ML17055D923

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Insp Repts 50-220/88-15 & 50-410/88-15 on 880506-24.Apparent Violations Noted.Major Areas Inspected:Licensee Action on Previously Identified Items,Plant Tours,Safety Sys Walkdowns & Review of Unit 1 App R Compliance
ML17055D923
Person / Time
Site: Nine Mile Point  
Issue date: 06/02/1988
From: Jerrica Johnson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17055D922 List:
References
50-220-88-15, 50-410-88-15, NUDOCS 8806150466
Download: ML17055D923 (26)


See also: IR 05000220/1988015

Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report

No.

Docket No.

88-15/88-15

50-220/50-410

License

No.

DPR-63/NPF-69

Licensee:

Niagara

Mohawk Power Corporation

301 Plainfield Road

Syracuse,

New York

13212

Faci l ity:

Nine Mile Point, Units

1 and

2

Location:

Scriba,

New York

Dates:

May 6,

1988 through

May 24,

1988

Inspectors:

Approved by:

ate

W.A. Cook, Senior Resident

Inspector

W.L. Schmidt,

Resident

Inspector

A.G. Krasopoulos,

Resident

Inspector (Acting)

~/i,

f z

>:frp+

p'>>

.R. Johnson,

Chic

, Reactor

Projects

Section

2C,

DRP

INSPECTION

SUMMARY

Areas

~Ins ected:

Routine inspection

by the resident

inspectors

of station

activities including Unit

1 and

2 power operations,

licensee

action

on

previously identified items, plant tours,

safety

system walkdowns,

surveillance testing reviews,

maintenance

and modifications review, review of

Erosion-Corrosion

Program,

LER and Special

Reports

review and review of Unit

1

Appendix

R compliance.

This inspection

involved 137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br />

by the inspectors

which included

15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> s of backshift inspection

coverage

and

7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> s of

weekend inspection

coverage.

P

Results:

Inspector review of recent fire barrier penetration

concerns identified

an apparent

VIOLATION of 10 CFR 50 Appendix

R.

Inspector

review of this issue

is documented

in Section

10.

The licensee's

quality control measures

for the

installation of fire penetration

seals

was not available for inspector .review

prior to the conclusion of the inspection

and this item will remain

UNRESOLVED

ending review of the documentation

the licensee

has committed to provide the

nspectors

(also

see Section

10).

A review of the Unit

1 Erosion-Corrosion

rogram is documented

in Section

9.

8806150466

880607

PDR

ADOCK 05000220

O

DCD

DETAILS

Review of Plant Events

(71707,93702,71710)

UNIT

1

During this inspection period,

the unit remained

shutdown for the

1988

refueling outage.

The core

remained off-loaded pending final resolution

of numerous

Inservice Inspection

concerns identified prior to and during

the outage.

On May 10,

the licensee

determine'd that the Core Spray System

high p'oint

vent valve

( IV 40-30) did not stroke closed

in less

than the

30 seconds

Technical Specification

(TS) limit.

IV 40-30 is

a normally closed,

inside containment isolation valve.

Actual stroke time was measured

to

be 32.28

seconds.

This was discovered

as

a result of licensee

followup

to

INPO

SOER 86-2,

Inaccurate

Closed Position Indication

on Motor-Operated

Valves.

IV 40-30 was the only valve found to have

a stroke time in excess

of the

TS limit.

The inspector determined

from the licensee that the most

probable

cause of this excessive

closing time is improper placement of the

position indication limit switches.

The inspector will review licensee

actions to correct this problem in a subsequent

inspection.

On May 12,

the licensee

preliminari ly determined that the reactor coolant

system pressure

versus

temperature

curves in the

TS may be inaccurate.

Information provided to the

NRC staff by the licensee,

to date,

indicates

that the reactor vessel

irradiated

samples

may not be of the

same material

as the vessel beltline

~

The irradiated

samples

are

used to estimate

the

vessel

metal radiation embrittlement.

This information is then

used to

assist

in generating

revised reactor

vessel

heatup

and cooldown limits.

The licensee

is evaluating this concern

along with their engineering

consultant

MPR and General

Electric Co.

Evaluations

conducted,

to date,

indicate that the current

TS limits and operating

curves

are conservative.

The inspectors will continue to monitor licensee

progress

on this issue.

On May 12, the licensee

concluded that there is a significant discrepancy

between

the

FSAR and another

licensee classification,

namely,

a

1983

"Appendix

B Determination" concerning whether the emergency battery

motor-generator

set battery chargers

(161 and

171) are safety or

non-safety related.

The

FSAR considers

the battery chargers

to be vital

(safety related) to the restoration of emergency lighting and

DC power

from the emergency

diesel

generators

within 130 seconds

following the

loss of offsite power (LOP).

Contrary to this, the

1983 "Appendix

B

Determination" concluded that the battery chargers

were non-safety

related

because

the batteries

have sufficient capacity to supply

emergency lighting and

DC loads following a

LOP.

The licensee

has considered

the

161 and

171 battery chargers

non-safety

related

since

1983

and all maintenance

and

spare

parts were treated

accordingly.

As of the

end of this inspection period,

the licensee

had

not resolved this concern.

The .inspectors will review this item in a

subsequent

inspection period.

1.2

UNIT 2

During this inspection period the unit was in

a planned

maintenance

outage

which began

on April 29.

The outage

was concluded

and the reactor

was placed in the

STARTUP Mode on

May 22,

and taken critical at 11:46

p.m.

on the

same

day.

a.

On May 10, the

Emergency

Response

Facility (ERF) computer

was taken out

of service for planned modifications.

The licensee notified the

Headquarters

Duty Officer of this

eve~,

via the

ENS because

the licensee

considers

the

ERF computer function essential

to emergency

response

assessment.

By licensee

standards,

the

ERF computer out of service

constitutes

a major loss of emergency

assessment

capability.

A similar

notification was

made

on

May 24 when the Liquid Radwaste

Processing

computer

was out of service

due to

a hardware

problem.

The

ERF computer

function is part of the larger Liquid Radwaste

Processing

computer

system.

b.

The inspector discussed

the reportability of this event with licensee

management.

The licensee

stated that the practice of reporting the

ERF

computer

being out of service is

a carryover from Unit 1.-

Because

of the

redundancy

in emergency

assessment

capability available at Unit 2 via the

process

computer

and telephone

communications,

the licensee

is

reconsidering

the reportabi lity of the

ERF computer not being available

for service.

The inspector will review the licensee's

final decision.

On May 18, four (10') emergency

response

sirens

were out of service

and

the licensee notified the

NRC via the

ENS of the degraded

emergency

response

notification system condition.

The licensee

had planned

an

outage of three sirens

due to the necessity

for work on Niagara

Mohawk

transmission

lines.

However, the drawings that the licensee

referred to

were inaccurate

and

a fourth siren

was deenergized

along with the three

sirens

planned.

The inspector determined

that the licensee

is revi-sing and verifying all

emergency notification system electrical

drawings to prevent recurrence.

The inspector will review licensee corrective actions

when completed.

The inspectors

reviewed licensee

preparations

for restart of Unit 2 and

verified selected

prerequisites.

No discrepancies

were noted,

d.

On May 23, with the reactor at approximately three percent

power and 400

psig, the

A recirculation

pump outer seal

pressure

went to zero (0) psig

and the high pump seal

leakage

alarm sounded.

A reactor

shutdown

was

commenced at 9:50 a.m.

and the

A recirculation

pump was secured

and

isolated

by 10:02 a.m.

At 10: 17 a.m.

the licensee

declared

an

UNUSUAL

EVENT following an increase

in drywell floor drain leakage

in excess

of

the

TS limit of five (5)

gpm.

Leakage

was below the

TS limit

approximately

one half hour later

and the licensee

secured

from the

UNUSUAL EVENT.

The reactor

was placed in HOT

SHUTDOWN by 2:34 p.m.

The inspectors

reviewed licensee

actions in response

to this event

and

'ound

no discrepancies.

The inspectors will review the licensee's

evaluation of the seal failure in

a subsequent

inspection period.

The inspectors verified that the licensee

made the appropriate

10 CFR 50.72 notifications via the

ENS for the events

discussed

above.

2.1

~Foliowu

on Previous Identified Items (71707,82203)

Unit

1

(Closed)

Inspector

Followup Item (50-220/83-04-01):

Complete installation

of two additional

emergency notification sirens

as part of the system

enhancement

program.

The inspector verified that the licensee installed

two additional sirens,

one in Oswego

and one South of Ninetto,

as

required.

This item is closed.

Plant

~ins ection Tours (71707,71710,62703,64704,71881)

During this reporting period,

the inspectors

made tours of the Unit

1 and

2 control

rooms

and accessible

plant areas

to monitor station activities

and to make

an independent

assessment

of equipment status,

radiological

conditions,

safety

and adherence

to regulatory requirements.

The

following were observed:

Unit

1

No discrepancies

were

noted'.2

Unit 2

While conducting

a tour of the Reactor Building, the inspector identified

a few minor housekeeping

items which were brought to the attention of the

control

room operators.

The inspector

subsequently

verified that these

items were corrected.

The inspector also noted the imprope'r installation

of SILTEHP protective wrap around the

3A squib valve electrical

cable.

This item was brought to the attention of the Fire Protection Supervisor

who took action to correct this discrepancy.

The protective wrap is

installed

on one squib valve cable

because

of the requirement for

divisional separation.

The Fire Protection

Supervisor also initiated a

maintenance

procedure

revision to ensure

the protective wrap is properly

restored after

squib valve maintenance.

No violations were identified.

Surveillance

Review (61726)

The inspectors

observed

portions of the surveillance

testing 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.

4.1

Unit 1

Nl-ISP-Q-68, Reactor Building-to-Torus Vacuum Relief Valve

Instrumentation

Testing,

performed

on May 12,

1988.

During this inspection

period the licensee

conducted

the monthly

operability surveillance

on the

102 emergency diesel

generator.

During this surveillance test,

the engine tripped

on low lube oil

pressure.

The pressure

sensor is located

on the side of the crank-

case.

The licensee

has investigated

the problem

and believes

that the pressure

sensing

diaphragm

was impinged

upon

by lube oil

spraying

from the crankcase

internal

lube oil relief valve.

The

licensee

plans to inspect

the

103 diesel for the

same condition.

The inspectors will review licensee

findings in a subsequent

report.

4.2

Unit 2

N2-FSP-FPG-R002,

Halon System Nozzle Flow Test,

performed

on May 13,

1988.

No violations were identified.

5.

Maintenance

and Modifications Review (62703,37700,37701)

The inspector

observed

portions of various safety-related

maintenance

and

modification activities to determine that redundant

components

were

operable,

that these activities did not violate the limiting conditions

for operation,

that required administrative

approvals

and tagouts

were

obtained prior to initiating the work, that approved

procedures

were

used

or the activity was within the "skills of the trade", that appropriate

radiological controls were implemented,

that ignition/fire prevention

controls were properly implemented,

and that equipment

was properly

tested prior to returning it to service.

5.1

Unit

1

The inspectors

reviewed various aspects

of the

Emergency Battery ll and

12 replacement.

The inspector s observed that this modification was well

planned

and executed.

No discrepancies

were noted.

5.2

Unit 2

Prior to restart of the unit on May 22, the inspectors. reviewed licensee

startup preparations

and prerequisites.

One item reviewed

by the

inspectors

was the Operations'taff modification notebook.

This

notebook

was required reading for the entire Operations staff and

included

a

summary of each modification completed during the planned

outage.

The inspector

determined that the notebook adequately

summarized

the significant outage modifications,

provided appropriate modification

5.3

details

where necessary,

and was reviewed by shift personnel

prior to

unit startup.

The inspector

found no discrepancies.

Review of Maintenance

Self-Assessment

- Unit

1 (90713)

On May 20, the inspector held

a discussion with licensee

representatives

to review their Nine Mile Point Unit

1 Maintenance

Self-Assessment

conducted

in 1987.

This self-assessment

was

an Institute of Nuclear

Power Operations

( INPO) initiative designed

to accelerate

maintenance

performance

improvements

in the nuclear industry.

The self-assessment

conducted

by Niagara

Mohawk personnel

is the first phase of the assessment.

The second

phase is

a special on-site maintenance

review and assessment

by

INPO representatives

(the

second

phase

has not been

conducted,

to date).

A general

overview of the self-assessment

was presented

to the i nspector.

The licensee

indicated

the assessment

was useful

in identifying both

specific

and program weaknesses.

The identified problems will be tracked

by the licensee

and corrective action taken

as appropriate.

The licensee

stated

many

new initiatives,

such

as the materials

issue

and control

program enhancements,

have already begun'pecific

self-assessment

findings were not discussed

at this meeting.

The inspector will follow

selected

items

and discuss their progress with the licensee

in a

subsequent

irspection period.

The inspector

had

no further questions.

~Ph sical ~Securit

Review (71709)

The inspector

made observations

to verify that selected

aspects

of the

station physical security program were in accordance

with regulatory

requirements,

physical security plan

and approved

procedures.

The inspector walked

down the perimeter

fence to verify that there

were

no obstructions

in the vicinity of the fence or other fence

impairments

that could aid the unauthorized

entry of an individual into the plant.

No unacceptable

conditions were

identified'eview

of Licensee

Event

~Re orts ~LERs

and ~Secial

~Re orts

~SRs

(90712,92700),

These

LERs and

SRs submitted to the

NRC were reviewed to determine

whether the details

were clearly reported,

the cause(s)

properly

identified and the corrective actions appropriate.

The inspectors

also

determined

whether the assessment

of potential

safety

consequences

had

been properly evaluated,

whether generic implications were indicated,

whether the event warranted

on site follow-up, whether the reporting

requirements

of 10 CFR 50.72 were applicable,

and whether the

requirements

of 10 CFR 50.73

had been properly met.

(Note: the dates

indicated are the event dates)

0

7.1

Unit

1

a.

The following reports

were reviewed

and found to be satisfactory:.

LER 88-10,

4/19/88 - Failure to submit

a Special

Report within

thirty days.

SR, 5/6/88 - Fire'etection

and suppression

systems

inoperable

for greater

than fourteen days.

b.

For the following report,

the licensee

has committed to issue

a

supplemental

report.

This report will be reviewed in a subsequent

inspection period:

LER 88-12,

4/18/88 - Failure to hydrostatically test

a portion

of the

ASME Class

1 Pressure

Boundary due to procedural

error.

7.2

Unit 2

a.

The following LERs were reviewed

and found to be satisfactory:

LER 87-74,

Rev.

1, 12/19/87

Inoperable fire barrier due to

breached floor plug.

LER 88-20, 4/7/88,

Secondary

Containment isolation

and

Standby

Gas Treatment

automatic start

due to spiking on normal

Reactor Building ventilation radiation monitor .

8.

Review of Feedwater Transient

~Re ort Unit

1 (90712)

On Oecember

19,

1987, Unit 1 was operating at

98% power when vibration in

the Feedwater

System

(FWS) piping resulted in the control

room operators

scramming

the reactor.

Subsequent

investigation of this event identified

the

FWS piping vibrations to be the result of flow oscillation caused

by

the

stem

and plug separation

of the

13A feedwater control valve.

Analysis of the

13A control valve failure, resultant

FWS transient

and

FWS piping and support

damages

are

summarized

in

a licensee

report to the

NRC dated

March 1,

1988 (NMP1L0229).

The inspector

reviewed the contents

of the March 1,

1988 report and found

no significant discrepancies

from the information independently

gathered

and assessed

by the

NRC staff.

The inspector

found the report to be

well-organized,

thorough

and concise.

Licensee. corrective

actions

outlined in the report appear to be appropriate.

The inspector specifically reviewed the following report attributes:

Scope of

FWS piping inspections,

including drywell piping

examinations.

Visual inspection

adequacy

and examination results.

Loose parts safety analysis

(pump impeller blade piece).

Sequence

of events,

including shaft driven feedwater

pump

impeller'ailure.

FWS repairs

and prerequisites

for unit restart.

Plant

systems

response

to

FWS transient,

including fire detection

system

response.

Correlation of this

FWS transient/failure to previous

FWS problems.

Operating/maintenance

history of feedwater control valves.

Analysis of No.

11 feedwater

pump suction piping corrosion.

Examination results of No.

12 feedwater

pump suction piping.

Results of feedwater control valves

No

~

11 and

12 internals

inspection.

Metallurgical analysis of stem-to-di sc failure.

FWS transient analysis results.

Although not specifically addressed

in the licensee's

corrective action

for this transient,

the inspector determined that in addition to the

improved stem-to-disc

weld design,

the licensee

is evaluating

new

feedwater control valve designs.

New designs

are being entertained

to

address

the valve plug and

cage

wear concerns

which contributed to the

valve failure.

Additional inspector observations

and findings have

been

documented

in

Region I Inspection

Report 50-220/88-02.

The inspector

had

no further

questions.

Review of Erosion-Corrosion

~Pro

ram

Unit

1 (61726)

On May 20, the inspectors

met with licensee

Engineering representatives

to discuss

the Carbon Steel

and

Low Alloy Piping System Erosion-Corrosion

Review Program for Unit

1 and its implementation during the current

1988

Refueling Outage.

The purpose of the program is to evaluate

the

performance of carbon steel

and low alloy piping systems

which are not

reviewed per the Inservice Inspection

Program,

but which are susceptible

to deterioration

caused

by high-energy single

and two-phase fluid

erosion-corrosion.

The program

was developed

as

a result of recent

industry problems,

NUMiARC initiatives and interest

by the

NRC staff in

programs established

by the nuclear utilities to address

this potential

high energy piping system failure mechanism.

(Reference,NRC Bulletin No.

87-01).

The inspector

determined that the Unit

1 program was formally implemented

for the first time during the current refueling outage.

Some feedwater

system piping wall thickness

data

was taken during earlier refueling

outages;

however, this information was not formally evaluated

and trended

in the fashion the

new program

has established.

The licensee

has

identified specific examination points in both single-phase

and two-phase

flow systems (ie. feedwater,

feedwater heating,

extraction

steam,

steam

drains, etc.) which will be baselined

during the

1988 outage

and

periodically examined

in the future.

Piping examinations

are currently

being performed

independent

of the ISI staff efforts by contractors with

direct oversight

by Niagara

Mohawk engineers.

-9"

The inspector

found the program to be well-structured

and adequately

detailed to ensure

consistent

examination results.

The inspector

questioned

the licensee

representatives

on the mechanisms

used to elevate

identified problems or potential piping degradation

to station

management

for resolution prior to unit restart.

The licensee

indicated that the

Erosion-Corrosion

Program does

have provisions for interim status

reports

to identify any significant potential

problems to management,

but no

specific guidance is provided in the program to document

and track

nonconformances

identified during the field examinations

or the

Engineering

review process.

This observation

was discussed

with station

management

who indicate that the guidance to track Erosion-Corrosion

Program identified nonconformances

would be strengthened

to ensure

overall

program results

are properly assessed

by station

management prior

to unit restart.

The inspector

had

no further questions.

10.

Fire Barrier Penetration

Review

Unit 1 (64704)

On March 26,

1988, while performing

a modification to replace

DC cables

from the Battery Board

Rooms

11 and

12, the licensee

determined that

some

of the existing fire barriers

were inoperable.

The inoperable fire

barriers (floors of the battery

rooms) were found to contain penetrations

sealed with unqualified material.

The licensee

documented this event

Licensee

Event Report

( LER) 88-09 and committed to review all Technical

Specification

(TS) fire barriers for adequacy

and repai r all non-functional

penetrations

identified prior to restart.

The repair work and fire barrier

review began prior to the issuance

of the

LER.

In addition,

compensatory

fire watches,

as specified

in the TS, were established

until all fire

barriers

were reexamined.

The licensee's

evaluation of the inoperable barriers

concluded that this

problem was caused

by an inadequate

original (1983) review of the barriers

by the contractor hired to survey the barrier penetrations.

This contractor,

because

of inadequate

guidance

from Niagara

Mohawk, failed to identify and

list all of the penetrations

that were in the barriers.

Additionally,

this error was perpetuated

by an inadequate

surveillance

procedure.

The

surveillance

procedure directed the individuals performing the surveillance

to inspect the operability of a specific penetration

rather than the

operability of the barrier

as

a whole.

Thus,

the procedure

had

no provisions

to inspect the operability of the entire barrier,

only failures of penet-

rations listed in the procedure.

To prevent recurrence

the licensee is

updating the procedure

to include all the penetrations

that the original

survey failed to identify and is revising the surveillance

method

so that

the overall fire barrier adequacy

is inspected

rather than the operability

of a specific penetration.

To assure

that the penetration

surveillance list is accurate,

the

licensee,

as committed to in the

LER, is resurveying all of the

TS

barriers

and penetrations.

As of the end of this inspection period,

0

-10-

approximately

20% of the fire barrier reexaminations

have

been

completed.

Of the

1325 penetrations

inspected,

68 were found to be non-functional.

A penetration

is considered

to be non-functional

by the licensee if its

seal

has

been

damaged

or if it has

been

sealed with materials

or methods

that have not been fire tested.

The fire tests

provide assurance

that

the installed

seal configuration will not degrade

during

a fire.

The inspectors

observed that the inoperable

penetrations

were in fire

barriers that separate

safe

shutdown

components.

The barriers

in

particular are the Battery

Room floors, the Cable Spreading

Room floor

and the Auxiliary Control

Room floor.

A design basis fire in any of

these fire areas

has the potential of propagating

to the adjacent fire

areas

via the degraded

penetrations

and could damage

the control

room and

both remote

shutdown

panels

(RSPs).

The

RSPs

were installed to assure

the ability to safely

shutdown

the

plant in the event of a fire in the control

room.

Manning of the

RSPs

is required

by Special

Operating

Procedure

for Control

Room Evacuation,

N1-SOP-9.

This procedure

requires that the operators trip the reactor

and initiate and control

emergency

cooling at the

RSP if that could not

be accomplished

in the Control

Room.

The rate of reactor

cooldown is

regulated

from these

panels

so that it does

not exceed

100~ F/hr.

The possibility that

a design basis fire has the potential of damaging

both

RSPs

and the control

room is an apparent violation of 10 CFR 50,

Appendix

R,Section III.G.

Section III.G requires that fire protection

features,

such

as fire barriers,

be provided to protect

safe

shutdown

systems

and components.

These

features

must

be capable of limiting the

fire damage

so that at least

one safe

shutdown train remains

free of fire

damage.

APPARENT VIOLATION (50-220/88-15-01)

.

Detailed review of this concern

by the inspectors

determined that

a fire

which could damage

the Control

Room and both

RSPs is not

a highly

credible event.

This determination

was based

on several

mitigating

factors.

The areas

where the degraded

penetrations

were'found were

protected with automatic

suppression

and detection

systems.

The

combustible

loading is composed

mostly of cable insulation with the

heavier concentrations

in the auxiliary control

room and cable

spreading

room.

Each of these

areas

is protected with two suppression

systems.

The auxiliary control

room is protected with a total flooding halon

suppression

system activated automatically

and

a total flooding C02

system that requires

manual activation.

The cable

spreading

room is

protected with an automatic

C02 total flooding system

and

a sprinkler

system.

The inspector verified these

systems

were operable.

Another

mitigating factor is that although the penetrations

have

been declared

inoperable

they do contain seals

which provide

a degree of protection

and

resistance

to the spread of fires.

The licensee

has stated that even if this event occurred (ie.

a design

basis fire) the safe

shutdown

systems

would still work and provide

shutdown capability.

In

a design basis fire, one function that could be

lost is the condensate

return flow control

from the emergency

condensers

to the reactor.

This system regulates

the cooldown rate of the reactor.

Also, the capability to monitor the reactor pressure

and level

from .the

RSP could be lost.

However,

these

parameters

can

be monitored

from other

locations

in the plant.

In addition,

the starting

power source for the

emergency diesels

could

be lost.

However,

the diesels

are not relied

upon for the

HOT

SHUTDOWN phase

and the licensee

has procedures

and

materials,

in place,

to make the required repairs.

These

procedures

and

repair methods

were reviewed

by

NRC inspectors

during

a previous

inspection

and were found acceptable

(reference

NRC Region I Inspection

Report 50-220/85-01).

In addition to the degraded barriers,

the

new survey conducted

by the

licensee

has identified

a number of minor discrepancies

that are being

addressed

and corrected.

These discrepancies

include cosmetic

damage

to

the seals,

the presence

of duct seal material

on top of the fire seal

and

penetrations

sealed

to

a depth slightly less

than that specified

in the

drawings,

but still adequately

sealed

to qualify as

a three

hour barrier.

The licensee,

as

a conservative

measure,

declared

these

penetrations

inoperable

and established

compensatory

measures

prior to dispositioning

the discrepancies.

The licensee's

disposition of these

concerns

involves

the review of the discrepancy

by

a Fire Protection

Engineer,

who makes

a

determination

of the adequacy

of the seal.

The

NRC inspectors

reviewed the evaluation

methods

used

by the licensee

to verify that

each identified discrepancy

is properly dispositioned.

During this review the inspectors

raised the concern that the licensee'

Engineering staff was declaring

untested

penetrations

operable

by

evaluations

performed after

a nonconforming condition was identified.

Unless

the evaluation

was in place at the time the non-conforming

condition is identified, the penetration

should

be declared

inoperable

and reported to

NRC accordingly.

The inspectors

also requested

to review installation records of the

penetration

seals

to verify that the seals

were installed

as

per

the

design details.

This information was not available for review by the

inspectors

by the end of the inspection,

therefore this item will

remain unresolved

pending

a review of the records

being gathered

by the

licensee.

UNRESOLVED ITEM (50-220/88-15-02)

10.1

~Sommar

of ~Findin

a

The resurvey of the fire barriers,

to date,

has identified 68 non-functional

fire barrier penetrations.

This survey also identified a number of minor

deficiencies

on the penetration

seals that require repair.

These findings

-12-

are

a cause for concern

because

the barriers

have

been repeatedly

(and

'rogrammatically)

inspected

and these

degradations

were not identified.

The degraded

barriers

represent

an apparent violation of the requirements

of 10 CFR 50, Appendix

R, which stipulate that fire protection features

such

as fire barriers shall

be provided to assure that at least

one shut-

down train remains free of fire damage.

At the conclusion of the inspection

the licensee

committed to provide the

NRC with assurance

that all penetration

installations

conform to the

design details.

Unit

1 Restart

Plan

~Meetin

(30702)

Following the

SALP Management

Meeting held at the Nuclear Training Center

on May 10,

1988,

the

NRC (Region I and

NRR) staff held

a meeting with the

licensee

(corporate

and station

management

personnel)

to discuss their

plans for restart of Unit l.

A tentative list of certain discussion

topics

for the meeting

was communicated

to the licensee

by

NRC letter dated

May

4,

1988.

These topics were reviewed

by the licensee

and

a status

was

provided during the meeting.

The licensee

plans to meet with the

NRC staff

three

weeks prior to Unit

1 startup to discuss

additional details of

management

controls of all items affecting unit startup.

Currently an

interim meeting is scheduled

for June

21,

1988.

~Meetin

With Local Of'icial (94600)

On May 13,

1988 the Nine Mile Point and FitzPatrick resident

inspectors

met with the Mayor of the City of Oswego.

The purpose of the meeting

was

to familiarize the Mayor with the role of the

NRC resident

inspectors.

Topics discussed

included resident

inspector

coverage of routine

and

off-normal plant events,

NRC and licensee

Emergency

Plans,

the

NRC

Inspection

Program

and the Systematic

Assessment

of Licensee

Performance

process.

No additional

concerns

were identified during this meeting.

Assurance

of ~ua'lit

Identification of. the Unit

1 reactor coolant

system pressure,

versus

temperature

curve

and battery charger

problems represent

good detailed

engineering

reviews

by the licensee's

staff.

However, the errors which

led to these

concerns

appear

to be additional

examples of past

insufficient staff oversight of contractor activities.

The maintenance

self-assessment

appears

to be

a fruitful initiative and warrants

management

attention

and follow-through.

The Unit

1 feedwater transient

followup efforts and

summary report are of good detail

and thorough.

The

erosion-corrosion

program appears

to be well-structured

and properly

implemented.

As noted in Section

10-; 1, the fire barrier penetration

problems

are of serious

concern

from a program implementation

standpoint.

Licensee

response

to these

concerns

appear

to be appropriate,

to date.

Exit ~Meetin

s (30703)

At periodic intervals

and at the conclusion of the inspection,

meetings

were held with senior 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

-13-

determined that this report does not contain 'Safeguards

or 10 CFR 2.790

information.