IR 05000333/1989007

Insp Rept 50-333/89-07 on 890419-0603.No Violations Noted. Major Areas Inspected:Normal Steady State & Reduced Power Plant Operations,Reportable Operational Events,Qa, Surveillance & Emergency Preparedness Activities

ML20245E739
Person / Time
Site:	FitzPatrick
Issue date:	06/15/1989
From:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20245E728	List: IR 05000333/1989007 ML20245E723
References
50-333-89-07, 50-333-89-7, IEB-87-002, IEB-87-2, NUDOCS 8906270424
Download: ML20245E739 (16)

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Region I Report N /89-07 Docket N License N DPR59 Licensee: New York Power Authorit P.O. Box 41 Lycoming, New York 13093-Facility: James A. - FitzPatrick Nuclear Power Plant

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Location: Scriba, New York Dates: April .19,1989 through June 3,1989'

Inspectors: .. W..Schmidt, Senior Resident Inspector R. Plasse, Jr., Resident Inspector T. Rebelowski,. Senior Reactor Engineer, DRS Approved by: hk-N8M4W Nid M J. Johnson, Chief, Reactor

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Date Projects Section 2C, DR INSPECTION SUMMARY This inspection report discusses routine and reactive inspections'during day and backshift hours of plant activities including; normal steady' state and reduced power plant operations, reportable operational events, previously identified open items, quality' assurance, surveillance, maintenance,.

security, radiation protectior, and' emergency preparedness activities. Thi report period encompassed a total of 289 hours0.00334 days <br />0.0803 hours <br />4.778439e-4 weeks <br />1.099645e-4 months <br /> of direct inspection effor Of that total, 63.5 were backshift hours while 3.5 were deep backsnift hours which were conducted on 5/21 and 5/2 INSPECTION RESULTS o

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Previously opened items are closed in Sections 3, 5,-6, and .

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' violation, for which no Notice of Violation, is being iss'ued is discussed in section 3.a regarding failure to test time delay relays. An unresolved item-which deals with failure to perform fire barrier penetration inspections at )

the required TS intervals is addressed in section j

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i The inspector will track the following issues in a subsequent inspection report: 1) The need for Standby Liquid Control (SLC) accumulators and !

i pressure instrumentation (section 1.a);= 2) Implementation of new surveillance

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test' guidelines (section 3.b); 3) Procedure changes to minimize i drywell-to-torus dif ferential pressure decreases below the TS limit (section -i 3.c) and, 4) Resolution of design deficiencies identified by SSFI team {

(section 5.d).  !

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1 DETAILS 1. Operations (71707,93702,71710,92700)

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During this reporting period, the unit operated at 100% of rated power l except for load reductions to approximately 50% on April 29, May 2, and j May 21. The first reduction was to allow identification and correction i of a condenser tube leak. The second reduction was needed to repair the j manual / automatic controls for the "A" reactor feed pump turbine. The ;

third reduction was needed to support troubleshooting of feed flow 1 oscillations caused by the "A" reactor feed pump turbine control system I and to allow inspection of the condenser to identify additional tube i leakag '

The inspector reviewed the operability of the following systems during )

the inspection period:

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low pressure coolant injection l

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crescent room unit coolers

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emergency diesel generators I On April 19, while performing the Standby Liquid Control (SLC) pump functional test, ST6A, on the B SLC pump, an operator installed the test gauge and found that the nitrogen accumulator was depressur-ized. Because of this the B train of SLC was declared inoperable

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and the required surveillance testing, ST-6A, was begun on the A l train. While installing the test gauge to the A SLC pump accumu- {

lator, the needle valve broke, allowing this accumulator to depressurize (The nitrogen accumulators are required by licensee procedures to be maintained greater than 450 psig. The purpose of the accumulator is to dampen pulsation inherent with the SLC positive displacement pumps.) The licensee then declared both SLC pumps inoperable. This placed the plant in a.24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> cold shutdown Limiting Condition of Operation (LCO).

The licensee recharged the B accumulator and observed the needle valve to stick and leak. This appears to be the cause of the B accumulator discharging. The licensee reseated and snooped the valve. No additional leakage was noted. Applicable surveillance testing was performed and the B SLC pump was declared operabl This declaration removed the plant from the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO and placed ,

the plant in a seven day LCO with the A SLC pump inoperable. The licensee replaced the broken needle valve, replaced the bladder on the A SLC pump accumulator, and recharged the accumulator. This '

event was reported via ENS, because it could cause an initiation of

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I a shutdown required by Technical Specifications. This event is discussed in LER 89-06. Although there were no concerns with licensee actions, the inspector questioned the need for those accumulators and the lack of readily observable pressure instrumentation. This will be reviewed in a future routine inspectio I

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1.1 Safety Assessment j Operation of the plant continues to be performed safely. Operators were observed to be alert and knowledgeabl t Security (71707)

The inspector walked the restricted area fences and observed searches of j personnel and vehicles. No deficiencies were note . Surveillance and Maintenance Observations (61726, 92700, 92702, ,

93702,62703) I

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The inspector observed portions of the surveillance procedures listed  !

below to verify that the test instrumentation was properly calibrated, approved procedures were used, the work was performed by qualified personnel, limiting conditions for operations were met, and the system  ;

was correctly restored following the testing and maintenance . On April 27, the inspector observed performance of portions of the )

low pressure coolant injection (LPCI) subsystem logic functional '

test. ST-4H. During the test, the RHR pump breakers are racked to i the test position to allow breakers to be closed without starting i the pumps. The C RHR pump breaker failed to close within the required Technical Specification (TS) time of 5.5-6.5 seconds. This time is important because it sequences the RHR pump onto the emergency bus when it is repowered after a loss of powe i When this was found by the operators, the procedure was stopped,  ;

the time delay relay was adjusted and the procedure steps were reperforme It took three iterations to bring the time into the required range. The relay adjustment and reperformance of steps l was not specifically described by the procedure. The inspector reviewed TS Table 4.2.2 for the LPCI logic subsystem functional test and determined that a calibration of these time delay relays must be done each time the functional test is performed. No WR was written to perform the adjustment, but an occurrence report (OR) was generated. Since the work was done without a WR per a procedure it appears to be outside the licensee's administrative procedure The inspector discussed this practice with the licensee. While the work that was done was technically satisfactory and' properly retested, it was not either controlled by the procedure or docu-mented with a work request. The licensee has committed to reviewing this issue, and if necessary, providing operators with further clarification on how to handle such situations.

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The note to calibrate time delay relays applies to other functional i testing listed in Table 4. This was discussed with the Superin-tendent of Power. He was asked to review the possibility that other relays were not being tested. Subsequent to this discussion the licensee determined that four tine delay relays in. the isola-tion subsystems for the high pressure coolant injection (HPCI)

and reactor core isolation cooling systems (RCIC) were not being tested or calibrated. These relays were initially installed to prevent inadvertent isolation due to high temperature conditions and to give operators time to assess the extent of a break prior to system isolation in the areas of the drywell entry and torus rooms (in the reactor building). Failure to test these time delay relays, as required by TS is an apparent violation. As allowed by NRC enforcement' policy, 10 CFR Part 2, Appendix C, section V.G.1, no Notice of Violation is being issued since this would be a severity level IV or V violation and immediate and effective corrective actions were taken to prevent reoccurrence of the even !.

An open item number is assigned to this non-cited violation solely '

for tracking purposes NCV (89-07-01).

Upon further review by the onsite technical support staff it was determined that the high energy line break (HELB) analysis for the reactor building did not take these time delays into account. On May 15, the licensee entered TS LC0 3.7.D.3 for the loss of primary containment, because the containment isolation functions for HPCI and RCIC were declared inoperabl At that time, it was not desirable to shut the isolation valves since this would have made HPCI and RCIC inoperabl This LCO required that a shutdown be initiated and that the plant be in cold shutdown within 24 hour:;.

The licensee did not commence any power reduction at the time. The !

licensee completed a safety evaluation and performed a modification to jumper out the relays, which removed the 15 minute time dela This event will be evaluated further upon review of the licensee's LER on this inciden b. On May 18, during performance of ST-34B, Reactor Building Exhaust Monitors Instrument / Isolation Logic System Functional and Simulated Automatic Actuation Test, drywell-to-torus differential pressure fell below the Technical Specification (TS) limit of 1.7 psid. Due to the loss of differential pressure, torus level also dropped below the TS limit of 51.5 inches. The cause of the event was personnel error. The auxiliary operator performing the initial valve lineup to support test performance inadvertently opened four !

valves in the containment vent and purge system which should have been verified in the closed position. This error allowed pressure equalization between the drywell and torus. The Control Room Operators noted the loss of differential pressure and informed the Shift Supervisor who secured the test and directed reestablishment j of differential pressure, j

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During review of the event, the inspector noted that the licensee assumed that the plant had six hours per TS 3.7.A.7.3 to restore the differential pressure to normal, or at that point commence _a shutdown and be in hot shutdown within six hours and cold shutdown within the following 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. The inspector questioned the Shift-Supervisor as to why he had.not used the (apparently more conserva-tive) TS for torus water level 3.7.A.1.b', which would force entry-

'into TS 3.0.C, requiring that the unit be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This was reviewed by the Operations Superintendent and ]

the inspector was. informed that the plant should have been in the ;

24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LC0 due to the out of specification torus' level. -This j event.was reported via ENS. Torus level was restored within one j half-hour and the differential pressure.was. restored in approxi- :q mately one hou The inspector reviewed the licensee's critique and corrective actions regarding this. event. The auxiliary operator did not understand the significance of mispositioning these particular i valves and the potential for equalizing drywell-to-torus differen- l tial pressure. The operator directing the test was not positioned "

near remote indicators to monitor the differential pressure during the valve manipulations. Based on this event, the licensee has-implemented the following guidelines during performance of I surveillance tests: j Pre-evolution briefings will be conducted prior to conducting involved testing (ie. logic tests, auto actuation, etc.). j Personnel involved in testing will be assigned responsibili-ties during the tes ! The consequences of each action or' series of actions during the testing will be discusse ] An operator shall be assigned as." Test Director" and position !

himself strategically such that he can observe the plant j responses during the test. He should be in the control room l

" horseshoe" area during tests which cause half scrams, isola -

tions and/or ECCS actuation i

These corrective actions appear adequate. The inspector will  !

monitor the implementation of the new surveillance test guidelines i'

in future routine inspections.

, On May 20, during the performance of ST-4N, HPCI Flowrate and

Inservice Test (IST), drywell-to-torus differential pressure decreased from 1.9 psid to 1.4 psid. The TS limit-is 1.7 psid, but i the differential pressure is allowed to drop below this limit  !

, during required operability testing of emergency core coolin j system and drywell-to-torus chamber vacuum breaker testing. During- !

his followup, the inspector noted that recent performances of ST-4N !

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have not resulted in any noticeable decrease in drywell-to-torus differential pressure. In discussing this event, the inspector-determined that' during previous tests, the operators established torus cooling and venting to the standby gas treatment system to'

minimize the affect on containment parameters due.to the added torus head load from the HPCI exhaust. This was not a procedure requirement but considered by the licensee to be a good operator practic Although TS allow the differential pressure to fall below the required limit'during certain testing, it is'. prudent to minimize these occurrence This was discussed with.the Operations Superintendent who is in-the process of reviewing this event and evaluating a procedure change to establish the required plan conditions which prevent a decrease in the drywell-to-torus .

differential pressure. The inspector will followup this evaluation:

in a subsequent repor d. (Closed) Violation 86-11-01: Inadequate care of items' in storag This item identified specific weaknesses in that the licensee was not performing preventive maintenance (PM), as specified' by the manufacturers, for equipment in storage. In response to this violation, the licensee has developed and implemented a formal storage PM program. The inspector reviewed the following proce-dures: Storage Maintenance Program, Warehouse Instruction #29 and Procedure for the Technical Review of Vendor Information, Instruc--

tions, and Manuals for Storage Maintenance Applicability, EDP3 !

The inspector discussed these procedures and.the implementation of j this program with the Superintendent of Material Control and the  ;

Procurement Engineer. In addition, the inspector toured the warehouse facilities and reviewed the PMs for several specific  !

components. It appears this new program is adequate. The long term effectiveness of this new program will be reviewed.in a-subsequent inspection report. This item is close e. (Closed) Unresolved Item 88-15-03: HPCI turbine lube oil switch (PS-1) requires review of the current mounting to meet seismic Category I installation. The licensee review indicated that PS-1 is considered a QA Category I, service component, and that mounting is adequately designed to meet design requirements. This item is close ;

f. (Closed) Unresolved Item 87-21-04: The Regional Administrator, '

during a plant tour, identified a weakness in the licensee attentiveness to properly closing equipment covers and cabinet !

The inspectors toured the reactor building and spent fuel pool  ;

areas and identified no loose or improperly fastened equipment covers, l In addition, Plant Standing Order #1 requires the identification of '

problems by performing a system walkdown on a quarterly basis Housekeeping was observed and found to be satisfactory.. This item is close _ _ _ _ _ _ _ __ _ _ - _ _ _ _ _ _ _ _ - _ _ _ - _ _ - - _ _ ___ __ _ _ _ __- _ _ A

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1 In addition, the licensee is' reviewing a proposed program, in which the plant is divided into discrete areas and supervisory -

responsibilities for' housekeeping are allocated on a. rotational !

sequence to ensure that all areas receive management overvie (Closed) Violation 88-15-01: Construction workers failed to return

a system to normal after. completion of ultrasonic testing. The resident inspector verified the licensee's immediate action of surveillance testing, safety evaluation and root cause evaluation for the. missing pipe supports. The long-term corrective action includes reinforcement of work control activity requirements as j documented in Procedure 10.1.1 Control of-Maintenanc In addition, lectures, self-study information, and supervisory manage-ment meetings were performed to identify. root causes. A review of training documentation confirmed that approximately forty-five contractors, technical support and maintenance supervisors and tradesmen participated in training. During tours of~ plant, the j inspector did not identify any similar problems. This item is I close I (Closed) Unresolved Item 89-03-05: This item addressed the installation of an incorrect component, designed for the RCIC, in the HPCI syste During subsequent post maintenance testing, a HPCI high steam flow isolation signal was received, resulting in an automatic isolation of the HPCI turbine and turbine tri '

This error is discussed in detail in LER 89-005. The inspector l reviewed the licensee's investigation of the causes of'this error '

and their corrective actions. The inspector verified that the spare parts system has been changed to provide different stoc numbers for HPCI and RCIC system governor' actuators. The licensee

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is in the process of updating the HPCI turbine technical manual and )

a associated drawings with the correct part numbers. In addition the i licensee is investigating the identity of other control components j in stock, and installed in the HPCI and RCIC systems, and is  ;

verifying with the vendor that they are the correct components to prevent a similar occurrence. This item is close The licensee has also initiated a periodic inspection of the electrical connector to prevent the accumulation of rust resulting ;

in a conductive path to ground. The inspector had no further 'i questions on this LE '

4. Emergency Preparedness (71707, 82301) On April 26, the licensee conducted a practice emergency dril !

The inspector observed the conduct of the drill in the control room ;

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(CR), the Technical Support Center (TSC) and the Emergency Operations Facility (EOF). The licensee was able to supply simulated plant data to Safety Parameter Display System (SPDS) screens in all three locations. The inspector made several observations during the drill. After discussion with the Emergency Preparedness Coordinator, it was determined that the licensee had made similar observations, and was taking appropriate corrective action. The inspector had no further question On May 22, the licensee made an ENS call reporting a major loss of emergency assessment capability. The event was a loss of 13 sirens for approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on the evening of May 21, cautad by a raccoon damaging a power supply transforme Niagara Mohawk Power Corporation (NMPC) identified the siren loss during a daily review of the monitoring system printout and informed Fitzpatric NMPC has the responsibility to maintain the sirens. Presently the two utilities have an agreement to ensure that NMPC informs Fitzpatrick of any changes in emergency assessment capability. The inspector determined the transfer of information from NMPC to the licensee and the 50.72 reporting by the licensee was adequat . Engineering and Technical Support (92702, 92703) On April 26, the licensee initiated Occurrence Report 89-72, to document the fact that six out of eight required reactor vessel-to-nozzle welds had not been inspecte These welds were to have been ultrasonically inspected, as scheduled by the licensee's ISI Program, during the 1988 refueling outage. This program requires that 25% of the 28 reactor vessel nozzle welds be examined in the first inspection period of the second ten year interva The exams were missed due to a programmatic error in the ISI computer tracking system. The inner radius of these nozzles was inspected by a separate requirement. The radius inspection was listed with a note that the weld should also be inspected. This note was missed by the contractor and completion of the exams was not properly verified by licensee personnel. A subsequent licensee audit of the contractor uncovered that these exams had not been performe Technical Specification 3.6.F.1 requires that the structural integrity of the Class I piping be maintained. The surveillance requirement associated with this specification (4.6.F.1) requires the licensee to conduct examinations as described in ASME Code Section XI. There is no specific action statement to follow if the exams are not complete ..

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The licensee informed the resident and regional inspectors and NRR Project Manager of this discovery. They felt that a relief request due to the missed examinations was the proper course of action to resolve this issue. The inspector asked the licensee why they had not entered TS LCO 3.0.C, which is applicable if no other specific LCO is provided. The licensee responded that there was no known problem with these welds and that they did not question their integrit Through discussions with the NRC staff, it was determined by the inspector that the use of a relief request was deemed to be inappropriate since the exams were missed. The inspector determined that the T.S. allowable surveillance extension (to 125%) was applicable in this case and that the licensee was planning on completing the inspections during a September 1989 outage. Since one inspection period is one third of a' ten year period, equivalent to 40 months, this approach appeared acceptable. Additional reviews will be performed in future routine inspection b. On May 9, the licensee was informed by a contractor that various fire barriers had not been inspected at their required Technical Specification (TS) interval TS 3.12.F requires all fire barrier penetration seals for each protected area to be visually inspected every 18 months to verify functional integrity. Sixteen continuous fire watches were established in various areas of the plant until i the required fire barriers were satisfactorily inspecte On May 23, during a subsequent review of the fire protection j program on site, the contractor identified additional fire barriers 1 that had not been inspected at their required intervals. Three i continuous fire watches were established in the affected areas of i the plant until the inspections were complet j The missed inspections were due to an inadequate surveillance test, !

ST-762, Revision 0, Fire Barrier Penetration Inspection and Damper Operability Surveillance Test, approved by the Plant Operation  ;

Review Committee (PORC) on July 7,1988. As documented in PORC l meeting minutes 88-50, this new surveillance test was based on a '

new fire protection reference manual. The new manual completed by the contractor as a controlled design document, was to improve the !

identification and implementation of the fire protection progra This manual, however, only identified the penetrations associated with the Appendix R fire barriers. All the other fire barriers that were not also Appendix R barriers were not included. The licensee was not aware of this fact and assumed that the manual contained all the fire barriers necessary. The licensee invoked-the new program without any further revie i

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The inspector was concerned that the implementation of.the fire protection program relied too much on contractors alone and that the licensee did not have adequate independent review to ensure !

that all fire protection program commitments were met. The inspector was also concerned that during review of the new surveil- ;

lance test ST-76Z, and the new fire protection reference manual, ;

the PORC did not identify these discrepancies with the fire i barriers. In fact, the PORC members did not understand the associated commitments when this procedure was approved. These concerns were addressed with the licensee's Director of Nuclear Licensing, Director of Project Enginee-ing and station managemen j They agreed that there are weaknesses in understanding the fire z

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protection program and associated commitments and are taking action j l

to upgrade training in this are They understood the concern with j program ownership and independent review, but feel that there is l

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adequate review of the program on site by the Fire Protection i Supervisor. The licensee is reviewing this concern and is planning

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to ensure that the progam has adequate oversight. The licensee j has committed to update the fire protection reference manual with i all required fire barrier penetrations identified by October 198 {

l In addition, they committed to having the contractor review the l fire protection program and all licensee commitments and to incorporate all commitments into a future revision to the fire {

i protection reference manua (

This item remains unresolved pending corrective actions and changes )

to the Fire Protection Program to include all inspections of all j required fire penetrations. (UNR 50-333/89-07-02) i i

c. On May 17, based on questions by the NRC Safety System Functional ;

Inspection (SSFI) team, the licensee determined that a design ;

deficiency existed with the air conditioning units for the

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i environmental enclosures housing safety-related switchgear L-15 and l L-16. In the postulated high energy line break (HELB) that is most i significant in thr area of the enclosures, the ambient temperature j will increase to M 4 F within 20 seconds. This increase would cause the temperature of the freon 12 refrigerant in che compressor and thus its pressure to rise above the high discharge pressure automatic shutoff point of the compressor. At that point, the compressor the condenser fan (located outside the enclosure) and ,

l the circulating fan (located inside the enclosure) would tri I i None of these loads would have automatically reenergized after the temperature decreased to a point where the high pressure trip reset.

l As a result, the licensee entered a iS LC0 3.0.C. which required l the plant to be in cold shutdown within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> They also prepared a safety evaluation which allowed the performance of a temporary modification to allow the compressor to restart when the discharge pressure was low enough and to keep the condenser and circulating fans running after the compressor tripped. The i

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licensee reported this deficiency via the ENS. The inspector reviewed the actions taken and found them to be appropriate, On May 31, the licensee made an additional ENS call based on four additional design deficiencies noted during the NRC SSFI. The licensee committed to having their analyses of these and other issues completed by June 9. Specific NRC findings wil'. be described in a separate inspection report (No. 50-333/89-80).

l (Closed) Violation 86-14-01: Inspector identified two Limitorque operators containing nine splices which were not environmentally qualifie The licensee stated in their response to the violation, dated October 13, 1987, that the reason that the splices were not constructed in accordance with the splice configuration which was environmentally qualified was a procedural noncompliance which occurred during modification to the subject Limitorques in the 1981 time frame. The licensee stated further that a non-environmentally qualified pVC tape, versus the required environmentally qualified Okonite No. 35 black tape, served the function of " jacketing" the ;

inner red tape (0konite T95). Based on a previous NYPA qualifi- '

cation program of Okonite tape splices in containment environments, '

the outer tape covering is not required to maintain the electrical integrity of the connection and thus would have been able to perform its environmental qualification function (assuming the material was not damaged during installation).

To correct the unqualified splics application, the licensee issued Work Request No. 00/42597, dated August 8, 1986, to replace the splices and install new splices using Okonite No. 35 tape per )

Installation Specification IS-E08. Furthermore, the licensee {

inspected the 17 Limitorque valve actuators located inside and !

outside the drywell to verify that no other environmentally unqualified splices existed. No other deficient splices were j identified as a result of this inspectio !

The inspector reviewed Work Requests No. 00/42597 and 00/37S17 governing the above noted work. No problems were noted. This  ;

violation is close l

(Closed) Unresolved Item 87-14-15: Licensee's Systematic Component Evaluation Worksheet (SCEW) stated that Anaconda-Continental Single Insulated Strand (SIS) and General Electric Vulcene SIS wire was qualified for generic use in the reactor b'ilding while the EQ reference files for the wire sttted that t se wire was only qualified for use as jumper wire for cont' ul circuits in Limitorque motor operators. Review of licensee doct entation by the inspector indicates that Anaconda wire is no longer in use in the plant;

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3g thus, the OR sheet for this wire has been deleted from the EQ progra The SCEW sheet for GE Vulkene SIS wire, identifies this wiring,as being qualified to the requirements of the DDR guide-lines; therefore, its use in-new EQ applications would require a special evaluation to confirm that the material is. environmentally qualified for its applicatio Furthermore, licensee maintenance procedures require that.the replacement of internal wiring:in EQ .

actuators is performed exclusively using Rockbestos firewall SIS, which-is qualified in accordance with 10 CFR-50.4 The inspector reviewed the SCEW sheets for both SIS wire types as well as reviewed the maintenance procedure regarding work on-Limitorque motor operators (MP59.21). No problems were note This item is close (Closed) Unresolved Item 86-14-02: Licensee needs to confirm that the materials'used in fabricating the rotor shafts in'Limitorque motor operators are environmentally' qualified for applications inside containment. During the plant outage'in October, 1986, all Limitorque actuators .in the drywell were. inspected per Work Request No. 00/37017. The results of. the inspection showed that the only limit switch rotors installed in Limitorque actuators used in containment are Melamine (white). rotors and Fibrite (brown) rotors, both of which are environmentally qualified for postulated contain-ment accident conditions. Furthermore, the licensee presently only stocks Fibrite limit switch and torque-switch material Therefore, the possibility of installing' unqualified switch materials in any Limitorque actuator in the future is minimize The inspector reviewed the results of the inspection conducted by Work Request No. 00/37017. No problems;were noted. This item is close (0 pen) Unresolved Item 87-00-02: I&E Bulletin 87-02 - Fastener Testing to Determine Conformance with Applicable Material Specification. The licensee response to the Bulletin on February 24, 1988 included the results of laboratory testing of representa-tive fasteners and nuts. The results determined that all safety related and nine (9) non-safety related fasteners were within the required specifications and that three (3) non safety related-fasteners were out-of-specification. fhe scmple size consisted of 12 (each) safety and non-safety related fasteners and typical nut The fastener non-conformance was limited to hardness, ultimate-tensile strength and carbon content. The inspector reviewed

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laboratory test reports and found them detailed and addressing all required areas of concern.

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13 l The Bulletin response, Item 6, notes four (4) continuing actions that licensee was pursuing. The inspector requested licensee to provide documentation of their actions: Engineering evaluation will be performed on the out-of-specifi-cation fasteners to determine the impact (if any) if one of i these fasteners was actually installed in one of its intended  !

application l The plant staff plans to review the various plant equipment information systems (i.e., equipment history and NPRDS system) I to identify non-safety-related component failures or  !

malfunctions which have been attributed to fastener failures i or degradatio j l The plant maintenance staff will be requested to provide any I additional information based on their experience associated  :

with the failure or degradation of installed fastene'r l 1 Based on the results of 1-3, above, the Authority plans to l determine if any additional pro 9 ram controls (i .e. , vendor ,

evaluation, receipt inspection or independent testing) are j necessary and perform corrective action as applicabl None of the above information was readily available or presented to ,

the inspector during this period of inspection. This item remains  !

open. In addition, the inspector confirmed by observation in the  ;

warehouse that the fasteners were identified as faulty and j segregated from stoc i. (Closed) Violation 89-02 03: In their response, dated April 21,

'1989, the licensee documented the actions that have been taken and made commitments for long term actions to prevent future drawing control violations. The short term actions taken include changing the method of ensuring that modifications are reflected on

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l applicable drawings by using a computer generated list and by  ;

walking down 120V electrical distributor panels. 'Also, the specific deficiencies have been corrected and the clerical personnel who update drawings have been cautioned on the need for accurac Long term commitments made are as follows:

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OP drawings are planned to be replaced by updated FM and FE drawings by December 199 _ _ _ _ _ - _ - _ - - _ _ _ -

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A CAD system is planned to be used to update FM and FE j drawings before a modification is made operable during the-1990 refueling outag l

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Drawings that are needed for the operation of the' plant will be identified and put-into the CAD system by December.199 .!

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Audits of the contro11ed' drawing locations will be conducted and the completeness of the modification notebooks in the CR 1 reviewed by July 198 New modification' control procedures are being ' implemented, which document the method to be used for updating drawings.' l

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The procedures for design change documents are being-revised j to ensure that changes are properly incorporated into operating  ;

procedures. This will be completed by September 1, 198 !

i Based on the short term actions.taken and the commitments made, I'

this item is closed. The inspector will review the long term commitments in subsequent routine inspection .1 Safety Assessment l i

The actions taken by the. licensee based on the SSFI findings appear to {

be timely. The use of entry into TS LCOs when conditions are foun '

outside design bases and use of safety evaluations and modifications' to -l correct design deficiencies was considered adequat i The issue of the missed fire barrier penetration surveillance points to the fact that the licensee relies heavily on contractors without-adequate independent oversigh : Radiological Protection (71707)

! (Closed) Unresolved Item 89-02-05: The licensee has taken correc-tive actions to resolve the concerns of increased radiation levels in the high pressure coolant injection (HPCI) system room during operation. Actions also applicable to the reactor core isolation cooling system (RCIC) were taken. The radiological status maps indicate that radiation levels in these areas may be five to ten  !

times above background when the machines are running. The HPCI l room ALARA sign has been properly positione Operating and surveillance procedures for HPCI and RCIC have been revised to include cautions which state that radiation levels will  :

increase, and that radiation protection should be notified prior to l running the systems and of any'significant nuclear steam leak Based on these corrective actions this item is closed.

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15 Assurance of Quality (40500, 71707)

This section is included to provide assessment of the licensee's oversight and effectiveness in ensuring that activities are conducted in a manner which assures quality, (Closed) Unresolved Item 88-04-06: Licensee identified that the-corrective action Procedure QAP No. 16.6, Rev. 1, 5/16/89 was not completely followed. The licensee has revised the above procedure to include provisions to provide corporate and plant manaaement status of all Standard and Significant Adverse Quality Conditions (SAQC). In addition, root cause analyses for SAQC must be deter-mined and documented, with the corrective action to prevent reoccurrence determined and documented along with the status of implementation. The procedure contains forms that provide input to the " Adverse Quality Control Tracking Log". Also provided~in the procedure are requirements necessary to formally request extension of time to reply to the AQCR. When responses to AQCR have not been promptly addressed, a method to escalate concerns to the corporate Vice President are included in the procedure. This item is close bi Quality Assurance Program Implementation (35502)

The NRC staff reviewed the licensee's performance since the'end of the last Systematic Assessment of Licensee Performance period in April of 1988. The staff raised several concerns develop during the review. These included: adequacy of surveillance testing to determine operability of systems and components, reporting of ever.ts and conditions in accordance with 10 CFR 50.72, use-of l safety evaluations and how they relate to TS LCO's, and offsite 115 KV power supply monitoring and coordination. As part of the review, a meeting was held in Region I on May 30, between NRC (Region 1 and NRR) and licensee management. The licensee was requested to address each of the concerns noted abo"- trt of their presentatio With respect to the surveillance testing operability issues, ths licensee has completed a review of TS to determine where testing is not specified to allow the determination of operability. During this review, the licensee found six surveillance tests that require :

additional review to determine whether any changes are necessary to !

prove that the systems or components can perform their safety I function. The licensee has. committed to completing the changes by j August 198 j

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l 10 CFR 50.72 reporting requirements were discussed. The NRC staf explained the need for these reports to ensure that the staff is made aware of adverse. conditions for generic review and emergency response purposes and how they are characterized by the license The licensee had previously believed that the reporting requirement of 50.72 did not apply if the determination of deportability was-made after one hour or four hours, as applicable, from the. time of the event o. condition being identified. The licensee committed to reviewing their policy in this are In the area of safety evaluations, the-licensee has committed to develop a new procedure to be used when design deficiencies are found. This procedure will control the determination of safety significance, and the application to any TS LCO's. This procedure is planned to be in place by the end of June,198 The licensee held a meeting with Niagara Mohawk Power Corporation on May 22 to discuss the control and monitoring of the offsite 115 Kv power supplies. As a result of the meeting, procedures are being formulated which will instruct the NMpC power controller, NYPA energy control center and Nine Mile Point and Fitzpatrick ~

control rooms on how to better control these lines. The2e pro-cedures are planned to be in place by the end of June, 198 During their presentation, the liceasee discussed.several self-initiated improvement items and introduced plans to enhance several areas. The licensee is presently developing a consolidated corrective' action program to be completed in the near future. An effort is underway to consolidate administrative procedures, the first phase of which will be completed by the fall'of 198 Additional details of the licensee's presentation are attached to this inspection repor . Exit Interview (30703) ,

At periodic intervals during the course of this inspection, meetings ;

were held with senior facility management to discuss inspection scope and findings. In addition, at the end of the period, the inspector met with licensee representatives and summarized the scope and findings of the inspection as they are described in this repor Based on the NRC Region I review of this report and discussions held with NYPA representatives during the exit meeting, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction

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