ML17054A029
| ML17054A029 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/20/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17054A030 | List: |
| References | |
| NUDOCS 8308240600 | |
| Download: ML17054A029 (64) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NIAGARA MOHAWK POWER CORPORATION NINE MILE POINT NUCLEAR STATION, UNIT I JUNE 20, 1983 8308240h00 8308f9
>DR ADQCK 05000220 j
7 PDR
1
I.
INTRODUCTION 1.1 Purpose 5 Overview 1.2 SALP Attendees
1.3 Background
II.
SUMMARY
'OF RESULTS III. CRITERIA IV.
PERFORMANCE ANALYSIS TABLE OF CONTENTS PAGE 1
1
~
~
1 l.
2.
3.
5.
6.
7.
8.
9.
Plant Operations Radiological Controls Extended Outage Work Maintenance Surveillance Fire Protection/Housekeeping Emergency Preparedness Security
& Safeguards Licensing Activities 5
7 10 12 13 14 15 16 17 V.
SUPPORTING DATA AND SUMMARIES l.
2.
3.
Licensee Event Reports Investigation Activities Escalated Enforcement Actions Management Conferences 18 18 19 19 TABLE 1 - TABULAR LISTING OF LERS BY FUNCTIONAL TABLE 2 - INSPETION HOURS
SUMMARY
TABLE 3 - VIOLATIONS (5/1/82 4/30/83)
TABLE 4 - INSPECTION REPORT ACTIVITIES.
TABLE 5 -
LER SYNOPSIS AREA 20 21 22 25 27
I l
I.
INTRODUCTION 1.1 Pur ose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC Staff effort to collect the available observations on an annual basis and evaluate licensee performance based on those observations with the objectives of improving the NRC Regulatory Program and licensee performance.
The assessment period for this report is May 1, 1982 through April 30, 1983.
The prior SALP assessment period was May 1, 1981 through April 30, 1982.
Significant findings of that assessment were provided in the applicable Performance Analysis Functional Areas (Section IV).
Evaluation criteria used during this assessment are discussed in Section III below.
Each criterion was applied using the "Attributes for Assessment of Licensee Performance" contained in NRC Manual Chapter 0516.
1.2 SALP Attendees:
R.
W. Starostecki, Director, Division of Project and Resident Programs H.
B. Kister, Acting Branch Chief, Project Branch No.
2 J.
P. Durr, Acting Branch Chief, Engineering Programs Branch S.
D. Hudson, Senior Resident Inspector, Nine Mile Point Unit 1
R. A. Hermann, Licensing Project Manager, Office of Nuclear Reactor Regulation 1.3
~Back round 1.3.1 Licensee Activities The plant remained out of service for the entire assessment period due to the replacement of the recirculation (recirc) system piping and safe ends.
This repair required the reactor core and control rod blades to be off-loaded to the spent fuel pool.
Just prior to the end of the period, the control rod blades were reinstalled in the reactor vessel and core loading began.
1.3.2 Ins ection Activities One NRC resident inspector was onsite during the assessment period.
The routine resident inspection program was modified to emphasize the review of ongoing recirc piping replacement activities and the associated radiological controls.
The total NRC inspection for the period were 2224 hours0.0257 days <br />0.618 hours <br />0.00368 weeks <br />8.46232e-4 months <br /> (resident and region based),
with a distribution as shown in Table 2.
l
Tabulations of Violation and Inspection Activities are attached as Tables 3 and 4 respectively.
0 l
l
II.
SUMMARY
OF RESULTS FUNCTIONAL AREAS CATEGORY 1
CATEGORY 2
CATEGORY 3
NINE MILE POINT NUCLEAR STATION UNIT 1 1.
Plant 0 erations 2.
Radiological Controls Radiation Protection Radioactive Waste Management Transportation Effluent Control and Monitorin 3.
Extended Outa e Work 4.
Maintenance 5.
Surveillance (Including Inser vice and Preoperati ona1 Testin Insufficient Basis 6.
Fire Protection 7.
Emer enc Pre aredness Insufficient Basis 8.
Securit
& Safe uards 9.
Licensin Activities Overview This assessment reflects the board's evaluation based on a period during which the plant was shutdown for replacement of the recirculation system piping.
The plant performance regarding the mechanical and radiological aspects of this extended outage is considered excellent.
The plant's well managed security organization was able to control the large number of workers onsite without incident.
The refueling operation was conducted in a very professional manner.
Subsequent to the assessment period, plant start-up operations were noted to proceed smoothly.
- However, the NRC will continue normal inspection activities to verify re-establishment of operating skills and continuation of radiological controls measures established during the outage.
I P
III. CRITERIA The following evaluation criteria were applied to each functional area:
1.
Management involvement in assuring quality.
2.
Approach to resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Reporting and analysis of reportable events.
6.
Staffing (including management).
7.
Training effectiveness and qualification.
To provide consistent evaluation of licensee performance, attributes associated with each criterion and describing the characteristics appli-cable to Category 1, 2, and 3 performance were applicable as discussed in NRC Manual Chapter 0516, Part II and Table l.
The SALP Board conclusions were categorized as follows:
Cateqaor 1:
Reduced NRC attention may be appropriate.
Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
~Cate or 2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are con-cerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
~Cate or 3:
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nulear safety, but weaknesses are evident; licensee resources appeared strained or not effectively used such that minimally satisfactory perfor-mance with respect to operational safety and construction is being achieved.
I I
IV.
PERFORMANCE ANALYSIS 1.
Plant 0 erations (30%)
The plant did not operate during the assessment period due to the r-circulation pipe replacement effort.
The fuel and control rods w
e offloaded and most of the surveillance program was suspended.
T e resident inspector however, continually observed the licensee'erformance in maintaining overall control of plant status an other outage activities.
During the previous assessment period, there were three ents involving improper removal of equipment from service.
e licensee's actions in this area appear to have been effective si e
no further events of this type have occurred.
- However, toward e end of this
- period, a set of jumpers were found installed when he Jumper log indicated they had been
- removed, and a set of unc trolled lifted leads were identified indicating a need for incr ased emphasis in this area with the plant returning to an opera onal status.
Licensee management continues to be involve in enhancing the quality of plant operations.
As an example, a co lete review of all operat-ing procedures has been initiated.
This eview includes a field verification of valve line-ups and labe ing of valves and equipment.
- Further, in response to questions by e resident regarding close out of modification packages, the gualit Assurance Department took the initiative and recently completed extensive effort to verify proper close out of safety relate modifications performed from 1975 to 1979, to ensure that drawing and procedures have been updated and that quality control records a
e complete.
On the other hand, the resi ent inspector identified several instances where Inspectio and Enforcement Circulars had not been reviewed by the plant st ff for applicability for extended periods of time (up to four years and when reviewed, corrective actions had not been fully implemente Also, twice during a
13 month period (once during the previous eriod) the reactor water cleanup filter sludge tank was overflowe apparently as a result of a level gauge
- problem, and caused exten ve contamination of the Reactor Building Venti la-tion system an several areas in the Reactor Bui lidng.
This event is further discu ed in functional area No. 2.
Onsite rev' committee is adequately staffed and appears to be functioni g in accordance with established procedures.
One exception to this as a failure to review a series of procedures for the remov and replacement of recirculation system nozzle safe-ends earl in the outage.
This however appeared to be an isolated case.
0 rations staffing continues to exceed requirements and training is dequate.
5 (See.Supplemental Page 5a)
J I
fp
')p l )~ <~)4
~'f '/S~l
IV.
PERFORMANCE ANALYSIS 1.
Plant 0 erations (30%)
The plant did not operate during the assessment period due to the re-circulation pipe replacement effort.
The fuel and control rods were offloaded and most of the surveillance program was suspended.
The resident inspector however, continually observed the licensee's performance in maintaining overall control of plant status and other outage activities.
During the previous assessment period, there were two events involving improper removal of equipment from service.
The licensee's actions in this area appear to have been effective since no further events of this type have occurred.
- However, toward the end of this
- period, a set of jumpers were found installed when the Jumper log indicated they had been
- removed, and a set of uncontrolled lifted leads were identified indicating a need for increased emphasis in this area with the plant returning to an operational status.
Licensee management continues to be involved in enhancing the quality of plant operations.
As an example, a complete review of all operat-ing procedures has been initiated.
This review includes a field verification of valve line-ups and labeling of valves and equipment.
- Further, in response, to questions by the resident regarding close out of modification packages, the guality Assurance Department took the initiative and recently completed an extensive effort to verify proper close out of safety related modifications performed from 1975 to 1979, to ensure that drawings and procedures have been updated and that quality control records are complete.
On the other hand, the resident inspector identified several instances where Inspection and Enforcement Circulars had not been reviewed by the plant staff for applicability for extended periods of time (up to four years) and when reviewed, corrective actions had not been fully implemented.
Also, twice during a
13 month period (once during the previous period) the reactor water cleanup filter sludge tank was overflowed apparently as a result of a level gauge
- problem, and caused extensive contamination of the Reactor Building Venti la-tion system and several areas in the Reactor Bui lidng.
This event is further discussed in functional area No. 2.
Onsite review committee is adequately staffed and appears to be functioning in accordance with established procedures.
One exception to this was a failure to review a series of procedures for the removal and replacement of recirculation system nozzle safe-ends early in the outage.
This however appeared to be an isolated case.
Operations staffing continues to exceed requirements and training is adequate.
5a
I
In summary, licensee management is involved in a continuing effort to improve the quality of plant operations
- however, continued attention is necessary to assure proper control of jumpers and lifted leads and ensure a more prompt review of NRC communications by the plant staff.
Conclusion Category 2
Board Recommendations Continue routine inspection program to verify establishment of normal operating skills.
2.
Radipl o ical Control s 15%
Ouring the previous assessment periods problems were evident in radiation protection procedure adherence, waste management
- audits, effluent controls and monitoring, and failure to fulfill commitments to the NRC relating to HP Appraisal findings.
A Category 3 perfor-mance rating was assigned.'uring the current assessment period,. four inspections were conducted by Region I Radiation Specialists.
The Resident Inspector continued to review ongoing radiological controls activities.
Three Severity Level IV violations were identified in the area of radiation protec-tion adherence:
two violations involving failure to adhere to radiation work permits, and one violation involving fai lure to inventory a number of radioactive sources.
The review of the licensee's Radiation Protection Program during the assessment period identified a number of deficiencies in the licensee implementation of documented commitments made to upgrade the program in response to Health Physics Appraisal findings.
This is a problem from the previous assessment period.
These commitments primarily involved establishment and implementation of additional program procedures.
The review of the licensee's technician training program indicated that the licensee had not established a program to ensure that technicians were adequately trained and qualified in their procedural responsibilities.
In addition, the licensee had not established a program to train technicians in new procedures or changes to existing procedures.
The licensee has taken action to resolve these matter s.
The licensee performed an audit of Health Physics Appraisal commitments to identify other commitments which may have been missed; is in the process of establishing a shift techni-cian training program; is establishing a long term technician train-ing and retraining program; and is establishing means to ensure technicians are trained in new procedures and changes to procedures.
In addition, the licensee hired a contractor to organize and track closure of Health Physics Appraisal Items.
The licensee also created and staffed the position of technician-compliance to track future commitments.
A review of inventory and control of radioactive sources with respect to licensee corrective actions for Health Physics Appraisal findings indicated that the licensee had not implemented procedures esta-blished to address appraisal findings in this area.
This finding resulted in a recur rent violation for failure to inventory sources.
No documentation was found to indicate that the individual performing the inventory had been trained in and qualified in the procedure requirements.
The licensee took action to correct this matter.
A review of the licensee's establishment and implementation of ALARA controls for replacement of recirculation safe-ends, indicated that the licensee implemented very good controls for the replacement.
Although some minor concerns were identified, the licensee adequately addressed these concerns.
However, the review of the licensee's Station ALARA Program with respect to commitments provided in response to an Immediate Action Letter issued as a result of Health Physics Appraisal findings indicated the licensee had not implemented the ALARA Program development commitments.
The licensee has contracted for ALARA Program development services and had provided program completion re-commitments.
A review of licensee audits indicated that the licensee was not performing reviews of Radiation Protection Program procedures in accordance with established schedules.
The licensee took action to review the procedures.
Following NRC identification of failure to meet commitments, the licensee initiated an audit of Health Physics Appraisal commitments.
The licensee is currently performing a comprehensive review of the onsite and corporate Radiation Protection and Chemistry Organization.
Job Task analyses are being performed in an effort to define the size of organization needed.
In addition, the licensee had doubled the size of the organization since the Health Physics Appraisal and has also increased the size of the training staff providing radiological controls training at the site.
The review of the licensee's Radioactive Maste Nanagement Program indicated the licensee has established a formal, dedicated Radio-active Maste Organization.
The licensee is currently developing job position descriptions for the organization.
The review of radioactive waste handling procedures indicated the licensee has established procedures for waste packaging, handling and transportation in response to a Health Physics Appraisal finding.
- However, a procedure established to ensure all radioisotopes have been identified in radioactive waste, also in response to an appraisal finding, did not provide adequate guidance for this activity.
The licensee took action to correct this matter.
During this assessment
- period, the licensee experienced a second spill of radioactive material from the Reactor Mater Clean-up System sludge tank.
The tank overflow, caused by a faulty tank level indicator resulted in contamination of duct work and floors in the Reactor Building.
The previous spill occurred on February 4,
1982 and resulted in the expenditure of about 8.5 person-rem in Reactor Building decontamination.
The licensee's corrective actions after the first event did not preclude recurrence.
The review o'f the licensee's radioactive waste transportation program indicated that the licensee established and implemented a training program for personnel involved in radioactive waste handling opera-tions.
The licensee established lesson plans to provide training required by IE Bulletin 79-19.
However, the lesson plan did not
I
provide for training of radiation protection and chemistry techni-cians in procedures involving radioactive waste packaging,
- handling, and shipping.
The licensee took action to ensure the training requirements of IE Bulletin 79-19 are implemented.
In summary, although there were recur ring problems from the previous assessment
- periods, management attention in solving these problems is now evident and significant strides have been made.
Commitments are now being tracked by a consultant, and management is being continu-ously appraised of progress.
- Also, an organizational structure is being developed for this department that will provide better overall control of radiological activities'urther, Radiological controls for the recirculation pipe replacement were excellent.
ALARA was evident in that total exposure was significantly less than the original estimate.
This was accomplished by decontamination of the recirculating piping, extensive use of shielding, mockup training, and close monitoring and control of worker exposure.
Conclusion Category 2
Board Recommendations None
3.
Extended Outa e Work (41%)
In March 1982, during a hydrostatic test of the reactor vessel, cracks were discovered in two reactor vessel safe ends for the recirculation (recirc) system.
Since these safe ends were furna e
sensitized during manufacturing, the licensee had been conduct' an augmented inservice inspection program since 1979.
Plans wer in place for eventual replacement of the safe ends in the even that intergranular stress corrosion cracking was found.
During the period of April thru September 1982, the lic nsee con-ducted additional ultrasonic testing of the piping wel s in the recirculation, shutdown cooling, core spray, and erne gency condenser systems to further define the extent of the cracki Multiple indications of intergranular stress corrosion cra ing (IGSCC) were identified in the recirc system piping although no indications of IGSCC were found in the other three systems ex ined.
To avoid hundreds of person-rem of exposure and the ne d for a second extended outage for replacement of the recirc system afe ends, the licensee decided that the most prudent course was t replace all of the recirc system piping using material not suspect le to IGSCC.
A great deal of management attention d resources have been devoted to assure the quality of the recirc iping replacement.
The replace-ment was performed by contractors o also supplied an extensive on-site guality Assurance functio Prior to beginning work, the licensee audited the contractor gA program to determine its com-pliance with 10 CFR 50, Append'x B.
Additionally, the licensee supplemented its own on-site
. A. staff to provide a separate overview of the contractor'ork.
The management of the replacement was supervised by a dedic ed staff engineer at the site and he was assisted by the seven ot er engineers.
At least one of these engineers was always o
site to provide a management review of ongoing operations.
The licensee estab shed special precautions to ensure that the radiation exposur to the workers was maintained as low as reasonably achievable (ALA ).
The recirc loops were chemically decontaminated prior to the r moval of the piping.
This lowered the general area radiation le ls in the drywell.
Specifically, designed shielding was install d into the reactor vessel and the safe ends to minimize the radia on shine from the reactor.
Video cameras were used to allow re ote monitoring of piping, cutting and welding in the highest radiat' areas.
The workers were trained on full scale mock-ups.
This ncreased their proficiency and decreased the time needed to per orm a task and the radiation exposure received.
Weekly, the li ensee compared the radiation exposure received to pre-established mits to determine the effectiveness of the ALARA program.
10 (See Supplemental Page l0a)
t J
I
3.
Extended Outa e Work (41%)
In March 1982, during a hydrostatic test of the reactor vessel, cracks were discovered in two reactor vessel safe ends for the recirculation (recirc) system.
Since these safe ends were furnace sensitized during manufacturing, the licensee had been conducting an augmented inservice inspection program since 1979.
Plans were in place for eventual replacement of the safe ends in the event that intergranular stress corrosion cracking was found.
During the period of April thru September
- 1982, the licensee con-ducted additional ultrasonic testing of the piping welds in the recirculation, shutdown cooling, core spray, and emergency condenser systems to further define the extent of the cracking.
Multiple indications of intergranular stress corrosion cracking (IGSCC) were identified in the recirc system piping although, no indications of IGSCC were found in the other three systems examined.
To avoid hundreds of person-rem of exposure and the need for a second extended outage for replacement of the recirc system safe ends and piping, the licensee decided that the most prudent course was to replace all of the recirc system piping using material not suspectible to IGSCC.
A great deal of management attention and resources have been devoted to assure the quality of the recirc piping replacement.
The replace-ment was performed by contractors who also supplied an extensive on-site guality Assurance function.
Prior to beginning work, the licensee audited the contractors gA program to determine its com-pliance with 10 CFR 50, Appendix B.
Additionally, the licensee supplemented its own on-site g. A. staff to provide a separate overview of the contractor's work.
The management of the replacement was supervised by a dedicated staff engineer at the site and he was assisted by the seven other engineers.
At least one of these engineers was always on-site to provide a management review of ongoing operations.
The licensee established special precautions to ensure that the radiation exposure to the workers was maintained as low as reasonably achievable (ALARA).
The recirc loops were chemically decontaminated prior to the removal of the piping.
This lowered the general area radiation levels in the drywell.
Specifically, designed shielding was installed into the reactor vessel and the safe ends to minimize the radiation shine from the reactor.
Video cameras were used to allow remote monitoring of piping, cutting and welding in the highest radiation areas.
The workers were trained on full scale mock-ups.
This increased their proficiency and decreased the time needed to perform a task and the radiation exposure received.
Weekly, the licensee compared the radiation exposure received to pre-established limits to determine the effectiveness of the ALARA program.
10 a
The licensee was responsive to the NRC's concerns about dissimilar metal welding, welders qualifications, repair of the cut on the reactor vessel
- nozzle, and a final stress analysis of new piping.
In each
- case, a timely and technically sound proposal was initiated to address the concern.
The licensee was also helpful in the evaluation of the generic implications of IGSCC in large diameter recirc system piping.
Three violations were identified which were associated with the piping replacement.
The licensee corrective action was prompt and effective.
This was demonstrated by the fact that the violation did not reoccur.
Early in the outage, the licensee's
- g. A. department issued a "show-cause" nonconformance report to the prime contractor based on several examples of programmatic problems with the imple-mentation of the contractor's g.
A. program.
The contractor's corrective action based on a meeting with corporate management, was effective in preventing reoccurrence.
The NRC also performed an independent non-destructive examination of selected welds performed in the recirc system.
This inspection included radiography and ultrasonic examination of welds for unidenti-fied defects and a review of the licensee's radiographs of selected welds.
No defects were identified.
The resident inspector witnessed portions of the reloading of the control rod blades and reactor core.
There was no licensee event reports concerning refueling and only one violation of fuel handling procedures concerning the control of material over the open reactor vessel.
prio~ to commencing the reloading operation, the licensee prepared a
master checklist of surveillance tests and preventive maintenance items that needed to be completed.
The inspector verified that the list addressed all items required by Technical Specifications and on a sampling basis, that the items had been properly completed.
The work hours of the operators conducting refueling allowed for breaks to prevent fatigue from causing personnel errors.
Except for minor equipment failures of the refuel bridge and grapple, the refueling proceeded swiftly yet safely.
Conclusion Category 1
Board Recommendation None 11
4.
Maintenance (2%)
The predominent effort during this assessment period has been the replace-ment of the Recirculation System piping.
This activity is discussed under Functional Area 3, Extended Outage Work.
During the previous assessment
- period, both the NRC and the licensee's guality Assurance Department noted deficiencies in the documentation of safety-related maintenance.
In June, 1982 Niagara Mohawk issued a major revision to the Administrative Procedure for controlling corrective maintenance.
The revision increased the responsibilities of the super-visors to review completed work requests.
The work request also requires final acceptance by guality Control and the shift supervisor prior to returning the equipment to service.
A November 1982 audit of the work request system revealed only one deficiency which indicates a significant improvement over the previous period.
The licensee has an established preventative maintenance program for safety related equipment such as motor operated
- valves, breakers, and M.G.
- sets, emergency diesel generator engines and mechanical snubbers which has enhanced the reliability of this equipment.
With regard to staffing, Niagara Mohawk has recently authorized the position of maintenance coordinator for each of the three maintenance areas
( 18C, electrical, mechanical).
Although still vacant, the duties will include scheduling, material procurement, and equipment tagout coordination and should improve equipment down time, and work force efficiency.,
In summary, management involvement is evident in the maintenance area.
Improved preventative maintenance along with increased control and coordination have resulted in a quality program.
Conclusion Category 1
Board Recommendation None 12
5.
Surveillance (2%)
During the assessment
- period, many surveillance tests were not required to be completed since the reactor core was off-loaded to the spent fuel pool.
Although the licensee continued to perform some of these tests, such as periodic testing of the emergency diesel generators, Region I decided to suspend routine inspections in this area.
One region-based inspector examined some of the areas of the licensee's inservice inspection program.
Based on the limited scope of inspections performed, an overall evaluation of this functional area cannot be made.
Prior to start-up in June
- 1983, the licensee performed all surveillance tests required for a refueling outage, including the containment inte-grated leak rate test and reestablished the normal schedule of periodic testing.
Conclusion Insufficient Basis Board Recommendation Resume routine inspection activities of this functional area.
13
6.
Fire Protection and Housekee in (3%)
During the current assessment
- period, one programmatic inspection was performed by a region based inspector.
Additionally, the resident inspector examined fire protection activities on a routine basis.
Although the licensee has committed considerable resources to the fire protection
- program, the admini strative details of the program were found to require improvement in several areas.
The licensee had previously committed via correspondence with the NRC to comply with the BTP 9.5-1 requirements or was required to comply based on 10 CFR 50.48.
During the inspection, the licensee agreed to correct the above deficiencies.
Based on the number of minor problems
- noted, addi-tional management attention in these areas appears warranted.
The procedure for training of the fire brigade did not specify the frequency of all of the training required by 10 CFR 50, Appendix R.
However, it was noted that fire brigade training and drills are conducted on regular basis in excess of that required by Appendix R.
The facilities for practical training were noted to be excellent.
The fire brigade consists of five shifts each manned by five full time firefighters.
Each shift attends 4 days of training every five weeks.
The licensee also employs a full time training instructor devoted to fire brigade training.
Housekeeping during this period was considered good taking into account the extensive work that was performed.
The effectiveness of the licensee's fire protection and housekeeping program was demonstrated by the fact that no major fires occurred during the assessment period when considerable welding and cutting was performed in association with the recirc piping replacement.
Conclusion Category 1
Board Recommendations None 14
7.
Emer enc Pre aredness During the current assessment period, there was one announced special safety inspection of emergency preparedness activities.
An inspection of the Public Prompt Notification System was conducted on March 2-4, 1983 to verify installation, testing, and documentation.
No deficiencies were identified by the inspector.
Records were complete and well maintained.
Management policies were strictly adhered to and verified.
There were no violations or reportable events during this assessment period.
The licensee had requested and was granted an exemption from the annual emergency preparedness exercise requirement.
The annual exercise was delayed until September, 1983.
A follow-up inspection has been scheduled for June, 1983 to verify the licensee's corrective actions identified during the Emergency Preparedness Implementation Appraisal which was conducted on August 17-20, 1981.
Conclusion Based on the above, the overall performance of the licensee during this assessment period cannot be evaluated.
Board Recommendation The licensee performance in this area will be examined during the annual exercise in September, 1983.
15
8.
Securit and Safe uards (5%)
During the assessment
- period, two routine physical protection inspections were accomplished by region-based inspectors.
Routine resident inspec-tions continued throughout the assessment period.
No violations were identified and no 10 CFR 73.71 Safeguards Events were submitted by the licensee.
The development and continued.enforcement of strong management controls is evidenced by no violations of regulatory requirements for a two-year period.
Management involvement was evidenced by planned program improve-ments that include:
(1) completing the upgrade of the access control system hardware/software project; (2) allocation of additional I&C technicians (estimated increase from 3 to 9) dedicated and assigned to the security organization; (3) procurement and assignment to the security organization of a mobile communications van to enhance communications effectiveness in the event of a site radiological and/or security emer-gency; (4) employment and assignment of an additional Security Area Investigator to the security organization; (5) design/layout of additional security facilities coincidental with the ongoing construction of Nine Mile Point, Unit 2; (6) planned procurement in FY 84 of a Security Organi-zation Central Alarm Station Simulator to be set up as a dedicated training/qualification module to improve CAS/SAS Operator performance; and (7) planned development of the security organization training program so that all shift personnel can be assigned to a dedicated training cycle (40-hour training week) each five weeks.
Program assessment revealed strong interface involvement by both corporate and site security management in directing the security organization.
Licensee cooperation was evident in their responses to NRC recommendations made during inspection visits and telephone conversations.
All security personnel appeared to be knowledgeable in their assigned duties.
The Guard Training and gualification Program is progressing on schedule.
The program is well defined and implemented with dedicated and professional personnel.
Classroom instruction was highly professional.
Lesson plans and tests were meaningful, and they appeared to be achieving the desired performance objectives.
These program improvements combined with a track record of sustained compliance with regulatory requirements for two consecutive years illu-strate balanced management effectiveness.
Conclusion Category 1
Board Recommendation None 16
\\
II'
9.
~Licensin Niagara Mohawk's approach to technical issues are indicative of the licensee's technical understanding of most issues.
Niagara Mohawk's rather large well qualified engineering staff, in concert with an astute licensing staff assures that most engineering work, either done in house or performed under its direction by contractors, adequately addresses complex technical issues.
An exception to this is the licensee's handling of the masonry walls issue.
As a result of a meeting with the licensee and exchange of information, an improvement in performance for this particular issue is expected.
With regard to responsiveness, in general, Niagara Mohawk has been respon-sive with regard to issues related to recirculation pipe replacement, Appendix R,
and TMI items, however with regard to masonry walls and core spray distribution, responses have not, been as timely as desired.
These issues have been outstanding for extended periods.
Events are generally reported in a timely manner, reasonably identifying causes and corrective actions.
Followup reports are generally provided when appropriate.
Licensing and engineering staffing appears to be
- adequate, particularly as it applied to the recirculation pipe replace-ment.
Operator license examinations were conducted during the evaluation period.
This process included both written and oral examinations.
Examinations were given to 17 candidates.
Of these, 13 persons passed.
RO licenses were issued to 4 persons and SRO licenses were issued to 9 persons.
Conclusion Category 1
Board..Recommendation None 17
V.
SUPPORTING DATA AND SUMMARIES 1.
Licensee Event Re orts Tabular Listin Type of Events:
A.
Personnel Errors 0
B.
Design/Man./Constr. /Install
~
~
5 C.
External Cause D.
Defective Procedure E.
Component Failure 0
X.
Other Tot 5
16 LER's Reviewed:
LER 882-11 to 82-23 83-01 t 83-05 82-14 and 14 were deleted y licensee.
Causal Anal sis Three sets of common mode ents were identified.
a.
LER 82-17, 18, 19, nd 20 reported the failure of containment isolation valves meet the specified value for local leak rate testing.
These ai lures were attributed to poor design and modifications w re made to improve the leakage.
b.
LER's 82-22 nd 23 reported the failure of containment isolation valves to et the specified value for local leak rate testing.
These fai res were attributed to dirt and corrosion in the seating rea of the valves.
Each valve was disassembled, cleane
, and successfully tested.
LER'2-12 and 83-03 reported the failure to meet the lower li t of detection sensitivity for radioanalysis of fish sample.
A hange to Technical Specifications has been submitted to evise this value to be in accordance with Regulatory Guide 8.4.
2.
In sti ation Activities one (See Supplemental Page 18a)
A
V.
SUPPORTING DATA AND SUMMARIES 1.
Licensee Event Re orts Tabular Listin Type of Events:
A.
Personnel Errors B.
Design/Man./Constr. /Install C.
External Cause D.
Defective Procedure E.
Component Failure X.
Other Total 5
16 LER's Reviewed:
LER ¹82-11 to 82-23 83-01 to 83-05 82-13 and 14 were deleted by licensee.
Three sets of common mode events were identified.
a.
LER 82-17, 18, 19, and 20 reported the failure of containment isolation valves to meet the specified value for local leak rate testing.
These failures were attributed to poor design and modifications were made to improve the leakage.
b.
LER's 82-22 and 23 reported the failure of containment isolation valves to meet the specified value for local leak rate testing.
These failures were attributed to dirt and corrosion in the seating area of the valves.
Each valve was disassembled,
- cleaned, and successfully tested.
LER' 82-12 and 83-03 reported the failure to meet the lower limit of detection sensitivity for radioanalysis of fish sample.
A change to Technical Specifications has been submitted to revise this value to be in accordance with Regulatory Guide 8.4.
2.
Investi ation Activities None
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3.
Escalated Enforcement Actions
- 3. 1 Civil Penalties None 3.2 Orders Confirmatory Order dated March 14, 1983 which confirms specific implementation dates for post TMI related items.
3.3 Confirmator Action Letters None 4.
Mana ement Conferences SALP Management Meeting held July 8, 1982.
19
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TABLE 1 TABULAR LISTING OF LERS BY FUNCTIONAL AREA NINE MILE POINT NUCLEAR STATION UNIT 1 Area 1.
Plant 0 erations 2.
Radiolo ical Controls 3.
Extended Outa e Work 4.
Maintenance 5.
Surveillance 6.
Fire Protection 7.
Emer enc Pre aredness Number/Cause Code 1/E 1/B 1/0 4/X None None 4/B 3/C 1/E 1/X None Total 8.
Securit and Safe uards None 9.
Licensin Activities None TOTAL 16 Cause Codes:
A - Personnel Error B - Design, Manufacturing, Construction or Installation Error C - External Cause D Defective Procedures E
Component Failure X - Other 20
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TABLE 2 INSPECTION HOURS
SUMMARY
5/1/82 - 4/30/83 NINE MILE POINT NUCLEAR STATION UNIT 1
HOURS
% OF TIME 1.
Plant Operations 2.
Radiological Controls 3.
Extended Outage Work 4.
Maintenance 5.
Surveillance 6.
Fire Protection 7.
Security
& Safeguards 9.
Licensing Activities 10.
Other Total 676 336 918 51 62 21 118 24 2251 30 15 1
100/
- Special Nuclear Material Control 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 21
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TABLE 3 VIOLATIONS 5/1/82 4/30/83 NONE MILE POINT NUCLEAR STATION UNIT 1 A.
Number and Severit Level of Violations
~l" "i L
Deviation Severity Level I Severity Level II Severity Level III Severity Level IV Severity Level V
Severity Level VI 0
0 0
0 5
5 0
Total 10 B.
Violati ons Vs. Functional Area FUNCTIONAL AREAS 1.
Plant 0 erations 2.
Radiolo ical Controls 3.
Extended Outa e Mork 4.
Maintenance 5.
Surveillance 6.
Fire Protection 7.
Emer enc Pre aredness 8.
Securit 8 Safe uards 9.
Licensin Activities Total Severit Levels I
II III IV V
VI DEV 1
2 3
1 5
5 Total Violations =
10 22
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C.
~Summer Inspection
~Re ort No.
Inspection Date (TABLE 3 Continued)
Severi ty Functi ona 1 Level Area
~Ri Vi 82-06 82-09 82-10 82-11 82-14 Nay 18-21, 1982 June 22-24, 1982 June 15-18, 1982 June 21-25, 1982 Oct. 26-29, 1982 Aug. 1-31, 1982 5
2 Tech.
Spec.
Tech.
Spec.
Tech.
Spec.
Failure to follow Radiation Work Permit Failure to establish a
fire watch Failure to SORC approved procedures for safe s'afe ends Failure to correctly label radiographs Failure to fol low Radiation Protection Procedure 83-02 Feb 1-28, 1982 10 CFR 50, Appendix B
Failure to provide acceptable procedures for instal-lation of flange s Failure to document review of pipe hanger inspection 23
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Feb. 28 March 4, 1983 (TABLE 3 Continued) 2 Tech.
Spec.
Failure to conduct inventory of radio-active source April 1-30, 1983 Tech.
Spec.
Failure to control the use of jumpers Apr. 12-15, 1983 Tech.
Spec.
Failure to control material over the reactor vessel 24
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TABLE 4 INSPECTION REPORT ACTIVITIES 5/1/82 4/30/83 NINE MILE POINT NUCLEAR STATION UNIT 1 Ins ection Re ort No.
82-06 82"07 82-08 82-09 82-10 82-11 82-12 82-13 82-14 82-15 82-16 82-17 82-18 82-19 82-20 82-21 82-22 82-23 83-01 83-02 83-03 Ins ection Hours 66 141 62 39 30 103 86 58 51 87 30 72 27 79 138 107 30 Areas Ins ected Radiological Controls
- Routine, Resident
- Routine, Resident Fire Protection Modifications Recirc Piping Replacement
- Routine, Resident Recirc Piping Replacement
- Routine, Resident Security Inservice Inspection Recirc Piping Replacement
- Routine, Resident 1
Nuclear Material Control
- Routine, Resident Radiological Controls
- Routine, Resident Security
- Routine, Resident
- Routine, Resident
- Routine, Resident Radiological Controls 25
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TABLE 4 INSPECTION REPORT ACTIVITIES 5/1/82 - 4/30/83 NINE MILE POINT NUCLEAR STATION UNIT 1 Ins ection Re ort No.
83-04 83-05 83-06 83-07 83-08 83-09 Ins ection Hours 13 82 548 132 27 Areas Ins ected Public Notification System Management Meeting
- Routine, Resident Independent Non-Destructive Examination of Recirc Piping
- Routine, Resident Radiological Controls 26
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LER Number TABLE 5 LER SYNOPSIS 5/1/82 4/30/83 NINE MILE POINT NUCLEAR STATION UNIT 1 Summar Descri tion 82-11 82-12 82-13 and 14 82-15 30 day 30 day deleted by licensee 30 day Fuel leak on diesel fire pump Failure to meet lower limit of detection sensitivity Removal of a fire system from service for a modification 82-16 82-17, 18, 19, 20, 21, 22, 23 83-01 83-02 83-03 83-04 83-05 30 day 30 day 30 day 10 day 30 day 10 day prompt Inadvertent discharge of radioactive water to Lake Ontario Exceeded local leak rate requirement for containment isolation valves Improperly installed wind direction indicator Tritium found in intake water sample during reverse flow Failure to meet lower limit of detection sensitivity Cesium 137 found in shoreline sediment samples Inadvertent overflow of cleanup sludge tank 27
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