychem sleeve, Niagara Mohawk concluded that the Raychem preformed boot provides strain relief only.
The Raychem sleeve was not needed to provide the moisture seal.
The test specimen exhibited the ability to maintain 660YAC between conductors.
The safety impact of electrical penetration X-E2004 is addressed in Attachment 3 to Test Report 17775-1.
Attachment 4 of this same report supports the above conclusions.
This item is closed.
C.
(Closed) Violation (50-220/88-15-01 AEB):
Adequacy of installed fire seals and failure to establish prompt corrective actions.
During the enforcement conference and in response to Part A of the violation, Niagara Mohawk specified that the following action would be taken to assure that the installed barriers are operable.
revise the fire barrier surveillance procedure, walkdown 100% of all fire bar riers to identify deficien-cies, and destructively examine a
number of penetration seals to statistically determine the adequacy of the fire barriers.
Niagara Mohawk has completed the 100%
barrier walkdown and revised the penetration surveillance procedure (NEL-805)
to address the timeliness of audits and open items.
Committees have been established to review open items status on a regular basis.
Response to audit findings by =individuals to whom they are assigned is limited to a maximum of 30 days by Revision 1 to Procedure No. NEL-80 The revised statistical sampling analysis (NMPlL-0439 dated September 29, 1989)
demonstrated the functional capability of the 156 penetrati on seal assembl ies whi ch were destructi vely examined with no failures.
The tests performed by the Underwriters Laboratories, Inc. (file no.
NC601-1,
-2, -3, and -4) demonstrated that the performance of the cable penetration fire stops in each of the four test assemblies met the requirement for a three hour fire rating in accordance with the criteria specified and provisions outlined for power generating stations in IEEE Standard 634-1978.
This violation is closed.
6.2 Unit 2 (Closed)
Violation (50-410/89-05-03):
The high pressure core spray (HPCS)
keep fill pump was removed from service without declaring the system inoperable or performing a
CFR 50.59 safety evaluation to determine that this change did not involve an unreviewed safety question.
In their response to this viola-tion, Niagara Mohawk admitted to the violation as stated.
Niagara Mohawk engineering performed a
safety evaluation (No.
89-29) to assess the effects of removing the keep fill pump from service and the utilization of an alternative method to keep the HPCS discharge piping full.
The alternative method consisted of maintaining a sufficient level in the condensate storage tank to provide hydrostatic head necessary to keep the HPCS discharge piping full.
The evaluation utilized a non-safety related level switch on the standpipe of the discharge piping and provided for venting the high point at least once per'ay to ensure the pip-ing was full.
An interim Technical Specification (TS) inter-pretation was issued and an off-normal procedure was added to the HPCS operating procedure that authorized the use of the alternative keep fill configuration.
The inspector found the alternative keep fill method to be tech-nically feasible, but considered this configuration to be non-conservative with respect to the Final Safety Analysis Report ( FSAR)
and TS intent.
The HPCS keep fill pump is a
safety related subcomponent of the HPCS system which provides continu-ous filling of the discharge piping and has supporting safety related pressure annunciation in the c'ontrol room, as discussed in the FSAR.
The alternative keep fill method utilized a
non-safety related level switch, did not provide for continuous filling,.and did not rely on a safety related annunciator in the control room.
Further, Niagara Mohawk's evaluation allowed the keep fill pump to be removed from service indefinitel r
In summary, the inspector did not consider that the alternative keep fill method provided suitable equivalent compensatory measures for an inoperable keep fill pump.
Further, the NRC Safety Evaluation Report, dated February 1985, Section 6.3.3, did not recognize an alternative keep fill method.
The inspector discussed these concerns with operations management and found them receptive and responsive to these concerns.
Niagara Mohawk committed to implement the alterna-tive keep fill system only on an emergency basis and to treat the HPCS system as TS inoperable if the keep fill pump becomes inoper-able.
This will ensure no other emergency core cooling systems are deliberately taken out of service while the HPCS system is in a
degraded configuration.
7.
Safet Assessment/
ualit Verification 7.1 SRAB Meetin Review 7.2 On January 11, the inspector attended a
scheduled Safety Review and Audit Board (SRAB)
meeting (Meeting No.
90-01)
held in Niagara Mohawk's Salina Meadows office; The inspector observed the presenta-tion of several SRAB and SRAB/guality Assurance audits to the board.
The inspector noted that some representatives of the audited Niagara Mohawk organizations were in attendance for the respective audit presentation.
Board members frequently questioned and sought clarif-ication or explanation from both the auditors and the audited parties in order to better understand the concerns and make appropriate recommendations for improvement.
The inspector considered the items reviewed by the SRAB to have been appropriately evaluated and their recommendations to the Executive Vice President of Nuclear Operations to have a proper safety perspective.
Review of Fitness for Dut Trainin During the week of December 18, the inspectors all attended the Niagara Mohawk station employee and contractors Fitness for Duty (FFD)
Program training sessions.
The inspectors used Temporary Instruction 2515/104 as a
guide to assessing the adequacy of the initial Niagara Mohawk FFD Program training.
The inspectors'ssessment of the training provided was that the lectures satisfactorily covered the fundamentals of the new
CFR Part
FFD Rule and the Niagara Mohawk FFD Policy.
The inspectors noted that limited supervisory training and escort training were pro-vided during these initial employee training sessions.
Subsequent discussions with the Niagara Mohawk FFD Program coordinator identi-fied that these specific areas of training would be covered in detail during annual General Employee Training sessions and in a specific supervisory training program commencing in 'early 1990.
The inspec-tors will continue to monitor these training programs and the imple-mentation of the Niagara Mohawk FFD Policy during routine safety inspection.
Review of Licensee Event Re orts LERs and S ecial Re orts The following LERs and Special Reports were reviewed by the inspectors and determined to have accurately described the events and to have been pro-perly addressed for corrective or compensatory action:
Unit
LER 88-13, Supplement 1,
September 29, 1989, Design basis of 125 vdc system altered by declassifying motor generator sets to non-safety related due to personnel error.
LER 89-15, November 10, 1989, Emergency diesel failure modes not identified during Appendix R review.
LER 89-16, November 7, 1989, Engineered safety feature actuation (isolation of the drywell vent and purge lines)
due to personnel error by failure to properly follow an approved procedure.
LER 89-17, December 4,
1989, Plant operated outside of design basis due to design deficiency of. 125 vdc molded case circuit breakers in battery boards
and 12.
LER 89-19, December 14, 1989, Emergency diesel generator (102).not in compliance with 10 CFR 50, Appendix B.
Special Report dated December 7,
1989, NMP 59090.
Special Report dated December 8,
1989, NMP 59093.
Special Report dated January 22, 1990, NMP 60692.
Unit 2 LER 89-21, August 15, 1989, Primary containment vent and purge valve isolation caused by lightening strike to main stack which initiated a
power transient to the gaseous radiation monitor.
LER 89-22, October 7, 1989, Standby gas treatment system initiated due to an electrical fault in the cable feeding the 'A'us of the 600 volt unit substation.
LER 89-23, September 6,
1989, Standby ga0 treatment system initiation caused by a spurious high signal from a reactor building ventilation radiation monito r
LER 89-24, September 8,
1989, Recirculation pump transfer to slow speed causes entry into restricted zone of power-to-flow map and manual scram.
LER 89-25, September 8,
1989, Emergency diesel generator surveillance not performed due to personnel error.
LER 89-26, September 26, 1989, Multiple engineered safety feature initiations due to spurious trip signals caused by high frequency welding.
LER 89-27, September 13, 1989, Missed chemistry surveillance due to poor scheduling and work assignment.
LER 89-28, September 27, 1989, Reactor core isolation cooling pump reference speed was not obtained prior to measuring flow and differ-ential pressure as required by ASME Section XI requirements.
LER 89-29, September 20, 1989, An incorrect engineering change caused improper setting of the suppression chamber/drywell vacuum. breakers.
LER 89-30, September 20, 1989, Failure to submit a special report due to inadequate managerial methods.
Special Report dated February 6,
1989, NMP 44061.
Special Report dated May 17, 1989, NMP 49053.
Special Report dated September 12, 1989, NMP 55268.
Special Report dated September 27, 1989, NMP 56804.
Special Report dated October 10, 1989, NMP 56581.
Special Report dated October 20, 1989, NMP 56870.
Special Report dated December 18, 1989, NMP 60618.
Special Report dated December 26, 1989, NMP 60635.
Special Report dated December 26, 1989, NMP 60637.
Special Report dated January 2,
1990, NMP 6065 At periodic intervals and at the conclusion of. the inspection, meetings were held with senior station management to discuss the scope and findings of this inspection.
Based on the NRC Region I review of this report and discussions held with Niagara Mohawk representatives, it was determined that this report does not contain Safeguards or 10 CFR 2.790 informatio 'r~