ML17056A323
| ML17056A323 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/22/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A324 | List: |
| References | |
| EA-89-070, EA-89-70, NUDOCS 8910040232 | |
| Download: ML17056A323 (10) | |
Text
NOTICE OF VIOLATION Niagara Mohawk Power Corporation Nine Mile Point Unit 1
Docket No. 50-220 License No.
DPR-63 EA 89-70 During several NRC'nspections conducted between February 22, 1988 and February 17,
- 1989, as well as 'during an investigation by the NRC Office of Investigations, several violatjons of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (Enforcement Policy) ( 1988),
the particular vi.olations set forth below:
I I.
VIOLATIONS ASSOCIATED WITH THE LICENSED OPERATOR REQUALIFICATION PROGRAM A.
10 CFR 50.54 (i-1) requires that the fac'ility licensee
'have in
'ffect a requalification program for licensed operators (operators or 'senior operators) that meets, at a minimum, the requirements of 10 CFR 55.59(c).
10 CFR 55.59('c)(l) requires that the requalification program,.
as devel,oped by the licensee and 'approved by the
- NRC, be conducted for a continuous period not. to exceed two years.
Contrary to the above, for the requalification program cycle of February 1986 to February 1988, portions of requalification training were not completed by thirty-nine (39) licensed operators.:
For
- example, classroom training, reading assignments and/or simulator training were not completed fo'r those individuals.
II B.
Technical Specification 6.8. 1, Procedures,
- requires, in part, that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix A of Reg'ulatory Guide 1.33, Quality-
.Assurance Program Requirements-Operations.
NRC Regulatory Guide 1.33, Appendix A, requires written procedures to establish various administrative controls.
Facility Procedure NTP-11, Licensed Operator Retraining and Continuing Training, Revision 4 (effective September ll, 1987), requires that each license holder shall fully complete all required training for each requalification cycle, and that the station superintendent shall be notified for all cases where required training was riot completed prior to the end of the requalification cycle.
Contrary to the above, the station superintendent was not notified of approximately 50% of the training that was not completed prior to the end of the February i986 to February 1988 requalification cycle.
C.
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
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NOTICE OF VIOLATION Contrary to the above, a condition adverse to quality was not
'promptly corrected.
Specifically, for the requalification cycle between February 1986 and February
- 1988, the requalification program was not properly implemented and documented.
This condition adverse to quality was, in part, identified during two Safety Review and Audit Board (SRAB) audits of facility licensee training programs conducted in March 1986 and April 1987.
The audits identified deficiencies in the documentation of training.
- However, measures did not exist to assure that this condition adverse to quality was promptly corrected by the end of the requalification cycle.
II.
VIOLATIONS OF OTHER REGULATORY REQUIREMENTS Technical Specification 6.8. 1, Procedures,
- requires, in part, that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements-Operations.
NRC Regulatory Guide 1.33, Appendix A, requires written procedures for combating emergencies and other significant events, such as' loss of coolant accident.
Contrary to the above, procedures in effect as of the October 7, 1988 NRC inspection, and written pursuant to Technical Specification 6.8. 1, were not adequate for operation of the core spray
- system, as evidenced by the following examples:
1.
Emergency Operating Procedure EOP-4, "Primary Containment Control," Revision 0, did not contain adequate instructions for maintaining'or'us water level within the normal operating band under post-LOCA Conditions.
The procedure was inadequate in that the means for restoring torus water level following a
LOCA would require the securing of one loop of the core spray system which is unacceptable in a LOCA condition where both core spray loops could be required.
2.
Procedure OP-2, Core Spray
- System, Section 1.2.4, Revision 17, did not adequately describe the actions to be taken by the operator in case annunciator K2-4-7 "Core Spray Pumps Discharge Pressure High" is activated.
The procedure was inadequate in that it directs operators to secure both sets of core spray and topping pumps in the affected loop, but provides no directions to reinitiate the system once reactor pressure decreases below 365 psig and'he isolation valves are opened to allow vessel injection.
B.
10 CFR Part 50, Appendix B, Criteria III, states, in part, that measures shall be established to assure that applicable regulatory requirements and design basis are correctly,translated into specifications,
- drawings, procedures, and instructions.
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NOTICE OF VIOLATION Contrary to the above, on several occasions, design basis information was not properly translated into operating, test, and safety system instructions, as evidenced by the following examples:
1.
In 1'978, the impellers for the two, motor-driven feedwater pumps were replaced and the licensee's design process did not adequately translate the effects of this change into appropriate specifications,
- drawings, procedures, and instructions.
Speci-fically the licensee's design process identified that the new impellers provided 200 feet less head at rated flow and 500 feet less head at maximum flow, but as of October, 1988 the design pump head curves were not updated to account for the new impeller performance characteristics.
2.
In 1984, changes were made to the Technical Specifications which raised the setpoint for the reactor vessel low-low-low level alarm.
As of October
- 1988, two design documents (Drawing Number C-35843-C, Rev.
1, dated July 24, 1985 and Drawing Number C-18015-C, Rev.
87-039-C1, dated November 3, 1987) were not updated to reflect this change.
3.
In 1972, the power supplies for the reactor feedwater auxiliary oil',pumps were moved from Motor Control Center
As of October
- 1988, the Electrical
System Description
document was not revised to show this change in power supply.
4.
In 1971, the original design of the core spray system (which had all-safety-related 4160 VAC motors being stripped from Power Boards 102 and 103) was modified to have one core spray pump remain on each bus following an" undervoltage condition.
As of October 1988, Surveillance Test Procedure (NI-ST-R2) was not modified to reflect the change.
5.
Loss of Coolant Accident (LOCA) analysis, conducted between 1975 and 1987 pursuant to the requirements of 10 CFR 50, Appendix K
(ECCS Evaluation Models), failed to translate into Technical Specifications for core spray system(s) assumptions that flow was available from two core spray loops.
C.
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures shall be established to assure that conditions adverse to quality such as deficiencies and nonconformances are promptly identified a'nd corrected.
Contrary to the above, in September
- 1987, the licensee determined that continued operation of the plant with only one core spray loop operable, although authorized for seven days by Technical Specification LCO 3. 1.4.d, would result in operation of the plant in an unanalyzed condition;
- however, these deficiencies were not corrected until August 23, 1988.
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NOTICE OF VIOLATION "D ~ 1 10 CFR 50.72(b)(2)(iii) requires that the licensee notify the NRC
'as soon as practical and in all cases.within four hours of any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to remove residual heat, control the release of radioactive material, or mitigate the consequences of an accident.
D.2 Contrary to the above, on August 23,
- 1988, the licensee determined that the Technical Specification Li'miting Condition for Operation allowing continued plant operation for up to seven days with one core spray loop inoperable was a condition that could have prevented the fulfillment o'f the safety function of the core spray system to
=
mitigate the consequences of an accident since the analysis to demonstrate compliance with 10 CFR Part 50, Appendix K, assumed that two core spray loops were always available in a
LOCA.
The licensee did not notify the NRC Operations Center of thi s condition unti l September 16, 1988.
10 CFR 50.72(b)(1)(ii)(A) and (B), respectively, require that the-licensee shall notify the NRC Operations Center within one hour of any event or condition during.operation that results in the nuclear" power plant being in an unanalyzed condition that significantly compromises
- safety, or in a condition during operation that results in the nuclear power plant being outside the design basis of the plant.
Contrary to the above, on December 9,
1987 and Hay 7,
- 1988, Load Flow/Voltage Drop calculations performed by the licensee during the design phase of a modification to the 125 volt DC Distribution System
,.identified that the system was outside its design basis during operation because of low voltage provided by the system to operate safety related loads of selected panelboards.
The NRC Operations Center was not'otified of this condition until November 18, 1988.
E.
Technical Specification
- 4. 2
~ 6. b (Inservi ce Testing) requires, in part, that Inservice Testing (IST) of guality Group A, B and C pumps and valves shall be performed in accordance with the requirements of Section XI of the ASME Boiler and Pressure Vessel Code as required by 10 CFR 50.55a(g).
Section XI ot the ASME Boiler and Pressure Vessel Code requires periodic testing to verify pump performance and valve stroke time.
Contrary to the. above, as of October 26, 1988, deficiencies were identified in the Inservice Testing Program's
( IST) first ten year interval which runs from December 1979 through December 1989.
These deficiencies resulted in not all guality Group A',
B and C pumps and valves being incorporated into the first ten year interval IST Program, and, therefore, not.- being periodically tested.
10 CFR 50.71(e). requires, in part, that the licensee bring the original FSAR up to date within 24 months of July 22, 1980, to assure OFFICIAL RECORD COPY CP PKG NNP EA 89-70 9/20 0010.0.0 09/20/89
NOTICE OF VIOLATION that the material contained in the FSAR contains the latest material developed.
Contrary to the above, as of October 1988, the FSAR had not been brought up to date to reflect changes to the facility as described in the original FSAR.
Specifica'lly, FSAR Figure IX-1 and associated text were not revised to reflect (1) a 1971 change to the core spray system load stripping sequence, and (2) a 1972 change to the power supplies for the reactor feedwater auxiliary oil pumps.
Violations I and II are categorized in the aggregate as a Severity Level III problem.
(Supplement I)
\\
Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, w'ithin 30 days of the date of this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each, alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results
- achieved, (4) the corrective steps that will be taken i:o avoid further violations, and (5) 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 issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
FOR THE NUCLEAR REGULATORY COMMISSION Dated at King of Prussia, Pennsylvania
'this QP day of September 1989 Origlna1 Skinned By Ptr,1,-.,H T. HUBS~L William T. Russell Regional Administrator OFFICIAL RECORD COPY CP PKG NMP EA 89-70 9/20 " 0011.0.0 09/20/89