IR 05000220/1990007
| ML17056B005 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/05/1990 |
| From: | Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056B004 | List: |
| References | |
| 50-220-90-07, 50-220-90-7, 50-410-90-07, 50-410-90-7, NUDOCS 9010010048 | |
| Download: ML17056B005 (36) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.:
50-220/90-07 50-410/90-07 Docket Nos.:
50-220 50-410 License Nos.:
DPR-63 NPF-69 Licensee:
Facility:
Location:
Dates:
Inspectors:
Niagara Mohawk Power Corporation 301 Plainfiel'd Rbad Syracuse, New York 13212 Nine Mile Point, Units 1 arid
Scriba, New York July 12 through August 22, 1990 W.A.
R.R.
R.A.
T.H.
R.A.
W.L.
C.E.
L.J.
Cook, Senior Resident Inspector Temps, Resident Inspector Laura, Resident Inspector Fish, Operations Engineer Plasse, Resident Inspector,FitzPatrick Schmidt, Senior Resident Inspector, FitzPatrick Sisco, Operations Engineer Wink, Reactor Engineer Approved by:
lenn W. Meyer, Chze
, Reactor Projects Section 1B, DRP
~+To Date Ins ection Summar This inspection report documents routine and reactive inspections during day and backshift hours of activities including:
plant operationsi radiological protection; surveillance and maintenance; emergency preparedness; and safety assessment/quality verification.
Results:
No violations were identified.
An Executive Summary follows.
901001004S 90090~"
PDF ADCiCK 05000220
Executive Summary Nine Mile Point Inspection Report 50-220/90-07 and 50-410/90-07 July 12, 1990 August 22, 1990 Plant 0 erations:
Performance by both the Unit
and Unit
Operations staffs was generally good.. Unit 1 operator support of the Power Ascension Testing Program (PATP) and their competent and professional control of the unit during four reactor startups and three shutdowns were noteworthy.
The recent error-free operation by the Unit 2 operators was also indicative of closer attention to detail and improved supervisory oversight.
Radiolo ical Protection:
The failure of the Unit 2 reactor cleanup system filter seal and accompanying spill of reactor water resulted in several personnel comtaminations and warrants management review and corrective action.
Surveillance and Maintenance:
Completion of phase one of the Unit 1 PATP testing was successful and characterized by generally good coordination and control by the testing engineers, operators and
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technicians.
Poor performance by the maintenance organization resulted in two forced shutdowns.
The apparent inability of the Unit 2 maintenance and engineering staffs to resolve feedwater pump seal problems and pump isolation valve leakage has imposed some operational limitations and an inability to perform corrective maintenance on the redundant pumps while operating at power.
Emer enc Pre aredness:
Execution during the two Unusual Events at Unit 1 was good.
Station personnel responded promptly and properly to the events, and notifications to the NRC were satisfactory.
/
Safet Assessment ualit Verification:
Station management oversight of the restart and PATP at Unit 1 has been evident and effective.
Problems which have arisen were properly and conservatively addressed, and the overall coordination of the various station support organizations has been good.
Niagara Mohawk was slow in identifying and resolving the program weaknesses with the blue markup controls which surfaced as a result of the Unit 1 feedwater pump suction valve incident.
However, adequate corrective actions were instituted, and station personnel were trained on the administrative control changes prior to Unit
restar l l
'I
DETAILS 1.
Plant 0 erations (Modules 71707,71710,93702,71715,71711,72700)
1.1 Unit 1 During the inspection period, Niagara Mohawk completed all actions required to support the restart of Unit 1.
By letter dated July 13, 1990, Niagara Mohawk requested permission from the NRC Region I Regional Administrator for restart of the reactor.
This permission was granted through the issuance of Supplement 1 to CAL 88-17, dated July 27, 1990.
Niagara Mohawk. has established a
Power Ascension Testing Program (PATP)
to test and assess reactor systems and personnel performance.
A sequence of restart events with inspectors observations and assessments follows:
a ~
At 1:25 a.m.
on July 29, 1990, the reactor mode switch for the Unit 1 reactor was taken to "STARTUP" and control rod withdrawal to criticality was commenced.
The inspectors reviewed the startup prerequisites and observed good procedural adherence with the governing startup procedure, N1-OP-43.
Control rod withdrawal was observed and determined to be in accordance with the pullsheet and Technical Specifications (TS) requirements.
The inspector noted that extra personnel were available on shift and that there was good management oversight and supervision of the evolution.
b.
At 6:10 a.m. the reactor was declared critical.
As power was increased to the intermediate range, Intermediate Range Monitors (IRMs)
15 and 16 failed to respond.
As IRM 16 had been bypassed earlier due to spiking problems, further rod withdrawals were halted and a half scram inserted on the 12 Reactor Protection System (RPS) side (detectors 15-18 are on the 12 side) in accordance with TS.
Immediate actions were taken to troubleshoot and repair the inoperable detectors.
The inspector observed the actions and determined they were done properly and in accordance with station procedures.
c ~
At 2:35 p.m.,
IRM 15 was returned to service and rod withdrawals commenced with IRM 16 in bypass as allowed by the TS.
The IRM/SRM overlap test, Nl-PAT-1.1, was then completed satisfactorily.
d.
At approximately 9:45 a.m.
on July 30, reactor temperature had been raised to 245 degrees Fahrenheit with a corresponding reactor pressure of 15 psig.
At that time, the
"Pressure Safety Relief Valve Flow" control room (CR) annunciator actuated.
Investigation by the operators determined that the acoustic monitors for
electromatic relief valves (ERVs)
112 and 123 were sensing steam flow past the valve seats.
At 10:51 a.m.,
Niagara Mohawk commenced a unit shutdown due to the ERV leakage and because the drywell floor drain (DWFD) leakage rate had increased from zero to 1.8 gpm in the last hour.
The DWFD accounts for unidentified leakage sources in the drywell.
At 11:00 a.j.,
an Unusual Event (UE)
was declared when the-DWFD leakage rate exceeded 2 gpm.
The UE was initiated in accoidance with unit procedures as the leakage rate had increased by greater than
gpm in less than a
24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, a
condition requiring shutdown by Technical Specification.
At 11:20 a.m.,
the UE was terminated when DWFD leakage dropped below 2 gpm.
The inspectors noted good operator response to these problems.
Appropriate procedures were followed, crew communications were good, and the Unit and Operations superintendents were both in the control room overseeing activities.
Overall, the event was handled in a controlled and competent manner.
Investigation into the ERV leakage problem and the DWFD leakage rate problem revealed that approximately three
- weeks before unit startup, all six ERVs were disassembled for inspection of the pilots and seats.
This was done to determine what had caused the.112 ERV to weep following the vessel hydrostatic test.
The disassembly, inspection and reassembly was performed per procedure N1-NMP-001-203.
During reassembly, the pilot valve adjustment step of the procedure was N/A'd because the mechanic and first line supervisor in charge of the job concluded that the inspection activity would not affect the pilot adjustment.
As evidenced'by the consequent events, this was an error in.judgement.
Maintenance staff inspection of the 112 ERV found the pilot assembly to be out of adjustment.
The 123 ERV pilot assembly was found to be sticking.
In both cases, the pilot valve was venting the ERV and therefore, as reactor pressure increased and overcame valve internal spring force, the valves started weeping by.
Assessment of this finding and other corrective actions taken is discussed more fully in Section 3.1 of this report.
The cause of the DWFD leakage was traced to a failed four inch vacuum breaker in the 123 ERV downcomer.
Each ERV discharges through a bellows assembly with flow directed through a downcomer into the torus.
Each downcomer has four vacuum breaker assemblies (two'0-inch and two 4-inch butterfly valves)
which allow equalization of pressure from the drywell to the downcomer.
The spring was broken which keeps the valve flappers closed under
normal zero differential pressure conditions.
This allowed a direct flow path to the drywell from the leaking ERV.
This steam leakage was condensed by the drywell coolers and resulted in the DWFD leakage increase.
When the plant shutdown and cooldown was initiated, the leakage rate decreased as steam was no longer being produced and relieved through the ERV.
Further details of'he valve failures are discussed in the maintenance section, along with corrective actions.
On August 2, 1990, the unit was restarted at 4:51 a.m..
By 1:00 p.m. criticality was achieved and power was increased.
The IRM correlation test at range 6 to 7 was completed satisfactorily per N1-PAT-1-1, and reactor power increase and plant heatup continued.
At approximately 330 degrees Fahrenheit (F) plant heatup was stabilized to perform piping inspections in the drywell per procedure N1-PAT-6-1, Section 6.1.
The inspection identified only one Level 1 test exception, which
. involved an instrument line that was in contact with a floor grating.'his problem was corrected by cutting a section of the grating to remove the interference.
While holding at 330 degrees, calculations were performed for adjusting the IRM gains in accordance with the results of the IRM heatup calibration performed earlier by N1-PAT-1-1.
When *an attempt was made to perform the adjustment at 12:15 a.m. on August 3, the I&C technicians determined there was insufficient adjustment capability on the gain potentiometer.
Nl-PAT-1-1 was then placed on hold while technical resolution of the problem was obtained.
At 8:40 a.m.
a SORC meeting was convened to review the Level 1 test exception for N1-PAT-6.1 concerning the instrument line interference with the grating, and the IRM gain adjustment issue.
An interim measure approved by SORC was to limit the IRMs to Range 8 or less pending further evaluation and consultation with General Electric (GE).
Assessment of the SORC meeting by the inspector concluded the SORC was effective in addressing and resolving the safety significance of the two issues.
In particular, the approach to resolving the IRM gain adjustment concern was conservative and rational.
Later that day, Niagara Mohawk was informed by GE that the IRM heatup calibration method was one that GE no longer used and further did not recommend, as it had proven not to work well in the field.
A letter stating this was transmitted and SORC reconvened.
Following the recommendations of GE, SORC recommended that their current values should be adjusted and verified to be at
the gain settings used in the last plant startup.
This recommendation was consistent with prior plant startup practice, industry practice and GE's recommendation.
Further, SORC recommended to administratively limit the IRMs to range 8.
The Niagara Mohawk power ascension approach was to increase reactor power enough to open two bypass valves, correlate APRM indicated power to bypass valve position, and then correlate the IRMs.
Accordingly, the mode switch could be taken to RUN, and when power was at 20 to 254, a routine heat balance could be performed for a more accurate APRM and IRM gain adjustment.
The inspector observing the SORC meeting determined that the issues were thoroughly discussed and a conservative course of action taken.
On August 4, normal operating pressure was achieved.
The final drywell (DW)
inspections per N1-PAT-6-1 were initiated.
At 7:15 p.m. the inspector was informed that one of the individuals performing inspections had exhibited signs of heat exhaustion and was being taken out of the DW and that an ambulance had been, called.
An Unusual Event was initiated at 7:27 p.m.
on the event classification for injured-contaminated worker.
The event declaration was precautionary, as it was unknown if the individual transported to the hospital was contaminated.
At 7:46 p.m. the event was terminated.
Reports from Niagara Mohawk health physics personnel at the hospital indicated that the individual was not contaminated and had physically recovered.
The inspector's assessment was that the declaration of an Unusual Event was conservative and proper, and that the control room personnel handled the event properly.
On August 5, 1990, after placing the mode switch in RUN and achieving 154 power, lift/reset testing of the six electromatic relief valves (ERVs)
was performed per procedure Nl-ST-C2.
The inspector observed the testing and reviewed the completed test procedure.
The inspector concluded that the testing evolution was well planned and executed quickly and professionally by the operators and other support personnel.
On August 6, 1990, the turbine was rolled for the first time.
On the initial roll, some vibration problems were experienced at 1300 rpm and the roll was secured.
The turbine was placed back on the turning gear to allow further break in of new components and to remove eccentricities.
Later in the day, turbine rollup was recommence As the turbine was being rolled up to its synchronous speed of 1800 rpm, the operators noted high vibration indication for the No.
5 turbine bearing at 1750 rpm.
Operations and maintenance personnel in the field confirmed there was a problem and requested the turbine be tripped, which the operators carried out at 5:30 p.m.
Soon thereafter, the request was made to break vacuum on the condenser to allow rapid slowdown of the turbine to prevent further damage to the bearing.
At 5:32 p.m., the reactor was manually scrammed from 20%
power in anticipation of a
low condenser vacuum scram (at
inches Hg) following breaking of the condenser vacuum.
The inspector present in the control room during the event concluded that the operators performed well during the event.
The appropriate emergency operating procedures were entered and executed professionally and calmly.
All systems responded as required and plant conditions were quickly stabilized.
Following the manual scram, the plant was cooled down to less than 200 degrees F and an investigation into the bearing problem commenced. It was confirmed that the No.
5 bearing was severely damaged and required replacement.
Further investigation revealed that the cause of the problem was a blank flange left in the oil supply line to the bearing.
Therefore, once the lift oil pumps were secured at around 900 rpm, the bearing was not receiving adequate lubrication and this led to the vibration problem and damaging of the bearing surface.
Additional information concerning this event.
and inspector assessments are documented in Section 3.1 of this report.
Following the four day forced outage to replace the turbine bearing, restart of the unit commenced at 9:30 a.m.
on August 11.
Reactor criticality was reached at 3:00 p.m.
The reactor mode switch was taken to RUN on August 12 and later the generator was synchronized to the grid.
For the next six days, electrical output was maintained around 100 MWe and numerous reactor physics surveillances were performed.
The generator was taken off the grid on August 17 in preparation for the turbine torsional testing.
As a result of turbine vibration problems encountered during the torsional testing, the turbine was tripped and the reactor was manually scrammed at 5:47 p.m.
on August
when the need to break condenser vacuum arose for the rapid slowing of the turbine.
Inspector assessment of the operations staff during this event was that operators responsed properly to the operational problems and the plant transien Overall performance by the Unit 1 operations staff in preparation for unit restart and during the power ascension testing, as observed during this inspection period, was generally good.
Effective Operations management oversight and decision making, operator knowledge, awareness of plant conditions, and professionalism, as well as, good interdepartmental coordination and support were evident.
The inspector concluded that areas for improvement were communication'ractices and attention to detail by operators with respect to monitoring and responding to control room annunciators and trend logs.
1.2 Safet S stem Verification Unit 1 The inspector directly examined portions of selected safety system trains to verify that the systems were properly aligned in the standby mode.
The following systems were examined.
Liquid Poison Emergency Service Water (ESW)
No discrepancies were identified during the liquid poison system walkdown. As-built conditions matched the system P&ID, and valves-were in the positions indicated by the most recent valve lineup sheets and as: required by system operating procedures.
The ESW system was walked down in a similar method to liquid poison.
However, the inspector also performed a verification to ensure that appropriate system root valves had been identified and incorporated into P&IDs and valve lineup sheets as a result of corrective actions for unresolved item 50-220/90-80-01 (see section 6.f.).
The inspector determined that ESW valves on the lineup sheet were in the expected positions.
He also verified that recent revisions to the P&IDs which added instrument root valves not previously identified on P&IDs had also been added to the valve lineup sheets and that they too were in their expected position.
However, the inspector noted that there were three instruments on the P&ID that, had root valves identified on the print that were not incorporated into the valve lineup sheet.
Further, the root valves were ones already incorporated into the P&IDs prior to the corrective actions for the root valve issue identified by item 50-220/90-80-01.
The inspector questioned Niagara Mohawk as to whether the root valves for the three instruments should have been in the valve
.lineup sheet.
Niagara Mohawk confirmed these valves should have been on the lineup sheet.
They then initiated an
investigation as to why the root valves were overlooked on the valve lineup and to determine if any other systems recently reviewed had the same problem.
Niagara Mohawk's investigation revealed the following:
Resolution of the root valve issue was assigned to the Operations Events Analysis (OEA) group.
, OEA developed written guidelines to address the-issue.
These guidelines included:
a field review of P&IDs to identify instruments for which root valve numbers were to be identified/verified; incorporation of newly identified root valves into P&IDs; and revision/verification of the
. valve lineups sections of the system operating procedures to include all root valves.
The OEA group did part of the root valve walkdowns, and the remainder were turned over to the systems engineering group.
The engineering group conducted the review of the ESW system.
OEA was able to devote exclusive time to this issue and understood and fully implemented the requirements of the guidelines.
The system engineers performed their portion as time permitted, and when questions arose, they were communicated to their supervisors, not to the OEA personnel who had oversight of the program.
Guidelines specified that root valves on P&IDs were to be added or verified to be. included in the system lineup sheets.
This statement was misinterpreted by some system engineers to mean only newly identified root valves need be added to the P&IDs, not root valves present prior to revision.
Review by OEA of all other systems with respect to the inspector's concern identified no additional discrepancies.
The inspector assessment of this issue was that while it was similar to the problems identified in the initial reload system walkdowns (reference inspection report No. 50-220/89-08), there was an important difference.
The initial system walkdowns involved implementation of a new initiative and the failure of management to communicate their expectations for it.
The root valve verification program was also a
new initiative; however, management s expectations were clearly expressed and incorporated into written guidelines.
Responsibility for implementation of this effort was divided between, two groups and consequently one requirement of the guidelin'e was not uniformly implemented.
Niagara Mohawk responded quickly to the inspector's initial concern and took prompt and effective action to correct the proble ~
)
1.3 Unit 2 The inspection period began with the unit operating at reduced power (approximately 884) due to end-of-cycle coastdown.
With reactor power at 74%
on August 16, the C main feed pump developed excessive mechani'cal seal (outboard)
leakage and had to be secured.
The A feed pump has also been unavailable due to an inboard pump seal leakage problem.
Consequently, reactor power was lowered to 654 to be within the operating limits of the one operational feed pump.
a ~
A review of active mark-ups was performed by the inspector to verify technical adequacy, as well as/
compliance with administrative procedures.
One area of concern was identified regarding the restoration of instrumentation in systems that were drained for maintenance.
Specifically, there was no formal mechanism to. ensure instrumentation lines were properly vented concurrent with system refill.
This could lead to trapped air in transmitter lines and result in erratic operation of indicators or pressure and level switches.
Operations management agreed with the concern and performed an audit of existing mark-ups and made a change to N2-0DI-5.06 (Mark-ups)
in the mark-up preparation section.
Zt specified that isolation boundaries shall be checked for instrumentation that will be affected by the mark-ups and requires a refill and vent of the instrumentation, as necessary.
The audit was a
100%
review of active mark-ups to identify instrument lines that would potentially-be drained during system maintenance and not refilled and vented.
Ten examples were identified where instrumentation would potentially be impacted by a system drain and refill, and appropriate action was taken to ensure proper venting.
Previously drained and refilled systems were also reviewed and appropriate venting was performed.
Based on this concern at Unit 2, Niagara Mohwak performed a similar review at Unit 1.
Approximately 10 detectors were identified where the low pressure instrument lines required venting.
A small amount of air was discharged from each detector.
The inspector concluded that weak attention to detail during the preparation of mark-up boundaries with regard to refill and venting of detectors had existed.
However, Niagara Mohawk was responsive to the inspector's concern and took effective corrective action.
Radiolo ical Protection (Module 71707)
Unit 2 The upper seal on the B reactor water cleanup filter demineralizer vessel failed as the vessel was being placed in service subsequent to maintenance.
The seal failure resulted in a multi-level spill of approximately 500 gallons of reactor water in the reactor building.
During the spill and subsequent decontamination effort, eight personnel were contaminated.
Niagara Mohawk initiated a
radiological occurrence report to investigate the circumstances associated with the spill.
The inspector expressed his concerns for the large number of personnel contaminations involved with this event and subsequent cleanup.
In addition, the failure of the filter,seal has been a continuing problem and warrants further Niagara Mohawk attention.
The inspector planned to review the Niagara Mohawk evaluation and corrective actions.
3.
Surveillance and Maintenance (Modules 71707, 61726, 62703)
3.1 Unit 1 Surveillance The following surveillances were observed by the inspectors.
Other surveillances observed as part of the PATP are discussed in the Section 1.1 of this report.
N1-ST-Q8, Liquid Poison Quarterly N1-ISP-W-092-334, Weekly Surveillance of f14 APRM 3.2 Unit 1 Maintenance A
strong effort was made by the various maintenance departments to support the restart of Unit 1.
However, this effort was overshadowed by two forced outages as a result of poor mechanical maintenance practices.
a.
As discussed in the operations section, the first forced outage was a
result of leaking ERVs.
Subsequent investigation revealed that the ERVs had been recently worked on and that the procedural step for the post reassembly adjustment. of the pilot valves had been marked
"N/A".
As a result, two of the ERV's pilot valves had incorrect lift pressure setpoints and leaked by during the startup.
Inspector assessment of this incident is that. while marking the maintenance procedure steps
"N/A" was an error in judgement by the workers, it pointed out the need for higher level supervisory and technical review for all procedures for which steps or sections have been marked "N/A".
Niagara Mohawk investigation into this event resulted in the following recommendations to be issued in a Lessons Learned Transmittal.
Any type of component adjustment, critical in nature, will not be marked N/A without a technical review by the system engineer.
Technical assumptions should not be made without adequate review, (ie.
do not assume that final assembly of a
component does not effect adjustments).
Procedure writers should ensure critical adjustments do not have provision for N/As when adjustments are needed after reassembly.
These actions, along with others described in an August 1,
1990 memorandum documenting Niagara Mohawk's investigation into the event, were deemed appropriate and adequate.
Additional details concerning the ERV leakage issue and discussion of the problem with the vacuum breakers on the ERV discharge lines were discussed in specialist inspector report 50-220/90-22.
b.
As discussed in Section 1.1 above, a second forced outage was caused by vibration of and damage to the g5 turbine bearing.
Investigation revealed a blanked oil supply line flange supplying the bearing.
Inspector assessment is that this event continues to demonstrate the need for better system configuration control and awareness of system status.
c ~
The inspectors performed an inspection of the various drywell (DW) levels on July 27, 1990.
This was performed just prior to closeout of the DW.
The inspectors noted a vast improvement in the overall cleanliness of the drywell since the previous inspection.
The inspectors concluded that the material condition of the DW was adequate to support restart of the reactor.
3.3 Unit 2 Maintenance Replacement of the mechanical seal on the A reactor building closed loop cooling (RBCLC)
pump was observed by the inspector.
The maintenance was performed in a controlled and competent manner.
The inspector reviewed the Work-in-Progress sheet, work procedure, pre-work checklist and procurement documentation for the new seal.
One minor concern was identified where the system isolation specified in the work procedure did not match the isolation provided by the markup.
Specifically, valve CCPV200 (pump drain) was shut vice tagged
open.
Further review revealed an upstream drain valve (CCPV680)
was tagged open to ensure the maintenance area was drained.
The inspector concluded that the isolation in effect was adequate.
The inspector did questioned the mismatch between the procedure and actual isolation used from a
procedural compliance standpoint.
The maintenance supervisor agreed with the concern and issued a
procedure change to clarify isolation requirements.
After the work was completed, a post maintenance test was satisfactorily completed.
3.4 Unit 2 Surviellance The following surveillances were observed by the inspector:
N2-ISP-LDS-M006, Monthly test of the leak detection system high temperature isolation functions.
N2-0SP-SLS-QOOl, Quarterly test of the shutdown liquid system pump, check valve and relief valve operability test.
~
Emer enc Pre aredness (Module 71707)
As discussed in Section 1.1 of this report, two Unusual Events were declared at Unit 1 during this inspection period.
The inspectors noted that these events were properly executed and in accordance with station procedures.
Operators promptly identified the emergency condition entry levels, properly declared and made appropriate notifications of the UEs and took prompt action to resolve the conditions leading to the UEs.
5.
Safet Assessment ualit Verification (Modules 71707, 40500)
Niagara Mohawk has provided the resident staff with a weekly update of the status of open Quality First Program (Q1P)
concerns for the past few years.
The inspector chose to conduct a followup of one of these concerns recently closed by the Q1P staff.
QlP concern No. 88-00005 was received on February 17, 1988 and addressed a
concern for electrical drawings not reflecting as-built configurations and no interfacing of electrical as-builts between interdisciplinary drawings.
Quality Assurance representatives assigned to investigate validated the concern and initiated a Corrective Action Report (CAR 88.6002, dated 6/8/88).
In response to CAR 88.6002, the engineering staff committed to conduct field walkdowns and complete all critical and non-critical drawing updates by December 1990.
In addition, they developed and implemented a
computerized drawing update database in July 1990.
The
Q1P report also noted that Nuclear Improvement Plan Item 6.1.3, regarding design basis reconstitution and configuration management, should provide further support of this issue.,
b.
c ~
The inspector concluded that this QlP concern was adequately reviewed and resolved by Niagara Mohawk.
On July 26 and 27 the Deputy Division Director of the Division of Reactor Projects, Region I, met with senior Niagara Mohawk management to discuss final preparations for Unit 1 restart.
One item of particular interest to the NRC'as the resolution of blue mark-up control concerns identified as a result of the May 21 feedwater pump suction valve event (reference Inspection Report No.
50-220/90-06).
Based upon the initial meeting on July 26, the NRC inspectors concluded that Niagara Mohawk had not fully evaluated the programmatic weakness in the current blue mark-up administrative controls.
After further discussion and clarification of the inspectors'oncerns, Niagara Mohawk developed additional administrative controls for the applicable mark-up procedures and presented those revisions to the inspectors during the July 27 meeting.
Specific changes to Operations Department Instruction 5.06, Mark-ups, included:
clarification of what activities constitute minor maintenance; annotation on the blue mark-up sheet of the as-left condition of the component; and a revision to the use of yellow holdout vice blue mark-ups for fire detection systems control.
The inspectors found the proposed procedural revisions satisfactory.
In addition, Niagara Mohawk committed to train all personnel on these revisions prior to restart and to monitor the effectiveness of these changes during the power ascension testing program.
The inspector attended the final Site Operations Review Committee (SORC) meeting prior to restart.
The following temporary procedures (TP) were completed, and exceptions were closed out or justified why they did not need to be completed prior to restart:
TP 88-6.0 (Reload)
TP 88-7.9 (Operating procedures required to be complete prior 'to restart)
TP 88-7.0 (Restart commitments closure and ready for restart)
The meeting was structured differently than previous ones in that the unit superintendent was the SORC chairman rather than the station superintendent.
The agenda and expectations for the meeting were clearly communicated at
the start of the meeting.
Signoff of the procedures and review of any exceptions were organized and effective.
The SORC chairman required proof of completion of outstanding issues and in a
few instances utilized Quality Assurance personnel to independently verify completion of issues.
This accountability of closed issues was viewed as a
positive attribute by the inspector.
In summary, the SORC meeting effectively carried out their responsibilities as delineated in TS 6.5.1.
6.
Review of 0 en Items and Res onses to Notices of Violation:
(Module 92702)
a ~
(Closed)
Violation (50-220/89-33-02):
Issued for a
. violation of 10,CFR 49 requirements regarding unqualified three-wire, V-type splice configurations.
By letter dated April 23, 1990, Niagara Mohawk admitted to the violation.
Although no technical response to the violation was required, Niagara Mohawk's response included a
description of the event and corrective actions taken to enhance the reliability of existing splices and to prevent recurrence by changes to maintenance instructions dealing with electrical splices.
The inspector determined that the response and corrective actions were adequate.
This violation is closed.
b.
(Closed)
Violation (50-220/89-33-01):
Issued for a
violation of TS 6.8.1 in that the requirements of Administrative Procedure 4.0 regarding the placement of yellow hold-out tags was not being properly implemented.
In a letter dated April 23, 1990, Niagara Mohawk admitted to the violation.
The inspector reviewed the violation response which included a summary of the events which led to the violation, as well as, the corrective actions taken.
The inspector concluded the violation response and corrective actions were adequate.
Additionally, inspector observations since the concern was initially identified indicate general compliance with the rules for using hold-out tags.
One exception was noted during this inspection period.
When removing fire detectors from service, to prevent nuisance alarms due to activities in the area such as grinding or welding, blue mark-ups were being used.
Per Administrative Procedure (AP) 4.2, Mark-ups, the inspector concluded that yellow holdout tags are more appropriate for this application than blue markups.
The inspector's observation was discussed with Niagara Mohawk management.
After further review, Niagara Mohawk agreed that, holdout tags vice blue mark-ups should be used when removing detectors from service.
Station personnel were instructed and all current fire system tagouts were reviewed and changed if necessary.
Niagara
Mohawk stated that this requirement will be clarified in the forthcoming revision to AP 4.2.
This violation is closed.
(Closed)
Violation (50-220/89-08-003):
Issued for failure to calibrate the Reactor Building Emergency Ventilation strip heaters.
In their response dated May 10, 1990, Niagara Mohawk admitted to the violation as stated.
The inspector reviewed the corrective actions taken and determined them to be adequate.
This violation is closed.,
(Closed)
Violation (50-220/89-08-001):
Issued for violation of 10 CFR 50, Appendix B for failing to follow the requirements of the reload systems walkdown procedure.
In their response dated May 10, 1990, Niagara Mohawk admitted to the violation.
The corrective actions were reviewed and determined to be adequate by-the inspector.
This violation is closed.
(Closed)
Open Items (50-220/89-01-001)
and (50-220/89-02-002):
These items dealt with failure to notify the NRC in a timely manner of a concern with the 125 VDC battery and deficiencies in the first ten year interval Inservice Testing (IST) program, respectively.
Further review of these open items concluded them to be violations and they were incorporated into a combined Enforcement Action 89-70.
In their response dated November 16, 1989, Niagara Mohawk admitted to both violations.
Issues concerning the 125 VDC batteries and IST program were incorporated into the Restart Action Plan and commitments made to fix both problems were completed prior to restart of the unit.
Additionally, NRC inspections subsequent to the initial findings indicated satisfactory resolution of these items.
These items are closed.
(Closed)
Unresolved Item (50-220/90-80-01):
Niagara Mohawk to establish control of instrument root valves.
Following the identification of this item by the Readiness Assessment Team (reference Inspection Report No. 50-220/90-80),
Niagara Mohawk developed a detailed action plan to verify the proper identification, control and positioning of all safety related instrumentation root valves.
The action plan included a detailed hand-over-hand field walkdown, review and revision of piping and instrumentation drawings and a review and revision of applicable operating, maintenance and surveillance testing procedures to ensure accuracy and comprehensive control of instrument root valves.
The inspector reviewed the action plan and discussed its implementation and results with the responsible station
gi personnel.
As discussed in section 1.2 of this report, an independent review of the emergency service water systems was performed with mixed results.
However, based upon this review and subsequent Niagara Mohawk re-review of this issue, the inspector concluded that adequate controls are currently in place to ensure proper root valve positioning.
This item is resolved.
(Closed)
Unresolved Item (50-220/90-05-02):
Operability of control rods based on scram tests performed without isolating the individual hydraulic control units (HCUs)
from the charging water pump.
Following identificat'ion of this concern by a region based specialist inspector, Niagara Mohawk elected to re-perform the individiual control rod scram test for all control rods using a
modified valve line-up which isolated the individiual HCUs from the charging water pump.
The re-test was completed on July 15, 1990, prior to restart of the unit.
The region based specialist inspector reviewed the scram time data obtained by the new method and compared it to the results previously obtained.
As expected, the scram times to
percent inserted position were slightly longer using the modified valve line-up, but were still within the limits required by Technical Specifications.
No evidence was found of degraded performance of the ball check valves in the individual control rod drive mechanisms.
This item is resolved.
h.
(Closed) Unresolved Item (50-220/89-18-04): Validation of the HPCI/Feedwater pump performance curves.
During the previous inspection period (50-220/90-06) the inspectors witnessed and reviewed the feedwater pump performance testing and determined the testing and test results were satisfactory, (reference Section 1.1.b of 50-220/90-06).
This item is resolved.
LER Review (Module 92700)
Unit The following LERs were reviewed and found satisfactory:
LER 90-13, June 15, 1990, Improperly supported instrument line.
LER 90-06, October 27, 1989, Unverified assumption in Appendix R Safe Shutdown Analysis.
This is a voluntary LE.
Mana ement Meetin s (Module 30703, 30702)
Mana ement Meetin s Conducted b
Re ion Based Ins ectors Durin this Ins ection Period Date Subject Report No.
7/26 Unit 1 Restart 7/30 Quality Verif.
none 90-22/90-20 Preliminar Ins ection Findin s 7/24 Radiochemistry 90-20/90-19 Inspector Kottan Wiggins Finkel 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 proprietary information.