ML17055D216
| ML17055D216 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/15/1987 |
| From: | Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055D215 | List: |
| References | |
| 50-410-87-32, NUDOCS 8709210225 | |
| Download: ML17055D216 (10) | |
See also: IR 05000410/1987032
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
87-32
Docket No.
50-410
License
No.
Category
B
Licensee:
Niagara
Mohawk Power Corporation
301 Plainfield Road
Syracuse,
13212
Facility:
Nine Mile Point Unit 2
Location:
Scriba,
Dates:
September
1,
1987 to September
8,
1987
Inspectors:
W.A. Cook, Senior Resident
Inspector
C.S. Marschall,
Resident
Inspector
W.L. Schmidt,
Resident
Inspecto~
J.R. Johnso,
Chief, Reactor
Projects
Section
2C,
INSPECTION
SUMMARY:
9/Is
/Bp'ate
Areas
~Ins ected:
Special
inspection
by resident
inspectors
to review the
events
leading to the
shutdown
on September
2,
1987 required
by Technical
Specifications.
This inspection
involved 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />
by the inspectors.
Results:
A sequence
of events is discussed
in section
2.
Five apparent
violations are discussed
in section
3.
87Pg210225
87
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8
DETAILS
l.
~Pur ose
The purpose of this special
safety inspection
was to review the circum-
stances
leading to the
shutdown initiated at Nine Mile Point Unit 2 to
comply with Technical Specifications
(TS) on September
2,
1987
'.
Event Chronolo
The following is
a chronology of the important events:
In early June
1987,
a cumulative count of operating
hours for each
Standby
Gas Treatment
(SBGT) train was conducted,
based
on the run
times documented
in the Chief Shift Operator
(CSO) logs.
This
action
was prompted
by
NRC inspector review during
an Operational
Readiness
Team Inspection (Inspection
Report
No. 50-410/87-16).
The
A train of SBGT was determined to have
440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />
and the
B train to
have
200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of cumulative
run time at the
end of May 1987.
Both
SBGT trains were operated
during the months of June, July and
August 1987.
The
SBGT trains were operated
for normal surveillance
testing,
venting of the containment drywell and,
on occasion,
due
to spurious actuations.
On September
1,
1987 at 1:20 p.m., the Division II emergency
diesel
generator
(EDG) was
removed
from service
so that modification work
could be performed.
Prior to removing the Division II EDG from
service,
the requirements
of TS Limiting Condition for Operation
(LCO) action statement
3.8. 1. l.e were reviewed
and logged
as
completed in the Station Shift Supervisor
(SSS)
log.
Approximately three
hours after the Division II diesel
was taken out
of service,
on September
1,
1987, calculations for the run time on
SBGT train A indicated that the train had been
run for 785 hours0.00909 days <br />0.218 hours <br />0.0013 weeks <br />2.986925e-4 months <br />,
in
excess
of the
surveillance limit of 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />.
This
cumulative
run time was based
on
a review of the
CSO logs through the
end of July 1987.
Subsequent
to the above determination,
Operations
management
immediately contacted
the corporate licensing staff to determine if
the standard
255 variance in surveillance
frequency applied to TS
surveillance 4.6.5.3.c limit.
Operations
was told verbally that the
25% variance
was applicable.
This made the
maximum allowable sur-
veillancee
frequency
900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />.
At that time, Operations
management
did not continue with the
SBGT run time review because it was thought
that the
900 hour0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> limit would not be exceeded.
0
On September
2,
1987,
the review of the cumulative
run time on the A
train of SBGT was continued
and it was determined
to have
exceeded
the 900 hour0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> surveillance
requirement
(1120 actual
hours).
Based
on
this determination,
the A train was declared
and Unit
"management
was informed.
At 5:35 p.m.
on September
2,
1987,
a reactor
shutdown
was
commenced
to comply with TS 3.8. l.l.e,
due to train A of SBGT being inoperable
while the Division II EDG was also out of service.
3.
Ins ector Findin
s
Failure to comply with a Technical Specification Surveillance
requirement
to sample
SBGT charcoal filters after -720 hours of operation:
C.
On September
1,
1987, after the Division II emergency diesel
generator
(EDG) was
removed
from service,
Operations
Department
management
became
aware that the limit for accumulated
run time
hours
on train A of SBGT was exceeded.
The licensee
subsequently
determined
on September
2,
1987 that the total
number of run hours
on train. A was greater
than
1100.
The purpose for tracking accum-
ulated run hours is to ensure
a sample of charcoal filter adsorber
medium is drawn and chemically analyzed
in accordance
with TS sur-
vei llance requirement 4.6.5.3.c.,
(after 720, plus or minus
25%,
hours of operation).
The analysis
determines if the charcoal
still has its adsorbing properties for iodine.
The failure to
sample train
A charcoal filter medium after
720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation
is an apparent violation of T.S. 4.6.5.3.c
~
VIOLATION (50-410/87-32-01)
Failure to inform the Station Shift Supervisor
(SSS) of the potentially
SBGT trains:
On September
1,
1987, Operations
management
knew that train A of
SBGT had exceeded
720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of cumulative run time, but did not
believe that the total run time exceeded
900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />.
The licensee
was unable to provide
an adequate
reason for the belief.
In addition,
the cumulative
run time for the
B train was uncertain.
T.S. 6.8 and
Regulatory
Guide 1.33 require that the licensee
implement adminis-
trative procedures
for personnel
authorjties
and responsibilities
for
the safe operation of the plant.
Administrative Procedure
1.2,
section
4. 1 states
that under the general direction of the Superin-
tendent of Operations,
the SSS's
function includes
ensuring that the
plant is operated
safely and within the license
and Technical Specifi-
cations.
When the operability of the
SBGT trains
was first in question,
the
was not informed of. the status of the surveillance testing
requirement,
and therefore,
not afforded the opportunity to make
an
operability determination of the
SBGT system.
This is an apparent-
violation of T.S. 6.8 and procedure
VIOLATION (50-410/87-32-02)
From approximately mid-June,
1987 to September
1,
1987,
the licensee
did not know the total
run time on either train of SBGT.
This led
to two apparent violations of TS Limiting Condition for Operation
3.8.l.l.e:
Failure to recognize that that train A of SBGT was inoperable
when the Division II EDG was taken out of service:
When the Division II EDG was
removed
from service,
TS 3.8. 1. 1.e
required that the licensee verify that all systems that depend
on the remaining operable
EDG as
a source of emergency
power
are
also operable.
The
SSS verified that the surveillance tests
in
the surveillance
schedule
computer printout were up-to-date
and
that
no out-of-service
equipment entries
were
made in the
Equipment Status
Log for components
or systems that rely on
Division I
EDG for emergency
power.
In addition, the Division
II EDG outage
was
a preplanned
evolution
and the inspectors
could
find no evidence that
a detailed
management
review was conducted,
in advance,
to ensure
compliance with TS 3.8. 1. l.e.
In that the
licensee
did not verify that surveillance
testing
on the
A train
of SBGT was current,
the lic'ensee failed to comply with the
LCO
requirement of TS 3.8. 1. l.e.
This is an apparent violation of
T.S. 3.8. 1. 1.e.
VIOLATION (50-410/87-32-03)
Failure to be in
HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the
cumulative
run time
on the A SBGT train exceeded
the required
720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />
(+25%) in conjunction with the inoperability of the
Division II EDG.
Shortly after the Division II EDG was
removed
from service
on
September
1,
1987,
the licensee identified that the operabli lity
of train A of SBGT was in question.
Although a
TS interpreta-
tion was
made that
a
25% variance applies to the
720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />
surveillance
frequency,
the licensee did not verify that the plus
25% (900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />) limit was not exceeded.
TS 3.8. 1. l.e requires
that the unit be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
and
COLD
SHUTDOWN in the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if the operability of systems
dependent
on the operable
EDG are not verified.
The licensee
'did not take action within the allowable
TS action statement
to
shutdown the unit when the operability of the
SBGT system
came
into question.
This is an apparent violation of T.S.
3'. 1. l.e.
VIOLATION ( 50-410/87-32" 04)
d.
Failure to take prompt and effective action
on
a previously
identified item:
During the Operational
Readiness
Team inspection
conducted during
the first few weeks in June
1987,
a deficiency was noted in the
licencee's
program for tracking the accumulated
run hours
on the
two redundant
Standby
Gas Treatment
System trains.
During this
inspection, it was not clear by whom or how these
hours were being
tracked.
Prior to the
end of the team inspection,
the inspector
was
shown documentation
on
SBGT system
run hours
accumulated
through
May
1987.
0
Based
on this earlier inspection,
the licensee initiated changes
to
the
SBGT system operating
procedures.
The changes
to the procedures
incorporate
a log sheet to be completed
by the control
room operators
when
a train of SBGT has
been
operated.
These
procedure
changes
were
not incorporated
into the procedure until August 31,
1987.
In addi-
tion,
no interim action was taken
by the licensee
to ensure
a current
status of SBGT train run times was maintained.
10 CFR 50, Appendix
B, Criterion XVI, requires
that conditions adverse
to quality be
promptly identified and corrected.
NMPC Quality Assurance
Program
Topical Report for Nine Mile Point Nuclear Station Operations,
QATR-1, Revision 2; states
that program
and hardware conditions
adverse
to quality are identified promptly and corrected
as
soon
as
.
practical.
Failure to take prompt and appropriate corrective action
for this previously identified deficiency is an apparent violation
of 10 CFR, Appendix B, Criterion XVI, and the
QA program.
VIOLATION (50-410/87-32-05)
4. Exit M~eetin
At the conclusion of the inspection,
a meeting
was held with senior
corporate
and station
management
to discuss
the
scope
and findings of
this inspection.
Based
on the
NRC Region I review of this report
and discussions
held with
licensee
representatives, it was determined that this report does
not
contain Safeguards
or 10 CFR 2.790 information.
P
0