IR 05000220/1998015
| ML20198L396 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/23/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198L386 | List: |
| References | |
| 50-220-98-15, 50-410-98-15, NUDOCS 9901040186 | |
| Download: ML20198L396 (31) | |
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l U.S. NUCLEAR REGULATORY COMMISSION j REGION I l
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l Docket / Report Nos.: 50-220/98-15 l 50-410/98-15
- License Nos.: DPR-63 i NPF-69 l
Licensee: Niagara Mohawk Power Corporation P. O. Box 63 4 Lycoming, NY 13093 1
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Facility: Nine Mile Point, Units 1 and 2 l
l Location: Scriba, New York j
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Dates: September 27 - November 21,1998 Inspectors: G. K. Hunegs, Senior Resident inspector B. S. Norris, Senior Resident inspector R. A. Fernandes, Resident inspector l
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R. A. Skokowski, Resident inspector L. M. James, Reactor Engineer
, E. B. King, Physical Security inspector l R. C. Ragland, Radiation Specialist Approved by: Lawrence T. Doerflein, Chief i
Projects Branch 1 Division of Reactor Projects I
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, t EXECUTIVE SUMMARY Nine Mile Point Units 1 and 2 50-220/98-15 & 50-410/98-15 September 27 - November 21,1998 This integrated inspection report includes aspects of licensce operations, engineering, maintenance, and plant support. The report covers an eight week period of resident inspection and the results of a radiological protection inspection by a region based radiation specialist and a safeguards inspection by a region based physical security inspecto Ooerations l
- On November 13,1998, the Unit 2 "B" reactor recircuiation flow control valve i failed closed. Control room operator response to the rapid reduction in power was good. The operators demonstrated a good awareness of the potential for power oscillation due to the power-to-flow condition resulting from the transient. (Section 01.2)
- Unit 2 preparations for the recovery from single loop operations that resulted from !
the November 13,1998 recirculation flow control valve failure were well performe The use of simulator training for Unit 2 operators in anticipation of recovery from single loop operations was considered good. (Section 01.3)
- Poor reactivity management at Unit 1 resulted in a control rod being established in an incorrect position during a control rod sequence exchange. Specifically, personnel error during the development of the control rod movement sheets caused the control rod to be in a position that was not as previously planned. The licensee identified and corrected violation is being treated as a Non-Cited Violation (NCV),
consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-220/98-15-01) (Section 01.4)
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- Operator response to a single control rod scram on November 11,1998 at Unit 2 was good. Technical specification and procedure requirements were appropriately implemented. (Section O2.1)
- On September 11,1998, the Unit 2 operations staff identified and promptly corrected the improper positioning of a manualisolation valve to the suction of the '
Division il standby liquid control system pump. The licensee determined that the valve was locked closed vice locked open, since the performance of surveillance testing on August 27,1998. This licensee identified and corrected violation of j Technical Specification 3.1.5.a.1 (reference LER No. 50-410/98-25)is being treated -
as a Non-Cited Violation (NCV), consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-410/98-15-02)(Section 08.1) j i
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Executive Sumrnary (cont'd)
l Maintenance
- Unit 2 troubleshooting efforts for the single control rod scram on November 11, ;
1998 were reasonable. Although a definite cause could not be determined, corrective and preventive actions were appropriate. (Section M1.2)
- The material condition of the Unit 2 reactor recirculation flow control system was poor as evidenced by the numerous deficiencies identified by Niagara Mohawk Power Corporation during troubleshooting of the November 13,1998, flow control valve failure. (Section M1.3) l l
Enaineerina I
- Unit 2 troubleshooting was methodical, thorough and provided a technically sound ;
explanation of the failure of the recirculation system flow control valve to lock in I the as-is position during the event. However, the initiating cause of the event was not positively identified. (Section E1.1)'
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- The failure to complete timely repairs to the Unit 2 recirculation system flow control ,
valve isolation coils indicated poor management oversight. Work prioritization l failed to recognize the impact that the failed recirculation system hydraulic power ;
unit isolation coils could have on reactivity control. (Section E1.1) ;
- r,om September 29,1998 until October 8,1998, the Unit 2 main stack effluent monitoring instrumentation portion of the gaseous affluent monitoring system was inoperable. The cause was that an alternate power supply had been established to facilitate maintenance, but was inadequate. NMPC determined that a lack of rigor during the technical review process contributed to the problem. Proper corrective actions were taken. The inadequate development of the alternate power supply was determined to be a violation of 10 CFR 50, Appendix B, Criterion lil, " Design Control." However, this licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-410/98-15 04) (Section E8.3)
Plant Sucoort
- Unit 1 exhibited effective performance in maintaining radiation exposures as low as is reasonably achievable (ALARA) in 1998 as evidenced by being on pace to receive the lowest collective dose in station history in spite of significant challenges including a forced outage, a cleanup of the spent fuel pool, and on-line level switch work in feedwater heater bays. (Section R1)
- Unit 2 effectively planned and implemented specific ALARA initiatives during the sixth refueling outage including hot spot and system flushes, reactor vessel nozzle
, hydrowashes, and temporary shielding. However, the overall ALARA goal for 1998 ( was exceeded due to deficiencies in planning, coordination and communication of
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, i Executive Summary (cont'd)
outage work: a 24% increase in outage scope growth; and cancellation of a plannw chemical decontamination of the recirculation systern. (Section R1)
- Access to high radiation areas was effectively controlled with radiation w;rk l permits, health physics briefings, and locked doors. Housekeeping was effectively l l maintained as evidenced by clear aisles and walkways in both Unit 1 and 2 reactor l buildings. Efforts to improve material conditions in the Unit 1 No.11 concentrated
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waste tank room was effective in that encrusted concentrates had been removed from floors and piping, and the room was cleared of loose debris including paper, trash, and asbestos. (Section R2)
- * Deviation event reports were effectively used to document, evaluate, and resolve redioactive waste and transportation issues as evidenced by thorough reviews, accurate causal analyses, and corrective actions which specifically addressed t identified root causes. (Section R7)
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- Deviation event reports, self-assessments, and quality assurance audits were effectively used to identify a declining trend in the radiation dosimetry program and i to initiate corrective actions. (Section R7)
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- On June 17,1998, a security force member left a post prior to ensuring that the l intrusion detection aids were functioning properly. The inspector concluded, based i on observation of the area in question, discussions with security supervision, and j procedural reviews, that there was no violation of NRC requirements as security i was not compromised. However, procedural weakness were noted which were associated with the deactivating and securing of intrusion detection aids. (Section l S2)
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. TABLE OF CONTENTS i
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l E X EC UTIV E S U M M A RY , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii l
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L' TA B LE O F C O NTE NT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v i
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l- Summary of Plant Status ............................................1
1. Operations ....................................................1 I
- , 01 . Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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01.1 Gene ral Com ments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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i 01.2 ' Reactor Recirculation Flow Control Valve Failure (Unit 2) . . . . . . . 1 01.3 Preparations for Recovery from Single Loop Operations (Unit 2) .. 2
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01.4 Control Rod Sequence Exchange Error (Unit 1) .......,...... 3 l 02 Operational Status of Facilities and Equipment ................... 4 ,
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02.1 : Single Control Rod Scram (Unit 2) .......................4 l 05 Operator Training and Qualification (92901) . . . . . . . . . . . . . . . . . . . . . 5 L 05.1 (Closed) Apparent Violation (EEI) 50-410/98-02-04 . . . . . . . . . . . 5 l 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 08.1 (Closed) Apparent Violation (EEI) 50-410/98-14-01: Unit 2 l Standby Liquid Control System inoperable Due to a Valve
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Inadvertently Locked Closed . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
! 08.2 (Closed) LER 50-410/9 8 2 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' 6 l
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i l l .~ M ai nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ' 7
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! M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 i M 1.1 General Com ments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . 7 (; M1.2 Control Rod Scram Troubleshooting Efforts (Unit 2) . . . . . . . . . . . 7 l Reactor Recirculation Flow Control Valve Material Condition Deficiencies .......................................8 M8 Miscellaneous Maintenance issues (92902,92700,90712) . . . . . . . . . . 0
' M8.1 (Closed) Violation 50-2 20/98-01 -03 . . . . . . . . . . . . . . . . . . . . . . 9
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M8.2 (Closed) Unresolved item 50-410/97-02-03 . . . . . . . . . . . . . . . . 9 l .' 111. E n g i n e e ri ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 j E1 Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
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E Unit 2 - Root Cause Determination and Corrective Actions Associated with the Failed Reactor Recirculation Flow Control Valve . . . . . . . 9 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 E (Closed) Unresolved item 50-410/96-06-01 ............... 12 E8.2 (Closed) Unresolved item 50-410/96-06-03 . . . . . . . . . . . . . . . 13 E8.3 - Inoperable Gaseous Effluent Monitoring System (Unit 2) . . . . . . . 13 E8.4 (Closed) Violation 50-2 20/9 8-16-02 . . . . . . . . . . . . . . . . . . . . . 14
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l Table of Contents (cont'd)
I V. Pl a nt S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 14 R1 Radiological Protection and Chemistry (RP&C) Controls ........... . 14 R1.1 As Low as Reasonably Achievable (ALARA) . . . . . . . . . . . . . . . 14 R2 Status of RP&C Facilities and Equipment ......................15 R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . . . . . . . . . . . 16 R8 Miscellaneous RP&C lssues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 i
R (Closed) VIO 50-220:50-410/EA-97-53001013 ............ 18 i R8.2 (Closed) VIO 50-220:50-410/EA-97-53001023 . . . . . . . . . . . . 18 l R8.3 (Closed) VIO 50-220:50-410/EA-97-53001033 . . . . . . . . . . . . 18 i
R8.4 (Closed) IFl 5 0-2 20/9 8-04-01 . . . . . . . . . . . . . . . . . . . . . . . . . 18 R8.5 (Closed) VIO 5 0-2 20/9 8-04-0 2 . . . . . . . . . . . . . . . . . . . . . . . . 19 S2 Status of Security Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . 19 S2.1 (Closed) Licensee Event Report (LER) 50-220 & 410/98-S01, Security Force Member Leaves Compensating Post Without Verifying Zone Secured .............................19 ;
S8 Miscellaneous Security and Safeguards issues ..................20 S8.1 Fitness-For-Duty ..................................20 l
S8.2 (Closed) VIO 50-220/98-08-01 and 50-410/98-08-01 ........ 20 V. M an ageme nt Me eting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 l ATTACHMENTS Attachment 1 - Partial List of NMPC Persons Contacted
- Inspection Procedures Used-items Opened, Closed, and Updated
- List of Acronyms Used l
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I Report Details Summarv of Plant Status With the exception of routine scheduled power reductions, Unit ? operated at 100%
reactor power throughout the inspection perio Unit 2 began the inspection period at 100% reactor power. On October 2,1998, reactor power was reduced to 90% when the fourth point feedwater heater drain pump tripped on a motor electrical fault. The plant was returned to 100% reactor power on October 8, 1998. On November 11,1998, a single control rod scrammed during testing and power was reduced to 97%. On November 12,1998, power was returned to 100%. On November 13,1998, a reactor recirculation flow control valve (FCV) failed closed. The plant was placed in single loop operation and operators stabilized reactor power at 62E The plant remained at a reduced power level through the end of the inspection period during the FCV troubleshooting effort . Operations 01 Conduct of Operations 1 01.1 General Comments (71707)
Using NRC Inspection Procedure 71707, the resident inspectors conducted frequent reviews of ongoing plant operations. The reviews included tours of accessible areas of both units, verification of engineered safeguards features (ESP) system operability, verification of adequate control room and shift staffing, verification that the units were operated in conformance with Technical Specifications (TS), and verification that logs and records accurately identified equipment status or deficiencies. In general, the conduct of operations was professional and safety-Consciou .2 Reactor Recirculation Flow Control Valve Failure (Unit 2) insoection Scope (93702)
At 2:54 p.m. on November 13,1998, with Unit 2 operating at 100% of rated power, control room operators received alarms and indications that the "B" reactor recirculation flow control valve (FCV) had failed closed, which caused a rapid /
reduction in reactor power. The inspectors responded to the control room and observed the operators' response to the event, including the use of procedures and actions taken in accordance with T ' Topical headings such as o1, M8, etc., are used in accordance with the NRC standardized reactor inspection report outlin Individual reports are not expected to address all outline topics. The NRC inspection manual procedure or temporary instruction that was used as inspection guidance is listed for each applicable report section.
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2 Observations and Findinas l Following the closure of the recirculation FCV, reactor power stabilized at l approximately 75% rated power and 59% rated reactor core flow. Operators implemented Procedure N2-SOP-29, " Sudden Reduction in Core Flow." Within the l two hours following the event, the licensee was unable to determine the root cause l of the FCV failure. Therefore, the operators took the actions as required by TS 3.4.1.3 regarding jet pump flow mismatch and secured the "B" reactor recirculation pump in accordance with Procedure N2-CP-29, " Reactor Recirculation System." l Once in single loop operation, the operators stabilized reactor power at 62% and )
took the TS 3.4.1.1 required actions to adjust average power range monitor l setpoints and thermal limit ,
l As observed by the inspectors, the operators' response to this event was goo The actions taken were deliberate and in accordance with procedures. Operators demonstrated a good awareness of the potential for power oscillation due to the power-to-flow condition resulting from the transient. This was evidenced by the operators' discussions during crew briefs and by the assignment of an operator the sole responsibility of monitoring reactor power for indications of power oscillation Conclusions On November 13,1998, the Unit 2 "B" reactor recirculation flow control valve failed closed. Control room operator response to the rapid reduction in power was good. The operators demonstrated a good awareness of the potential for power oscillation due to the power-to-flow condition resulting from the transien j 01.3 Preparations for Recoverv from Sinale Looo Ooerations (Unit 2) Insoection Scoce (71707)
The inspectors assessed the licensee's preparations to recover from single loop ]
operations that resulted from the November 13,1998, failed recirculation flow control valve. The assessment included observation of the evolution as performed in the Unit 2 simulator, review of the applicable procedures, discussions with various members of the Unit 2 operating staff, and observations of the pre-evolution brie Observations and Findinas Since Unit 2 had not recovered from single loop operations since pre-operational testing, Niagara Mohawk Power Corporation (NMPC) evaluated the procedure by l performing the evolution on the Unit 2 simulator. Additionally, NMPC contacted l several other utilities for insights into the recovery from single loop operations and l incorporated additionalinformation to enhance the procedure. Operating crews also i practiced the evolution on the simulator. The inspectors considered the simulator
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training usefulin preparing the operators for this rarely performed evolutio _ _ _ _ _ _ . _ __ _ ._ . .__ . _. _ _ _ _ _ _ . _ _ _ _ _ _ . . _
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l On November 20,1998, the inspectors observed the loop recovery pre-evolution brief. The brief was conducted in accordance with Procedure GAP-SAT-03, l " Control of Special Evolutions." The brief was thorough and provided insights on
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questions raised by the operating crew indicated a good understanding of the upcoming evolution, Conclusions
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Unit 2 preparations for the recovery from single loop operations that resulted from thp November 13,1998 recirculation flow control valve failure were well performe The use of simulator training for Unit 2 operators in anticipation of recovery from single loop operations was considered good.
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01.4 Control Rod Seauence Exchance Error (Unit 1)
- Inspection Scooe (71707)
On November 15,1998, while performing a control rod sequence exchange at Unit 1, operators determined that a rod movement step was missing from the reactivity movement sheets. The inspector reviewed the associated deviation / event report (DER), control rod sequence exchange procedures, and discussed the issue with NMPC personne Observations and Findinos A control rod sequence exchange was scheduled to be conducted on November 14, 1998. The procedure is required to be completed approximately every three full power months and is conducted at a reduced reactor power of 60% to ensure nodal power remains below limits. During the evolution, when implementing a step to move control rod 06-23, operators discovered that the control rod was not at the expected position and stopped the evolution. Specifically, when control rod 06-23 was selected for movement to position 32, it was determined to be at position OO instead of the expected position 46. The reactor engineer was consulted and it was determined that an error in the reactivity movement sheet resulted in an incorrect control rod position. The movement sheet had omitted the step to move control rod 06 23 to position 48. The movement sheet was appropriately revised, the entire rod sequence exchange waa reverified (without additional errors found), and the control rod sequence exchange was completed. An evaluation of thermallimits was completed which showed no adverse affect on core thermallimits because of the control rod misposition. NMPC documented the error in a DER and initiated a root cause analysis. NMPC also briefed operating crews and reactor engineering to stress the importance of proper reactivity management. NMPC is also evaluating l enhanced verification methods for the development of reactivity movement shecF..
l The development of the control rod movement sheet to perform the control rod sequence exchange was poor. Although the evolution had been scheduled in advance, the movement sheet was revised just prior to conducting the evolutio . -
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Supervisor oversight was not appropriate for the reactivity management aspects of developing the rod movement sheet and the second verification was not thorough enough to identify the problem. The incorrect development of the control rod sequence exchange movement sheet was contrary to the station reactivity management control procedures and is a violation of TS 6.8.1. However, this licer.see identified and corrected violation is being treated as a Non-Cited Violation (NCV), consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-220/98-15-01)
I Conclusions Poor reactivity management at Unit 1 resulted in a control rod being established in I
an incorrect position during a control rod sequence exchange. Specifically,
! personnel error during the development of the control tod movement sheets caused I
the control rod to be in a position that was not as prev ously planned. This Ucensee identified and corrected violation is being treated as a Non-Cited Violation (NCV),
consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-220/98- l 15-01)
02 Operational Status of Facilities and Equipment O2.1 Sir, ale Control Rod Scram (Unit 2) Inspection Scope (71707)
On Novernber 11,1998, a single control rod scrammed at Unit 2 during the performance of manual scram functional testing. The inspector reviewed operator's immediate response and observed portions of subsequent recovery actions.
- Applicable procedures, TS requirements, and the DER were reviewed and discussed
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with NMPC personnel, Observations and Findinas On November 11, during the performance of Procedure N2-OSP-RPS-WOO 2,
" Manual Scram Functional Test," Control Rod 14-19 scrammed from position 48 when the reactor protection system logic channel was tripped. Operators entered appropriate response procedures and reduced power by 40 megawatt electric
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TS 3.1.3.1, " Control Rods," was properly entered. Core thermal power limits were l determined to be acceptable. NMPC determined that the apparent cause was a loose or intermittent connection at the reactor protection system (RPS) fuse holder for the control rod. (see Section M1.2) Conclusions l
Operator response to a single control rod scram on November 11,1998 at Unit 2 was good. Technical specification and procedure requirements were appropriately implemente _ _. - -.- _ - . _ - - - . .. -- _. . _ _ . - - .-
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05 Operator Training and Qualification (92901)
05.1 (Closed) Aooarent Violation (EEI) 50-410/98-02-04: No licensed operator at the controls. The NRC completed the investigation (NRC Office of Investigation Report No.1-08-10) concerning a former licensed Reactor Operator (RO) who left the controls of Unit 2 unattended for approximately six minutes on December 24,199 The NRC investigation determined that a violation of Technical Specifications occurred and by separate letters, dated November 19,1998, both NMPC and the individual were cited in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-160 Accordingly, eel 50-410/98-02-04is close l As stated in the November 19,1998 letter to NMPC, no response to the Notice of ,
( Violation was required, based upon NMPC's docketing of the event and corrective 1 l actions taks.7 (reference LER 50-410/98-02and Supplement 1, dated February 17, 1 1998 and August 17,1999, respectively). Accordingly, this violation is closed (EA l No.98-267, VIO 50-410/93-15-05) '
l 08 Miscellane.ous Operations Ir. sues i 08.1 (Closed) Accarent Violation (eel) 50-410/98-14-01: Unit 2 Standby Liauid Control System inocerable Due to a Valve inadvertentiv Locked Closed insoection Scope (929011 On September 11,1998, operators identified that a normally locked open valve in the Unit 2 standby liquid control system (SLS) was locked closed. The initial actions by NMPC were described in NRC Inspection Report (IR) 98-14, Section M1.3; however, pending completion of the NMPC investigation, and issuance of the associated Licensee Event Report (LER), this issue was left open. The inspectors reviewed the DER, LER No. 50-410/98-25,and the Independent Plant Examination l (IPE), discussed the event with the Unit 2 Operations and Plant Managers, and performed an independent system line-up of the Unit 2 SL Observations and Findinas l On September 11, during a routine surveillance test of the Division i SLS, operators l discovered that the manualisolation valve (2SLS*V46) between the SLS tank and the suction of the Division 11 SLS pump was locked closed. The Station Shift l
Supervisor (SSS)immediately declared Division il SLS inoperable. Because the Division i SLS was rendered inoperable due to the in-progress surveillance test, the SSS took prompt action to return valve 2SLS*V46 to the open position and comply with the Technical Specification (TS) eight-hour action statement (TS 3.1.5.a.2) to restore the system's safety function to servic NMPC's investigation revealed that the last known time that 2SLS*V46 was operated was during surveillance testing on August 27,1998. During that l
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surveillance test, the valve was manipulated four times, with the final position intended to be locked open. NMPC determined that the root cause included poor work practices; in that, the operators did not use proper self-checking techniques to position the valve and independently check its required positio In addition to the SSS having directed valve 2SLS*V46 opened and independently verified open, a check of the entire SLS line-up was performed and a verification of select safety systems at both units was conducted. As stated in LER No. 50-410/98-25, dated October 12,1998, remediation was held with the individuals involved in the August 1998 surveillance test and training was conducted with all operators on the lessons learned from this even NMPC's description and analysis of this event, as documented in LER 98-25, was consistent with the inspectors' review and assessment. The increase in core damage frequency and risk significance of the closed manual suction valve to the Division 11 SLS pump was minimal, in that, the open manual cross-connect valves (2SLS*V28 and V29) would have provided sufficient net positive suction head and flow to the Division 11 pump. Consequently, the SLS safety function was available, but aegraded since the completion of the August 1998 surveillant a tes As documented and properly reported in LER No. 98-25, the failure of the operations staff to restore the Division 11 SLS to an operable status on August 27, 1998, was contrary to Technical Specifications. TS 3.1.5.a.1 states that with one pump and/or explosive valve inoperable, restore the inoperable pump and/or valve within seven days. Valve 2SLS*V46 remained closed until September 11, (a 15-day period). This licensee identified and corrected TS violation is being treated as a Non-Cited Violation (NCV 50-410/98-15-02), consistent with Section Vll.B.1 of the NRC Enforcement Policy. The inspectors noted that NMPC properly classified this event as a maintenance preventable functional failure under the Maintenance Rul Conclusions On September 11,1998, the Unit 2 operations staff identified and promptly corrected the improper positioning of a manualisolation valve to the suction of the Division ll standby liquid control system pump. The licensee determined that the valve was locked closed vice locked open, since the performance of surveillance testing on August 27,1998. This licensee identified and corrected violation of Technical Specification 3.1.5.a.1 (reference LER No. 50-410/98-25)is being treated as a Non-Cited Violation (NCV), consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-410/98-15-02)
08.2 (Closed) LER 50-410/98-25: Inoperability of standby liquid control system due to mispositioned valve. The inspectors reviewed the technical issues associated with this LER and initially described the event in NRC Inspection Report 50-220,410/ *
98-14; subsequent review is contained in Section 08.1 of this inspection repor The insoectors conducted on-site follow-up and completed an in-office review of the LER and considered the root cause and corrective actions to be reasonable. The l
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description and analysis of the event, as contained in the LER, were consistent with the inspectors' understanding of the event. This LER is close l II. Maintenance
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l M1 Conduct of Maintenance l
M1.1 General Comments (61726,62707) l Using NRC Inspection Procedures 61726 and 62707, the resident inspectors periodically observed various maintenance activities and surveillance tests. As part of the observations, the inspectors evaluated the activities with respect to the requirements of the Maintenance Rule, as detailed in 10CFR50.65, in general, maintenance and surveillance activities were conducted professionally, with the work orders (WOs) and necessary procedures in use at the work site, and with the appropriate focus on safety. Specific activities and noteworthy observations are detailed in the inspection report. The inspectors reviewed procedures and observed i all or portions of the following maintenance / surveillance activities: l l
N1-ST-Q8, Liquid Poison Pump and Check Valve Operability OSP-RP3-WOO 2, Manual Scram Functional Test WO 98-12869, Troubleshoot Control Rod 14-19 OSP-LOG-D001, Recirculation Loop Mismatch N1-ST-M4, Emergency Diesel Generator Operability Test ST-Q25, Emergency Diesel Generator Cooling Water Test N2-OSP-EGS-M@002, Diesel Generator and Diesel Air Start Valve Operability Test - Division 111 M1.2 Control Rod Scram Troubleshootina Efforts (Unit 2) [rtsp_ection s Scoce (61726,62707)
On 14avomber 11,1998, a single control rod scrammed at Unit 2 during the performance of manual scram functional testing. The inspector observed work control activities, reviewed the deviation and event report and discussed the f ailure with licensee personnel, l
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i b. Observations and Findinas Work Order 98-12869 was prepared to troubleshoot the control rod. Although extensive troubleshooting efforts were conducted, no definitive cause could be identified. Troubleshooting included checking the reactor protection system fuse, fuse holder and related circuitry, and system hydraulics. Plant activities were reviewed and it was determined that there were no activities that may have disturbed the system. NMPC determined that the apparent cause was a loose or intermittent connection at the fuse holder. NMPC's irnmediate corrective actions were to replace the fuse and fuse holder. Additional preventive actions to be scheduled include inspection of scram solenoid pilot valve and reactor protection fuses and fuse terminations for degradation. NMPC considered the single control rod scram to be a functional failure under the maintenance rul c. Conclusions Unit 2 troubleshooting efforts for the single control rod scram on November 11, 1998 were reasonable. Although a definite cause could not be determined, corrective and preventive actions were appropriat M1.3 Reactor Recirculation Flow Control Valve Material Condition Deficiencies (Unit 2)
a. Inspection Scoce (62707)
During troubleshooting of the November 13,1998, failure of the Unit 2 reactor recirculation flow control valve (FCV) several material conditions deficiencies were identified by NMPC. These deficiencies were in addition to the deficiencies that caused the failure of the valve. The inspectors reviewed the licensee's actions to address these deficiencie Observations and Findinas The deficiencies included blown fuses in various FCV system alarm circuits and the automatic start circuit of the standby hydraulic pump, and defective or out-of calibration temperature, level, and flow switches. The deficiencies were corrected and DER 2-98-3463was written to evaluate the preventive maintenance program for the reactor recirculation FCV. Although these deficiencies did not impact the safety function of the system, they indicated poor material condition of the syste NMPC's investigation identified that two blown fuses were undersized. Specifically, 3/8 amp fuses were installed where 1 amp fuses were required. NMPC concluded that the undersized fuses were installed by the original manufacturer prior to shipping the equipment to the utility. The recirculation control panelis not safety-
, related and therefore not subject to the requirements of 10 CFR 50 Appendix B,
" Quality Assurance Criteria for Nuclear Power Plant and Fuel Reprocessing Plants."
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The material condition of the Unit 2 reactor recirculation flow control system was poor, as evidenced by the numerous deficiencies ideritified by Niagara Mohawk Power Corporation during troubleshooting of the Novernber 13,1998, flow control valve failure.
l M8 Miscellaneous Maintenance issues (92902,92700,90712)
M8.1 (Closed) Violation 50-220/98-01-03: Inadequate testing of liquid poison system piping to verify operability. The NMPC testing program did not verify that the piping from the liquid poison tank to the pump suction valves was unobstructed. NMPC subsequently developed and approved a surveillance test to verify system flow when taking suction from the liquid poison tank and performing a flush of the piping after the test. In addition, all fluid system operations surveillance procedures were reviewed to assure that hydraulic flow paths were being properly demonstrate NMPC did not identify arty other system operability concerns as a result of the review. The inspector conducted an on site review of the new surveillance procedure and observed other liquid poison system surveillance testing. No additional concerns were identified. The inspectors concluded that the licensee's corrective actions had been appropriate. This violation is close M8.2 (Closed) Unresolved item 50-410/97-02-03: Adequacy of seismic monitoring surveillance test procedure. The concern involved the use of a vendor's procedure concurrent with the NMPC procedure to meet technical specification testing requirements. The NMPC surveillance test program was not consistent with this procedural application. NMPC subsequently performed a review of all seismic monitoring surveillance tests performed in the past and determined that the technical specification required actions were performed satisfactorily, in addition, the licensee re-issued surveillance test Procedure N2-ISP-ERS-R101," Operating Cycle Calibration Test of Triaxial Seismic Monitoring Time History Accelerograph Instrument Channels," to incorporate the vendor's test methods. The changes were endorsed by the vendor. The inspector's on site review determined that this issue did not involve a violation of regulatory requirements. This unresolved item is close . Enoineerina E1 Conduct of Engineering E Unit 2 - Root Cause Determination and Corrective Actions Associated with the Failed Reactor Recirculation Flow Control Valve a. inscoetion Scoce (37551. 62707)
The inspectors assessed the licensee's root cause determination and ctrrective
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actions for the November 13,1998, failure of the Unit 2 "B" reactor recirculation l flow control valve (FCV). The assessment included a review of the associated
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l deviation / event reports (DERs), applicable Updated Final Safety Analysis Report l (UFSAR) sections, and selected sections of the Niagara Mohawk Power Corporation I Individual Plant Examination (IPE). The inspectors also discussed the issue with j NMPC personnel, and observed the licensee's Station Operations Review Committee l (SORC) meeting, which discussed the root cause of the event, in addition, the i inspectors also reviewed the impact of the equipment failure with respect to the l Maintenance Rule (10 Code of Federal Regulations (CFR) 50.65).
b. Observations and Findinas '
l The two reactor recirculation FCVs are positioned by hydraulic actuators that I receive motive power from independent hydraulic power units (HPUs). The HPUs I generate and control flow and pressure of the hydraulic fluid to the actuator. Each HPU consists of two redundant sub-loops, with some common components, such l as hydraulic fluid reservoirs and drains. The control signals to the HPUs are provided through a programmable logic controller (PLC) that receives inputs from l sensors and operator controls, and provides output signals to the HPU and associated components. During normal operation, one of the two redundant hydraulic sub-loops will control the actuator while the other sub-loop is in standb Shou!d a sub-loop malfunction occur, the running sub-loop would trip and the standby sub-loop would start and assume control. However,if there were indications of a problem common to both sub-loops, a trip signal would be generated and the running sub-loop would trip and the standby sub-loop would remain idlo. In addition, each HPU sub-loop contains isolation coils used to lock the FCV in the as-is position upon a failure of the HP Troubleshooting by NMPC identified that a combination of two equipment deficiencies and a design deficiency were needed to allow the valve to go closed during the event. Specifically, the two equipment deficiencies were: 1) the isolation coils for each sub-loop of the "B" HPU were failed, which prevented the FCV from locking in the as-is position; and 2) the valve position servo currents were not balanced and allowed the flow of hydraulic fluid to reposition the FCV, if the standby hydraulic pump was running. The design deficiency was a logic error in the PLC that allowed the standby sub-loop to start upon a trip signa With respect to the equipment deficiencies described in the previous paragraph, NMPC was aware of these issues prior to the event. Specifically, the problem identifications (PIDs) were written on the damaged isolation coils in July,1998, for subloop "A" and in August,1998, for sub-loop "B." An attempt to replace the coils during a planned down power evolution was canceled due to concerns with the post maintenance testing procedure. Due to previous problems with these isolation coils failing, NMPC was evaluating a design change to provide permanent solutio Due to other priorities, this design change was not yet complete. As for the i imbalanced servo currents, a DER was written during the recently completed refueling outage, and the decision was made to accept the condition as-is.
l Through their troubleshooting, NMPC was able to reproduce the closing of the FCV on several different trip signals. However, they were unable to positively identify
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the trip signal that initiated the event. NMPC testing of the control circuitry identified anomalies associated with the two cards within the recirculation flow control panel and concluded that the most likely initiator of the event was a spurious trip signal generated by these card The root cause of the event, as determined by NMPC, focused on the f ailure to repair the non-functional isolation coils upon initial identification. The corrective actions addressed the equipment deficiencies identified during NMPC's troubleshooting and testing. NMPC intended to perform additional tests on the suspect cards removed from the recirculation flow control panel to confirm spurious signals from these cards initiated the event. Plans were developed to address the possibility of similar concerns on the "A" reactor recirculation FCV at the earliest possibility. Also, corrective actions were developed to address process problems regarding the prioritization of maintenance and engineering activities, and to evaluate the reactor recirculation FCV preventive maintenance progra The inspectors reviewed the DER associated with the event, and observed the SORC meeting regarding the approval of the DER disposition. The inspectors considered NMPC's root cause of the event to be appropriate. NMPC's troubleshooting was methodical and thorough and provided a technically sound explanation of the failure of the FCV to lock in the as-is position during the even Although NMPC was unable to positively identify the initiator of the event, their conclusion was reasonable. The inspectors noted that the recirculation control panelis not safety-related and therefore, not subject to the requirements of 10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear Power Plant and Fuel Reprocessing Plants." However, the failure to complete timely repairs to the i system's isolation coils indicated poor management oversight, in that during the prioritization of work, NMPC failed to recognized the impact that the failed recirculation system isolation coils could have on reactivity contro The inspectors considered the corrective actions taken by NMPC to address the hardware deficiencies to have been appropriate. Also, the inspectors considered the corrective actions taken to address the identified process concerns to be reasonable to identify similar concerns and prevent recurrenc During the event, the recirculation FCV f ailed to operate as design. Specifically, the FCV did not lock in the as-is position upon a failure of the HPU. As a result of the event, the inspectors reviewed the accident analysis section of the Unit 2 UFSAR and verified that closure of a recirculation FCV had been previously reviewed and found acceptable.
- During NMPC's activities associated with the reactor recirculation FCV failure, the inspectors verified that appropriate actions were taken in accordance with the Maintenance Rule. Specifically, NMPC concluded that the reactor recirculation FCV l failure was a maintenance preventable functional failure (MPFF) and will be further j evaluated. Although this failure was considered an MPFF, it did not change the
, classification of the recirculation system, since the system was already classified as l a category a(1) system due to previous failures associated with the FCV.
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Additionally, NMPC evaluated the impact of the f ailure on scheduled work and rescheduled work as necessary to minimize ris Conclusions 1 l
Unit 2 troubleshooting was methodical, thorough, and provided a techmcally sound explanation of the failure of the flow control valve to lock in the as is position during the event. However, the initiating cause of the event was not positively identifie l
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The failure to complete timely repairs to the system's isolation coils indicated poor management oversight. Work prioritization failed to recognize the impact that the failed recirculation system hydraulic power unit isolation coils could have on reactivity contro i
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E8 Miscellaneous Engineering issues (92903) I l
E8.1 (Closed) Unresolved item 50-410/96-06-01: Full core offloads at Unit 2. This issue was initiated to evaluate the licensing basis for NMPC's past practice of off-loading
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the full core. The inspectors performed an in-office review of Licensco Event Report (LER) 50-410/96-03, generated as a result of NMPC's determination that certain full core offloads to the spent fuel pool were outside the design bases of the plan Specifically:
(1) Full core offloads were performed during refueling outages conducted in September 1990, March 1992, October 1993, and April 199 (2) The full core offloads were initiated following the minimum 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after shutdown limitation assumed in Updated Final Safety Analysis Report (UFSAR)
Section 9. (3) The maximum spent fuel pool temperature reached following the full core offloads was below 125 degrees Fahrenheit (* F). This temperature was below the design criterion of 150*F described in UFSAR Section 9. The inspectors noted that UFSAR Section 9.1.3, by introducing the terms " normal and off-normal," characterizes each of the design basis cases in a way that could imply that full core offloads are to occur on a less frequent basis than partial core offloads. The inspectors were unable to conclude, however, that Section 9. represents a specific commitment to limit the frequency with which full core offloads are conducted. As noted above, nothing in the UFSAR description of the spent fuel pool cooling design basis is sensitive to the frequency with which full
, core offloads are conducted. Therefore, the licensee remained in compliance with
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the technical requirements for spent fuel pool temperature and minimum offload tim ; . .
The inspectors concluded that the practice of off-loading the full core during each refueling outage did not represent a change to the f acility or to procedures l described in the UFSAR, and thus did not require a review pursuar*. to 10 CFR
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50.59. On this basis, the inspectors concluded that no violation os regulatory
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requirements occurred. Unresolved item 50-410/96-06-01is closed.
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E8.2 (Closed) Unresolved item 50-410/96-06-03: Single f ailure criterion for spent fuel pool cooling. UFSAR Section 9.1.3.3 directs the other cooling loop to be placed into service within one hour, should the operating spent fuel pool cooling loop be lost due to a single-failure. However, during four refueling outages, conducted between 1990 and 1995, divisional (electrical) bus maintenance was performed, j during which time the redundant train of spent fuel pool cooling was unavailabl Operating Procedure (OP)-38, for the spent fuel pool cooling and cleanup system had been inconsistent with the UFSAR and did not contain the requirement to be able to place the redundant train in service within one hour. NMPC determined that the safety consequence of this problem was limited, in that the electrical bus cutages did not exceed time-to-boil estimates, and maximum pool heat loads were within the design basis value of 31.2 (MDtu) per hour. Also, shutdown risk measures were in effect during the offloads in question. Although alternative means were available to ensure that decay heat could have been removed from the spent fuel pool, during past divisional bus outages, NMPC did not adequately translate the design basis into procedure While this inconsistency represented a violation of 10 CFR 50, Appendix B, Criterion Ill, " Design Control," it was not a condition that could have reasonably been prevented by corrective actions for previous similar violations. This licensee identified and corrected violation is being treated as Non-Cited Violation consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-410/98-15-03)
E8.3 Inocerable Gaseous Effluent Monitorina System (Unit 2) Insoection Scope (90712,92700)
NMPC determined that from September 29,1998, until October 8,1998, the main stack effluent monitoring instrumentation portion of gaseous effluent monitoring system (GEMS) had been inoperable in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Therefore, in accordance with Tachnical Specification Table 3.3.7.10.1, " Radioactive Gaseous Effluent Monitoring instrumentation," NMPC submitted a special report to the NR The inspector conducted an on site review of NMPC special reports dated October 16,1998, and November 13,1998, concerning the inoperable GEMS, Observations and Findinas l
! The GEMS continuously monitors the gaseous effluents from the plant at the main stack, and the combined reactor and radwaste buildings ventilation exhaust duct.
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On September 29,1998, NMPC established an alternate power supply to GEMS to facilitate battery replacement while maintaining GEMS operable. On October 6, 1998, NMPC determined that the main stack effluent monitoring instrumentation l portion of GEMS would not operate when post accident loads were added to the system's alternate power supply. An investigation showed that the alternate power supply capacity was inadequate. The alternate power supply was sufficient for normal operation, but not for post accident conditions due to increased system l loads. The licensee determined cause for the inadequate alternate power supply to l
the GEMS system was lack of rigor in the design review process. The inspector noted that backup sampling methods were available to obtain post- accident sampling to ansess radiological releases, if neede I l
The establishment of an inadequate alternate power supply to the GEMS was a violation of 10CFR50, Appendix B, Criterion Ill, " Design Control." However, this licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-410/98-15-04) Conclusion From September 29,1998 until October 8,1998, the Unit 2 main stack effluent monitoring instrumentation portion of the gaseous effluent monitoring system was inoperable. The cause was that an alternate power supply had been established to facilitate maintenance, but was inadequate. NMPC determined that a lack of rigor during the technical review process contributed to the problem. Proper corrective actions were taken. The inadequate development of the alternate power supply was determined to be a violation of 10CFR50, Appendix B, Criterion Ill, " Design Control." However, this licensee identified and corrected violation is being treated l as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-410/98-15-04)
E8.4 (Closed) Violation 50-220/98-16-02: Failure to identify and implement corrective actions for core spray pump motor cooler flow deficiency. This violation was issued in NRC Inspection Report 50-220/98-16and 50-410/98-16with no response required. Accordingly, this violation is close IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 As low as Reasonably Achievable (ALARA) Inspection Scope (83750)
A selected review was performed of programs to maintain radiation exposures as low as is reasonably achievable (ALARA). Information was gathered by a review of radiation exposure goals, selected ALARA reviews, several ALARA initiatives, through discussions with cognizant personnel, and tours through the plant.
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b. Observations and Findinas Unit 1 ALARA challenges for 1998 included a forced outage, spent fuel pool cleanup, concentrated waste tank room cleanup, and leve! switch work in the feed water heater bays. In spite of these challenges, as of October 30,1998, Unit 1 was on pace to receive the lowest collective dose for any year in their operating history. This success was attributed to increased awareness and communication and cooperation between work groups. ALARA performance was closely tracked and routinely reported to work groups. Remote cameras were also frequently used to monitor steam related areas with elevated dose rate Major ALARA initiatives taken at Unit 2 to reduce radiation exposures during the NMP2 sixth refueling outage included frequent radiation protection /ALARA briefings, hot spot and system flushes, reactor vessel nozzle hydrowashes,41 temporary shielding installations, and use of cameras and remote monitoring. In spite of these !
efforts, as of October 28,1998, collective dose at Unit 2 was 317.702 person-rem and had exceeded the original 1998 goal of 239 person-rem. The ALARA supervisor attributed the increased exposure to a 24% outage scope growth which included work on recirculation system (RCS)isolatico va!ves and flexible hose removalin the drywell; cancellation of a planned chemical decontamination of the RCS; and deficiencies in planning, coordination, and communication that resulted in increased time spent working on RCS isolation valves and on RCS flexible hose removal. To ensure that good practices and lessons learned were captured, a critical post outage summary was developed that detailed lessons learned and opportunities for improvemen c. Conclusions Unit 1 exhibited effective performance n maintaining radiation exposures as low as is reasonably achievable (ALARA)in 1998 as evidenced by being on pace to receive the lowest collective dose in station history in spite of significant challenges including a forced outage, a cleanup of the spent fuel pool, and on-line level switch work in feedwater heater bay Unit 2 effectively planned and implemented specific ALARA initiatives during the sixth refueling outage including hot spot and system flushes, reactor vessel nozzle hydrowashes, and temporary shielding. However, the overall ALARA goal for 1998 was exceeded due to deficiencies in planning, coordination and communication of outage work; a 24% increase in outage scope growth; and cancellation of a planned chemical decontamination of the recirculation syste R2 Status of RP&C Facilities and Equipment Insoection Scope (83750)
A review was performed of housekeeping, material conditions, and radiological boundaries. Information was gathered through tours of Unit 1 and Unit 2 reactor buildings, through discussions with cognizant personnel, and a review of a video
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taken of the cleanup of the Unit 1 No.11 concentrated waste tank room and cubicle, Observation and Findinas Access to high radiation areas was well controlled with radiation work permits, health physics briefings, radiological postings, and locked doors. Walkways and aisles were clear and free of debris and radiological boundaries were well delineate A video of the clean up of the No.11 concentrated waste tank room showed that housekeeping had significantly improved, in that encrusted concentrates had been removed from floors and piping, and the room was cleared of loose debris including l paper, trash, and asbestos, i Conclusions l
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permits, health physics briefings, and locked doors. Housekeeping was effectively maintained as evidenced by clear aisles and walkways in both Unit 1 and 2 reactor l
buildings. Efforts to improve material conditions in the Unit 1 No.11 concentrated ;
l waste tank room were effective, in that encrusted concentrates had been removed l
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l R7 Quality Assurance in RP&C Activities Insoection Scoce (83750)
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The inspector reviewed quality assurance and self-assessment oversight of the
, radiological controls organization. Information was gathered by a selected review of
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radiological control issues documented in deviation event reports, quarterly self-
! , assessments, and quality assurance (QA) audits, Observations and Findinas Deviation / Event reports (DERs) used to document, evaluate, and resolve the radioactive wastes and transportation issues discussed in Sections R8.1 - R8.5 of this report were thorough, causal analyses appeared accurate, and corrective and preventive actions specifically addressed identified root causes and causal factor Quarterly self-assessments evaluated the status of radiological control programs and were used to identify trends and weaknesses. Self-assessments discussed deviation event reports, staff assessments, QA/ peer assessments, and provided an overall assessment for major program area Quality Assurance Audit Report No. 98013," Radiation Protection Program,"
L provided an assessment of radiation protection programs in the areas of ALARA, dosimetry, effectiveness of deviation event reports, updated final safety analysis
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report, training and qualifications. The audit provided a thorough, critical, and detailed review and resulted in the initiation of a number of DER NMPC identified a notable trend, in that DERs, self-assessments, and quality assurance audits all identified programmatic weaknesses in dosimetry including procedural guidance, record and data management, bioassay, dosimetry placement, and electronic dosimetry malfunctions. In response to these findings, major program improvements were initiated including the development and revision of numerous procedures. For example, DER C-98-0820, discussed in QA audit report No. 98013, indicated that a lack of procedural guidance resulted in the download of irnproperly formatted data into the radiation protection computer system (RPCS).
Also, it was recognized that the dosimetry staff had to perform many unproceduralized manual tasks because of weaknesses in the RPCS software. The dosimetry supervisor stated that a prioritized list of needed software enhancements was being generated and plans were being made to address these concern Incomplete Exposure Reco_ During a review of an individual exposure file a minor violation was identifie CFR 19.13(e) requires NRC licensees to provide exposure information to individuals upon termination of their employment,if it is requested. If estimated, the exposure information is required by 10 CFR19.13(e)to be provided with a clear indication that it is an estimate. Contrary to this requirement, on May 26,1998,an individual was provided exposure information labeled " Record" rather than estimat The record exposure did not include 3.7 rem of calculated skin dose that was received from exposure to a hot particle. (Note: The skin dose limit is 50 rem).
Dosimetry clerks were not aware that a separate skin dose assessment had been performed and as a result, only provided the individual with results from thermoluminescent dosimeter (TLD) processing. The root cause was attributed to
- the lack of a process to notify dosimetry clerks when a special (e.g., skin or internal) dose assessment was being/had been performed. At the time of the inspection, the individual's exposure file did contain correct and up-to-date information and it was scheduled to be sent to the individual at the end of the yea Immediate corrective actions included sending the individual an updated " record" exposure and initiating a review of all other files that had a skin or internal dose assessment. No additional discrepancies in reported dose were identified. Planned preventive actions included procedural revisions and/or compu ir software enhancements to " flag" or notify dosimetry clerks when dose ;ssessments were in proqress or had been performed. This failure represents a violation of minor significance and is not subject to formal enforcement action c. Conclusions Deviation / Event reports were effectively used to document, evaluate, and resolve radioactive waste ard transportation issues as evidenced by thorough reviews, accurate causal analyses, and corrective actions which specifically addressed identified root cause ___
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Deviation / Event reports, self-assessments, and quality assurance audits were l effectively used to identify a declining trend in the radiation dosimetry program and to initiate corrective action R8 Miscellaneous RP&C lesues (86750,92904)
R (Closed) VIO 50-220:50-410/EA-97-53001013: Radiation levels exceeded allowable limits in truck cab. This item was originally opened due to shipment of radioactive materials causing dose rates of 2.8 millirem in the cab of the transport vehicle that exceeded the 2 mrem / hour limit. The root cause of the event was determined to be an inadequate radiological survey with multiple causal factor This on site review verified that corrective and preventive actions identified in the February 23,1998, Reply to Notice of Violation adequately addressed root causes and were performed. Enhancements were made to procedural guidance for the conduct of radiological surveys for radioactive material / waste shipments and specific continuing training was developed and conducted. This item is close R8.2 (Closed) VIO 50-220:50-410/EA-97-53001023: Shipment of incorr3ct liner of radwaste to a processor. This item was originally opened after an incorrect liner was inadvertently shipped to a vendor for processing. The root cause of the event was determined to be inadequate work package preparation with multiple personnel errors and contributing causes. This review verified that corrective and preventive actions identified in the February 23,1998, Renly to Notice of Violation adequately addressed root causes and were performed. Procedural guidance was enhanced to ensure a systematic approach to preparing radioactive material / waste shipment Work orders, which include appropriate verifications, are now used for all radioactive material / waste shipments. This item is close R8.3 (Closed) VIO 50-220:50-410/EA-97-53001033: Radioactive material shipped to an office complex. This item was originally opened after a metal sample removed from the Unit 1 emergency core cooling condenser tube sheet was shipped on September 25,1997, to a BWX administrative office complex rather than the intended licensed facility. The root cause of the event was determined to be cognitive error on the part of a stock handler and inadequacies in controlling procedures. This review verified that corrective and preventive actions identified in the February 23,1998, Reply to Notice of Violation adequately addressed root causes and were performed. Procedural guidance was enhanced to require all shipments of radioactive rnaten. to be performed by Radwaste personnel who have specific expertise and training in the area of radioactive material handling and shipping. This item is closed.
l R8.4 (Closed) IFl 50-220/98-04-01: Follow-up on scaling factor determination relative to j changing plant conditions. This item was originally opened due to a concern that i
sample frequencies used to evaluate the adequacy of isotopic scaling factors (ratios of easily identifiable gamma emitters to hard to detect beta and alpha emitters) was not frequent enough to represent the plant isotopic mix, if plant conditions rapidly changed. NMPC addressed this concern by comparing the isotopic mix on the r
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waste form being shipped to the isotopic mix ror the composite used to determine the scaling factors. This item is close R8.5 (Closed) VIO 50-220/98-04-02: Flatbed trailer returned to service with radiation levels in excess of DOT limits. This item was originally opened after a flatbed trailer that had been released by Unit 1 on February 6,1998, was delivered to BWX technologies in Vandergrift, PA on February 9,1998, with two isolated spots of radioactive contamination (1.4 mrem /h and 30 mrem /h) which exceeded the allowable dose limit of 0.5 mrem /h. The root cause of the event was determined to be an inadequate survey by the health physics technician that performed the survey. This review verified that corrective and preventive actions identified in the April 28,1998, Reply to Notice of Violation adequately addressed root causes and were performed. Procedural guidance for the performance of surveys on large items was enhanced and studies were initiated to investigate the use of survey j instruments with larger probe surface areas. This item is close S2 Status cf Security Facilities and Equipment S2.1 (Closed) Licensee Event Report (LER) 50-220 & 410/98-S01, Security Force Member Leaves Compensatina Post Without Verifvina Zone Secured Intoection Scope (81700)
The inspector conducted an on site review of the LER and inspected compensatory measure Observations and Findinas
! On September 29,1998, the inspector reviewed a deviation / event report (DER) '
dated June 17,1998, which was associated with a security force member (SFM)
leaving a post prior to ensuring that the intrusion detection aids were functioning properly. Specifically, Security Procedure S-SEC 3.3, Section 7.10, states, in part, shat if the alarm on the vehicle gate has been inactivated during vehicle access control activities, the gate SFM and tha central alarm station (CAS) operator shall ensure the alarm is resecured and verified functional before leaving the affected area. However, on June 17,1998, at 3:49 p.m., the vehicle gate was left unmanned without verifying the alarm functions. The LER root cause and corrective l
actions were reasonable and the LER is closed.
i l Conclusions On June 17,1998, a security force member left a post prior to ensuring that the intrusion detection aids were functioning properly. The inspector concluded, based
on observation of the area in question, discussions with security supervision, and proceduralieviews, that there was no violation of NRC requirements as security was not compromised. However, procedural weakness were noted which were associated with the deactivating and securing of intrusion detection aids.
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S8 Miscellaneous Security and Safeguards issues S8.1 Fitness-For-Duty I Inspection Scope (81700,81810)
l 10 CFR 26.20(a)(2) requires that the licensee policy for fitness-for-duty (FFD) to address other factors that could affect fitness for duty such as mental stress, fatigue, and illness. The inspector reviewed the NMPC policies and procedures that cover fatigue of security staff. The policies and procedures were reviewed to determine if fatigue, while on duty at Nine Mile Point (NMP), caused by employment outside NMP was controlle Observations and Findinas AH employees of NMPC are covered by personnel policy l-5.1, which specifically allows employment outside NMP that does not adversely affect employment with NMPC. Security staff are not defined as safety-related workers and are not under the jurisdiction of Procedure GAP-FFD-02, which limits the amount of time, during the week, an employee may work at NMP. This procedure is precautionary and intended to prevent fatigue while on the job. It is therefore possible for Security personnel to work an unlimited amount of time at Nine Mile Point and then, in turn, work an unlimited amount of time in outside employmen !
l Procedure NIP-FFD-01, Rev. 6, specifically includes fatigue, in Paragraph 4.12, as '
l part of the fitness-for-duty requirements that are observed by trained supervisory personnel. This requirement is expanded on in a security specific procedure, SSAP 21.0, Rev. O, which requires security supervisors to observe security staff l personnel for signs of fatit,de affecting their duties (paragraph 4.4.1) and directs the I
supervisor to take action (paragraph 5.1.2.6).
l- Conclusions The security organization has no prohibition against an unlimited amount of work while at Nine Mile Point and specifically allows an unlimited duration of employment outside Niagara Mohawk. The security organization does, however, guard against fatigue related problems by including fatigue observation in the fitness-for-duty program and in a security specific procedure. These actions should be sufficient to prevent fatigue from becoming a factor in the work related performance of security staf S8.2 (Closed) VIO 50-220/98-08-01 and 50-410/98-08-01: Failure to properly control, store and classify safeguards information. During the previous security inspection conducted in April 1998, the inspector determined, based on discussions with
- security management, observations, and document reviews, that the licensee f ailed to properly classify, store, and control safeguards information.
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With respect to this violation, the inspector conducted an on site inspection and determined that the corrective actions described in the licensee's July 30,1998 letter, in response to the NRC's Notice of Violation were reasonable, complete and appeared to be effective.
l l V. Manaaement Meetinas
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! X1 Exit Meeting Summary i
- The inspectors presented the inspection results to members of the licensee
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management at the conclusion of the inspection on December 3,1998. The licensee acknowledged the findings presented.
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c o ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Niaaara Mohawk Power Corooration R. Abbott Vice President, Nuclear Engineering D. Barcomb Manager, Unit 2 Radiation Protection D. Bosnic Manager, Unit 2 Operations J. Burton Manager, Training H. Christensen Manager, Security J. Conway Vice President, Nuclear Generation W. Davey Manager, Unit 1 Work Control (acting)
R. Dean Manager, Unit 2 Engineering S. Doty Manager, Unit 1 Maintenance G. Helker Manager, Unit 2 Work Control A. Julka Director, ISEG C. Merritt Manager, Unit 2 Chemistry P. Mezzafero Manager, Unit 1 Technical Support N. Paleologos Plant Manager, Unit 2 L. Pisano Manager, Unit 2 Maintenance N Rademacher Manager, Quality Assurance R. Randall Manager, Unit 1 Engineering V. Schuman Manager, Unit 1 Radiation Protection C. Senska Manager, Unit 1 Chemistry R. Smith Picat Manager, Unit 1 C. Terry Vice President, Nuclear Safety Assessment & Support D. Topley Manager, Unit 1 Operations K. Ward Manager, Unit 2 Technical Support D. Wolniak Manager. Licensing
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Attachment 1 INSPECTION PROCEDURES USED IP 37551 On-Site Engineering IP 61726 Surveillance Observations IP 62707 Maintenance Observations IP 71707 Plant Operations IP 71750 Plant Support IP 81810 Physical Protection of Safeguards information IP 81700 Physical Security Program for Power Reactors IP 83750 Occupational Radiation Exposure IP 86750 Solid Radwaste Management and Transportation of Radioactive Materials IP 90712 In-Office Review of Written Reports of Non-Routine Events at Power Reactor Facilities IP 92700 Onsite Follow-up of Written Reports of Non-Routine Events at Power Reactor Facilities IP 92901 Follow-up - Operations IP 92902 Follow-up - Maintenance IP 92903 Follow-up - Engineering IP 92904 Follow-up - Plant Support IP 93702 Event Response ITEMS OPENED, CLOSED, AND UPDATED OPENED 50-220/98-15-01 NCV Unit 1 Poor Reactivity Management During Rod Sequence Exchange 50-410/98-15-02 NCV Unit 2 Standby Liquid Control System Inoperable due to a Valve inadvertently Locked Closed 50-410/98-15-03 NCV Unit 2 Single Failure Criterion for Spent Fuel Pool Cooling
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50-410/98-15-04 NCV Uni'. 2 Inoperable Gaseous Effluent Monitoring System -
50-410/98-15-05 VIO Unit 2 Violation of TS 6.2.2.b for failure to ensure operators at l
the controls CLOSED
! 50-220/98-16-02 VIO Failure to identify and implement corrective actions for core spray pump motor cooler flow deficiency 50-220 & 410 L EA 97-530 01013 VIO Radiation levels exceeding allowable limits 50-220 & 410 EA 97-530 01023 VIO Activity reported on shipping paper not reflective of liner l 50-220 & 410 l- EA 97-530 01033 VIO Office Complex not listed on material License certificate
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98-08-01 VIO Failure to properly control, store and classify safeguards A-2 r
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! Attachment 1 50-220 & 410/
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98-S01 LER Security Force Member Leaves Compensatory Post Without l Verifying Zone Secured 50-410/96-06-01 URI Completion of Full Core Offloads at Unit 2 as a Normal Evolution While Not Being Analyzed as Such
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50-410/96-06-03 URI Failure to meet the single failure criterion for spent fuel cooling, as state in Section 9.1.3 of the Unit 2 UFSAR 50-220/98-01-03 VIO Inadequate Testing of Liquid Poison System Piping to Verify i Operability 50-410/97-02-03 URI Adequacy of Seismic Monitoring Surveillance Test Procedure i 50-410/98-02-04 eel No Licensed Operator at the Controls i
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50-220/98-04-01 IFl Scaling factor determination relative to plant conditions l 50-220/98-04-02 VIO Flatbed trailer returned to surface w/ radiation levels in excess of DOT limits 50-410/98-14-01 eel Unit 2 Standby Liquid Control System inoperable Due to a Valve Inadvertently Locked Closed 50-220/98 15-01 NCV Unit 1 Poor Reactivity Management During Rod Sequence Exchange 50-410/98-15-02 NCV Unit 2 Standby Liquid Control System inoperable due to a Valve Inadvertently Locked Closed 50-410/98-15-03 NCV Unit 2 Single Failure Criterion for Spent Fuel Pool Cooling 50-410/98-15-04 NCV Unit 2 Inoperable Gaseous Effluent Monitoring System )
50-410/98-15-05 VIO Unit 2 Violation of TS 6.2.2.b for failure to ensure operators at the controls
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LIST OF ACRONYMS USED i
ALARA As Low as is Reasonably Achievable APRMs Average Power Range Monitors CAS Central Alarm Station CFR Code of Federal Regulations '
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DER Deviation / Event Report eel Escalated Enforcement item ESF Engineered Safeguards Feature GEMS Gaseous Effluent Monitoring System HPU Hydraulic Power Unit IPE Independent Plant Examination LER Licensee Event Report MPFF Maintenance Preventable Functional Failure
! mrem Millirem l Mwe Megawatt electric l NCV Non-Cited Violation l
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l Attachment 1 NMPC Nine Mile Point Corporation NRC Nuclear Regulatory Commission l OP Operating Procedure ;
PID Problem identification '
PLC Programmable Logic Controller l
OA Quality Assurance RCS Recirculation System RPS Reactor Protection System l SFC Spent Fuel Cooling !
SLS- Standby Liquid Control System - i SORC Station Operating Review Committee SSS Station Shift Supervisor l TS Technical Specification TSSR Technical Specification Surveillance Requirement i UFSAR Updated Final Safety Analysis Report URI Unresolved item l Unit 1 Nine Mile Point Unit 1 Unit 2 Nine Mile Point Unit 2 VIO Violation WO Work Order ;
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