IR 05000220/1993003

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Insp Repts 50-220/93-03 & 50-410/93-02 on 930228-0410. Major Areas Inspected:Plant Operations,Radiological Controls,Maint,Surveillance & Safety Assessment/Quality Verification Activities
ML20035H754
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 04/29/1993
From: Briggs L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20035H752 List:
References
50-220-93-03, 50-220-93-3, 50-410-93-02, 50-410-93-2, NUDOCS 9305070007
Download: ML20035H754 (15)


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U.S. NUCLEAR REGULATORY COMMISSION i

REGION I

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Report Nos.:

93-03; 93-02

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Docket Nos.:

50-220; 50-410 License Nos.:

DPR-63; NPF-69 Licensee:

Niagara Mohawk Power Corporation j

301 Plainfield Road Syracuse, New York 13212 Facility:

Nine Mile Point, Units 1 and 2 i'

Location:

Scriba, New York Dates:

February 28 through April 10, 1993 Inspectors:

W. L. Schmidt, Sonor Resident Inspector R. A. Plasse, Re sident Inspector

W. F. Mattingly, Resident Inspector

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A. L. Burritt, Operations Engineer j

4 29k3 Approved by:

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(j Larry E. Briggs, Chief E Reactor Projects Section No.

Division of Reactor Projects Inspection Summary: This inspection report documents routine and reactive inspections of plant operations, radiological controls, maintenance, surveillance, and safety assessment / quality verification activities.

Results: See Executive Summary.

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EXECUTIVE SUMMARY

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Nine Mile Point Units 1 and 2

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NRC Region I Inspection Report Nos. 50-220/93-03 & 50-410/93-02 i

02/28/93 - 04/10/93

Plant Operations NMPC conducted refueling outage activities at Unit 1 and operated Unit 2 safely. The

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quality of engineering and management involvement in the daily conduct of Unit 1 outage activities ensured proper resolution ofidentified safety concerns. Unit 2 operators

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demonstrated excellent attention-to-detail and the proper safety perspective during several planned power reductions and one unplanned plant transient. Inadequate planning, shift knowledge and a breakdown in communications caused an unknowing entry into several thermal limit technical specification limiting conditions for operation. The Unit 2 staff aggressively pursued corrective actions and performed an objective and thorough root cause

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evaluation.

i Radiolonical and Chemistry Controls

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and disposition the three leaking fuel rods at Unit I were considered appropriate.

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NMPC effectively implemented the radiological controls program. The actions to identify Maintenance i

NMPC completed several plant modifications and design changes such as the hardened vent and several control room instrumentation upgrades during the Unit I refueling outage.

Observations of routine maintenance activities revealed an acceptable level of performance.

A work in progress data sheet did not properly reflect existing plant conditions. The shift supervisor failed to correct the discrepancy when he authorized the maintenance activity.

Surveillance Conduct of the Unit 1 emergency diesel generator cooling water flow special test procedure, subsequent pump replacement, and retest was an example of a thorough, well planned, and properly executed activity, with an appropriate amount of management attention. Conduct of the containment integrated leak rate test and subsequent test results were satisfactory.

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i Engineerine and Technical Support

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Observation of testing and review of NMPC's response to NRC Bulletin 88-04, " Potential Safety-Related Pump loss," for the Unit I core spray system showed that the common i

recirculation line did not affect system operability.

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Safety Assessment /Ouality Verification

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Controls established for site operations review committee (SORC) review and approval of all special test and modification functional tests was an excellent example of SORC.

effectiveness.

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SUMMARY OF FACILITY ACTIVITIES 1.1 Niagara Mohawk Power Corocration Activities

The Niagara Mohawk Power Corporation (NMPC) conducted nuclear activities safely at Nine

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Mile Point Unit 1 (Unit 1) and Unit 2 (Unit 2). At the end of the inspection period, Unit 1

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was in day 50 of a scheduled 55 day refueling outage and making the final preparations for l

the unit start-up. NMPC safely operated Unit 2 at essentially full power throughout the

period.

1.2 NRC Activities

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Resident inspectors conducted inspection activities during normal, backshift and weekend I

hours including: 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of backshift (evening shift) and 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> of deep backshift (weekend, holiday, and midnight shift) inspection during this period.

2.0 PLANT OPERATIONS (71707,93702,60710)

2.1 Residual Heat Removal System t

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The inspector performed a comprehensive walkdown of the accessible portions of the Unit 2

"A" residual heat removal system (RHS) to verify correct system alignment and operability

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using procedure N2-OP-31 and piping and instrument drawings (P& ids) 31 A through 31G.

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The inspector noted good physical condition of the system and general area housekeeping.

i One discrepancy between the system configuration and the applicable P& ids was identified.

Valve 2RHS*V41, identified on P&ID-31F-10 as a swing check valve, had a manual

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operator. The control room staff stated that a deviation / event report (DER) would be initiated to resolve the discrepancy.

Major components were properly labeled, system valves were properly aligned. The l

inspector verified system breaker alignments and support system operability. System

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instrumentation was consistent with expected values. In addition, a sample of

instrumentation calibrations were checked and verified to be current. Accessible piping i

supports and snubbers were properly installed; missing snubbers were verified removed as i

l part of the facilities snubber reduction program, with appropriate changes made to the station

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l isometric and piping support drawings. A review of outstanding RHS system DERs and l

corrective maintenance, identified no significant problems or system reliability concerns.

The inspector concluded that the "A" RHS system had no observable problems impacting system operability or reliability.

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2.2 Restoration of Offsite Power On March 11 the inspector observed excellent coordination within the Unit 2 operating shift during the restoration of offsite power line 6 following a planned outage for breaker repairs.

The bus restoration required integrated use of three separate operations procedures, N2-OP-70, N2-OP-71, and N2-OP-100. The assistant shift supervisor conducted a thorough pre-evolution brief with all participating personnel in attendance. Personnel demonstrated a questioning attitude for various aspects of the evolution as well as their individual responsibilities. The individual directing the evolution used the approved control room copy of the procedures. Additionally, during the evolution the control room staff performed double verification of critical manipulations which consisted of a second person confirming that the person performing the manipulation had the appropriate switch in hand. According to the station shift supervisor (SSS), the crew had practiced this verification method during their last simulator training session and found it effective in preventing potential personnel errors.

2.3 Operator Training Review The inspector reviewed the training package provided to the Unit 1 operators for plant modifications completed during refueling outage (RFO) 12. The training provided a general description and purpose of the modifications, and simplified schematic drawings of the hardware changes. The inspector completed a walkdown of the hardware improvements which affected the Unit I control room. The inspector determined all indicators and annunciators were upgraded as described in the modification training package. The inspector discussed the modifications with several operators on shift and determined the operators understood the physical changes to the plant. The inspector determined that the annunciator response procedures (ARPs) affected by the modifications were revised prior to closeout of the modifications. The inspector reviewed several plant drawings and determined the drawings reflected the modifications. Based on the sample reviewed, the inspector concluded that NMPC provided the operators with adequate information to understand the operational improvements to the plant during RFO 12.

2.4 (Closed) Violation 220/92-24-02. Failure to Follow Procedures Durine Surveillance Test The inspector noted during a review of control room logs that the SSS terminated surveillance test procedure N1-ISP-036-003 following three unanticipated half-scrams and l

prior to completion of the procedure. Inspector review of the procedure and electrical logic diagrams determined the system responded as designed, however, the plant impact statement l

for the procedure did not specify that a half-scram condition would occur during the performance of the test. In addition, the operators failed to stop the procedure following the

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receipt of the initial unexpected half-scram condition. The inspector verified the procedure was revised to incorporate the appropriate half-scram conditions. The inspector verified the operations and I&C departments received lessons learned training for weaknesses identified during NMPC's formal root cause evaluation of this event. This item is closed.

2.5 Refueling Activities l

Observation of refueling activities at Unit I verified fuel moves accomplished according to

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approved procedures and TS. The inspectors verified that refueling personnel understood their responsibilities, plant conditions and prerequisites were properly verified prior to moving fuel, required surveillances were complete, and required authorizations were received. Refueling procedures reviewed included:

N-FHP-27B Whole Core Reload i

N1-FHP-25 General Description of Fuel Moves

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N1-REP-17 Core Post-Alteration Inspection and Verification i

N1-FHP-12 Blade Guide Installation and Removal N1-RESP-11 In-Sequence Shutdown Margin Test N1-RESP-9 Source Range Monitor Operability for Core Alterations

N1-ST-WlO Refueling Platform High Radiation Monitor Instrument Channel Test

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l 2.6 Various Power Transients j

Unit 2 operators reduced power several tiraes to clean condenser inlet tube sheets and switch the operating reactor feedwater pumps in order to install new pump seals (an upgraded design) on 2FWS-PIB. NMPC properly planned and controlled these power reductions.

j Two unplanned power reductions also occurred to troubleshoot tid turbine mechanical overspeed trip test device and to isolate feedwater pump 2FWS-PIB because of failure of the newly installed seals. On March 28 the turbine mechanical overspeed trip test device malfunctioned during the routine surveillance test. Plant management subsequently directed that power be reduced to within the bypass valve capacity to allow troubleshooting.

Investigations revealed a misaligned test oil injection line which NMPC determined did not adversely affect the actual mechanical overspeed trip device function (only affected the testability of the device). Normal full power operations were resumed while a repair plan was developed. On March 31, four days after its installation, the newly installed outboard seal on reactor feedwater pump 2FWS-PIB failed. Operators reduced power to within the capacity of a single feedwater pump to shutdown 2FWS-PIB and placed 2FWS-PIC in service. Full power operations resumed with 2FWS-PIB out of service. Mechanical maintenance personnel subsequently installed the old design seals in 2FWS-PIB.

At the end of the inspection period, NMPC's evaluation of the test oil injection line repair plan continued, as did the investigation into the "- d he seal failure. The inspectors t

observed various portions of the power transients, pre-transient planning meetings, special

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evolution management crew briefs, and the normal planned transient shift briefs Unit 2 management and supervision actively participated in all aspects of the various evolutions.

The Unit 2 operators demonstrated excellent attention-to-detail, plant knowledge, procedural adherence, and communications.

2.7 Unknowing Entry Into Thermal Limit Limitine Conditions For Operation During the mid-shift on March 31, following a control rod pattern adjustment to compensate for a xenon transient, the 3D Monicore computer (monitors core thermal limits and the flux profile) alarmed in the Unit 2 control room. The control room shift properly responded to the alarm and the shift technical advisor (STA) determined that three thermal limits exceeded their respective alarm setpoints. These plant conditions required entry into the limiting conditions for operation (LCOs) for three separate thermal limits, however, the SSS directed immediate corrective actions in accordance with only one LCO. The LCO action for all three thermal limits directs corrective action within 15 minutes and re" oration of the applicable parameter to within the limits within two hours; otherwise reduce thermal power to less than 25% of rated thermal power within the next four hours. The corrective action (insert eight rods) restored all three thermal limits to within their respective limits after approximately one hour. Although the STA was aware that three thermal limit LCOs were entered, this information was not fully conveyed to nor was known by the rest of the shift.

Following the morning log review and discussions with reactor engineering personnel, operations management determined that the operating shift was not aware that three TS LCOs had been entered and immediately initiated a deviation / event report (DER) to evaluate the event.

NMPC performed a root cause evaluation and determined that several factors contributed to this event, including: inadequate analysis and planning for the xenon transient; inadequate shift knowledge and training on core dynamics, thermal limits, and thermal limit TS; and a

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breakdown in the normal shift communications. The inspector independently reviewed the j

event, interviewed several persons involved with the event, including shift personnel and i

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those performing the root cause evaluation, and discussed the event with operations and plant management. The inspector agreed with the findings of the root cause evaluation, considered the process to be objective and thorough, and found the immediate corrective actions satisfactory. The safety significance of this event is low because at all times the unit operated within the requirements of the TS. This event is of concern, however, because the j

licensed operators on shift were not aware that the LCOs for three different thermal limits

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were entered.

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3.0 RADIOLOGICAL AND CIIEMISTRY CONTROLS (71707)

3.1 Routine Observations

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The inspector observed good use of radiological protection practices, proper use of l

procedures, and adherence to postings during routine plant tours. The inspectors toured the Unit 1 drywell during the outage, and found the material condition and housekeeping to be j

maintained satisfactory.

3.2 Identification of Fuel Failure

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Due to increased offgas radiation levels identified September 28,1992 (see IR 50-220/92-24), Unit 1 maintenance personnel obtained water samples (sipped) from 100% of the core

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during off-load and identified three failed fuel rods (one rod in three different fuel bundles).

Pellet-clad interaction most likely caused the failure of two fuel rods which were located in

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symmetric fuel cells that experienced control rod motion shortly before the increase in offgas

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radiation levels. The most likely cause of failure in the third rod was an undetected manufacturing defect. GE examined the manufacturing records of the three failed fuel rods and found that the rods met the manufacturing specifications. All three fuel rod failures

were in GE7 non-barrier fuel manufactured in 1985 and first used at Unit 1 in 1986. NMPC i

replaced the three failed fuel bundles and their nine symmetric bundles with barrier fuel. No operating restrictions were considered necessary for the remaining GE7 fuel bundles. NMPC plans to replace the remaining non-barrier fuel with barrier fuel during the 1995 refueling outage, however, this decision was made prior to the identification of fuel failure. The inspector reviewed the precursor event and the results of the sipping and considered NMPC's actions appropriate.

4.0 MAINTENANCE (62703,37828)

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4.1 Maintenance Observations - Units 1 and 2 Through observations of safety-related maintenance activities, interviews, and review of records the inspectors verified the: proper use of administrative authorizations and tag outs, adequacy of procedures, use of certified parts and materials, calibration of measuring and test equipment (M&TE), proper implementation of radiological control requirements, use of controlled system prints and wiring removal documentation, and proper establishment of quality contral hold points.

WO 11-92477-00; EDG 103 cooling water pump replacement WO 93-01097-03; MSIV repair post-maintenance test WO 12-03768-05; CRD pump gearbox vibration

. WO 12-05710; Provide penetration for RWCU valve 35-49 operator WO 93-00758; H,O, analyzer repair WO 93-00732; RHR high point vent ultrasonic level detector replacement

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WO 93-00930; Replace damaged shunt on 13.8 kV auxiliary boiler breaker N2-EPM-GEN-V532; SWP*MOV17A and CCP*MOV14A VOTES sensor installation N2-EPM-GEN-R555; 13.8 kV auxiliary boiler breaker maintenance The above activities met the safety objectives discussed above.

4.2 Emergency Diesel Generator Cooling Water Pump Reolacement The inspector monitored the replacement of the 103 EDG cooling water pump as a result of degraded performance (see section 5.3 below). Overall, mechanical maintenance technicians demonstrated adequate knowledge, skill and, attention to procedure requirements during the deep draft pump replacement. The inspector discussed the maintenance activities with the

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maintenance supervisor and the system engineer at the job site. The removed pump had microbiologically-induced corrosion (MIC) present across the external surfaces of the pump

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assembly, and several zebra mussels. The pump impeller area, however, appeared to be in good condition with no significant debris.

The inspector found the work in progress (WIP) data sheet and the plant impact statement for i

l the maintenance activity did not properly reflect existing plant conditions. The plant impact l

stated the job should be done in the major maintenance condition with the core defueled and when secondary containment was not required. However, existing plant conditions were cold shutdown, reactor refueled, with both 115 KV lines and the 102 EDG operable. Inspector

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review of TSs indicated that the maintenance activity could be performed under the existing conditions. The inspector discussed the adequacy of the plant impact statement with the system engineer. The WIP was subsequently revised to reflect the existing plant conditions.

i The inspector discussed this observation with the operations manager. It appeared the WIP sheet was completed several months prior to the maintenance activity and the operators who authorized the activity overlooked the differences in plant conditions. The inspector determined NMPC met their TS requirements for one inoperable EDG and had no other concerns.

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4.3 Liquid Poison Discharge Pressure Transmitter Simple Design Change - Unit 1 Simple design change SCI-0160-91 (SDC) replaced the liquid poison discharge header GEMAC pressure transmitter with a Rosemount transmitter and local indicator. This SDC increased the reliability of the discharge pressure transmitter and made transmitter maintenance and calibration easier. The inspector reviewed the SDC package, safety eva!un+ ion preliminary determination, post-modification test results, control room drawings, l

and the affected procedures. Selected portions of the modification were inspected and

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compared to the design drawings. The inspector reviewed the training provided to the j

l operators on the SDC and interviewed several operators to determine their familiarity with l

the SDC and associated procedure changes. The inspector considered all aspects of the SDC satisfactory.

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5.0 SURVEILLANCE (61726, 70313)

5.1 Surveillance Observations - Units 1 and 2 Through observation of safety-related surveillance activities, interviews, and review of records, the inspectors verified: use of proper administrative approvals, personnel adherence to procedure precautions and limitations, accurate and timely review of test data, conformance of surveillances to technical specifications, including required frequencies, and use of good radiological controls. Surveillance activities observed included those listed and discussed below:

N2-ISP-CMS-Q110; Calibration test of the CMS H,0, analyzer N2-ISP-NMS-WOO 7; APRM channel functional test N2-ISP-RCS-Q101; APRM flow unit calibration N2-ISP-RDS-R103; HCU scram accumulator pressure and level instrument channel calibration N2-ISP-MSS-M002; Main steam line high flow instrument channel 2 MSS *1686D functional test The above activities were effective with respect to meeting the safety objectives.

5.2 Containment Integrated Leak Rate Test Review The inspector observed portions of the performance of N1-TSP-201-001, Integrated Leak Rate Test of the Primary Containment "A" Test. The inspector reviewed the test procedure and recorded data and performed independent calculations of the test results to verify proper conduct of the containment integrated leak rate test. The inspector reviewed TS section 4.3.3 and NRC safety evaluation report (SER) dated May 6,1988 documenting specific exemptions to 10 CFR 50, Appendix J requirements for performance of the Type A CILRT at Unit 1. The calculated "as left" condition CILRT test results (including penalties and adjustments at the 95 percent upper confidence level) was 0.4492 wt % per day. This result was consistent with the previous CILRT performed May 3,1990 (0.4257 wt % per day), and well within the TS requirement of 0.826 wt % per day.

The inspector verified the alignment of plant systems to support the CILRT and that specific systems isolated to support the test were acceptable by the NRC SER. The correct leakage l

rates for the isolated penetrations were added to the leakage results of the CILRT per l

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surveillance procedure N1-TSP-201-550, Ixcal Leak Rate Test (LLRT) - Summary - Type B and C tests. The leakage results of the CILRT satisfied the criteria for an abbreviated (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> vice 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) test in accordance with topical report BN-TOP-1, Testing Criteria for CILRT. The inspector verified appropriate data was recorded for atmospheric and containment pressures, temperature, dew point temperature, and liquid levels. The inspector determined that NMPC performed all test phases properly and that the principal test engineer logged pertinent test observations.

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5.3 Emergency Diesel Generator Cooling Water Flow Test On March 25, the inspector monitored the performance of special test procedure N1-STP-29, EDG Cooling Water Flow Test. The purpose of the procedure was to verify that parallel EDG cooling water pump operation provided adequate EDG heat removal during a simulated loss of offsite power (i.e.. no service water system impact) condition. The EDG cooling water pumps raw water to the individual EDG jacket coolers and the flow returns to a common line connected to the non-safety-related service water return header. The level 1 acceptance criteria of the STP required individual EDG cooling water pump flow of 296 gpm l

with the service water system isolated (296 gpm provides adequate cooling capability at a design lake water temperature of 82 F). The results of this test indicated the following:

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102 EDG cooling water pump flow - 517 gpm t

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103 EDG cooling water pump flow - 294 gpm Based on the results falling below the acceptance criteria, (294 gpm vice 296 gpm), the procedure was secured, the 103 EDG was declared inoperable, and the site operations review committee (SORC) met to review the test results.

The inspector observed the presence of a quorum of members and that discussions focused on appropriate corrective actions to address the test results. The SORC recommended replacement of the 103 EDG cooling water pump to improve system flow rate to the 103 EDG.

In addition, the operations department reviewed the operability of the 103 EDG with a flow rate marginally less than the design specification and determined that the 103 EDG cooling water pump was operable with lake water temperature less than 77*F. The operations department declared the 103 EDG cooling water pump operable with actual lake water temperature at 34*F. The inspector reviewed the engineering calculation supporting the operability determination and considered NMPC's actions to be appropriate.

NMPC reperformed N1-STP-29 on April 4 after the 103 EDG cooling water pump replacement. The test was completed satisfactorily with the following results:

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102 EDG cooling water pump flow - 334 gpm

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103 EDG cooling water pump flow - 329 gpm The inspector concluded that the testing and recommended pump replacement to the EDG cooling water system were thorough, well planned, and properly execute _ _ _ _ _ _ _ _ _ _.

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6.0 ENGINEERING AND TECIINICAL SUPPORT (71707,37700)

l 6.1 NRC Bulletin 88-04. Potential Safety Related Pump Loss l

This bulletin addressed the potential for dead-heading or inadequate recirculation flow I

through one or more pumps in safety-related systems when operating pumps in parallel with a common recirculation line. The core spray system is comprised of two separate loops,11 j

and 12. Each loop consists of two parallel pump sets (core spray pump and a core spray l

topping pump) discharging into a 12-inch diameter pipe. For each loop, pump recirculation is provided via a two inch relief valve in the 12 inch discharge pipe. The relief valve

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discharges through a three inch diameter pipe to the torus. The lift setpoint for the relief valve is 320 psig. The recirculation line is designed for minimum flow of 385 gpm.

The inspector monitored the performance of N1-STP-32, Core Spray Pump Recirculation l

Line Operability Test. This test was developed and performed to confirm the adequate flow l

through the recirculation lines. The pumps were operated for the established times of the l

procedure. Temperature rise was within established limits, and flow through each pump was greater than the acceptance criteria. The test results indicated that there was no dead-heading during parallel pump operation. The inspector determined the test adequately verified the operability of the core spray system when operating the pump sets in parallel.

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. Control Rod Drive Select Switch Modification During power ascension testing at Oyster Creek in December 1989, plant opemtors selected i

two control rods simultaneously. This condition was not supposed to have been possible, and was subsequently investigated by the vendor, General Electric. Modification N1-90-184, revises the control rod drive select switches at Unit I to prevent the possibility of selecting i

two rods at the same time. NMPC made a commitment to the NRC that they would complete this modification during the 1992 refueling outage. The inspector verified the modification was completed at Unit 1 and satisfactorily retested by modification functional test N1-MFT-006, Verification of Single Control Rod Selection Modification.

7.0 SAFETY ASSESSMENT AND QUALITY VERIFICATION (71707,92700)

7.1 Review of Licensee Event Renons - Unit 1 LER 93-03; Failure of primary containment penetration X-154 to meet its LLRT leakage limit. During the outage NMPC could not quantify the "as found" LLRT for the reactor water cleanup (RWCU) isolation valves 33-OlR and 33-03 with the leak rate monitors used.

The valves were subsequently repaired and a satisfactory "as left" LLRT completed. The inspector discussed this "as found" failure with the system engineers. NMPC considers the

"as found" integrated leak rate test (ILRT) to be failed based on the unquantified LLRT leakage for penetration X-154. NMPC plans to discuss this condition in their ILRT report submittal. The inspector had no further question __

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l 7.2 Control of Special Evolutions The :nspector monitored several special test procedures (STPs) performed during the Unit 1 outage. The inspector reviewed GAP-SAT-03, Conduct of Special Evolutions, which governs the requirements and responsibilities c special tests. The procedure requires that

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SORC review level 1 acceptance criteria tc.st exception resolutions prior to resumption of testing. A level 1 acceptance criteria is defined as a characteristic of the system or component which may adversely affect nuclear safety if not met. The inspector determined NMPC followed the guidelines set forth in GAP-SAT-03.

I On two separate occasions, during core spray ar.d EDG cooling water testing, the inspector monitored STP performances where the level 1 acceptance criteria was not met. The principal test engineer secured the evolutions and emergent SORC meetings were held to resolve the test conditions. The inspector attended the SORC meetings and determined the

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technical discussions focused on safety and proper resolution of the test condition. The inspector cetermined the NMPC controls established for SORC review and approval of all special test and modification functional tests was an excellent example of SORC effectiveness.

8.0 MANAGEMENT MEETINGS

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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 arvj discussions held vith Niagara Mohawk representatives, it

was determined that this report does not contain safeguards or proprietary information.

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