ML17055D344

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Notice of Violation from Insp on 870901-08.Violations Noted: Charcoal Adsorber of Standby Gas Treatment Sys (SBGT) Not Tested W/Correct Frequency & Emergency Diesel Generator 3 Removed from Svc While SBGT Inoperable
ML17055D344
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 11/05/1987
From: Kane W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17055D343 List:
References
50-410-87-32, EA-87-187, NUDOCS 8711090174
Download: ML17055D344 (4)


Text

NOTICE OF VIOLATION Niagara Mohawk Power Corporation Nine Mile Point, Unit 2 Docket No. 50-410 License No.

NPF-69 EA 87-187 During a NRC special safety inspection conducted on September 1-8,

1987, NRC inspectors reviewed the circumstances associated with violations identified by the licensee and reported to the NRC, including a violation of a technical specification limiting condition for operation.

In accordance with the "Gen-eral Statement of Policy and Procedure for.NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1987),

the violations are set forth below:

A.

Technical Specification LCO Action Statement 3.8. l. l.e requires that in operational condition 1 whenever either the Division I emergency diesel generator (EDG"1) or the Division II EDG (EDG 3) is inoperable, action shall be taken within two hours to verify that all systems, subsystems or trains that depend on the remaining operable EDG for emergency power are also operable; otherwise, the plant shall 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 /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, on September 1,

1987, in operational condition 1, EDG*3 wah removed from service and adequate action was not taken within two hours to verify operability of the A train of the Standby Gas Treatment (SBGT) System, which receives emergency power from EDG*1, and action was not taken to place that unit 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 within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

At the time, the A t~ain of the SBGT System was considered inoperable in that its charcoal adsorber had not been tested at the frequency set forth in Technical Specification Surveillance Requirement 4.6.5.3.c.

Technical Specification Surveillance Requirement 4.6.5.3.c requires that after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of, Standby Gas Treatment (SBGT) System operation, a sample of the charcoal adsorber be drawn and analyzed to verify it meets certain required criteria.

Technical Specification 4.0.2.a allows for a maximum allowable extension of 25/, of the specified frequency (1.25 N 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />

= 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />).

Contrary to the above, on September 2,

1987, train A of the SBGT System had operated for greater than 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> since its charcoal adsorber was last sampled and analyzed.

(720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> was exceeded on July 8, 1987 and 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> was exceeded on July 29, 1987)

The above examples constitute one Severity Level IV Violation.

(Supplement I) 71gPP0174

>gpp~iG pi i05

@gal PgClCH 0 pgR OFFICIAL RECORD COPY NOV/EA 87-187 0003.0.0 10/28/87

'e 10 CFR 30; Append1x 9, Criterion XVI, Correct1ve Action, requires that conditions adverse to quality be promptly identified and corrected.

"NMPC guality Assurance Topical Report, Section 16, Corrective Action, also requires for conditions adverse eo.quality, that corrective action be implemented in a timely manner.

Contrary Co ~he >bove, an identified condition adverse to quality was

-., not promptly corrected in that <he lack of meaningful tracking of'BGT system run times was identified during a June 1987 NRC team 1nspect1on, highlighted to N1agara Mohawk management during a June H, l987 inspection ex1t meeting," and documented in 'Inspection Report 30-420/87-16 dated August 3, 3.987; yet; corrective actions were not 1mplemented in a timely manner until after this deficiency contributed to a violat1on of a surveillance requirement and a Technical Specification LCO on September 1-2, l987.

'This is a Severity Level.ZV.Violation.

(Supplement I)

"'Pursuamt to-the provision of'10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required <o submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN:,.Document Control Desk, Washington, OC 20555, with a copy to the Regional Administrator, Region I, and a copy to the

'NRC "Senior Res'ideiit 'Inspe'ctor with'in 30 days of the date of the letter trans-

-'mi~ting'.<iiisNotice,.'. Tiiis~m.eply-.'.should.be"w1.earlyhnarkedlws".a "Reply to a

t'otice of Vfolation",and should 1nclude'or each violat1on: " (1) the reason for

- -the violation if admitted, (2) the correct steps that have been taken and the results ectiieved, (3) <iie corrective steps<hat will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an

. adequate reply is not received within the time specified in this Notice, an order may be 1ssued

<o show cause why the 1'1ceiise should not be modified, suspended, or revoked. or why sucti other action as may be proper should not be taken.

Considerat1on may M given to extending the response time for good cause shown.

FOR TRE NUCLEAR REGULATORY COMMISSION William F. Kane, Dir.ector Division,of Reactor. Projects

.Dated at King -of Prussia, Pennsylvania,

-t;hip /th day,of November 1987

'-",.DFFICIAL'ACCORD'"COPY

"'NOV/EA'87-'187 0004.0. 0 11/03/87

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